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PILAR SANDERS
Plaintiti;

IN THE DISTRICT COURT

v. DEIONDRA SANDERS; PRIME TIME ENTERPRISE INC.; AND DEION SANDERS
Defendant.

2-tte_ JUDICIAL DISTRICT
COLLIN COUNTY, TEXAS

PLAINTIFF'S

ORIGINAL PETITION

TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Plaintiff Pilar Sanders ("Plaintiff"), and files this, her
Plaintiffs Original Petition against Defendants Deiondra Sanders C'_Deiondra"),

Prime Time Enterprise, Defendants") follows:

Inc. ("PTE"), and, Deion Sanders, ("DSIt), ("Collectively

and, for cause, would respectfully show unto this Honorable Court as

NATURE OF THE ACTION 1. Deion Sanders thinks he is above the law - - i.e. exempt from the laws

that apply to everyone else. Like many famous people in sports, Po1itirn~~CWJ Deion Sanders thinks that money trumps everything and he will

frl1'£e~ ~ ff. ~~

PLAINTIFF'S

ORIGlNAL PETITION

snUB

accountable for his actions. So strongly is his belief that he is above the law, that he leads his children and those around him by that example. In this case, when

Deion's daughter Deiondra tweeted to the world that: (a) Pilar was a "Gold Diggin' Ho," (b) Pilar was "the number one gold digger of the year, LOLj'" (c) Pilar was a "GoldDigginH* e," and, (d) ALL PILAR DO IS LIE, Deion did nothing about it. Instead, he publically endorsed Deiondra's false statements proclaimed that

Deiondra was "only defending her father," and then Tweeted to the world that he was "tired of all [Pilar's] lies and foolishness." These acts, along with numerous other parcel of a pattern and practice of causing personal injuries to Plaintiff. 2. This suit is the vehicle through which the Plaintiff can recover for the The Plaintiff brings several arising from the

unlawful acts of Deiondra and the other Defendants. categories numerous of claims comprising

of various causes of action

breaches of the duties Defendants

owed to Plaintiff, the disgraceful

conduct of Deiondra and the other Defendants, the extraordinary acts of dishonesty, libel, slander by defamation of the Defendants which has caused the Plaintiff to

suffer severe personal injuries, emotional, abuse, mental distress and physical, and financial damages.

PIAINTIFF'S ORIGINAL PETfnON 577U8

PAGE

2

DISCOVERY CONTROL PLAN

3.

Discovery shall be conducted under Level 3 pursuant to Rule 190.03 of

the TEXAS RULES OF CIVIL PROCEDURE.
PARTIES

4.
5.

Plaintiff Pilar Sanders ("Pilartl) is a resident of the State of Texas. Defendant Deiondra is a resident of Denton County, Texas, who may

be served with process at her current place of residence: 9120 Fossil Ridge Drive, Cedar Hill, Texas 75104.

6.

Defendant Deion is a resident of Collin County, Texas, who may be

served with process at his current place of residence: 1280 North Preston Road, Prosper, Texas 75078.

7.

Defendant Prime Time Enterprise is a Texas corporation who may be

served with process to the registered agent, Akbar Ali Momin and at its principal place of business: 9850 S. Kirkwood, #802, Houston, Texas 77047. 8. each of the Plaintiff believes and hereby alleges that at all times mentioned herein, Defendants were the agents, representation, officers, directors,

employees, or partners of one or more, or all of each of the remaining Defendants, and acted within the scope and authority of such agency, employment, partnership, or authority and with the knowledge, consent, approval, and ratification of one or

PLAf.'JTIFF'S 577118

ORIGINAL PETITION

PAGE

3

more or all of the other Defendants.

Unless a particular Defendant is named,

whenever this pleading references the acts of any Defendant or Defendants, such allegations shall be deemed to mean the acts of those Defendants named in the particular cause of action, and each of them acting individually, jointly and severally.
JURISDICTION AATJ)VENUE

9.

This Honorable Court has jurisdiction over this matter, as the amount

of the dispute is within the jurisdictional limits of this Honorable Court. Venue is proper in Dallas County, Texas as all, or a substantial part, of the transactions and for occurrences which gave rise to the immediate action occurred in Dallas County, Texas. In addition, the Defendants committed libel, slander, and invasion of

privacy in Dallas County, Texas. Tex. civ. Prac. & Rem. Code § 15.017. The choice of venue is at the Plaintiffs election. Tex. Civ. Prac. & Rem. Code § 15.017.
DAMAGE REQUEST AND REQUEST FOR AN EXPEDITED TRIAL BY JURY

10.

The Plaintiff is seeking damages against the Defendants, jointly and

severally, and an expedited trial by jury.
PRELIMINARY STATEMENT

11.

