State Court of Fulton County

**E-FILED**
18EV003863
8/10/2018 3:26 PM
LeNora Ponzo, Clerk
Civil Division
IN THE STATE COURT OF FULTON COUNTY
STATE OF GEORGIA

DELICIA CORDON, :
:
Plaintiff, :
: CIVIL ACTION FILE NO:
v. :
: ______________________
LESHAWN KAMEL MCCOY, :
TAMARCUS JEROD PORTER, and LKM :
TRUST, :
:
Defendants. :

COMPLAINT FOR DAMAGES

COMES NOW, DELICIA CORDON, Plaintiff in the above-styled action, and by and

through her undersigned counsel, files this, her Complaint for Damages against Defendants

LESHAWN KAMEL MCCOY, TAMARCUS JEROD PORTER and LKM TRUST, and shows

this Honorable Court as follows:

JURISDICTION AND VENUE

1.

Plaintiff is the victim of multiple crimes and has suffered significant damages due to the

intentional torts committed by either Defendant LESHAWN KAMEL MCCOY, Defendant

TAMARCUS JEROD PORTER, or both of said Defendants, and others at Plaintiff’s former

residence which is located at 392 Hickory Pass, Milton, Georgia 30004. Said residence is located

in Fulton County. Defendant MCCOY and PORTER are joint tortfeasors who committed various

intentional torts that occurred at said residence. Accordingly, said Defendants are subject to the

jurisdiction and venue of this Honorable Court. Each Defendant may be served with a Summons

COMPLAINT FOR DAMAGES CORDON

8/10/18

Page 1 of 14
and a copy of this Complaint at his residence address, or at any place where each Defendant may

be found. Defendant LKM TRUST is the grantor trust that owns the residence located at 392

Hickory Pass, Milton, Georgia 30004, and may be served with a Summons and a copy of this

Complaint upon the Trustee for said Defendant, at any place where said Trustee for this Defendant

may be found.

THE PARTIES

2.

Plaintiff is a former resident of 392 Hickory Pass, Milton, Georgia 30004, where she and

her children lived from October, 2016 through and including July, 2018. Plaintiff was previously

involved in a romantic relationship with Defendant, LESHAWN KAMEL MCCOY (hereinafter

referred to as, “McCoy”) from June, 2016 until June 1, 2018; however, Plaintiff and McCoy have

been acquainted for over five (5) years.

3.

Defendant, TAMARCUS JEROD PORTER (hereinafter referred to as, “Porter”), is the

best friend and/or personal assistant of McCoy. Throughout Plaintiff’s 5-year acquaintance with

McCoy and at all times relevant hereto, Porter has always overseen, or been personally involved

with McCoy’s personal business and affairs.

4.

After discovery is conducted in this litigation, there may be one (1) or more party

Defendants added to this action and/or substituted as party Defendant(s) to this action.

COMPLAINT FOR DAMAGES CORDON

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Page 2 of 14
 INTRODUCTION

5.

The relationship between Plaintiff and McCoy began with both parties in a perpetual state

of bliss. McCoy, who had been an acquaintance and friend of Plaintiff’s for at least three (3) years

before June, 2016, finally made his feelings for Plaintiff known to her. While Plaintiff was on a

trip to Las Vegas in June, 2016, McCoy flew to Las Vegas and confessed his love for Plaintiff to

her in person. Plaintiff and McCoy, who had been friends for years, began their romantic

relationship immediately.

6.

At the beginning of said relationship, Plaintiff was a resident of Cobb County, Georgia.

McCoy did not reside in the state of Georgia at all in June, 2016. Upon information and belief, at

the time, McCoy maintained a home in Harrisburg, Pennsylvania, a condo in Miami, Florida, and

an apartment in Buffalo, New York.

7.

In August, 2016, McCoy showered Plaintiff with multiple gifts for her birthday. Said gifts

included several expensive articles of jewelry, some of which were custom-made, among other

gifts.

8.

Around this time, McCoy and Plaintiff discussed living together, and McCoy promised to

buy Plaintiff a home. Plaintiff began looking for a home while McCoy was actively working as an

NFL player for the Buffalo Bills.

