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6/2/2016

Seafarer Exploration Corp. vs Darrell Volentine
Deposition of Timothy A. Parsons BACKORDER 14-CA-8902

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IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR
HILLSBOROUGH COUNTY, FLORIDA

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SEAFARER EXPLORATION
CORP.,

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Plaintiff,
vs.

CASE NO.: 14-CA-8902
DIV. L

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DARRELL VOLENTINE,
Defendant.
______________________/

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THE DEPOSITION OF:

DR. TIMOTHY PARSONS

AT THE INSTANCE OF:

THE DEFENDANT

DATE:

JUNE 2, 2016

TIME:

COMMENCED: 12:11 p.m.

LOCATION:

PREMIER REPORTING
114 W. 5TH AVENUE
TALLAHASSEE, FLORIDA 32301

REPORTED BY:

KAIRISA MAGEE
Court Reporter and
Notary Public in and for
State of Florida at large

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PREMIER REPORTING
114 W. 5TH AVENUE
TALLAHASSEE, FLORIDA 32303
(850)894-0828

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Premier Reporting
114 W. 5th Avenue, Tallahassee, FL 32303

(850) 894-0828

Reported by: Kairisa Magee
premier-reporting.com

.com 13 FLORIDA DEPARTMENT OF STATE 500 South Bronough Street 14 Tallahassee. was examined and testified as follows: EXAMINATION BY MR. Could you please state your name and occupation for the record? A. I have a master's degree and Ph. .D. Florida 32305-0250 (850) 245-6536 15 12 16 16 9 **NO EXHIBITS MARKED** 13 14 15 ALSO PRESENT: 17 **Uh-uh is a negative response **Uh-huh is a positive response 17 Mr. I've also worked in the nonprofit 12 industry. KIDD . FL 32303 Page 5 1 State University in anthropology and archaeology. Tallahassee. Could you give me a brief description of your professional and educational background? A. Worked as an archaeologist 9 and cultural resources professional for the National Park 10 Service for six years. It's the coffee. Esquire 4 SECURUS LAW GROUP. I'm going to ask you some questions. . Parsons BACKORDER 14-CA-8902 Page 2 1 APPEARANCES: 1 2 ON BEHALF OF THE PLAINTIFF: (APPEARING TELEPHONICALLY) 3 Craig Huffman. 5th Avenue. I have 2 a bachelor's degree from Millsaps College in anthropology. Tim A. TIMOTHY PARSONS BY MR. and then we did some others things. having been first duly sworn to speak the truth. . Q. . .6/2/2016 Seafarer Exploration Corp. 6 THE WITNESS: I'm sorry. . FUGETT: I think -. Florida 6 2 7 7 3 4 2 Page 3 EXAMINATION INDEX EXAMINATION OF DR. Thomas Soeder 19 18 19 20 20 21 21 22 22 23 23 24 24 25 25 Page 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 DEPOSITION Whereupon. and sociology. FL 34684 10 10 11 ON BEHALF OF THE FLORIDA DEPARTMENT OF STATE: 11 12 David A Fugett. So as you know. I certainly will. attorney for Darrell Volentine. I worked for the National Park Service -5 THE COURT REPORTER: I need you to slow down. Bachelor's 8 Degree from Millsaps College. Okay. Been working at the Department of 11 State for four years. HUFFMAN . Mark Blumstin 18 Mr. Division of Historical Resources.myflorida. . . We've had Tim. You can please keep everything as accurate and truthful as possibly. 13 BY MR. 13046 Race Track Road 5 #243 Tampa. and nothing but the truth.A. is from Florida State. . . MARKED 8 Evan Kidd. vs Darrell Volentine Deposition of Timothy A. I oversee the day-to-day operations and budget of 19 the Division's Historical Resources. KIDD: Q. . The court reporter is going to record your answers. Are you responsible for maintaining any of 21 the files produced herein? 22 MR. Okay. . . And what would your job duties entail? 18 A. P.he's not the records 23 custodian for these. . Division Directer. the whole truth. Division of Historical 16 Resources. 7 The Ph. . 16 5 INDEX TO EXHIBITS DESCRIPTION 6 ON BEHALF OF THE DEFENDANT: 8 NO. as well as Roger and 24 Mary. . . . (850) 894-0828 Reported by: Kairisa Magee premier-reporting.com .D. Esquire david. . but I'm Evan Kidd. Division Director. 20 Q. as we discussed earlier. . . .fugett@dos. I graduated from high school 4 in 1999. . I don't know if it's morning or afternoon anymore. Q. 17 Q. . 4 BY MR. 3 archaeology. TIMOTHY PARSONS was called as a witness. . Parsons. Okay. Have you been deposed before? A. Kyle Kennedy Mr. If you need me to repeat any questions. . Esquire 9 704 1st Court Palm Harbor. look through their files to 25 give us what they had. Yes. from Florida Premier Reporting 114 W. Department of State. And what is your current occupation? 15 A. . KIDD: 14 Q.