The Defendants have caused the Plaintiff to suffer severe personal

injuries, emotional abuse, mental distress and physical and financial damages. Specifically, the emotional abuse inflicted upon the Plaintiff was and continues to be

PLAINTIFF'S ORIGINAL PEnnON
577118

PAGE

4

a form of relationship violence characterized by a pattern of the Defendants' behaviors that resulted in numerous injuries to the innocent party, the Plaintiff. Here, the Defendants inflicted or failed to reasonably prevent others from inflicting mental pain, anguish, and/or distress through verbal and/or nonverbal acts,

including terrorizing, isolating, exploiting, humiliating, intimidating, threatening, harassing, and cvber-stalking the Plaintiff. Here, the Defendants' actions have led to the Plaintiffs personal injuries, emotional abuse, mental distress and physical and financial damages. 12. Here, on the facts present in this case, the Defendants deployed the

following emotional weapons on the Plaintiff: dominance, humiliation, isolation, threats, defamation, disparagement, intimidation, denial, and blame. 1 The

Defendants were dominant because they expected the Plaintiff to obey without question and treated her like a servant, a child, as well as a possession. The

Defendants constantly humiliated the Plaintiff by making her feel bad about herself. The Defendants made the Plaintiff defective in numerous ways and manners. The Defendants even persuaded the Plaintiff that she was and is worthless, a ""Gold Diggin' Ho,1Iand that no one else would want her. Further, the Defendants utilized

Attached a, Exhibit" 1" to this pleading are true and correct copies of Defendant's twitter account and twitter activity. Exhibit" I" is hereby incorporated by reference as if set forth in full herein.
PLAINTIFF'S 577118 ORIGINAL PETITION PAGE 5

insults, name-calling, shaming, and public put-downs directed toward eroding the Plaintiffs self esteem. 13. The Defendants even utilized isolation tactics. These tactics were

designed to cut the Plaintiff off from the outside world, keep her from seeing her family and friends, prevented her from meeting new people, seeking career opportunities, places. 14. The Defendants even used threats and intimidation. Abusers like the responsibilities, and even required her to obtain permission to go

Defendants used threats to keep their victim, the Plaintiff, from going places. They even scared the Plaintiff into dropping and/or enunciating outcry statements. The Defendants members. threatened to hurt the Plaintiff, her children, and other family

Types of intimidation

included assault and battery, verbal abuse,

slamming doors, threatening looks and/or gestures, smashing things in front of the Plaintiff, destroying property, hurting pets, and/or putting weapons on display. 15. To add insult to injury, emotionally abusive people like the Defendants

are especially adept at rationalization, justifications, and excuses. The Defendants have tried to explain their abusive behavior with references to bad childhoods, bad days, or to behavior stimulated by the Plaintiff.

PLAINTIFF'S 577118

ORIGINAL PETITION

PAGE

6

16.

Emotional abuse usually occurs within the context of a relationship and

may be more difficult to identify than physical abuse because there is often no overt physical evidence left behind. However, the majority of professionals consider

emotional abuse to be just as damaging as physical abuse. In abusive relationships, there is an imbalance of power, creating an environment in which one person is more susceptible to being abused. 17. Accordingly, this action arises out of Defendants' numerous breaches

of their duties to Plaintiff and the Defendants' blatant, egregious, and inequitable trespasses to, and violations of Plaintiff, Plaintiffs rights and interests. The

Defendants fraud, negligence, and intentional torts against Plaintiff, include the infliction of severe physical and emotional abuse/hardship upon the Plaintiff, and

the intentional infliction of harm to Plaintiff with the herein relevant intent of obstructing and preventing the Plaintiffs financial stability. The Defendants have knowingly, recklessly, and/or negligently engaged, or have allowed themselves to be engaged, in various deceptive techniques and trade practices designed to mislead the Plaintiff. directors Defendants and/or and employees their principals, agents, representatives, officers, knowingly, recklessly, and/or negligently

have

misrepresented the true nature of their dealings with the Plaintiff and knowingly, recklessly, or negligently omitted the disadvantages of associating with the

PLAINTIFF'S ORIGINAL PImTION
S77UB

PAGE

7

'_"

_'
and belief, Defendants knowingly,

Defendants.

In addition, upon information

recklessly, or negligently pursued Plaintiff with tactics designed to deceive, coerce, harass, or force Plaintiff to engage in dealings with the Defendants, some of which exposed Plaintiff to violations of the law.
THE FACTS

18.

Plaintiff brings this action to remedy the harm that Defendants have

caused her: (1) by inflicting severe and intentional emotional abuse; (2) by stalking, harassing, terrorizing, and threatening Plaintiff; (3) by acting negligently toward Plaintiff; (4) by acting recklessly with wanton disregard to the rights of Plaintiff; (5) by making fraudulent and negligent misrepresentations to and about the Plaintiff; (6) by failing to disclose material information to Plaintiff; (7) by breaching their fiduciary duties to Plaintiff; (8) by knowingly and intentionally violating numerous state statutes regulating and protecting Plaintiff from Defendants' fraud in the sale of stock and real estate; (9) by violating Texas Blue Sky and securities laws; (10) by publically disparaging and humiliating Plaintiff; (11) by violating other laws designed to protect Plaintiff from Defendants (12) by falsely and fraudulently inducing her to enter into and execute contracts; (13) by fraudulently inducing her to enter into and execute written contracts under duress; and, (14) by committing numerous

intentional torts against her including, but not limited to, numerous common law

PulNTIFF'S 577118

ORIGINAL PETITION

PAGE

8

torts, such as assault, battery, defamation, false imprisonment,

libel, slander, invasion of privacy, and

the facts supporting which are already known to Defendants.
CAUSES OF ACTION

Fraud, Fraud by Non-Disclosure, Fraud by Omission, and Fraud in the Inducement
19. The Plaintiff re-alleges each and every one of the foregoing paragraphs

as though set forth fully herein. 20. fraudulent By reason concealment of the Plaintiffs reliance on the representations

and

of material facts by Defendants,

the Plaintiff has been

damaged in an amount of not less than $50,000,000 Dollars. 21. to defraud Defendants Defendants have employed a scheme and common course of conduct the Plaintiff. were material. The misrepresentations On information and concealment of facts by knew the

and belief, Defendants

misrepresentations

and concealment

of facts were false. Alternatively, Defendants to Plaintiff were true. The

acted with reckless disregard whether the representations Plaintiff relied upon the misrepresentations The Plaintiffs reliance

and concealment of facts by Defendants. and concealment of facts by

on these representations

Defendants was reasonable and justifiable.

