UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF FLORIDA 

TALLAHASSEE DIVISION 

GLOBAL MARINE 

EXPLORATION, INC., 

Plaintiff, CASE NO: 4:20-cv-00181-AW/MJF 

vs. 

REPUBLIC OF FRANCE, 

Defendant. 

/ 

AMENDED COMPLAINT 

Plaintiff, GLOBAL MARINE EXPLORATION, INC. ("GME") brings this 

action against Defendant, REPUBLIC OF FRANCE, and says: 

1. This action relates to valuable historic shipwreck sites discovered by 

GME on sovereign submerged lands under authority of the State of Florida's salvage 

activity program. France has collaborated with the State of Florida to recover the 

sites and their value for their own purposes, using GME's confidential locational 

information, in derogation of GME's rights and entitlements. GME undertook 

massive efforts and incurred significant financial expenditure discovering and 

locating the sites in justifiable reliance upon its program rights being honored and is 

entitled to relief against France to vindicate its rights under both admiralty law and 

Florida law. 

1 1

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF FLORIDA

TALLAHASSEE DIVISION

GLOBAL MARINE

EXPLORATION, INC., 

Plaintiff, CASE NO: 4:20-cv-00181-AW/MJF

vs.

REPUBLIC OF FRANCE,

Defendant.

___________________________________/

AMENDED COMPLAINT

Plaintiff, GLOBAL MARINE EXPLORATION, INC. (“GME”) brings this 

action against Defendant, REPUBLIC OF FRANCE, and says:

1. This action relates to valuable historic shipwreck sites discovered by 

GME on sovereign submerged lands under authority of the State of Florida’s salvage 

activity program. France has collaborated with the State of Florida to recover the 

sites and their value for their own purposes, using GME’s confidential locational 

information, in derogation of GME’s rights and entitlements. GME undertook 

massive efforts and incurred significant financial expenditure discovering and 

locating the sites in justifiable reliance upon its program rights being honored and is 

entitled to relief against France to vindicate its rights under both admiralty law and 

Florida law.

Case 4:20-cv-00181-AW-MJF Document 3 Filed 04/17/20 Page 1 of 21
2. This Court has jurisdiction pursuant to Article III, § 2 of the United 

States Constitution and 28 U.S.C. § 1330 (a) (2019) providing that the United States 

District Courts shall have original jurisdiction without regard to amount in 

controversy of any nonjury civil action against a foreign state as to claims for relief 

in personam with respect to which the foreign state is not entitled to immunity either 

under 28 U.S.C. §§ 1605-1607 or applicable international agreement. 

3. Defendant is the Republic of France, a foreign country, that is not 

entitled to immunity either under federal law or international agreement with respect 

to the claims for relief in personam brought by this complaint. 

4. The Court has subject matter jurisdiction over the claims herein 

pursuant to 28 U.S.C. § 1605 (2019), because Defendant France is engaging in 

commercial venture activity in Florida that affects GME. France's activity is of a 

nature that private parties would do, regardless of the purpose of the activity, and 

therefore is commercial activity.* 

* See Republic of Arg. v. Weltover, 504 U.S. 607, 614 (1992) (Under the FSIA's 

definition of "commercial activity," whether a foreign government acts out of a profit 

motive or out of a desire to fulfill "uniquely sovereign objectives" is entirely 

irrelevant to the analysis of whether an activity qualifies as "commercial." Instead, 

we must determine "whether the particular actions that the foreign state performs 

(whatever the motive behind them) are the type of actions by which a private party 

engages in trade and traffic or commerce)." 

2 2

2. This Court has jurisdiction pursuant to Article III, § 2 of the United 

States Constitution and 28 U.S.C. § 1330 (a) (2019) providing that the United States 

District Courts shall have original jurisdiction without regard to amount in 

controversy of any nonjury civil action against a foreign state as to claims for relief 

in personam with respect to which the foreign state is not entitled to immunity either 

under 28 U.S.C. §§ 1605–1607 or applicable international agreement.

3. Defendant is the Republic of France, a foreign country, that is not 

entitled to immunity either under federal law or international agreement with respect 

to the claims for relief in personam brought by this complaint. 

4. The Court has subject matter jurisdiction over the claims herein 

pursuant to 28 U.S.C. § 1605 (2019), because Defendant France is engaging in 

commercial venture activity in Florida that affects GME. France’s activity is of a 

nature that private parties would do, regardless of the purpose of the activity, and 

therefore is commercial activity.*

 

* See Republic of Arg. v. Weltover, 504 U.S. 607, 614 (1992) (Under the FSIA’s

definition of "commercial activity," whether a foreign government acts out of a profit 

motive or out of a desire to fulfill "uniquely sovereign objectives" is entirely 

irrelevant to the analysis of whether an activity qualifies as "commercial." Instead, 

we must determine "whether the particular actions that the foreign state performs 

(whatever the motive behind them) are the type of actions by which a private party 

engages in trade and traffic or commerce)."

Case 4:20-cv-00181-AW-MJF Document 3 Filed 04/17/20 Page 2 of 21
5. This court has personal jurisdiction over Defendant as a foreign state 

pursuant to 28 U.S.C. § 1330 (b) (2019) with respect to the claims herein for which 

the Court has subject matter jurisdiction. 

6. Venue lies in this Court pursuant to 28 U.S.C. § 1391(f) (1) (2019) 

because a substantial part of the events giving rise to Plaintiff's claims have taken 

place and will continue to take place in Leon County, Florida, in the Tallahassee 

Division of the Northern District of Florida. The events include France's 

negotiations with the Florida Department of State, Division of Historical Resources, 

to reach agreement to, and to undertake operations to recover, conserve, study and 

exhibit in Florida historic shipwrecks discovered by GME; entering into one or more 

agreements to carry out and implement such operations, and communications 

relative thereto; and planning, coordinating, and directing work with the State of 

Florida, Department of State with respect to those activities for mutual benefit. 

7. Plaintiff GME is a Florida corporation that conducted marine salvage 

activity and discovered historic shipwreck sites in State coastal waters on sovereign 

submerged lands under authorization agreement with the Florida Department of 

State, Division of Historical Resources, pursuant to its commercial salvage activity 

program, and with all other required governmental approvals. 

8. The Florida Department of State, Division of Historical Resources 

("DOS") administers historical shipwreck resources on State-owned coastal 

33 

5. This court has personal jurisdiction over Defendant as a foreign state 

pursuant to 28 U.S.C. § 1330 (b) (2019) with respect to the claims herein for which 

the Court has subject matter jurisdiction.

