Seacoast response to motions to set aside, for disclosure, and for hearing

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87383077;1 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
FORT LAUDERDALE DIVISION 
IN ADMIRALTY 
CASE NO.: 0:26-cv-60289-WPD 
SEACOAST NATIONAL BANK, 
Plaintiff, 
vs. 
M/V SLOW UR ROLL II, a 2008 Everglades 350LX 
Express, Official No. 1220768, HIN: RJDE0005I708, 
Together with all masts, boilers, cables, engines, 
machinery, etc., in rem, and STARBOARD YACHT
GROUP LLC, a Florida limited liability company, in 
personam, 
Defendants. 
_________________________________________/ 
PLAINTIFF SEACOAST NATIONAL BANK’S RESPONSE IN OPPOSITION TO 
CHARLES JACOB STRATMANN’S OBJECTIONS TO CONFIRMATION AND 
REQUESTS FOR POST-SALE DISCOVERY  
Plaintiff, Seacoast National Bank (“Seacoast” or the “Bank”), by and through undersigned 
counsel, files this Response in Opposition to: (I) Objection of Charles Jacob Stratmann’s 
(“Stratmann”), Pro Se Claimant and Party-in-Interest, to Confirmation of Judicial Sale and 
Request for Evidentiary Hearing  (the “Objection”) (DE 92), (II) Claimant’s Protest of Judicial 
Sale and Motion to Set Aside or Defer Confirmation of the June 26, 2026 Auction of M/V Slow Ur 
Roll II (DE 97) (“Second Objection”), filed by Stratmann, pro se as a “party-in-interest and as the 
sole member of Starboard Yacht Group, LLC” (collectively, the Objection and Second Objection 
are referred to as the “Objections”), 1 and (III) Motion for Disclosure of Bidder Identities and 
Auction Records, and for Order Preserving Such Records Pending Appellate Review  (DE 96) 
1 Stratmann has been repeatedly admonished that he cannot represent Starboard Yacht Group, LLC’s interests as a 
non-lawyer. [DE 15, 53, 61]. 
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(“Disclosure”), also filed by Stratmann, pro se.  In support of its response in opposition to the 
above-referenced filings, Seacoast states as follows:  
INTRODUCTION 
On May 21, 2026, the Court ordered the sale of the Defendant M/V SLOW UR ROLL II 
(the “Vessel”). [DE 70.]  On June 26, 2026, the United States Marshals Service conducted the 
court-ordered sale of the Vessel at the Fort Lauderdale Federal Courthouse. After numerous rounds 
of competitive bidding by many of the ten registered bidders, the Vessel ultimately sold to William 
Wilson for $160,000.00, who provided a certified check deposit at the time of sale [DE 87], and 
subsequently deposited the remaining sale price with the U.S. Marshal.  
Stratmann, proceeding pro se, now asks the Court to refuse confirmation of a well-attended 
and competitive judicial sale. He believes the Court should order a new judicial sale under onerous 
minimum bid requirements, or impose extraordinary post-sale conditions. The Objections are 
based on speculation, an unsigned declaration, incorrect factual assertions, a two-year old 
unverified appraisal by an appraiser who did not even turn on the Vessel, and mischaracterized or 
hallucinated legal authority. None of the Objections provides a valid basis for relief. 
The Objections do not establish any defect in the Marshal’s sale, do not identify competent 
evidence of fraud, collusion, mistake, or irregularity, and do not provide a legally sufficient basis 
to delay confirmation or require an evidentiary hearing, or permit post-sale discovery.  
ARGUMENT AND INCORPORATED MEMORANDUM OF LAW 
I. The District Court Has Jurisdiction to Confirm the Sale 
Although Stratmann has appealed the Court’s Orders denying his claim for seaman’s 
wages, denying his motion to vacate default, and denying his motion to stay judicial sale [DE 79, 
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84, 88], Stratmann’s notice of appeal does not divest this Court of jurisdiction to confirm the June 
26, 2026 sale of the Vessel.  
The divestiture rule is limited: a notice of appeal transfers jurisdiction only “over those 
aspects of the case involved in the appeal.” Griggs v. Provident Consumer Discount Co., 459 U.S. 
