Plaintiff Alleges Unpaid Compensation Against Former Employer Hi Solutions

Michael K. Cohen Courthouse
Michael K. Cohen Courthouse
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Robert L. Brown has filed a lawsuit against a group of companies and individuals for alleged violations of employment agreements and wage laws. The complaint was lodged in the United States District Court for the District of New Jersey on November 17, 2025, targeting RC-1, Inc., along with its subsidiaries and key executives. Brown accuses these entities of failing to pay his salary, bonuses, vacation pay, and amounts due under a convertible note.

The plaintiff, Robert L. Brown, claims that the defendants have willfully neglected their financial obligations towards him in violation of the New Jersey Wage Payment Law (WPL) and common law. According to Brown’s allegations, he was employed as Chief Financial Officer by RC-1 on June 12, 2023, under an employment agreement promising him a base salary of $250,000 per year along with bonuses and stock options. However, between May 24 and November 4, 2024, Brown asserts that he was not paid his base salary totaling $106,730.76 nor his $75,000 bonus for the year 2023 despite meeting required targets.

Brown further alleges that upon his resignation on October 4, 2024—citing “Good Reason” due to non-payment—he was entitled to severance pay including continued salary and benefits for six months which were also not honored by the defendants. Additionally, a Note Purchase Agreement signed on June 11, 2024, where Brown loaned $50,000 to RC-1 with a maturity date of July 31, 2024, remains unpaid according to the complaint.

The complaint details how each subsidiary under RC-1 shared control over Brown’s employment terms and conditions making them joint or co-employers liable for the unpaid compensation. The defendants are accused of knowingly permitting these payment failures which constitutes willful misconduct under the WPL.

Brown is seeking relief from the court in various forms including declaratory judgment declaring that the defendants’ actions violated his rights under WPL and common law; compensatory damages for all unpaid wages; liquidated damages amounting to double the owed amounts; pre-judgment interest; attorney’s fees; costs; and any other relief deemed appropriate by the court.

Representing Robert L. Brown is Stephanie J. Mensing from Mensing Law LLC based in Philadelphia. The case has been assigned Civil Action No: 1:25-cv-17637 in front of an unnamed judge at this stage.

Source: 125cv17637_Brown_v_RC_1_Inc_Complaint_District_New_Jersey.pdf



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