EXHIBIT A

Aug 4 (7
days ago)

Hearing and Complaint

Inbox x

Evan Kidd

<evankiddjd@gmail.com>

Jul
11

to craig

Craig:

We are looking to schedule a hearing for Defendant's Motion to Compel ClearTrust, there is time on
August 4th at 11:30 AM, and August 5th at 3:30, 4, and 4:30. Let me know what works for you. If I
don't hear back by tomorrow at 2PM, I will set a time and let you know.

I have a copy of the original complaint, but it is missing page 23, which corresponds to paragraphs 8891. Could you please send me either the page or the complaint in entirety, whichever is easier for
you.

Regards,

craig@securuslawgroup.com

Jul
11

to me

Evan,

1.

Attached is the complaint, which is whole as filed.

2. As to hearing concerning Cleartrust, you should share with me the

motion, as I do not have that in the filings I can find. Volentine has done so
many of these that they are hard to keep track of. I just went through the last
electronic filings received and did not see it. As you may or may not know, we

have had a large volume of matters available since last summer, and have
held them pending protection, but avowing we had items. Volentine never
was able to put together a coherent relevant list so we stuck to all the notices
that we had documents and for protection. Bottom line, get me the list and
documents you want and we have no problem producing them under a
protective agreement as to who sees them. Other than that, August 4th will
work for the motion if needed. I don't believe it is, if you can give what it is
you are requesting.

3. We need to set the depositions of Kyle Kennedy and Volentine set. I have
a court reporter near Volentine for Video Deposition. We should do them on
back to back dates of two days. Since Volentine is West Coast, we would
begin at 11:30 ESTand continue until 5:00 if needed. Right now I am posing
that the dates of July 27 through July 29th, August 1st through the 3rd, and
August 8th through the 10th. We can argue and decide the Order of them or
flip a coin.

Craig A. Huffman, Esquire

Securus Law Group, P.A.
13046 Racetrack Road #243
Tampa, Florida 33626
Phone: (888) 914-4144
Fax: (888) 783-4712
E-mail: Craig@securuslawgroup.com

Attachments area

Evan Kidd

<evankiddjd@gmail.com>

Jul
11

to craig

Craig,

Thank you for the complaint, I have attached to this email the Motion to Compel Cleartrust. I
will work on compiling a list of documents, and so long as we get the documents, I agree there

won't be a need for a hearing on the matter. I will review the protective order, and so long as it
is fair, I respect that your client has business interests to protect and this seems reasonable as
well.

Let's continue dialogue on the order of depositions and the dates, as of right now the latter
dates look more feasible to me.

Sincerely,
Evan Kidd
Attachments area

Cleartrust Document Request

Inbox x

Evan Kidd

to craig

<evankiddjd@gmail.com>

Jul
13

Craig:

Please see the attached list of documents I request. Let me know when they can be produced.
Let's chat soon about depo order.

Sincerely,
Attachments area

craig@securuslawgroup.com

Jul
15

to me

Evan,

1. As to documents, we have a lot of those and we had sought protection on

their disclosure to third parties. Actually Darrell and I had over the documents
from the auditor which included a lot of those documents. I have no issue
with redoing the agreement for Cleartrust (although their main counsel will
have to approve out of New York) but it is our property, so not an issue, we
produce it. Maybe a bit extensive on the time though since it is out of bounds
on the relevant periods, but we can agree on most.

2. As to depos, I want a confirmation now of the dates, and I have a

solution for who goes first. A random draw based on a lottery drawing. We
pick a drawing and one side picks odd or even. Whatever the last number is
decides from that drawing. I propose we select and lock in now August 8th
and 9th for depositions of both Kyle and Darrell.

Craig A. Huffman, Esquire

Securus Law Group, P.A.
13046 Racetrack Road #243
Tampa, Florida 33626

Phone: (888) 914-4144

Fax: (888) 783-4712
E-mail: Craig@securuslawgroup.com

Evan Kidd

<evankiddjd@gmail.com>

Jul
15

to craig

Craig:

My client advised me that he sent you an addendum to the protective agreement that also
covers Cleartrust. Was that insufficient? Please let me know what needs to be done on that
front and we will get it done ASAP.

We know that the auditor had a fraction of the documents that Cleartrust must have, since
they only had a sampling of documents provided to them by Seafarer.

