Dragging You to Court Over Sixty Days of Billing Disputes and a Paint Job

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HORNSWAGGLED

The Newsletter Sea Tow Doesn't Want You to Read

Special Edition | February 2026 | Public Court Filings

THE DRAGNET

Sea Tow fires 17 subpoenas at people who have nothing to do with its lawsuit — including an elderly couple in Apollo Beach, a federal agency, an insurance giant, and a towing company in Texas.

If it can happen to them, it can happen to you.

──────────────────────────────────────────────────────────────────── Dear Sea Tow Franchisee, Picture this: You wake up one morning to someone banging on your door. It's the guy serving you a federal subpoena. He's just doing his job, but you are confused. You are not a party to any lawsuit.

You have never been deposed in your life.

You barely know the people named in the case.

And yet here it is — a command, on official United States District Court letterhead, telling you that you must hand over five and a half years of business records in less than two weeks, and appear for a deposition the following month.

That is not a hypothetical. It happened — twice, in two waves — to seventeen real people and businesses across Florida, Ohio, Illinois, and Texas in February 2026. It is documented in federal court records that anyone can read. And the entity that sent those subpoenas was Sea Tow Services International, Inc.

This edition of Hornswaggled walks you through every name on that subpoena list, explains why a federal court is being asked to throw all seventeen subpoenas out, and — most importantly — helps you understand what Sea Tow's conduct in this case tells you about the risks you face simply by operating under their flag.

The Lawsuit: A Six-Year War Over A Tampa Bay Franchise

════════════════════════════════════════════════════════════════════ The case is Sea Tow Services International, Inc. v. Tampa Bay Marine Recovery, Inc., et al., Case No. 2:20-cv-02877-WFK-SIL, filed in the Eastern District of New York in 2020. Sea Tow sued its own former franchisee — Erich Jaeger and his companies — claiming breach of a management agreement and trademark infringement.

The Jaegers didn't roll over. They filed counterclaims and third-party claims against Mitchell Stein (Sea Tow's lawyer, who is simultaneously a named third-party defendant in the same case) and Joseph Frohnhoefer III, alleging violations of the New York Franchise Sales Act, among other things.

Six years later, the case has been dramatically narrowed. What remains are two surviving issues: a breach of contract dispute over management fees from May and June of 2020 — two months — and a trademark claim about the appearance of Jaeger's boat. That's it.

Sixty days of billing disputes and a paint job.

Most of the Jaegers' counterclaims remain, BTW.

Yet on February 5 and February 10, 2026, Sea Tow served seventeen subpoenas on people and businesses that had nothing to do with those two surviving issues — demanding records going back to June 26, 2020, through the present day. That is five and a half years of documents for a case about two months of fees.

Six weeks before the subpoenas landed, Judge Locke had already declared that document discovery was closed. On December 29, 2025, he denied Sea Tow's third motion to compel, describing its requests as so "overbroad that they read like an attempt to obtain the discovery the Court denied on procedural grounds." The subpoenas that followed were, point for point, the same documents the Court had just refused to order.

┌─────────────────────────────────────────────────────────────┐ │ "Document discovery in this case is closed." │ │ — Judge Steven I. Locke, December 29, 2025 │ └─────────────────────────────────────────────────────────────┘ ════════════════════════════════════════════════════════════════════

The 17 People Sea Tow Tried To Drag Into Federal Court

════════════════════════════════════════════════════════════════════ The following names and dates are drawn directly from public federal court filings — Documents 311-1 and 311-2, filed on the PACER docket for Case No. 2:20-cv-02877-WFK-SIL on February 18, 2026. These are facts, not allegations.

──────────────────────────────────────────────────────────────────── WAVE ONE — Subpoenas filed February 5, 2026 Filed with the Court as Document 311-1 on February 18, 2026 ──────────────────────────────────────────────────────────────────── Document production deadlines ranged from February 19 to February 23 — giving recipients as little as two weeks to comply.

1. DR. RUSS L'HOMMEDIEU

Docs due: February 19, 2026 | Deposition: March 5, 2026 NOTE: Private individual. His company, Cross Bay Marine, Inc., wasn't incorporated until May 2021 — 14 months after the May–June 2020 events at the center of the surviving claims.