what stage of the process is the application in? A. feel free to answer. In regards to what? A. but if you're just going to 3 to any of my questions would differentiate between the two 4 ask him just a general question as to whether or not he's 4 of them. 2. but that would take -MR. BY MR. Area 2? And what about Area 1? 13 A. Information.com . and I forget the woman's name. He would have to actually look at all of 6 Q. KIDD: 24 Q. The Groobers. so -MR.some steps they need to take? MR. Go ahead. Q. Yes. yes. Permit applications.6/2/2016 Seafarer Exploration Corp. Not really. Yes. How about Area 1? 25 A. Go ahead. KIDD: Q.I mean. We received application materials for Area 3. 5 familiar with all of the two -. FL 32303 Page 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. KIDD: Q. To the extent that -that what has been provided is not privileged or confidential at this point. Permit applications. It's pending. but we haven't been processing it. HUFFMAN: Objection to form. Exploration. You can use it however you want. And what was the nature of communication with them? A. Okay. Do they have a permit pending in Area 1? 15 A. Is there anything pending with regard to Area 3? A. have they 19 ever had a recovery permit in Area 2? 20 MR. when I refer to either 8 A. FUGETT: Form. 18 Q. he would be happy to answer. vs Darrell Volentine Deposition of Timothy A. THE WITNESS: Sorry. I believe so. Exploration permit. Pending. 16 Q. BY MR. Page 8 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. let me know and just don't answer it. I believe they have an exploration permit for 11 Area 2. But if it is. but go ahead. Okay. What type of permit is being applied for in Area 3? A.3. FUGETT: I want to object to this witness commenting on an ongoing permitting application process that hasn't been completed yet. Q. Permit applications? And when you say "permit applications. his wife. MR. Okay. Q. KIDD: Q. (Nodding) 6 object to that. 7 permits that Seafarer has in the aforementioned areas? 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. Have you had any communication with Kyle Kennedy? A. To the best of your knowledge. Parsons BACKORDER 14-CA-8902 Page 6 3 Page 7 1 So he's -. KIDD: Okay. KIDD: Q. I don't know them very well. Okay. BY MR. And what type of permit would that be? 17 A. That would take -THE WITNESS: And I have to be done by 1:30. if you can ask him about any specific 1 Seafarer Exploration or Seafarer Quest. 14 Q. MR. Q. 12 Q. George Groober. FUGETT: He can do that. No. MR." are you discussing the possibility of one? Are you obtaining information you need to process the permit? A. I'm going to 5 A. And what stage of the application is the -.000 pages. 5th Avenue. and 1 as they relate to Seafarer and their salvage activities? MR. Exploration? Okay. 22 THE WITNESS: No. KIDD: Just have a few more question. FUGETT: Object to the form. Premier Reporting 114 W. Can you tell me a little bit more about who the Groobers are? A. Tallahassee. THE WITNESS: We received materials." If for some reason your answer 3 familiar with a lot of them. MR. KIDD: Yeah. How about anybody else with Seafarer? A. MR. And what type of permits would those be? 10 A. No. BY MR. Q.the 7 them before he could give an answer to that. BY MR. 9 Q. 21 Go ahead. Would you be able to describe the nature of that communication? MR. Okay. Q. FUGETT: Object to form. And just to state. He's obviously 2 use the work "Seafarer. FUGETT: It's your time. (850) 894-0828 Reported by: Kairisa Magee premier-reporting. FUGETT: Object to form. Are you familiar with Areas 3. KIDD: Q. I'm going to just 2 documents. 23 BY MR. Could you be a little more specific? Is there anything else that they need -. FUGETT: Hang on. Trying to be a little more specific. THE WITNESS: Telephone and e-mail. So are you familiar with the -. please be specific for me.

