Gross is alleged to have touted his work with Gunawardhana, Fletcher, Ridge Hill and Ataraxia in offering connections, financial scale, quality control and experience that “most in the PPE market do not.” Unknown to Remcoda at the time, Remcoda alleged the only information that Gross relayed that was true was that Ridge Hill and Ataraxia are one in the same.
Also on July 28th, Gunawardhana is alleged to have sent Remcoda a fraudulent email from Vaidyanathan falsely claiming that “government intervention” in Vietnam was delaying Remcoda’s order, but assuring that the De Raj Entities’ “connections at the most senior level in VGloves and the relevant government ministries” would provide a “big advantage” and the gloves would be ready for delivery shortly. In forwarding the fraudulent email to Remcoda, Gunawardhana falsely assured them that an inspection of the gloves had been scheduled for July 30th, and the goods would be shipped on August 8th.
Despite repeatedly advising Remcoda that Ridge Hill had sourced and secured full stock of all of the gloves that they had ordered, Ridge Hill failed to deliver the gloves by July 31st, as required by the agreement. Instead, with knowledge that Remcoda had time sensitive commitments to supply the gloves to its customers and to repay its lender, the defendants were alleged to have pressed forward with their fraudulent scheme to prevent Remcoda from defaulting Ridge Hill and taking steps to obtain a refund of the deposit by continuing to misrepresent that delivery of gloves was imminent.
