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Home / The Archive / We Are the Jaegers

SPECIAL EDITION · FEB. 2026

We Are the Jaegers

Web edition of the original email dispatch, reproduced from the published text. Transport headers and recipient details removed; content otherwise as sent.

HORNSWAGGLED

◆T H E N E W S L E T T E R F O R S E A T O W F R A N C H I S E E S W H O D E S E R V E T H E T R U T H ◆

S P E C I A L E D I T I O N · F E B R U A R Y 2 0 2 6 · S E A T O W F R A N C H I S E E A L E R T

⚓ E X C L U S I V E R E P O R T

A Working Family. A $1.5 Million Lawsuit. A Warning to Every Franchisee.

S E C T I O N O N E

Meet Erich and Abigail Jaeger

They are not corporate villains. They are not rogue operators. They are not a threat to anyone. They are a husband and wife who loved the water, believed in a brand, and built a business with their bare hands on the waters of Tampa Bay.

Erich and Abigail Jaeger operated as a Sea Tow franchisee, just like you. They were proudly announced at the annual meeting as "The New Owners of Tampa Bay"!

They ran boats in the dark, in the rain, in the heat, answering calls from panicked boaters in the middle of the night. They rent their home. They do not own it. They have two young boys. Whatever wealth they had was bound up entirely in their franchise — their equipment, their reputation, and their customer relationships. That was their retirement. That was their children's future.

Just. Like. You.

In 2019, they had the franchise taken back, and if that was not enough to crush them, they were immediately sued. If they had not found an attorney with a really big heart, they would not have survived the process.

Think about that.

Sea Tow did not need to win this lawsuit; they thought they won simply by filing it.

$1,500,000 The demand in Case No. 2:20-cv-02877-WFK-SIL. At the time Sea Tow filed suit, there was no reasonable expectation that a family renting their home — with two children — could ever pay this sum. None. They had to know that.

Why? Why Would Sea Tow Do This?

Was it about the money? Think about it for a moment. A family that rents their home. Two kids. Now, with no income. Did Joe, Mitch, and Kristen genuinely believe these people could pay a judgment of $1.5 million? Did Joe, Mitch, and Kristen even feel they had a case? Of course not. It was about crushing this family. Crushing them.

This was not a lawsuit designed to recover damages. This was a message. A message delivered with the blunt force of federal court process, served upon a family at their rented home, sent to every Sea Tow franchisee in America: "This can happen to you . . . and you can't do anything about it."

This Lawsuit Was A Message To You — The Franchisee.

S E C T I O N T W O

You Are the Jaegers

If you hold a Sea Tow franchise today, take a moment to look in the mirror. What do you see?

You see someone who works on the water. Someone who got into this business because you believed in it. Maybe you're like the Jaegers — you have a family, a mortgage or a landlord, kids in school. Your franchise is not just a business. It is your livelihood, your identity, and your financial security. Everything you've worked for is tied to that brand.

And sitting in Southold, New York, the people who control that brand see you very differently than you see yourself. They behave as if you are simply gears in a money machine. Disposable, replaceable. Functional trash that's only as good as long as the money flows without squeaks or gaffs. Ask yourself these questions. Be honest.

? Did I make the right decision buying this franchise?

? Is my investment losing value by the day?

? Is BoatUS or Flagship Marine quietly taking my market share because customers are fed up with Sea Tow's reputation in court?

? Why didn't Sea Tow register as a franchisor in New York State — as required by law — for over forty years?

? Why did they let their signature yellow trademark get cancelled by the Trademark Trial and Appeal Board — for systematic discovery misconduct — but still chose to systematically destroy a hard-working family?

? Am I going to lose my franchise without cause?

? Am I going to have unreasonable fees and fines imposed on me out of spite or for revenge?

? Am I going to be pressured to spin the corporate narrative under oath?

? Am I going to be leveraged into joining a lawsuit against a former franchisee — someone just like me?

? Do I trust Joe, Mitch, or Kristen?

These are not paranoid questions. They are documented patterns. At least three Sea Tow franchisees reportedly refused to participate when Sea Tow attempted to coordinate them into litigation against the Jaegers in a duplicate case in NY state court. They said no. Do you know which ones? Do you know what happened to them? What about the ones that did agree? What leverage did Sea Tow have on them?

⚖ D O C U M E N T E D F A C T — U S P T O R E C O R D S

Sea Tow's signature yellow color trademark was CANCELLED by the Trademark Trial and Appeal Board for systematic discovery misconduct — the TTAB finding that "any sanction short of judgment would be futile." They lost the mark that identifies every boat, every truck, and every piece of gear you own. And they chose to spend that energy suing the Jaegers instead of protecting your brand.

