Another excerpt from the suit:
28. In May 2015, Jerry Grisaffi met Joe Radcliffe and developed a business
relationship with him that encompassed Rocky Mountain High Brands, Inc. which was then operating under the name of Totally Hemp Crazy, Inc. Over a period of time, Radcliffe and his associates (the Radcliffe Group) negotiated a distribution contract under Epic One Group. Radcliffe was also involved in fund raising activities for Rocky Mountain. Throughout the
course of the dealings with Grisaffi and the Radcliffe Group, Grisaffi caused to be issued 113,688,625 purported shares of Rocky Mountain common stock to individual members and entities controlled by the Radcliffe Group (J. Radcliffe, K. Radcliffe, D. Radcliffe, P. Uhrik, Crackerjack, and Universal Consulting, LLC.) The consideration received by Rocky Mountain
for those common shares was $201,500.00, or an average of $.0018 per share. Over the same time period, at the time of the issuances, the market value of the total stock issued was over $4.5 million. Such purported issuances, and upon information and belief, and sales violated Grisaffi’s
fiduciary duties to Rocky Mountain. Rocky Mountain believes that the issuance of these shares was part of a scheme to ultimately insinuate the Radcliffe Group into a control position of Rocky Mountain and to assist Grisaffi in maximizing the sale price of his Preferred A Shares to Lily
Li/LSW Holdings, to the detriment of Rocky Mountain.