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CIRCUIT COURT OF
IN THE CIRCUIT COURT OF COOK COUNTY ILLINBBIS COUNTY;, ILLINOIS
',
LAW DIVbiON
COUNTY DEPARTMENT, LAW DIVISIQN CLERK DOROTHY BROWN
DEVONA D. BENTON and FRANK JACKSON,
individually, and on behalf of their minor child, J. B.;
ROBERTS. BUFFORD, JR., Individually, and on behalf
of their minor child, C. B.; DAROLD BUTLER, SR. and
DO NITA BRUCE, individually, and on behalf of their
minor child, D.B.; VENISA BEASLEY -GREEN and
CHRISTOPHER GREEN, individually, and on behalf of
their minor child, B.G.; CARL TON A. HONDRAS, II and
SHEREE HONDRAS, individually, and on behalf of
their minor child, C.H.; JERRY F. HOUSTON and
MYRTLE HOUSTON, individually, and on behalf of
their minor child, J.H.; EDWARD HOWARD III, and
CALANDRA HOWARD, individually, and on behalf of
their minor child, E. H.; LINDA SNEED HARRIS,
individually, and on behalf of her minor child, M.J.;
NEDRA JONES and ALVIN JONES, individually, and
on behalf of their minor child, P.J.; TAMMY KING and
EDDIE KING, SR., Individually, and on behalf of their
minor child, E.K.; PRENTISS LUSTER and DARLENE
LUSTER individually, and on behalf of their minor child,
P.R.; SANJA E. NOBLE, Individually, and on behalf of
her minor child, L.N.; and CLAUDIA HARVEY,
individually, and on behalf of her minor child, D.R.;
Plaintiffs,
v.

LITTLE LEAGUE BASEBALL, IN CORPORA TED;
JACKIE ROBINSON WEST LITTLE LEAGUE, INC.,
an Illinois Not-for-Profit Corporation; BILL HALEY,
Individually, and as agent and/or employee of JACKIE
ROBINSON WEST LITTLE LEAGUE, INC.; ANNIE
HALEY, Individually, and as agent and/or employee of
JACKIE ROBINSON WEST LITTLE LEAGUE, INC.;
EVERGREEN PARK ATHLETIC ASSOCIATION, an
Illinois Not-for-Profit Corporation; CHRIS JANES,
Individually, and as agent and/or employee of
EVERGREEN PARK ATHLETIC ASSOCIATION;
ESPN, INC., a Delaware corporation; and STEPHEN A.
SMITH, Individually, and as agent of ESPN, INC.,
Defendants.

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Case No.

COMPLAINT AT LAW
NOW COME the Plaintiffs, DEVONA D. BENTON and FRANK JACKSON,
individually, and on behalf of their minor child, J. B.; ROBERTS. BUFFORD, JR., Individually,
and on behalf of their minor child, C.B.; DAROLD BUTLER, SR. and DONITA BRUCE,
individually, and on behalf of their minor child, D.B.; VENISA BEASLEY -GREEN and
CHRISTOPHER GREEN, individually, and on behalf of their minor child, B.G.; CARLTON A.
HONDRAS, II and SHEREE HONDRAS, individually, and on behalf of their minor child, C.H.;
JERRY F. HOUSTON and MYRTLE HOUSTON, individually, and on behalf of their minor
child, J.H.; EDWARD HOWARD III, and CALANDRA HOWARD, individually, and on behalf
1

of their minor child, E.H.; LINDA SNEED HARRIS, individually, and on behalf of her minor

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1 child, M.J.; NEDRA JONES and ALVIN JONES, individually, and on behalf of their minor

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~ :~~ 'o :. child, P.J.; TAMMY KING and EDDIE KING, SR., Individually, and on behalf of their minor
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child, E.K.; PRENTISS LUSTER and DARLENE LUSTER individually, and on behalf of their

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minor child, P.R.; SANJA E. NOBLE, Individually, and on behalf of her minor child, L.N.; and
CLAUDIA HARVEY, individually, and on behalf of her minor child, D.R.; (hereinafter
; collectively referred to as the "JRW Parents"); by and through their attorneys, Barney &
Karamanis, LLP, and complaining of Defendants, LITTLE LEAGUE BASEBALL,
INCORPORATED (hereinafter referred to as "LITTLE LEAGUE"); JACKIE ROBINSON
WEST LITTLE LEAGUE, INC. (hereinafter referred to as "JRWLL"); BILL HALEY,
Individually, and as agent and/or employee of JRWLL; ANNIE HALEY, Individually, and as
agent and/or employee of JRWLL; EVERGREEN PARK ATHLETIC ASSOCIATION
(hereinafter referred to as "EP AA''); CHRIS JANES, Individually, and as agent and/or

2

employee ofEPAA; ESPN, INC.; and STEPHEN A. SMITH, Individually, and as agent and/or
employee ofESPN, INC.; state as follows:
PARTIES
1.

At all times relevant hereto, Plaintiffs, the JRW Parents, acting on behalf of

themselves and their minor children.
2.

At all times relevant hereto. Defendant, LITTLE LEAGUE, was a Not-for-Profit

corporation, federally-chartered under 36 U.S.C. § 13501, and headquartered in Williamsport,
Pennsy Ivania.
3.

