January 5, 2014

THE HONORABLE MARTHA J. COOK 800 E. TWIGGS STREET, ROOM 524 EDGECOMB COURTHOUSE TAMPA, FLORIDA 33602 Via Overnight Delivery

RE: SEAFARER EXPLORATION CORP VS. VOLENTINE, CASE NO.: 14-CA-8902, OIV. B, HILLBOROUGH COUNTY CIRCUIT COURT, DEFENDANT'S MOTION TO COMPEL DISCOVERY

Dear Judge Cook:

Enclosed is my Motion to Compel Answers to Interrogatories and Responses to Requests to Produce. Also enclosed is my proposed Order and self addressed, stamped envelopes. After review of my Motion kindly enter the enclosed Order and have your assistance send out conformed copies with the envelopes provided. Since I have complied with Administrative Order S-2012-064 I am hopeful that the Order to Compel will be entered without the necessity of a hearing as provided in the Administrative Order.

Thank you in advance for your time and attention to this matter.

Cc: Craig A, Huffman, Esq

Sin~

Darrell Volentine

803 Via Concha Road, Nipomo, California 93444 Phone: 805-343-1256

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA

SEAFARER EXPLORATION CORP.,

Plaintiff,

Vs.

DARRELL VOLENTINE,

Defendant.

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CASE NO.: 14-CA-8902 DIV. B

DEFENDANT'S MOTION TO COMPEL ANSWERS TO INTERROGATORIES AND RESPONSES TO REQUESTS TO PRODUCE

Defendant, Darrell Volentine, pro se, files this Motion to Compel Answers to

Interrogatories and Responses to Requests to Produce, pursuant to Administrative Order

S-2012-064 and Rule 1.380 (a)(2), FRCP, and states as follows:

1. On November 21, 2014, I served the Plaintiff (through counsel) with

Interrogatories and filed a Notice of Service of Interrogatories with the court. Attached

hereto as Exhibit "A" is a copy of the Notice of Service of Interrogatories as well as the

Interrogatories.

2. On November 21, 2014, I served the Plaintiff (through counsel) with a

Request to Produce, a copy of which is attached hereto as Exhibit "B".

3. On December 1, 2014, I served the Plaintiff with another Request to

Produce, a copy of which is attached hereto as Exhibit "C".

4. I had attempted to contact Plaintiff's counsel with regard to the issues in

this motion but was unable to contact Plaintiff's counsel.

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5. As of the date of this Motion to Compel, Plaintiff has not filed any

response or objection to the discovery, nor has the Plaintiff requested an extension of

time to respond with the court.

6. In accordance with Administrative Order S-2012-064, I am requesting the Court to

enter an Order without a hearing requiring compliance with the original discovery within ten (10)

-days fr-om t-he -signing of t-he order compelling such compliance.

7. Provided with this Motion to Compel is a Proposed Order along with self addressed

stamped envelopes as required by the foregoing administrative order.

WHEREFORE Defendant, Darrel~ V-Olentine, pro se, requests thts Court grant

this Motion, order Plaintiff to respond to the original discovery within ten (10) days from

the signing of the order, and such other and further relief this Court deems just and

proper.

I hereby certify that this Motion to Compel was mailed to Craig A. Huffman, Esq.,

13046 Racetrack Road, Tampa, Florida 33626 on January~ 2015,

Darrell Volentine, Pro Se 803 Via Concha Road Nipomo, California 93444 805-343-1256

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