SFRX fied another Motion For Protective Order.......
It seems the Defendant has the legal foundation (ClearTrust failed to respond under the rules) and so to avoid sanctions being imposed, SFRX is willing to OPEN THE BOOKS. But no personal info of the lenders or others is to be disclosed, as I said it shouldn't be EXCEPT to issue a subpoena.
Notice footnote (1) in red between 4 and 5. The Court rejected the stipluation to liability as SFRX now admits. The Defendant was NOT FOUND GUILTY. That is another myth that has been put forth.
Translation, the Court nor SFRX is busting a gut, as you called it. Of course the filing isn't available unless you pay for it or have connections, so folks can decide if the following is true or not. It should appear on the docket in a day or so.
SFRX is erronously called the Defendant Corporation in (3.), but they are in fact the Plaintiff Corporation.
Regardless, SFRX obviously did this to avoid ClearTrust from being sanctioned becaue they FAILED to respond under the rules. I suppose the Defendant now has some LEVERAGE since SFRX is seeking sanctions because the Defendant "allegedly" violated the ORDER by Judge Cook.
Filing # 31481693 E-Filed 08/30/2015 05:40:58 PM
IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
CIVIL DIVISION
SEAFARER EXPLORATION CORP.,
Plaintiff,
Vs. $17MM Man (edited),
Defendant.
NOTIFICATION OF PRODUCTION
AND MOTION FOR PROTECTIVE ORDER\
Plaintiff, Seafarer Exploration, through the undersigned attorney, pursuant to Rule 1.280, Florida Rules of Civil Procedure, hereby files this notification of production of documents, under such conditions of a protective order which may be granted by the Court to protect such documents and those parties involved from the conduct of the Defendant which would result in improper disclosure of personal and non-disclosable information regarding such matters. Such disclosure is under no existing Court Order or obligation, other than to completely refute the alleged defenses of the Defendant that he was not the cause of damages to the Company, but instead to show that he was the main source of such damages during the relevant time period being tried before the Court for damages in this cause of action. As such the Plaintiff further avers:
1. This cause of action is set for trial upon damages before the Court in a trial without jury on December 1, 2015.
2. Such trial for damages is based upon the earlier stipulation by the Defendant to the Court and Defendant on September 30, 2015, and acceptance of such liability, while the then Court rejected the stipulation for damages. (Emphasis added by SCM)
2. The present case is set for non-jury trial before the Court on the matter of damages in this matter. The Defendant had previously agreed to a stipulation of liability in this matter. This is not a matter of liability at all, and the only issue is the actual damages that the
Defendant caused to the Company through his admitted false internet postings.
3. The Defendant has made requests of documentation, as well as postings and supply of information to outside parties that the decline in market price of the common shares of the Plaintiff Corporation was due to “insider” trading of such shares. Repeatedly the Defendant has set forth that his defense to such damages is that there was somehow some form
of “pump and dump” going on with the Defendant Corporation through the actions of management and family, and related entities of the Corporation, who were all illicitly selling (“dumping”) shares of the stock of the company on the public market.
4. The disclosure of certain matters including the investments and loans of certain persons to the Company has thus far been protected, since the Defendant failed to show any actual proof of any such insider actions, and his speculation is completely belied by the applicable Securities Act laws to whit the Company and all associated persons are and have
been subject to the necessary public filings. None-the-less, the Company is willing to reveal such necessary documentation to the Defendant, under a strict measure of control and protection by the Court from the insipient conspiratorial beliefs of such Defendant and his continued postings and relation of such protected information to outside parties.
1.Such stipulation which was agreed to and rejected by the former Judge, would have allowed the Defendant a complete protection from collection for the first amount of $2,400,000 which he may accrue in personal assets, combined, in the following 90 months after the Settlement and entry of an agreed judgment. The then trial Court rejected such stipulation, and thus the Plaintiff is ready to prove damages, without limitation or protection for the Defendant from collection immediately following any award of damages in this matter.
5. As such the Plaintiff Corporation is now presenting to the Court the complete and applicable loan documents, promissory notes, conversions, and holdings of all applicable parties to which the Defendant has referred to directly or implicitly, including all relatives of
management of the Corporation, directors, and others that the Defendant has communicated of that he avers were involved in wrongful sales of shares. Such documentation completely shows that the Defendant, yet again, continues to make a mockery of the truth, and speaks of that to
which he knows nothing. His wrongful accusations of improper conduct have no foundation in fact and are completely made up with malicious intent, as these documents will show.
6. Such documentation is being presented and available for protected inspection by the Defendant, under an Order of Protection, for such documents that such cannot in any way be shared or published in any manner, and that their examination be limited under order of the
Court.
7. Protection of such production is authorized under Rule 1.280, Florida Rules of Civil Procedure which provides:
(c) Protective Orders. Upon motion by a party or by the person from whom discovery is sought, and for good cause shown, the court in which the action is pending may make any order to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense that justice requires, including one or more of the following:
(1) that the discovery not be had; (2) that the discovery may be had only on specified terms and conditions, including a designation of the time or place; (3) that the discovery may be had only by a method of discovery other than that selected by the party seeking discovery; (4) that certain matters not be inquired into, or that the scope of the discovery be limited to certain matters; (5) that discovery be conducted with no one present except persons designated by the court; (6) that a deposition after being sealed be opened only by order of the court; (7) that a trade secret or other confidential research, development, or commercial information not be disclosed or be disclosed only in a designated way; and (8) that the parties simultaneously file specified documents or information enclosed in sealed envelopes to be opened as directed by the court. If the motion for a protective order is denied in whole or in part, the court may, on such terms and conditions as are
just, order that any party or person provide or permit discovery. The provisions of rule 1.380(a)(4) apply to the award of expenses incurred in relation to the motion. 8. Indeed any and all sales which may have occurred from the conversion of debt which were the result of loans from any such parties, would and did comply with the Securities Act regulations. The Defendant’s implications of wrongdoing are unsupported by any facts, and there has been no wrongful actions of any of the insiders or those related to the Company as the Defendant accuses.
9. Thus all matters to which the Defendant had related and requested which he alleges would have shown wrongful conduct, are being produced under control of the Court, with specific objections that such would be turned over to the Defendant in an uncontrolled manner. As such the Plaintiff Corporation requests that the Court institute a level of control and protection over such documentation and information.
WHEREFORE the Plaintiff, Seafarer Exploration Corporation, hereby notices such production of such materials and moves for Order protecting such information from improper disclosure by the Defendant.
CERTIFICATE OF SERVICE
I hereby certify that this Notice of Production and Motion for Protective Order to was served via email to $17MM Man (edited) at the email of $17MMman@verizon.net (edited) on August 30, 2015.
/s/ Craig A. Huffman
Craig A. Huffman, Esquire
Securus Law Group, P.A.
13046 Racetrack Road #243
Tampa, Florida 33626
Tel: (888) 914-4144
Fax: (888) 783-4712
E-Mail: Craig@securuslawgroup.com
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