21 July 2026

 Not legal advice,  see Caveats & Limitations.

Summary

On 20 July 2026, John C. Textor filed a Verified Complaint against Yongmee Michele Kang, and Kang alone, in the Circuit Court for the Fifteenth Judicial Circuit, Palm Beach County, Florida. 

The complaint pleads seven counts: 

• defamation/defamation per se, 
• fraud in the inducement, 
• fraudulent concealment, 
• tortious interference with existing contractual/business relationships, 
• constructive fraud, 
• civil conspiracy, and (in the alternative) unjust enrichment. 

Damages are pleaded as “believed to be in well excess of $400,000,000”, with punitive damages demanded on every substantive count and a jury trial demanded on all triable issues. John Textor has verified the factual allegations under penalty of perjury.

The complaint is the civil-court expression of the narrative Textor has been building since January 2026: that Kang, acting with Ares, Christopher Mallon and the Series C investors (James Dinan and Alex Knaster are named as controlling parties), procured his resignation from Olympique Lyonnais and Eagle Football Group in June 2025 through false assurances of support for the multi-club model, having already pre-negotiated a Term Sheet with Ares that was signed on the day of his resignation and a “Secret Side Agreement” executed on 7 July 2025, and then used a shadow executive committee, manufactured defaults, and Eagle Bidco’s UK administration to acquire OL for herself on 26 June 2026, cancelling more than $230m of intra-group liabilities and leaving Textor exposed on personal guarantees.

Sections 2–5 summarise what the complaint itself alleges. Sections 6–8 are my assessment. The distinction is flagged throughout: everything in Sections 2–5 is Textor’s sworn account, untested and one-sided; nothing in it has been admitted by Kang, Ares, the administrators, or any regulator.

Filing at a glance

Two immediate observations. First, because both parties are Florida-domiciled, there is no diversity basis for removal to federal court: this case stays in Palm Beach state court, before a jury pool in the county where both litigants live. Textor has chosen his home forum and pleaded venue aggressively (residence of Kang, and of Dinan and Knaster as material witnesses). 

Second, suing Kang alone, while pleading Ares, Mallon and the Series C investors into every layer of the alleged conspiracy, is a deliberate structural choice. It avoids the jurisdictional and arbitration-clause fights that corporate defendants and the financing documents would bring, keeps the case against a Palm Beach resident in Palm Beach, and preserves the ability to add defendants later. It also means the conspiracy count does heavy lifting: Kang is being asked to answer for the conduct of an entire syndicate.

The Case as pleaded (Textor’s sworn account)

Everything in this section is allegation, not established fact. The chronology below is the complaint’s own, cross-checked against the document for dates and figures.

Structure and stakes

Eagle Football Holdings Ltd (EFH), majority-owned (c.60%) by Textor, sits above Midco, which owns Eagle Bidco, which controls Eagle Football Group SA (EFG), the Euronext-listed entity holding OL,  plus Botafogo and RWDM Brussels. 

Kang, through YMK Holdings, initially acquired 6% of EFH for $25m (elsewhere in the complaint stated as 5%, an internal inconsistency). The goal was to roll up the multi-club model and take it public in the US; EFH filed an S-1 with a leading investment bank on 13 June 2025. 

Textor pleads that he invested more than $275m into the structure and approximately €60m of new capital into OL in the twelve months before the DNCG ruling.

The DNCG crisis and resignation (May–July 2025)

The complaint characterises the DNCG as captured by hostile league presidents and nostalgic for Aulas. 

After a “pleasantly surprised” preliminary hearing on 20 May 2025, the DNCG on 24 June 2025 announced administrative relegation despite an improved package (a further €25m injection, a €35m player sale, the €69.7m “Hutton Investment”, a €25m Ares commitment letter, and Crystal Palace sale proceeds in reserve). 

Critically, the complaint alleges that just before the hearing Kang withdrew her “friendly” €30m equity commitment and substituted a punishing unconditional loan, €600,000 upfront fee, 20% interest rising to 30% within a year, plus demanded control of transfer decisions. Textor was then told the DNCG would look favourably on OL if he resigned. 

