This page summarizes allegations recorded in a verified complaint filed on the public docket in Seakeeper, Inc. v. Starboard Yacht Group LLC (S.D. Fla. No. 0:23-cv-61696-AHS), and related docket entries in the same case. Statements described here are allegations or findings recorded in filed documents — not independent findings of fact by HelmLegal — unless the cited document itself records a court finding. Corrections are welcome via the corrections page.
On June 19, 2024, SHM LMC, LLC d/b/a Lauderdale Marine Center filed its Amended Verified Complaint in Intervention and Cross-Claim (D.E. 94) in the M/V Octopussy admiralty case. Because the complaint is verified, its factual allegations were sworn to under penalty of perjury by Lazaro Roig, LMC's General Manager, on May 24, 2024. Several of those sworn allegations describe how the Octopussy billing arrangement was structured — including that invoicing was redirected to Starboard Yacht Group at Contessa Marine Research's direction so that Contessa could use SYG's Florida resale certificate, and that Contessa never objected to that arrangement.
SHM LMC alleges that on June 10, 2022, Jake Stratmann, as Manager of SYG, emailed LMC's account representative Jessenya Burrell and directed LMC to send the Octopussy bills to SYG "so the owner, Contessa, could take advantage of SYG's 2022 Resale Certificate and receive the benefit of a state sales tax cap" on the refit. The email itself is attached to the complaint as Exhibit 2 (D.E. 94-2).
D.E. 94 ¶12 & Ex. 2 (DE 94-2) — verified complaint exhibit, public docketSHM LMC alleges the June 10, 2022 email "was copied to Contessa's local agent, Joe Seinitz."
D.E. 94 ¶13SHM LMC alleges: "Defendant, Contessa, did not object to or countermand SYG's June 10, 2022 email instruction that directed LMC to send its OCTOPUSSY invoices to SYG for handling and payment."
D.E. 94 ¶14SHM LMC itemizes four credit-card payments later charged back: $53,935.00 (Dec. 28, 2022, AmEx), $52,857.36 (Jan. 17, 2023, BofA), $59,282.04 (Mar. 16, 2023, AmEx), and $60,427.79 (May 1, 2023, BofA). These four items total $226,502.19 — the identical figure later awarded to Contessa in the Court's September 2026 findings.
D.E. 94 ¶¶22–25; compare D.E. 337 at 18–19, 39SHM LMC alleges "the total amount of $238,483.55 remains unpaid, due and owing at the time of this filing" — the same figure later used as the settlement amount between SHM LMC and SYG.
D.E. 94 ¶91Lazaro Roig, General Manager of SHM LMC, declared "the factual allegations are true to the best of my own knowledge and belief" and that "the documents in Exhibits 1 through 8 are true and correct copies of the original documents and records maintained by the LMC."
D.E. 94 at 24 (Verification, executed May 24, 2024)Analytical note: the docket reflects two money awards touching the same chargeback pool — a judgment for SHM LMC against SYG on the settled chargeback balance (January 2026), and an award of the identical $226,502.19 chargeback figure to Contessa in the September 2026 judgment. Whether the two awards overlap is a question raised in post-judgment proceedings; this page reports the docketed figures only.
According to a follow-up letter dated September 30, 2026, a formal Tax Violation Report and Application for Compensation for Tax Information (Form DR-55) was submitted to the Florida Department of Revenue on April 14, 2026, reporting approximately $1,043,682 in transactions on which sales and use tax was allegedly not collected, and the alleged misapplication of SYG's Florida Annual Resale Certificate No. 16-8014975102-2 to charges of a third-party entity. The letter cites D.E. 94-2 — SHM LMC's own filed exhibit — as corroboration. The referral requests confirmation of receipt, a case number, and status; per the letter, no acknowledgment had been received in the five months since submission.
Whistleblower note: the DR-55 submission is a formal referral to a state revenue authority. Florida law provides a compensation and review process for tax-information referrals, and federal and state law restrict retaliation for lawful reporting to government agencies. This note describes the referral's existence and procedural status only; it is not a legal determination that any violation occurred, and it is not legal advice.