Filing # 47775782 E-Filed 10/18/2016 03:58:56 PM

IN THE CIRCUIT COURT FOR THE THIRTEENTH JUDICIAL CIRCUIT

IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
CIVIL DIVISION
SEAFARER EXPLORATION CORP.,
Plaintiff,
CASE NO.: 14-CA-8902
DIV: L
-vDARRELL VOLENTINE, an individual,
Also Known as BUCCANEER1961
Defendant.
____________________________________/
NOTICE BY COUNSEL OF CORRECTION
Plaintiff, Seafarer Exploration Corp. by the undersigned counsel hereby files this
Notice of Correction as to an Exhibit presented before the Court at the hearing on Plaintiffs
Motion for Order to Show Cause against the Defendant on April 7, 2016. Such Exhibit A as
entered contained a rendition of the source for certain written posts made by the Defendant
which was erroneous when reviewed this day. Counsel for the Plaintiff hereby avers:
1.

On April 7, 2016, the Court held a hearing on Plaintiff, Seafarers Exploration

Corp.s Motion for Order to Show Cause. The nature of the hearing was to show that the
Defendant, Volentine, had violated the permanent injunction against him by posting and
communicating about Seafarer in message boards and to third parties.
2.

In support of such Motion, Plaintiffs counsel had prepared what was Exhibit A of

posts made by Volentine about Seafarer Exploration or its management, which was in violation
of the terms of his permanent injunction. Such Exhibit included on page 2, a Note written by
counsel commenting on the content of posts, messages or communications that the matters
presented on page 2, following to the top of page 4 were posted through www.Investorshub.com.

3.

A review of the source of those matters made by Counsel on this day showed that

the matters included were mislabeled by the undersigned Counsel as being from Investorshub,
when they actually had been sent to counsel in July 2015 by the source of information, Gregory
J. Petrakis. Mr. Petrakis had communicated to Counsel that such posts of messages to a third
party by Volentine had actually been from Facebook sources. Counsel did not review the emails
from Mr. Petrakis providing these matters to counsel when the Exhibit was prepared and filed
later in 2015. Counsel mistakenly placed in the Note that the matters had been posted through
Investorshub. In either situation the Defendant violated the injunction conditions no matter
where such material and how it was placed to third parties. That is no excuse for Counsel not
rechecking the source of the matters, but is simply a comment that it was not necessary to show
that the comments or communications were through Investorshub in order to prove violation of
the injunction, thus there was no nefarious intent at all.
4.

Such was not done to mislead the Court in any fashion, and Counsel is presenting

this filing to state such to the Court when the matter was realized this day.
CERTIFICATE OF SERVICE
I hereby certify that this filing was served via electronic filing system to Evan Kidd,
Esquire to email evankiddjd@gmail.com on this 18th day of October, 2016.
Respectfully submitted,
/s/ Craig A. Huffman
_______________________
Craig A. Huffman, Esquire
Florida Bar No. 116149
Securus Law Group, P.A.
13046 Racetrack Road
Tampa, Florida 33626
Telephone (888) 914-4144
E-mail: craig@securuslawgroup.com