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Dr. Mary Glowacki Deposition SFRX Sham Lawsuit
Dr. Mary Glowacki Deposition SFRX Sham Lawsuit
vs Darrell Volentine
Deposition of Mary Glowacki BACKORDER 14-CA-8902 1
4 SEAFARER EXPLORATION
CORP.,
5
6 Plaintiff,
vs. CASE NO.: 14-CA-8902
7 DIV. L
9 DARRELL VOLENTINE,
10 Defendant.
______________________/
11
THE DEPOSITION OF: DR. MARY GLOWACKI
12
AT THE INSTANCE OF: THE DEFENDANT
13
DATE: JUNE 2, 2016
14
TIME: COMMENCED: 10:12 a.m.
15
LOCATION: PREMIER REPORTING
16 114 W. 5TH AVENUE
TALLAHASSEE, FLORIDA 32301
17
REPORTED BY: KAIRISA MAGEE
18 Court Reporter and
Notary Public in and for
19 State of Florida at large
20
21
22
23 PREMIER REPORTING
114 W. 5TH AVENUE
24 TALLAHASSEE, FLORIDA 32303
(850)894-0828
25
1 APPEARANCES:
8
ON BEHALF OF THE DEFENDANT:
9
Evan Kidd, Esquire
10 704 1st Court
Palm Harbor, Florida 34684
11 (727) 786-3015
12
18
ALSO PRESENT:
19
Mr. Mark Blumstin
20 Mr. Kyle Kennedy
Mr. Thomas Soeder
21
22
23
24
25
1 EXAMINATION INDEX
2
EXAMINATION OF DR. MARY GLOWACKI
3 BY MR. KIDD . . . . . . . . . . . . . . . . 4
BY MR. HUFFMAN . . . . . . . . . . . . . . 58
4 FURTHER BY MR. KIDD . . . . . . . . . . . . 70
5
6
7 EXHIBIT INDEX
8 MAR
Plaintiff's Exhibit
9 6 Documents. E-mail dated Sunday, 63
02114/16 05:32:51 PM
10
11 Defendant's Composite Exhibit
5 Documents and CD provided by the Florida 54
12 Bueau of Archaeological Research
13
Defendant's Exhibit
14 1 SEAFARER EXPLORATION CORP. AND 30
SUBSIDIARIES
(A Development Stage
15 Company)
NOTES TO CONDENSED FINANCIAL
STATEMENTS
(Unaudited)
16
2 Document. 10K 34
17
3 Document. Exploration Permit with the 37
18 Florida Division of Historical Resources
for an Area off of Juno Beach, Florida
19
4 Document. Entitled "Seafarer 39
20 Exploration
Corp. Discovers
Silver
Treasure Coins at
Salvage Site"
21
22
23
**Uh-uh is a negative response
24 **Uh-huh is a positive response
25
1 D E P O S I T I O N
2 Whereupon,
3 MARY GLOWACKI
7 follows:
8 EXAMINATION
9 BY MR. KIDD:
11 A. Good morning.
14 A. No.
25 complete as possible.
1 A. (Nodding)
2 Q. All right --
5 Dr. Glowacki.
9 to her.
14 pretty loud; so --
15 BY MR. KIDD:
20 record.
21 A. Yes.
22 Q. Thank you.
2 A. Archaeologist.
5 background please?
9 Q. Okay.
15 I received my Ph.d.
16 Q. Okay.
21 BY MR. KIDD:
4 will be here.
9 laying foundation.
15 authenticity. I apologize.
18 foundation.
20 BY MR. KIDD:
1 about anything --
7 them.
9 BY MR. KIDD:
18 lot of documents.
1 looked at everything.
8 not be hers.
10 MR. FUGETT: So --
12 please.
15 BY MR. KIDD:
17 A. Yes.
1 for me?
12 that is.
17 Q. Yes.
21 guess?
24 remains of shipwrecks.
9 BY MR. KIDD:
13 1A-31.
15 A. The rules?
17 permit.
1 BY MR. KIDD:
4 A. I --
5 Q. So --
7 Q. Sure. Sure.
12 A. Yes.
19 was completed --
20 Q. Okay.
2 Q. Okay.
9 Beach, or Lantana.
17 permit.
