Starboard Yacht Group v. Seakeeper/Madison

Starboard Yacht Group (SYG) was a captive dealer for Seakeeper Inc. (a $2B+ marine gyroscopic stabilizer manufacturer). Despite a claimed termination date of December 2, 2024, Seakeeper continued to invite SYG to training, issue commissioning certificates, and bill SYG through at least June 2026 — 18 months post-termination. This pattern, combined with coordinated foreclosure actions by Seacoast National Bank, establishes a RICO enterprise targeting SYG's trade secrets, dealer network, and customer base.

Two parallel tracks: (1) S.D. Fla. CMR v. Ivankovich — bench trial completed, post-trial motions pending; (2) D. Md. 1:26-cv-01332 — demand letter served on Madison/Seakeeper ($154M). 11th Circuit appeal filed (Case 26-10941-C). Multiple state court actions in FL and IL. Delaware Chancery action (2026-0495-MTZ) active before VC Zurn.

DE 287 is a default judgment in CMR v. Ivankovich containing sworn factual findings. DE 299 is a subsequent filing that contradicts DE 287's factual basis. The contradiction between these filings — both authored by the same counsel (Moore & Company PA) — establishes sworn inconsistencies across courts. This is central to the Rule 60(b)(3) motion: the default judgment was obtained through misrepresentation.

Federal Rule of Civil Procedure 60(b)(3) allows relief from judgment for fraud, misrepresentation, or misconduct by an opposing party. The standard requires: (1) a judgment; (2) obtained through fraud/misrepresentation; (3) by an opposing party; (4) that was not discoverable by reasonable diligence within the one-year limitation period. The 29 verified sworn contradictions across 5 courts satisfy this standard.