At all times relevant hereto, Defendant, JRWLL, was an Illinois Not-for-Profit

corporation, engaged in the operation of a Little League chartered baseball league on the South
Side of Chicago, Cook County, Illinois.
4.

On information and belief. and at all times relevant hereto, Defendant, Bill Haley,

was a resident of Cook County, Illinois.
5.

At all times relevant hereto, Defendant, Bill Haley, was an agent and/or employee

of Defendant, JRWLL.
6.

At all times relevant hereto, Defendant, Bill Haley, was acting within the course

and scope of his agency and/or employment with Defendant, JRWLL.
7.

On information and belief, and at all times relevant hereto, Defendant, Annie

Haley, was a resident of Cook County, Illinois.
8.

At all times relevant hereto, Defendant, Annie Haley, was an agent and/or

employee ofDefendant, JRWLL.
9.

At all times relevant hereto, Defendant, Annie Haley, was acting within the

course and scope of her agency and/or employment with Defendant, JRWLL.

3

10.

At all times relevant hereto, Defendant, EP AA, was an Illinois Not-For-Profit

corporation organized under the laws of the State of Illinois, engaged in the operation of a Little
League chartered baseball league in Evergreen Park, Cook County, Illinois.
11.

On information and belief, and at all times relevant hereto, Defendant, Chris

Janes, was a resident of Cook County, Illinois.
12.

At all times relevant hereto, Defendant, Chris Janes, was an agent and/or

employee ofDefendant, EPAA.
13.

At all times relevant hereto, Defendant, Chris Janes, was acting within the course

and scope of his agency and/or employment with Defendant, EPAA.
14.

At all times relevant hereto, Defendant, ESPN, was a Delaware corporation, based

in Bristol, Connecticut, which owned and operated various sports broadcasting outlets, including
, cable channels, sports radio network, an accompanying website and other assets.
15.

At all times relevant hereto, Defendant, Stephen A. Smith, was an agent and/or

employee of Defendant, ESPN, INC.
16.

At all times relevant hereto, Defendant, Stephen A. Smith, was acting within the

-' course and scope of his agency and/or employment with Defendant, ESPN INC.
FACTS COMMON TO ALL COUNTS

17.

At all times relevant hereto, Defendant, Little League, organized and administered

local youth baseball and softball leagues throughout the U.S. and the rest of the world pursuant
to its official rules and regulations, with these official rules and regulations administered and
enforced by agents and/or employees in its Pennsylvania headquarters and District
Administrator's offices.

4

18.

At all times relevant hereto, Defendant, Little League, published its official rules

and regulations in a book entitled Little League® Rules and Regulations for Baseball Divisions2014 (hereinafter referred to as the "Rule Book"). A copy of the relevant provisions of said Rule
Book are attached hereto as Exhibit "A." 1
19.

At all times relevant hereto, Defendant, Little League, issued charters to local

leagues on an annual basis with the requirement that the local league "adhere scrupulously to all
rules and regulations established by Little League." Ex. A, Administration, p. 12.
20.

At all times relevant hereto, Defendant, Little League, placed the responsibility of

revtewmg, granting, suspending and/or revoking the privileges and conditions of the local
league's charter and the authority to grant any written requests of a local charter to waive a
specific rule or regulation with its Charter Committee. Ex. A, Charter Committee/Waivers of
Rules and Regulations, p. 12.
21.

In order to be eligible, under the rules of Defendant, Little League, a "player must

qualify under the Little League's definition of residence printed in Section 2 of this book, must

be the correct 'league age' for the division, and must have parental consent." Ex. A, Player
Eligibility, p. 12.
22.

According to the Rule Book, "[ e]ach local Little League determines the actual

geographic boundaries of the area from within which it shall select players" and "these
boundaries must be described in detail and shown on a map and dated when making application
for a Little League charter."

Ex. A, Residence and School Attendance Player Eligibility

Requirements, p. 16.

1

Due to its length, Plaintiffs have not attached a copy of the Rule Book in its entirety to this Complaint. However,
a complete copy of this Rule Book will be made available for inspection and/or copying upon request of any party.

5

23.

Section 2 of the Rule Book, further provides that in order to be eligible to play

with a particular league, only players who "reside or the physical location of the school where
they attend classes is within the boundaries provided to and approved by Little League Baseball,
Incorporated." I d.
24.

Section 2 then lists the supporting documents which would be acceptable to

determine the residence of a player's parent or legal guardian, which included, for example,
driver's license, utility bills and medical records.
25.

Section 2 of the Rule Book, further provides that "[i]t is recommended that the

league require some proof of residence or school attendance with the league's boundaries at the
i time the player registers." Id., p. 17.

26.

The Rule Book further provides that "[i]f a claim for residency or school

· attendance is challenged, the above materials must be submitted to Little League Baseball,
Incorporated, with an affidavit of residency or school attendance from the parent(s) or guardian.
27.

At all times relevant hereto, Defendant, JRWLL, was within the geographic

boundaries of the Defendant, Little League's, District Administrator for Illinois District Four
(hereinafter referred to as "Illinois District Four").
28.

Sometime prior to April 30, 2014, Defendant, Little League, issued a charter to

Defendant, JRWLL.
29.

