1 

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA, 

FORT LAUDERDALE DIVISION

Case No.: 0:22–CV– 62321–XXXX 

WSPSL, LLC and SAVANT CONSULTANTS LLC d/b/a 

BLUE SKIES AVIATION, 

Plaintiffs 

vs.

AIRCRAFT MANAGEMENT CORPORATION 

and JORGE LUIS CRUZ PONCE, 

Defendants. 

______________________________/ 

COMPLAINT AND DEMAND FOR JURY TRIAL

COMES NOW Plaintiffs, SAVANT CONSULTANTS LLC d/b/a BLUE 

SKIES AVIATION and WSPSL, LLC, and hereby sues Defendants, AIRCRAFT 

MANAGEMENT CORPORATION and JORGE LUIS CRUZ PONCE, and in 

support thereof states as follows:

PARTIES

1. Plaintiff, WSPSL, LLC is, and at all times herein mentioned was, a 

limited liability company formed under the laws of the State of Delaware, with its 

principal place of business in the State of Delaware, and is transacting business in 

the State of Florida within the Southern District of Florida, Fort Lauderdale Division.

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2. Plaintiff, SAVANT CONSULTANTS LLC d/b/a BLUE SKIES 

AVIATION (hereinafter “BLUE SKIES AVIATION”) is, and at all times herein 

mentioned was, a limited liability company formed under the laws of the State of 

Delaware, with its principal place of business in the State of Colorado, and is 

transacting business in the State of Florida within the Southern District of Florida, 

Fort Lauderdale Division.

3. Defendant, AIRCRAFT MANAGEMENT CORPORATION is, and at 

all times material herein was, a corporation incorporated under the laws of the State 

of Florida, with its principal place of business in the State of Florida, and is 

transacting business in the State of Florida within the Southern District of Florida, 

Fort Lauderdale Division.

4. Defendant, JORGE LUIS CRUZ PONCE (hereinafter “JORGE 

CRUZ”) is, and at all times material herein was, an individual and citizen of 

Guatemala residing in and conducting business in the State of Florida within the 

Southern District of Florida, Fort Lauderdale Division. 

5. Additionally, Defendant, JORGE CRUZ is, and at all times material 

herein was, the President of AIRCRAFT MANAGEMENT CORPORATION and 

acted as its agent with express authority while conducting business in the State of 

Florida within the Southern District of Florida, Fort Lauderdale Division. 

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JURISDICTION

6. This Court has jurisdiction over this cause pursuant to 28 U.S.C. § 1332 

because the citizenship of Plaintiffs and Defendants are diverse, and the amount in 

controversy, exclusive of interests and costs, far exceeds the sum of Seventy-Five 

Thousand Dollars ($75,000.000).

VENUE

7. Venue is proper in the Southern District of Florida, Fort Lauderdale 

Division, under 28 U.S.C. § 1391(b)(2) because a substantial part of the events or 

omissions giving rise to this claim, including but not limited to the entering into the 

contracts between the parties, occurred within the Southern District of Florida, Fort 

Lauderdale Division. 

GENERAL FACTS PERTINENT TO ALL COUNTS

8. WSPSL, LLC and AIRCRAFT MANAGEMENT CORPORATION by 

and through its agent, JORGE CRUZ, entered into a valid non-exclusive Lease 

Agreement concerning a 1988 Gulfstream Aerospace Corporation GIV aircraft 

bearing U.S. registration number N254CA, and manufacturer’s serial number 1054 

(hereinafter the “Aircraft”) on April 20, 2022. [Ex. “1”, Lease Agreement]. 

9. Under this Lease Agreement, AIRCRAFT MANAGEMENT 

CORPORATION and its agent, JORGE CRUZ, were required to maintain 

operational control at all times while operating the Aircraft, and they were 

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responsible for locating and retaining a qualified flight crew for all flights pursuant 

to Lease Agreement. [Lease Agreement Section 5.5 and 5.6].

10. AIRCRAFT MANAGEMENT CORPORATIONand its agent, JORGE 

CRUZ, were also responsible for all flight related costs, all unscheduled 

maintenance costs, all costs for damage done to the Aircraft, maintaining appropriate 

liability and hull insurance, and hourly rent for use of the Aircraft. [Lease Agreement 

Section 5.3, 5.4, 8.1, and 8.2].