PLAINTIFF'S

snus

ORIGINAL PETITION

PAGE

9

_22. economic The Plaintiff has suffered, and continues to suffer, economic and nonlosses because of the wrongful conduct of the Defendants. On

information and belief, the wrongful acts of Defendants were done maliciously, oppressively, and with the intent to mislead and defraud the Plaintiff, and the Plaintiff is entitled to punitive and exemplary damages to be ascertained according to proof, which is appropriate to punish and set an example of the Defendants. Accordingly, the Plaintiff respectfully requests that exemplary damages of not less than three times the amount of actual damages, or $150,000,000 Dollars be awarded against the Defendants. Negligent Misrepresentation 23. The Plaintiff re-alleges each and every one of the foregoing paragraphs

as though set forth fully herein. 24. By reason of the Plaintiffs reliance on the representations and

fraudulent concealment of material facts by the Defendants, the Plaintiff has been damaged in an amount within the jurisdictional limits of this Honorable Court. 25. defraud The Defendants employed a scheme and common course of conduct to The misrepresentations and concealment of facts by

the Plaintiff.

Defendants were materiaL misrepresentations and

On information and belief, the Defendants knew the concealment of facts set forth herein were false.

PLAINTIFF'S ORIGINAL PETITION
S77llB

PAGE

10

Alternatively, representations

the

Defendants

acted

with

reckless

disregard

whether

the

made by Defendants

were true.

The Plaintiff relied upon the The Plaintiffs reliance on The losses

misrepresentations

and the facts concealed by Defendants.

these representations

and concealment of facts was reasonable and justifiable.

Plaintiff has suffered and continues to suffer economic and non-economic because of the wrongful conduct of the Defendants Dollars. 26. On information

of not less than $50,000,000

and belief, the wrongful acts of the Defendants

set

forth in this Count were done maliciously, oppressively, and with the intent to mislead and defraud the Plaintiff, and the Plaintiff is entitled to punitive and exemplary damages to be ascertained according to proof, which is appropriate punish and set an example of the Defendants. to

Accordingly, the Plaintiff respectfully

requests that exemplary damages be awarded against the Defendants of not less than three times the amount of actual damages, or $150,000,000 Dollars. Breach of Fiduciary Duties 27. Plaintiff re-alleges each and every one of the foregoing paragraphs as

though set forth fully herein. 28. The Defendants' owe fiduciary duties to the Plaintiff. The Defendants'

breached the following fiduciary duties owed to the Plaintiff:

PLAINTIFF'S 577118

ORIGINAL PETITION

PAGE 11

• • • • • • • • the duty of loyalty and utmost good faith; the duty of candor; the duty to act with integrity of the strictest kind; the duty of fair, honest dealing; the duty of full disclosure; the duty of good faith, fair dealing, loyalty, and fidelity; the duty of full disclosure on all matters affecting the Plaintiff; and, the duty of utmost good faith, fairness and honesty in dealing with the Plaintiff.

29.
the Plaintiff.

The breaches of fiduciary duties by Defendants resulted in injuries to Accordingly, the Plaintiff seeks all actual, consequential, and

incidental damages that have resulted from Defendants' breaches of fiduciary duties of not less than $50,000,000 Dollars, plus exemplary damages in a sum that is not

less than three (3) times the amount of Plaintiff's actual damages or $150,000,000 Dollars. 30. Plaintiff also seeks costs, expenses, and pre- and post- judgment interest Further, Plaintiff seeks forfeiture and

as allowed by law, and attorneys' fees. disgorgement

of all benefits that have been received by Defendants

as a result of

their breaches of fiduciary duties.

PlAINTlFF'S ORlGI~AL PETITION
S77UB

PAGE 12

Tortious Interference 31.

with Contracts and! or Prospective Business Relations of the foregoing paragraphs as

Plaintiff re-alleges each and everyone

though set forth fully herein. 32. The Defendants acted with the intent to interfere with existing

contracts as well as to prevent execution of prospective contracts.

The Plaintiff has

lost the opportunity to enter into several future contracts as result of the interference by the Defendants. On information and belief, the wrongful acts of the Defendants

set forth in this count were done maliciously, oppressively, and with the intent to harm the Plaintiff, and the Plaintiff is entitled to actual damages of not less than $150,000,000 Dollars and punitive and exemplary damages to be ascertained to punish and set an example of the

according to proof, which is appropriate Defendants.

Accordingly, the Plaintiff respectfully request that exemplary damages

be awarded against the Defendants in a sum that is not less than three (3) times the amount of Plaintiffs actual damages or $150,000,000 Dollars. Negligence and Gross Negligence 33. Plaintiff rc-allcges each and everyone of the foregoing paragraphs as

though set forth fully herein.

