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IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT

IN AND FOR HILLSBOROUGH COUNTY, FLORIDA

CIVIL

DIVISION

SEAFARER EXPLORATION CORP.,

Plaintiff,

Vs. CASE NO.: 14-CA-8902

DIV. B

DARRELL VOLENTINE,

Defendant.

_______________________________/

RESPONSE OF PLAINTIFF SEAFARER EXPLORATION TO DEFENDANTS

FIRST SET OF INTERROGATORIES

Plaintiff, Seafarer Exploration, through the undersigned attorney, hereby submits the

following responses to the Defendants first set of interrogatories.

FIRST SET OF INTERROGATORIES

1. What is the name and address of the person answering these

interrogatories, and, if applicable, the person's official position or relationship with SEC?

Kyle Kennedy, Chief Executive Officer and Chairman, Seafarer Exploration Corp.

2. List the names and addresses of all persons who are believed or known by you,

your agents, or your attorneys to have any knowledge concerning any of the issues in this

lawsuit; and specify the subject matter about which the witness has knowledge.

Gregg Petrakis

Unknown

Fred Rector

14204 Chesnay Court,

Little Rock, AR 72211

Jon Kennedy

45 Pebble Beach Dr.

Little Rock, AR 72212

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Len Kohl

200 Carnegie Beach Road

Port Perry, Ontario

3. Identify each item of expense or damage that are you claiming in connection

with each Count of your Complaint.

Loss of shares due to lower stock price caused primarily by the postings of the Defendant.

SEAFARERs common stock traded as high as $0.0245 per share in July 2014, and as low as a recent level of $.006 per share in October 2014. Such decline in price was primarily, or in part

due to the postings by VOLENTINE, which are addressed herein. Calculation of damages caused

is based on the amount of shares that were issues which were more at a lower price, than would

have been issued at the higher price due to the Defendants actions.

Included in the request for production, is the subscription agreements which were done at

the lower values of $.007 and $.008 per share were used due to the lower stock price during the

period of the Defendants posting. As well conversions based upon lower stock price are included

in such calculations as provided in the documents produced.

As well the stock price is reflected upon the produced stock price chart drawn from Yahoo

Finance, which shows the weekly stock price, and the lower prices due to the Defendants postings.

On July 1, 2014, the share price of the corporation was $0.0245 per share. Due to the postings of

the Defendant the stock price to $0.006 per share in October 1, 2014 when the Defendant was still

posting libelous matters. Thus Seafarers 6,000 shareholders had a loss in value of $ 15,901,554.00 to their holdings. This is directly attributable to the actions of the Defendant. The number of shares

issued on July 1, 2014 was 883,419,726 shares.

4. Identify every document that supports each item of expense or damage identified in

Paragraph 3 above.

As provided by the Stock Transfer Agent and the Corporation, the items of damages are

set forth in the response to request for production and as stated above. These include subscription

agreements that were in place during such time period, as well as the stock transfer agents share breakdown representing the shares outstanding on July 1, 2014, and October 1, 2014. The pricing

charts provided by public information for the price of the stock on yahoo.com as well as

otcmarkets.com show the pricing and performance of Seafarers shares on each day.

5. Identify each item of expense or damage that are you claiming in connection

with your Motion.

We are uncertain what motion is being contended. An emergency motion was brought before the

Court for sanctions for continued posting by the Defendant.

Loss of stock/share value to the shareholders of the Corporation. As well as provided on the

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produced share issuance data as addressed in number 3 and 4 above, the amount of shares issued

were greater than what would have been needed to be issued at the lower price of $0.0245 per

share, due to the Defendants actions and postings. On July 1, 2014, the share price of the

corporation was $0.0245 per share. Due to the postings of the Defendant the stock price to $0.006

per share in October 1, 2014 when the Defendant was still posting libelous matters. Thus Seafarers 6,000 shareholders had a loss in value of $ 15,901,554.00 to their holdings. This is directly

attributable to the actions of the Defendant.

6. Identify every document that supports each item of expense or damage identified in

Paragraph 5 above.

Objection, duplicative. See documents produced and as stated in number 3 above.

7. List the names and addresses of all persons who are believed or known by you,

your agents, or your attorneys to have any knowledge concerning any of the issues in your

Motion; and specify the subject matter about which the witness has knowledge.

Gregg Petrakis

Fred Rector

Jon Kennedy

8. List the names and addresses of all expert witnesses you have consulted with or

retained and who you expect to testify, and for each expert witness specify the area of expertise

and the subject matter about which the witness is expected to testify.

No experts have been identified at this time for purposes of trial.

9. Do you contend that Defendant is the only person or entity that posted false

or misleading information with regard to SEC and/or Kyle Kennedy on the internet? If

your answer is no, identify all other persons or entities that posted false or misleading

information with regard to SEC and/or Kyle Kennedy and identify the false or misleading

information that was posted.

Objection. This would be an affirmative defense to damages. Seafarer has no obligation to decipher

other postings, and is not aware of any other defamatory postings during such period.

10. What was the price per share of SEC stock at the close of business on the

2nd

and 16th

of each month from January 2010 to the present.

Such price chart is provided as to a weekly basis in documentation provided to the Defendant in an

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Excel sheet. The actual parameters of a price chart for those days can not be provided as such.