2. KAREN L'HOMMEDIEU

Docs due: February 19, 2026 | Deposition: March 5, 2026 NOTE: Dr. L'Hommedieu's spouse. Subpoenaed individually at the same home address. Same 14-month timing problem.

3. U.S. COAST GUARD

c/o Department of Homeland Security 2707 Martin Luther King Jr. Ave., SE, Washington, D.C. 20528-0485 Docs due: February 20, 2026 | Deposition: March 6, 2026 NOTE: Sea Tow subpoenaed a federal agency of the United States.

4. Progressive Casualty Insurance Company

(The Progressive Corporation) Docs due: February 20, 2026 | Deposition: March 6, 2026 NOTE: One of the largest auto and marine insurers in the country, headquartered in Ohio.

5. MORGAN MARINE SALVAGE & RECOVERY, LLC

Docs due: February 23, 2026 | Deposition: March 9, 2026 NOTE: A Florida marine salvage company. Not a party to the case.

6. CITY OF ST. PETERSBURG, FLORIDA

Custodian of Public Records, City Clerk's Office

Deposition: March 9, 2026

NOTE: Sea Tow subpoenaed a municipal government.

──────────────────────────────────────────────────────────────────── WAVE TWO — Subpoenas filed February 10, 2026 Filed with the Court as Document 311-2 on February 18, 2026 ──────────────────────────────────────────────────────────────────── Five days after Wave One. Eleven more subpoenas. Document production demanded by February 25–27. Depositions scheduled for March 11–13.

7. COMPASS MARINE SERVICES, INC.

Attn: Patrick Farrell

Docs due: February 25, 2026 | Deposition: March 11, 2026

8. IAA HOLDINGS LLC

Attn: Mark Oliver

Docs due: February 25, 2026 | Deposition: March 11, 2026 NOTE: A holdings company based in suburban Chicago.

9. A-C-T Environmental & Infrastructure, Inc.

Docs due: February 25, 2026 | Deposition: March 11, 2026

10. VESSEL TRANSPORT LLC

Attn: Tim Garcia Docs due: February 25, 2026 | Deposition: March 11, 2026

11. Intrepid Marine Salvage & Towing Inc.

Attn: Patrick Lamb

Docs due: February 26, 2026 | Deposition: March 12, 2026

12. THE MONEY TREE FINANCIAL SERVICES

Docs due: February 26, 2026 | Deposition: March 12, 2026

13. RYAN HURLEY [ SEE NOTE BELOW ]

Docs due: February 26, 2026 | Deposition: March 12, 2026 NOTE: Ryan Hurley also appears on Sea Tow's party deposition list — meaning Sea Tow attempted to depose the same person twice in the same case.

14. FLAGSHIP TOWING L.L.C.

Attn: Christopher Riley

Docs due: February 26, 2026 | Deposition: March 12, 2026 NOTE: A towing company in Texas. Two Texas addresses listed.

15. DUKE OVERSTREET I CAN DO TOWING INC.

Docs due: February 27, 2026 | Deposition: March 13, 2026

16. SOUTHWEST FLORIDA MARITIME INC.

Docs due: February 27, 2026 | Deposition: March 13, 2026 17. MGD, LLC Attn: Preston Cockey Docs due: February 27, 2026 | Deposition: March 13, 2026 ────────────────────────────────────────────────────────────────────

WHAT DID SEA TOW DEMAND FROM ALL 17?

Every subpoena contained an Appendix A demanding the same four categories of documents:

(1) All communications with the Jaegers, Maverick Marine Services, Cross Bay Marine, and any Sea Tow franchisee relating to Sea Tow Tampa Bay.

(2) All records about vessels sold by or on behalf of the Jaegers. (3) All social media posts about the Jaegers or their businesses.

(4) All communications with the U.S. Coast Guard about maritime licensing or franchising.

Time period demanded: June 26, 2020 to the present day.

That is five and a half years of documents.

For a case about two months of fees. . . and a paint job.

That's all they are supposed to be talking about.

The Math Sea Tow Can'T Do — Or Doesn'T Care To

════════════════════════════════════════════════════════════════════ On February 2, 2026 — three days before the first wave of subpoenas went out — Judge Locke issued a scheduling order: each side gets ten depositions. Not a suggestion. A court order.

