Case 1:25-cv-05635-SEG Document 1 Filed 10/01/25 Page 1 of 33

IN THE UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION

CHANDLER MOORE and )

MOWORKS LLC, )
)
Plaintiffs, )
)
v. )
)
NORMAN GYAMFI, INSIGNIA )
Civil Action File No.
HOLDING COMPANY, INSIGNIA )
Jury Demand
ASSETS, LLC, TRIBL )
PUBLISHING INC., TRIBL )
RECORDS, LLC, MAVERICK )
CITY MUSIC, INC., and )
MAVERICK CITY MUSIC )
PUBLISHING LLC, )
)
Defendants.

COMPLAINT

Plaintiffs Chandler Moore (“Moore”) and MoWorks LLC (“MoWorks”)

(collectively, “Plaintiffs”) bring this Complaint (“Complaint”) against Defendants

Norman Gyamfi (“Gyamfi”), Insignia Holding Company (“Insignia Holding”),

Insignia Assets, LLC (“Insignia Assets”), TRIBL Publishing Inc. (“TRIBL

Publishing”), TRIBL Records, LLC (“TRIBL Records”), Maverick City Music, Inc.

(“Maverick City Music”), and Maverick City Music Publishing, LLC (“Maverick

City Publishing”) (collectively, “Defendants”) and state and allege as follows:

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INTRODUCTION

1. This case involves the all-too-common fact pattern of a business

manager and his corporate alter egos taking advantage of a creative musical artist

and violating the trust the artist placed in the manager. Here, the business manager,

Norman Gyamfi, exploited his fiduciary relationship with musical artist Chandler

Moore by, among other things, entering into deals to enrich himself without Moore’s

knowledge, secretly forging Moore’s name on a contract to divert monies owed to

Moore into Gyamfi’s own pockets, misappropriating Moore’s intellectual property

rights and the right to receive millions of dollars in royalties and other monies to

which Moore and his company, co-plaintiff MoWorks LLC, are entitled. Moore

brings this complaint to achieve the full severance of his relationship with Gyamfi

and to seek legal and equitable remedies for Gyamfi’s (and his alter ego entities’)

misconduct, including their breaches of contract, breaches of fiduciary duties, fraud,

and other related claims.

PARTIES

2. Plaintiff Chandler Moore is a Texas citizen and resident.

3. Plaintiff MoWorks LLC is a limited liability company organized under

the laws of the State of Texas and is a citizen of the State of Texas.

4. Norman Gyamfi is a citizen and resident of Georgia and may be served

at 5168 Lake Forrest Dr., Atlanta, GA 30342.

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5. Insignia Holding Company is a Georgia corporation having its principal

place of business at 369 Palm Sedge Loop, Elgin, SC 29045. Insignia Holding may

be served through its registered agent, Norman Kofi Gyamfi, at its registered office

located at 3607 Wheeler Branch Rd., Hephzibah, GA 30815.

6. Insignia Assets, LLC is a limited liability company organized under the

laws of Delaware and, pursuant to the Georgia Long-Arm Statute, O.C.G.A. § 9-10-

90 et seq., may be served through its registered agent, the Corporation Trust

Company, at 1209 Orange St., Wilmington, DE 19801. Upon information and belief

formed upon a reasonable investigation, Plaintiffs understand the members to be

residents of Georgia. Plaintiffs are not aware of any member that is a citizen of

Texas.

7. TRIBL Publishing Inc. is a Georgia corporation having its principal

place of business at 369 Palm Sedge Loop, Elgin, SC 29045. TRIBL Publishing may

be served through its registered agent, Norman Gyamfi, at 3607 Wheeler Branch

Rd., Hephzibah, GA 30815.

8. TRIBL Records, LLC is a limited liability company organized under

the laws of Georgia and may be served through its registered agent, Anthony Brown,

at 1551 Thomas Rd., Decatur, GA 30032. Upon information and belief formed upon

a reasonable investigation, Plaintiffs understand the members to be residents of

Georgia. Plaintiffs are not aware of any member that is a citizen of Texas.

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9. Maverick City Music, Inc., is a Georgia corporation having its principal

place of business at 2411 Player Ct. Duluth, GA 30096. Maverick City Music may

be served through its registered agent, Jonathan Jay, at 2411 Player Ct., Duluth, GA

30096.

10. Maverick City Publishing LLC is a defunct limited liability company

organized under the laws of the State of Georgia. Upon information and belief,

Maverick City Publishing may be served through its agent, Jonathan Jay, at 2411

Player Ct., Duluth, GA 30096. Upon information and belief formed upon a

reasonable investigation, Plaintiffs understand the members to be residents of

Georgia. Plaintiffs are not aware of any member that is a citizen of Texas.

ALTER EGO ALLEGATIONS

11. Upon information and belief and at all times relevant hereto, a unity of

interest and ownership has existed between Defendants Insignia Holding, Insignia

Assets, TRIBL Publishing, TRIBL Records, Maverick City Music, and Maverick

City Publishing. Each of them are alter ego entities of individual Defendant Norman

Gyamfi and/or are directed, influenced, and controlled thereby.