S E C T I O N T H R E E

Who Are Russ & Karen L'HommeDieu — and Why Should You Care?

Russ and Karen L'HommeDieu are not parties to the Jaeger lawsuit.

They never were. They are a husband and wife — non-parties — who had absolutely nothing to do with the events at the center of this case. As far as we can tell, Russ L'HommeDieu was the former owner of Cross Bay Marine, Inc. — a business that was not even incorporated until May 2021, over a year after the May–June 2020 events that survive as the core claims in this lawsuit. Cross Bay Marine could not have been involved in what Sea Tow claims happened in 2020. It did not legally exist.

Yet Sea Tow served non-party subpoenas on both Russ and Karen FIRST. The subpoenas arrived before the Jaegers had even been given adequate time to respond. The strategy was clear: hit the non-parties first, hit them hard, and use them as leverage. Sea Tow came for them with the full force of federal court process, knowing they had no connection to the relevant events, knowing they would have to spend time and money defending themselves against a company that had already been found by a federal judge to have made false statements in its filings.

But, why? Who are these people? What is the story here? What does Cross Bay Marine have to do with all this? If you google "Russ L'HommeDieu" this is the second link that pops up: https://www.workcompassociates.com/singlepost/florida-man-loses-business-after-someone-hijacks-his-company Holy crap.

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

Sea Tow attempted to subpoena 23 or more non-party witnesses in a case where Magistrate Judge Locke's February 2026 scheduling order permits only 10 depositions total. The arithmetic alone tells you everything you need to know about the purpose of these subpoenas. Discovery as a weapon. Witnesses as hostages.

If they will do this to non-parties who have no connection to the case — what will they do to you if you ever become a problem for them?

The Depositions Are Coming

U N D E R O A T H · O N T H E R E C O R D · M A R C H 2 0 2 6

Three key figures will sit for depositions in March 2026. Below are the questions every Sea Tow franchisee should want answered — the questions that go to the heart of how this company operates and what it means for your future. They will be under oath. Consider what the truth looks like.

D E P O S I T I O N · M A R C H 1 6 , 2 0 2 6

Mitchell A. Stein

General Counsel, Stein Law P.C. · Named Defendant · Third-Party Defendant · Lead Trial Attorney for Sea Tow Mitchell Stein occupies a position that has no parallel in conventional legal practice. He is simultaneously the lead attorney representing Sea Tow Services International as plaintiff and a named defendant in the very same case. He files briefs. He argues motions. He submits sworn affidavits. And he is being sued in those same proceedings by the Jaegers as a third-party defendant. He was also, upon information and belief, representing both Sea Tow and individual franchisees at the time those franchisees purchased their agreements. Think carefully about what that means for you and whether your interests were represented at the table when you signed.

If You Could Ask Mitchell Stein Anything Under Oath:

Q.01

Mr. Stein, you are simultaneously the lead attorney representing Sea Tow as plaintiff and a named third-party defendant in this same case. How is that not a textbook conflict of interest, and when did you consult with an ethics board about it?

Q.02

When franchisees purchased their Sea Tow franchise agreements, were you representing Sea Tow, the franchisee, or both simultaneously? Were franchisees ever told in writing that you represented both sides in that negotiation?

Q.03

Do you have an ownership interest — direct or indirect, through any trust, holding entity, or compensation arrangement — in Sea Tow Services International or any affiliated entity?

Q.04

Did Joseph Frohnhoefer II establish any trust structure for Sea Tow? Were you involved in drafting that trust? Do you serve, or have you ever served, as trustee or beneficiary of any trust that controls Sea Tow? Are you a shareholder?

Q.05

The Trademark Trial and Appeal Board cancelled Sea Tow's yellow color trademark due to systematic discovery misconduct. Were you Sea Tow's counsel during those proceedings? What instructions did you give regarding document production and discovery responses?

Q.06

Magistrate Judge Locke found that Sea Tow's representation in motion papers was "untrue." You signed filings in this case. Can you explain the factual basis for statements a federal judge found to be false?

Q.07

Federal courts in three separate proceedings — Libaire v. Kaplan, Margo v. Weiss, and Alkoff v. Gold — imposed sanctions against you for professional misconduct, including findings of "Machiavellian tactics." Do you consider those findings relevant to your credibility as the affiant in this case?