Relying on Kang’s repeated assurances, to him and, decisively, to a “key man” lender whose loan would otherwise have defaulted, that she supported him and the multi-club model, Textor resigned on 29 June 2025 and appointed Kang President of OL SASU and of EFG. 

Relegation was reversed on appeal within 16 days, on a package the complaint says was “dramatically similar” to what the DNCG had just rejected from Textor.

The term sheet, secret side agreement, and the shadow board

Within hours of her elevation on 29 June 2025, Kang allegedly signed a pre-negotiated Term Sheet with Ares. 

At the 3 July 2025 EFH board meeting she presented the full suite of transaction documents, the complaint quotes the minutes at length, without mentioning the Term Sheet; 

Ares-connected directors gave proxies and left; the financing was approved. 

On 7 July 2025 Kang, Ares and Mallon (purportedly for Bidco, without board authorisation) executed the secret side agreement: a shadow five-person executive committee dominated by Ares-note investors; Ares veto rights over transfers, debt, equity, and any payment or engagement with Textor; a lock-up on EFG shares; entrenchment of Kang until 30 June 2027; and recovery rights on her DNCG guarantee. 

The approved DNCG package itself is described as “a trojan horse”, $102.4m of financing to Bidco including Kang’s $35.3m personal loan at an effective 30% and a €30m YMK bank counter-guarantee, positioned so that a short-dated default would deliver EFG shares to Kang and the Series C investors. The shadow committee allegedly met approximately 30 times between July and December 2025 while the real EFG board met twice.

Implementation: starvation, defaults, discovery (July 2025 – January 2026)

Textor pleads he was cut off from all information from the day of his resignation; that Kang caused OL to retain a €24m pledged Santander balance reserved for a $25m Ares payment, generating the first default; that an €80m replacement financing he sourced was refused engagement; that OL refused to pay Botafogo, RWDM, MCCP (c.€44m factoring exposure on the Igor Jesus transaction, on which Textor and Botafogo are guarantors) and his own $2.7m of management fees; and that OL staff told MCCP the underlying transaction was “fraudulent”, contradicted, he says, by the Gerlinger memorandum at Exhibit A (“I wrote the memo”) confirming the pathway transfers were FIFA-compliant and cash-generative. The 2024/25 accounts, approved 28 November 2025 over his objections and, he alleges, before any final auditor analysis, were “manipulated” and later used to place Bidco in administration. The Side Agreement’s existence leaked via an Ares disclosure to a prospective debt buyer (under an NDA that expressly barred sharing it with Textor) and a whistleblower; Textor received the document itself from Ares on 25 January 2026, one day before learning Bidco’s voting card for the EFG general assembly had already been mailed, entrenching the Kang slate.

Regulatory escalation and endgame (January – June 2026)

Textor notified the AMF on 28 January 2026, alleging breach of the EU Market Abuse Regulation and French disclosure law. EFG’s 10 March 2026 press release, which the complaint says was forced by the AMF but drafted to look like a response to Textor, confirmed the letter agreement exists and “applies as long as Ms. Michele Kang holds her position as CEO of EFG”, while asserting EFG is not a party and describing the committee as merely consultative and “suspended since mid-December”. 

Bidco entered UK administration on 27 March 2026; the administrators (Cork Gully) allegedly ignored Textor and ran a sale process in which he and his introduced parties were denied current financials. 

EFG’s 14 April 2026 release confirmed confidentiality undertakings with “a consortium comprising funds managed by Ares Capital and an affiliate of Michele Kang”, both sides of the transaction. Textor filed his French criminal complaint on 17 April 2026 (private corruption, abuse of corporate power, presentation of inaccurate accounts, dissemination of false or misleading information). 