PlAINTIFF'S ORIGINAL PETITION
S77l1B

PAGE

13

34. Defendants Plaintiff. 35. In addition, Plaintiff will show that the Defendants' acts and omissions, viewpoint, involved an extreme The Defendants breached owed and still owe duties to the Plaintiff. The these duties which proximately caused damages to the

when viewed objectively from the Defendants'

degree of risk, considering the magnitude and potential harm to the Plaintiff. 36. And, the Defendants had actual, subjective awareness of the risk, but

still proceeded with their scheme with a conscious indifference to the rights, safety or welfare of the Plaintiff. 37. As a proximate result of the Defendants' negligence and gross

negligence, the Plaintiff has been damaged and she seeks to recover all actual, consequential, damages incidental, damages of less than $50,000,000 Dollars plus exemplary three (3) times the amount of actual damages or

of not less than Dollars.

$150,000,000

Defamation, Slander, Libel, and Business Disparagement
38. Plaintiff re-alleges each and every one of the foregoing paragraphs as

though set forth fully herein. 39. The Defendants called Plaintiff a "gold diggin' Ho." These published negatively affected the Plaintiff, her business opportunities, her

false statements

PLAINTIFF'S 577118

ORIGINAL PETITION

PAGE 14

career and her future. statements. 40.

No privilege, absolute or conditional, attaches to these

The Defendants made these statements to third parties without any The Defendants' false These statements are or

legitimate interest in the information contained therein. statements and omissions caused damages to the Plaintiff. unambiguous implication.

and defamatory or, alternatively, defamatory by innuendo

Each of the above-referenced acts and omissions, single or in

combination with others, constituted defamation and slander as well as defamation and slander "per se'' and caused the damages suffered by the Plaintiff. As a result, the Plaintiff has been damaged and seeks to recover all actual, consequential, and incidental damages caused by the defamation/slander in an amount of not less than $50,000,000 Dollars. 41. On information and belief, the wrongful acts of the Defendants set

forth in this Count were done maliciously, oppressively, and with the intent to harm the Plaintiff, and the Plaintiff is entitled to punitive and exemplary damages to be ascertained according to proof, which is appropriate to punish and set an example of the Defendants. Accordingly, the Plaintiff respectfully requests that exemplary

damages be awarded against the Defendants in a sum that is not less than three (3) times the amount of Plaintiffs actual damages or $150,000,000 Dollars.

PLAINTIFF'S ORIGI~AL PETITION
577118

PAGE

15

Civil Conspiracy 42. Plaintiff incorporates each and every one of the foregoing paragraphs as

though set forth fully herein. 43. The Defendants participated in a conspiracy to harm Plaintiff. The

Defendants were a member of a combination

of two or more persons or entities.

The object of the combination was to accomplish an unlawful purpose. 44. Defendants had a meeting of the minds on the object or course of

action, and in furtherance of the object or course of action, one of the members of the combination committed an unlawful, overt act. 45. The actions of Defendants complained of herein were a proximate

cause of harm to Plaintiff and which resulted in actual damages in an amount of not less than $50,000,000 Dollars for which sums Plaintiff now sues Defendants, who

should be held jointly and severally liable for the underlying acts. 46. As a result of Defendants' conduct, which was committed knowingly,

willfully, intentionally,

with actual awareness, or with actual malice, Plaintiff also

seeks the recovery of exemplary damages from Defendants in an amount of not less than three (3) times the amount of Plaintiffs actual damages of $50,000,000 Dollars. 47. Further, the wrongful acts of the Defendants were done maliciously,

oppressively, and with the intent to harm the Plaintiff, and the Plaintiff is entitled to

PLfl.INllFF'S ORIGINAL PETITION
577118

PAGE 16

punitive and exemplary damages to be ascertained according to proof, which is appropriate to punish and set an example of the Defendants. Accordingly, the

Plaintiff respectfully requests that exemplary damages be awarded against the Defendants in a sum that is not less than three (3) times the amount of Plaintiffs actual damages or $150,000,000 Dollars. Aiding and Abetting, Joint Enterprise, Assisting and Encouraging, Participatory and Vicarious Liability, and Concert of Action 48. Plaintiff incorporates each and every one of the foregoing paragraphs as

though set forth fully herein. 49. The Defendants aided and abetted one another in committing torts

against the Plaintiff. The Defendants had specific intent and knowledge that their conduct constituted torts. Clearly, the Defendants had the intent to assist one The Defendants gave one another assistance or

another in committing the tons.

encouragement and the Defendants' assistance or encouragement was a substantial factor in causing the torts. The actions of Defendants complained of herein were a proximate cause of harm
to

Plaintiff and has resulted in actual damages than

$50,000,000 Dollars for which sums Plaintiff now sues Defendants, who should be held jointly and severally liable for the underlying tort. As a result of Defendants'

conduct, which was committed knowingly, willfully, intentionally, with actual

PlAINTIFF'S ORIGINAL PETITION
577118

PAGE

17

awareness, or with actual malice, Plaintiff also seeks the recovery of exemplary damages from Defendants. 50. Further, the wrongful acts of the Defendants set forth in this Count

were done maliciously, oppressively, and with the intent to harm the Plaintiff, and the Plaintiff is entitled to punitive and exemplary damages to be ascertained according to proof, which is appropriate to punish and set an example of the Defendants. Accordingly, the Plaintiff respectfully requests that exemplary damages be awarded against the Defendants in a sum that is not less than three (3) times the amount of Plaintiffs actual damages or $150,000,000 Dollars.
Respondent Superior

51.

Plaintiff incorporates each and every one of the foregoing paragraphs as

though set forth fully herein. 52. Plaintiff was injured as a result of torts committed by the Defendants.