COMPLAINT FOR DAMAGES CORDON

8/10/18

Page 3 of 14
 9.

Plaintiff located a home for herself, her children and McCoy which was located at 392

Hickory Pass, Milton, Fulton County, Georgia 30004 (hereinafter referred to as, the “Residence”).

Plaintiff and McCoy both liked the Residence, and McCoy initially informed Plaintiff that the

Residence would be titled in both names. However, within two days of the scheduled home closing

for the Residence in October 2016, McCoy informed Plaintiff that his financial advisor instructed

him not to include Plaintiff on the deed for their new home. Instead, McCoy purchased the

Residence himself, and based upon Plaintiff’s information and belief, either at the closing or

immediately thereafter, McCoy transferred the title of the Residence into the name of Defendant

LKM Trust. The address associated with the trust was identical to the address for the apartment

that McCoy resided in at the time in Buffalo, New York.

10.

Based upon Plaintiff’s information and belief, McCoy is the Trustmaker of the LKM Trust.

11.

Plaintiff is unaware how long McCoy and Porter have been friends; however, since

Plaintiff has been acquainted with McCoy, Porter has always been McCoy’s best friend and/or

personal assistant.

12.

Based upon Plaintiff’s information and belief, Porter has maintained a residence in or about

West Palm Beach, Florida; in or about Orchard Park, New York; and/or in or about Philadelphia,

Pennsylvania.

COMPLAINT FOR DAMAGES CORDON

8/10/18

Page 4 of 14
 FACTUAL ALLEGATIONS AND CLAIMS

13.

Plaintiff hereby incorporates Paragraphs 1-12 set forth hereinabove as if each paragraph

were fully stated herein.

14.

Plaintiff and her children moved into the Residence in October, 2016, during the 2016 NFL

season. Plaintiff brought furniture from her Cobb County residence into the home, and also

purchased new furniture and furnishings for the Residence in 2016. Plaintiff completely furnished

the entire Residence and by the time the 2016 season ended, McCoy came home to a fully-

furnished home with the Plaintiff.

15.

Plaintiff’s fairytale relationship with McCoy did not last long. During the offseason

subsequent to the 2016 NFL season, Plaintiff began to notice some disturbing behavior exhibited

by McCoy. Because she truly loved McCoy, and she believed that he truly loved her, Plaintiff

sought to make their relationship work for several months.

16.

The offseason following the 2016 NFL season was a turbulent time for Plaintiff’s and

McCoy’s relationship. First, McCoy would constantly allow Porter and other friends to enter the

Residence, without Plaintiff’s consent. In fact, Porter sporadically occupied an upstairs bedroom

in the Residence, which had a total of five (5) bedrooms. Plaintiff has a young daughter and a

minor son, and did not feel comfortable with various men coming in and out of the home

unannounced. However, Plaintiff tolerated this for the sake of the relationship.

COMPLAINT FOR DAMAGES CORDON

8/10/18

Page 5 of 14
 17.

McCoy’s behavior became erratic during the offseason after the 2016 NFL season. He

would exhibit rage and often brutally beat his dog in the presence of the Plaintiff and her friends.

McCoy did not care who was present. When Plaintiff expressed concern about McCoy beating his

dog, he would turn his anger against the Plaintiff.

18.

McCoy is the father to a young son who visited the Residence during the offseason after

the 2016 NFL season. McCoy would aggressively, physically discipline and beat his young son

over minor mistakes that all young children make. When Plaintiff questioned McCoy about beating

his son, he would yell and scream at Plaintiff for commenting on how he should raise his son.

Plaintiff disagreed with how McCoy physically disciplined his son, but McCoy gradually changed

his behavior and disciplinary tactics regarding his son as he was approaching court proceedings

with his son’s mother.

19.

During February, 2017, Plaintiff and McCoy attended 6th Annual NFL Honors. As a

surprise for Plaintiff, McCoy rented some diamond hoop earrings. Both Plaintiff and McCoy loved

how the earrings looked on Plaintiff, so McCoy promised to purchase the earrings for her. Plaintiff

was ecstatic about her new earrings.