KIDD: Q. A. but it -BY MR. FUGETT: Object to form. I mean. Q. THE WITNESS: I'm familiar with what Rule 1A-31 says. Go ahead. 19 20 as far as if you were to call. To the best of your knowledge. 3 Go ahead. FUGETT: Object to form. In the capacity of their communication with you. 23 24 Answer if you can. would you comment on that? Would you answer 8 9 their questions? 10 9 MR. KIDD: Q. so -BY MR. FUGETT: Object to form. Go ahead. I believe Rule 1A-31 says that an applicant must demonstrate financial ability to carry out the requested activities.usually after I talk to (850) 894-0828 Reported by: Kairisa Magee premier-reporting. FUGETT: -. Go ahead. KIDD: 6 5 Q. Within these documents. MR.say you 20 21 were a potential investor and you wanted to inquire as to 21 22 what the status of the permit was. like. I'll be done in just a few minutes. Are you familiar with the financial requirements necessary to maintain permits? MR. Q. KIDD: 4 THE WITNESS: Not to the best of my knowledge. (Whereupon there was a short break. 24 25 THE WITNESS: If there's a permit application. THE WITNESS: I'd have to revisit the rule. FL 32303 Q. has Seafarer complied with the requirements? MR. KIDD: Q. THE WITNESS: Sorry. 12 13 MR. Could you be a little more descriptive of what the requirements are within the rule? MR. THE WITNESS: To the best of my knowledge. And the court reporter is shaking her head yes. KIDD: Specifically. THE WITNESS: The status of any application before it's issued is "pending. other than pending. Tallahassee. It's not secret information. but when we come back. Yes. That part of it's general. you indicated that you had. 3 BY MR. has Seafarer ever gave notice to the State that their financial position has Page 12 1 changed? Page 13 1 would tell anyone who called that someone has a pending 2 MR. So how would you keep those records? A. And so if someone was to contact your office and 6 7 inquire about the status of a pending permit 7 8 application. Q. KIDD: Yes. 15 16 MR. did they identify themselves as having a position within Seafarer? A. BY MR. Go ahead. FUGETT: Object to form. I need to slow down. FUGETT: Slow down. 4 5 BY MR. FUGETT: Object to form.or are you just asking a 13 14 general -- 14 15 MR. No. Q. How about once the permit has been issued? If a company such as Seafarer's financial position changed. for example. KIDD: I'd like to take a quick break. MR.we'll start with records of phone calls. FUGETT: Object to form. I think they're project managers. KIDD: Q. If we set up a -. you know -. Do you mean records of meetings or records of phone calls or something like that? I mean -Q. are they required to notify the State? A.com . 5th Avenue. To the best of your knowledge. Calling back to a previous question about whether or not you've had any communication with Kyle Kennedy. we 25 Premier Reporting 114 W. We'll start with -. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 4 Page 11 A." so it's -. A. vs Darrell Volentine Deposition of Timothy A.off the top of my head. How about the status of the pending permit application? MR. 2 permit application. Go ahead. and.6/2/2016 Seafarer Exploration Corp. BY MR. Go ahead. would there be any records of that? A. FUGETT: Are you talking specifically about 10 11 this particular case -- 11 12 MR. Okay. And to the best of your knowledge. KIDD: No. FUGETT: Is there a particular communication 16 17 that you're referring to? Or are you referring generally. FUGETT: Object to form. KIDD: Q.) BY MR. Parsons BACKORDER 14-CA-8902 Page 10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. 22 23 MR.there's not really a status per se. Okay. MR. -. would you -- 18 19 MR. I don't know that it says anything specific about that -BY MR. KIDD: Q. would they need to notify the State? MR. If a company's financial position changes after they have started the application process. 17 18 if Seafarer had done this. FUGETT: Object to form. THE WITNESS: I don't have the rule in front of me.