At all relevant times, the Defendants were the agents, representatives and/or employees of one another. The torts were committed while the tortfeasors were The Defendants are

acting within the scope of their agency or representation.

vicariously liable for the acts of their agents, representatives and/or employees. 53. Alternatively, the Defendants ratified the conduct of Defendants and

approved of the tortious conduct by word, act, or conduct after acquiring full

PLAINTIFF'S 577118

ORIGINAL PETITION

PAGE 18

knowledge of the act, and their approval was given with the intention of giving validity to Defendants' acts. Intentional Infliction of Emotional Abuse and Mental Distress 54 Plaintiff incorporates each and every one of the foregoing paragraphs as

though set forth fully herein. 55. The Defendants are fully aware of the facts that support this claim. The

Defendants' conduct was extreme and outrageous in character, and so extreme in degree, as to go beyond all possible bounds of decency, as to be regarded as atrocious, utterly intolerable, and despicable in a civilized community. 56. The Defendants' conduct proximately caused Plaintiff damages in that

it caused Plaintiff to suffer severe emotional distress. In particular, the Defendants' conduct was the direct and proximate cause of Plaintiffs severe mental pain and anguish. 57. Defendants. 58. In addition to severe emotional abuse and mental distress, the Plaintiff In addition, the Plaintiff continues to suffer from the actions of the

has suffered and will continue to suffer additional damages as a proximate result of the Defendants' conduct in that, in all reasonable probability, Plaintiff will continue

-------------------------~--~---------------------------------PAGE 19 PLI\L'l'TIFF'S ORIGINAL PETITION
577118

to suffer this emotional abuse and mental pain and anguish for a long time into the future - most likely the rest of her life. 59. The conduct of the Defendants was maliciously negligent and/or

grossly negligent, and fraudulent so as to entitle Plaintiff to recover exemplary damages. In this connection, Plaintiff will show that as a result of Defendants'

conduct, Plaintiff has suffered losses of time and other expenses, including attorney's fees incurred in the investigation and prosecution of this action. 60. Accordingly, Plaintiff asks that exemplary damages be awarded against

the Defendants in a sum that is not less than three (3) times the amount of Plaintiffs actual damages of not less than $50,000,000, or $150,000,000 Dollars.

Assault and Battery
61. Plaintiff incorporates each and every one of the foregoing paragraphs as

though set forth fully herein. 62. Defendant intentionally, knowingly, and recklessly caused bodily injury

to the Plaintiff by assaulting and battering her through physical contact. ABa direct and proximate result of the Defendant's conduct as alleged in this Petition, Plaintiff sustained bodily injuries. 63. Therefore, Plaintiff will incur reasonable expenses for necessary medical

treatment by mental health professionals.

PLAINTIFF'S ORIGINAL PETInON
577118

PAGE 20

64.

Plaintiff will continue to require medical care and attention

in

the

future, and, thus, will continue to incur expenses for treatment. 65. As a direct and proximate result of the Defendant's conduct, the

Plaintiff has suffered physical pain and mental anguish to her damage in an amount within the jurisdictional limits of this Honorable Court. 66. In committing all the acts alleged in this Petition, the Defendants acted

with a specific intent to cause substantial injury to the Plaintiff. 67. The Defendant's conduct, when viewed objectively from the standpoint

of the Plaintiff at the time it occurred, involved an extreme degree of risk, considering the probability and magnitude of the potential harm to the Plaintiff, and the Defendant proceeded with conscious indifference to the rights, safety, or welfare of the Plaintiff despite the Defendant's actual, subjective awareness of the risk involved. 68. Accordingly, Plaintiff is entitled to judgment against the Defendant's

for actual damages to be determined by the trier of fact and punitive damages in a sum that is not less than three (3) times the amount of Plaintiffs actual damages to deter such similar conduct by these Defendants.

PLAINTIFF'S ORIGINALPETITlO~
577118

PAGE 21

Alter Ego 69. Plaintiff re-alleges each and everyone of the foregoing paragraphs as

though set forth fully herein. 70. The identity of Defendants ate in substance one and the same; acting

solely as a conduit for the performance of the other's business, and as a device to cause harm or prejudice to those dealing with it. In support thereof, Plaintiff will show that, at all material times: (1) said Defendants constitute a single business enterprise and act as the alter ego of the other; (2) said Defendants and other "entities" share common principals, officers, directors, managers, members, partners, agents and employees; (3) some of the "entities" do not maintain distinct operations; (4) the Defendants have formed a corporate structure for the purpose of avoiding liability by improperly shielding assets; and, (5) the Defendants have engaged in selfdealing. 71. Upon information and belief, the Defendants have committed these

acts to shield themselves from liability, comingle funds and assets, and as a sham to perpetrate fraud, and have committed actual fraud. Further, the wrongful acts of the Defendants were done maliciously, oppressively, and with the intent to harm the Plaintiff, and the Plaintiff is entitled to punitive and exemplary damages to be ascertained according to proof, which is appropriate to punish and set an example of

PLAL"lTIFFS 577118

ORIGINAL PETITION

PAGE 22

the Defendants.

Accordingly, the Plaintiff respectfully requests that exemplary

damages be awarded against the Defendants in a sum which is not less than three (3) times the amount $150,000,000 of Plaintiffs actual damages of not less than $50,000,000 or

Dollars. Breaches of Contract

72.