20.

By the summer of 2017, Plaintiff and McCoy would argue over McCoy beating his dog

and beating his son frequently, as well as other issues. The parties would “break up” and get back

together again, but Plaintiff was never asked to leave the Residence until July, 2017. Plaintiff and

McCoy had the most serious argument of their relationship at the time, and Plaintiff left the

COMPLAINT FOR DAMAGES CORDON

8/10/18

Page 6 of 14
Residence to go visit one of her friends. About an hour after Plaintiff left the Residence, McCoy

called the police to have Plaintiff permanently removed from the Residence. McCoy instructed

Porter to begin to unlawfully remove Plaintiff’s personal belongings from the home. When police

arrived on the scene it was explained to McCoy that he could not simply remove Plaintiff’s

belongings from the home because she and her children resided in the Residence. McCoy filed the

first eviction against the Plaintiff on or about July 3, 2017. At this time, Plaintiff found out that

McCoy never paid for the diamond hoop earrings, and she returned the earrings to McCoy in July,

2017 so that he could return them to the jeweler. However, the parties reconciled their relationship

immediately thereafter and stayed together. The 2017 eviction proceedings were not pursued by

McCoy any further.

21.

McCoy did not reside at the Residence during most of the 2017 NFL season, and there

were no incidents between the parties during that time.

22.

After the 2017 season ended, McCoy returned to the Residence with Plaintiff and her

children. Their relationship seemed back on track, but that was short lived. The parties broke up

again in April, 2018, only to get back together shortly thereafter. By May, 2018, the parties were

discussing the possibility of becoming engaged, and they discussed a possible engagement in depth

on May 28, 2018, which was Memorial Day.

23.

On or about May 30, 2018, McCoy left the Residence and traveled to Miami, Florida to

begin training for the upcoming 2018 NFL Season. Plaintiff left the Residence to attend the out of

state graduation for a family member.

COMPLAINT FOR DAMAGES CORDON

8/10/18

Page 7 of 14
 24.

The last direct communication that Plaintiff had from McCoy was in the early morning

hours of June 1, 2018 via text message. Plaintiff expressed her excitement about spending the

summer with McCoy. He responded with what appeared to be an innocuous message stating that

Plaintiff “already started” so he will “finish it” before texting her saying, “we gon kill it” at 12:23

a.m. on June 1, 2018, followed by “love u” at 12:35 a.m. to which Plaintiff responded, “Love you

more bae!!” at 12:58 a.m. By 9:00 a.m. on June 1, 2018, however, Plaintiff was alerted by the

doorbell camera video feed on her cell phone. She could see Porter and others removing her

furniture from the Residence on the live-streamed video footage on her phone.

25.

This Complaint arises from several intentional acts committed by Porter against the

Plaintiff, either on his own, or at the direction of McCoy beginning on June 1, 2018, and continuing

thereafter. Most of the intentional acts committed by McCoy and/or Porter occurred at the

Residence, or have been in reference to the Residence and/or the home invasion which occurred

at the Residence.

26.

On June 1, 2018, upon viewing McCoy’s friends, family and associates on the doorbell

camera, Plaintiff viewed an individual cover the doorbell camera with an article of clothing to conceal

the activities that were taking place. Plaintiff instructed her neighbor to call the authorities to prevent

the unlawful removal of her items from the Residence. Police arrived on the scene and instructed the

individuals to place Plaintiff’s items back inside the Residence. Most of the furniture was placed in

the basement of the Residence. However, a couch, coffee table, and two (2) area rugs, totaling

approximately Thirteen Thousand Dollars ($13,000.00) in value, were not placed in the basement

COMPLAINT FOR DAMAGES CORDON

8/10/18

Page 8 of 14
and, to date, have not been returned to Plaintiff despite Plaintiff’s request therefor (See August 7,

2018 letter to McCoy’s eviction attorney, attached hereto as Exhibit “A” and incorporated herein

by this reference). The electricity to the Residence was also disconnected on this date.

27.