On or about April 30, 2014, Defendant, JRWLL, submitted its 2014 boundary

map (hereinafter referred to as the "JRW Map") to Illinois District Four in compliance with the
Little League's rules and regulations.

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30.

Sometime thereafter, Illinois District Four emailed the JRW Map to the Little

League Central Region Headquarters in Indianapolis, and the Little League Central Region
confirmed that the JRW Map had been received.
31.

On or about May 1, 2014, the 2014 regular season for the Defendant, JRWLL,

32.

Defendant, JRWLL, played regular season games from May 1, 2014, to June 30,

33.

During this regular season, the League coaches, Plaintiff, Darold Butler, along

began.

2014.

- 1

with the other coaches Houston and Little, selected a "Tournament Team" from the best players

. in the League.
34.

According to the tournament rules of the Little League, "[i]t shall be the league

president's responsibility to review and certify the birth records (league age) by viewing the
original birth record and residence (as defined by Little League Baseball, Incorporated) of all
players. When the league finally decides on the makeup of the team, names must be entered on
the league's Eligibility Affidavit.

Once the District Administrator certifies the Eligibility

Affidavit, the tournament team will be required to have in its possession: (1) the Eligibility
Affidavit; (2) a map showing the actual boundaries of the league, with locations noted for the
residences of the parent or legal guardian (court appointed) or location of the school for every
participant named on the affidavit; (3) tournament verification form for each player (strongly
recommended); (4) three or more documents to determine residency of the parent(s) or legal
guardian (court appointed) or a document to support school attendance/enrollment for each
player named on the tournament affidavit; (5) waivers ...."
Affidavit, p. T-4

7

Ex. A, Tournament Eligibility

35.

Prior to every tournament level game, the Eligibility Affidavit of each team must

be certified by the District Administrator or his/her appointee and presented to the Tournament

Director.
36.

The JRW Parents, along with the rest of the Tournament Team parents, then

submitted residency documents and birth certificates to Defendant, Bill Haley.
37.

At no time did Bill Haley inform the JRW Parents that their children were

ineligible to play due to residency requirements.
38.

At no time from April 2014 to August of 2014 were any of the JRW Parents

aware of any residency issues that may have existed under rules of Defendant, Little League.
39.

From July 3, 2014, to July 7, 2014, the JRW League hosted the Illinois District

Four Tournament and advanced to the next tournament round.
40.

From July 14,2014, to July 21,2014, the JRW Tournament Team participated in

the Illinois Section Three Tournament in Hegewisch, Illinois, which they won and again
· advanced.
41.

The Illinois Section Three Tournament is where the JRW Tournament team

encountered Defendants Evergreen Park Athletic Association and Defendant Chris Janes.
42.

From July 22, 2014, to July 27, 2014, the JRW Tournament Team attended and

won the Illinois State Championship in Manteno, Illinois, and earned a spot in the Great Lakes
Regional Tournament in Indianapolis.
43.

At the Illinois State Championship, volunteers working for the event were

charged with verifying the eligibility of the players on each participating team, including the
JRW Tournament Team.

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44.

From July 31, 2014, to August 9, 2014, the Great Lakes Regional Tournament

was held, which included participating teams from six states, and was televised by ESPN.
45.

Plaintiff Darold Butler, as Coach of the JRW Tournament Team, submitted a

"residency binder" to Defendant Little League through its Central Region Tournament Director,
Scott Spillman (hereinafter referred to as "Spillman").
46.

That residency binder included the JRW Map, the birth certificates of each

participating player, and the proof of residency documents for each JRW Tournament Team
player.
47.

Defendant Little League was responsible for revtewmg and scrutinizing the

• residency documents with the boundary map, and then confirming the eligibility of each player
participating in the tournament.
48.

On information and belief, Little League was aware of the potential residency

issues of the children of the JRW Parents, but chose to ignore and/or deliberately conceal these
I

: facts in order to garner higher ratings, publicity, and money for Defendant Little League.
49.

On or about August 9, 2014, the JRW Tournament Team defeated Indiana and

won the Great Lakes Regional Tournament; thereby advancing to the Little League World Series
Tournament.
50.

From August 10, 2014, to August 23, 2014, the JRW Tournament Team

continued to advance and succeeded in winning the United States Championship.
51.

On or about August 24, 2014, the Jackie Robinson West Tournament Team was

defeated by South Korea in the International Championship game.

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52.

From April 30, 2014, to August 24, 2014, no complaints were lodged against the

JRW Tournament team for ineligibility, and no one informed any of the JRW Parents that there
was any problem with the residency of the players.
53.

Instead of alerting the JRW Parents, the JRW Tournament Coach Darold Butler,

or the JRW Tournament Team members, Defendant Little League and Defendant JRWLL chose
to conceal and/or ignore any and all potential residency issues that existed during the
tournament.
54.

In or around August of2014, Defendant JRWLL submitted its map and boundary

information to the Central Regional Assistant Tournament Director, Scott Spillman ("Spillman").
55.
i

In or around August of 2014, Spillman expressly approved the information

submitted by Defendant JRWLL.
56.

At all times relevant, Spillman was the assistant to the Tournament Director, Nina

Johnson.
57.

At no time during the tournament was any protest or complaint raised against

JRWLL.
58.

