Seems some fun went down in Texas today. This is just one of the many filings that went down, but it is very important, We have another affidavit, and it is even more damning:
AFFIDAVIT OF REDACTED
STATE OF REDACTED)
County of REDACTED )
I, REDACTED, being first duly sworn, upon oath, depose and say:
That I am the principle owner of REDACTED via it’s parent company, REDACTED. doing business in the State of REDACTED.
That in January 2013, Charles Clifton retained REDACTED’s services on behalf of Red Rock Ordinance (RRO). The nature of the agreement was for REDACTED to provide technical support, marketing support, and business management consultation.
That REDACTED was very successful on the technical and marketing portions of the agreement, however RRO had trouble following the business management recommendations, which generally centered around shipping product before continuing to transact sales.
That Mr. Clifton made the assertion that the reason they had not shipped product was due to lack of management on the part of Ben REDACTED, who was in control of a facility in Red Rock, Texas, and that they were in the process of terminating his employment due to squatting and daily alcohol abuse while on premises.
That, around that same time, Mr. Clifton solicited me for a weeklong, onsite consultation,and I agreed. The agreed purpose of my consultation was to bring the Red Rock facility into production.
That I flew down to Texas on March 26th, 2013, and began my consult. RRO instructed me not to rent accommodations, and to, instead, stay at the home of the Clifton’s.
That during this entire stay, I saw very little management of RRO. Mr. and Mrs. (Barb) Clifton abused alcohol every night of the 7 nights I was there, and generally got up at 10-11am. after advising me that I would need to be awake around 6:00 a.m. each morning so we could start working each day.
That on a daily basis, while I was on consult, they misused corporate funds for personal purchases. The two regular employees that were there each weekday in the capacity of landscaping and babysitting, and were paid with corporate checks.
That the night of March 26th, 2013, was spent with Charles Clifton, REDACTED (another contractor), and myself, discussing the status of the RRO facility. Mr. Clifton informed us that Ben REDACTED was, in fact, a venture capitalist, and not an employee, who had invested roughly two hundred twenty thousand dollars ($220,000) into RRO without being under a contract. Further, we were informed that, upon Mr. Clifton receiving the proposed contract, he disagreed with the terms. Mr. Clifton went on to inform us the relationship with Mr. Ben REDACTED had degraded after he had a verbal altercation with Mr. Ben REDACTED wherein Mr. Clifton lost his temper, and allegedly, and inadvertently, threatened Mr. Ben REDACTED.
That they drank until 1:00 a.m. on this occasion, talking about retiring back to the Dominican Republic. I went to bed at the same time.
That the Cliftons had brand new beds purchased and setup by their staff in each of the two previously empty bedrooms on the ground floor of the house. I stayed in one of those rooms. I was not able to get sleep as the 8 kenneled dogs they have, as well as their children, kept me awake with their barking and noise for most of the night.
That March 27th, 2013, was spent in many hours of discussion regarding business issues regarding the separation of Mr. Ben REDACTED and RRO. Mr. REDACTED spent the majority of the day trying to locate a security company to handle a ‘Hostile Employee Termination’ as Mr. Clifton asserted that Mr. Ben REDACTEDwas a violent alcoholic who was squatting for the purpose of forcing him to sign an unreasonable contract for venture capital.
That Mr. Clifton instructed everyone to steal back a document he had given Mr. Ben REDACTED as proof of cash flow during his negotiations with him for venture capital. The document was described as a PayPal transaction printout with customer names and email addresses removed.
That March 28th, 2013, was my first visit to the facility. My instructions were to carry out any steps that I saw fit to turn the shop into a functional production facility.
That the shop was not production ready before or after this visit. Two of the three CNC machines were not wired in, and despite repeated questions, Mr. Clifton could not provide the g-code to program the third. None of the machines were technically capable of producing the components necessary for the product sold by RRO.
That I was told that the Fadal which was connected to power was for the purpose of cutting AR15 lower receiver blanks, which was not an item being sold by RRO. All machines lacked programming. All Machines lacked fixtures and complete tooling setups. Two of the machines had not been physically installed and would have presented a safety hazard if they were powered.
That after roughly two hours, I was instructed to tear down and remove all easy to move equipment of value from the premises. During this time, I learned that Mr. Ben REDACTED was a co-signer on the building’s lease.