11. WSPSL, LLC delivered the Aircraft to JORGE CRUZ and 

AIRCRAFT MANAGEMENT CORPORATION and otherwise upheld all of its 

obligations pursuant to the Lease Agreement.

12. JORGE CRUZ and AIRCRAFT MANAGEMENT CORPORATION 

violated the Lease Agreement by failing to make payments for their utilization of 

the Aircraft as required under the Lease Agreement.

13. JORGE CRUZ and AIRCRAFT MANAGEMENT CORPORATION 

violated the Lease Agreement by damaging the Aircraft and failing to pay for those 

damages as required under the Lease Agreement.

14. JORGE CRUZ and AIRCRAFT MANAGEMENT CORPORATION 

violated the Lease Agreement by failing to pay for unscheduled maintenance on the 

Aircraft as required under the Lease Agreement.

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15. Additionally, JORGE CRUZ and AIRCRAFT MANAGEMENT 

CORPORATION used the Aircraft in violation of Lease Agreement by operating 

commercial flights with the Aircraft.

16. As a result of JORGE CRUZ and AIRCRAFT MANAGEMENT 

CORPORATION failing to make required payments for utilization of the Aircraft 

and unscheduled maintenance for the Aircraft as required under the Lease 

Agreement, JORGE CRUZ entered into a promissory note with WSPSL, LLC and 

BLUE SKIES AVIATION, which was attached as an addendum to the original lease 

agreement on July 27, 2022. [Ex. “2”, Addendum].

17. Despite this, JORGE CRUZ and AIRCRAFT MANAGEMENT 

CORPORATION have failed to make any payments due under the Addendum.

18. To date, JORGE CRUZ and AIRCRAFT MANAGEMENT 

CORPORATION owe in excess of $800,000 to WSPSL, LLC and BLUE SKIES 

AVIATION in past due payments under the Lease Agreement and the Addendum.

COUNT I BREACH OF CONTRACT– WSPSL, LLC v. AIRCRAFT 

MANAGEMENT CORPORATION

19. WSPSL, LLC incorporates by reference and re-alleges paragraphs one 

(1) through eighteen (18) as if fully set-forth herein. 

20. WSPSL, LLC entered into a valid contract, the Lease Agreement, with 

AIRCRAFT MANAGEMENT CORPORATION.

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21. AIRCRAFT MANAGEMENT CORPORATION breached the Lease 

Agreement by failing to make payments as required. 

22. As a result, AIRCRAFT MANAGEMENT CORPORATION entered 

into a second valid contract, the Addendum, with WSPSL, LLC that set forth a 

payment schedule for past due payments AIRCRAFT MANAGEMENT 

CORPORATION owed under the Lease Agreement.

23. AIRCRAFT MANAGEMENT CORPORATION has breached the 

Addendum by failing to make the payments owed under the Lease Agreement and 

the Addendum.

24. WSPSL, LLC has suffered contractual damages in the amount of the 

past due payments AIRCRAFT MANAGEMENT CORPORATION owes under the 

Lease Agreement and Addendum.

25. Additionally, WSPSL, LLC has incurred special and consequential 

damages from AIRCRAFT MANAGEMENT CORPORATION’S breach of the 

Lease Agreement and Addendum, including but not limited to loss of use of the 

Aircraft, diminished value of the Aircraft, and interruption/loss of business profits. 

COUNT II, BREACH OF CONTRACT – WSPSL, LLC v. JORGE CRUZ

26. WSPSL, LLC incorporates by reference and re-alleges paragraphs one 

(1) through eighteen (18) as if fully set forth herein. 

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27. After AIRCRAFT MANAGEMENT CORPORATION fell behind on 

payments pursuant to the Lease Agreement, WSPSL, LLC and AIRCRAFT 

MANAGEMENT CORPORATION entered into a promissory note and Addendum 

to the Lease Agreement, as explained above. 

28. JORGE CRUZ acknowledged the debt owed and signed the Addendum 

in his personal capacity.

29. Thus, JORGE CRUZ entered into a valid contract, the Addendum, with 

WSPSL, LLC.