19 BY MR. KIDD:
25 Q. Okay.
5 A. It was Area 2.
7 citywise, townwise?
9 Q. Sure.
13 A. -- do that?
15 map.
20 see what you have in here and see if you can find
21 it.
3 more specific?
7 down; so --
22 BY MR. KIDD:
23 Q. Okay.
25 BY MR. KIDD:
6 BY MR. KIDD:
11 Q. Okay.
14 BY MR. KIDD:
21 and --
22 Q. Okay.
4 means to be anomaly?
6 Go ahead.
10 Sonar that's used. And lines are run back and forth
14 BY MR. KIDD:
15 Q. Okay.
20 remains of a shipwreck.
8 Go ahead.
12 BY MR. KIDD:
15 A. Yes.
21 contract --
22 Q. Okay.
24 calls.
9 do that --
13 BY MR. KIDD:
24 her about --
4 BY MR. KIDD:
11 modification?
12 A. Yes.
14 Area 1?
16 Go ahead.
18 yet.
19 BY MR. KIDD:
21 A. Yes.
22 Q. Thank you.
3 to --
8 first.
12 there.
15 BY MR. KIDD:
23 Go ahead.
13 still answer.
17 BY MR. KIDD:
19 A. Please.
20 Q. No problem. Okay.
22 issuance" --
1 coffee today.
2 BY MR. KIDD:
11 statement or not?
13 yes.
15 Go ahead.
18 context. I can't --
19 BY MR. KIDD:
20 Q. Right.
21 A. -- comment.
9 that.
13 do?
15 question.
16 BY MR. KIDD:
15 my client?
20 question.
5 BY MR. KIDD:
9 Historical Resources?
16 exploration permit?
20 recovery --
21 Q. Sure.
24 people.
2 permit?
5 salvagers --
6 BY MR. KIDD:
9 permit --
18 BY MR. KIDD:
20 exploration permit?
3 BY MR. KIDD:
4 Q. Okay.
16 BY MR. KIDD:
17 Q. No.
22 Q. Okay.
25 allowed to recover?
2 Go ahead.
7 affiliation.
15 can hear.
17 BY MR. KIDD:
24 ahead.
1 BY MR. KIDD:
2 Q. Thank you.
3 So --
6 question?
8 reporter.)
14 Exhibit 1.
16 identification.)
19 the class.
20 Mr. Evan?
7 BY MR. KIDD:
9 document?
10 A. Yes.
15 BY MR. KIDD:
19 Historical Resources."
4 the Bureau that I'm aware of. But you can ask
12 BY MR. KIDD:
17 date, but I can tell you that Tulco and Seafarer did
13 please.
15 identification.)
16 BY MR. KIDD:
18 2015.
9 it.
18 BY MR. KIDD:
2 BY MR. KIDD:
5 aforementioned site?
7 Go ahead.
9 BY MR. KIDD:
14 Q. Absolutely.
20 permit?
3 this.
11 is it?
15 identification.)
24 and let us know when she'd done, and counsel may ask
1 (Pause.)
4 BY MR. KIDD:
6 it over?
7 A. Yes.
14 BY MR. KIDD:
21 Go ahead.
24 BY MR. KIDD:
2 Q. Okay.
4 Exhibit 4.
6 identification.)
8 use a sticker?
18 questions. And --
21 BY MR. KIDD:
1 Beach, Florida.
7 Go ahead.
10 BY MR. KIDD:
12 reporting requirements?
17 can answer.
20 That'll be good.
1 Go ahead.
2 BY MR. KIDD:
3 Q. Please proceed.
17 Go ahead.
22 BY MR. KIDD:
24 that information?
1 here today.
9 Exhibit 4?
18 dates.
24 So object to form.
3 BY MR. KIDD:
5 of this discovery?
7 Go ahead.
10 BY MR. KIDD:
11 Q. Okay.
14 you today.
19 press release.
20 On Page 2 --
22 reference?
25 BY MR. KIDD:
7 findings reported?
13 question.
20 permitting.
21 BY MR. KIDD:
3 A. Yes.
12 BY MR. KIDD:
13 Q. Thank you.
15 need to be reported?
16 A. Yes, of course.
25 witness?
5 BY MR. KIDD:
8 in any way?
9 A. No.
11 needed?