12. Throughout the Parties’ relationship, Insignia Holding, Insignia Assets,

TRIBL Publishing, TRIBL Records, Maverick City Music, and Maverick City

Publishing represented themselves and acted as the same entity through various

corporate officers including, without limitation, Norman Gyamfi. Further, the

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agreements, accounting statements, and documents referenced herein refer to

Insignia Holding, Insignia Assets, Maverick City Music, Maverick City Publishing,

TRIBL Publishing, TRIBL Records, and several other unaffiliated Insignia entities

interchangeably.

13. While Maverick City Publishing has been a defunct entity since

September 2023, Defendants have referenced Maverick City Publishing in

documents and agreements as recently as 2024. The defendants also reference

Maverick City Publishing as a trade name or “d/b/a” for Maverick City Music

despite there being no official documentation thereof.

14. Contrary to any legitimate agreements between the Parties, Defendants

have directed that publishing monies be paid directly to Insignia entities that are

nowhere mentioned in said agreements including, without limitation, Maverick City

Publishing and other Insignia entities controlled by Norman Gyamfi and nowhere

mentioned in any agreements between the Parties.

15. Upon information and belief, Defendants’ corporate forms have each

been used as a shell for Norman Gyamfi to conduct and fund his personal business

and to fund and operate the Insignia entities including, without limitation, the named

Defendants, interchangeably.

16. Upon information and belief, Norman Gyamfi and the entity

Defendants acted for each other in connection with the conduct alleged herein,

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performed the acts complained of herein, and breached the duties complained of

herein as alter egos of each other, and any separation or distinction between the

Defendants, therefore, should be disregarded.

17. Adherence to the fiction that the Defendants exist as separate

entities/individuals distinct from each other and Norman Gyamfi would amount to

abuse of the corporate privilege and would promote fraud and injustice.

18. Accordingly, as alter egos of each other, Defendants are each liable for

the acts of the other.

JURISDICTION AND VENUE

19. This Court has subject matter jurisdiction over this action pursuant to ,

because the amount in controversy exceeds $75,000 exclusive of interest and costs,

and Moore and the Defendants are citizens of different states.

20. This Court has personal jurisdiction over Defendants because they are

all citizens of Georgia.

21. Alternatively, Insignia Assets, LLC is subject to jurisdiction under the

Georgia Long-Arm Statute, O.C.G.A. § 9-10-91 because it (1) transacts business

within this state; and (2) committed a tortious act or omission within this state.

22. Additionally, this Court has personal jurisdiction over TRIBL

Publishing, TRIBL Records (collectively, the “TRIBL Defendants”), and Maverick

City Music because the TRIBL Defendants consented to jurisdiction in Georgia in

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the Deal Memo Agreement (as defined below), an accurate copy of which is attached

hereto as Exhibit A, and Maverick City Music consented to jurisdiction in Georgia

in the Ownership Agreement (as defined below).

23. Venue is proper in this district pursuant to 28 U.S.C. § 1391(b) and(c)

because several Defendants reside in the Northern District of Georgia.

FACTUAL BACKGROUND

Chandler Moore

24. Chandler Moore is a Grammy Award winning singer, songwriter,

multi-instrumentalist, and worship leader known for his successful hit songs in the

contemporary Christian music industry, such as “Jireh,” “Lead Me On,” and

“Kingdom.” Moore is widely recognized as a founding member and frequent

collaborator with the contemporary Christian music collective, Maverick City

Music.

25. Moore has been releasing music since June 2014, and he has been a

member of Maverick City since 2018. Moore’s solo music as well as his

collaborations have gained tremendous success, earning him more than eleven (11)

Grammy Award nominations and ten (10) Gospel Music Association (“GMA”)

Award nominations.

26. Moore’s contribution to Maverick City’s success cannot be overstated

as he is the most prominent face of the group, has made significant contributions to

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Maverick City’s highest charting songs and albums, and has had one of the most

successful solo music careers to spawn from Maverick City.

Norman Gyamfi

27. Beginning in 2020, and throughout the formative years of Moore’s

career, Norman Gyamfi acted as both Moore’s personal and business manager,

providing advice, counsel, and direction to Moore in the development and

enhancement of Moore’s professional career and personal life.

28. It was around 2020 that Moore personally introduced Gyamfi to the

ownership and team at Maverick City, identifying Gyamfi as his management

representative. Prior to this introduction, Gyamfi had no relationship or connection

to Maverick City Music and was not actively involved in Maverick City Music’s

business dealings.

29. In discharging his duties as Moore’s personal and business manager,

Gyamfi exercised control over nearly all aspects of Moore’s career, financial affairs,

and business dealings, including but not limited to Moore’s access to his own

personal financial assets.