30. WSPSL, LLC, upheld its obligations under the Lease Agreement and 

the Addendum. 

31. JORGE CRUZ breached the valid contracts, the Lease Agreement and 

Addendum, by failing to make payments due under the Lease Agreement and the 

Addendum.

32. WSPSL, LLC has suffered contractual damages in the amount of the 

past due payments JORGE CRUZ owes under the Lease Agreement and Addendum.

33. Additionally, WSPSL, LLC has incurred special and consequential 

damages from JORGE CRUZ’S breach of the Addendum, including but not limited 

to loss of use of the Aircraft, diminished value of the Aircraft, and interruption/loss 

of business profits.

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COUNT III, BREACH OF CONTRACT – BLUE SKIES AVIATION v.

AIRCRAFT MANAGEMENT CORORATION

34. BLUE SKIES AVIATION incorporates by reference and re-alleges

paragraphs one (1) through eighteen (18) as if fully set forth herein. 

35. AIRCRAFT MANAGEMENT CORPORATION entered into a valid 

contract, the Addendum, with BLUE SKIES AVIATION, requiring AIRCRAFT 

MANAGEMENT CORPORATION to make past due payments owed under the 

Lease Agreement to BLUE SKIES AVIATION. 

36. BLUE SKIES AVIATION upheld its obligations under the Addendum.

37. AIRCRAFT MANAGEMENT CORPORATION breached the 

Addendum by failing to make the past due payments owed under the Lease 

Agreement and the Addendum to BLUE SKIES AVIATION. 

38. BLUE SKIES AVIATION has suffered contractual damages in the 

amount of the past due payments AIRCRAFT MANAGEMENT CORPORATION

owes under the Lease Agreement and Addendum.

39. Additionally, BLUE SKIES AVIATION has incurred special and 

consequential damages from AIRCRAFT MANAGEMENT CORPORATION’S 

breach of the Lease Agreement and Addendum, including but not limited to loss of 

use of the Aircraft, diminished value of the Aircraft, and interruption/loss of business 

profits.

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COUNT IV, BREACH OF CONTRACT – BLUE SKIES AVIATION v.

JORGE LUIS CRUZ PONCE

40. BLUE SKIES AVIATION incorporates by reference and re-alleges 

paragraphs one (1) through eighteen (18) as if fully set forth herein. 

41. JORGE CRUZ entered into a valid contract, the Addendum, with 

BLUE SKIES AVIATION, requiring JORGE CRUZ to make past due payments 

owed under the Lease Agreement to BLUE SKIES AVIATION. 

42. BLUE SKIES AVIATION upheld its obligations under the Addendum.

43. JORGE CRUZ breached the Addendum by failing to make the past due 

payments owed under the Lease Agreement and the Addendum to BLUE SKIES 

AVIATION.

44. BLUE SKIES AVIATION has suffered contractual damages in the 

amount of the past due payments JORGE CRUZ owes under the Lease Agreement 

and Addendum.

45. Additionally, BLUE SKIES AVIATION has incurred special and 

consequential damages from JORGE CRUZ’S breach of the Addendum, including 

but not limited to loss of use of the Aircraft, diminished value of the Aircraft, and 

interruption/loss of business profits.

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COUNT V, FRAUD – WSPSL, LCC v. AIRCRAFT MANAGEMENT 

CORPORATION

46. WSPSL, LLC realleges paragraphs one (1) through eighteen (18) as if 

fully set forth herein.

47. Pursuant to Section 5.2(ii) of the Lease Agreement, AIRCRAFT 

MANAGEMENT CORPORATION was not permitted to “operate the Aircraft in 

commercial service, as common carrier, or otherwise on a compensatory or ‘for hire’ 

basis except to the limited extent permitted under Subpart F of Part 91 of the FAR, 

if applicable[.]” [Lease Agreement Section 5.2(ii)].

48. Pursuant to Section 5.2(vi) of the Lease Agreement, AIRCRAFT 

MANAGEMENT CORPORATION was not permitted to “knowingly permit the 

Aircraft to be used for the carriage of any persons or property prohibited by law[.]”

[Lease Agreement Section 5.2(vi)]. 

