Navigating PA's Right to Know Law (RTKL)

Navigating PA's Right to Know Law (RTKL)

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Friday, January 19, 2018

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Exhibits/Sequence of Events

PSBA Exhibits A through I in its amended SLAPP constitutes the First Amendment activity I was sued for.


Event (click links)

Notes/PSBA exhibits




 March 2017

Statewide Request 1

Not sued for this request

 March 28, 2017

Emily e-mail blast guidance re: Statewide Request 1 (viewable as the first e-mail under the video/images of this non-advertised webpage.)

Emily called for research information about my request for the purpose of PSBA lobbying

 March 29, 2017

Simon email opinion to Shanksville-Stonycreek SD saying Emily was “unregistered lobbyist from a private corporation out there seemingly engaged in the authorized practice of law”

Exhibit D in PSBA's amended complaint (i.e. sued for expressing this opinion to the government). Emily Leader is not a SLAPP plaintiff.

April 14, 2017

Stuart Knade e-mail blast guidance re: Statewide Request 1 (viewable as the second e-mail under the video/images of this non-advertised webpage.)

Stuart stated PSBA's position was that school districts need not send records to Requesters i.e. requesters must visit in person

 April 22, 2017 and thereafter

Simon federal law public records request of PSBA and e-mail spat with Levin

Exhibits A and B in PSBA's amended complaint (i.e. sued for this speech)(first time Levin unequivocally threatened me). Levin is not a SLAPP Plaintiff.

 May 6 - May 8, 2017

Statewide Request 2 to c. 600 public school agencies (most of whom are PSBA members)

Exhibit H in PSBA's amended complaint (i.e. two months later sued for merely making this RTKL request. No OOR appeals were taken. No RTKL litigation occurred with any agency)

May 9, 2017

Lobbying video on PFUR website speaking to governments about how to process the request, and criticizing PSBA. Preserved as the second video from the bottom on this non-advertized webpage.

Exhibit G in PSBA's amended complaint (i.e. sued for petitioning govt. agencies to process the May RTKL request favorably to me)

Sometime in April & May

Two webpages set up on PFURs website ("PSBA Horror" and "Investigate PSBA") containing speech and parody that is critical of PSBA's position on matters of public interest (PSBA Horror preserved here in non-advertised view with both satirical images. Investigate PSBA preserved here in non-advertised view).

Exhibit E in PSBA's amended complaint (sued for parody).

 May 12, 2017

 Levin issues Cease and Desist letter within days of Statewide Request 2 being sent (Campbell on behalf of PFUR response May 18, 2017)


 May 16, 2017

Campbell on behalf of PFUR writes to Centennial SD Superintendent asking for clarification as to who Levin is representing in his 5-12-17 threat and stating the opinion that Levin would have a conflict if he counseled Centennial about the May RTKL request

Paragraphs 19 & 42; and Exhibit F in PSBA's amended complaint (sued for writing to the government). Levin is not a SLAPP Plaintiff.

 July 17, 2017

PSBA SLAPP Suit 1 calling Simon Campbell a criminal and demanding punitive damages for the mere act of filing a RTKL request.


 July 17, 2017

PSBA gloating statewide e-mail annoucement blast.


 Approx. July 18, 2017

 PFUR removes the webpages "PSBA Horror" and "Investigate PSBA" from public view after being intimidated (but preserves them in non-advertised view).


 July 19, 2017

Heim sends aggressive spoilation letter.


 July 23, 2017 and thereafter

Campbell (not PFUR) registers a new personal website and becomes an anti-SLAPP activist promoting the need for SB 95 to become law; and re-posts the two webpages that PFUR had removed from public view days earlier along with other speech criticial of PSBA for filing a SLAPP suit, including a satirical image of Mains on the home page saying into a radio microphone "Hey school children, **** the Constitution! **** the bill of rights", preserved in non-advertised mode here). By December 11, 2017 a total of fifteen (15) webpages existed on this website.

Exhibit C in PSBA's amended complaint.

 October 16, 2017

Mains sends e-mail blast of a weblink (still live here) to promote the as-yet-unserved July 17, 2017 SLAPP suit, and states that all 10 elected government officials on PSBA's board of directors voted to authorize the SLAPP.


 October 20, 2017

Service of the SLAPP suit occurs via certifed mail


 November 9, 2017

Campbell-PFUR files POs to the SLAPP


November 13, 2017 and thereafter

PA Department of Transportation responds to a Campbell 10-5-17 RTKL stating that it had records "responsive to your request" regarding the Commonwealth of PA giving no-fee auto tags to PSBA employees. Campbell, using this government answer, posts a stock image of cars on and a comment that is critical of the Commonwealth with the PennDOT source for the opinion underneath the comment. Preserved in non-advertised view here.

Exhibit C in PSBA's amended complaint.

December 11, 2017

SLAPP 2 (identical to SLAPP 1 but adding two new complaint count re: Exhibit C; while rambling about Emily Leader's status as a lawyer).

PSBA added an Exhibit I, but made no reference to it inside their complaint. It is retaliation for a different statewide request made subsequent to May 2017 and for my lobbying school entities to pass a resolution in oppositiion to the SLAPP. (Levin thinks I am using the RTKL to extort agencies into passing resolutions against PSBA's position).

December 12, 2017

Not knowing what RTKL request, govt. petitioning, or speech about matter of public interest will get him sued a third time, and feeling the heat of legal fees, Campbell chooses to removes all content from the 15 pages of but preserves all of it in non-advertised view.