Sea Tow had already scheduled six party depositions:

Erich Jaeger, Abigail Jaeger, Kathleen Moreno, Ryan Hurley, Tampa Bay Marine Recovery Inc., and Tampa Bay Marine Towing & Service Inc. Six down. Four remaining.

Then Sea Tow served seventeen non-party subpoenas on February 5 and February 10, 2026.

6 party depositions + 17 non-party subpoenas ───────────────────────── 23 total - 10 court-authorized ─────────────────────────

13 OVER THE LIMIT

And Ryan Hurley was counted twice — once as a party deposition, once as a non-party subpoena.

Federal Rule of Civil Procedure 30(a)(2)(A)(i) prohibits taking more than ten depositions without leave of court. Sea Tow did not seek leave. It simply sent the subpoenas.

This Is Not An Isolated Incident — It'S A Pattern

The Trademark Sea Tow Lost — And Didn'T Tell Anyone

In 2017, the Trademark Trial and Appeal Board cancelled Sea Tow's registered trademark in the color yellow for marine towing vehicles. The cancellation came after Sea Tow engaged in two and a half years of systematic obstruction during the TTAB proceedings — the same discovery games, the same stonewalling, the same delay tactics now on display in the federal case.

The loss of that yellow color trademark matters for every franchisee reading this. Sea Tow's trademark claims against the Jaegers include allegations about the appearance of their boats. But Sea Tow lost the exclusive right to "yellow" for marine towing eight years ago. Did Sea Tow tell its franchisees? Did it update its branding requirements? Did it disclose this in its Franchise Disclosure Document — which, as we've reported, may not legally exist?

────────────────────────────────────────────────────────────────────

THE TIMELINE OF REPEATED DENIALS

──────────────────────────────────────────────────────────────────── February 16, 2024 Sea Tow's second motion to compel denied as untimely.

February 27, 2024

Sea Tow immediately subpoenas non-party Maverick Marine Services, seeking the same documents the Court just refused to order.

March 19, 2024

Judge Locke limits discovery to the two surviving claims.

July 17, 2025

Sea Tow's objection to Judge Locke's limitations denied by District Judge Kuntz.

Mid-2024

Sea Tow files a parallel state court action in New York, asserting the very claims that were dismissed from the federal case.

Late 2024

New York Supreme Court Justice Andrews stays the state action, noting explicitly that Sea Tow appears to be using it to obtain discovery for the federal case.

December 29, 2025

Third motion to compel denied. Court declares document discovery closed. Court also finds that Sea Tow made a FALSE STATEMENT — claiming the Jaegers hadn't produced damages documents when they had in fact produced over 9,000 pages of bates-stamped records.

February 2, 2026

Judge Locke issues scheduling order: 10 depositions per side.

February 5, 2026

Wave One. Six non-party subpoenas served. Filed with the Court as Document 311-1 on February 18, 2026.

February 10, 2026

Wave Two. Eleven more non-party subpoenas served. Filed with the Court as Document 311-2 on February 18, 2026.

February 18, 2026

The Jaegers file a motion for protective order and to quash all 17 subpoenas (Documents 311, 311-3, 311-4).

──────────────────────────────────────────────────────────────────── The Jaegers' attorneys put it plainly in their motion papers: Sea Tow's subpoenas seek "the very documents the Court has twice denied by motion to compel as irrelevant and disproportionate."

This isn't a discovery dispute. It's a deliberate strategy.

WHAT THIS MEANS FOR YOU — RIGHT NOW

════════════════════════════════════════════════════════════════════ If you operate a Sea Tow franchise, you need to understand something the Tampa Bay case makes impossible to ignore: Sea Tow's litigation tactics treat anyone connected to a disputed franchise as fair game for a subpoena.

Look at that list again.

An elderly couple in Apollo Beach who apparently tried

to buy the Tampa Bay franchise and apparently got screwed.

(As per SunBiz Statement of Fact filing under Cross Bay Marine) An insurance company in Ohio that insured some boats.

1. A salvage company in the Florida Panhandle.

A towing company in Texas.

A municipal government.

The United States Coast Guard

None of them are parties. None of them were part of the original dispute. And yet each received a federal subpoena commanding them to produce records and appear for deposition — with their home or business address printed on official United States District Court letterhead, filed in a public federal docket.