Since I want the Cleartrust documents and time to review them before the Kennedy
deposition, we may or may not be able to have the depositions before August 15th. We may
need to agree on an extension of the date.

Since Mr. Kennedy was already scheduled for deposition, and given the reason it didn't take
place was a no-show, I don't see why the order of depositions should be in question now. I'm
fine with them taking place within a day of each other.

Sincerely,

Depositions
Inbox x

craig@securuslawgroup.com

Jul
27

to me

Evan,

This is going to be one more communication for the fulfillment of what Judge
Stephens Ordered at the last hearing. It was clear that he ordered both Mr.
Kennedy and Mr. Volentine to be deposed by August 15th. I have
communicated several times to you with offers of dates to do such
depositions.

You have balked at doing so because I had wanted to depose Mr. Volentine
first. I then proposed an easy solution that we decide by chance draw on a

lottery drawing. You again refused, with new conditions involving matters of
production of documents involving share transactions before you would
depose Mr. Kennedy. You never raised such a demand and condition before
the Court when you were simply arguing, and being granted, for the
deposition of Mr. Kennedy. While I agreed to work with the production of
documents, it is not a condition to deposition as ordered by the Court.

While I will agree to the confidentiality of the document production as I

proposed, which we have no issue with, the depositions will occur. If you are
conditioning the deposition of Mr. Kennedy on such documents you can
explain that to the Court. As to your wanting me to make changes, I would
challenge you that I am sure you can figure out how to use a redline edit and
make the suggested changes to the document as you would propose it.

Such production is certainly not a condition to my deposition of Mr. Volentine.

Therefore I am again stating the dates of August 9th and 10th for the
depositions. If you want to have the production of documents before the
deposition of Mr. Kennedy, then fine, but I will be deposing Mr. Volentine. If
you agree on both depositions, then we can have the order of the depositions
set by chance as I proposed. Respond by tomorrow on those dates.

Craig A. Huffman, Esquire

Securus Law Group, P.A.
13046 Racetrack Road #243
Tampa, Florida 33626
Phone: (888) 914-4144
Fax: (888) 783-4712
E-mail: Craig@securuslawgroup.com

Evan Kidd

to craig

<evankiddjd@gmail.com>

Jul
29

Craig:

With regard to the protective agreement, I responded to you with the changes that were
required. You have had since then to make the simple changes. I am not sure why you are
suddenly talking about redlining. It is your agreement, and you asked me if any changes were
required, and I promptly complied with your request.

With regard to the depositions, I agreed to the date without consulting with my client and
without all of the information that I needed to make such a decision. I also did not schedule my
Motion against Cleartrust because I believed you were going to produce those documents in
advance of the Kennedy deposition without the need for a hearing. You knew that I wanted
those documents in advance of the Kennedy deposition. I am sure the Court will agree that I
have a right to discovery responses in advance of the Kennedy deposition, the responses of
which are more than 6-12 months past due, and which responses are crucial to the case and
are needed for the deposition of Kennedy. Why should I depose Kennedy without the
production? Then I'd have to re-depose Kennedy once I get the production - which you will
certainly object to. And even if you didn't object to the second deposition, it would cost my
client double the expenses. You are more experienced than I so you know what is legal and
what is proper.
With regard to the order of the depositions, Darrell asked to set your client's deposition first.
Your client was set for deposition which you decided not to attend. Darrell never agreed to his
deposition first and you will find no email to that effect. You know what is right and you know
the custom and practice on this issue.
If it becomes necessary, I will be filing the appropriate motion with the Court on these issues.

Sincerely,

Depositions
Inbox x

craig@securuslawgroup.com

Aug 4 (9
days ago)

to me

Evan,

I am again requesting that we arrange the deposition of your client in this

matter.

1. This is a subsequent email with dates available for the deposition of Mr.
Volentine. I am proposing that his deposition be taken via video so he can
attend close to home on August 16, 17, 18 or 19, or August 22, 23 and 24
or August 29, 30 or 31st.

2. Depositions were ordered by the Court to be completed by August 15th.

You placed additional conditions of production of documents before you
wanted to take the deposition of Mr. Kennedy. That is an issue you did not
raise with the Court at the hearing before the Court ordered the date to be
done by. Such production is irrelevant to the deposition of Mr. Volentine and
therefore we will take his deposition.

