WTF (Welcome to Florida): The L’Hommedieu Story

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HORNSWAGGLED

A N A N O N Y M O U S I N V E S T I G AT I V E N E W S L E T T E R

Following the money, the filings, and the wake.

S P E C I A L E D I T I O N • M A R C H 2 0 2 6 • F R O M T H E P U B L I C R E C O R D

The L'Hommedieu Story:

Sour Ces: M.D. Fla. Case Nos. 8: 26-Mc-00008-Kkm-N H A & 8: 26-Mc-00009-Sdm-Tgw •

E.D.N.Y. No. 2 : 20-Cv-0287 7 -Wfk-Sil • Flor Ida Divi Sion Of Cor Por Ations (Sunbiz) •

H Illsboroug H County S H E R Iff' S Office • Flor Ida D H Smv • Jpmorgan C H Ase Bank

R ECORDS • FILED MA R C H 1 1 , 2026

The story of Dr. Russell L'Hommedieu and his wife Karen is, at its core, a story about trust. He was a federal employee, a Doctor of Physical Therapy, a man who had spent years building a clinical reputation and a professional life. And he trusted the Frohnhoefers — the family that ran Sea Tow Services International. According to his sworn declaration filed in federal court, he had known them personally for nearly three decades. That trust, and what happened to it, is now the subject of court filings in two Middle District of Florida miscellaneous proceedings.

What follows is drawn entirely from public court records, Florida state records, and documents filed under penalty of perjury. Nothing herein is speculation. The citations speak for themselves.

I. The Pitch: A Friend with an Offer

In or around mid-2021, Joseph J. Frohnhoefer III and Kristen Frohnhoefer — CEO and President, respectively, of Sea Tow Services International, Inc. ("STSI") — approached Dr. L'Hommedieu about acquiring an ownership interest in the Sea Tow Tampa Bay franchise opportunity.

M.D. Fla. Doc. 12 (mc-00008), Page 3: "In or around mid-2021, Dr. L'HommeDieu was approached by Sea Tow principals Joseph J. Frohnhoefer III and Kristen Frohnhoefer, longstanding personal acquaintances of nearly three decades, about acquiring an ownership interest in the Sea Tow Tampa Bay franchise opportunity. The Frohnhoefers presented term sheets and documents explicitly describing the arrangement as a franchise in which Dr. L'HommeDieu would have sole discretion and authority."

The pitch was compelling. The term sheets described the arrangement explicitly as a franchise. Dr. L'Hommedieu would have sole discretion and authority. The opportunity had the imprimatur of people he had known and trusted for the better part of his adult life — the children of Joseph Frohnhoefer II, the late founder of Sea Tow. He believed them. He acted on that belief in the most consequential ways a person can. II. The Sacrifice: Resignation, Relocation, Investment In reliance on the Frohnhoefers' representations, Dr. L'Hommedieu took three irreversible steps.

M.D. Fla. Doc. 12 (mc-00008), Pages 3–4: "In reliance on these representations, Dr. L'HommeDieu resigned from federal employment, sold his home in Southold, New York, and relocated with his wife Karen to Apollo Beach, Florida in September 2021, investing significant cash, assets, and unpaid labor — including the purchase of a 2019 RAM 2500 diesel truck (VIN 3C6URSDL0KG544190) for use in the business — all before Sea Tow provided actual deal documents for review."

He resigned from federal employment. He sold his home in Southold, New York. He and Karen relocated to Apollo Beach, Florida — uprooting an established life, a clinical reputation, a professional network built over decades. He purchased a 2019 RAM 2500 diesel truck for the business. He committed significant cash and unpaid labor. He did all of this before Sea Tow provided actual deal documents for review. "Nearly four years later, Dr. L'HommeDieu and Karen — now in their late fifties, having uprooted their lives and finances at Sea Tow's principals' urging — are being compelled to serve as instruments of Sea Tow's litigation against third parties with whom they have no relevant connection."

— M.D. FLA. DOC. 12 (MC-00008), PAGE 2

III. The Company: Cross Bay Marine, Inc.

On May 21, 2021, Dr. L'Hommedieu incorporated Cross Bay Marine, Inc. with the Florida Department of State, Division of Corporations. It was assigned Florida Document Number P31000048227. He was listed as the sole officer, sole director, and sole shareholder — all 200 shares were allocated to him. One day later, on May 22, 2021, the IRS issued an Employer Identification Number with Dr. L'Hommedieu identified as the Responsible Party.

