J.W. NAPIER 1900-1977
WM. H. NAPIER
LLOYD H. WOLF
DOUGLAS H. NAPIER
WOLF & NAPIER
EIGHTH STREET, SUITE ONE
FORT MADISON, IOWA 52627-2805
August 11, 1998
THOUSAND ADVENTURES FREQUENTLY ASKED QUESTIONS
Dear Thousand Adventures Members,
As you may be aware by now, our law firm initiated a class action
lawsuit against Thousand Adventures on behalf of the 70,000 plus
members of Thousand Adventures for breaching the membership contracts
and various other wrongdoings. We filed this lawsuit because
we felt this was the only way to protect the interest of the
many members who don't have the financial means to take on a "Goliath " company.
By joining all of the claims of the members, we hope that justice
will prevail and the interests of members will be protected.
We have heard from a great number of members who believe they
were misled when they purchased their membership and have not
received what they paid for. Many have expressed their appreciation
that someone is willing to take on their cause. Many have had
the same questions and this letter is an attempt to address the
majority of the most common questions.
What is the class action lawsuit about? The class action
lawsuit was filed in Iowa in May of 1997 on behalf of
all Thousand Adventures members no matter where they
signed up. The suit alleged that TAI misrepresented important
facts when memberships were sold, they used unfair methods
to induce sales, they breached the guaranteed resale
agreements, and they breached the terms of the membership
agreements. The petition sought rescission or cancellation
of the contract and damages (such as refunds) for the
What do I have to do to join the class action lawsuit?
Nothing. You are included in the class automatically.
If you do not want to be included in the class, you have
the right to "opt out " and can do so by simply mailing
a letter to our office stating you wish to be excluded
from the class. If you opt out, you will not be included
in any recovery that may obtained in this case. Once,
you opt out, you cannot rejoin the class.
Do I have to pay anything to be a part of this lawsuit?
No. Neither will you be responsible to pay for any of
the expenses should the lawsuit be unable to collect
any damages. Those expenses are being advanced by our
law firm. Our law firm will be compensated only in the
event of a recovery and will be paid from the proceeds
that are recovered or by the parties that we recover
What is the status of the class action suit? Thousand
Adventures failed to appear or defend the lawsuit and
as a result judgment was entered against them. The court
certified the class and awarded partial damages to the
class for expenses. The court was to have another hearing
at a later date to determine actual damages. That hearing
has not occurred due to the bankruptcy of TAI.
So you got a judgment for me, what does that mean to me?
At this point, it means you are part of a class that
carries a lot of weight in the bankruptcy court as a
major creditor and it entitles you to share in any recovery
of money that may be obtained. It also allows us to address
common complaints and problems that members are having
with various collection agencies and other companies
that are trying to get the members to pay them dues or
Can I expect to get any money out of this lawsuit? At
this point, that is difficult to say. Many of the assets
that had value have been transferred out of Thousand
Adventures to a separate company called RV Holdings.
The bankruptcy trustee is attempting to get these assets
returned. In addition, the trustee and our firm are pursuing
other possibilities that would recover money for the
members. For those members who financed the purchase
of their memberships by signing a retail installment
contract, there may be some recovery of money from the
lenders that received the members' payments. We are working
very hard at trying to recover some money for the members.
It is unlikely that anyone will get a full refund.
Why did TAI file for bankruptcy protection? Actually,
we filed an involuntary bankruptcy petition against Thousand
Adventures, Inc. because we became aware that many of
TAI's assets were "leaking" out and being transferred
to insiders, such as creditors and related parties. In
order to stop the transfers and recover those assets,
it was necessary to put TAI under the supervision of
the bankruptcy court.
Aren't there several Thousand Adventures bankruptcies?
Yes. Several of the subsidiaries also voluntarily filed
separate bankruptcy petitions before we got involved.
Most were filed in an attempt to stall foreclosure proceedings
against some of the campgrounds. Most have been converted
to Chapter 7 liquidation bankruptcies or have been dismissed.