30. Moore reposed great trust and confidence in and accepted Gyamfi’s

guidance in his business and financial decisions. Gyamfi, however, abused his power

and the trust that Moore bestowed upon him, by withholding material information

that would adversely affect Moore’s career.

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31. It was Gyamfi’s regular practice to engage in informal business

dealings on behalf of Moore. Despite Moore’s role as a lead singer and major

contributor to Maverick City, Moore was one of the only members that had little to

no formal contracts or agreements governing the terms of his business relationship

with Maverick City.

32. While still acting as Moore’s personal and business manager, Gyamfi

acquired an ownership interest in Maverick City Music without informing Moore.

Gyamfi never disclosed his business dealings nor his plan to acquire an ownership

interest in Maverick City to Moore prior to doing so.

33. In his role as Moore’s manager, Gyamfi was involved in entering

Moore into agreements that would negatively affect Moore’s financial interests,

assets, and ownership of his created works, compositions, and master recordings.

34. Despite the fiduciary duties he owed to Moore, Gyamfi went on to

secretly transfer Moore’s ownership and copyright interests in his works to Maverick

City Music as well as broker a deal to convey Moore’s master recordings of songs

created with Maverick City to the Orchard, a Sony Music Entertainment entity.

35. Gyamfi continued in his role as Moore’s personal and business manager

until 2023. Gyamfi would later go on to assume the position of Chief Executive

Officer of Maverick City Music and hold various other managerial and officer

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positions in each of the Defendant entities, over which he exercised dominion and

control.

36. Making matters worse, Gyamfi and the Insignia entities unlawfully

retained assets and monies that were owed to Moore by wrongfully directing

publishing entities, including, without limitation, Essential Music Publishing LLC,

to pay all of Chandler’s publishing monies directly to Gyamfi and the Insignia

entities and to channel all communications and accountings through Gyamfi and the

Insignia entities.

37. Defendants’ greed, exploitation, and misappropriation of Moore’s

assets and intellectual property have deprived Plaintiffs of their contractually owed

royalties, assets, monies, and ownership interests. As a result, Plaintiffs seek judicial

intervention to remedy Defendants’ breaches of contract, breaches of fiduciary

duties, fraudulent conduct, unlawful conversion, unjust enrichment, and self-

dealing.

Insignia Entities

38. During this period, Maverick City Music spawned a number of related

entities, including but not limited to the Defendant entities. Insignia Assets was

created by Norman Gyamfi to function as the parent company for these entities.

39. Gyamfi acts as a representative for each of the Defendant entities.

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Ownership Agreement

40. On April 13, 2021, Moore and Maverick City Music entered into an

agreement whereby Maverick City Music would convey a ten (10%) percent

ownership interest in Maverick City Music to Moore upon his fulfillment of certain

obligations, including but not limited to, attendance at Maverick City Music events,

quarterly recording requirements, and coordination and collaboration on projects and

releases.

The Unauthorized Sale of Maverick City Music’s Masters by Gyamfi

41. In 2021, Gyamfi brokered a deal selling Maverick City’s masters to The

Orchard Enterprises, Inc. d/b/a The Orchard (the “Orchard”), a division of Sony

Music Entertainment specializing in music distribution (the “Sale”). Through this

deal, Gyamfi received a commission. Despite the significance of the transaction and

Gyamfi’s close relationship with Moore, Moore never received prior notice or

disclosure of the Sale of his masters nor information that Gyamfi was profiting from

the Sale.

42. Upon information and belief, following the Sale, Gyamfi demanded

that Essential Music Publishing LLC, the Christian music publishing division of

Sony Music Entertainment (“Essential”), pay all proceeds earned in connection with

the publication of Moore’s compositions and works directly to the TRIBL

Defendants and Maverick City Music instead of Moore.

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43. Gyamfi also demanded that Essential send all accountings and

communications directly to him and that Essential limit their communications with

Moore.

44. Upon information and belief, Essential requested proof of TRIBL

Defendants’ and Maverick City Music’s rights to collect and receive proceeds and

accountings on behalf of Moore before acceding to Gyamfi’s demands to bypass

Moore on such payments and information.

45. Upon information and belief, Gyamfi had a publishing agreement

drafted in an effort to comply with Essential’s requirements and fraudulently affixed

Moore’s signature thereon as set forth below.

Fraudulent Publishing Agreement

46. On January 1, 2022, a Publishing Agreement entitled “Exclusive

Songwriting Co-Publishing Agreement” (“Publishing Agreement”) was

fraudulently entered into by Gyamfi on behalf of Moore and Maverick City Music

without Moore’s consent. In a communication with Gyamfi, Moore generally

discussed a potential co-publishing agreement with Maverick City Music but never

reviewed or discussed the Publishing Agreement nor the terms therein.

47. Moore’s signature was forged onto the Publishing Agreement, as

Moore had no knowledge of the existence of the Publishing Agreement at the time

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it was signed, never signed the Publishing Agreement himself, nor authorized

Gyamfi or anyone else to sign the Publishing Agreement on his behalf.

