INC. (RVSB”), by their attorney, and sue the Defendants, MARK BELLISSIMO (”Bellissimo”),
EQUESTRIAN SHOW HOLDINGS, LLC (“ESH”), EQUESTRIAN SPORT PRODUCTIONS,
LLC (“ESP”), and WELLINGTON EQUESTRIAN PARTNERS, LLC (“WEP”) and allege the
following, pleadings their claims in the alternative:
of Plaintiff, RVSB.
2. RVSB is a Florida corporation located at 1955 South S.R. 7, Ft. Lauderdale,
Broward County Florida.
3. At all times material RVSB was in the business of selling, servicing, and renting
Recreational Vehicles (“RVs”).
5. At all times material BELLISSIMO was the managing member of Defendants,
EQUESTRIAN SHOW HOLDINGS, LLC (“ESH”), EQUESTRIAN SPORT PRODUCTIONS,
LLC (“ESP”), and WELLINGTON EQUESTRIAN PARTNERS, LLC (“N’EP”).
6. At all times material BELLISSIMO was acting both in an individual capacity and in
the course and scope of his employment as the managing member of the Defendants, ESH, ESP and
7. At all times material ESH was a Florida corporation located at 14440 Pierson Road,
Wellington, Florida 33414-7673.
8. At all times material ESP was a Florida corporation located at 14440 Pierson Road,
Wellington, Palm Beach County, Florida 33414-7673.
9. At all times material WEP was a Florida corporation located at 14440 Pierson Road,
10. At all times material Defendant, ESH, held the license issued by the United States
Equestrian Federation (“USEF”), the governing body of American equestrian events, to operate the
Winter Equestrim1 Festival.
11. At all times material Defendants, ESH, ESP and WEP were vicariously responsible
for the actions of BELLISSIMO, as set forth below, who was acting both individually and in the
course and in the scope of his employment with the Defendant corporations.
12. The Winter Equestrian Festival is the premier horses how and equestrian competition
in the United States and is located in Wellington, Palm Beach County, Florida.
and regulations at the WEF and for protecting the rights of all USEF members at the Winter
Equestrian Festival including STETLER.
14. Defendant, ESP, at all times material, was the competition manager of the Winter
Equestrian Festival and was responsible for upholding and enforcing USEF mles and regulations
at the Winter Equestrian Festival and for protecting the rights of all USEF members, including
15. Defendant, WEP, at all times material was the operating manager of the Winter
Equestrian Festival and was also responsible for upholding and enforcing USEF rules and
regulations at the Winter Equestrian Festival and for protecting the rights of all USEF members,
16. Defendants have either held the license and/or managed the Winter Equestrian Festival
(“WEF”) for approximately three years.
17. The WEF runs for approximately four months during the winter season.
18. The WEF attracts equestrian competitors, participants, vendors and spectators from
all over the world.
19. From 1992 through 2009 STETLER was an exhibitor, participant, spectator,
competitor and sponsor of the WEF.
20. From 1992 through 2009 STETLER was an exhibitor, participant, spectator,
competitor and sponsor of the WEF.
20. From 1992 through 2009 RVSB was a sponsor of the WEF.
21. From 1992 tbrough 2008 STETLER and RVSB had written contracts for sponsorship
of the WEF with the prior USEF licensee.
22. The prior contracts contained option to renew and rights of first refusal clauses.
24. Many of the competitors, participants, vendors and spectators who attended the WEF
resided in RVs which they owned or rented during the four months of the competition.
25. STETLER and RVSB derived substantial revenue from selling, renting and servicing
RVs to the WEF participants and from providing and servicing the campsites for the RVs.
26. STETLER and RVSB would generate RV related sales, servicing and rentals
throughout the year from leads and contacts generated through the WEF.
27. In 2000 STETLER and RVSB, at their expense, began to build a campground on the
South Grounds of the WEF known as the Littlewood Farms. The campground when completed
provided hook-ups for sixty RVs. The campground was completed in 2003.
28. Commencing in 2003 and in each year until 2008, STETLER and RVSB had a
contract with Littlewood Fmms, whereby Plaintiffs would lease the campground during the WEF
and pay Littlewood Farms a sum of money and other benefits.
29. At all times material until 2008 Littlewood Farms also had a horseshow on the South
Grounds at times other then on the dates of the WEF. STETLER and RVSB sponsored and
participated in the other horse show as well and derived income from that participation.
30. In approximately 2008 Defendants purchased or otherwise acquired the rights and
ownership to the WEF and the Littlewood Farms horseshow which included the land on which the
campground built by Plaintiffs was situated.
31. Plaintiffs entered into an oral agreement with MARK BELLISSIMO and the other
Defendants whereby Plaintiffs sponsored the 2009 WEF and operated the campground in exchange
32. The value of the equipment loaned by Plaintiffs to Defendants exceeded $200,00.00.
33. After the 2009 WEF STETLER contacted BELLISSIMO to negotiate the terms for
Plaintiffs sponsorship of the 2010 WEF.
