Consumer Fraud Complaint
NATURE OF COMPLAINT
This complaint is filed against Gravel Monkey / Groundworks Supply LLC and related entities for consumer fraud, deceptive business practices, and failure to deliver goods or provide refunds after accepting payment.
RESPONDENT INFORMATION
- Primary Business: Gravel Monkey / Groundworks Supply LLC
- Website: gravelmonkey.com
- Related Entities: Persona AI, Distributed, Inc., Clyr Inc
- Principals: Omer Menashe, Eran Artzi
- States of Incorporation: Wyoming, Colorado, Delaware, New York
FACTUAL ALLEGATIONS
The complainant placed order(s) for construction materials through the Gravel Monkey website. Full payment was made at the time of order. Despite promises of delivery, the products were never received. Multiple attempts to contact the business for status updates or refunds were unsuccessful or met with evasive responses.
PATTERN OF CONDUCT
Investigation reveals this is not an isolated incident. The business operates through a complex shell company structure spanning multiple states, making accountability difficult. The pattern includes:
- Professional-appearing website soliciting orders
- Acceptance of full payment upfront
- Repeated delays and excuses
- Eventual communication breakdown
- Failure to deliver products or provide refunds
VIOLATIONS ALLEGED
- Arizona Consumer Fraud Act (A.R.S. § 44-1521 et seq.)
- Deceptive trade practices
- False advertising
- Failure to deliver goods as promised
- Unjust enrichment
RELIEF REQUESTED
The complainant requests that the Arizona Attorney General investigate this matter, take enforcement action against the respondents, and seek restitution for all affected Arizona consumers.
SUPPORTING DOCUMENTATION
- Order confirmations and receipts
- Payment records
- Email correspondence
- Corporate registration documents
- Evidence of shell company structure