48. Moore’s signature was forged throughout the Publishing Agreement

and Exhibits. The Publishing Agreement purported to assign and transfer an

undivided fifty percent (50%) interest in Moore’s compositions, works, copyrights,

titles and interests in proceeds obtained as a result of Moore’s past and future works,

compositions, and services to Maverick City Music, including but not limited to

Moore’s solo works and collaborations with Maverick City.

49. Further, the fraudulently obtained Publishing Agreement granted

Maverick City Music an irrevocable Power of Attorney, purporting to allow

Maverick City Music to utilize Moore’s name and/or stand in his place or stead to

take any action, sign and execute any document, and transfer Moore’s rights in his

works and compositions.

50. The fraudulently obtained Power of Attorney is unlimited in scope and

duration, as the Publishing Agreement explicitly states that the Power of Attorney

will survive the termination of said agreement. The Power of Attorney clause also

purports to allow Maverick City Music to take any of the aforementioned actions

even if Moore refuses to sign the documents or agree to the transfers as long as a

good faith effort is made to obtain his consent and/or signature.

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51. In addition to the various other fraudulently obtained rights, the

Publishing Agreement explicitly permits Maverick City Music to sign letters and

notices of assignment of Moore’s copyrights and rights to proceeds and accountings

attached to the Publishing Agreement as exhibits.

52. Moore’s signature was also forged onto several attachments to the

forged Publishing Agreement, including (1) the Assignment of Copyright in all prior

compositions (“Assignment”); (2) the Notice of Transfer to Public Performance

Rights Society (“Notice of Transfer”); (3) the Notice of Assignment of Copyrights

and Income (“Notice of Assignment”); and (4) Christian Copyright Licensing

International Notice of Assignment (“CCLI Notice”).

53. In the Assignment, Moore purportedly irrevocably transfers and assigns

an undivided fifty percent (50%) interest in his copyrighted works dating back to

2018. Moore’s signature was forged onto the Assignment, as Moore never signed

the Assignment himself nor authorized it to be signed on his behalf.

54. In the Notice of Transfer, Moore purportedly names Maverick City

Music as an administrator over his public performance rights and requires that all

proceeds be directed to Maverick City Music rather than to him until Maverick City

Music notifies the Public Performance Rights Society that the transfer agreement is

terminated. Moore’s signature was forged onto the Notice of Transfer, as Moore

never signed the Notice of Transfer himself nor authorized it be signed on his behalf.

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55. In the Notice of Assignment, Moore purportedly states that he

transferred to Maverick City Music the exclusive right to own and administer all

musical compositions that he owns or co-owns and requires that all proceeds earned

in relation to the aforementioned compositions be paid directly to Maverick City

Music. Moore’s signature was forged onto the Notice of Assignment, as Moore

never signed the Notice of Assignment himself nor authorized it be signed on his

behalf.

56. In the CCLI Notice, Moore purportedly authorizes and directs the

Copyright Administration of the Christian Copyright Licensing International to pay

all proceeds earned in relation to Moore’s public performance rights directly to

Maverick City Music. Moore’s signature was forged onto the CCLI Notice, as

Moore never signed the CCLI Notice himself nor authorized it be signed on his

behalf.

57. Additionally, the Publishing Agreement purports to grant Maverick

City Music the exclusive right to collect and receive proceeds from all licenses

issued under the Publishing Agreement in perpetuity.

58. When confronted about the fraudulently obtained Publishing

Agreement in 2024, Gyamfi stated that he was unsure who had signed on Moore’s

behalf but that he had access to the IP address information and would look further

into it.

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59. Gyamfi never provided any further information on Moore’s forged

signatures.

Deal Memo

60. On April 18, 2024, Moore and TRIBL Defendants entered into a

binding agreement entitled “Production Deal Memo” (“Deal Memo”) whereby

Moore agreed to satisfy specific live performance, recording, and publishing

obligations.

61. The Deal Memo obligated Moore to (1) record one album of at least ten

(10) newly recorded master recordings (“Recording Obligations”); (2) commit to

performing in a series of forty (40) concert-tour dates by December 21, 2024

(“Touring Obligations”); and (3) deliver at least twelve (12) compositions

(“Publishing Obligations”). A true and correct copy of the Deal Memo is attached

hereto as Exhibit A.

62. In connection with Moore’s Recording Obligations, the Deal Memo

obligates TRIBL Defendants to pay Moore (1) an advance of $300,000.00 upon

execution of the Deal Memo; (2) $125,000.00 towards the initial recording costs

upon execution of the Deal Memo; and (3) $125,000.00 following delivery of the

recorded product. If the mutual extension option is exercised, TRIBL Defendants

would be obligated to credit seventy-five percent (75%) of royalties derived from

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the recorded product at a minimum of $750,000.00 and a maximum of

$1,500,000.00.