49. AIRCRAFT MANAGEMENT CORPORATION falsely represented to 

WSPSL, LLC that the Aircraft would not be used in connection with transport in a 

commercial or “for hire” capacity, or for the carriage of persons or property 

prohibited by law, in compliance with these sections and Federal Law. 

50. AIRCRAFT MANAGEMENT CORPORATION knew these 

representations were false at the time they were made to WSPSL, LLC. 

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51. AIRCRAFT MANAGEMENT CORPORATION made these 

representations to induce WSPSL, LLC to rely upon them in agreeing to enter into 

the Lease Agreement and the subsequent Addendum. 

52. WSPSL, LLC did in fact rely upon these statements in choosing to enter 

into the Lease Agreement and Addendum with AIRCRAFT MANAGEMENT 

CORPORATION.

53. These statements were false, and AIRCRAFT MANAGEMENT 

CORPORATION did, in fact, use the Aircraft in connection with commercial flights

which violated the Lease Agreement and FAA regulations. 

54. AIRCRAFT MANAGEMENT CORPORATION also used the aircraft 

in connection with the transportation of persons or property prohibited by law, again 

in violation of the Lease Agreement and FAA regulations. 

55. WSPSL, LLC’s reliance upon AIRCRAFT MANAGEMENT 

CORPORATION’s fraudulent statements has resulted in damage to WSPSL, LLC, 

including devaluation of WSPSL, LLC’s business assets and damage to WSPSL, 

LLC’s business reputation.

COUNT VI, FRAUD – WSPSL, LLC v. JORGE LUIS CRUZ PONCE

56. WSPSL, LLC realleges paragraphs one (1) through eighteen (18) as if 

fully set forth herein.

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57. Pursuant to Section 5.2(ii) of the Lease Agreement, AIRCRAFT 

MANAGEMENT CORPORATION was not permitted to “operate the Aircraft in 

commercial service, as common carrier, or otherwise on a compensatory or ‘for hire’ 

basis except to the limited extent permitted under Subpart F of Part 91 of the FAR, 

if applicable[.]” [Lease Agreement Section 5.2(ii)].

58. Pursuant to Section 5.2(vi) of the Lease Agreement, AIRCRAFT 

MANAGEMENT CORPORATION was not permitted to “knowingly permit the 

Aircraft to be used for the carriage of any persons or property prohibited by law[.]” 

[Lease Agreement Section 5.2(vi)]. 

59. JORGE CRUZ made representations on behalf of AIRCRAFT 

MANAGEMENT CORPORATION to WSPSL, LLC.

60. JORGE CRUZ falsely represented to WSPSL, LLC that the Aircraft 

would not be used in connection with transport in a commercial or “for hire” 

capacity, or for the carriage of persons or property prohibited by law, in compliance 

with these sections and Federal Law. 

61. JORGE CRUZ knew these representations were false at the time they 

were made to WSPSL, LLC. 

62. JORGE CRUZ made these representations to induce WSPSL, LLC to 

rely upon them in agreeing to enter into the Lease Agreement and the subsequent 

Addendum. 

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63. WSPSL, LLC did in fact rely upon these statements in choosing to enter 

into these agreements with AIRCRAFT MANAGEMENT CORPORATION and 

JORGE CRUZ.

64. These statements were false, and JORGE CRUZ and AIRCRAFT 

MANAGEMENT CORPORATION did, in fact, use the Aircraft in connection with 

commercial flights which violated the Lease Agreement and FAA regulations.

65. JORGE CRUZ and AIRCRAFT MANAGEMENT CORPORATION

also used the Aircraft in connection with the transportation of persons or property 

prohibited by law, again in violation of the Lease Agreement and FAA regulations. 

66. WSPSL, LLC’s reliance upon AIRCRAFT MANAGEMENT 

CORPORATION’s fraudulent statements has resulted in damage to WSPSL, LLC, 

including devaluation of WSPSL, LLC’s business assets and damage to WSPSL, 

LLC’s business reputation.

COUNT VII, FRAUD – BLUE SKIES AVIATION v. AIRCRAFT 

MANAGEMENT CORPORATION

67. BLUE SKIES AVIATION realleges paragraphs one (1) through 

eighteen (18) as if fully set forth herein.