6. Venue lies in this Court pursuant to 28 U.S.C. § 1391(f) (1) (2019) 

because a substantial part of the events giving rise to Plaintiff’s claims have taken 

place and will continue to take place in Leon County, Florida, in the Tallahassee 

Division of the Northern District of Florida. The events include France’s 

negotiations with the Florida Department of State, Division of Historical Resources, 

to reach agreement to, and to undertake operations to recover, conserve, study and 

exhibit in Florida historic shipwrecks discovered by GME; entering into one or more 

agreements to carry out and implement such operations, and communications 

relative thereto; and planning, coordinating, and directing work with the State of 

Florida, Department of State with respect to those activities for mutual benefit. 

7. Plaintiff GME is a Florida corporation that conducted marine salvage 

activity and discovered historic shipwreck sites in State coastal waters on sovereign 

submerged lands under authorization agreement with the Florida Department of 

State, Division of Historical Resources, pursuant to its commercial salvage activity 

program, and with all other required governmental approvals.

8. The Florida Department of State, Division of Historical Resources 

(“DOS”) administers historical shipwreck resources on State-owned coastal 

Case 4:20-cv-00181-AW-MJF Document 3 Filed 04/17/20 Page 3 of 21
submerged lands. Pursuant to Section 267.031, Florida Statutes, Florida DOS agrees 

and contracts for commercial salvage activity, i.e. survey, exploration, identification, 

excavation and recovery of historical shipwreck sites by commercial salvors, and for 

the transfer of resources or value equivalent for their services. 

9. Florida DOS entered into authorization agreements with GME to entitle 

it to conduct salvage activities in State coastal waters in designated areas off Cape 

Canaveral, Florida. 

10. The State of Florida, Division of State Lands conferred upon GME a 

fixed term "cultural resource recovery easement for salvage exploration and 

operational purposes" for the designated State-owned submerged lands, and the 

Florida Department of Environmental Protection and the Federal Corps of Engineers 

issued permits for GME to use designated submerged lands and navigable waters for 

such construction work. 

11. GME undertook prolonged and expensive research, survey, reporting, 

and identification of shipwrecked sites and artifacts and contents, with reasonable 

investment-backed expectation and program assurances that its salvage activity in 

State waters would be fully compensated based on the value of discovered sites. 

GME expended millions of dollars and enormous time and effort to survey, discover, 

locate, identify, analyze, and conserve the historic shipwreck sites and artifacts 

found. 

4 4

submerged lands. Pursuant to Section 267.031, Florida Statutes, Florida DOS agrees 

and contracts for commercial salvage activity, i.e.survey, exploration, identification,

excavation and recovery of historical shipwreck sites by commercial salvors, and for 

the transfer of resources or value equivalent for their services.

9. Florida DOS entered into authorization agreements with GME to entitle 

it to conduct salvage activities in State coastal waters in designated areas off Cape 

Canaveral, Florida. 

10. The State of Florida, Division of State Lands conferred upon GME a 

fixed term “cultural resource recovery easement for salvage exploration and 

operational purposes” for the designated State-owned submerged lands, and the 

Florida Department of Environmental Protection and the Federal Corps of Engineers 

issued permits for GME to use designated submerged lands and navigable waters for 

such construction work. 

11. GME undertook prolonged and expensive research, survey, reporting, 

and identification of shipwrecked sites and artifacts and contents, with reasonable 

investment-backed expectation and program assurances that its salvage activity in 

State waters would be fully compensated based on the value of discovered sites.

GME expended millions of dollars and enormous time and effort to survey, discover, 

locate, identify, analyze, and conserve the historic shipwreck sites and artifacts 

found.

Case 4:20-cv-00181-AW-MJF Document 3 Filed 04/17/20 Page 4 of 21
12. Beginning in 2014, the Florida DOS agreed with GME for salvage 

activity related to six different three-square mile areas off the coast of Cape 

Canaveral for renewable three-year terms. GME's efforts in these areas turned up 

some shipwreck evidence (anchors) dating in the 1700s, but mostly resulted in 

identification of rocket debris. 

13. On August 14, 2015, Florida DOS and GME entered a seventh 

agreement, being designated Permit No. 2015-03, specifically authorizing GME, on 

an exclusive term basis, to survey another designated three-square mile area off Cape 

Canaveral and locate and report any shipwreck sites discovered therein. 

14. Amendment One known as the Dig Addendum was subsequently 

added, recognizing GME's successful completion of the sensing survey work phase 

within the exclusive designated area, and specifically authorizing GME to undertake 

activity to identify newly discovered cultural materials and perform limited test 

excavation and diagnostic artifact recovery for shipwreck identification purposes, 

and specifically promising for their value to be pooled with the value of all ultimately 

recovered objects to calculate 80% thereof to be paid to GME. 

15. GME discovered five separate shipwrecks and six historic shipwreck 

sites within the exclusive area pursuant to Permit Agreement # 2015-03, as depicted 

by GME's mapped conclusions attached hereto as Exhibit 1. These mapped 

55 

12. Beginning in 2014, the Florida DOS agreed with GME for salvage 

activity related to six different three-square mile areas off the coast of Cape 

Canaveral for renewable three-year terms. GME’s efforts in these areas turned up 

some shipwreck evidence (anchors) dating in the 1700s, but mostly resulted in 

identification of rocket debris.

13. On August 14, 2015, Florida DOS and GME entered a seventh 

agreement, being designated Permit No. 2015-03, specifically authorizing GME, on 

an exclusive term basis, to survey another designated three-square mile area off Cape 

Canaveral and locate and report any shipwreck sites discovered therein. 

14. Amendment One known as the Dig Addendum was subsequently 

added, recognizing GME’s successful completion of the sensing survey work phase 

within the exclusive designated area, and specifically authorizing GME to undertake 

activity to identify newly discovered cultural materials and perform limited test 

excavation and diagnostic artifact recovery for shipwreck identification purposes, 

and specifically promising for their value to be pooled with the value of all ultimately 

recovered objects to calculate 80% thereof to be paid to GME.

15. GME discovered five separate shipwrecks and six historic shipwreck 

sites within the exclusive area pursuant to Permit Agreement # 2015-03, as depicted 

by GME’s mapped conclusions attached hereto as Exhibit 1. These mapped 

Case 4:20-cv-00181-AW-MJF Document 3 Filed 04/17/20 Page 5 of 21
conclusions were provided to the Florida DOS as part of GME's report 

accompanying its request for promised approval to proceed with recovery. 

