Verified Complaint for Damages, Declaratory Relief, and Other Relief

The Verified Complaint alleges that the plaintiffs were solicited in mid-2025 as prospective minority investors in the Remington firearms business operated from the LaGrange Manufacturing Facility at 1475 South Davis Road, LaGrange, Georgia. After executing a non-disclosure agreement (August 2025) and a letter of intent (September 2025), plaintiffs allege they discovered that the enterprise was operated through a deliberately opaque network of at least nine related entities whose ownership and inter-relationships were not documented to them despite repeated requests during formal due diligence.

The pleading further alleges, among other things: that the 856-job commitment publicly announced to the State of Georgia in November 2021 was materially inconsistent with internal operating plans projecting a workforce below 200; that a construction-loan draw (“Draw 9”) designated for identified contractors was diverted; that more than 250 trade creditors of the enterprise remain unpaid by design; that certain secured positions held by entities described as “SIFT” and “Western Rock” are self-dealing interests subject to equitable subordination; and that the plaintiffs themselves remain unpaid for services provided to the facility. The complaint pleads eleven counts: fraud in the inducement; promissory fraud; civil conspiracy; voidable/fraudulent transfers; conversion; breach of contract or quantum meruit; civil theft by deception; Georgia RICO violations; punitive damages; attorneys’ fees; and a declaratory judgment that the parties’ NDA cannot suppress the facts alleged.

Each of the foregoing is an allegation of the plaintiffs, presented here in summary form for public reference. The full text below is the authoritative source.