3 with Kyle Kennedy? 4 MR. defendant. Whether it was a meeting. Approximately. We will read if ordered. to the best of my knowledge. you'll be able to see that in all of these documents. The other would be -. so we would like to recess this for the current time with the possibility of reopening. all this stuff is kept and produced when asked for. we are the plaintiffs in this case. I'm sorry I didn't get a 24 A. KENNEDY: I don't know either. There may be some of that in 2 that this deposition was scheduled by plaintiffs. 7 Dr. I didn't 19 mean it. Okay. how many times have you met 10 MR. and we'll take a look at it.they asked for who they wanted. and we 7 Q. 5 Q. Similar to the last one. 9 to. HUFFMAN: Q. That was the end of my 18 objection. FUGETT: Just guess. 25 chance to be there today.let me -- Just to follow up. 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Do you recognize Kyle Kennedy? 6 plaintiff. Fugett. that would be in the records. FL 32303 (850) 894-0828 Reported by: Kairisa Magee premier-reporting. MR. 15 MR. you know. Parsons. 19 MR. They 3 there. sometimes I'll send an e-mail 1 2 describing the conversation. that is not going to be 10 the fault of the Department of State or any of these 11 witnesses. We 6 have cooperated fully. again. These are documents that they 7 probably already have a lot of them or that they could 8 have brought with them. FUGETT: Don't ask him for help -- 14 That's it for me. I'm going to say that. Indeed. an e-mail. 18 that's fine. I didn't mean to cut you off. have you had personal meetings 2 3 MR. If you think there's something that we don't have. a phone call. Yes. if there was any e-mail communication setting up a meeting. 16 He's ready to answer any and all questions that you might 17 have. I'm sorry. vs Darrell Volentine Deposition of Timothy A. we received about 2. 18 THE WITNESS: No. FUGETT: Okay. KENNEDY: No wonder it's so thick.6/2/2016 Seafarer Exploration Corp. To the person I was on the phone with. I'm sorry. Parsons without a court order 21 forcing us to do so. right? 23 Premier Reporting 114 W.100 documents today. this depo is 19 closed for good. I want to say on the record 1 somebody on the phone. no. Of 2015. Dr.let me -. Late December. Who would you send that e-mail to? A. give me a call. I think -. To the extent that they were not 9 prepared for these depositions. And we join you in your 10 with Kyle Kennedy? A. 20 Go ahead. Yeah. any party. no. but as far as we're concerned. MR. Parsons' deposition again. every contact with Kyle Kennedy and Seafarer between that group and the Department of State is reflected in these documents. KIDD: Okay. 14 THE WITNESS: I'm sorry. obviously. We can't -. HUFFMAN: Right. 5 reflects that any party in this case. Again. FUGETT: All right. and 14 we will want to appear before the court and have a court 15 order before he is deposed again in matter. and we're not going to let you have 20 another deposition of Dr. FUGETT: All right. or something or something else.com . And when did you take over as director? 24 represent Seafarer Exploration.two times? 13 foundation as previously objected to. we object to it. 21 17 MR. FUGETT: -. MR. MR. Tallahassee. Yes. I believe I have in person with Kyle Kennedy 11 objection as to any documents that are attempted to be 11 12 provided or entered into exhibits which don't have the 12 two -. They asked what they wanted. Okay. 20 21 It might have been three. 13 MR. or anybody wants to take 6 A. 15 MR. KENNEDY: I was wondering about that.which. To the extent that you ever want to take 12 13 Dr. Yes. HUFFMAN: And not to scare Dr.I mean. 4 They asked -. we will object to that. I only have one question. 9 Q. 3 controlled the scheduling. He is here. 5th Avenue. again. but I think two in-person EXAMINATION 22 meetings. 22 BY MR. Any part -. Parsons -- 22 23 this is Craig Huffman representing Seafarer -. I got that 1 2 wrong. Kennedy 16 has not been sworn in.make sure that the record 4 A. 24 Mr. Parsons BACKORDER 14-CA-8902 Page 14 5 Page 15 MR. 25 It's the defendant -- Page 16 Page 17 1 there. If you close the depo out. MR. Okay.Mr. I'm Craig Huffman. and he has done so. but I appreciate you being 25 Q. FUGETT: Again. so you've got it all. I 23 Q. Is Kyle Kennedy sitting in the room with you? 8 will not do so absent a court order saying that we have 8 A. and how much 5 time they were going to spend with those individuals. Parsons' deposition again. 16 And -17 MR. KIDD: And if it helps.I think it's been two times. for the record. HUFFMAN: I'm sorry. and you're free to have everything that we've got on this case.