3. Mr. Kennedy, as represented before is more than willing to be deposed

and has been ready to be deposed. Your additional condition of production of
other documents not withstanding which you did not raise before the Court. I
have given you the option of such depositions of both Mr. Kennedy and Mr.
Volentine being done on consecutive days a number of times, but you are
placing conditions on depositions that were not raised with the court as to
order of depositions and the production of documents.

4. As to the production of documents, I have sent you the agreement which

you reviewed and invited you to edit it as you would want, which you have
not done. I am not here to do your editing on a proposed agreement that I
provided to you in a word document that you can edit as well for agreement.
We can still do that if you merely take the time to edit the agreement to your
approval.

Respond as to the dates for Mr. Volentine please.

Craig A. Huffman, Esquire

Securus Law Group, P.A.
13046 Racetrack Road #243
Tampa, Florida 33626
Phone: (888) 914-4144
Fax: (888) 783-4712
E-mail: Craig@securuslawgroup.com

-------- Original Message -------Subject: Re: Depositions

From: Evan Kidd <evankiddjd@gmail.com>
Date: Fri, July 29, 2016 6:58 am
To: craig@securuslawgroup.com
Craig:
With regard to the protective agreement, I responded to you with the changes
that were required. You have had since then to make the simple changes. I am
not sure why you are suddenly talking about redlining. It is your agreement, and
you asked me if any changes were required, and I promptly complied with your
request.

With regard to the depositions, I agreed to the date without consulting with my
client and without all of the information that I needed to make such a decision. I
also did not schedule my Motion against Cleartrust because I believed you were
going to produce those documents in advance of the Kennedy deposition without
the need for a hearing. You knew that I wanted those documents in advance of
the Kennedy deposition. I am sure the Court will agree that I have a right to
discovery responses in advance of the Kennedy deposition, the responses of which
are more than 6-12 months past due, and which responses are crucial to the case

and are needed for the deposition of Kennedy. Why should I depose Kennedy
without the production? Then I'd have to re-depose Kennedy once I get the
production - which you will certainly object to. And even if you didn't object to the
second deposition, it would cost my client double the expenses. You are more
experienced than I so you know what is legal and what is proper.
With regard to the order of the depositions, Darrell asked to set your client's
deposition first. Your client was set for deposition which you decided not to
attend. Darrell never agreed to his deposition first and you will find no email to
that effect. You know what is right and you know the custom and practice on this
issue.
If it becomes necessary, I will be filing the appropriate motion with the Court on
these issues.

Sincerely,
Evan Kidd

On Wed, Jul 27, 2016 at 9:12 PM, <craig@securuslawgroup.com> wrote:

Evan,

This is going to be one more communication for the fulfillment of what Judge
Stephens Ordered at the last hearing. It was clear that he ordered both Mr.
Kennedy and Mr. Volentine to be deposed by August 15th. I have
communicated several times to you with offers of dates to do such
depositions.

You have balked at doing so because I had wanted to depose Mr. Volentine
first. I then proposed an easy solution that we decide by chance draw on a
lottery drawing. You again refused, with new conditions involving matters of
production of documents involving share transactions before you would
depose Mr. Kennedy. You never raised such a demand and condition before
the Court when you were simply arguing, and being granted, for the
deposition of Mr. Kennedy. While I agreed to work with the production of
documents, it is not a condition to deposition as ordered by the Court.

While I will agree to the confidentiality of the document production as I

proposed, which we have no issue with, the depositions will occur. If you are
conditioning the deposition of Mr. Kennedy on such documents you can
explain that to the Court. As to your wanting me to make changes, I would

challenge you that I am sure you can figure out how to use a redline edit and
make the suggested changes to the document as you would propose it.

Such production is certainly not a condition to my deposition of Mr. Volentine.

Therefore I am again stating the dates of August 9th and 10th for the
depositions. If you want to have the production of documents before the
deposition of Mr. Kennedy, then fine, but I will be deposing Mr. Volentine. If
you agree on both depositions, then we can have the order of the depositions
set by chance as I proposed. Respond by tomorrow on those dates.

Craig A. Huffman, Esquire

Securus Law Group, P.A.
13046 Racetrack Road #243
Tampa, Florida 33626
Phone: (888) 914-4144
Fax: (888) 783-4712
E-mail: Craig@securuslawgroup.com