A secured lender alleges that its efforts to recover millions in unpaid loans were deliberately delayed by a representative who participated in a scheme to divert business assets and funds beyond the lender’s reach. According to an amended complaint filed on March 6, 2026, in the United States District Court for the Southern District of New York, LER Management LLC accuses Daniel Huff of knowingly assisting others in moving company operations and proceeds away from their rightful creditor.
The complaint was filed by LER Management LLC against Daniel Huff. It outlines how LER Management provided $1.5 million in loans to 21st Century AEYE LLC through two promissory notes dated September 10 and September 16, 2024. These loans were secured by agreements granting LER Management a first-priority security interest under Article 9 of the Uniform Commercial Code in nearly all assets of 21st Century AEYE LLC, including those acquired from Financial Technology Solutions International, Inc., also known as Original FTSI.
LER Management reports that after the loans matured in September 2025 with principal and interest still unpaid, individuals associated with 21st Century—including Brannon Castleberry, Lisa Huertas, and John De La Peña—began transferring assets to entities with similar names such as “FTSI Corp.” The complaint alleges that Daniel Huff knowingly joined this effort by making misleading statements about the company’s finances during a July 10, 2025 meeting in Palm Beach County, Florida. During this meeting, Huff allegedly told LER Management that “we can pay any unhappy noteholder,” “cash is available now,” “the business is healthy,” “the pipeline is strong,” and “repayment can be made upon demand.” The plaintiff asserts these statements were false at the time they were made.
According to the filing, Huff also negotiated extensions and forbearance agreements with LER Management’s New York counsel through emails, texts, phone calls, and proposed video meetings directed into New York. The plaintiff claims these communications were intended to induce it to delay enforcement actions on its loans while insiders continued diverting company assets. As stated in the complaint: “Plaintiff did, in fact, forbear and postpone enforcement steps it otherwise would have taken earlier.”
The document further describes an attempted unauthorized transfer of approximately $130,000 from 21st Century’s bank account to Huff on or about August 6, 2025. Although this transfer was ultimately prevented by Dr. Said El-Bilani—the lawful manager of 21st Century—the plaintiff alleges that Huff stood ready to receive these funds despite knowing they constituted part of the collateral securing LER Management’s loans.
LER Management contends that as a result of these actions it suffered damages including unpaid principal and interest on its notes, impairment of collateral value, loss of potential equity upside valued at over $10 million according to investor valuations cited in the complaint, investigation costs, and other consequential damages.
The amended complaint sets forth multiple legal claims against Huff: fraud and fraudulent inducement; aiding and abetting fraud; aiding and abetting breach of fiduciary duty; tortious interference with contract; conversion; aiding and abetting conversion; unjust enrichment (pleaded alternatively); declaratory judgment and injunctive relief; as well as accounting for all funds received by Huff from related parties since January 1, 2025.
Among other remedies sought from the court are compensatory damages exceeding $10 million (exclusive of interest), punitive damages where available by law “in an amount sufficient to punish Defendant,” restitution or disgorgement of any amounts traceable to LER Management’s collateral or loan proceeds received by Huff or related parties; declaratory relief confirming LER Management’s security interests; preliminary and permanent injunctions preventing further transfers or dissipation of relevant funds or assets; an accounting detailing all payments or benefits received by Huff connected to Castleberry or affiliated entities; imposition of constructive trust or equitable lien over traceable property; pre-judgment and post-judgment interest; attorneys’ fees where recoverable under applicable law; as well as any additional relief deemed just by the court.
The filing names Gary Rosen of Rosen Law LLC as attorney for LER Management LLC. The case identification number is Docket No: 26-CV-1031 (GHW).
Source: 226cv3002_LER_Management_LLC_v_Huff_Complaint_District_New_Jersey.pdf