4 STATE OF FLORIDA 5 MR. Parsons BACKORDER 14-CA-8902 Page 18 1 2 A.com . certify that the 9 10 the witness did not waive his right to read and sign. we will read. HUFFMAN: Okay. FUGETT: Any follow-up? 5 6 MR. 17 _________ ______________________________ _________ 18 18 _________ ______________________________ _________ 19 19 _________ ______________________________ _________ 20 20 _________ ______________________________ _________ 21 21 _________ ______________________________ _________ 22 23 24 __________________________ KAIRISA JOI MAGEE NOTARY PUBLIC COMMISSION #FF971623 EXPIRATION DATE MARCH 15. DARRELL VOLENTINE) I. 2016 REPORTER: KAIRISA MAGEE 24 25 (850) 894-0828 Reported by: Kairisa Magee premier-reporting. 16 16 17 17 18 18 19 19 20 20 __________________________ 21 21 22 22 23 23 KAIRISA JOI MAGEE NOTARY PUBLIC COMMISSION #FF971623 EXPIRES MARCH 15. the undersigned authority. KAIRISA JOI MAGEE. Professional Court 6 Reporter. 2016.) 10 above-named witness personally appeared before me and was 11 11 duly sworn. FUGETT: All right.. are a true and correct record of the aforesaid 9 _________ ______________________________ _________ 10 _________ ______________________________ _________ 11 proceedings. 3 4 THE WITNESS: You're welcome. 11 _________ ______________________________ _________ 9 my supervision. Then we're done. That's all I have. Thank 6 2 3 you. TIMOTHY PARSONE 5 (SEAFARER V. 5th Avenue.m. Parsons. Dr. nor 13 _________ ______________________________ _________ 14 am I a relative or employee of any of the parties' 14 _________ ______________________________ _________ 15 attorney or counsel connected to this action. ) ) 8 9 (Whereupon the deposition was concluded at 12:34 p. sir. KIDD: No. 6 COUNTY OF LEON 7 MR.6/2/2016 Seafarer Exploration Corp. Pages 1 through 21 and hereby subscribe to same. including any ) ) 3 corrections and/or amendments listed below. 12 _________ ______________________________ _________ 13 employee. Correct. 7 _________ ______________________________ _________ REASON FOR CHANGE 8 that my shorthand notes were thereafter translated under 8 _________ ______________________________ _________ 10 21. 2016. certify that the foregoing proceedings were 6 PAGE/LINE CORRECTION/AMENDMENT 7 taken before me at the time and place therein designated. vs Darrell Volentine Deposition of Timothy A. and if 7 8 it's ordered. and the foregoing pages numbered 1 through I further certify that I am not a relative. and I. 2020 24 24 25 25 WITNESS my hand and official seal 21st day of Page 20 1 CERTIFICATE OF REPORTER 2 STATE OF FLORIDA 3 COUNTY OF LEON 2 I have read the transcript of my deposition. FL 32303 22 23 DATE OF DEPOSITION: JUNE 2. Page 19 CERTIFICATE OF OATH 1 MR. Tallahassee. 12 12 13 13 14 14 15 15 June. 16 _________ ______________________________ _________ 12 17 DATED this 21st day of June. attorney or counsel of any of the parties. 4 DATE:__________________________ __________________________ 4 5 Page 21 ERRATA SHEET 1 DR. 2020 25 Premier Reporting 114 W. nor am I 15 _________ ______________________________ _________ 16 financially interested in this action.