IN THE COUNTY COURT FOR THE NINTI
IN AND FOR MARTIN COUNTY, FLORIDA
CIVIL DIVISION
SEAN MURPHY,
Plaintiff,
CASE NO.: 10-397 CC
DIV: JUDGE STEELE,
Ey
SEAFARER EXPLORATION CORPORATION,
SEAFARER EXPLORATION HOLDINGS, “ORP.
SEAFARER EXPLORATION INCORPORATED,
(a corporation doing business in the State of Florida),
KRISTIN GONZALEZ, (registered agent)
KYLE KENNEDY, CHRISTOPHER GILCHER,
PELLE OJASU, VICTOR SILVA,
Defendant(s).
o
AFFIDAVIT OF THOMAS E. LAW, II, IN SUPPORT OF DEFENDANTS”
MOTION TO DISMISS FOR EXTORTIONATE CONDUCT
THOMAS F. LAW, Il, being over the age of eighteen years of age, do hereby swear to
the following:
1. My name is THOMAS E. LAW, II. I have personal knowledge of the facts
included in this affidavit.
2, On June 9, 2010, in the afternoon, I was on the telephone with Kyle Kennedy, the
Chief Executive Officer of Seafarer Exploration, when Sean Murphy called. Our book keeper
was also sitting in my office atthe time, I asked Kyle if he wanted to listen to the call, he said
yes so T put Sean Murphy on speakerphone. He opened the call by yelling angrily about how he
\vas ripped off by Judd Laird, Seafarer and every-one involved. Sean stated, "this is bullshit!”
and he was not going to be left out of the loop.
3, He went on to say how they owed him money. I asked him if he had a writtencontract with anybody stating they were going to pay him and he said it was told to him by Judd.
Murphy would not answer the question, instead he continued to seream that he was wronged, and
that he would not let me see his agreement with Laird,
4. Murphy further stated he would take it to the FBI and two other Federal agencies
including a Federal Judge. He said and I quote “if SeaFarer does not pay me $10,488.00 by three
o'clock tomorrow I am going to the federal authorities to blow the lid off of all the crimes
Seafarer and Judd are committing”.
5. He also stated he would take this to a federal judge. Lasked him ifhe really
wanted to do that because if he made false claims to federal law enforcement it could be a crime,
He stated that besides the FBI's number he had two other federal agencies he would call to report
them, I said to him well if you have proof then you should be ok. He stated he had lots of
evidence, Murphy again stated that Seafarer had to drop the lawsuit against him and that he again
threatened Tom by stating, "T want my money by 3 o'clock tomorrow or its done," and he hung
up the phone.
‘Swom to this, tay of, yout __, 2010, under penalty of perjury.
STATE OF FLORIDA,
COUNTY OF _/
BEFORE ME, the undersigned authority, personally appeared, THOMAS E. LAW, Il,
who were identified via identification number __ and
“oF are personally known to me, who after first being duly
Sworn, depose and Say that the foregoing facts set forth in this affidavit are true and correct as
herein above stated.
LB
THOMAS E. LAW, IT
¢
SWORN TO AND SUBSCRIBED before me this O IMfay of Jue ___, 2010.
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NOTARY PUBLIC STATE OF NOTARY PUBLIC
games 8. Sts State of Florida
Notary Seal: { Qf consi spo eions My Commission expires: 6-97-90!
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