Plaintiff re-alleges each and every one of the foregoing paragraphs as The Defendants entered into contracts with the

though set forth fully herein. Plaintiff. The agreements

are binding and enforceable agreements between the The breaches of contract by Defendants resulted in injury and incidental

Plaintiff and Defendants.

to the Plaintiff. Accordingly, Plaintiff seeks all actual, consequential, damages that have resulted from Defendants'

breaches of the agreements, plus

exemplary damages and costs, expenses, pre- and post- judgment interest as allowed by law, and attorneys' fees. Conversion, Civil Theft, and Violations of the Texas Theft Liability Act 73. Plaintiff re-alleges each and everyone of the foregoing paragraphs as

though set forth fully herein. 74. Plaintiff has a possessory right to her interests in property and business Defendants unlawfully appropriated, secured,

interests, which constitutes property.

or stole property belonging to the Plaintiff. The unlawful taking was made with the

PLAINTiFF'S ORIGINAL PETInoN
577U8

PAGE 23

intent to deprive Plaintiff of the property.

As a result, Plaintiff sustained actual

damages as a result of the theft in an amount that is within the jurisdictional limits of this Honorable Court, for which the Plaintiff now brings this suit. In addition,

Plaintiff seeks recovery of interest, attorneys' fees and costs. 75. Further, the wrongful acts of the Defendants set forth in this Count

were done maliciously, oppressively, and with the intent to harm the Plaintiff, and the Plaintiff is entitled to punitive and exemplary damages to be ascertained to punish and set an example of the

according to proof, which is appropriate Defendants. 76.

Accordingly, the Plaintiff respectfully requests that exemplary damages

be awarded against the Defendants in a sum that is not less than three (3) times the amount of Plaintiffs actual damages. Exemplary Damages 77. Plaintiff re-alleges each and everyone of the foregoing paragraphs as

though set forth fully herein. 78. The Defendant's acts complained of herein were committed knowingly,

willfully, intentionally, with actual awareness, or with actual malice. 79. In order
to

punish

the Defendant

for such

immoral,

corrupt,

disgraceful, and shameful conduct and to deter such actions and/or omissions in the

PLAINTIFF'S 577118

ORIGINAL PETITION

PAGE

24

future, and to protect every other person that might fall victim to Defendants in the future, Plaintiff seeks recovery from the Defendant for exemplary damages as

provided by Chapter 41 of the Texas Civil Practice and Remedies Code. Attorneys Fees 80. Plaintiff re-alleges each and everyone of the foregoing paragraphs as

though set forth fully herein.

Request is made for all costs and reasonable and

necessary attorneys' fees incurred by or on behalf of Plaintiff, and all fees necessary in the event of an appeal of this cause to the Court of Appeals and the Supreme Court of Texas, as the Court deems equitable and just.
CONDITIONS PRECEDENT

81.

All conditions precedent to the Plaintiffs right of recovery have been

performed, have occurred, or have been waived.

No WAIVER
82. By filing this lawsuit, Plaintiff does not waive or release any rights,

claims, causes of action, or defenses, or make any election of remedies that they have, but expressly reserve such rights, claims, causes of action, and defenses.

PLAINTIFF'S 577118

ORIGINAL PETITION

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25

RELIEF REQUESTED

WHEREFORE, PREMISES CONSIDERED, Plaintiff respectfully requests
that the Defendants be cited to appear and answer, as required by law, and that

Plaintiff have the following relief: • Judgment against the Defendants for pecuniary, economic, non-economic,

special, general, consequential,

and incidental damages in an amount within

the jurisdictional limits of this Honorable Court; • Actual damages in the amount determined Plaintiff of not less than $50,000,000 Dollars; • • • Compensatory damages; Damages for mental anguish; Punitive damages of not less than three (3) times the amount of Plaintiffs actual Damages or $150,000,000 Dollars; • • Pre- and Post-Judgment Interest; Costs of this lawsuit, including reasonable attorneys fees, experts' fees, and other disbursements; and, • Such other and further relief, at law or in equity, to which the Plaintiff may show herself to be justly entitled. to have been sustained by the

PLAINTIFF'S ORIGINAL PrnnON
577118

PAGE 26

DATE!)l

February ~

, 2012 Respectfully submitted,

James S. Bell State Bar No. 24049314

FRIEDMAN

& FElGER, LL.P.

5301 Spring Valley Road, Suite 200 Dallas, Texas 75254 (972) 788..1400 (Telephone)

(972) 776-5313 (Facsimile) ATTORNEY FOR PLAINTIFF

PLAJNTIPF'S O,'RtGll-l'•

snua

.u. PETITION

PAGE 27

1

--RetweetedRetweet ~
• • -Delete FavorltedFavorite . Close Open Details

I just comment on what HAS ALREADY been on the blogs should tell PiLAR to SToP putting their business out

Be of Pilar

calling in. So maybe u

-_

!~~
,

8 Feb l_neiondra

Sanders@DelondraSanders

• •
• • •

~

RetweetedRetweet Delete FavoritedFavorite • Close OQen Details

It would be one thing if I am making the phones calls! Im putting it on the blogsl BUT I'm NOT! have u notice every blog says II PILAR SAY"?

·

• • •

~ RetweetedRetweet
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On a lighter note! Had a great money making day at work today! Lol but I'm ready to get off:)

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II. _t ..
EXHIBIT

STOP telling me2stay out of grown ppl business. 1.1'mNOT a child! 2.Their business is allover the net be of Pilar, I might as well comment! ~ 8 Feb.