┌─────────────────────────────────────────────────────────────┐ │ "The Jaegers do not want to upset in any way the │ │ depositions already ordered by Your Honor. They simply │ │ want to stop the indiscriminate targeting of innocent │ │ non-parties." │ │ │ │ — Jaegers' attorneys, Document 311, Feb. 18, 2026 │ └─────────────────────────────────────────────────────────────┘ Now think about your own situation. If Sea Tow has a dispute with you — over fees, territory, a boat's color, a termination — who in your orbit could end up on a subpoena list?

Your insurer?

Your bank?

Your marina neighbor?

A company that transported your vessel once?

A city permit office?

Your Mom?

The answer, if this case is any guide, is: anyone Sea Tow thinks might have a document they want.

Most people are thinking that doing business with ANY Sea Tow Franchise may not be worth the risk of going to court.

. . . and the Coast Guard?

What are they thinking?

The Franchise Disclosure Question Sea Tow Still Hasn'T Answered

──────────────────────────────────────────────────────────────────── Sea Tow publicly markets itself as a franchise network — on its website, on LinkedIn, in press coverage, and in the SBA Franchise Directory. Sea Tow's President Kristen Frohnhoefer has personally described Sea Tow on LinkedIn as operating a "franchise network."

Yet in federal court, Sea Tow's attorney Mitchell Stein has argued that Sea Tow "does not collect a franchise fee, placing it outside the ambit of the [New York Franchise Sales Act]."

These two positions cannot both be true. Either Sea Tow is a franchise and must comply with registration and disclosure requirements — or it is not a franchise, and every "franchise"

promise made to you may be legally unenforceable.

Ask your attorney which one it is.

MARCH 11, 2026: THE DATE THAT MATTERS

════════════════════════════════════════════════════════════════════ At 10:00 AM on March 11, 2026, attorneys will appear before Magistrate Judge Steven I. Locke at 100 Federal Plaza, Central Islip, New York. The Jaegers have asked the Court to:

1. Issue a protective order prohibiting enforcement of all 17 non-party subpoenas.

2. Quash all 17 subpoenas under Federal Rule of Civil Procedure 45. 3. Direct Sea Tow to notify each non-party that the subpoenas are unenforceable.

4. Award the Jaegers their attorneys' fees and costs.

5. Grant such other relief as the Court deems just and proper.

Sea Tow's opposition is due March 3. The Jaegers' reply is due March 10. Then Judge Locke rules.

If the Court grants the motion, all seventeen subpoenas die. The non-parties — are released from compliance.

This tells you something about how Sea Tow uses

litigation — and what it's willing to do to people who get in its way, or who happen to be adjacent to someone who did.

Questions Worth Asking At Your Next Meeting

════════════════════════════════════════════════════════════════════ You have the right to ask Sea Tow leadership direct questions about these matters. Here are five worth raising:

1. A federal court found that Sea Tow made a false statement in its December 2025 motion papers about what documents had been produced. What steps are being taken to ensure accuracy in future filings?

2. Sea Tow's yellow color trademark was cancelled by the TTAB in 2017 after a finding of systematic discovery obstruction. Was this disclosed to franchisees? Has the Franchise Disclosure Document been updated to reflect it?

3. If Sea Tow has a dispute with my franchise, what is to prevent my insurers, bankers, vendors, and neighbors from receiving federal subpoenas?

4. Sea Tow is simultaneously the plaintiff in a federal lawsuit and listed as a principal in a third-party action in the same case.

5. Is Sea Tow registered to offer franchises with the New York Department of State?

6. Has any franchisee received a compliant Franchise Disclosure Document?

7. Mitchell Stein, Sea Tow's outside counsel, is himself a named third-party defendant in the same litigation. How is he advising Sea Tow on strategy when he has personal exposure in the case?

These are not hostile questions. They are the questions any reasonable businessperson would ask before renewing a franchise agreement, before signing a new management contract, or before accepting any representation from corporate leadership about the legal strength of their position.

A FINAL WORD

════════════════════════════════════════════════════════════════════ The people who received those seventeen subpoenas on February 5 and February 10 did not ask to be part of a six-year franchise war. They ran their businesses, answered their phones, and one morning found some dude banging on the door. Some of them had their home addresses printed on official United States District Court letterhead and filed in a public federal docket.