56, 58 (1982); Johnson v. 3M Co., 55 F.4th 1304, 1309, 1319 (11th Cir. 2022) (“The district court 
has authority to proceed forward with portions of the case not related to the claims on appeal” and 
lacks jurisdiction only where a district court action would “alter[ ] the status of the case” on appeal) 
(internal citations omitted); Boyd v. Secretary, Dept. of Corr ., 114 F.4th 1232, 1238 (11th Cir. 
2024) (the district court has jurisdiction to rule “on collateral issues or in aid of the appeal.”). An 
appeal does not strip the district court of authority to perform post-judgment ministerial, 
enforcement, or sale-administration functions that implement an existing judgment and do not alter 
the orders under appellate review.   
Here, the contemplated confirmation order would implement the Default Judgment and 
sale procedures set forth therein. [DE 70.]  It would not reconsider the orders noticed for appeal, 
which struck Stratmann’s asserted seaman’s wage claim, denied his motion to vacate, and denied 
his emergency motion to stay the sale. [DE 79, 84.]  Nor does the notice of appeal operate as a 
stay. See U.S. Commodity Futures Trading Comm. v. Escobio , 946 F.3d 1242, 1251 (11th Cir. 
2020) (“Absent entry of a stay, a district court retains jurisdiction to enforce its judgment . . . during 
the pendency of an appeal.”).  
“A stay is not a matter of right, even if irreparable injury might otherwise result.” Nken v. 
Holder, 556 U.S. 418, 433 (2009) (citation omitted).  In evaluating whether a stay pending judicial 
review is appropriate, courts should consider four factors: “(1) whether the stay applicant has made 
a strong showing that he is likely to succeed on the merits; (2) whether the applicant will be 
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irreparably injured absent a stay; (3) whether issuance of the stay will substantially injure the other 
parties interested in the proceeding; and (4) where the public interest lies.” Id. at 434 (citation 
omitted). “The first two factors of the traditional standard are the most critical. It is not enough 
that the chance of success on the merits be ‘better than negligible.’ ” Id. See also Huntington Nat'l 
Bank v. M/Y SOMETHING ABOUT MERI , No. 0:25-CV-61018-WPD, 2026 WL 1664108, at *1 
(S.D. Fla. Apr. 29, 2026) (denying stay of judicial confirmation of vessel sale pending appeal). 
Here, the first factor weighs heavily against staying judicial confirmation of the sale 
pending appeal.  Stratmann is unlikely to succeed on the merits of his appeal, given his lack of 
standing and the lack of merits in prevailing on his untimely “seaman’s wage” claim that is the 
basis for his appeal, given that Stratmann as a matter of law is not a stranger to the vessel, as 
required to be a seaman.  Moreover, only money damages are at issue therefore “irreparable injury” 
under factor two is unlikely, and factors three and four also weigh heavily against the stay, given 
that the purchaser, the mortgagee, and the substitute custodian will be prejudiced by the delay, and 
it is in the public interest to promptly confirm sales. See Wong Shing v. M/V Mardina Trader, 564 
F.2d 1183, 1189 (5th Cir. 1977). 
Accordingly, the Court has jurisdiction to consider and overrule the Objections, confirm 
the sale, and enter such further orders as are necessary to complete the sale process.  
II. The Objections Are Procedurally Defective 
Local Admiralty Rule E(17)(g) governs objections to a sale of a vessel in this Court.  In 
particular, the rule requires that any party who objects to the sale of a vessel must deposit with the 
U.S. Marshal “the cost of keeping property for at least fourteen (14) days.” See Local Admiralty 
Rule E(17)(g)(ii). Proof of the deposit with the Marshal’s Office shall be delivered to the Clerk of 
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Court’s Office by the moving party. Id. “The Court will not consider the objection without proof 
of this deposit.” Id.   
There is no evidence in the court record that Stratmann has made the requisite deposits 
with the U.S. Marshal, and therefore his Objections cannot be considered by the Court and should 
be denied outright.  Furthermore, Stratmann also failed to serve the U.S. Marshal with the 
Objections, as required by Local Admiralty Rule E(17)(g)(i).  
Because Stratmann has failed to comply with the procedural requirements for objections 
under the Local Admiralty Rules, his Objections should be overruled. 
III. The Objections Do Not Establish a Basis to Disturb the Marshal’s Sale 
Admiralty courts may consider objections before confirmation, but “extreme caution” is 
required before disturbing a sale duly conducted under the court’s decree. Wong Shing v. M/V 
Mardina Trader, 564 F.2d 1183, 1188 (5th Cir. 1977). The recognized grounds for setting aside 
an admiralty sale are narrow: fraud, collusion, or gross inadequacy of price that amounts to fraud 
or unfairness. Id. As such, the objecting party must present competent evidence of a legally 
cognizable defect that affected the sale process.  