On September 9, 2014, Nina Johnson sent an email to JRW Coach Bill Haley,

indicating that there were ineligible players on the JRW Tournament Team.
59.

In or around this time, Central Region Tournament Director Nina Johnson

contacted JRW owner Bill Haley about the JRW Map, but only after JRW had won the United
States Little League World Series.
60.

In that September 9, 2014, email, Nina Johnson informed Defendant Bill Haley

that she had examined the map herself and told Coach Haley that eleven of the JRW players
lived within the proper boundaries and that two players lived outside of the boundaries.

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61.

Nina Johnson and Pat Wilson expressly informed Bill Haley in September and

October 2014 that there were JRW players who lived outside the proper boundaries, however,
neither Defendant Little League, Defendants JRWLL, Bill Haley, nor Annie Haley take any
further steps to acknowledge the potential problem.
62.

On or around November 6, 2014, Defendant Little League organized a trip for the

JRW Tournament Team to visit the White House and arranged for the JRW Team to attend the
Major League Baseball World Series in San Francisco.
63.

Defendant Little League CEO Steve Keener and Rules Chairman Pat Wilson

accompanied the JRW Team to the White House and are included in the picture with President
Barack Obama.
64.

After the visit with the President, Little League distributed the pictures from the

visit worldwide.
65.

On information and belief, Defendant Little League deliberately capitalized on the

notoriety of the JRW Team and the JRW Parents in order to bolster its corporate image, gain
donations and otherwise profit from the unique appeal of the JRW Tournament Team.
66.

On information and belief, Little League motivation to enhance its corporate

image to raise, among other things, the value of its television deal with ESPN.
67.

At no time relevant did Defendant Little League contact JRW Coach Darold

Butler to determine what he knew or did not know regarding the childrens' residency.
68.

Defendant Little League did not contact any of the JRW Parents to investigate

further as to the residency issues.

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69.

Defendant Little League did not attempt to meet with the children, directly or

even through their parents, to explain to them that there were concerns regarding their respective
residency issues.
70.

Defendant Little League did not meet with District Four Administrator Michael

Kelly to determine what was known about the boundary issues.
71.

Defendant Little League did not expressly meet with anyone affiliated with JRW

and provide an explanation as to which rule or rules in the relevant rulebook were at issue and
potentially violated.

72.

Defendant Little League failed to perform an adequate investigation either

, Individually, or in compliance with its own rules, policies or procedures.
73.

In December of 2014, Steve Keener, ("Keener") made public statements clearing

JR W of any wrongdoing.
74.

Even if there were boundary issues with JRW, Keener himself either determined

: that the JRW Tournament Team's eligibility was not violating of Little League Rules or
: deliberately canceled the boundary issues so that could profit through the unique appeal of the
JRW Tourmament Team in its contract with Little League and ESPN.
75.

During this period, Chris Janes, Individually and as agent of Evergreen Park

Athletic Association, had filed a grievance with the Little League about the JRW player
residences.
76.

According to the Little League Rules of play any Protest regarding Rule

violations and player ineligibility must have been raised before the subject Tournament is
completed.

12

77.

Keener himself publicly acknowledged that no protests or complaints were raised

in a timely manner and in accordance with Little League rules.

78.

On information and belief, following the success of the JRW Team, Defendant

Little League, through its agent and CEO, Steve Keener, entered into a television rights
agreement with ESPN.
79.

On or about December 23, 2014, Defendant JRWLL through its agent Bill Haley

had attempted to absorb territories around Chicago-land from other leagues in order to
retroactively legitimize the eligibility of all the JRW Team members.
80.

On or about February 11, 2015, Defendant Little League announced that it was

• stripping the title from the JRW Tournament Team without giving the JRW Team or the JRW
Parents advance notice, due process or an opportunity to be heard and in contravention to the
rules outlined in the Little League Handbook.
81.

Immediately prior to Defendant Little League announcing that the title had been

I stripped, ESPN broke the story before any of the JRW players or their families were informed.

82.

I

The press release issued by Little League on February 11, 20 15, failed to mention

I

~-- - ~ -- ) its Official Regulations and/or procedures for stripping the title from the JRW Team.

83.

The memorandum sent by Little League to JRW on February 12,2015 also failed

to mention the Official Regulations.
84.

The Official Regulations contain the rules that govern all teams that play Little

League baseball.
85.

ESPN continually aired the Jackie Robinson West tournaments and reported on

circumstances surrounding the stripping of the World Series Title from the JRW Tournament
Team.

13

..

86.

At all times relevant, neither the players on the JRW Tournament Team, nor the

JRW Parents submitted any boundary maps to JRWLL or Little League.
87.

At all times relevant, neither the players on the JRW Tournament Team, nor the

JRW Parents accepted any boundary maps from JRWLL or Little League.
88.

At all times relevant, neither the players on the JRW Tournament Team, nor the

JRW Parents approved any boundary maps for JRWLL or Little League.
89.

Finally, Defendant Little League misrepresented the facts involved by asserting

that an altered boundary map was the boundary map submitted in the tournaments.
90.

In reality, the original JRW Map submitted to at the tournaments and to

· Defendant Little League was true and correct, and for that reason Defendant Little League was
· aware of the eligibility issues with the JRW Players as soon as the original JRW Boundary Map
, was submitted in August of2014.