Q.08

Have you personally ever recommended to Joseph Frohnhoefer III that Sea Tow pursue litigation against a franchisee or former franchisee primarily to set an example, or to deter other franchisees from leaving?

Q.09

What is the precise structure of your compensation from Sea Tow? Do you receive equity, royalties, profit-sharing, contingent fees, or any compensation beyond standard hourly legal fees?

Q.10

Why did you continue representing Sea Tow as lead trial counsel after being named a defendant in this case, rather than withdrawing to allow unconflicted counsel to take over?

Q.11

How many times have you made representations to franchisees — in connection with franchise sales, renewals, or terminations — that were not accurate?

D E P O S I T I O N · M A R C H 1 7 , 2 0 2 6

Joseph Frohnhoefer III

Chief Executive Officer · Sea Tow Services International, Inc. · Third-Party Defendant Joseph Frohnhoefer III is the CEO of Sea Tow Services International. He directs litigation strategy. He approves termination decisions. He controls the machine that decides whether your franchise lives or dies. And on March 17, 2026, he sits for his deposition under oath.

Federal Judge Joanna Seybert has already ruled that Sea Tow's "Management Agreement" payment structure "fits comfortably within" the statutory definition of a franchise fee (Document 216, Page 28). The New York Attorney General confirmed via FOIL response that Sea Tow has never registered as a franchisor in New York State. Not once. In over forty years.

If You Could Ask Joseph Frohnhoefer III Anything Under Oath:

Q.01

A federal judge ruled that Sea Tow's Management Agreement payments "fit comfortably within" the definition of a franchise fee. The New York Attorney General confirmed Sea Tow has never registered as a franchisor. Have you ever instructed anyone to investigate Sea Tow's registration obligations, and what was the result?

Q.02

Have you ever levied fines, fees, or penalties against a franchisee for reasons that were personal, retaliatory, or designed to punish conduct you found objectionable — rather than for legitimate, documented business reasons?

Q.03

When you decided to pursue $1,500,000 in damages against the Jaegers — a family that rents their home and has two children — did you conduct any analysis of their ability to pay that judgment? What was the actual purpose of that demand?

Q.04

Do you view your franchisees as independent business owners and mutual partners in a shared enterprise, or as revenue-generating units subject to your absolute control?

Q.05

At least three Sea Tow franchisees reportedly declined when you coordinated franchisees to take legal action against the Jaegers. What happened to those franchisees? Were there consequences for their refusal to participate?

Q.06

Sea Tow's public marketing and franchise recruitment materials explicitly describe a franchise network, franchise fees, and franchise relationships. Yet in federal court, Sea Tow has argued it does not operate a franchise. Which version is true?

Q.07

The SBA Franchise Directory certification deadline of June 30, 2026, is approaching. If Sea Tow certifies it operates a franchise system, that directly contradicts your litigation position here. If Sea Tow declines to certify, every franchisee who wants to sell loses access to SBA financing. How do you intend to resolve this contradiction for the people who depend on you?

Q.08

Your father, Joseph Frohnhoefer II, built Sea Tow into a national brand over decades of genuine work. Looking at the documented findings in this litigation — the false statements found by Judge Locke, the trademark cancellation for misconduct, the franchise law violations — do you believe this is what he intended?

Q.09

You have children. What example do you want to set for them about how you treat people who dedicate years of their lives to building your brand?

Q.10

How do you sleep at night?

D E P O S I T I O N · M A R C H 1 8 , 2 0 2 6

Kristen Frohnhoefer

President · Sea Tow Services International, Inc.

Kristen Frohnhoefer is the President of Sea Tow Services International. Court documents indicate she has been involved in franchise termination decisions and operational matters. Sea Tow's own counsel represented to the Court that she has "no knowledge" of this ongoing litigation.

⚠ C O N S I D E R T H I S C A R E F U L L Y

The President of the plaintiff company allegedly has "no knowledge" of a $1.5 million federal lawsuit that has consumed her company for six years. Either that representation to the Court was false, or it raises profound questions about who is actually running Sea Tow and what the role of President means at this organization.

If You Could Ask Kristen Frohnhoefer Anything Under Oath:

Q.01

Sea Tow's counsel represented to the Court that you have "no knowledge" of this litigation. You are the President of the company that has been the plaintiff in this case since 2020. Is that representation to the Court accurate?

Q.02

Welcome to the big leagues. As President, do you have any concerns about personal criminal exposure arising from the conduct alleged in this case?