On June 2, 2018, Porter, McCoy, and McCoy’s mother were on a “conference call” and

contacted the police so that the dispatcher could hear all three individuals during the call. The police

were informed that Porter was requesting a police escort to retrieve items from the Residence. Porter

would enter the Residence without warning. Plaintiff later called police about feeling uncomfortable

with Porter and others having unfettered access to the Residence. Because Porter was given

permission by McCoy to come and go into the Residence, there was nothing the police could do about

Porter’s unlimited access to the Residence. Plaintiff began making plans to relocate herself and her

minor children from the Residence.

28.

On June 3, 2018, Porter changed the locks to the doors of the residence and deactivated the

doorbell camera that was linked to the Plaintiff’s cell phone.

29.

On June 5, 2018, Plaintiff’s close childhood friend, who Plaintiff refers to as her “cousin”,

Elizabeth Donald, was at the home caring for Plaintiff’s minor child while Plaintiff was out of the

state. Porter and McCoy’s other friend, Thomas Williams, entered the Residence unannounced

through a side door and installed a new security system, along with new security camera(s), at the

direction of McCoy. Although Plaintiff and her children were residents at the Residence, Plaintiff was

not informed of the new security codes and did not have the ability to arm or disarm the new security

system. Plaintiff further did not have the ability to access the new security camera(s).

COMPLAINT FOR DAMAGES CORDON

8/10/18

Page 9 of 14
 30.

On June 6, 2018. Porter and McCoy called police together on a conference call requesting

assistance with removing individuals from the Residence. When asked how he knew that individuals

were inside of the residence, Porter advised that he and McCoy were not at the Residence, but that he

(Porter) had access to cameras inside the Residence which showed that people were present in the

Residence. Porter proceeded to file an improper eviction petition on behalf of McCoy on this date.

McCoy and Porter were on the call to police attempting to get Plaintiff’s cousin, and Plaintiff’s

teenage son, removed from the Residence while Plaintiff as out of town. After Plaintiff’s cousin

communicated with the police who arrived on the scene, Porter and McCoy were informed that they

could not lawfully put Plaintiff’s son out of the Residence because he lived there, Porter and McCoy

could not put Plaintiff’s cousin out of the Residence because she had Plaintiff’s permission to be there.

On this same day, June 6, 2018, Porter filed an eviction proceeding against Plaintiff on behalf of

McCoy.

31.

Porter entered the residence, unannounced on June 8, 2018, and again, accompanied by

Williams on June 19, 2018. Porter and Williams seemed to be doing something in Porter’s old

bedroom and/or in the attic, as well as something in the basement of the Residence. Once Plaintiff

filed her Motion to Quash the improper eviction proceeding filed by Porter on behalf of McCoy,

Porter no longer entered the Residence unannounced.

32.

On July 3, 2018, Plaintiff left the Residence for a vacation trip. Ms. Donald came to the

Residence to care for Plaintiff’s son while she would be out of town. Plaintiff returned to the

Residence on the evening of July 9, 2018. Ms. Donald stayed at the Residence overnight.

COMPLAINT FOR DAMAGES CORDON

8/10/18

Page 10 of 14
and, to date, have not been returned to Plaintiff despite Plaintiff’s request therefor (See August 7,

2018 letter to McCoy’s eviction attorney, attached hereto as Exhibit “A” and incorporated herein

by this reference). The electricity to the Residence was also disconnected on this date.

27.

On June 2, 2018, Porter, McCoy, and McCoy’s mother were on a “conference call” and

contacted the police so that the dispatcher could hear all three individuals during the call. The police

were informed that Porter was requesting a police escort to retrieve items from the Residence. Porter

would enter the Residence without warning. Plaintiff later called police about feeling uncomfortable

with Porter and others having unfettered access to the Residence. Because Porter was given

permission by McCoy to come and go into the Residence, there was nothing the police could do about

Porter’s unlimited access to the Residence. Plaintiff began making plans to relocate herself and her

minor children from the Residence.

28.

On June 3, 2018, Porter changed the locks to the doors of the residence and deactivated the

doorbell camera that was linked to the Plaintiff’s cell phone.

29.