That on March 29th, 2013, Charles Clifton, two of his “ranch” employees, Mr. REDACTED, and myself removed consumable materials and office equipment from the leased shop in Red Rock, Texas. A sheriff standby was requested for our protection, and a deputy stayed onsite through the duration. We were told by Mr. Clifton that all materials we were removing were property of RRO, and unencumbered prior to going to the site.
That during the removal I was instructed by Mr. Clifton to remove a set of cutting heads for a Fadal CNC machine. I enquired as to ownership and was told that they belonged to RRO. Upon returning to the residence of Mr. and Mrs. Clifton, I was instructed by Mrs. Clifton to hide the cutting heads on the top shelf of a closet. The closet was in their house rather than in a separate building where we were instructed to store the rest of the materials. I was told later on that night by Mr. Clifton that the cutting heads were not, in fact, property of RRO, and that Mr. Clifton had been contacted by the police.
When I enquired as to why Mr. Clifton wanted these items removed, I was told that they wanted to make sure that Mr. Ben REDACTED would not be successful in manufacturing with the Fadal machine, and that they would have better leverage in their intended lawsuit.
That I set up two computer workstations in their dining room to help them move forward with production. On these workstations I installed “SolidWorks 2013” and “Mastercam”. Both programs were licensed and legitimate. In my professional experience this normally represents around eight thousand dollars($8,000) worth of software. I asked Mr Clifton what he would like to do with the machines and where he was keeping his CAD files. He explained that RRO did not have any CAD files to derive cutting information from, and that he would need me to acquire some for him. I explained that, while I did have some, I didn’t have all the files necessary for an AR15
Bolt Carrier Group. He offered one thousand dollars($1,000) for the Bolt Carrier CAD file if I was able to acquire one. I provided the remaining CAD files that I did have.
That the morning of March 30th, 2013, when I used the computer I had set up the night before, I noticed that someone had used it to access my personal email and memory key without my knowledge or permission.
That March 31st, 2013, I purchased a CAD file of an AR15 Bolt Carrier with my company’s funds, and provided it for use by RRO. I spent the day configuring a CNC mill (X3 Mini-Mill that was supposed to go to Colorado, which did not get shipped because it waiting for parts, i.e. part clamping fixtures and an upgrade to the z-axis motor.) for shipment and use to Victory Defense in Colorado. That night I was told that Mrs. Clifton was very angry with a woman they had staying with them, Jessica REDACTED, because she had found out, by accessing Ms. REDACTED’s cellular phone, without her knowledge or permission, and while she was out of the house, that the woman was attracted to me. This escalated into multiple arguments between them.
That on April 1st, 2013, Mr. Clifton accompanied me to an electronics retailer so I could advise him on surveillance equipment. He purchased surveillance equipment stating that he was securing his property against Mr. Ben REDACTED and angry customers. At the same time he purchased the equipment, he also purchased additional surveillance equipment with the stated intention of spying on Ms. REDACTED.
That on April 2nd, 2013, Mr. Clifton left to Houston, Texas transporting a trailer of metal barstock and cutting lubricant to a shop that he was hiring to begin cutting the Bolt Carrier portion of the product using the CAD file I had provided. I missed my flight waiting for the return of some of my property the Cliftons had removed from me without my knowledge, and had to reschedule for the next day.
That on April 3rd, 2013, I flew back to my home state, deciding that my storage devices were of less value than continually rescheduling my flight again. To date my personal storage has not been return to me and has been effectively stolen by the Cliftons.
That to date RRO, to the best of my knowledge, is selling a product they have never shipped, nor have the financial or technical ability to produce. Further, they are using intellectual property provided by REDACTED that they do not have rights to use as a basis of production, and have not have not paid for.
That I had access to the bank, e-commerce, and PayPal accounts as part of the technology side of REDACTED’s services, and, to the best of my knowledge, RRO has received over four hundred thousand dollars ($400,000) in customer purchases, and two hundred twenty thousand dollars ($220,000) in venture capital. This money has not resulted in any benefit to any party other than RRO, Charles Clifton and Barb Clifton, and, to the last of my knowledge, on April 1st, 2013, only one hundred sixty thousand dollars($160,000) of it remained.
That, upon my return to the State of redacted, I terminated my contract with RRO due to my belief that they are an unethical company based on the above things that I viewed while I was in Texas.
Folks, if you want more information on what we redacted, you are going to have to call up that Texas Court yourselves. We are trying to protect the innocents the best we can.