63. In connection with Moore’s Touring Obligations, the Deal Memo

obligates TRIBL Defendants to pay Moore an advance of $1,400,000.00 as follows:

(1) $200,000.00 upon execution of the Deal Memo; (2) $100,000.00 upon

completion of twenty (20) shows; (3) $100,000.00 following completion of the final

show; and (4) $1,000,000.00 acknowledged as received.

64. In connection with Moore’s Publishing Obligations, the Deal Memo

obligates TRIBL Defendants to pay Moore an advance of $250,000.00 as follows:

(1) $125,000.00 upon execution of the Deal Memo; and (2) $125,000.00 upon the

one-year anniversary of the Deal Memo. Further, TRIBL Defendants are required to

pay Moore (1) seventy-five (75%) percent of all mechanical royalties; (2) fifty (50%)

percent of all performance royalties; (3) seventy-five (75%) of all royalties from

synchronization rights and covers; and (4) seventy-five (75%) of all other income

received. With respect to the works and compositions written prior to the Deal

Memo, the Publishing Agreement purportedly still controls.

65. The Deal Memo obligated TRIBL Defendants to pay Moore fifty (50%)

percent of all net profits from the sound recordings excepting all third party costs

and expenses paid by TRIBL Defendants for the sound recordings, provide semi-

annual accounting records within ninety (90) days following the closing of each

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quarter, and adhere to the policy of no cross collateralization of compositional

royalties with sound recording royalties.

66. The Deal Memo requires TRIBL Defendants to convey Moore a fifteen

percent (15%) ownership interest in Maverick City Music in accordance with the

following vesting schedule: (1) 7.5% vested immediately upon the later of the

execution of the Deal Memo and the equity documents (which were to be entered

into separately for the purpose of effectuating the transfer of ownership); and (2)

7.5% vested upon the later of Moore’s satisfactory delivery of the initial period

album (pursuant to Moore’s Recording Obligations), completion of the forty (40)

shows (as contemplated by the Touring Obligations), and execution of the equity

documents.

67. The Deal Memo explicitly states that TRIBL Defendants will cover

marketing expenses in the amount of $100,000.00 at a minimum and that marketing

is a non-recoupable expense.

68. The Deal Memo further contemplated Moore and TRIBL Defendants’

intention to enter into a longer, more formal publishing agreement and explicitly

recognizes their obligation to negotiate the terms to be included therein in good faith.

69. Moore satisfied his live performance and publishing obligations

required by the Deal Memo, and Moore and TRIBL Defendants renegotiated the

terms of the recording obligation clause.

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70. Despite Moore’s satisfaction of the Touring Obligations, TRIBL

Defendants cancelled six (6) shows and failed to compensate Moore in accordance

with the terms of the Deal Memo.

71. Further, in accordance with his obligations under the Deal Memo,

Moore and TRIBL Defendants agreed that Moore’s latest album, comprised of seven

(7) songs (the “Latest Album”) would satisfy Moore’s Recording Obligations,

subject to their understanding that three (3) of Moore’s preexisting recorded songs

would be used to create a deluxe version of the album and that Moore would be

available to serve as an executive producer on a number of Maverick City records.

72. Upon request from TRIBL Defendants, Moore provided a proposed

written amendment to the Deal Memo memorializing the oral agreement.

73. During the process of memorializing the oral agreement between

Moore and TRIBL Defendants, Gyamfi and TRIBL Defendants unilaterally

attempted to impose completely different terms that were well beyond the scope of

what was originally agreed.

74. For example, Gyamfi and TRIBL Defendants demanded, among other

things, that Moore also agree to extend Moore’s publishing commitment an

additional two (2) years, to withdraw Moore’s ownership stake in Maverick City

Music, and to receive a fifteen percent (15%) override on Moore’s subsequent two

albums.

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75. Due to Gyamfi and TRIBL Defendants’ unconscionable requests and

refusal to negotiate in good faith, the negotiations on a written amendment fell apart,

and the parties continued their duties under the terms of the original Deal Memo

subject to the oral agreement regarding satisfaction of Moore’s Recording

Obligations.

76. Additionally, throughout this period, Moore had been requesting

accurate and timely accountings in accordance with TRIBL Defendants’ obligations

under the Deal Memo to no avail. On the rare occasions that Moore received

accountings, they were not timely and did not accurately reflect the royalties to

which Moore is entitled.

77. As of the date of this filing, Moore has yet to receive accountings that

accurately reflect the agreements lawfully entered into between himself and

Defendants.

78. Upon information and belief, TRIBL Defendants currently owe Moore

more than $800,000.00 in publishing proceeds in accordance with TRIBL

Defendants’ obligations under the Deal Memo.

79. After Moore began to demand accurate accountings, and despite

TRIBL Defendant’s acceptance of the Latest Album, Moore’s substantial

performance of his obligations under the Deal Memo, and TRIBL Defendants’

improper cross-collateralization of compositional royalties and sound recording

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royalties, TRIBL Defendants sent Moore a Notice of Breach of the Deal Memo

(“Notice of Breach”) stating that Moore was in breach of the Deal Memo for failure

to deliver ten (10) newly recorded masters recordings and improperly demanded that

Moore remedy the alleged breach within thirty (30) days.