Deiondra Sanders .@nejondraSande~ ~ RetweetedRetweet
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@TheNewTou Thank You:)
In reply to SheNke Johnson Hide conversation

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I may be immature but I refuse to let someone sit there & LIE on my dad EVERY SINGLE WEEK. I am gonna do w/e r can to prove 2 u the TRUTH!!


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Its Pilar not my dad! He is not with the drama! She calls trnz every week:( RT @necolebitcbie: Pilar & Deion sanders are doing way too much

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LtTeamPilar this is 4u! U didn't know that side of her huh?? http://www.youtube.com!watch?v=kYlRFQdFqlQ but she says my aunt went over here 2 beat her up? STOP IT!
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CHECK OUT #ReaIAudio found in the house of @PILARSANDERS AUNT. She Didn't know she was being recorded http://www.youtube.com!watch?v=kYIRFOdFqIQ
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ALTERCATION

WIT

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1m sad2 admit making $$ makes me happy.Nvr thought i would fall in2 the trap but i did. If u runt talkin dollars than dnt even bother:) 101

8 F,b ~Aue,ond'"

Sanders""DelondraSanders

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8 Feb~~-..~.", 'DeloF'ldra Sanders@DeiondraSaRders

"Ii
r. .,
-0

• B.ru!.!Y

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Aye! I've been having sharp pains behind my ear close to the bone .. What could this be?? Should I go see a doctor or is it just sinuses?

8 Feb~_Oeiondra

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Sanders @DelondraSanders

• Rmlli • RetweetedRetweet

on another note, i hope everyone has a great day today:)

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PILAR i don think you got the memo but NOBODY CARES anymore. LOL PLEASE TAKE TMZ OFF SPEED DIAL. Its time to move on and go be a mom tOL

8 Feb &ei

•• dra S..... rs@O.i.ndraS>nd ....

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Rru!IY

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I MISS YOU.

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All that money The money is the motive ..... Girl put in work

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The truest and best form oflove is built on the worst of circumstances #RandomThought

~"Ilf~
7 Feb _oelondra

Sa'nders @DelondraSanders

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shout out to PLUV aka :@PilarSanders the ARTIST .. #ALBUMCOMINGSOON http://www.youtube.comiwatch7v=KX9VteRbBhM LOL
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Rru!!.'t

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Getting my hair sewn in!! I am in so much pain I am so tender headed :(

1 Fob ~Oeionsand''''

@DeionSanders

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furnbl

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Enough is Enough we're so tired and exhausted from the lies and foolishness. My kids are being affected weekly with these false allegations. Retweeted by Deiondra Sanders

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.B!Jill!

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Happy 10th birthday to my little brother Shedeur :) J.m.p:lllockerz.comls/181612192
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I

7 Feb 'h-~ .'

'1\
i. '
'J. : .,

'DeiOndlQ,

S,anders

@DeiondraSanders

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ICEBOX.

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Hello everyone :) take a second 2 thank God for allowing us another day despite our sins, for we are unworthy!!

eland ra Sanders. (oiI_DeiondraSanders

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OG Sanders.) RT ,@.DeionSandersJr:

@,DeiondraSanders

is a thug

k~_
3

FebaDeiondra

SanderS:@OeiondraSanders


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Out and about in these Dtown streets.
i .

2 Feb

Deiondra

Sanders@DeiondraSanders

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Happy Belated 40th birthday to the number one gold digger of the year LOL 00000 1iOkImDone

2 Feb

l_oei0l1dra5anders @De!ondraSanders
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k'tk

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"0

This dude just said

y'all just go Coo now. 0 yeah I'm flying out" LMBO DODD

#icant



• &ru:t

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#HOP imhis daughter not Pilar LOL 0 DO DO RT ('@'siksigmabarry: @DeiondraSanders Sorry about your divorce to Deion Sanders. Now, #PlayBall!

30 Jan

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~-


RIP to the girl I use to be.

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101

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We wanted too 101 but we couldn't embarrass ourselves like that. Plus I'm not a bag girl anymore.

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~ RetweetedRetweet Delete FavoritedFavorite • Close Open Details #Aries don't take sh *t from nobody.

RT ~XSTROLOGY:


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RT fffiLevisOnMyAss:

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I dont think you got the memo but NOBODY CARES anymore 101have some class!!

17Jon aDeiO"dr.

Sande" ""DeiondraS.nders

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YOU guys still live in the same house so how are u stranded & starving?? PLEASE stop with all the lies or you will see part 2 !!

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YOUR bummer is in the garage! The engine u blew out the other car is CURRENTLY getting
fixed this second.

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back to work now:)

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Rely on the MIGlITY hand offfGod to perfect your faith, as you live EACH day one step closer to the calling he's placed 011 ill life 1tAmen

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maybe next time u will actually chase yo marriage and not yo dream affame

*DROPS MIC*

WALKS OFF

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WHELP being that your "3rd" catch is over! now u can go back to "catch 1" Johnny Mitchell or "catch 2" Wesley Snipes ..... yeah we know


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Pilar stop tryna play the VICTIM. MAYBE IF U OF ACTUALLY LOVED MY DAD AND NOT LOVED THE LIFE HE GAVE YOU WE WOULD BE HERE TODA Yl!

wotn»


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my sister turned. 8 December 14th i COULDN'T even take her spa day for her birthday she told me "my mommy wont allow me to go wit uri ON BIBLE
.