On June 5, 2018, Plaintiff’s close childhood friend, who Plaintiff refers to as her “cousin”,

Elizabeth Donald, was at the home caring for Plaintiff’s minor child while Plaintiff was out of the

state. Porter and McCoy’s other friend, Thomas Williams, entered the Residence unannounced

through a side door and installed a new security system, along with new security camera(s), at the

direction of McCoy. Although Plaintiff and her children were residents at the Residence, Plaintiff was

not informed of the new security codes and did not have the ability to arm or disarm the new security

system. Plaintiff further did not have the ability to access the new security camera(s).

COMPLAINT FOR DAMAGES CORDON

8/10/18

Page 9 of 14
 35.

Porter admitted to police on June 6, 2018 that he had access to live video footage from cameras

inside of the Residence. Defendants further refused to provide information and access to the new

security system and cameras to Plaintiff. As such, Defendant McCoy had actual and constructive

knowledge of criminal activity existing on the property on July 10, 2018 due to the direct knowledge

of his employee and/or agent, Porter.

36.

At all times mentioned herein, Defendant McCoy owned and controlled the Residence.

Defendant McCoy breached his duty owed to Plaintiff not to injure her willfully or wantonly.

37.

Defendant McCoy intentionally permitted a hazardous condition to exist on the premises

when he caused the new security system and cameras to be installed at the Residence and refused to

provide information and access of said system and cameras to Plaintiff, prohibiting her ability to arm

or disarm the Residence.

38.

Defendant McCoy breached his duty to use ordinary care to protect Plaintiff from dangerous

activities being conducted at the Residence. By changing the security system and preventing

Plaintiff’s access thereto, Defendants effectively left Plaintiff and her minor children defenseless in

their own home.

39.

Defendants are liable for the assault, battery, and intentional infliction of emotional distress

suffered by the Plaintiff. Said assault, battery, and emotional distress were inflicted upon Plaintiff

without necessity, privilege, or consent.

COMPLAINT FOR DAMAGES CORDON

8/10/18

Page 12 of 14
 40.

Defendant’s wanton conduct was a cause in fact and the proximate cause of the injuries

suffered by Plaintiff during the home invasion at the Residence on July 10, 2018.

41.

As a result of Defendants’ wanton conduct, Plaintiff is entitled to recover for the injuries

sustained, pain and suffering, expenses of treatment, costs of future care and treatment, lost wages

and ability to labor, and all remaining elements of damages allowed under Georgia Law, including

special damages, compensatory damages, consequential damages, and economic damages.

42.

Plaintiff is entitled to an award of punitive damages without restriction or cap, because the

actions of Defendants and their agents and/or employees showed willful misconduct, malice,

wantonness, and an entire want of care, which raise the presumption of conscious indifference to the

consequences, equivalent in spirit to actual intent to cause harm.

43.

Because Defendants’ bad faith and stubborn litigiousness has caused Plaintiff undue expense,

Plaintiff is entitled to recover her necessary expenses of litigation, including an award of reasonable

attorney’s fees and expenses on account, required by this action pursuant to O.C.G.A. § 13-6-11.

Additionally, Plaintiff is entitled to all expenses of litigation and attorney’s fees on account pursuant

to all applicable statutory law.

44.

Plaintiff hereby specifically reserves the right to amend her Complaint for Damages to include

additional grounds for recovery if the parties do not settle this case immediately.

COMPLAINT FOR DAMAGES CORDON

8/10/18

Page 13 of 14
 WHEREFORE, Plaintiff prays:

a) That process issue;

b) That Defendants be served as the law provides;

c) That the case be heard by a jury;

d) That Plaintiff be awarded special, general, compensatory, punitive, and all further

permissible damages in harmony with the enlightened conscience of an impartial jury;

e) That Plaintiff be awarded attorney’s fees on account and expenses of litigation; and

f) That Plaintiff be awarded such other and further relief as this Court deems necessary

and proper.

RESPECTFULLY SUBMITTED, this 10th day of August, 2018.

