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Home / Scallywags & Crew / Dr. Russ & Karen L’Hommedieu

The Believers

Dr. Russ & Karen L’Hommedieu

Non-party witnesses · Movants to quash, M.D. Fla. · Acquaintances of the Frohnhoefers for nearly three decades

Cases
8:26-mc-00008-KKM-NHA · 8:26-mc-00009-SDM-TGW (M.D. Fla.)
Company
Cross Bay Marine, Inc. — Fla. Doc P31000048227, inc. May 21, 2021
Motion to quash
Filed March 11, 2026
Key filings
M.D. Fla. Docs. 12 & 13 (mc-00008), sworn declarations

A story about trust

Dr. Russell L’Hommedieu was a federal employee and Doctor of Physical Therapy with a clinical reputation built over decades. He had known the Frohnhoefer children — Joe 3 and Kristen — for nearly thirty years. According to his sworn declaration, in mid-2021 they approached him about acquiring an ownership interest in the Sea Tow Tampa Bay opportunity, presenting term sheets that explicitly described the arrangement as a franchise in which he would have “sole discretion and authority” M.D. Fla. Doc. 12 (mc-00008), p.3. He believed them — and acted on that belief in the most consequential ways a person can.

What the declarations describe

Per the filings M.D. Fla. Doc. 12 (mc-00008), pp.3–4: in reliance on those representations, he resigned from federal employment. He sold his home in Southold, New York, and relocated with his wife Karen to Apollo Beach, Florida in September 2021. He invested “significant cash, assets, and unpaid labor” — including the purchase of a 2019 RAM 2500 diesel truck for the business — all before Sea Tow provided actual deal documents for review. He incorporated Cross Bay Marine, Inc. on May 21, 2021 as its sole officer, director, and shareholder, with an EIN issued the next day naming him Responsible Party — formed, per the declaration, specifically so he could serve as the sole contract provider of towing and salvage services for Sea Tow Tampa Bay while the franchise acquisition was negotiated. When the deal documents finally arrived, the declaration says, they did not match the pitch. In early March 2022 he formally declined to proceed after raising documented concerns about the deal structure and its terms Doc. 12, pp.4–5: a minimal ownership interest compared to what the Frohnhoefers retained; a negative-cash-flow business plan driven by debt service payable to the Frohnhoefers through STSI; a purchase price never independently appraised — an outside appraisal the Frohnhoefers expressly refused; a full personal guarantee of the entire loan; and employment terms that directly contradicted the recruitment promises. Approximately twenty days later, per Florida corporate records and his sworn Statement of Fact, his company was taken over on paper; two days after that, its assets were transferred; his truck ended up in 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 — became the subject of a stolen-property report, until Sea Tow’s own general manager told the responding deputy the boat belonged to Dr. L’Hommedieu HCSO Street Check SC# HS 2022-20927 · Exhibit A, Doc. 13.

“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.”Supplemental Declaration · M.D. Fla. Doc. 13 (mc-00008), p.4

Then came the subpoenas

Cross Bay Marine was not even incorporated until May 2021 — a year after the May–June 2020 events that survive in the federal case. Yet when Sea Tow launched its 2026 subpoena campaign, Dr. L’Hommedieu was served on or about February 5, 2026 — the earliest service date in the campaign that the public filings document. Their March 11, 2026 motion to quash asks the court not to 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, p.18. Everything above is drawn from public court records, Florida corporate records available at SunBiz.org, and declarations filed under penalty of perjury; Sea Tow disputes their account, and the questions now belong to the Middle District of Florida.

⚓ Why it matters to the case

The L’Hommedieu declarations matter for one structural reason: they describe, under penalty of perjury, a 2021 pitch that used the word franchise — in writing — during the exact years Sea Tow was telling a federal judge it operates no franchises. Two courtrooms, two vocabularies, one company. Sea Tow opened these Florida dockets to compel testimony; in doing so it created a public record where a story it never wanted told is now being told under oath. They may get more than they bargained for.

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