M.D. Fla. Doc. 12 (mc-00008), Page 4: "He incorporated Cross Bay Marine, Inc. (Florida Document No. P31000048227) on May 21, 2021 as its sole officer, director, and shareholder, and obtained a federal Employer Identification Number on May 22, 2021, identifying him as the Responsible Party. Cross Bay Marine was formed specifically so that Dr. L'HommeDieu could serve as the sole contract provider of towing and salvage services for Sea Tow Tampa Bay during the interim period while the franchise acquisition was being negotiated and finalized."

The purpose of Cross Bay Marine was explicit and documented: it was the vehicle through which Dr. L'Hommedieu would provide towing and salvage services to Sea Tow Tampa Bay while the franchise acquisition was being negotiated. He was not an employee of Sea Tow. He was the owner of an independent subcontracting company. This distinction would later become the subject of misrepresentations to law enforcement. Cross Bay Marine appears to have been his attempt to protect himself prior to the franchise deal he was promised. It did not protect him at all. For context, let's not lose sight of the fact that this was the very franchise that was taken from the Jaegers.

Statement of Fact, signed June 2022: "On formation of the Company, I was listed as the sole Officer/Director of the Company with the title of President. On formation of the Company, the 200 Shares set out in the Articles of Incorporation were allocated to me as the sole shareholder of the Company. On or about 05/22/2021, an EIN was issued by the Internal Revenue Service, with my information being identified as the Responsible Party for the Company."

IV. The Collapse: Why the Deal Died

The franchise arrangement was never completed. In early March 2022, Dr. L'Hommedieu formally declined to proceed. His sworn declaration sets out the reasons in specific terms.

M.D. Fla. Doc. 12 (mc-00008), Page 4–5: "Dr. L'HommeDieu

formally declined to proceed with the transaction in early March 2022 after raising documented concerns about the financial viability of the deal structure and unconscionable contract terms, including: a minimal ownership interest as compared to that retained by the Frohnhoefers; a negative-cash-flow business plan driven by debt service payable to the Frohnhoefers through Sea Tow Services International; a purchase price that had never been independently appraised, and which the Frohnhoefers expressly refused to subject to an outside appraisal; a full personal guarantee of the entire loan amount payable to Sea Tow; and employment terms that directly contradicted the promises made during the recruitment process."

In short: the actual deal documents bore little resemblance to what had been pitched. The ownership interest was minimal. The business plan was cash-flow negative. The purchase price had never been independently appraised and Sea Tow refused to allow one. A full personal guarantee was required. And the employment terms directly contradicted what he had been promised when he resigned from federal employment and moved his family to Florida.

V. The Fraud: Cross Bay Marine's Annual Report

What happened next is documented in the public records of the Florida Division of Corporations — records accessible to anyone at SunBiz.org — and in Dr. L'Hommedieu's sworn Statement of Fact.

On March 21, 2022 — approximately twenty days after Dr. L'Hommedieu formally declined to proceed with the transaction — a fraudulent Annual Report was filed for Cross Bay Marine, Inc.

M.D. Fla. Doc. 12 (mc-00008), Pages 4–5: "Joseph J.

Frohnhoefer III and Kristen Frohnhoefer were never, at any time, owners, officers, directors, or shareholders of Cross Bay Marine, Inc. Dr. L'HommeDieu was, from the date of formation, the sole officer, sole director, and sole shareholder of the corporation he incorporated with his own funds. The fraudulent Annual Report removed Dr. L'HommeDieu entirely and listed Joseph J.

Frohnhoefer III as 'President' and 'CEO' and Kristen Frohnhoefer as 'Vice President' — titles and positions that neither of them ever lawfully held, were never authorized to hold, and to which they had no legal entitlement whatsoever. The filing was signed by Joseph J. Frohnhoefer III as 'CEO,' a designation he fabricated."

Statement of Fact, signed June 2022: "On or about 03/25/2022, I noticed that a fraudulent Annual Report was filed for the Company, by Joseph J. Frohnhoefer and Kristen Frohnhoefer (together, the 'Parties'), which removed my information and listed themselves respectively as the Registered Agent, President and Vice President, as well as changing the locations of the Company's mailing and physical addresses."