The Objections do not meet that burden. Stratmann relies largely on his own assertions and 
an unsigned proposed declaration, neither of which warrant delay of confirmation or an evidentiary 
hearing. The sale was conducted by the United States Marshal at the federal courthouse, pursuant 
to the Court’s sale process. [DE 70.] Ten bidders registered to bid in the sale, and the auction 
generated twenty total bids for the Vessel in addition to the Plaintiff’s opening credit bid of 
$50,000. Before closing bidding, the U.S. Marshal called out “going once” and “going twice,” 
providing multiple opportunities for any competing bidder to submit a higher bid. The Objections 
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do not identify any defect in the Marshal’s authority, the Marshal’s conduct of the sale, the bidding 
procedure, or the notice of sale, sufficient to invalidate the sale. 
Stratmann’s allegations are especially insufficient because they seek extraordinary relief 
after a completed judicial auction. Setting aside a Marshal’s sale would prejudice the successful 
purchaser, Seacoast, the substitute custodian, and the orderly administration of this admiralty 
proceeding. The Objection offers no competent record basis for that result. 
IV. Stratmann Lacks Standing to Object to Confirmation of the Marshal’s Sale 
Stratmann cannot revive his participation in the case through an objection to sale 
confirmation based on personal dissatisfaction with the auction result. The Court has already 
dismissed Stratmann’s claim of interest and struck his answer [DE 53], and struck Stratmann’s 
claim for seaman’s wages [DE 79]. Further, as this Court has already made clear in several of its 
orders [DE 15, 53, 61],  Stratmann may not use his status as sole member and manager of Starboard 
Yacht Group LLC  (“SYG”) to assert SYG’s rights as the owner of the Vessel, pro se.  
Stratmann’s claimed individual interest in alleged proprietary evidence aboard the Vessel 
likewise does not confer a right to block confirmation of the judicial sale. The Objections do not 
establish ownership, possession, or a superior legal right in any discrete property aboard the 
Vessel. Instead, they offer only broad assertions concerning alleged proprietary installation 
architecture, trade-secret configuration data, and physical evidence – which assertions were not 
timely raised and do not justify vacating a Marshal’s sale of the Vessel.   
Furthermore, to the extent that the Objections are attempting to assert a new distinct interest 
in certain property aboard the Vessel, the assertion of such interests are untimely under 
Supplemental Rule C(6) and Local Admiralty Rule C(6), and must be denied as post-sale claims 
under Local Admiralty Rule E(18). 
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Lastly, the Court has already rejected the “preservation” argument by denying Stratmann’s 
Emergency Motion to Preserve Physical and Electronic Evidence, Hold Sale Proceeds in Court 
Registry, and for Reconsideration  [DE 82] and Emergency Motion for Stay of Judicial Sale 
Pending Appeal [DE 85], both of which were premised on the same alleged intellectual property 
and/or trade secrets. Stratmann’s attempt to repackage preservation relief as an objection to sale 
confirmation should likewise be denied.  
V. The Alleged “Price Inadequacy” Does Not Justify Denial of Confirmation 
The Objection asserts that the sale price is inadequate because Stratmann relies on a May 
8, 2024 appraisal stating a market value of $1,000,000. That argument fails for several reasons. 
First, the appraisal is not a guarantee of value at a forced judicial sale. A court-ordered 
Marshal’s sale is not a private retail yacht sale, and a prior appraisal does not establish that the 
auction price was legally inadequate. The relevant question is not whether Stratmann prefers a 
higher valuation, but whether there is competent evidence that the sale process was legally 
defective. There is none.
Second, the appraisal attached to the Objection is dated more than two years before the 
June 2026 sale. It is not evidence of what qualified bidders were willing to pay for the Vessel at a 
public Marshal’s auction in June 2026. It also reflects important limitations, including that the 
survey was conducted without a trial run and without testing equipment. The appraisal therefore 
does not establish that the auction price was invalid or that the Marshal’s sale should be disturbed. 
See Wong Shing, 564 F.2d at 1189 (“Where there is no certainty that a resale will produce a higher 
price, the court is justified in confirming the sale. To do otherwise would prejudice the lien holders 
who must continue to go unpaid. Refusing confirmation in such situations would also prejudice 
the purchaser.”) 