Defendant can find such on Yahoo Finance where historical prices are attainable, as well as other

stock price web sites.

11. Identify your stock transfer agent and identify any employees, officers, or directors

of the stock transfer agent that are related to any employee, officer, or director of SEC.

ClearTrust LLC Kara Kennedy and Kyla Kennedy are Kyle Kennedys daughters. Juan Osorio is his son-in-law.

12. Identify all press releases issued by SEC from January 1, 2010 to the present and

for each press release identify the author.

All Press Releases of Seafarer Exploration are on its site of www.seafarerexploration.com available

to the Defendant. As well all press releases are available from martketwatch.com, otcmarkets.com,

and numerous other public sources.

13. Identify the officers and directors of SEC from January 2013 to the present.

Kyle Kennedy CEO Charles Branscum Director Robert Kennedy - Director

14. Identify all contracts and vendors that have been lost by SEC as a result of the

postings of Defendant.

There have not been established vendor losses. However, the company did suffer sales of shares

that were sold by shareholders. Additionally, the company had to distribute a vast number of shares

which were in addition to what would have had to be issued due to the actions of the Defendant.

On July 1, 2014, the share price of the corporation was $0.0245 per share. Due to the postings of

the Defendant the stock price to $0.006 per share in October 1, 2014 when the Defendant was still

posting libelous matters. Thus, the company had to issue three times more shares than it would

have had to issue when the price was higher. As an example, if such share price were at $0.024 per

share, and the

company were selling restricted shares for $10,000, then the company would issue 408,163 shares.

However, due to the price declination due to the Defendants postings, when such share price was declined to $0.006 per share, then the company would have to issue 1,666,667 shares. This is a vast

amount of dilution to the shareholders of the Company due to the Defendants actions.

15. Describe in detail how you determined that Defendants postings between July 2014

and September 3, 2014 were the cause of any diminution of SECs stock value.

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Seafarer received numerous enquiries through shareholders, directors, officers and

outsiders as to the postings when they occurred. Direct information by at least one and more

shareholders stated they were selling their positions or parts of positions due to the allegations

being made by the Defendant. This caused pressure on the stock price where there otherwise

would not have been sales being made.

16. Is it your contention that Defendants posting from July 2014 to September

3, 2014, were the sole cause of the diminution of SECs stock value during that period? If not, describe in detail other factors that caused or contributed to the diminution of SECs stock value during that period.

For purposes of our causes of action, and the damages caused, yes, this is our sole

contention. We are not aware of any other factors. Any other factors would be affirmative defenses

of the Defendant to damages.

17. Describe in detail how you determined that Defendants actions on October

1, 2104, were the cause of any diminution of SECs stock value.

Objection. Calls for a legal conclusion and finding of fact which has already been stated in the

Complaint and in number 15 above. On July 1, 2014, the share price of the corporation was

$0.0245 per share. Due to the postings of the Defendant the stock price to $0.006 per share in

October 1, 2014 when the Defendant was still posting libelous matters. Thus Seafarers 6,000 shareholders had a loss in value of $ 17,000,000.00 to their holdings. This is directly attributable to

the actions of the Defendant.

18. Is it your contention that Defendants actions on October 1, 2014, were the sole

cause of the diminution of SECs stock value after such actions? If not, describe in detail other factors that caused or contributed to the diminution of SECs stock value.

Yes. Any other cause is unknown. The Defendant may present other information to offset damages

at the trial on damages.

19. Identify all lawsuits filed by or against SEC from January 2010 to the present.

MICAH ELDRED v Seafarer Exploration, Kyle Kennedy, Charles Branscum and Robert

Kennedy. Hillsborough Circuit Court Civil Action No. 14-CA-5360

Sunpwr LLC vs. Seafarer Exploration, Martin County, Florida Court

20. Identify all lawsuits filed against Kyle Kennedy from January 2010 to the present

that relate in any way to SEC.

See above.

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21. Identify all compliance complaints or notices of violation issued against

SEC by any county, state, or federal entity from January 2010 to the present.

Seafarer is not aware of any such matter. Any such matter would be disclosed in public filings by

the Corporation, and none were found.

22. Describe in detail how SEC first become aware of Defendants postings about

the SEC.

Response: Numerous phone calls and messaged came to Kyle Kennedy and Seafarer Office as to

such postings.

23. Identify who, on behalf of SEC, is responsible for reviewing internet

message boards, blogs, or any other published material that affects SEC.

Seafarer has no person assigned to such duties. Shareholders and others send messages and/or

phone calls of postings to bring it to attention of Seafarer. Then outside counsel may be called upon

to review such postings as a matter of course to determine if an action is warranted in order to

protect the shareholders.

24. Identify (including, without limitation, their name, address, email address, and

relationship, if any, to SEC or Kyle Kennedy) the following aliases which post/have posted on

Ihub regarding SEC:

a. wlfr01 - Unknown

b. BISerNOMORE Michael Ware- Independent Contractor, Deckhand. c. goldfinger2 Brendan Burke, Investor

d. GREGG THE GREEK Gregg Petrakis

Seafarer v Volentine - Seafarer Response First Volentine Interrogatories 6-15-15.pdfKyle sigature page.pdf