The Motion to Quash notes the applicable Florida law directly:

M.D. Fla. Doc. 12 (mc-00008), Page 5: "Florida Statutes Section 817.155 provides that filing false information with the Florida Division of Corporations constitutes a third-degree felony. These are matters of public record."

VI. The Asset Transfers: Two Boats, One Truck

Two days after the fraudulent Annual Report was filed — on March 23, 2022 — the assets followed.

M.D. Fla. Doc. 12 (mc-00008), Page 5: "Two days later, on March 23, 2022, two Twin Vee vessels purchased for use in Dr.

L'HommeDieu's business were transferred out of Cross Bay

Marine, Inc. to Sea Tow Services International, Inc. and then to H2Fro, Inc., a Florida corporation controlled by the Frohnhoefers, all on the same day. The 2019 RAM 2500 diesel truck purchased by Dr. L'HommeDieu was subsequently transported to New York, where title was transferred bearing the forged signature of Kristen Frohnhoefer as purported 'President'

of Cross Bay Marine, Inc., a position she never held. Dr.

L'HommeDieu did not authorize, execute, or consent to any of these transfers."

appears to have been the instrument used to establish the false predicate for these transfers. By inserting the Frohnhoefers into the corporate records as officers of a company they never owned, and doing so while removing the actual owner's name entirely, the transfer of assets that followed two days later could be processed under a chain of title that appeared facially legitimate — but was predicated on fabricated records.

VII. The Boat He Bought For Himself

There was a third vessel — one Dr. L'Hommedieu purchased personally, entirely separate from any Cross Bay Marine transaction.

On December 21, 2021, Dr. L'Hommedieu wired $26,400.00 from his JPMorgan Chase account to Jacob Garber at Wells Fargo Bank to purchase a 2002 Twin Vee catamaran (Hull Identification Number TVG26103H102, Florida Registration FL1126LT). The wire transfer record is now Exhibit C to his Supplemental Declaration filed in federal court. On March 9, 2022, the Florida Department of Highway Safety and Motor Vehicles issued Certificate of Title No. 84361916 in his name — Russell Alan L'Hommedieu, 6312 Lake Sunrise Drive, Apollo Beach, Florida. No lienholders. His boat. M.D. Fla. Doc. 13 (mc-00008), Page 2: "Beyond the loss of my business, professional livelihood, and vehicle, Sea Tow and its principals then sought to deprive me of a personal vessel — a 2002 Twin Vee (Hull Identification Number TVG26103H102, Florida Registration FL1126LT, Title Number 84361916) — which I lawfully purchased on December 21, 2021, for $24,500.00."

VIII. The Sheriff's Deputy and the Admission on the Scene On June 10, 2022, Hillsborough County Sheriff's Deputy Yvette Hibbard (Badge 252159) responded to a stolen boat call at 11806 S US Highway 41 — the Sea Tow Tampa Bay location. The call had been placed by Joseph Frohnhoefer. The resulting street check, SC# HS 2022-20927, approved June 24, 2022, is now Exhibit A to Dr. L'Hommedieu's Supplemental Declaration filed in federal court.

Deputy Hibbard met with Sea Tow's then-current general manager, Stephen Vigilante. His account, as recorded in the deputy's narrative, cut through the dispute with remarkable clarity.

HCSO Street Check SC# HS 2022-20927, Deputy Hibbard's

Narrative (Exhibit A, Doc. 13, mc-00008): "Stephen also

advised their parking lot had several boats and if it was a random thief who stole the boat, why they would select that specific boat which the property manager and the old general manager are disputing on. Stephen advised it's a 'bad divorce' and 'technically the boat belongs to Russ.'"

Sea Tow's own general manager, on the scene, told a law enforcement officer that the boat belonged to Dr. L'Hommedieu. Deputy Hibbard's recorded response was equally direct: "I explained to both that if the boat is titled to the old general manager and it's a 'bad divorce' as his current general manager explained, then the old general manager is entitled to it."

Joseph Frohnhoefer's response to his own manager's truthful acknowledgment was, according to the sworn declaration, to make three materially false statements to Deputy Hibbard.

M.D. Fla. Doc. 13 (mc-00008), Page 3: "(a) Frohnhoefer

represented that surveillance video existed of the incident. Yet the deputy's own narrative reflects that Frohnhoefer could not identify the person in the surveillance as [Dr. L'Hommedieu].

