It says so in the original complaint filed 2 years ago:
"9. UnderSea and Madero entered into a Memorandum of Agreement dated February 8, 2013 (the “Agreement”) pursuant to which Madero agreed to deliver bonds issued by the Central Bank of Venezuela in the face amount of $10,000,000 in US currency in exchange for an interest in Pedro Bank Shipwreck Exploration and Excavation, LLC (“Pedro”) and a warrant for 17% of UnderSea’s common stock"
"12. Madero signed the Agreement on February 8, 2013."
"15. Madero and UnderSea also signed the Operating Agreement for Pedro on February 8, 2013."
"18. For example, Ramon Madero wrote UnderSea’s principal, Herbert Leeming, on February 27, 2013 stating that “I am getting a $10,000,000 USD face value bond just for the transaction that I signed with you, this will happen between this coming Friday (March 1) and next Friday (March 8). . . .”"