Q.03

Have you ever signed corporate documents — franchise termination notices, corporate filings, financial representations — that you now believe may have been inaccurate or misleading to the parties who relied on them?

Q.04

Have you ever communicated, directly or indirectly, with any Sea Tow franchisee in a way designed to pressure them to participate in litigation, provide testimony favorable to Sea Tow, or refrain from communicating with former franchisees?

Q.07

Do you understand that "I don't recall" and "I have no knowledge" are not the same thing under oath — and that providing false testimony about your level of involvement in this company's decisions constitutes perjury?

What Are You Going to Do?

Y O U D O N O T H A V E T O S I T O N T H E S I D E L I N E S .

The Jaegers fought alone for six years. They produced over nine thousand pages of documents. They watched a federal judge find that Sea Tow made false statements about their production. They endured. They managed. They fed their kids. They paid their crew. They did what it takes to stay alive and they are still standing. STILL STANDING!! A bit bit battle worn but, still standing.

Could you survive wihtout your franchise?

How about without your franchise AND a multimillion dollar legal bill? But they should never have had to fight alone. And neither should you. 100+ franchise territories across America.

One hundred + business owners who have invested their savings, their time, and their families' futures into this brand.

Individually, You Are Vulnerable. Together, You Are

THE BRAND.

The franchise laws that Sea Tow has ignored for forty years were written to protect you. The New York Franchise Sales Act. The FTC Franchise Rule. These are not abstract legal theories. They are your rights. And a federal judge has already said, in writing, that Sea Tow's payment structure fits comfortably within the definition of a franchise fee — which means Sea Tow has been operating as an unregistered franchisor, and the agreements you signed may be void and unenforceable under New York law.

If Sea Tow's franchise agreements are probably void because Sea Tow failed to register, the non-compete clauses they have used to imprison former franchisees like the Jaegers likely cannot be enforced. The fees and penalties imposed may lack legal foundation. The termination provisions they have threatened you with may be unenforceable.

But none of that matters if you do nothing. Sea Tow is counting on your silence.

They are counting on you being too busy, too scared, too isolated to act. They are counting on you not knowing what the Jaegers know.

Now you know.

⚠ S T R A T E G I C D E A D L I N E — J U N E 3 0 , 2 0 2 6

The SBA Franchise Directory certification deadline will force Sea Tow to choose: confirm in writing that they operate a franchise system — directly contradicting their federal court position — or decline to certify and cut off SBA financing access for every franchisee who ever wants to sell their business. Either way, you are affected. Either way, you deserve to know what is coming before it arrives.

Join together. Talk to each other. Talk to an attorney who represents your interests — not Sea Tow's.

The depositions are on March 16, 17, and 18.

The truth is coming out.

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HORNSWAGGLED

S P E C I A L E D I T I O N · F E B R U A R Y 2 0 2 6 · P U B L I S H E D F O R S E A T O W F R A N C H I S E E S

All facts herein are drawn from publicly available federal court records in Case No. 2:20-cv-02877-WFK-SIL (U.S. District Court, Eastern District of New York), official USPTO records, Florida Division of Corporations filings, and FOIL responses from the New York Attorney General's office. This newsletter constitutes protected commentary and the exercise of First Amendment rights. It does not constitute legal advice. Readers are encouraged to consult independent legal counsel regarding their own franchise agreements and rights. 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.

We be but humble researchers with library cards and internet connections. IMPORTANT DISCLAIMERS (The Boring But Necessary Stuff):

⚓ Document Accuracy:

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?

⚓ Satire and Commentary:

We may engage in satire, parody, and rhetorical flourishes for the purpose of provoking thought, which be our First Amendment right as a U.S.-based pirate crew.

(Aye, even pirates can be patriots!)

⚓ AI Usage Disclaimer:

Some of our content may be created, enhanced, or assisted by artificial intelligence tools.

We be livin' in the future, mateys, where even parrots be digital. Any AI-generated content should be considered part of our creative and analytical process.

⚓ AI Image Generation Disclaimer:

Images accompanying our publications may be generated wholly or partially by artificial intelligence.

These images be for illustrative, satirical, or commentary purposes only. They do not represent real people, real events, or real photographs unless explicitly stated otherwise.

No AI-generated image should be construed as documentary evidence. ⚓ No Legal or Financial Advice:

We not be lawyers, accountants, or licensed advisors of any sort.

We be storytellers, researchers, and question-askers.

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.

AI-GENERATED CONTENT DISCLAIMER

Document Creation Date: October 31, 2025

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.