On February 03, 2023 a
Party Statement
was filed
involving a dispute between
and
for DECLARATORY - CIRCUIT
in the District Court of Pinellas County.
Preview
Filing # 186405215 E-Filed 11/17/2023 04:06:11 PM
AFFIDAVIT 3
AFFIDAVIT OF PAUL GAGLIANO
STATE 0F FLORIDA
COUNTY 0F PINELLAS
BEFORE ME, the undersigned authority, on this date personally appeared Paui Gagliano B
who, after being by me duly sworn, deposes and says as follows:
1. I am a private citizen and resident ofthe State 0f Florida above the age ofmajority under
Florida law and am in all ways capable of making this afiidavit.
2. This affidavit is based upon my personal knowledge and on true and correct copies of
documents attached as Affidavit Exhibits 1-3
3. I was an investor and the Operations and Development manager of Rainbow Aviation in
Dunnellon, Florida. Working directly with Allan Corbin, President of Rainbow Aviation
we sucessfully operated the Dunnellon Airport (X39) aka Dunnellon Field, owned by
Marion County, Florida beginning in 1976 and my active involvement ended in 1979.
4. I was the owner and CEO of Flightshops (aviation bookstore), located at St. Petersburg I
Clearwater Airport and later purchased National Aviation (flight school) where I was
CEO and Ray Clark was CFO. I also participated in the planning and development by
William Krusen of a privately owned ‘T‘ hanger project ‘The Landings’ located 0n the
St. Petersburg f Clearwater Airport. National Aviation was also a user 0fthese hangers.
5. Upon its closure, a National Aviation school aircrafi, Cessna N71 IWE was relocated t0
Clearwater Airpark where it came to be hangered.
6. Ray Clark and I were members in ‘N71 IWE, LLC’, the Florida company that owned the
1979 Cessna 172 aircraft registered as N71 1 WE
7. Ray Clark and 1 were joint tenants in Clearwater Airpark Hanger H‘Z for app. 10 years
8. Hanger 1-1—2 was burglarized on the weekend 0f 9/1 6/201 8 and David King Jr. (employee
of the FBO) was later charged and convicted ofthese felony crimes.
9. Clearwater Police Department Report CW1 8- 137732 enumerated several additional
concerns with the City’s operation and oversight of the Airpark (Affidavit Exhibit l)
***ELECTRONICALLY FILED 11/17/2023 04:06:07 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
10. I raised those reported con'cems before both Clearwater City stafi and City Council.
This report CW1 8-137732 is entirely a product of the Clearwater Police Department.
ll. I have been sued for Defamation by David King Sr., former Airpark FBO and after four
years, this case was settled by sealed agreement without a finding. (Pinellas Florida 6‘“
Circuit Case 19-596l-CI)
12. I have worked pro bono on behalf of the Clearwater Airpark community in an attempt to
improve it’s operation by the City to the benefit of all the stakeholders since 201 8
13. I do not seek any financial benefit or gain from the Clearwater Airpark of any kind.
14. In addition to the exhibits in Plaintist Motion in Opposition to Defendant’s Motion for
Summary Judgment (in this instant case # 23-941-CO) my statements have also been
based upon the following public documents:
A. FDOT Florida Aviation Project Handbook (Affidavit Exhibit 2)
B. FDOT Airport Business Plan Handbook (Affidavit Exhibit 3)
FURTHER AFFIANT SAYTH NOT.
4%
Paul Gagliano
SWORN T0 AND SUBSCRIBED before me this l S day ofmozs
fléc /
NOTARY PUBLIC
State of Florida
My Commission Expires
Affiant produced DL Identification
g glaév /
'
NANCY DUNHAM 2
State of Florida -
Notary Public i.
.
Commission # HH 360866 9
My Commission Expires 02/12/2027 T’
Document Filed Date
November 17, 2023
Case Filing Date
February 03, 2023
Category
DECLARATORY - CIRCUIT
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # 186405215 E-Filed 11/17/2023 04:06:11 PM AFFIDAVIT 3 AFFIDAVIT OF PAUL GAGLIANO STATE 0F FLORIDA COUNTY 0F PINELLAS BEFORE ME, the undersigned authority, on this date personally appeared Paui Gagliano B who, after being by me duly sworn, deposes and says as follows: 1. I am a private citizen and resident ofthe State 0f Florida above the age ofmajority under Florida law and am in all ways capable of making this afiidavit. 2. This affidavit is based upon my personal knowledge and on true and correct copies of documents attached as Affidavit Exhibits 1-3 3. I was an investor and the Operations and Development manager of Rainbow Aviation in Dunnellon, Florida. Working directly with Allan Corbin, President of Rainbow Aviation we sucessfully operated the Dunnellon Airport (X39) aka Dunnellon Field, owned by Marion County, Florida beginning in 1976 and my active involvement ended in 1979. 4. I was the owner and CEO of Flightshops (aviation bookstore), located at St. Petersburg I Clearwater Airport and later purchased National Aviation (flight school) where I was CEO and Ray Clark was CFO. I also participated in the planning and development by William Krusen of a privately owned ‘T‘ hanger project ‘The Landings’ located 0n the St. Petersburg f Clearwater Airport. National Aviation was also a user 0fthese hangers. 5. Upon its closure, a National Aviation school aircrafi, Cessna N71 IWE was relocated t0 Clearwater Airpark where it came to be hangered. 6. Ray Clark and I were members in ‘N71 IWE, LLC’, the Florida company that owned the 1979 Cessna 172 aircraft registered as N71 1 WE 7. Ray Clark and 1 were joint tenants in Clearwater Airpark Hanger H‘Z for app. 10 years 8. Hanger 1-1—2 was burglarized on the weekend 0f 9/1 6/201 8 and David King Jr. (employee of the FBO) was later charged and convicted ofthese felony crimes. 9. Clearwater Police Department Report CW1 8- 137732 enumerated several additional concerns with the City’s operation and oversight of the Airpark (Affidavit Exhibit l) ***ELECTRONICALLY FILED 11/17/2023 04:06:07 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** 10. I raised those reported con'cems before both Clearwater City stafi and City Council. This report CW1 8-137732 is entirely a product of the Clearwater Police Department. ll. I have been sued for Defamation by David King Sr., former Airpark FBO and after four years, this case was settled by sealed agreement without a finding. (Pinellas Florida 6‘“ Circuit Case 19-596l-CI) 12. I have worked pro bono on behalf of the Clearwater Airpark community in an attempt to improve it’s operation by the City to the benefit of all the stakeholders since 201 8 13. I do not seek any financial benefit or gain from the Clearwater Airpark of any kind. 14. In addition to the exhibits in Plaintist Motion in Opposition to Defendant’s Motion for Summary Judgment (in this instant case # 23-941-CO) my statements have also been based upon the following public documents: A. FDOT Florida Aviation Project Handbook (Affidavit Exhibit 2) B. FDOT Airport Business Plan Handbook (Affidavit Exhibit 3) FURTHER AFFIANT SAYTH NOT. 4% Paul Gagliano SWORN T0 AND SUBSCRIBED before me this l S day ofmozs fléc / NOTARY PUBLIC State of Florida My Commission Expires Affiant produced DL Identification g glaév / ' NANCY DUNHAM 2 State of Florida - Notary Public i. . Commission # HH 360866 9 My Commission Expires 02/12/2027 T’