More critically, [he] was never on that property on the date in question. (b) Frohnhoefer represented to Deputy Hibbard that civil litigation was pending against [Dr. L'Hommedieu] at that time. That statement was false. No civil litigation naming him as a defendant was pending at the time of that street check. (c) The report characterizes [Dr. L'Hommedieu] as the 'old general manager' of the Sea Tow operation. That characterization is false. He was never a general manager of Sea Tow or any Sea Tow entity. He was the owner of Cross Bay Marine, Inc., a separate Florida corporation and independent subcontractor."

The deputy's own narrative records Frohnhoefer's statement about civil litigation: "per Joseph Frohnhoefer, the business is in civil litigation with Russell L'Hommedieu." According to the sworn declaration, that statement was false at the time it was made. IX. The Professional Aftermath Dr. L'Hommedieu's Supplemental Declaration, filed under penalty of perjury on March 11, 2026, addresses what the years since have meant in practical terms. M.D. Fla. Doc. 13 (mc-00008), Pages 1–2: "I have not recovered professionally from the harm caused by Sea Tow and its principals, and I want this Court to understand what that means in practical terms. In the years since Sea Tow dismantled my business and livelihood, I have not worked a single full-time week... the financial and reputational damage inflicted by Sea Tow's conduct is the proximate cause of my diminished professional capacity. The passage of time has not restored what was taken."

M.D. Fla. Doc. 13 (mc-00008), Page 2: "I am also attempting to reinvent myself professionally — to transition from clinical physical therapy practice into academia. At this stage of my career, that transition is extraordinarily difficult. Academic positions are competitive under any circumstances; they are far more so for a practitioner attempting a late-career shift at this stage of life."

At the time of filing, Dr. L'Hommedieu holds a position as part-time adjunct faculty in the Doctor of Physical Therapy Program at Bowling Green State University. He is licensed to practice in New York, Ohio, and Florida.

X. The Subpoenas: Sea Tow Comes Back

On or about February 5, 2026, Sea Tow served Dr. L'Hommedieu with a Subpoena to Testify at a Deposition and to Produce Documents in connection with its ongoing Eastern District of New York lawsuit against the Jaeger defendants — a case, as of that date, pending for nearly six years. The subpoena demanded production of four categories of documents by February 19, 2026, and deposition for March 5, 2026. A separate subpoena was served on Karen L'Hommedieu.

The document categories were sweeping: all communications with the Jaegers or related individuals and entities concerning any Sea Tow-related maritime business; all documents concerning vessels or equipment used or sold by the Jaegers; all social media posts concerning the Jaegers' maritime business or Sea Tow; and all communications with the Coast Guard or any government agency concerning maritime services, franchising, or legal compliance related to the Jaegers. The time period: June 26, 2020 to the present — spanning nearly six years.

M.D. Fla. Doc. 12 (mc-00008), Page 3: "Cross Bay Marine was formed specifically so that Dr. L'HommeDieu could serve as the sole contract provider of towing and salvage services for Sea Tow Tampa Bay during the interim period while the franchise acquisition was being negotiated and finalized." The corporation was incorporated on May 21, 2021 — nearly a full year after the June 26, 2020 start date specified in the subpoena's document demands.

On February 16, 2026, Dr. L'Hommedieu timely served written objections pursuant to Federal Rule of Civil Procedure 45(d)(2)(B). On February 25, 2026, Magistrate Judge Steven I. Locke of the Eastern District of New York issued Document 314, which authorized four additional non-party depositions — including Dr. L'Hommedieu's — while expressly preserving each recipient's independent right to object in the appropriate court. Karen L'Hommedieu was not among the four authorized deponents. XI. The Pressure Campaign: Bond, Stein, and the Deletion Demand What followed DE 314's issuance is documented in the Motion to Quash as a pattern — not a series of isolated mistakes, but a coordinated sequence.

On February 27, 2026 — the same day DE 314 was issued — attorney Clifford J. Bond emailed Dr. L'Hommedieu demanding immediate compliance and threatening fees under Rule 37. The Motion to Quash notes that Rule 37 governs party discovery disputes; its fee-shifting provisions do not apply to a non-party who has properly served Rule 45 objections. The same email, according to the motion, omitted DE 314's express preservation of each recipient's right to object in the appropriate court. On March 3, 2026, Mitchell A. Stein, Esq. — Sea Tow's General Counsel since 1985 and a named Third-Party Defendant in the underlying New York action — inadvertently forwarded an internal litigation strategy communication to Dr. L'Hommedieu. Mr. Stein then sent two separate messages, at approximately 12:02 PM and 12:09 PM, instructing Dr. L'Hommedieu to delete the forwarded communication. M.D. Fla. Doc. 12 (mc-00008), Page 7: "Directing a potential deponent to destroy a communication that may be relevant to pending proceedings raises concerns under 18 U.S.C. Section 1512 that Dr. L'HommeDieu has documented and will present to appropriate tribunals."