13 Go ahead.
17 BY MR. KIDD:
21 Go ahead.
24 representative of Seafarer; so --
2 BY MR. KIDD:
8 recovery permit?
16 BY MR. KIDD:
19 A. No.
2 proposed.
3 BY MR. KIDD:
7 Go ahead.
9 BY MR. KIDD:
14 company?
22 things work.
7 objections.
8 BY MR. KIDD:
13 question?
15 reporter.)
17 Go ahead.
23 BY MR. KIDD:
5 BY MR. KIDD:
6 Q. No problem.
11 A. Yes --
13 compound.
19 BY MR. KIDD:
23 Go ahead.
3 BY MR. KIDD:
8 Go ahead.
11 BY MR. KIDD:
13 Something you --
17 Go ahead.
4 work.
5 BY MR. KIDD:
7 2014?
11 BY MR. KIDD:
13 submitted?
14 A. Yes.
17 Fleet?
2 not.
3 BY MR. KIDD:
6 Fleet.
9 Go ahead.
10 THE WITNESS: Oh --
13 Yes.
14 BY MR. KIDD:
24 BY MR. KIDD:
3 Go ahead.
10 significance.
7 MR. KIDD: 5.
13 admission.
7 that?
12 could --
17 please.
25 proper.
17 I think the --
19 all good.
25
1 EXAMINATION
2 BY MR. HUFFMAN:
5 A. Yes.
10 maybe.
11 Q. Okay.
22 Go ahead.
24 bureau chief.
25 BY MR. HUFFMAN:
3 A. Yes.
4 Q. Okay.
16 clarifications --
18 the question?
19 BY MR. HUFFMAN:
2 Go ahead.
4 case.
5 BY MR. HUFFMAN:
9 permit?
13 BY MR. HUFFMAN:
20 BY MR. HUFFMAN:
21 Q. Yes, ma'am.
4 north to south.
6 backwards.
7 BY MR. HUFFMAN:
16 identify.
17 BY MR. HUFFMAN:
19 sought?
21 BY MR. HUFFMAN:
2 Q. Understood.
6 talked about?
9 BY MR. HUFFMAN:
15 Go ahead.
19 BY MR. HUFFMAN:
20 Q. Yes.
3 area.
4 BY MR. HUFFMAN:
16 some e-mails.
20 identification.)
16 BY MR. HUFFMAN:
19 question.
24 A. Yes.
7 is what?
12 BY MR. HUFFMAN:
15 at the bureau?
16 A. Exploration.
20 exploration permit.
4 BY MR. HUFFMAN:
10 Go ahead.
13 BY MR. HUFFMAN:
16 Lantana?
18 Go ahead.
20 BY MR. HUFFMAN:
24 "Melbourne"?
6 doctor.
8 question?
12 BY MR. HUFFMAN:
19 items --
22 familiar with?
1 under a contract --
2 BY MR. HUFFMAN:
3 Q. Okay.
5 different protocol.
12 Go ahead.
14 BY MR. HUFFMAN:
22 Q. Oh, okay.
18 anything.
20 have.
22 ordered --
24 up.
25 FURTHER EXAMINATION
1 BY MR. KIDD:
9 question.
19 Melbourne.
20 BY MR. KIDD:
25 BY MR. KIDD:
2 permit?
5 BY MR. KIDD:
9 Go ahead.
14 record.)
19 you said recess. That may have made the record, but
2 record.
4 12:08 p.m., and the witness did not waive her right
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1 CERTIFICATE OF OATH
4 STATE OF FLORIDA
6 COUNTY OF LEON
11 duly sworn.
12
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15 June, 2016.
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1 CERTIFICATE OF REPORTER
2
STATE OF FLORIDA
3 COUNTY OF LEON
11 proceedings.
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21
Wlli .
KAIRis.f:roI ftAGE~
22
23 NOTARY PUBLIC
COMMISSION #FF971623
24 EXPIRATION DATE MARCH 15, 2020
25
1 ERRATA SHEET
4 DATE:__________________________ ___________________
DR. MARY GLOWACKI
5 (SEAFARER V. DARRELL VOLENTINE)
22
DATE OF DEPOSITION: JUNE 2, 2016
23
REPORTER: KAIRISA MAGEE
24
25