EXCLUSIVE: I have just received the copy of a 48-page complaint filed today in the Los Angeles Superior Court on behalf of plaintiffs Aramid Entertainment Fund Limited and Aramid Grantor Trust against Relativity Media LLC, Fortress Investment Group, and others. The lawsuit allegations include fraud and breach of contract, etc. It was filed by the Century City firm of Jeffer Mangels Butler & Mitchell LLP. For the complete lawsuit, click here. But the provocative summary of the complaint reads:

In the lawsuit, Aramid Entertainment Fund claims that LA-based Relativity Media and NYC-based Fortress Investment Group conspired with a “break-in and switcheroo” to successfully cheat the hedge fund out of investments in the $525 million “Beverly Blvd” film slate co-financing fund with Sony.

Interestingly, despite all the crime novel jargon about “one of the greatest heist stories ever” and being “ruthlessly plundered,” Aramid does not actually name Sony, Citibank, or Ryan Kavanaugh as defendants. But Kavanaugh does have a spotlight shone on his business practices. Claiming that “slate deals within Relativity roll up to him,” Aramid says, “Relativity has struggled to retain other top executives over the years as a result of Kavanaugh’s need for absolute control, his inability to sustain sources of funding (and operational liquidity), and his unsuccessful attempts at transforming Relativity into something legitimately competitive with major studios.”

Kavanaugh’s ability to even meet payroll “for over 200 employees” is questioned in the suit, with a January 19th, 2012, Deadline story quoted. The suit also alleges that taking a loan of $200 million from the Ron Burkle-backed Colbeck Capitol in the fall of 2011 — a loan that was later converted into equity — “only worsened Relativity’s financial distress since by fall 2011, any incoming moneys were fully pledged to Relativity’s creditors” and banks “refused to extend any further credit”.

From Relativity’s early days, the suit alleges, Kavanaugh took big credits for very little work. “Plaintiffs further allege, on information and belief, that Relativity’s CEO Ryan Kavanaugh negotiated a ‘producing’ credit for himself on films financed in whole or in part through Relativity’s slate deals,” says the suit. “Plaintiffs are informed and believe that Kavanaugh wanted people to believe that he really was ‘the producer’ of such films in spite of the fact that he never provided any actual producing services.”

The terms of the co-financing slate allowed Kavanaugh “to benefit more than anyone else from the Beverly slate transaction,” the suit says, citing the Relativity CEO’s majority ownership of his own company. “Regardless of whether Kavanaugh or anyone else from Relativity ever read a script, visited a set, or rendered any producing services,” it continues, “these ‘producing’ fees and ‘gross participations’ were to be paid to Relativity’s subsidiaries. That meant as much as $45 million in producing fees alone over five years. If the slate generated an additional $3 billion in receipts, which was entirely possible… that would have meant an additional $60 million paid to Kavanaugh and Relativity – or over $100 million in fixed fees and contingent gross participation.”

Detailing Kavanaugh’s attempts in more recent years “to morph into a ‘real’ producer,” the suit alleges that Relativity borrowed against those “receivables” to buy Citibank generated Class C equity in Beverly Blvd and “finance the operations of Relativity.” Finances that were never doing very well, the suit alleges. Aramid states in the suit “that while Relativity had publicly portrayed its slate deals as success… with one exception, its previous deals had performed so poorly that equity investors in each deal lost substantially their entire investment.”

In 2008, after repeated approaches by Citibank, Aramid invested $22 million in the fund, which was to be matched by another $500 million from Sony. That investment later grew to be worth over $44 million, says Aramid, in what it thought to be a fund intended to cover as many as 45 films over a 5-year period. The filing alleges an alliance between Relativity and Fortress to leave Aramid’s investment decimated and themselves enriched. The suit claims “the effect of these acts was to reduce the value of Aramid’s investment from approximately $44 million to zero.” Aramid claims Fortress, who as a potential investor had once taken a very close and confidential NDA-governed look at the former’s books back in 2010, paid a cash strapped Relativity $14.5 million in late 2011 to get it to approve the money management firm’s 50 cents on the dollar buyout of Citibank’s then $226.7 million position in Beverly Blvd. The suit claims Fortress walked away with at least in the end, after paying off Relativity and capping the slate deal with Sony, with at least $96.1 million in gross profit. Citibank first became involved in 2007 after Relativity, who would not gain hedge fund Elliot Management as its primary backer for another year and therefore “did not have $555 million with which to capitalize” for the fund itself, solicited the bank to raise the money through investors or “put up at least $525 million” to guarantee Sony would enter into the deal.

Aramid is run by financier David Molner who is no stranger to lawsuits himself. He is repped by Stanley Gibson of Jeffer Mangels Butler & Mitchell in this suit seeking restitution and $44 million in damages for a litany of offenses by Relativity and its alleged subsidiaries and Fortress.

Editor-in-Chief Nikki Finke - tip her here.