The deletion demand alone, the motion notes, was not the most significant part. What was significant was the specific statement accompanying it:

M.D. Fla. Doc. 12 (mc-00008), Page 8: "What rendered Mr.

Stein's communications coercive was not the deletion demand itself, but the specific statement accompanying it: that he had insisted Dr. L'HommeDieu be told directly that this instruction came from Mr. Stein personally... That statement is a deliberate assertion of personal identity and authority by a named ThirdParty Defendant — directed at a potential adverse witness who had already eaten, firsthand, the consequences of resisting the demands of Sea Tow and its principals."

Later that same day, after Dr. L'Hommedieu had placed all counsel on written notice that off-topic communications would be treated as harassment, Mr. Stein contacted him directly and personally. The content of that message is quoted in the Motion to Quash: "My point was only to let you know that wives and kids who have no roll are always off limits... You guys just need to verify the 'no roll' part."

— Mitchell A. Stein, Esq., March 3, 2026,

Quoted In M.D. Fla. Doc. 12 (Mc-00008), Page 8

The Motion to Quash identifies the logical problem with that statement directly: Mr. Stein acknowledged in writing the standard under which Karen should be released, while simultaneously refusing to answer repeated written requests asking Sea Tow to identify which surviving claim requires either of their testimony. Sea Tow had not answered those requests as of the date of filing.

XII. The Motion to Quash: Filed March 11, 2026

On March 11, 2026, Dr. L'Hommedieu filed his Motion to Quash or Modify Subpoenas and for Protective Order in the Middle District of Florida, Tampa Division — Case No. 8:26-mc-00008-KKM-NHA, assigned to Judge Kathryn Kimball Mizelle with discovery before Magistrate Judge Natasha Hirt Adams. He filed a companion Supplemental Declaration the same day.

A parallel motion was filed in Case No. 8:26-mc-00009-SDM-TGW, assigned to Judge Steven Merryman with Magistrate Judge Thomas Wilson, which covers both Dr. L'Hommedieu and Karen.

On March 10, 2026, Dr. L'Hommedieu and Karen filed an Emergency Motion for Continuance of a March 17, 2026 hearing scheduled before Magistrate Judge Adams, citing a pre-planned family camping trip beginning March 11 in an area without reliable internet, and requesting a continuance to no earlier than April 1, 2026 to allow the threshold arguments in the Motion to Quash to be briefed before oral argument. M.D. Fla. Doc. 8 (mc-00009), Pages 2–3: "Movants are appearing pro se. Despite diligent efforts since receiving the subpoenas in February 2026, Movants have been unable to retain legal counsel in the Middle District of Florida due to significant financial constraints and the extremely compressed timeline created by the manner and timing of service."

XIII. The Agencies: A Record Spanning Hundreds of Pages

The street check and the Cross Bay Marine fraud are, by Dr. L'Hommedieu's own account filed under penalty of perjury, representative examples from a much larger record.

M.D. Fla. Doc. 13 (mc-00008), Pages 3–4: "The complaints, agency referrals, and supporting records I have assembled in connection with Sea Tow and its principals span literally hundreds of pages across multiple law enforcement and regulatory agencies. Those agencies include, but are not limited to: the Federal Bureau of Investigation; the Federal Trade Commission; the Internal Revenue Service; the Tampa Police Department; the Hillsborough County Sheriff's Office; the Florida Department of Law Enforcement; the Florida Attorney General's Office; and the Florida Department of State."

XIV. What the Court Records Show More Broadly

The L'Hommedieu story does not exist in isolation. It sits inside the wider record of the Eastern District of New York action — Sea Tow Services International, Inc. v. Tampa Bay Marine Recovery, Inc., et al., Case No. 2:20-cv-02877 — now in its sixth year. That record contains its own pattern.