80. The Notice of Breach was sent as a pretextual reaction once Moore

began questioning the wrongful activities of Gyamfi and Defendants.

81. The thirty (30) day period to remedy the alleged breach ended on or

around April 25, 2025. Upon information and belief, TRIBL Defendants never

intended to act upon their Notice Letter since the parties to the Deal Memo had

already accepted Moore’s Latest Album in satisfaction of the Recording Obligation.

82. In regard to royalties, Defendants have and continue to unlawfully

cross-collateralize monies earned from Moore’s entire catalog of masters with his

new masters, contrary to the terms of the Deal Memo.

83. Defendants continue to withhold proceeds, royalties, and monies

rightfully owed to Moore in violation of the Deal Memo.

84. Defendants’ unlawful, fraudulent, and unconscionable business

practices have permeated and, thereby, tainted every agreement between Plaintiffs

and Defendants as evidenced by the innumerable breaches, violations, and instances

of misconduct referenced herein.

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85. Similarly, Gyamfi’s unlawful business practices and willful misconduct

have led to him being the subject of additional ongoing litigation commenced by

other previous members and owners of the Defendant entities.

COUNT I: BREACH OF CONTRACT AND DECLARATORY JUDGMENT

AGAINST DEFENDANTS

86. Plaintiffs incorporate the numbered paragraphs above as if fully set

forth herein.

87. In 2024, Plaintiffs and TRIBL Defendants entered into the Deal Memo.

88. Plaintiffs have performed their obligations under the Deal Memo.

89. In accordance with the Deal Memo, TRIBL Defendants were required

to (1) pay Plaintiffs the remaining $125,000.00 publishing advance by April 23,

2025; (2) pay Plaintiffs publishing royalties in accordance with the terms of the

Royalties subsection; (3) produce accurate and timely accountings to Plaintiffs; (4)

pay Plaintiffs fifty percent (50%) of all net profits from the recordings after all costs

have been recuperated.

90. TRIBL Defendants failed to pay Plaintiffs the $125,000.00 publishing

advance due and payable on April 23, 2025, and have still yet to pay Plaintiffs as of

the date of this filing.

91. Further, rather than collecting their portion of net profits after

recoupment, TRIBL Defendants have and continue to collect fifty percent (50%) of

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all revenue earned from Moore’s recordings under the Deal Memo and allocate only

Plaintiffs’ share of net profits to recuperate all costs.

92. Accordingly, TRIBL Defendants continue to retain publishing proceeds

paid by the Orchard that should have been paid directly to Plaintiffs.

93. To date, TRIBL Defendants still owe Plaintiffs more than $800,000.00

pursuant to their obligations under the Deal Memo and have yet to provide Plaintiffs

accurate accountings with calculations that adhere to the terms of the Deal Memo.

94. Despite entering into the Deal Memo with TRIBL Defendants, monies

received therefrom have channeled through and been attributed to a number of

different Insignia entities including, without limitation, Maverick City Music.

95. As a result, Defendants have materially breached the Deal Memo.

96. As a result of Defendants’ material breach of the Deal Memo, Plaintiffs

have suffered damages in an amount to be determined at trial.

97. Plaintiffs are also entitled to a declaratory judgment that Defendants

materially breached the Deal Memo, thereby rendering the Deal Memo void,

voidable, or terminable by Plaintiffs.

COUNT II: UNJUST ENRICHMENT AGAINST DEFENDANTS

98. Plaintiffs incorporate the numbered paragraphs above as if fully set

forth herein.

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99. Plaintiffs have substantially performed the Recording, Publishing, and

Touring Obligations outlined in the Deal Memo.

100. Defendants have unlawfully appropriated and retained Plaintiffs’

publishing proceeds amounting to over $800,000.00 which Plaintiffs have a legal

right to receive, despite demands therefor.

101. Defendants have also benefited from the unlawful retention of other

monies that rightfully belong to Plaintiffs.

102. As a result of Defendants’ unjust enrichment, Plaintiffs are entitled to

damages and/or disgorgement in an amount to be determined at trial.

COUNT III: BREACH OF FIDUCIARY DUTY

AGAINST NORMAN GYAMFI

103. Plaintiffs incorporate the numbered paragraphs above as if fully set

forth herein.

104. Gyamfi had a fiduciary relationship with Moore wherein Gyamfi acted

as Moore’s personal and business manager for several years. Moore and Gyamfi

shared a confidential relationship that bestowed upon Gyamfi substantial control and

influence over Moore’s professional career, business interests, and finances,

including his personal finances. Moore placed significant trust and dependence in

Gyamfi to act in his best interest.