The Jaegers' attorneys fought back — hard and fast. Within days of the second wave, they had a Notice of Motion filed, a Memorandum of Law written, and an emergency request before the judge.

But the lesson for every Sea Tow operator is not about the outcome of one court hearing. The lesson is about the pattern. When a company uses the federal court system to pursue dismissed claims through non-party subpoenas, files parallel state court actions to get around federal discovery limits, and — according to a federal judge — makes false statements in motion papers.

──────────────────────────────────────────────────────────────────── Stay informed. Stay protected. Your livelihood depends on it.

Fair winds, Hornswaggled We may or may not be watching.

We may or may not be listening.

We definitely have more to say.

"In a world of corporate plunder, sometimes you need someone willing to read the docket."

DISCLAIMERS & SOURCE DOCUMENTATION

════════════════════════════════════════════════════════════════════ All information in this newsletter is drawn from publicly available documents filed on the PACER docket for Case No. 2:20-cv-02877-

WFK-SIL (E.D.N.Y.).

PRIMARY SOURCES:

Document 311 Emergency Letter Motion for Temporary Protective Order — Rosen Karol Salis PLLC, Feb. 18, 2026 Document 311-1 Exhibit A — Wave One Subpoenas (42 pp.)

PageIDs 12288–12329

Subpoenas dated February 5, 2026

Filed with the Court February 18, 2026

Document 311-2 Exhibit B — Wave Two Subpoenas (69 pp.)

PageIDs 12330–12398

Subpoenas dated February 10, 2026

Filed with the Court February 18, 2026

Document 311-3 Exhibit C — Notice of Motion for Protective Order and/or to Quash Filed February 18, 2026 Document 311-4 Exhibit D — Memorandum of Law in Support (22 pp.)

Filed February 18, 2026

Documents are accessible via PACER at pacer.uscourts.gov.

SunBiz:

This newsletter is not legal advice. All characterizations are based on filed documents. Consult a licensed franchise attorney for your specific situation.

NY Attorney General's Investor Protection Bureau: (212) 416-8222 This content was generated and/or enhanced with the assistance of artificial intelligence (Claude, Anthropic). All facts have been verified against source documents. AI-assisted content should be independently verified. This is not legal advice.

Hornswaggled | Public Court Filings | E.D.N.Y.

════════════════════════════════════════════════════════════════════ Ahoy, Mateys and Landlubbers Alike, Ye be askin' who be Hornswaggled?

Aye, that be a question worthy of ponderin', though we may or may not be obliged to give ye a straight answer.

(Ah - before we forget, if this message got to you in a bottle floatin' on the internet and you want the scoop directly from the crow's nest, respond to this email and we will add ya to the list!!!)

We may or may not be:

A single scallywag with a quill and a grudge

A motley crew of seafarin' souls who've been hornswaggled by corporate buccaneers Yer neighbor at the annual meeting, sippin' grog and takin' notes Someone dockin' at a certain harbor on Hummel Avenue as ye read this very scroll Current crew members who've grown weary of sailin' under a tattered flag Former hands what got marooned after years of loyal service Landlubbers with access to the ship's log Ghosts in the rigging what see all and say nothin'... until now Our Mission Be Crystal Clear (even if our identities be foggier than Point Judith): We sail these troubled waters to inspire thoughtful questions about yer business, yer future, and whether the ship ye be sailin' on has sprung more leaks than the captain be admittin'.

We may or may not have witnessed—or been keelhauled by—what some might call a "Frochise" business model (that be a franchise what acts more like a noose than a partnership, savvy?).

We believe the time has come for true transparency to be the new corporate culture. No more hidin' behind the legal fog.

Ye be heading for a legal Malstrom and Ye ought to know when to batten down and make fast the deck tackle.

No more makin' honest sailors walk the plank whilst the officers in the great cabin count their doubloons.

A Word on Our Tales:

Some of our yarns may feature composite characters—a bit of this captain mixed with that first mate, perhaps a dash of a deckhand thrown in for flavor. We do not acknowledge, confirm, or deny that these characters represent any person, living or dead, drowned or saved, real or imagined.