68. BLUE SKIES AVIATION and JORGE CRUZ on behalf of 

AIRCRAFT MANAGEMENT CORPORATION agreed to allow “conditional, 

continued utilisation (sic.) of the aircraft in accordance with both the lease agreement 

and the amendments stated” in the Addendum. 

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69. Pursuant to Section 5.2(ii) of the Lease Agreement, AIRCRAFT 

MANAGEMENT CORPORATION was not permitted to “operate the Aircraft in 

commercial service, as common carrier, or otherwise on a compensatory or ‘for hire’ 

basis except to the limited extent permitted under Subpart F of Part 91 of the FAR, 

if applicable[.]” [Lease Agreement Section 5.2(ii)].

70. Pursuant to Section 5.2(vi) of the Lease Agreement, AIRCRAFT 

MANAGEMENT CORPORATION was not permitted to “knowingly permit the 

Aircraft to be used for the carriage of any persons or property prohibited by law[.]” 

[Lease Agreement Section 5.2(vi)]. 

71. AIRCRAFT MANAGEMENT CORPORATION falsely represented to 

BLUE SKIES AVIATION that the Aircraft would not be used in connection with 

transport in a commercial or “for hire” capacity, or for the carriage of persons or 

property prohibited by law, in compliance with these sections and Federal Law. 

72. AIRCRAFT MANAGEMENT CORPORATION knew these 

representations were false at the time they were made to BLUE SKIES AVIATION. 

73. AIRCRAFT MANAGEMENT CORPORATION made these 

representations to induce BLUE SKIES AVIATION to rely upon them in agreeing 

to enter into the promissory note and addendum. 

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74. BLUE SKIES AVIATION did in fact rely upon these statements in 

choosing to enter into these agreements with AIRCRAFT MANAGEMENT 

CORPORATION and JORGE CRUZ.

75. These statements were false, and AIRCRAFT MANAGEMENT 

CORPORATION did, in fact, use the Aircraft in connection with commercial flights 

which violated the Lease Agreement and FAA regulations. 

76. AIRCRAFT MANAGEMENT CORPORATION also used the Aircraft 

in connection with the transportation of persons or property prohibited by law, again 

in violation of the Lease Agreement and FAA regulations. 

77. BLUE SKIES AVIATION’S reliance upon AIRCRAFT 

MANAGEMENT CORPORATION’s fraudulent statements has resulted in damage 

to BLUE SKIES AVIATION, including devaluation of BLUE SKIES 

AVIATION’S business assets and damage to BLUE SKIES AVIATION’S business 

reputation.

COUNT VIII, FRAUD – BLUE SKIES AVIATION v. JORGE LUIS CRUZ 

PONCE

78. BLUE SKIES AVIATION realleges paragraphs one (1) through 

eighteen (18) as if fully set forth herein.

79. BLUE SKIES AVIATION and JORGE CRUZ agreed to allow 

“conditional, continued utilisation (sic.) of the aircraft in accordance with both the 

lease agreement and the amendments stated” in the Addendum. 

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80. Pursuant to Section 5.2(ii) of the Lease Agreement, AIRCRAFT 

MANAGEMENT CORPORATION was not permitted to “operate the Aircraft in 

commercial service, as common carrier, or otherwise on a compensatory or ‘for hire’ 

basis except to the limited extent permitted under Subpart F of Part 91 of the FAR, 

if applicable[.]” [Lease Agreement Section 5.2(ii)].

81. Pursuant to Section 5.2(vi) of the Lease Agreement, AIRCRAFT 

MANAGEMENT CORPORATION was not permitted to “knowingly permit the 

Aircraft to be used for the carriage of any persons or property prohibited by law[.]” 

[Lease Agreement Section 5.2(vi)]. 

82. JORGE CRUZ falsely represented to BLUE SKIES AVIATION that 

the Aircraft would not be used in connection with transport in a commercial or “for 

hire” capacity, or for the carriage of persons or property prohibited by law, in 

compliance with these sections and Federal Law. 

83. JORGE CRUZ knew these representations were false at the time they 

were made to BLUE SKIES AVIATION. 