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No competent declaration identifies a timely higher bid that the Marshal refused. No record 
evidence shows fraud, collusion, or a material irregularity in the auction. And the existence of an 
outdated appraisal does not overcome the public policy favoring confirmation of a fairly conducted 
judicial sale to the highest bidder.  This Court should not ordain the “fishing expedition” that it is 
not obligated to undertake, when Stratmann has failed to produce an iota of evidence that the sale 
price was insufficient. See Wong Shing, 564 F.2d at 1187. 
VI. The Sales Agent Agreement Does Not Show an Irregularity, Conflict, or Suppression 
of Bidding 
The Objections argue that National Liquidators’ Exclusive Sales Agent Agreement 
(“Marketing Agreement”) creates a “structural conflict” because National Liquidators was both 
substitute custodian and commission-earning sales agent. The argument is conclusory and 
unsupported. The agreement, filed with the Court, states that National Liquidators would receive 
a reduced eight percent commission only if there was a successful third-party sale, and no 
commission if Seacoast credit bid the Vessel. [DE 86.] That compensation structure is aligned with 
the objective of obtaining a third-party cash buyer rather than requiring Seacoast to credit bid. The 
Objections do not explain how that arrangement harmed the estate, chilled bidding, or rendered 
the Marshal’s sale invalid. 
The Objections also argue that the Marketing Agreement’s execution date means National 
Liquidators could not have performed marketing before the sale. But the Objections offer no 
competent evidence that the Vessel was not marketed, that bidders lacked notice, that interested 
buyers were excluded, or that any person was prevented from bidding. The Objection’s inference 
from an execution date is not evidence of a defective sale. The record is to the contrary. The 
agreement describes National Liquidators’ role in promoting the sale through yacht-focused 
channels and educating potential buyers about the process. The sale occurred publicly at the federal 
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courthouse. The Objection’s speculation about what marketing could or could not have occurred 
does not warrant denial of confirmation.  Moreover, the confirmation of the sale itself does not 
require approval of the Marketing Agreement. 
VII. The Unsigned Declaration Cannot Support an Evidentiary Hearing 
The Objection’s phone-bidder theory depends on the purported declaration of Bob Wilson 
attached to the Objection. That document is defective on its face. It is not signed. It is not dated. It 
does not identify the place of execution. It leaves the execution date and location fields blank. 
Under 28 U.S.C. § 1746, an unsworn declaration may substitute for an affidavit only when it is 
subscribed by the declarant as true under penalty of perjury and dated in substantially proper form. 
The purported Wilson declaration does not satisfy that statute. The absence of a signature means 
there is no declaration by Wilson before the Court. 
Without that declaration, the phone-bidder allegations are unsupported. The Objection asks 
the Court to infer a bidding irregularity from Stratmann’s description of a person on a phone 
allegedly saying words to the effect of “we missed it.” That is hearsay, speculation, and not 
evidence that a higher bid was actually made, timely communicated, improperly refused, or 
prevented by the Marshal. It also does not establish collusion, fraud, or any defect in the auction 
process. The Court should deny the request for an evidentiary hearing because the Objection does 
not present competent evidence creating a genuine factual issue about the integrity of the sale.  
VIII. Stratmann’s Allegation That the Sale Was Not Fully Funded is Moot 
The Objections assert that confirmation should be deferred because only a deposit had been 
paid and the remaining balance was supposedly unpaid. That assertion is procedurally incorrect, 
and also moot. An objection to confirmation of a sale (such as that filed by Stratmann) defers 
payment of the remaining sale price until 7 days after the Court confirms the sale. See Local 
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Admiralty Rule E(17)(a).  Thus, an objection to confirmation cannot be made on the basis that sale 
price has not been paid yet.  
Moreover, the US Marshal has advised the substitute custodian that the buyer has in fact 
paid the sale price. Thus, Stratmann’s request to defer confirmation pending full payment should 
be denied as moot.   