In March 2023, Judge Nina Morrison denied Sea Tow's motion for leave to file a Third Amended Complaint, finding that Sea Tow appeared to be seeking the amendment "simply to slow down the litigation and drain the Jaeger Defendants of their comparatively limited resources." (DE 238 at 7–8.)

On December 29, 2025, Magistrate Judge Locke denied Sea Tow's Third Motion to Compel. In that ruling — the "Federal Judge Calls Out Sea Tow" ruling — Judge Locke found Sea Tow's discovery requests "overbroad, unduly burdensome and wholly disproportionate to the needs of the case" and characterized them as so overbroad "that they read like an attempt to obtain the discovery the Court denied on procedural grounds in its earlier proceedings." Judge Locke simultaneously closed document discovery entirely. In the same ruling, the court found Sea Tow's representation about the Jaegers' document production to be, in the court's word, "untrue." Hornswaggled, "Federal Judge Calls Out Sea Tow"

(December 29, 2025): "THE BOMBSHELL: Sea Tow claimed in its motion papers that 'the Jaeger Defendants have not produced any documents concerning or containing a calculation of damages sought [concerning their] counterclaims.' The Court's Response: 'This is untrue.'"

When Sea Tow then attempted to obtain the same dismissed-claim discovery through a parallel New York state court action, Justice Andrews in Suffolk County explicitly found that Sea Tow appeared "to be attempting to use this action to obtain further discovery to be used in the federal action," stayed the case, and created a second court record flagging franchise registration problems. (DE 311-4 at 7.)

XV. The Through Line

Dr. L'Hommedieu articulates the through line in his Supplemental Declaration with precision:

M.D. Fla. Doc. 13 (mc-00008), Page 4: "Sea Tow's principals and counsel have sought, on multiple occasions, to use legal and law enforcement mechanisms against me as instruments of pressure rather than legitimate process."

And in the Motion to Quash, the argument is put this way:

"This Court should not allow the federal subpoena power to be used as a tool of intimidation against two non-party individuals who have already suffered enormously at the hands of the very principals directing this litigation."

— M.D. FLA. DOC. 12 (MC-00008), PAGE 18

The case number for the Motion to Quash is 8:26-mc-00008-KKM-NHA. It was filed on March 11, 2026, in the United States District Court for the Middle District of Florida, Tampa Division. It is a public record, accessible through PACER. The exhibits include the Hillsborough County Sheriff's street check, the Florida Certificate of Title for the vessel, and the JPMorgan Chase wire transfer proving the purchase — documents that, together, tell the same story the federal filing tells.

A man trusted people he had known for nearly thirty years. He resigned from federal employment, sold his home, moved his family to Florida, incorporated a company, bought equipment for the business — all before the deal documents arrived. When the documents arrived, they did not match the pitch. He declined. Twenty days later, his company was seized on paper. Two days after that, his assets were transferred. His truck went to New York. A law enforcement officer was told litigation was pending against him when no such litigation existed. His own boat — purchased with his own money, titled in his own name — was the subject of a stolen-property report, until Sea Tow's own general manager told the responding deputy that the boat belonged to Dr. L'Hommedieu.

That general manager's words, preserved forever in Sheriff's Street Check SC# HS 2022-20927, approved June 24, 2022, now filed as Exhibit A in a federal court proceeding in the Middle District of Florida:

"It's a bad divorce. Technically the boat belongs to Russ."

— STEPHEN VIGILANTE, SEA TOW GENERAL

Manager, June 10, 2022, Per Hcso Sc# Hs 2022-

20927 (Exhibit A, M.D. Fla. Doc. 13, Mc-00008)

All factual claims in this report are sourced to public court filings, Florida state records, and law enforcement documents cited inline. Case documents from M.D. Fla. No. 8:26-mc-00008-KKM-NHA and 8:26-mc-00009-SDM-TGW are accessible through PACER. Florida corporate records are publicly available at SunBiz.org. Nothing herein constitutes legal advice or a legal conclusion. The matters described are allegations, assertions under penalty of perjury, or findings in court orders — each characterized accordingly.

Hornswaggled is an anonymous investigative newsletter reporting exclusively on public court records, regulatory filings, and publicly available documents. Nothing herein constitutes legal advice or creates any attorney-client relationship. All documents cited are publicly available through PACER (pacer.uscourts.gov), the Florida Division of Corporations (sunbiz.org), or other public sources. Yes, we have Merch Great to wear for depositions or annual meetings.

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:

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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?

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

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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.