COUNT I- ULTRA VIRES
(Against Little League)
1.-90. Plaintiffs repeat and reallege Paragraphs 1 through 90 of Common Facts as
· Paragraphs 1 through 90 of Count I as though set forth fully herein.
91.

The stripping of the World Series Title was contrary to the rules and procedures

established by Defendant Little League, thereby not affording Plaintiffs JRW Parents and/or the
JRW Team sufficient due process.
92.

Pursuant to the Little League 2014 Baseball Official Regulations with Playing and

Tournament Rules "if the facts establishing or verifying the ineligibility of a player become
known AFTER [sic] a game, and the ineligible player participated in the game, that team shall
forfeit the game in question, subject to the following conditions: (a) A protest may be lodged by
the manager or coach with the Tournament Director or District Administrator. Such protest
14

must be made before either team affected by the protest begins another game. (b) The
Tournament Director or District Administrator must contact the Regional Director (or his/her
appointed agent), who shall contact the Tournament Committee for a decision. The decision of

the Tournament Committee shall be final and binding." Little League 2014 Baseball Official
Regulations with Playing and Tournament Rules at T-11 Conditions of Tournament Play §C(3)

(emphasis added).
93.

No protests were made against the JRW Tournament Team until after the

tournament was completely over; including both national and international tournament play.
94.

On information and belief, the facts of this matter were never submitted to any

Tournament Committee, but instead the decision was made unilaterally by the administration of

i Defendant Little League.
I

95.

Defendant Little League was influenced by bias, prejudice, and/or did not act in

: good faith when it stripped Plaintiffs of the World Series title, and it did not follow the
'

prescribed procedures.
96.

Little League's actions are contrary to rudimentary due process and natural

97.

As a result of Defendant Little League's disregard for their own procedures,

I

-' justice.

Plaintiffs were severely damaged both emotionally and economically when the title was stripped.
WHEREFORE,

Plaintiffs,

DEVONA

D.

BENTON

and

FRANK

JACKSON,

individually, and on behalf of their minor child, J. B.; ROBERTS. BUFFORD, JR., Individually,
and on behalf of their minor child, C.B.; DAROLD BUTLER, SR. and DONITA BRUCE,
individually, and on behalf of their minor child, D.B.; VENISA BEASLEY -GREEN and
CHRISTOPHER GREEN, individually, and on behalf of their minor child, B.G.; CARLTON A.

15

HONDRAS, II and SHEREE HONDRAS, individually, and on behalf of their minor child, C.H.;
JERRY F. HOUSTON and MYRTLE HOUSTON, individually, and on behalf of their minor
child, J.H.; EDWARD HOWARD III, and CALANDRA HOWARD, individually, and on behalf
of their minor child, E.H.; LINDA SNEED HARRIS, individually, and on behalf of her minor
child, M.J.; NEDRA JONES and ALVIN JONES, individually, and on behalf of their minor
child, P.J.; TAMMY KING and EDDIE KING, SR., Individually, and on behalf of their minor
child, E.K.; PRENTISS LUSTER and DARLENE LUSTER individually, and on behalf of their
minor child, P.R.; SANJA E. NOBLE, Individually, and on behalf of her minor child, L.N.; and
CLAUDIA HARVEY, individually, and on behalf of her minor child, D.R.; respectfully request
that this Honorable Court award Plaintiffs an amount in excess of $50,000.00 for pain and
suffering and lost prospective economic benefits, reinstate the World Series Title to JRW, and
for such other and further relief as this Court deems just and proper.
COUNT II -UNJUST ENRICHMENT
(Against JRWLL and Little League)
1.-97. Plaintiffs repeat and reallege Paragraphs 1 through 97 of Count I as Paragraphs 1
through 97 of Count II as though set forth fully herein.
98.

Defendant JRWLL and Defendant Little League orchestrated and/or concealed

the ineligibility of the JRW Team Members in order to reap the benefits of the notoriety and
media attention.
99.

Defendant JRWLL and Defendant Little League earned hundreds of thousands of

dollars as a result of their concealment and deception.
100.

Plaintiffs JRW Parents paid league fees and costs to Defendant JRWLL and

Defendant Little League.

16

I0 I.

This benefit of these earned monies and fees were retained to the detriment of

JRW Parents.
102.

Defendant JRWLL's and Defendant Little League's retention of these benefits

violates the fundamental principles of justice, equity, and good conscience.
WHEREFORE,

Plaintiffs,

DEVONA

D.