34. Initially BELLISSIMO agreed to allow Plaintiffs to sponsor the 2010 WEF.
35. BELLISSIMO requested that STETLER forward to him RVSB’s Confidential Client
List as well as the budget, trade secrets and business model for the campground operation.
36. As consideration for the agreement, BELLISSIMO also requested that he be allowed
to keep for his own personal use certain equipment previously loaned by Plaintiffs to Defendants
in exchange for sponsorship of the 2009 WEF.
37. Plaintiffs were led to believe that they had an agreement with Defendants for the
sponsorship of the 2010 WEF and the campground rights. As a result, Plaintiffs provided
and allowed Defendants the use of equipment identified in Exhibit “A”, attached.
38. Plaintiffs also agreed that BELLISSIMO could keep certain equipment identified in
Exhibit “A”, attached, as consideration for sponsorship of the 2010 WEF and operation of the
39. Shortly after receiving Plaintiffs Confidential Client List and other proprietary
information Defendants advised Plaintiffs that they were not the sponsors of the 2010 WEF and that
Camping World, a major competitor of RVSB, had been given the sponsorship.
40. Defendendants then contacted all of Plaintiffs clients listed on the Confidential Client
List and advised each client that Camping World was the new and only RV provider of the WEF and
Release as to the above is attached hereto as Exhibit “B”).
the use of Plaintiffs equipment located on the campground, including on-site utility equipment
necessary to operate the campground, and Plaintiffs’ trade secrets as to the operation of the
42. Plaintiffs retained an attorney who wrote Defendants in November and December of
2009 and demanded the return of Plaintiffs’ equipment now in the wrongful possession of the
Defendants. (The letters sent on behalf of Plaintiffs to Defendants dated November and December
of 2009 demanding the return of Plaintiffs’ equipment are attached as Exhibits “C” and “D”.)
43. Defendants refused to return Plaintiffs’ property.
44. STETLER is an accomplished equestrian competitor and it was critical for STETLER
to compete in the 2010 WEF as that was her long standing method to promote her RV business and
to maintain customer relations with her horseshow clients.
45. A major reason why STETLER’s clients did business with Plaintiffs was STETLER’s
long term involvement and support of equestrian competitions and the horse show community.
46. Although Plaintiffs were no longer sponsors of the 2010 WEF competition,
STETLER personally was a competitor in the Adult Jumper Division of the 2010 event.
47. Far Niente VI, LLC is Florida a corporation owned or controlled by Defendants.
48. Far Niente VI, LLC now owns the land on which the WEF is held.
49. On February 16′”, 2010, in the midst of STETLER’s personal competition at the
WEF, MARK BELLISSIMO, acting individually and on behalf of the Defendants, through Far
barred fi·om the horse show grounds as a competitor, exhibitor, spectator and patticipant and
threatened her with trespass penalties if she came on the WEF grounds. (The letter written on
February 16, 2010 excluding STETLER from the WEF grounds is attached as Exhibit “E”).
States Equestrian Federation (“USEF”) rules which governed the event.
51. STETLER filed a protest with the USEF.
52. On March 24, 2010 a full-day hearng was held by the USEF in its headquatters in
Lexington, Kentucky which all the parties to this lawsuit attended. GIGI STETLER and MARK
BELLISSIMO testified at that hearing.
53. On May 17, 2010, after the 2010 WEF had concluded, the USEF, in a unanimous
decision, found that the Defendants violated USEF rules by wrongfully excluding STETLER from
the 2010 WEF premises.
54. The USEF further found that Defendants violated USEF rules by denying STETLER
the right to compete in the 2010 WEF and in future competitions.
55. On June 29, 2010 Plaintiffs, through their attorney, wrote Cettified Letters to
Defendants, pursuant to Florida Statutes, Section 772.11, the “Civil Theft Statute”, and again
demanded return of their property. (Plaintiffs “Civil Theft” letters dated June 29, 2010 are attached
as Composite Exhibit “F”).
56. Defendants still refiised to return Plaintiffs equipment
57. This lawsuit followed.
PLAINTIFFS’ CONVERSION CLAIM AGAINST THE DEFENDANTS
59. Plaintiffs are the rightful owners of the property which is specifically identified in
Exhibit “A”, attached.
60. With respect to the 2009 WEF, Plaintiffs allowed Defendants to utilize the property
in exchange for sponsorship rights of that event, which event was sponsored by Plaintiffs.
61. With respect to sponsorship of the 2010 WEF, initially Defendants agreed that
Plaintiffs could sponsor that event.
62. In exchange for sponsorship rights Plaintiffs agreed to allow Defendants to utilize the
property described above.