16. GME provided its "Final Dig & Identify Report and Request for Rescue 

Recovery Permit" to the Florida DOS on June 30, 2016. GME described the various 

discovered historic shipwreck sites and artifacts; provided diagrams, underwater 

photographs, field notes, activity logs, inspection reports, archeological research 

assessment and documentation; and requested specific authorization for 

rescue/recovery to secure these historically significant artifacts. 

17. GME excavated and was conserving certain small artifact items from 

its discovered historic shipwreck Site #2, and provided the Florida DOS with 

photographic and video identification of certain cannons and monuments from that 

Site. These were relied on by the Florida DOS and Defendant France to surmise that 

shipwreck Site # 2 was probably the historic French vessel la Trinite, which was 

involved in French Huguenot resettlement and sank off the Florida coast below 

St. Augustine during a hurricane in 1565. 

18. GME's Final Dig and Identify Report submitted to Florida DOS did not 

include the precise data coordinate locations of any of the discovered historic 

shipwreck sites, but noted that in accordance with GME's research design plan of 

September 27, 2015 that: "GME will record every find with precise measurements 

singularly, and as a whole, sites to include . . . "description, compass heading, depth 

66 

conclusions were provided to the Florida DOS as part of GME’s report 

accompanying its request for promised approval to proceed with recovery. 

16. GME provided its “Final Dig & Identify Report and Request for Rescue 

Recovery Permit” to the Florida DOS on June 30, 2016. GME described the various 

discovered historic shipwreck sites and artifacts; provided diagrams, underwater 

photographs, field notes, activity logs, inspection reports, archeological research 

assessment and documentation; and requested specific authorization for 

rescue/recovery to secure these historically significant artifacts.

17. GME excavated and was conserving certain small artifact items from 

its discovered historic shipwreck Site #2, and provided the Florida DOS with 

photographic and video identification of certain cannons and monuments from that 

Site. These were relied on by the Florida DOS and Defendant France to surmise that 

shipwreck Site # 2 was probably the historic French vessel la Trinité, which was 

involved in French Huguenot resettlement and sank off the Florida coast below 

St. Augustine during a hurricane in 1565.

18. GME’s Final Dig and Identify Report submitted to Florida DOS did not 

include the precise data coordinate locations of any of the discovered historic 

shipwreck sites, but noted that in accordance with GME’s research design plan of 

September 27, 2015 that: “GME will record every find with precise measurements 

singularly, and as a whole, sites to include . . . “description, compass heading, depth 

Case 4:20-cv-00181-AW-MJF Document 3 Filed 04/17/20 Page 6 of 21
of waters, depth of overburden (sand, mud, mud clay, etc.), size, length, width, 

height, type of material, quality, condition, etc. This will include drawings and 

maps. In this way, the site plan of each site(s) will be compiled and recorded." 

19. The precise coordinate locations of the historic shipwreck sites 

discovered by GME and the methods GME used to identify those locations were 

owned by GME, and were considered proprietary, confidential trade secret 

information so maintained by GME. There was no requirement or agreement for 

public disclosure of this confidential information which was exempt from under 

Florida's Public Records Act. The confidentiality of the information and GME's 

entitlement for it to be maintained confidential was made known in writing to Florida 

DOS and confirmed as such by its personnel. 

20. Although GME was directed to submit the location coordinate 

information to the Florida DOS incident to that agency's oversight and inventory of 

historical resources, the information was to remain confidential, to be used 

commercially only by GME upon its full recovery of the shipwreck sites. 

21. The Florida DOS never raised any issue or ever commented or 

suggested that GME had improperly proceeded; nor had the Florida DOS ever 

indicated any reason or justification that GME would not be specifically authorized 

to fully recover its various shipwreck site finds and retain 80% of their value. 

77 

of waters, depth of overburden (sand, mud, mud clay, etc.), size, length, width, 

height, type of material, quality, condition, etc. This will include drawings and 

maps. In this way, the site plan of each site(s) will be compiled and recorded.” 

19. The precise coordinate locations of the historic shipwreck sites 

discovered by GME and the methods GME used to identify those locations were 

owned by GME, and were considered proprietary, confidential trade secret 

information so maintained by GME. There was no requirement or agreement for 

public disclosure of this confidential information which was exempt from under 

Florida’s Public Records Act. The confidentiality of the information and GME’s

entitlement for it to be maintained confidential was made known in writing to Florida 

DOS and confirmed as such by its personnel. 

20. Although GME was directed to submit the location coordinate 

information to the Florida DOS incident to that agency’s oversight and inventory of

historical resources, the information was to remain confidential, to be used 

commercially only by GME upon its full recovery of the shipwreck sites.

21. The Florida DOS never raised any issue or ever commented or 

suggested that GME had improperly proceeded; nor had the Florida DOS ever 

indicated any reason or justification that GME would not be specifically authorized

to fully recover its various shipwreck site finds and retain 80% of their value.

Case 4:20-cv-00181-AW-MJF Document 3 Filed 04/17/20 Page 7 of 21
22. To the contrary, in July 2016, the Secretary of State of Florida spoke 

with GME by telephone, with an Assistant Secretary and the Director of the Division 

of Historical Resources on the call, and assured GME that the Florida DOS would 

be "partnering" with GME in the full recovery of the GME discovered shipwreck 

sites. 

23. Subsequently, however, GME learned the Florida DOS was 

collaborating and negotiating with France to recover the shipwreck sites without 

GME's involvement, surmising that Site # 2 was an abandoned French shipwreck la 

Trinite. 

24. GME became concerned, and in September 2016, filed a federal court 

in rem admiralty action against "The Unidentified, Wrecked and (for Finders-Right 

Purposes) Abandoned Sailing Vessel," in an attempt to protect its supposed 

ownership interest of the Site # 2 shipwreck under the Law of Finds (that actually 

applies in international waters, but not for State owned coastal waters). The Florida 

DOS and France became parties to that action. 

25. Incident to filing the in rem action, GME deposited with the federal 

court several small artifacts (ballast stones, pics) from shipwreck Site # 2 that GME 

had recovered and was properly conserving. Deposit of these items was required by 

admiralty law to confer constructive possession upon the federal court of the 

88 

22. To the contrary, in July 2016, the Secretary of State of Florida spoke 

with GME by telephone, with an Assistant Secretary and the Director of the Division 

of Historical Resources on the call, and assured GME that the Florida DOS would 

be “partnering” with GME in the full recovery of the GME discovered shipwreck 

sites.

