Plaintiff Alleges Fraudulent Transfer Against Former Business Partner

Honorable Timothy C. Batten, Sr., Chief United States District Judge
Honorable Timothy C. Batten, Sr., Chief United States District Judge - law.uga.edu
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R.R. Donnelley & Sons Company has taken legal action against P23 Labs, LLC and its insiders, George Montgomery Jr. and Tiffany Montgomery, alleging fraudulent transfer of property to avoid a debt. The complaint was filed on February 6, 2026, in the United States District Court for the Northern District of Georgia against P23 Labs, LLC. R.R. Donnelley & Sons Company is seeking to recover $768,284.36 awarded in a previous judgment and claims that P23 Labs transferred real estate to the Montgomerys for a nominal fee to evade this obligation.

The lawsuit details how P23 Labs, through Tiffany Montgomery as CEO, executed a quitclaim deed transferring valuable real estate in Coweta County, Georgia to herself and George Montgomery Jr., for just one dollar without paying any real estate transfer tax. This transaction occurred after R.R. Donnelley had already initiated legal proceedings against P23 Labs for unpaid debts related to goods supplied by them. The plaintiff argues that this transfer was made with the intent to defraud creditors like themselves by removing assets from the company’s ownership that could have been used to satisfy their claim.

According to R.R. Donnelley & Sons Company, the transfer exhibits several “badges of fraud,” including the involvement of insiders (the Montgomerys), lack of reasonable consideration (only $1 paid), absence of formalities such as paying transfer taxes, and the fact that litigation was ongoing at the time of transfer. They further allege that P23 Labs failed to maintain corporate separateness from its members by commingling assets and not observing corporate formalities—actions which effectively make it an alter ego of the Montgomerys.

In their prayer for relief, R.R. Donnelley seeks multiple remedies: nullification of the quitclaim deed; injunctive relief preventing further disposal or encumbrance of the property; appointment of a receiver over both P23 Labs and the property; recovery of either the property itself or its value; piercing of P23 Labs’ corporate veil so that George and Tiffany Montgomery are held personally liable for the full judgment amount plus interest; and reimbursement for legal costs incurred.

Representing R.R. Donnelley & Sons Company is attorney Thomas R. Walker from Pierson Ferdinand LLP based in Atlanta, Georgia. The case is being overseen by Judge Amy Totenberg under Case ID 1:26-cv-00711-AT.

Source: 126cv00711_RR_Donnelley_v_P23_Labs_Complaint_Northern_District_of_Georgia.pdf


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