IX. The Preservation Arguments Do Not Justify Delaying or Conditioning Confirmation. 
The Objections’ preservation-based conditions should be rejected for the same reasons 
discussed above. They are unsupported, overbroad, and directly overlap with preservation relief 
the Court already denied. [DE 91.] Stratmann cannot repackage that denied relief as a sale-
confirmation objection by seeking inspection, forensic imaging, alteration restrictions, or 
conditions on sale proceeds based on alleged evidence aboard the Vessel. Nor has Stratmann 
shown any ownership or superior right to separate property aboard the Vessel, or any basis to 
burden the purchaser with post-sale obligations tied to unrelated litigation. Any discovery or 
preservation relief Stratmann believes he may have in other cases must be pursued in the proper 
forum; it is not a basis to delay or condition confirmation of the Marshal’s sale. 
X. The Objection Mischaracterizes and Relies on Unsupported Legal Authorities 
Like Stratmann’s other filings, the Objection contains significant citation problems which 
call to question Stratmann’s verification that “every case citation in this Objection has been 
independently verified to the reporter, volume, page, and holding stated.”  Specifically:  
 Friese v. Boatworks, Inc., No. 09-cv-10296, 2010 WL 1838693 (S.D. Fla. May 7, 2010) is 
not a real Southern District of Florida decision; 
 In re Perez  does not concern Supplemental Admiralty Rule E(9) or confirmation of an 
admiralty judicial sale; 
 United States v. 2,116 Boxes of Boned Beef does not concern Supplemental Admiralty Rule 
E(9) or confirmation of a vessel sale;  
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 In re Dierschke  does not support the asserted “duty to scrutinize sale price” in the 
admiralty-sale context; 
 Deckert v. Independence Shares Corp . concerns equitable rescission of fraudulent 
securities sales, not admiralty sales or conflicted substitute custodians; and 
 Flury v. Daimler Chrysler Corp . concerns alleged spoliation involving a vehicle in a 
products-liability context; it does not justify delaying confirmation of a Marshal’s sale 
based on Stratmann’s claimed evidence-preservation concerns. 
The Court should not credit the Objection’s legal argument where the Objection relies on 
non-existent or materially inapposite authorities.    
CONCLUSION 
In sum, Stratmann has not shown standing, has not submitted competent evidence, has not 
established fraud, collusion, mistake, or material irregularity, and has not provided valid legal 
authority supporting denial or deferral of confirmation. The judicial sale of the Vessel should be 
confirmed. 
WHEREFORE, Plaintiff Seacoast National Bank respectfully requests that the Court 
enter an order: (1) overruling and denying  (I) Objection of Charles Jacob Stratmann’s 
(“Stratmann”), Pro Se Claimant and Party-in-Interest, to Confirmation of Judicial Sale and 
Request for Evidentiary Hearing (DE 92), (II) Claimant’s Protest of Judicial Sale and Motion to 
Set Aside or Defer Confirmation of the June 26, 2026 Auction of M/V Slow Ur Roll II (DE 97) and 
(III) Motion for Disclosure of Bidder Identities and Auction Records, and for Order Preserving 
Such Records Pending Appellate Review  (DE 96); (2) denying the request for an evidentiary 
hearing; (3) confirming the judicial sale of the M/V Slow UR Roll II; and (4) granting such other 
and further relief as the Court deems just and proper. 
Dated:  July 7, 2026  Respectfully submitted, 
/s/ Amanda Klopp  
Amanda Klopp, Esq. 
Florida Bar Number: 124156 
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amanda.klopp [at] akerman.com 
Jenna M. Yoss, Esq. 
Florida Bar Number: 1049858 
jenna.yoss [at] akerman.com 
AKERMAN LLP 
777 S. Flagler Dr., Ste 1100 - West Tower 
West Palm Beach, FL 33401 
Tel: [phone masked] /Fax: [phone masked] 
Attorneys for Seacoast National Bank
CERTIFICATE OF SERVICE 
I hereby certify that on July 7, 2026, I electronically filed the foregoing document with the 
Clerk of the Court using CM/ECF.  I also certify the foregoing document is being served the same 
day via transmission of Notices of Electronic Filing generated by CM/ECF to those parties 
registered to receive electronic notices of filing in this case, and via US Mail and email to those 
listed below. 
Charles Jacob Stratmann 
545 NE 17th Avenue 
Fort Lauderdale, FL 33301 
E-mail: jake [at] starboardyacht.com  
Starboard Yacht Group LLC 
545 NE 17th Ave. 
Ft. Lauderdale, FL 33301 
Defendant 
National Liquidators 
800 Old Griffin Rd 
Dania Beach, FL 33004 
Substitute Custodian 
/s/   Amanda Klopp
Amanda Klopp, Esq. 
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