23. Subsequently, however, GME learned the Florida DOS was 

collaborating and negotiating with France to recover the shipwreck sites without 

GME’s involvement, surmising that Site # 2 was an abandoned French shipwreck la 

Trinité.

24. GME became concerned, and in September 2016, filed a federal court 

in rem admiralty action against “The Unidentified, Wrecked and (for Finders-Right 

Purposes) Abandoned Sailing Vessel,” in an attempt to protect its supposed 

ownership interest of the Site # 2 shipwreck under the Law of Finds (that actually

applies in international waters, but not for State owned coastal waters). The Florida 

DOS and France became parties to that action.

25. Incident to filing the in rem action, GME deposited with the federal 

court several small artifacts (ballast stones, pics) from shipwreck Site # 2 that GME 

had recovered and was properly conserving. Deposit of these items was required by 

admiralty law to confer constructive possession upon the federal court of the 

Case 4:20-cv-00181-AW-MJF Document 3 Filed 04/17/20 Page 8 of 21
shipwreck Site # 2 vessel to arrest that ship to vest admiralty in rem subject matter 

jurisdiction. 

26. In early October 2016, the Florida DOS demanded that GME 

immediately turn over those small recovered artifacts to DOS, although the federal 

court controlled them. The Florida DOS then "suspended" GME's salvage activity 

permit # 2015-03 and refused to allow GME to proceed with full recovery of its 

discovered historic shipwreck sites, stating that the only cure was for GME to deliver 

the small recovered artifacts to it forthwith. 

27. The federal court magistrate judge assigned to hear the in rem action 

subsequently transferred control of the small artifacts to the Florida DOS, fulfilling 

this demand. However, Florida DOS still refused to allow GME to recover any of 

the shipwreck sites. 

28. The federal court magistrate judge subsequently conferred temporary 

in rem custody to DOS during the admiralty case and precluded any shipwreck site 

recovery pending its decision as to ownership entitlement. 

29. Almost two years later, on June 29, 2018, the federal magistrate judge 

granted France's Motion to Dismiss the in rem admiralty action for lack of federal 

court subject matter jurisdiction over the vessel (shipwreck Site # 2) because France 

had a colorable claim to the vessel as being the la Trinite that sank in 1565 south of 

St. Augustine. 

99 

shipwreck Site # 2 vessel to arrest that ship to vest admiralty in rem subject matter 

jurisdiction.

26. In early October 2016, the Florida DOS demanded that GME 

immediately turn over those small recovered artifacts to DOS, although the federal 

court controlled them. The Florida DOS then “suspended” GME’s salvage activity 

permit # 2015-03 and refused to allow GME to proceed with full recovery of its 

discovered historic shipwreck sites, stating that the only cure was for GME to deliver 

the small recovered artifacts to it forthwith. 

27. The federal court magistrate judge assigned to hear the in rem action 

subsequently transferred control of the small artifacts to the Florida DOS, fulfilling 

this demand. However, Florida DOS still refused to allow GME to recover any of 

the shipwreck sites.

28. The federal court magistrate judge subsequently conferred temporary 

in rem custody to DOS during the admiralty case and precluded any shipwreck site 

recovery pending its decision as to ownership entitlement.

29. Almost two years later, on June 29, 2018, the federal magistrate judge 

granted France’s Motion to Dismiss the in rem admiralty action for lack of federal 

court subject matter jurisdiction over the vessel (shipwreck Site # 2) because France 

had a colorable claim to the vessel as being the la Trinité that sank in 1565 south of 

St. Augustine. 

Case 4:20-cv-00181-AW-MJF Document 3 Filed 04/17/20 Page 9 of 21
30. Pursuant to the Foreign Sovereign Immunities Act ("FSIA"), 

28 U.S.C.A. § 1609, federal courts do not have subject matter jurisdiction to arrest 

a res that is colorably claimed by a foreign government, and any such vessel is 

immune from federal court in rem adjudication or disposition. 

31. The federal court magistrate hearing the in rem action determined that 

under FSIA, the federal district court had no subject matter jurisdiction to proceed 

to determine any ownership interest entitlement to the constructively arrested 

shipwreck vessel. The magistrate judge dismissed the entire case for lack of subject 

matter jurisdiction, with direction for the Court's constructive custody of the res 

(presumed to be the vessel la Trinite) to be returned to France, or retained by the 

State as agreed by France, and with recovery now being allowed. The magistrate's 

order of dismissal is found at Global Marine Exploration, Inc. v. The Unidentified, 

Wrecked and (For Finders-Rights Purposes) Abandoned Sailing Vessel, 348 

F. Supp. 3d 1221 (M.D. Fla. 2018). 

32. The decision of the federal court magistrate to dismiss the in rem action 

for lack of subject matter jurisdiction under the FSIA is not res judicata of any 

ownership or beneficial interest entitlement to any of the historic shipwrecks sites 

discovered and located by GME. The magistrate judge's decision could not and did 

not purport to determine GME's rights, including its right to benefit from its finds 

or to receive fair compensation for its efforts and expertise. 

10 10

30. Pursuant to the Foreign Sovereign Immunities Act (“FSIA”), 

28 U.S.C.A. § 1609, federal courts do not have subject matter jurisdiction to arrest 

a res that is colorably claimed by a foreign government, and any such vessel is 

immune from federal court in rem adjudication or disposition. 

31. The federal court magistrate hearing the in rem action determined that

under FSIA, the federal district court had no subject matter jurisdiction to proceed 

to determine any ownership interest entitlement to the constructively arrested 

shipwreck vessel. The magistrate judge dismissed the entire case for lack of subject 

matter jurisdiction, with direction for the Court’s constructive custody of the res

(presumed to be the vessel la Trinité) to be returned to France, or retained by the 

State as agreed by France, and with recovery now being allowed. The magistrate’s 

order of dismissal is found at Global Marine Exploration, Inc. v. The Unidentified, 

Wrecked and (For Finders-Rights Purposes) Abandoned Sailing Vessel, 348 

F. Supp. 3d 1221 (M.D. Fla. 2018).

32. The decision of the federal court magistrate to dismiss the in rem action 

for lack of subject matter jurisdiction under the FSIA is not res judicata of any 

ownership or beneficial interest entitlement to any of the historic shipwrecks sites 

discovered and located by GME. The magistrate judge’s decision could not and did 

not purport to determine GME’s rights, including its right to benefit from its finds 

or to receive fair compensation for its efforts and expertise.