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28 Dec

DeIondraSanders;@lDeiondl"aSanders

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#HowYoTopPriorityBeen yo marriage and yo kids when YO OWN KIDS cant even talk to their brothers and sister without getting a whoopin?

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all u had to do was be a supportive wife. ONL Y THING U EVER CARED ABOUT DOING

WITH MY DAD IS REALITY SHOWS, ALL STAR AND SUPPER BOWL ....

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#.HowYouDidntKnow but according THE BLOGS this yo SECOND ATTORNEY tryna fight a prenup #GoldDigginH*e

cause u

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SHE STAY TRYNA SLANDER MY DADDY NAME, THE SAME NAME THAT MADE THAT MADE HER FAMOUS .

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she just need to stop playing the victim, when she really the problem.

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DetaIls but all 5 of the kids was set down and explained WHAT WAS GOING

#HowYouDidntKnow.

ON?

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tfHowYoTopPriorityBeen

YO MARRIAGE AND YO KIDS when u flying out of town to see other niggas., .... Yeah We Know

28 Dec~. _."••- '.

t··s-""· Deioodra

F·· '-.''-.-Ft.'

Sanders @DelondraSanders

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#HowYoTopPriorityBeen YO MARRIAGE AND YO KIDS when U WONT EVEN TALK TO YO OWN MOM N LAW WHEN SHE COMES IN TOWN

Reply

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#HowYoTopPriorityBeen yo marriage and yo kids when YOUR OWN STEP CHILDREN NOT ALLOWED AT WHEN MY DADDY NOT THERE

oelondta

Sanders·.@Oei'ondraSanders

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.#HowYoTopPrioriD'Becn yo marriage on yo kids when THEY COME HOME FROM PRACTICE AT 9PM DINNER NOT EVEN COOKED CAUSE U BEEN OUT ALL DAY

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ttHowYoTopPriorityBeen

yo marriage & yo kids when YOU FLYING IN AND OUT FROM

MIAMI, NEW YORK., ATLANTA 2 "HOST" LIKE U A 20YR OLD VIDEO MODEL

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~HowYoTopPrioritJBecn yo kids and yo marriage when u in the studio EVERY NIGHT TRYING TO COME TO COME OUT WITH AN ALBUM

28 Dec.V '"'.. ~beiondraSanders@DeiondraSanders

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NEXT lSSUE ..... BLOGS SAID" "Pilar's lawyer adds, "Pilar's sole focus & top priority 4 the last 12.5 years has been her marriage&children."

r"
28

Ded··: .--. -Del ondra Sanders

La"
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#HowYouDidntKnow but before my dad even filed for divorce YOU SENT IN THE STORY .... OVER 2 MONTHS AGO TO lVlEDIATAKEOUT !fRowYouDidntlmow

28 Dec ~_Deiondra

la~

Sanders @DeiondraSander.s

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#HowYouDidntKnow but yo "lawyer" sent out a press statement last week on the blogs said u been searching for a 9 million dollars house??

28 De-c·


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#HowYouDidntKnow but yo got a video half naked at PhotoShoot now you know MY DADDY WOULDN'T ALLOW TIIAT IF YALL WAS WORKING ON YO MARRIAGE

28Doc ;'&O.;O"d

.. S.nders @Delondr.Sanders

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#HowYouDidntKnow BUt01ChaseNCashe
town?? ht1;p:/J1ockerz.com/s/169286639 View photoHide photo

chillin at my dads crib with the kids when he Gutta

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1t-HowYouDidntKnow but lately you been HOSTING ALL THE PARTIES, EVERY CITY, ALL DAY EVERY DAY

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!kP.!Y

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tEHowYouDidntKnow but yo boxes have been packed for weeks now #RealTalk http://lockerz.c-omls/1692850 16
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fumti

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like THE divorce has been going on for months so new trending topic #HO'VYOUDlDNTKNOW #PILAR

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on TMZ today it says PILAR stated SHE DID NOT KNOW about the divorce untill a few days ago which she found out ONLINE #LIES

lA&'~'
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28 Dec ~-. '_'. ;-~>De(Dndra Sa·nders·@ DeiondraSanders

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TIIEREFORE the REAL ....

IM ABOUT TO ADDRESS THE "blog" and the "issue" line by line and tell yall

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NORMALLY I mST SIT BACK & WATCH ALL HER LIES & MESS BUT ITS TO WHERE SHE'S GETTING PERSONAL. SHE IS TRYING 2 SLANDER MY DADDY NAME.

#STOPIT

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NOW roy dad HAS BEEN been nothing but GREAT to PILAR. HER, NOR HER MOM HAS WORKED IN OVER 11 YEARS!!

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with that being said SORRY DADDY

li:~~ 28 DeC~_Deiondra Sanders '@OekmdraSanders


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FIRST &FOR MOST I WOULD LIKE 2 APOLOGIZE FOR \VHAT IS BOUT TO HAPPEN MY DAD IS GOING 2 BE VERY UPSET AT ME 4 HE ALWAYS TAKES THE mGHER ROUTE

• BMIl!


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BACK FROM THE OFFICE ..... .IT IS TIME .)

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!!.!m!Y.

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LIES! LIES! ALL PILAR DO IS LIE!! wait till i leave this office


If

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Goodmorning Everyone :) take a second to thank God for allowing you another day despite our sins, for we are unworthy. Have a great day:)

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