BENTON

and

FRANK

JACKSON,

individually, and on behalf of their minor child, J. B.; ROBERTS. BUFFORD, JR., Individually,
and on behalf of their minor child, C.B.; DAROLD BUTLER, SR. and DONITA BRUCE,
individually, and on behalf of their minor child, D.B.; VENISA BEASLEY -GREEN and
CHRISTOPHER GREEN, individually, and on behalf of their minor child, B.G.; CARLTON A.
HONDRAS, II and SHEREE HONDRAS, individually, and on behalf of their minor child, C. H.;

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JERRY F. HOUSTON and MYRTLE HOUSTON, individually, and on behalf of their minor

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child, J.H.; EDWARD HOWARD III, and CALANDRA HOWARD, individually, and on behalf

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of their minor child, E.H.; LINDA SNEED HARRIS, individually, and on behalf of her minor

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child, M.J.; NEDRA JONES and ALVIN JONES, individually, and on behalf of their minor

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child, P.J.; TAMMY KING and EDDIE KING, SR., Individually, and on behalf of their minor
child, E.K.; PRENTISS LUSTER and DARLENE LUSTER individually, and on behalf of their
minor child, P.R.; SANJA E. NOBLE, Individually, and on behalf of her minor child, L.N.; and
CLAUDIA HARVEY, individually, and on behalf of her minor child, D.R.; respectfully request
that this Honorable Court award Plaintiffs an amount in excess of $50,000.00 for the unjustly
enriched amounts, and award such other and further relief as this Court deems just and proper.
COUNT III -INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
(Against All Defendants)
I. -102. Plaintiffs repeat and reallege Paragraphs 1 through I 02 of Count II as Paragraphs
1 through 102 of Count III as though set forth fully herein.
17

103.

Defendant JRWLL through its agents Bill Haley and Annie Haley deliberately

ignored and/or concealed the eligibility problems of the JRW Tournament Team in conjunction
with Defendant Little League in order to reap the rewards of the short-lived fame and media
attention.
104.

Defendant Chris Janes individually and as agent, servant, or employee of

Evergreen Park Athletic Association, and Evergreen Park Athletic Association, individually and
through its agent, servant, or employee Chris Janes, intentionally investigated the JRW
Tournament Team and delayed until after the tournament was over to raise their complaints.
105.

Defendant Little League despite reviewing the boundary map and eligibility

documents of the JRW Parents failed to alert any of the parents or coaches that the JRW players
1

were ineligible to play.
106.

Defendant JRWLL and Defendant Little League failed to act until after JRW

Tournament Team won the Little League World Series.
107.

Furthermore, following the discovery of the residency problems, Defendant Little

: League failed to follow appropriate prescribed procedures and stripped Plaintiffs' World Series

J Title without due process of law.
108.

Subsequently, JRWLL through its agent Bill Haley perpetuated the distress by

stating that he was organizing a petition to send to Defendant Little League in an attempt to
reinstate the title.
109.

Despite the players and family having collected thousands of signatures and

delivering them to Bill Haley, JRWLL failed to send those petitions to Defendant Little League.
110.

On information and belief, these petitions were nothing more than a fiction

created by Defendant JRWLL to placate the JRW Parents.

18

Ill.

ESPN then failed to heed the warning of Defendant Little League and released the

news that the JRW Team was being stripped of its title before the team even knew.
112.

The young players first became aware through the news that the title they had

worked so hard to achieve had been stripped from them over an alleged technicality.
113.

In the ensuing media coverage, ESPN and Stephen A Smith accused the JRW

Parents of falsifying documents and perpetrating a fraud upon the Little League.
114.

Those statements were patently false and were baseless and without merit.

115.

All of these events were deliberate acts by Defendants, while they ignored the

well being of Plaintiff JRW Parents and their participating minor children.
116.

The conduct of Defendants referenced above was extreme and outrageous.

117.

Defendants knew or had reason to know that there was a high probability that

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their conduct would cause the JRW team members severe emotional distress.

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118.

Plaintiff JRW Parents, Individually and on behalf of their minor children, have

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been severely emotionally damaged as a result of Defendants' conduct. .

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WHEREFORE,

Plaintiffs,

DEVONA

D.

BENTON

and

FRANK

JACKSON,

individually, and on behalf of their minor child, J. B.; ROBERTS. BUFFORD, JR., Individually,
and on behalf of their minor child, C.B.; DAR OLD BUTLER, SR. and DO NIT A BRUCE,
individually, and on behalf of their minor child, D.B.; VENISA BEASLEY-GREEN and
CHRISTOPHER GREEN, individually, and on behalf of their minor child, B.G.; CARLTON A.
HONDRAS, II and SHEREE HONDRAS, individually, and on behalf of their minor child, C.H.;
JERRY F. HOUSTON and MYRTLE HOUSTON, individually, and on behalf of their minor
child, J.H.; EDWARD HOWARD III, and CALANDRA HOWARD, individually, and on behalf
of their minor child, E.H.; LINDA SNEED HARRIS, individually, and on behalf of her minor

19

child, M.J.; NEDRA JONES and ALVIN JONES, individually, and on behalf of their minor
child, P.J.; TAMMY KING and EDDIE KING, SR., Individually, and on behalf of their minor
child, E.K.; PRENTISS LUSTER and DARLENE LUSTER individually, and on behalf of their
minor child, P.R.; SANJA E. NOBLE, Individually, and on behalf of her minor child, L.N.; and
CLAUDIA HARVEY, individually, and on behalfofher minor child, D.R.; respectfully request
that this Honorable Court award Plaintiffs an amount in excess of $50,000.00 for pain and
suffering, award amounts due for lost prospective economic benefits, reinstate the World Series
Title upon the JRW, and for such other and further relief as this Court deems just and proper.
COUNT IV-DEFAMATION PER SE
(Against Defendants ESPN, Inc. and STEPHEN A. SMITH)

1.-118. Plaintiffs repeat and reallege Paragraphs 1 through 118 of Count III as Paragraphs
1 through 118 of Count IV as though set forth fully herein.
119.