Case 4:20-cv-00181-AW-MJF Document 3 Filed 04/17/20 Page 10 of 21
33. In December 2018, France entered into a Declaration of Intent with the 

Florida DOS providing for their recovery of the shipwreck sites discovered by GME, 

and for recovered materials to be conserved and displayed for the benefit of the 

public in Florida on a long-term basis. In the recovery of the historic shipwrecks, 

France will participate in their study, preservation, consultation and evaluation, as 

well as the mobilization and oversight of public and/or private resources and 

organizations to fulfill the Declaration's objectives. A copy of the Declaration of 

Intent is attached hereto as Exhibit 2. 

34. Actions and agreements by France with the Florida DOS and others 

subsequent to the Declaration confirm and implement France's declared 

undertakings. 

35. A France-Florida Steering Committee, including six representatives of 

France and two representatives of Florida, was organized to implement the 

Declaration agreement. 

36. France is sending missions to Florida to oversee the project and provide 

scientific expertise, and work is on-going. 

37. France is performing commercial activity in the State of Florida 

through agreement with Florida DOS and others, and by activities undertaken or to 

be undertaken, in relation to GME's discovered shipwreck sites for which GME 

claims rights and interest. 

11 11

33. In December 2018, France entered into a Declaration of Intent with the 

Florida DOS providing for their recovery of the shipwreck sites discovered by GME, 

and for recovered materials to be conserved and displayed for the benefit of the 

public in Florida on a long-term basis. In the recovery of the historic shipwrecks, 

France will participate in their study, preservation, consultation and evaluation, as 

well as the mobilization and oversight of public and/or private resources and 

organizations to fulfill the Declaration’s objectives. A copy of the Declaration of 

Intent is attached hereto as Exhibit 2. 

34. Actions and agreements by France with the Florida DOS and others 

subsequent to the Declaration confirm and implement France’s declared 

undertakings. 

35. A France-Florida Steering Committee, including six representatives of 

France and two representatives of Florida, was organized to implement the 

Declaration agreement.

36. France is sending missions to Florida to oversee the project and provide

scientific expertise, and work is on-going. 

37. France is performing commercial activity in the State of Florida 

through agreement with Florida DOS and others, and by activities undertaken or to 

be undertaken, in relation to GME’s discovered shipwreck sites for which GME 

claims rights and interest. 

Case 4:20-cv-00181-AW-MJF Document 3 Filed 04/17/20 Page 11 of 21
COUNT I 

IN PERSONAM LIEN AWARD 

38. GME alleges paragraphs 1-37 above, as if rewritten herein. 

39. GME is entitled to a salvage and/or maritime lien under federal 

admiralty law, enforceable in personam against France to compensate GME's 

authorized services in the discovery, location, identification, or mapping of the 

shipwreck sites being recovered by France in connection with its joint undertaking 

with the Florida DOS. 

40. Under federal admiralty law, GME is entitled to be compensated for its 

beneficial services performed and authorized by the State of Florida as owner of the 

submerged sovereignty land where the historic shipwrecks were found and as their 

putative owner under the Abandoned Shipwreck Act of 1987. 

41. The full recovery of the historic shipwreck sites will significantly 

benefit from GME's services. Without GME's services, those shipwreck sites would 

not have been discovered, located, or identified, and could not be recovered. 

42. Because the shipwreck sites will be recovered at the direction of France 

and with its participation and assistance under claim of ownership, GME is entitled 

to enforce a salvage and/or maritime lien in personam against France for GME's 

assistance in ultimate recovery of the shipwreck sites. 

43. GME secured and funded all equipment and personnel, and covered all 

related expenses over an extensive period in prolonged search and location efforts, 

12 12

COUNT I

IN PERSONAM LIEN AWARD

38. GME alleges paragraphs 1-37 above, as if rewritten herein. 

39. GME is entitled to a salvage and/or maritime lien under federal 

admiralty law, enforceable in personam against France to compensate GME’s 

authorized services in the discovery, location, identification, or mapping of the 

shipwreck sites being recovered by France in connection with its joint undertaking 

with the Florida DOS.

40. Under federal admiralty law, GME is entitled to be compensated for its 

beneficial services performed and authorized by the State of Florida as owner of the 

submerged sovereignty land where the historic shipwrecks were found and as their

putative owner under the Abandoned Shipwreck Act of 1987. 

41. The full recovery of the historic shipwreck sites will significantly

benefit from GME’s services. Without GME’s services, those shipwreck sites would 

not have been discovered, located, or identified, and could not be recovered.

42. Because the shipwreck sites will be recovered at the direction of France 

and with its participation and assistance under claim of ownership, GME is entitled 

to enforce a salvage and/or maritime lien in personam against France for GME’s 

assistance in ultimate recovery of the shipwreck sites. 

43. GME secured and funded all equipment and personnel, and covered all 

related expenses over an extensive period in prolonged search and location efforts, 

Case 4:20-cv-00181-AW-MJF Document 3 Filed 04/17/20 Page 12 of 21
and GME's claim includes compensation in relation to its expenses incurred and 

time and effort expended. 

44. GME's claim seeks compensation for the value of its services, 

including compensation for the risk involved in its operations and the skill with 

which they were performed. 

45. In addition, GME's claim for compensation must be determined in 

relation to the anticipated market and historic value of recovery made or to be made 

with respect to the shipwreck sites. 

WHEREFORE, GME requests declaration that it is entitled to a salvage or 

maritime lien award against France to compensate for GME's services for the 

recovery of the historic shipwreck sites, and that GME be awarded full compensation 

for its services consistent with law, and for such other and further relief related 

thereto as appropriate. 

COUNT II 

QUASI CONTRACT/UNJUST ENRICHMENT 

46. GME alleges paragraphs 1-37 and 43-45 above, as if rewritten herein. 

47. Under Florida law, GME is entitled to enforce a claim for unjust 

enrichment or quantum meruit against France, i.e. by contract implied at law for the 

13 13

and GME’s claim includes compensation in relation to its expenses incurred and 

time and effort expended. 

44. GME’s claim seeks compensation for the value of its services,

including compensation for the risk involved in its operations and the skill with

which they were performed. 

45. In addition, GME’s claim for compensation must be determined in 

relation to the anticipated market and historic value of recovery made or to be made 

with respect to the shipwreck sites.