Macquarie accelerated its €27.2m Botafogo facility on 16 March 2026 and sued Textor on his personal guaranty in New York on c.20 April 2026 (Index No. 652320/2026); he has also been sued on the Palm Beach Gardens office lease guaranty after EFG defaulted. 

EFG’s 12 May 2026 release announced “undisclosed” guarantees signed by Textor; its 8 June 2026 release announced an internal investigation and a Lyon criminal complaint “against X” citing “deliberate disorganization”, “systematic opacity” and “hundreds of millions of euros in financial flows seemingly executed without economic justification” during his tenure. 

On 26 June 2026 Kang and the Series C investors took OL, with more than $230m of liabilities owed by OL to other network clubs cancelled through the administration.

The seven counts (as pleaded)

Count I (defamation/defamation per se) rests on four publication clusters: the 5 August 2025 Mallon letter to Botafogo alleging financial irregularities; statements by Moyal and Gerlinger to the head of MCCP that the Igor Jesus transaction was fraudulent; the 12 May 2026 EFG press release attributing undisclosed guarantees to Textor by name; and the 8 June 2026 “against X” criminal-complaint announcement. Per se treatment is claimed because the statements impute crimes and professional unfitness, with the Washington Spirit invoked as a prior pattern. 

Count II (fraud in the inducement) is the resignation itself: Kang’s assurances of support for Textor and the multi-club model, made while the Term Sheet was already negotiated, induced him to resign and appoint her. 

Count III (fraudulent concealment) is the non-disclosure of the Term Sheet and Side Agreement at the 3 July 2025 board meeting and thereafter. 

Count IV (tortious interference) is Kang causing OL to dishonour the MCCP, Macquarie and office-lease obligations knowing Textor was personally exposed as guarantor. 

Count V (constructive fraud) pleads a confidential and fiduciary relationship “as friends, as shareholders, directors… lenders and… creditors” that Kang abused. 

Count VI (civil conspiracy) sweeps Ares and Mallon into an agreement to entrench Kang, strip governance, make her a secured creditor and engineer the transfer. 

Count VII (unjust enrichment, in the alternative) claims Textor personally conferred the offices, control, goodwill and guarantee support that Kang retained.

What acts in the complaint’s favour? 

Assessment from here on. Four features distinguish this pleading from a bare grievance narrative.

The documentary spine is real and partly public. The side letter’s existence is confirmed by EFG’s own 10 March 2026 release; the 14 April 2026 release confirms the Ares/Kang consortium was inside the sale process while Kang chaired the target; the administration, the AMF correspondence, the general-assembly vote and the press releases are all verifiable. 

The complaint quotes EFH board minutes of 3 July 2025 verbatim, Textor plainly holds the underlying documents. If discovery reaches the shadow committee’s c.30 meetings’ worth of papers and the Term Sheet’s negotiation history, the timeline question, what was agreed before 29 June 2025, becomes answerable with documents rather than recollection.

The same-day timing is key If Textor proves the Term Sheet was substantively negotiated before his resignation while Kang was assuring him and a key-man lender of her support, the fraud counts acquire a potential, dated misrepresentation with a demonstrable undisclosed intent, the hardest element to plead in inducement cases, here handed to him by the calendar. The 10 March 2026 release’s claim that the committee “has never been consulted on or approved any operation” is also a hostage to fortune: if minutes show c.30 working meetings, the release itself becomes evidence of a disposition to conceal.

Verification raises the stakes symmetrically. A verified complaint converts the pleading into sworn testimony. That is leverage, and risk: any allegation shown to be knowingly false is now perjury exposure, and the complaint’s internal inconsistencies (5% vs 6% YMK stake; a sentence in ¶71(e) that breaks off mid-clause; “putative” for “punitive”; currency mixing) suggest drafting haste that a competent defence will exploit against the verifier, not the drafter.

Forum selection is rational. Kang is a Palm Beach resident, so personal jurisdiction is unassailable, removal is unavailable, and Florida’s forum non conveniens doctrine is harder to invoke against a plaintiff suing a resident defendant at home. A Palm Beach jury hearing a story about a $25m minority investor who ended up owning the crown-jewel asset while the 60% founder was wiped out is not a comfortable audience for the defence, whatever the law says.