84. JORGE CRUZ made these representations to induce BLUE SKIES 

AVIATION to rely upon them in agreeing to enter into the promissory note and 

Addendum. 

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85. BLUE SKIES AVIATION did in fact rely upon these statements in 

choosing to enter into these agreements with AIRCRAFT MANAGEMENT 

CORPORATION and JORGE CRUZ.

86. These statements were false, and AIRCRAFT MANAGEMENT 

CORPORATION and JORGE CRUZ did, in fact, use the Aircraft in connection with 

commercial flights which violated the Lease Agreement and FAA regulations. 

87. AIRCRAFT MANAGEMENT CORPORATION and JORGE CRUZ 

also used the aircraft in connection with the transportation of persons or property 

prohibited by law, again in violation of the Lease Agreement and FAA Regulations. 

88. BLUE SKIES AVIATION’S reliance upon JORGE CRUZ’S

fraudulent statements has resulted in damage to BLUE SKIES AVIATION, 

including devaluation of BLUE SKIES AVIATION’S business assets and damage 

to BLUE SKIES AVIATION’S business reputation.

COUNT IX, TORTIOUS INTERFERENCE WITH BUSINESS PRACTICE –

WSPSL, LLC v. AIRCRAFT MANAGEMENT CORPORATION

89. WSPSL, LLC realleges paragraphs one (1) through eighteen (18) as if 

fully set forth herein.

90. WSPSL, LLC’S business, in part, is in leasing aircraft pursuant to 

agreements similar to the one between WSPSL, LLC and AIRCRAFT 

MANAGEMENT CORPORATION. 

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91. AIRCRAFT MANAGEMENT CORPORATION was aware that 

WSPSL, LLC had business relationships with other entities and persons.

92. AIRCRAFT MANAGEMENT CORPORATION intentionally used 

the Aircraft for purposes outside of the contemplated scope of the agreement, and 

even in violation of Federal Law. 

93. AIRCRAFT MANAGEMENT CORPORATION’s intentional illegal 

and unpermitted use of the aircraft has disrupted WSPSL, LLC’s relationship with 

other potential customers, and damaged WSPSL, LLC’s reputation in the business 

community. 

94. WSPSL, LLC has suffered damages from this disruption in the form of 

cancelled agreements, complaints which required refunding of payments to 

dissatisfied customers, and loss of potential agreements. 

COUNT X, TORTIOUS INTERFERENCE WITH BUSINESS PRACTICE –

WSPSL, LLC v. JORGE LUIS CRUZ PONCE

95. WSPSL, LLC incorporates by reference and re-alleges paragraphs one 

(1) through eighteen (18) as if fully set forth herein.

96. WSPSL, LLC’s business, in part, is in leasing aircraft pursuant to 

agreements similar to the one between WSPSL, LLC and AIRCRAFT 

MANAGEMENT CORPORATION. 

97. JORGE CRUZ was aware that WSPSL, LLC had business relationships 

with other entities and persons.

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98. JORGE CRUZ intentionally caused the aircraft to be used for purposes 

outside of the contemplated scope of the agreement, and even in violation of Federal 

Law. 

99. JORGE CRUZ’S intentional illegal and unpermitted use of the aircraft 

has disrupted WSPSL, LLC’s relationship with other potential customers, and 

damaged WSPSL, LLC’s reputation in the business community. 

100. WSPSL, LLC has suffered damages from this disruption in the form of 

cancelled agreements, complaints which required refunding of payments to 

dissatisfied customers, and loss of potential agreements. 

COUNT XI, TORTIOUS INTERFERENCE WITH BUSINESS PRACTICE –

BLUE SKIES AVIATION v. AIRCRAFT MANAGEMENT 

CORPORATION

101. BLUE SKIES AVIATION incorporates by reference and re-alleges

paragraphs one (1) through eighteen (18) as if fully set forth herein.

102. BLUE SKIES AVIATION’S business, in part, is in facilitating the 

leasing of aircraft pursuant to agreements similar to the one between WSPSL, LLC 

and AIRCRAFT MANAGEMENT CORPORATION. 

103. AIRCRAFT MANAGEMENT CORPORATION was aware that 

BLUE SKIES AVIATION had business relationships with other entities and 

persons.