WHEREFORE, GME requests declaration that it is entitled to a salvage or

maritime lien award against France to compensate for GME’s services for the 

recovery of the historic shipwreck sites, and that GME be awarded full compensation 

for its services consistent with law, and for such other and further relief related 

thereto as appropriate.

COUNT II

QUASI CONTRACT/UNJUST ENRICHMENT

46. GME alleges paragraphs 1-37 and 43-45 above, as if rewritten herein.

47. Under Florida law, GME is entitled to enforce a claim for unjust 

enrichment or quantum meruit against France, i.e. by contract implied at law for the 

Case 4:20-cv-00181-AW-MJF Document 3 Filed 04/17/20 Page 13 of 21
value of GME's services benefitting France and the property that France is 

recovering. 

48. Obligation to fairly compensate another is created under Florida law 

where one is unjustly enriched by receiving a benefit under circumstances that make 

it unjust without giving fair compensation. 

49. GME conferred a substantial benefit upon France in respect to historic 

shipwreck sites that France is recovering or will recover, and France knows of and 

has accepted or retained the benefit without paying for its value. 

WHEREFORE, GME requests payment for the value of its efforts and 

services that were recognized and accepted by France and substantially benefit 

France in the recovery of the historic shipwreck sites. 

COUNT III 

MISAPPROPRIATION OF TRADE 

SECRET INFORMATION 

50. GME alleges paragraphs 1-37 above, as if rewritten herein. 

51. GME engaged in extensive and highly costly operations in order to find 

and locate the various historic shipwreck sites, and had significant investmentbacked expectation of its determinations of where such sites were and how they 

could be found. The precise locations of GME's discovered shipwreck sites and the 

methods used to identify those locations were proprietary and confidential 

14 14

value of GME’s services benefitting France and the property that France is 

recovering.

48. Obligation to fairly compensate another is created under Florida law 

where one is unjustly enriched by receiving a benefit under circumstances that make 

it unjust without giving fair compensation.

49. GME conferred a substantial benefit upon France in respect to historic 

shipwreck sites that France is recovering or will recover, and France knows of and 

has accepted or retained the benefit without paying for its value.

WHEREFORE, GME requests payment for the value of its efforts and 

services that were recognized and accepted by France and substantially benefit 

France in the recovery of the historic shipwreck sites.

COUNT III

MISAPPROPRIATION OF TRADE

SECRET INFORMATION

50. GME alleges paragraphs 1-37 above, as if rewritten herein. 

51. GME engaged in extensive and highly costly operations in order to find 

and locate the various historic shipwreck sites, and had significant investmentbacked expectation of its determinations of where such sites were and how they 

could be found. The precise locations of GME’s discovered shipwreck sites and the 

methods used to identify those locations were proprietary and confidential 

Case 4:20-cv-00181-AW-MJF Document 3 Filed 04/17/20 Page 14 of 21
information owned by GME, to be used solely for GME's commercial benefit in 

connection with its completion of recovery of the sites and otherwise. 

52. GME's precise coordinate location data was trade secret information, 

as defined by Florida Statutes §§ 815.045 and 812.081(1)(c) to include proprietary 

information made confidential and exempt from the public records law, and as 

defined by Florida Statute § 688.002(4)(a) to include a method, technique, and 

process that derives independent economic value, actual or potential, from not being 

generally known to, and not being readily ascertainable by proper means and is the 

subject of efforts that are reasonable under the circumstances to maintain its secrecy. 

53. Before providing its locational coordinate proprietary information to 

the Florida DOS at the insistence of its Director of the Division Historical Resources, 

GME repeatedly emphasized and specified in writing that the locational information 

was confidential and protected, and made reasonable efforts under the circumstances 

to maintain its secrecy and confidentiality. GME was assured by the Division 

Director in writing and otherwise that the information was exempt from public 

disclosure and would be protected. 

54. GME's proprietary locational data was confidential information 

exempt from Florida's Public Records Act and protected from public disclosure, 

misuse, exploitation or beneficial gain by the Florida DOS or by or for anyone else. 

15 15

information owned by GME, to be used solely for GME’s commercial benefit in 

connection with its completion of recovery of the sites and otherwise. 

52. GME’s precise coordinate location data was trade secret information,

as defined by Florida Statutes §§ 815.045 and 812.081(1)(c) to include proprietary 

information made confidential and exempt from the public records law, and as 

defined by Florida Statute § 688.002(4)(a) to include a method, technique, and 

process that derives independent economic value, actual or potential, from not being 

generally known to, and not being readily ascertainable by proper means and is the 

subject of efforts that are reasonable under the circumstances to maintain its secrecy.

53. Before providing its locational coordinate proprietary information to 

the Florida DOS at the insistence of its Director of the Division Historical Resources, 

GME repeatedly emphasized and specified in writing that the locational information 

was confidential and protected, and made reasonable efforts under the circumstances

to maintain its secrecy and confidentiality. GME was assured by the Division 

Director in writing and otherwise that the information was exempt from public 

disclosure and would be protected. 

54. GME’s proprietary locational data was confidential information 

exempt from Florida’s Public Records Act and protected from public disclosure,

misuse, exploitation or beneficial gain by the Florida DOS or by or for anyone else. 

Case 4:20-cv-00181-AW-MJF Document 3 Filed 04/17/20 Page 15 of 21
55. The Florida DOS received GME's confidential locational information 

under a duty to maintain its confidentiality and limit its use solely for official 

oversight purposes by the Division of Historical Resources to verify and inventory 

the historical shipwrecks on State-owned submerged lands and monitor GME's 

anticipated recovery. 

56. GME received assurances from the Florida DOS that GME would be 

authorized to complete its salvage activities and recover the shipwreck sites it had 

discovered and located. However, after DOS came into possession of GME's 

confidential proprietary information, it began working with France to jointly recover 

the shipwreck sites. Relations with GME were discontinued, and GME was not 

allowed to complete recovery of any of its finds. 

57. In connection with its salvage activity in Florida, France has used and 

continues to use GME's confidential, proprietary information as to the precise 

location of the historic shipwreck sites for its own benefit, gain or enhancement, to 

the detriment of GME's right to exclusive commercial use and benefit. 

58. France's use of GME's proprietary information is unauthorized and 

without GME's consent, and constitutes misappropriation of GME's trade secret 

property. 