Structural weaknesses (my assessment)

Count-specific vulnerabilities

Defamation (Count I) is the weakest of the front-line counts despite being pleaded first. Three of the four publication clusters are statements by corporate organs, EFG press releases, an OL/Bidco letter, statements by OL executives Moyal and Gerlinger, not by Kang personally; Florida requires the defendant to have made or directed the publication, and “at Kang’s direction” will need proof, not assertion. 

The Lyon criminal complaint attracts privilege protections for statements to prosecuting authorities; the “against X” formulation creates an of-and-concerning identification fight; the Botafogo letter, sent creditor-to-creditor, invites qualified privilege; and most publications occurred in France, raising choice-of-law questions Florida courts resolve by the place of injury. 

Above all, truth is a complete defence, and the truth or falsity of “financial irregularities” at OL is precisely what the French criminal process, the administrators and the auditors are contesting, a Florida jury would be asked to adjudicate the entire Franco-English accounting war as a predicate. Kang may also test Florida’s anti-SLAPP statute against a count built on statements about a matter of public concern.

Fraud in the inducement (Count II) is likely the strongest count, the injury (surrendering his own offices and appointment rights) is personal, the misrepresentation is dated, and undisclosed present intent is corroborated by the same-day Term Sheet. Its vulnerabilities are causation and reliance: the DNCG had effectively demanded Textor’s exit as the price of avoiding relegation, so Kang will argue he resigned under regulatory compulsion, not her assurances, and that a sophisticated party facing that squeeze cannot claim justifiable reliance on soft assurances of loyalty. 

Promissory statements about future support are actionable in Florida only where made with no intention to perform, pleaded here, but a jury question at best. Damages for this count alone (the value of the surrendered offices, as distinct from the derivative stake loss) are also much smaller than $400m.

Fraudulent concealment (Count III) rises or falls on duty. Absent a fiduciary or confidential relationship, arm’s-length counterparties owe no general duty of candour. Kang’s formal duties as an EFH/EFG director ran to those companies under English and French law, not to Textor personally, and the “friends and confidants” theory (Count V’s foundation too) asks a Florida court to construct an informal confidential relationship between two sophisticated, lawyered co-investors. Florida recognises such relationships, but sparingly, and almost never between business rivals of equal sophistication.

Tortious interference (Count IV) collides with the officer privilege. A corporate officer acting within her capacity is privileged against interference claims regarding the company’s own contracts unless she acted with pure malice or solely for her own benefit. 

The alleged interference is Kang causing OL not to pay OL’s debts, quintessentially a corporate decision, taken amid genuine distress and, latterly, administrator oversight, and the side letter itself gave Ares the veto over payments to Textor. The count’s real force is as a damages conduit for the guarantee exposure, which is Textor’s most concrete direct injury.

Constructive fraud, conspiracy and unjust enrichment (Counts V–VII) are derivative in both senses. Count V depends on the confidential-relationship theory above. Count VI needs an underlying tort to survive and imports proof burdens about Ares, Dinan, Knaster and Mallon, none of whom is before the court to be examined as a party. Count VII’s theory that resigning offices and lending goodwill “conferred a benefit” that equity should reprice is creative but has no obvious measure and sits awkwardly beside seven counts pleading adequate legal remedies.

Forum, comity and the collateral-attack problem

The economic heart of the complaint, that the administration was engineered, the sale process rigged, and the intra-group debts wrongly cancelled, is an attack on a UK insolvency process conducted by officers of the English court, on French listed-company governance now before the AMF and the Lyon and Paris prosecutors, and on financing documents almost certainly governed by English law with exclusive jurisdiction or arbitration clauses. 

A Florida state court will be pressed hard, on comity and forum grounds, not to re-try Cork Gully’s administration or the DNCG’s decisions; challenges to administrators’ conduct belong in the English court under the Insolvency Act. 