The effect of having so many subsidiaries in bankruptcy
is to destroy any hope that Thousand Adventures can reorganize
into a stable campground organization.
How did TAI get into such a financial mess? According
to the many witnesses that have testified in this case,
the primary reason TAI got into trouble was it grew very
rapidly adding new campgrounds and when they attempted
to get global financing to put the whole package together,
they had at least two funding attempts fail. When the
financing didn't work out, the parks were facing foreclosure
and thus the rapid dismantling of TAI.
What is Travel America? Travel America was formed in mid-1997
for the purpose of operating a campground system. It
is a separate and distinct company from Thousand Adventures.
Although they share the same monogram "TAI", they are
not the same company. The company was formed by one of
the directors of a major lender of TAI with the intent
that Travel America would operate the campgrounds so
that the members would continue to make payments on the
retail installment contracts that the lenders were still
holding. Steve Alleman, a former employer of TAI, now
works for Travel America and has testified under oath
that "No Thousand Adventures member has an obligation
to pay Travel America any dues." Travel America is offering
a NEW membership program and if Thousand Adventures members
decide they don't want to continue to pay dues, they
don't have to join Travel America. Unfortunately, Travel
America did not make this clear when they sent dues notices
to Thousand Adventures members. Many members believed
that Thousand Adventures had changed its name and the
members were required to continue to pay the dues. If
you get a dues statement from Travel America, simply
write back to the address on the statement and tell them
you DO NOT WANT TO BE A MEMBER OF TRAVEL AMERICA and
to take your name off of their mailing list. Keep a copy
of your letter.
Travel America offered to reduce the outstanding balance
on my retail installment contract if I would sign a new
contract with Travel America. Is this a good deal? I
have seen some of the offers made to members and am very
concerned by what may be happening here. The offers have
promised to reduce the outstanding amounts, but if you
fail to pay Travel America, then their letter informs
you that all of the amounts owed to Thousand Adventures
may become due again. First of all, I don't understand
how Travel America can alter your installment contract
which is between you and Thousand Adventures. Secondly,
the default judgment against TAI rescinded the membership
contracts and thus eliminated the members' obligation
to pay any more on the retail installment contracts.
My concern is that if you sign a new contract with Travel
America, it may be hard to get out from under it. If
you have signed such a contract, please send me a copy
of it along with any other documentation you have received
from Travel America.
Do I still have to pay dues? Thousand Adventures, Inc.
has ceased to operate any campgrounds. Some of the subsidiaries
still own and operate some campgrounds, but those subsidiaries
are no longer owned by Thousand Adventures, Inc.. Most
have been transferred to Travel America or are controlled
by Travel America. There has been much confusion because
Travel America has sent dues collection notices to TAI
members, but TAI members have no contract with Travel
America. If you think you will benefit from Travel America's
program, then you may want to join Travel America and
pay dues. If you doubt that you will get your money's
worth or can find a better offer somewhere else, then
Do I still have to make payment on my retail installment
contract? The default judgment against Thousand Adventures
effectively rescinds the membership contracts. As a result,
the members obligation to continue paying on the retail
installment contracts also should cease.
What about my Guaranteed Resale Agreement? Unfortunately,
the resale agreement was tied to continued sales of TAI
memberships. The resale agreement is virtually worthless.
I have seen some correspondence from TRAVEL AMERICA that
SEEMS TO SUGGEST you can still sell the membership, but
THAT YOU HAVE TO STAY CURRENT WITH PAYMENTS. NONSENSE!!!
Travel America has nothing to do with your resale agreement.
They have specifically avoided any commitment to assume
responsibility for those resale agreements. Besides,
how can you sell a membership to Thousand Adventures
when you know it has no value or use???
Thank you for your continued support and faith in our efforts.
//Douglas H. Napier//
NAPIER, WOLF & NAPIER
Don't give in