StayTerra files amended lawsuit complaints
BRADENTON – StayTerra Vacations has amended the lawsuit complaints originally filed in late 2025 and recently dismissed by Circuit Court Judge Charles Sniffen on June 18.
The original and amended lawsuit complaints name StayTerra Vacations, Prime Vacations and GSP Prime Holdings as the plaintiffs. One of the separate but similar original complaints named Kiri Stewart as the defendant and named as co-defendants several property-specific LLCs Stewart is or was associated with. The other complaint named Jennifer Warren-Kaleta as the defendant and named as co-defendants several property-specific LLCs she is or was associated with.
Warren-Kaleta is developer Shawn Kaleta’s ex-wife. Stewart is his current life partner. Shawn Kaleta is mentioned frequently in the complaints but he is not named as a co-defendant.
In the written dismissal order that granted Stewart and Warren-Kaleta’s motions to dismiss the original complaints, Sniffen stated the plaintiffs had 20 days to amend their complaint in conformity with his order.
According to the complaints, in September 2024, GSP, through StayTerra, closed on a transaction with the Prime Business founders and owners to acquire the majority stake in that business entity. The original complaints identified Shawn Kaleta and Roman Eckert as the Prime Business owners and founders. The complaints alleged a breach of contract for the $105 million consideration StayTerra paid Prime Business in exchange for the exclusive right to collect management fees for the Prime Business properties for a minimum of seven years.
According to the lawsuit complaints, Shawn Kaleta and Eckert also agreed to five-year no-compete provisions, which the lawsuits allege have been violated.
As a condition of closing the $105 million transaction, the Prime Business founders and owners entered into a master property rental and management agreement (PMA) with StayTerra Vacations.
In his June 18 order, Sniffen cited multiple issues with the original lawsuit complaints. He stated the similar original complaints filed separately against Stewart and Warren-Kaleta included hundreds of numbered paragraphs that are “replete with evidentiary facts and impertinent allegations.”
In response to Sniffen’s order, each of the amended complaints filed by attorneys Christopher Nigro, John Wagner and Carson Oakley has been shortened. The amended complaint filed against Warren-Kaleta now contains 166 paragraphs. The amended complaint filed against Stewart contains 132 paragraphs.
In his dismissal order, Sniffen stated the original complaints did not specifically allege whether Kaleta or Eckert signed the PMA as the Prime Business founders and owners, or as authorized signatories representing the individual LLCs named in the lawsuit, or some combination of both.
“These allegations shall be clarified in any amendment,” Sniffen’s order states.
With regard to Shawn Kaleta and Eckert’s role as authorized signatories of the PMA, the amended complaints state: “Kaleta and Eckert specifically represented to plaintiffs that they signed the master PMA in September 2024 in their capacity as the owners or legally appointed representatives of the properties that were owned directly by the property owners, and that they were authorized to act on behalf of the property owners.”
Sniffen’s order also notes the plaintiffs must prove that the defendants’ conduct “misled guests and distorted the vacation rental market” and that “plaintiffs had to mitigate the harm to guests and the public by preventing double-booking and disruption to reservations.”
The revised complaints allege, “Defendants diverted bookings and rental revenue from plaintiffs by listing vacation rental properties that were managed by the Prime Business on Airbnb, VRBO and other platforms and then, after receiving a booking for the property, coordinating with the owner of the property to inform plaintiffs that the dates should be blocked off for personal use, a representation that in all instances was false.”