59. France's misuse and misappropriation of GME's trade secret 

information is part of the commercial activities conducted by France in Florida, and 

16 16

55. The Florida DOS received GME’s confidential locational information 

under a duty to maintain its confidentiality and limit its use solely for official 

oversight purposes by the Division of Historical Resources to verify and inventory 

the historical shipwrecks on State-owned submerged lands and monitor GME’s 

anticipated recovery.

56. GME received assurances from the Florida DOS that GME would be 

authorized to complete its salvage activities and recover the shipwreck sites it had 

discovered and located. However, after DOS came into possession of GME’s 

confidential proprietary information, it began working with France to jointly recover 

the shipwreck sites. Relations with GME were discontinued, and GME was not 

allowed to complete recovery of any of its finds.

57. In connection with its salvage activity in Florida, France has used and 

continues to use GME’s confidential, proprietary information as to the precise 

location of the historic shipwreck sites for its own benefit, gain or enhancement, to 

the detriment of GME’s right to exclusive commercial use and benefit.

58. France’s use of GME’s proprietary information is unauthorized and 

without GME’s consent, and constitutes misappropriation of GME’s trade secret 

property.

59. France’s misuse and misappropriation of GME’s trade secret 

information is part of the commercial activities conducted by France in Florida, and 

Case 4:20-cv-00181-AW-MJF Document 3 Filed 04/17/20 Page 16 of 21
allowed France to conduct its recovery operations under direction of the Joint 

Steering Committee. 

WHEREFORE, the Court should determine that GME's proprietary 

information was misused and misappropriated by France without GME's consent in 

violation of its rights under law, and should award GME all damages, compensation, 

and attorneys' fees allowed by law, and further relief as appropriate. 

COUNT IV 

INTERFERENCE WITH RIGHTS AND RELATIONS 

60. GME alleges paragraphs 1-37 above, as if rewritten herein. 

61. A statutory program is recognized under Florida law for commercial 

salvage activity with respect to historic shipwreck sites in Florida coastal waters. 

62. Pursuant to Florida DOS' Rules, adopted as Chapter 1A-31, F.A.C., a 

commercial salvor, upon written documentation may apply to the Florida DOS to 

search for, locate, identify, conserve and recover on an exclusive basis archeological 

material from historic shipwreck sites in a designated area. A historic shipwreck site 

is the remains of an abandoned ship at least 50-years old, including hardware, cargo, 

personal items and treasure trove. The salvor must demonstrate financial ability and 

suitable qualifications; that it has engaged a professional archaeologist; that 

professionally accepted techniques will be utilized for exploration, identification, 

recovery, researching, conservation or stabilization of archaeological materials; and 

17 17

allowed France to conduct its recovery operations under direction of the Joint 

Steering Committee. 

WHEREFORE, the Court should determine that GME’s proprietary 

information was misused and misappropriated by France without GME’s consent in 

violation of its rights under law, and should award GME all damages, compensation, 

and attorneys’ fees allowed by law, and further relief as appropriate. 

COUNT IV

INTERFERENCE WITH RIGHTS AND RELATIONS

60. GME alleges paragraphs 1-37 above, as if rewritten herein. 

61. A statutory program is recognized under Florida law for commercial 

salvage activity with respect to historic shipwreck sites in Florida coastal waters.

62. Pursuant to Florida DOS’ Rules, adopted as Chapter 1A-31, F.A.C., a 

commercial salvor, upon written documentation may apply to the Florida DOS to 

search for, locate, identify, conserve and recover on an exclusive basis archeological 

material from historic shipwreck sites in a designated area. A historic shipwreck site 

is the remains of an abandoned ship at least 50-years old, including hardware, cargo, 

personal items and treasure trove. The salvor must demonstrate financial ability and 

suitable qualifications; that it has engaged a professional archaeologist; that 

professionally accepted techniques will be utilized for exploration, identification, 

recovery, researching, conservation or stabilization of archaeological materials; and 

Case 4:20-cv-00181-AW-MJF Document 3 Filed 04/17/20 Page 17 of 21
present adequate plans for analysis and curation of all recovered materials. The 

Florida DOS agrees with the Salvor for an exclusive 3-year term with a 3-year 

renewal term. An exploration permit authorizes collection of sensing and visual 

information of potential historic shipwreck sites without excavation and bottom 

disturbance, modified to allow such disturbance and excavation to determine the 

presence and value of potential historic shipwreck sites. A recovery permit follows 

after the existence and nature of a historic shipwreck has been documented. These 

matters are directed per Rules 1A-31.0015, 1A-31.050, 1A-31.0062, 1A-31.0082 

and 1A-31.040. 

63. The Florida DOS is obliged to approve an authorized salvor's 

excavation and recovery of artifacts that will assist in the identification of age and 

type of historic shipwreck site being investigated pursuant to exploration authority. 

For approval of ultimate recovery of an identified site, the Florida DOS commercial 

salvage program requires an approved research design and description of proposed 

excavation activities prepared by the project archaeologist and other documentation, 

as directed by Rules 1A-31.060, 1A-31.065, and 1A-31.070. 

64. And per its Rule 1A-31.090, DOS ensures that archaeological materials 

are transferred to the authorized salvor who receives approximately 80% of 

recovered archaeological materials with DOS receiving approximately 20%, with 

distribution of such recovered materials based on historical value. 

18 18

present adequate plans for analysis and curation of all recovered materials. The 

Florida DOS agrees with the Salvor for an exclusive 3-year term with a 3-year 

renewal term. An exploration permit authorizes collection of sensing and visual 

information of potential historic shipwreck sites without excavation and bottom 

disturbance, modified to allow such disturbance and excavation to determine the 

presence and value of potential historic shipwreck sites. A recovery permit follows 

after the existence and nature of a historic shipwreck has been documented. These 

matters are directed per Rules 1A-31.0015, 1A-31.050, 1A-31.0062, 1A-31.0082 

and 1A-31.040. 

63. The Florida DOS is obliged to approve an authorized salvor’s 

excavation and recovery of artifacts that will assist in the identification of age and 

type of historic shipwreck site being investigated pursuant to exploration authority. 

For approval of ultimate recovery of an identified site, the Florida DOS commercial 

salvage program requires an approved research design and description of proposed 

excavation activities prepared by the project archaeologist and other documentation,

as directed by Rules 1A-31.060, 1A-31.065, and 1A-31.070. 

64. And per its Rule 1A-31.090, DOS ensures that archaeological materials

are transferred to the authorized salvor who receives approximately 80% of 

recovered archaeological materials with DOS receiving approximately 20%, with 

distribution of such recovered materials based on historical value.