They be as fictional as mermaids... or as real as the Kraken, dependin' on who ye ask. About the Dangers of Our Trade:

Far too many brave souls risk their lives in the marine towing and salvage business.

They battle storms, rogue waves, and vessels in distress—and that be hard enough without also fightin' battles from within their own fleet.

When the greatest danger comes not from Poseidon himself, but from the corporate quarterdeck, something be terribly wrong with how we chart our course. Our Sources and Methods:

All information we provide be based on publicly available documents—court filings, federal records, treasure maps left in plain sight (also known as corporate filings), and such.

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We not be responsible for any errors, omissions, or deviations from the public record. We caution all readers to read the source documents for themselves. Don't take our word for it—verify with yer own eyes, savvy?

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Seek ye professional counsel for matters of law and coin.

So, who be Hornswaggled?

We be the voice in the crow's nest yellin' "Hard Alee!" when the corporate ship be headin' for the rocks.

We be the conscience that asks uncomfortable questions at midnight when the watch changes.

We be whoever needs to be, whenever truth needs tellin'.

Or perhaps we be nobody at all—just the wind whistlin' through the riggin', carryin' tales that needed to be told.

The only certainty?

We may or may not be watchin'.

We may or may not be listenin'.

And we may or may not have more stories to tell.

Fair winds and following seas, Hornswaggled We may or may not be a crew.

We may or may not be near ye right now.

We definitely be committed to transparency...

even if we be mysteriously opaque about ourselves.

"In a world of corporate plunder, sometimes ye need pirates to restore honor to the seas."

AI-GENERATED CONTENT DISCLAIMER

AI Involvement

This document was generated using Claude (Anthropic), an artificial intelligence language model, based on analysis of legal documents, court filings, and other materials provided in a project knowledge base. The AI synthesized information from these source documents to create a narrative analysis of the legal proceedings described herein.

Source Materials

The content is derived from:

Court documents filed in Case 2:20-cv-02877-WFK-SIL (U.S. District Court, Eastern District of New York) Court documents filed in Case 2:25-cv-02145 (U.S. District Court, Eastern District of New York) Legal pleadings, motions, memoranda, and orders Docket entries and case transcripts Attorney correspondence and discovery documents Analytical articles based on public PACER filings All dates, case numbers, document references, and quoted material are derived from these source documents to the best of the AI's ability to accurately represent them.

Not Legal Advice

This document is for informational and analytical purposes only. It does not constitute legal advice, and should not be relied upon as such. The analysis, interpretations, and conclusions presented represent one perspective on complex legal proceedings and should not be considered definitive or authoritative. Readers should:

Consult with licensed attorneys for legal advice specific to their situations Independently verify all factual claims and legal citations Review original court documents and filings through PACER or other official sources Recognize that legal proceedings are ongoing and facts may change Limitations and Caveats 1. Interpretation Bias: The narrative structure and framing reflect editorial choices made in synthesizing the material. Other reasonable interpretations of the same documents may exist. 2. Document Access: The AI's analysis is limited to documents provided in the project knowledge base. Other relevant documents may exist that were not analyzed.

3. Temporal Snapshot: This document reflects information available as of October 31, 2025. Court proceedings continue to evolve, and rulings or developments after this date are not included. 4. No Attorney-Client Relationship: Nothing in this document creates an attorney-client relationship between any reader and any person or entity.

5. Verification Recommended: While efforts were made to accurately represent source materials, readers should independently verify all claims, especially before taking any action based on this information. Purpose This document was created to:

Provide a comprehensive narrative timeline of the legal proceedings Synthesize complex legal documents into accessible prose Highlight patterns and connections across multiple filings Support informed discussion of franchise law compliance issues Parties' Rights All parties named in this document retain their full legal rights. Nothing herein should be construed as prejudging the outcome of pending litigation. Courts of competent jurisdiction will make final determinations on all disputed matters.

Public Records

The legal proceedings described herein are matters of public record. Court documents referenced can be accessed through the Public Access to Court Electronic Records (PACER) system at https://pacer.uscourts.gov or by visiting the clerk's office of the U.S. District Court for the Eastern District of New York. Questions or Corrections If you believe any factual statement in this document misrepresents source materials or contains errors, please consult the original court filings for authoritative information.