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105. In his role as Moore’s personal and business manager, Gyamfi was

required and expected to prioritize Moore’s interests and avoid self-dealing, disclose

all material information that Moore would be entitled to know, avoid engaging in

dishonest or deceptive practices, and avoid mismanaging Moore’s assets.

106. While still acting as Moore’s manager, Gyamfi secretly acquired an

ownership interest in Maverick City Music without consulting or disclosing this

information to Moore who was a member of Maverick City at that time. Gyamfi

brokered a deal with the Orchard to personally benefit himself at the expense of

Moore. Gyamfi also was involved in the conversion of all of the compositions that

Moore wrote or co-wrote, and the proceeds thereof, through Gyamfi’s execution of

the forged Publishing Agreement and collateral documents. Each of these actions

constitute a willful breach of the fiduciary duty owed to Moore and a violation of

the sacred trust and confidence that must exist in a manager-principal relationship.

107. As a result of Gyamfi’s repeated breaches of his fiduciary duties to

Moore, unauthorized acts, and abuses of his power and authority, Moore has suffered

significant harm and is entitled to compensatory and punitive damages, and equitable

relief including disgorgement and an accounting, against Gyamfi in an amount to be

determined at trial.

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COUNT IV: COMPUTER FORGERY AGAINST

DEFENDANTS

108. Plaintiffs incorporate the numbered paragraphs above as if fully set

forth herein.

109. Gyamfi and Maverick City Music were involved in creating a forged

signature for Moore in execution of the Publishing Agreement. Moore had no

knowledge of the Publishing Agreement, did not sign the Publishing Agreement, and

did not authorize anyone to sign the Publishing Agreement on his behalf.

110. Gyamfi and/or a Maverick City Music representative acting at his

direction knowingly signed Moore’s name on the Publishing Agreement,

Assignment, Notice of Transfer, Notice of Assignment, and CCLI Notice

(collectively, the “Agreements”) with the knowledge that Moore was neither aware

of the existence of these agreements nor had authorized anyone to sign on his behalf

with the intent to unlawfully acquire Moore’s rights in his works and compositions.

111. If the Agreements had been tangible documents and Gyamfi and/or

another Maverick City Music representative had signed Moore’s name as was done

on the electronic Agreements, that individual would have committed the crime of

forgery in the first degree pursuant to Ga. Code Ann. §§ 16-9-1(b) and 93(d).

112. Gyamfi signed on behalf of Maverick City Music and reaped the

benefits of misappropriating obtaining Moore’s rights including, but not limited to,

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Moore’s exclusive rights in his copyrighted works pursuant to 17 U.S.C. § 106.

Pursuant to the Deal Memo, Gyamfi and Maverick City Music continue to retain

certain rights in Moore’s works and exploitation proceeds therefrom predating the

Deal Memo because, in line with Gyamfi’s wrongful and unconscionable business

practices, the Deal Memo reinforces the terms of the Publishing Agreement with

respect to compositions written prior to the execution of the Deal Memo.

113. Gyamfi and Maverick City Music’s conduct as described in this

Complaint constitutes computer forgery as defined in Ga. Code Ann. § 16-9-93(d).

114. Gyamfi and Maverick City Music’s conduct has caused significant

harm to Moore, and Moore is, therefore, entitled to compensatory and punitive

damages in an amount to be determined at trial.

115. Moore is also entitled to a declaratory judgment that the Publishing

Agreement was fraudulently obtained and is, therefore, void.

COUNT V: IDENTITY FRAUD AGAINST DEFENDANTS

116. Plaintiffs incorporate the numbered paragraphs above as if fully set

forth herein.

117. Pursuant to Ga. Code Ann. § 16-9-121(a)(5) a person commits identity

fraud when that person willfully and fraudulently, “[w]ithout authorization or

consent, creates, uses, or possesses with intent to fraudulently use any counterfeit or

fictitious identifying information concerning a real person with intent to use such

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counterfeit or fictitious identification information for the purpose of committing or

facilitating the commission of a crime or fraud on another person[.]”

118. “Digital or electronic signatures” constitute “identifying information”

under Ga. Code Ann. § 16-9-120(5)(J).

119. The signature affixed to the Publishing Agreement by Gyamfi or at his

direction on behalf of Moore was not provided by Moore, nor is it his actual

signature. The signature was, therefore, a fictitiously created signature used with the

intent to falsely express Moore’s assent to the Publishing Agreement and thereby

fraudulently convey his rights and interests in his works and compositions to

Maverick City Music.

120. Further, the fictitious signatures on the Assignment, Notice of Transfer,

Notice of Assignment, and CCLI Notice were used with the intent to falsely express

Moore’s intent to divert and direct all of Moore’s proceeds and accountings to

Maverick City Music. Through these fictitious signatures, Gyamfi and Maverick

City Music intended to defraud not only Moore, but also public performance rights

societies and publishing entities including without limitation, the Orchard.

121. Gyamfi and Maverick City Music’s fraudulent conduct has resulted in

significant harm to Moore entitling Moore to an amount to be determined at trial.