Case 4:20-cv-00181-AW-MJF Document 3 Filed 04/17/20 Page 18 of 21
65. The Florida DOS was authorized by law to confer rights and privileges 

upon GME for salvage activity in the State's coastal waters on an exclusive basis, 

which precluded such activity of any third-party salvager, namely France. 

66. DOS' salvage activity program established a contract under law with 

GME upon DOS' acceptance of GME to conduct commercial salvage activity on 

state submerged coastal lands. GME enjoyed advantageous business relations with 

the Florida DOS pursuant to its salvage activity program that should have enabled 

GME to recover and benefit from its finds. 

67. DOS was obligated pursuant to its Rules to authorize GME to recover 

its discovered and documented shipwreck sites that were reasonably recoverable 

under GME's archaeologist prepared excavation design. 

68. GME's Permit agreement #2015-03 with the Florida DOS, inclusive of 

DOS' rules incorporated therein, also established a salvage activity contract, signed 

by both parties and containing mutual promises, obligations, and benefits, including 

promise for GME to salvage and benefit from its documented finds by recovery 

authorization upon reasonable action plan. 

69. The various historic shipwreck sites found by GME pursuant to its 

agreement with the Florida DOS were abandoned property that could be recovered 

by GME consistent with its relations with the Florida DOS. 

19 19

65. The Florida DOS was authorized by law to confer rights and privileges 

upon GME for salvage activity in the State’s coastal waters on an exclusive basis, 

which precluded such activity of any third-party salvager, namely France.

66. DOS’ salvage activity program established a contract under law with 

GME upon DOS’ acceptance of GME to conduct commercial salvage activity on 

state submerged coastal lands. GME enjoyed advantageous business relations with 

the Florida DOS pursuant to its salvage activity program that should have enabled 

GME to recover and benefit from its finds.

67. DOS was obligated pursuant to its Rules to authorize GME to recover 

its discovered and documented shipwreck sites that were reasonably recoverable 

under GME’s archaeologist prepared excavation design.

68. GME’s Permit agreement #2015-03 with the Florida DOS, inclusive of

DOS’ rules incorporated therein, also established a salvage activity contract, signed 

by both parties and containing mutual promises, obligations, and benefits, including 

promise for GME to salvage and benefit from its documented finds by recovery 

authorization upon reasonable action plan. 

69. The various historic shipwreck sites found by GME pursuant to its 

agreement with the Florida DOS were abandoned property that could be recovered 

by GME consistent with its relations with the Florida DOS.

Case 4:20-cv-00181-AW-MJF Document 3 Filed 04/17/20 Page 19 of 21
70. Even if shipwreck Site # 2 were a French vessel known as la Trinite, 

still the Florida DOS could authorize its salvage recovery by GME because that 

vessel was used for commercial purposes, to wit: the colonization of French 

Huguenots (a religious ministry), which was an activity that private persons engage 

in, so that Site # 2 was not a foreign military vessel protected from recovery without 

France's consent under the Sunken Military Craft Act. 

71. France knew of GME's contractual rights and advantageous relations 

with the Florida DOS, but nevertheless acted to influence, induce and collaborate 

with the Florida DOS for it to abrogate its obligations to and favorable relations with 

GME, even though France was not a privileged party to GME's relations with the 

Florida DOS. 

72. By its actions and activities taken, with respect to the historic shipwreck 

sites discovered by GME, France intentionally interfered with GME's business and 

contractual relations with the Florida DOS and with GME's rights to recover its 

discovered shipwreck sites and to receive their beneficial value, resulting in damages 

to GME. 

WHEREFORE, the Court should determine that France wrongfully interfered 

with GME's contractual rights and business relations with the Florida DOS, and 

award GME damages, and provide further relief as appropriate. 

20 20

70. Even if shipwreck Site # 2 were a French vessel known as la Trinité, 

still the Florida DOS could authorize its salvage recovery by GME because that 

vessel was used for commercial purposes, to wit: the colonization of French 

Huguenots (a religious ministry), which was an activity that private persons engage 

in, so that Site # 2 was not a foreign military vessel protected from recovery without 

France’s consent under the Sunken Military Craft Act.

71. France knew of GME’s contractual rights and advantageous relations 

with the Florida DOS, but nevertheless acted to influence, induce and collaborate 

with the Florida DOS for it to abrogate its obligations to and favorable relations with 

GME, even though France was not a privileged party to GME’s relations with the 

Florida DOS.

72. By its actions and activities taken, with respect to the historic shipwreck 

sites discovered by GME, France intentionally interfered with GME’s business and 

contractual relations with the Florida DOS and with GME’s rights to recover its 

discovered shipwreck sites and to receive their beneficial value, resulting in damages

to GME. 

WHEREFORE, the Court should determine that France wrongfully interfered 

with GME’s contractual rights and business relations with the Florida DOS, and 

award GME damages, and provide further relief as appropriate.

Case 4:20-cv-00181-AW-MJF Document 3 Filed 04/17/20 Page 20 of 21
Dated this 17th day of April, 2020. 

s/ Jennifer A. Winegardner 

JENNIFER A. WINEGARDNER 

Florida Bar No. 133930 

KIMBERLY A. GRIPPA 

Florida Bar No. 123587 

WINEGARDNER LAW 

2852 Remington Green Circle 

Suite 102 

Tallahassee, FL 32308 

Telephone: (850) 270-9064 

jwinegardner@winegardnerlaw.com 

21 

s/ M. Stephen Turner 

M. STEPHEN TURNER, P.A. 

Florida Bar No. 095691 

P.O. Box 10261 

Tallahassee, FL 32302 

Telephone: (850) 545-1061 

Mstephenturner.pa@gmail.com 

21

Dated this 17th day of April, 2020.

s/ Jennifer A. Winegardner

JENNIFER A. WINEGARDNER

Florida Bar No. 133930

KIMBERLY A. GRIPPA

Florida Bar No. 123587

WINEGARDNER LAW

2852 Remington Green Circle

Suite 102

Tallahassee, FL 32308

Telephone: (850) 270-9064

jwinegardner@winegardnerlaw.com

s/ M. Stephen Turner

M. STEPHEN TURNER, P.A.

Florida Bar No. 095691

P.O. Box 10261

Tallahassee, FL 32302

Telephone: (850) 545-1061

Mstephenturner.pa@gmail.com

Case 4:20-cv-00181-AW-MJF Document 3 Filed 04/17/20 Page 21 of 21