Textor’s own recent record sharpens the point: his parallel Florida federal action against Iconic was dismissed on jurisdictional grounds in October 2025 and the English Court of Appeal rejected his appeal in full in March 2026 ([2026] EWCA Civ 355). Suing only the Palm Beach resident is precisely designed to survive that history, and it may, but the court can still stay or trim the case to its genuinely Florida-triable core.

Procedural exposure on punitive damages and pleading standards

Florida is a fact-pleading jurisdiction with a particularity rule for fraud, and, more immediately,  section 768.72 of the Florida Statutes bars pleading punitive damages without first obtaining leave on a proffered evidentiary basis. The complaint demands punitive damages in every count without that gate having been passed; expect an early motion to strike, which the defence will use to force an evidentiary showing and to slow the case. Expect also a comprehensive motion to dismiss raising derivative standing, privilege, duty and forum, with realistic prospects of eliminating Counts I, V and VII at or shortly after the pleading stage.

Count-by-count likelihood (my opinion alone)

This is at least the fifth front Textor has opened: the English administration challenge and AMF referral; the dismissed Iconic litigation; the Rio proceedings around Botafogo; the April 2026 PNF criminal complaint; and now Palm Beach. 

The pattern is consistent, multiply forums, keep the narrative alive, and force adversaries to defend everywhere at once. 

The complaint’s own admissions cut both ways for that strategy: it concedes Textor is a “known disruptor” in French football governance, confirms he is being sued in New York on the Macquarie guaranty and in Florida on the lease guaranty, and attaches a French criminal complaint whose redactions will invite requests for the unredacted text.

For Kang, the danger is not the verdict but the process. Discovery requests will target the Term Sheet drafts and negotiation emails (June 2025), the c.30 shadow-committee meeting records, the Ares NDA barring disclosure to Textor, the Clifford Chance conflict question, and the drafting file behind the 10 March 2026 press release. Each of those is more dangerous in the French criminal and AMF contexts than in Florida. Her rational play is a maximal motion to dismiss on standing, privilege and forum grounds, a section 768.72 strike of the punitive claims, and, if the fraud counts survive, an early, quiet resolution.

Watch items over the next 60–90 days: (i) service and Kang’s response deadline, and whether she moves to dismiss on derivative-standing grounds first; (ii) any motion to stay pending the English administration and French proceedings; (iii) whether Textor amends to add Ares, Mallon or YMK once the pleading survives (or to cure defects); (iv) the AMF’s next step on the March disclosure, which would materially strengthen or weaken Count I’s falsity narrative; (v) the New York summary-judgment motion on the Macquarie guaranty, which quantifies the most concrete direct damages in this case; and (vi) any DNCG or Ligue 1 reaction to the sworn allegation that the regulator was steered against a sitting owner — a governance story in its own right.

Caveats & limitations

This assessment is based solely on the filed Verified Complaint (a “NOT A CERTIFIED COPY” docket copy, with Exhibit B heavily redacted), publicly reported context, and my accumulated research on the Eagle Football structure. 

No answer, defence, or responsive filing from Kang exists yet; every factual assertion assessed here is untested and drawn from one side’s sworn pleading. I am not a lawyer and this is not legal advice; likelihood bands are analytical judgments about litigation dynamics, not counsel’s opinion on Florida law. 

Specific limitations: the complaint’s internal inconsistencies (the 5%/6% YMK stake, the truncated ¶71(e), currency mixing between $ and €) mean some figures cannot be fully reconciled from the document itself; the governing-law and dispute-resolution clauses of the Notes Purchase Documents, the shareholders’ agreement and the Side Agreement are not before me and could materially change the forum analysis; the status of service on Kang is unconfirmed as at 21 July 2026; and the parallel French criminal process, the AMF inquiry and the English administration could each produce findings that override any assessment made from the civil pleadings alone. Figures cited are as pleaded and have not been independently verified.