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104. AIRCRAFT MANAGEMENT CORPORATION intentionally caused 

the aircraft to be used for purposes outside of the contemplated scope of the 

agreement, and even in violation of Federal Law. 

105. AIRCRAFT MANAGEMENT CORPORATION’s intentional illegal 

and unpermitted use of the aircraft has disrupted BLUE SKIES AVIATION’S

relationship with other potential customers, and damaged BLUE SKIES 

AVIATION’S reputation in the business community. 

106. BLUE SKIES AVIATION has suffered damages from this disruption 

in the form of cancelled agreements, complaints which required refunding of 

payments to dissatisfied customers, and loss of potential agreements. 

COUNT XII, TORTIOUS INTERFERENCE WITH BUSINESS PRACTICE

– BLUE SKIES AVIATION v. JORGE LUIS CRUZ PONCE

107. BLUE SKIES AVIATION incorporates by reference and re-alleges

paragraphs one (1) through eighteen (18) as if fully set forth herein.

108. BLUE SKIES AVIATION’S business, in part, is in facilitating the 

leasing of aircraft pursuant to agreements similar to the one between WSPSL, LLC 

and AIRCRAFT MANAGEMENT CORPORATION. 

109. JORGE CRUZ was aware that BLUE SKIES AVIATION had business 

relationships with other entities and persons.

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110. JORGE CRUZ intentionally caused the aircraft to be used for purposes 

outside of the contemplated scope of the agreement, and even in violation of Federal 

Law. 

111. JORGE CRUZ’s intentional illegal and unpermitted use of the aircraft 

has disrupted BLUE SKIES AVIATION’S relationship with other potential 

customers, and damaged BLUE SKIES AVIATION’S reputation in the business 

community. 

112. BLUE SKIES AVIATION has suffered damages from this disruption 

in the form of cancelled agreements, complaints which required refunding of 

payments to dissatisfied customers, and loss of potential agreements. 

DAMAGES

113. As a direct and proximate result of Defendants’ conduct, Plaintiff has 

suffered, and will continue to suffer, the following damages:

a. Interference with business activities;

b. Loss of benefit under business contract;

c. Decreased value of business equipment; and

d. Loss of business earning capacity.

PRAYER

114. For the above reasons, Plaintiffs pray that Defendants be cited to appear 

and answer herein and that upon final resolution of these claims, Plaintiffs have 

judgment against Defendants for the following:

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e. Actual damages, including general and special damages, in an 

amount in excess of $75,000.00 to be proven at time of trial;

f. Punitive damages;

g. Pre-judgment and post-judgment interest;

h. Costs of suit; 

i. Attorney’s fees; and

j. All such other and further relief to which Plaintiffs may show 

themselves justly entitled under law or in equity.

DEMAND FOR JURY TRIAL

115. Plaintiffs hereby demand a jury trial, pursuant to Rule 38 of the Federal 

Rules of Civil Procedure, on all issues so triable.

Dated: December 9, 2022

 s/ L. Delton Gunn, V, Esq. 

L. Delton Gunn, V, Esquire

Florida Bar No: 1038889

BANKER LOPEZ GASSLER P.A.

501 East Kennedy Blvd., Suite 1700

Tampa, FL 33602

Tel No: (813) 221-1500

Fax No: (813) 222-3066

Email: service-dgunn@bankerlopez.com 

Attorneys for Plaintiffs, WSPSL, LLC and 

BLUE SKIES AVIATION

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY THAT a true and accurate copy of the above and 

foregoing Complaint and Demand for Jury Trial was filed via the CM/ECF filing 

system on December 9, 2022.

 s/ L. Delton Gunn, V, Esq. 

L. Delton Gunn, V, Esquire

Florida Bar No: 1038889

BANKER LOPEZ GASSLER P.A.

501 East Kennedy Blvd., Suite 1700

Tampa, FL 33602

Tel No: (813) 221-1500

Fax No: (813) 222-3066

Email: service-dgunn@bankerlopez.com 

Attorneys for Plaintiffs, WSPSL, LLC and 

BLUE SKIES AVIATION

Case 0:22-cv-62321-XXXX Document 1 Entered on FLSD Docket 12/09/2022 Page 23 of 23