Because Defendants acted intentionally and willfully to defraud Moore, Moore is

entitled to statutory, compensatory, and punitive damages, and his fees and expenses

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incurred in connection with this action, pursuant to Ga. Code Ann. § 16-9-130.

Further, Moore is entitled to a declaratory judgment that the signatures on the

Publishing Agreement, Assignment, Notice of Transfer, Notice of Assignment, and

CCLI Notice were fictitiously created to defraud Moore and that the aforementioned

agreements are, therefore, void.

COUNT VI: CONVERSION AGAINST DEFENDANTS

122. Plaintiffs incorporate by reference the allegations above as if fully set

forth herein.

123. At the time of creation, Moore retained ownership interests in his

compositions and sound recordings pursuant to 17 U.S.C. § 201.

124. Through the forged signatures and Defendants’ fraudulent and/or

unauthorized transfers and assignments of Moore’s ownership and copyright

interests via the Publishing Agreement, Assignment, Notice of Transfer, Notice of

Assignment, and CCLI Notice, the Defendants unlawfully obtained possession of

Moore’s interests in his compositions and works.

125. While Defendants had limited authority to collaborate with Moore,

Defendants acted in bad faith and exceeded their authority by misappropriating

Moore’s interests in and unlawfully directing and diverting Moore’s right to receive

proceeds, royalties, and accountings in regard to his publishing, touring, and

recording obligations.

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126. Due to Defendants’ conversion of Moore’s interests, proceeds, assets,

and personal property, Moore is entitled to damages in the amount of the value of

the converted property. Further, because the transfer of Moore’s assets was

intentional, willful, and fraudulent, it should be set aside as void, and Moore is

entitled to punitive damages against Defendants.

COUNT VII: RESCISSION AGAINST DEFENDANTS

127. Plaintiffs incorporate by reference the allegations above as if fully set

forth herein.

128. Gyamfi’s fraudulent and unconscionable business practices negatively

affected Moore’s early career and has been a defining characteristic of their business

relationship from that moment on.

129. Every agreement between Moore and Defendants is so tainted by

misappropriations, breaches of fiduciary duty, forgery, breaches of contract, fraud,

and unconscionability that they all fail of their essential purpose and should be

rescinded as if void ab initio.

130. Plaintiffs are, therefore, entitled to a declaratory judgment that all

agreements between Moore and Defendants are void ab initio, voidable, and/or

otherwise subject to rescission by Plaintiffs.

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COUNT VIII: EQUITABLE ACCOUNTING AGAINST DEFENDANTS

131. Plaintiffs incorporate by reference the allegations above as if fully set

forth herein.

132. By virtue of the aforementioned conduct, Defendants have used

resources and monies belonging to Plaintiffs for the benefit of themselves in a

manner that damages Plaintiffs.

133. The balance due from Defendants to Plaintiffs resulting from

Defendants’ breach of their fiduciary and contractual duties can only be ascertained

by an accounting.

134. Defendants have not provided an accurate accounting.

JURY DEMAND

135. Plaintiffs demand a trial by jury.

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs respectfully request that the Court award the

following relief:

(A) Declaratory judgment that Defendants fraudulently obtained drafted

and executed the Publishing Agreement, Assignment, Notice of

Transfer, Notice of Assignment, CCLI Notice, and Deal Memo and that

they are, therefore, void;

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(B) Declaratory judgment that all agreements between Plaintiffs and any of

the Defendants are rescinded and, hereby, void ab initio;

(C) Compensatory damages in an amount to be determined at trial;

(D) Punitive damages in an amount to be determined at trial;

(E) Disgorgement in an amount to be determined at trial;

(F) An equitable accounting of the profits owed to Plaintiffs by Defendants

as a result of Defendants’ conduct described in this Complaint;

(G) Prejudgment interest and post-judgment interest;

(H) Attorneys’ fees, costs, and expenses incurred herein pursuant to the

Attorneys’ Fees provisions of the Deal Memo and Ownership

Agreement and Ga. Code Ann. § 16-9-130; and

(I) Such other and further relief as this Court deems just, proper, and

equitable.

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Respectfully submitted,

BRADLEY ARANT BOULT CUMMINGS, LLP

/s/ Anne H. Baroody

Anne H. Baroody
Georgia Bar No. 475569
Promenade Tower
1230 Peachtree Street NE, 21st Floor
Atlanta, Georgia 30309
Tel: 404-868-2100
Fax: 404-522-8409
abaroody@bradley.com

Samuel D. Lipshie*
Charles E. Elder*
Dawn M. Jackson*
1221 Broadway, Suite 2400
Nashville, TN 37203
Tel: 615-244-2582
Fax: 615-252-6380
slipshie@bradley.com
celder@bradley.com
djackson@bradley.com
*pro hac vice forthcoming

Counsel for Plaintiffs Chandler Moore and

MoWorks, LLC

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