63. Defendants subsequently refused to allow Plaintiffs to sponsor the 2010 WEF.
64. Plaintiffs demanded return of their property. (Plaintiffs letters demanding retum of
their property are attached as Exhibits “C”, “D”, and “F”.)
65. Defendants refused to return Plaintiffs’ property.
66. Plaintiffs did not authorize Defendants to maintain possession and control oftheir
67. Defendants refusal to return Plaintiffs’ property deprived Plaintiffs of their property
permanently or for an indefinite period of time.
68. Defendants refusal to return Plaintiffs’ property is inconsistent with Defendants
ownership interests in the property.
69. Defendants refusal to return Plaintiffs’ property constitutes a conversion of the
property which rightfully belongs to the Plaintiffs.
punitive damages, costs of litigation and such further relief as the Court deems fit. Plaintiffs demand
by jury of all issues so triable as of right.
PLAINTIFFS’ CIVIL THEFT CLAIM AGAINST DEFENDANTS
PURSUANT TO FLORIDA STATUTES, SECTION 772.11(1)
71. This claim is brought pursuant to Florida Statutes, Section 772.11 (1 ), entitled “Civil
Remedy For Theft”.
72. All conditions precedent to filing this claim have been met including proper pre-suit
written demand and notice on Defendants pursuant to FS 772.11 for return of Plaintiffs’ property.
73. Plaintiffs are the rightful owners of the properly which is specifically identified in
Exhibit “A”, attached.
74. With respect to the 2009 WEF, Plaintiffs loaned the property identified above to
Defendants and allowed Defendants to utilize the property in exchange for sponsorship rights of that
75. With respect to the 2010 WEF, Plaintiffs agreed to allow Defendants to utilize their
property if Defendants allowed Plaintiffs to sponsor the 2010 WEF.
76. Defendants initially agreed to allow Plaintiffs to sponsor the 20 I 0 WEF but
subsequently refused to allow Plaintiffs to sponsor the event.
77. Plaintiffs demanded return of their property. (Plaintiffs’ letters demanding return of
their property are attached as Exhibits “C”, “D” and “F”.)
78. Defendants refused to return Plaintiffs’ property.
property permanently or for an indefinite period of time.
80. Defendants refusal to return Plaintiffs’ property is inconsistent with Defendants
ownership interest in the property.
81. Defendants knowingly intended to either temporarily or permanently deprive
Plaintiffs of the right to their property.
82. Defendants intended to appropriate Plain tiffs’ property for their own use or for the use
of others who are not entitled to the use or possession of the property.
83. Defendants’ actions herein evidence a felonious intent to steal Plaintiffs’ property,
which actions constitute civil theft.
Defendants and further demands trial by jury of all issues so triable as of right.
85. As set forth in paragraphs 44 to 54, above, Defendants wrongfully and
deliberately caused STETLER to be barred from the horseshow grounds and the WEF competition.
86. Defendants conduct was intentional or reckless.
87. Defendants conduct was outrageous.
88. Defendants conduct was calculated to cause STETLER emotional distress.
89. STETLER suffered severe emotional distress, humiliation and embarrassment as
a result of Defendants’ conduct.
of litigation against Defendants and such further relief as the Court might grant. STETLER demands
trial by jury of all issues so triable as of right.
PLAINTIFFS’ CLAIM FOR INTERFERENCE WITH ADVANTAGEOUS BUSINESS
RELATIONS AGAINST DEFENDANTS
91. Plaintiffs had business relationships with the clients listed on their Confidential Client
92. Through the course of many years Plaintiffs established and refined certain operating
procedures with respect to managing the campground at the WEF.
93. Defendants acquired Plaintiffs Confidential Client List and campground operating
procedures through deceptive means as described in paragraphs 35 through 41, above.
94. Defendants had actual knowledge that Plaintiffs had business relationships with those
95. Defendants had actual knowledge that Plaintiffs’ campground management
procedures resulted in a high level of service to RV customers and was a major factor in why they
chose to stay for the season in the campground. These procedures which took years to develop and
refine constituted Plaintiffs’ trade secrets as to the operation of the campground.
96. Defendants without Plaintiffs knowledge or consent forwarded Plaintiffs’
Confidential Client List and trade secret operating procedures to Camping World, a RV dealer and
a major competitor of the Plaintiffs.
clients and to develop business relationships with those clients which was detrimental to Plaintiffs
98. Camping World utilized Plaintiffs’ trade secret campground operating procedures to
service Plaintiffs’ clients when Defendants awarded Camping World the right to operate the
99. Defendants intentionally and unjustifiably interfered with Plaintiffs business
100. As a result, Plaintiffs suffered economic damages.
WHEREFORE, Plaintiffs demand damages against Defendants including costs of litigation
and such further relief as the Court deems fit. Plaintiffs demand trial by jury of all issues so triable
as of right.
DAVID STONE, P.A.
Attorney for Plaintiffs
Defendants’ motions to dismiss denied