On or about February 11,2014, ESPN2 aired an episode of"First Take" with

Stephen A. Smith.
120.

During that episode, Stephen A. Smith directly accused the JRW Parents of

perpetrating a fraud against the Little League.
121.

Specifically, Stephen A. Smith stated that the JRW Parents falsified documents

and engaged in deceit when referencing the ineligible residences of the players.
122.

Stephen A. Smith stated that the picture ofDarold Butler was "throw kids into the

wind like this" and that his face should be put on the screen and "treat[ed] it like the mug shot it
deserves to be treated like."
123.

Stephen A. Smith, Individually and as agent, servant, or employee of ESPN,

defamed and slandered Darold Butler by indirectly and directly stating that he had engaged in
criminal, fraudulent acts.
20

124.

Stephen A. Smith, Individually and as agent, servant, or employee of ESPN,

accused the JRW Parents of falsifying documents and perpetrating a fraud upon the Little
League.
125.

Stephen A. Smith, Individually and as agent, servant, or employee of ESPN,

defamed the JRW Parents by indirectly and directly stating that they had engaged in criminal,
fraudulent acts.
126.

These statements and inferences by Stephen A. Smith and ESPN were false when

made and Defendants Smith and ESPN knew or had reason to know that they were false when
made.
127.

The statements of Stephen A. Smith showed a reckless disregard for the

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individuals involved and the facts of the case .

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128.

As a result of these statements and other coverage by ESPN, the reputations of

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: Darold Butler and the other JRW Parents were tarnished irreparably, and all have been damaged
i

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emotionally and economically as a result.
WHEREFORE,

Plaintiffs,

DEVONA

D.

BENTON

and

FRANK JACKSON,

individually, and on behalf of their minor child, J. B.; ROBERTS. BUFFORD, JR., Individually,
and on behalf of their minor child, C.B.; DAROLD BUTLER, SR. and DONITA BRUCE,
individually, and on behalf of their minor child, D.B.; VENISA BEASLEY -GREEN and
CHRISTOPHER GREEN, individually, and on behalf of their minor child, B.G.; CARLTON A.
HONDRAS, II and SHEREE HONDRAS, individually, and on behalf of their minor child, C.H.;
JERRY F. HOUSTON and MYRTLE HOUSTON, individually, and on behalf of their minor
child, J.H.; EDWARD HOWARD Ill, and CALANDRA HOWARD, individually, and on behalf
of their minor child, E.H.; LINDA SNEED HARRIS, individually, and on behalf of her minor

21

child, M.J.; NEDRA JONES and ALVIN JONES, individually, and on behalf of their minor
child, P.J.; TAMMY KING and EDDIE KING, SR., Individually, and on behalf of their minor
child, E.K.; PRENTISS LUSTER and DARLENE LUSTER individually, and on behalf of their
minor child, P.R.; SANJA E. NOBLE, Individually, and on behalf of her minor child, L.N.; and
CLAUDIA HARVEY, individually, and on behalf of her minor child, D.R.; respectfully request
that this Honorable Court award Plaintiffs an amount in excess of $50,000.00 for pain and
suffering, award amounts due for lost prospective economic benefits and loss of reputation, and
for such other and further relief as this Court deems just and proper.
COUNT V- FALSE LIGHT
(Against Defendants Little League, ESPN, and Stephen A. Smith)
l.-128. Plaintiffs repeat and reallege Paragraphs 1 through 128 of Count IV as Paragraphs

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1 through 128 of Count V as though set forth fully herein .
129.

On or about February 11, 2014, Defendant Little League stripped the mmor

Plaintiffs of their Championship title.
130.

Defendant Little League publically announced that the title had been stripped

because some of the team members did not qualify under the residency requirements of Little
League.
131.

Defendant Little League would go on to discuss that the JRW boundary map had

been altered, and publically questioned the residences of the JRW Parents.
132.

These acts portrayed the JRW Parents and the minor Plaintiffs in a false light and

damaged their reputation.
133.

On or about February 11, 2014, ESPN2 aired an episode of "First Take" with

Stephen A. Smith.

22

134.

During that episode, Stephen A. Smith directly accused the JRW Parents of

perpetrating a fraud against the Little League.
135.

Specifically, Stephen A. Smith stated that the JRW Parents falsified documents

and engaged in deceit when referencing the ineligible residences of the players.
136.

Stephen A. Smith stated that the picture of Darold Butler was "throw kids into the

wind like this" and that his face should be put on the screen and "treat[ed] it like the mug shot it
deserves to be treated like."
137.

Stephen A. Smith, Individually and as agent, servant, or employee of ESPN,

defamed and slandered Darold Butler by indirectly and directly stating that he had engaged in
criminal, fraudulent acts.
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138.

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Stephen A. Smith, Individually and as agent, servant, or employee of ESPN,

accused the JRW Parents of falsifying documents and perpetrating a fraud upon the Little

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League.

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139.

Stephen A. Smith, Individually and as agent, servant, or employee of ESPN,

U.l

defamed the JRW Parents by indirectly and directly stating that they had engaged in criminal,
fraudulent acts.
140.

These statements and inferences by Stephen A. Smith and ESPN portrayed

Plaintiffs in a false and misleading light.
141.

The statements of Stephen A. Smith showed a reckless disregard for the

individuals involved and the facts of the case.
142.

Defendants Little League, Stephen A. Smith, and ESPN acted in a manner that

was highly offensive to a reasonable person, and as a result of their statements, the reputations of

23

Darold Butler and the other JRW Parents were tarnished irreparably, and all have been damaged
emotionally and economically as a result.
WHEREFORE,

Plaintiffs,

DEVONA

D.

BENTON

and

FRANK

JACKSON,

individually, and on behalf of their minor child, J. B.; ROBERTS. BUFFORD, JR., Individually,
and on behalf of their minor child, C.B.; DAROLD BUTLER, SR. and DONITA BRUCE,
individually, and on behalf of their minor child, D.B.; VENISA BEASLEY -GREEN and
CHRISTOPHER GREEN, individually, and on behalf of their minor child, B.G.; CARLTON A.
HONDRAS, II and SHEREE HONDRAS, individually, and on behalf of their minor child, C.H.;
JERRY F. HOUSTON and MYRTLE HOUSTON, individually, and on behalf of their minor
: child, J.H.; EDWARD HOWARD III, and CALANDRA HOWARD, individually, and on behalf
of their minor child, E.H.; LINDA SNEED HARRIS, individually, and on behalf of her minor
child, M.J.; NEDRA JONES and ALVIN JONES, individually, and on behalf of their minor
child, P.J.; TAMMY KING and EDDIE KING, SR., Individually, and on behalf of their minor
child, E.K.; PRENTISS LUSTER and DARLENE LUSTER individually, and on behalf of their
minor child, P.R.; SANJA E. NOBLE, Individually, and on behalf of her minor child, L.N.; and
CLAUDIA HARVEY, individually, and on behalf of her minor child, D.R.; respectfully request
that this Honorable Court award Plaintiffs an amount in excess of $50,000.00 for pain and
suffering, award amounts due for lost prospective economic benefits, and for such other and
further relief as this Court deems just and proper.
COUNT VI-INVASION OF PRIVACY
(Against CHRIS JANES, individually and as agent, servant, or employee of Evergreen
Park Athletic Association, and EVERGREEN PARK ATHLETIC ASSOCIATION,
individually and through its agent, servant, or employee Chris Janes)
1-142. Plaintiffs repeat and reallege Paragraphs 1 through 142 of Count V as Paragraphs
1 through 142 of Count VI as though set forth fully herein.
24

143.

The JRW parents' home addresses were obtained without lawful authority.

144.

Janes committed an invasion or privacy against the JRW parents when he used

their license plates to discover their home addresses to report them to Little League.
145.

At all relevant times, Chris Janes knew that the addresses were obtained through

questionable and potentially illegal means.
146.

Chris Janes publicized Plaintiffs' private addresses and information to Defendant

Little League.
14 7.

As a result of the actions of Chris Janes, Plaintiffs were publicized in a false light

and painted as criminals.
148.

As a direct and proximate result of the actions of Chris Janes, individually and as

agent, servant, or employee of Evergreen Park Athletic Association, and Evergreen Park Athletic
: Association, individually and through its agent, servant, or employee Chris Janes, Plaintiffs were
severely damaged.
WHEREFORE,

Plaintiffs,

DEVONA

D.

BENTON

and

FRANK

JACKSON,

individually, and on behalf of their minor child, J. B.; ROBERTS. BUFFORD, JR., Individually,
and on behalf of their minor child, C.B.; DAROLD BUTLER, SR. and DONITA BRUCE,
individually, and on behalf of their minor child, D.B.; VENISA BEASLEY-GREEN and
CHRISTOPHER GREEN, individually, and on behalf of their minor child, B.G.; CARLTON A.
HONDRAS, II and SHEREE HONDRAS, individually, and on behalf of their minor child, C. H.;
JERRY F. HOUSTON and MYRTLE HOUSTON, individually, and on behalf of their minor
child, J.H.; EDWARD HOWARD III, and CALANDRA HOWARD, individually, and on behalf
of their minor child, E.H.; LINDA SNEED HARRIS, individually, and on behalf of her minor
child, M.J.; NEDRA JONES and ALVIN JONES, individually, and on behalf of their minor

25

child, P.J.; TAMMY KING and EDDIE KING, SR., Individually, and on behalf of their minor
child, E.K.; PRENTISS LUSTER and DARLENE LUSTER individually, and on behalf of their
minor child, P.R.; SANJA E. NOBLE, Individually, and on behalf of her minor child, L.N.; and
CLAUDIA HARVEY, individually, and on behalf of her minor child, D.R.; respectfully request
that this Honorable Court award Plaintiffs an amount in excess of $50,000.00 for pain and
suffering, award amounts due for lost prospective economic benefits, and for such other and
further relief as this Court deems just and proper.
Respectfully submitted,

By:

Is/ James A. Karamanis
One of Plaintiffs' Attorneys

i James A. Karamanis
I Shane M. Bradwell

: Kenneth A. Nazarian
I

Barney & Karamams, LLP
• Two Prudential Plaza
: 180 N. Stetson, Suite 3050
: Chicago, Illinois 60601
Phone: 312-553-5300
Attorney No.: 48525
1

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