3212 Northlake Parkway, N.E. THE LAW OFFICE OF

Box 450929 TANYA MITCHELL GRAHAM, P.C.
Atlanta, Georgia 31145 Attorneys for Plaintiff
770.492.9013 Telephone
770.492.9017 Facsimile

Tanya Mitchell Graham, Esquire

Georgia Bar No.: 513595
Demetrius J. Price, Esquire
Georgia Bar No.: 518237

COMPLAINT FOR DAMAGES CORDON

8/10/18

Page 14 of 14
 THE LAW OFFICE 0F
TANYA MITCHELL GRAHAM,P. C.
3212 NORTHLAKE PKWY, N.E.
Box 450929
Omen (770)492.9013

MW
ATLANTA, GEORGIA 31145
FACSIMILE (770) 492-9017

August 7, 201 8

Michael LaScala, Esquire

75 W. Wieuca Road, N,E.
Atlanta, Georgia 30342

RE: LeShawn McCoy v. Belicia Cordon

Case No: 1 8ED078693
FINAL DEMAND FOR STOLEN FURNITURE
PERSONAL PROPERTY
AND DAWGED
Dear Attorney LaScala:

Last week, this office informed you that Ms. Cordon

has lefl the residence shared with Mr.
McCoy; however, Ms. Cordon still needed to retrieve some
of her items fiom said residence. Since
then, your client has changed the locks to the residence;
thus, preventing Ms, Cordon fiom
retrieving the remaining items, Which include photos
of her children throughout the years and
of her son’s personal items. This case is still pending and
some
this constructive eviction by your client is
illegal. Our client hereby demands that her remaining personal photogaphs and
her son’s personal
items be returned immediately.

In addition to your client having his family and

friends remove Ms‘ Cordon’s couch,
table,
and two (2) area rugs from the residence on June 1, 2018,
your client’s family, friends and laborers
caused criminal damage to Ms. Gordon’s dining room table,
kitchen table, and two chairs that
she
paid for during the wrongful eviction.

ACCORDINGLY, PLEASE TAKE NOTICE that if your client does not make
arrangements through your office to return Ms. Gordon’s
furniture and persona] items, or
cost of same, by the close of business on this
pay for the
Thursday, August 9, 2018, then a cn'minal
wanant
shall be filed against all persons on the security
video footage from June 1, 2018,
who were
involved in the thefi of client’s personal property.

PLEASE TAKE FURTHER NOTICE that if your client

does not compensate our client for
the criminal damage to her fiJmiture that was moved out of the house on June
15‘,
moved back into
the house in the basement on June 15‘ (which our
client had moved upstairs on
June 4th), and then
thrown back into the basement on June 5m by Tamarcus Porter
and Thomas Williams, then please
take notice that criminal wanants will be filed against all
parties involved.

E] COP EXHIBIT
5208

No.

Blumberq

A
 Michael LaScala. Esquire
fmAL g‘igéiND FOR S TOLEN FURNITURE AND DAMA GED PERSONAL PR OPERTY
.ugust
Page 2
n
",

Should yofir client decide to reimburse our client for the

‘ V
dama ge to her r0 e she Is ',
'

gathermg the rgcelpts for the ogst of the damaged kitchen table, dining
room table,pan§ twig) chairs
Should your. chent fimher decxde to pay for our client’s fumiture that
was stolen on June 15‘ for.
your convemence, I have attached the receipts and pictures of Ms. Gordon’s
fumjture that wereasent
t0 you last week. -

PLEASE HA VE YOUR CLIENT GO VERN HIMSELFA CCORDINGLX

Tanya Mitchell Graham, Esquire

Kiarra L. Brown, Esquire

TMG/KLB/kj

Enclosures

Cc: Addressec (via electronic mail and certified mail, w/ encls.)

Delicia Cordon (via electronic mail, w/ encls.)
 W
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 THE LAW OFFICE 0F
TANYA MITCHELL GRAHAM, P. C.
3212 NORTHLAEE PKWY N.E.
Box 4.50929
OFFICE (770) 4-92-9018 ATLANTA, GEORGIA 31145 FACSDma (770) 4492-9017
www.tmgesq.com

August 8, 20 1 8

VIA CERTIFIED MAIL

RETURN RECEIPT N0.: 7018 0680 0000 1719 1195

Don F. Samuel, Esquire

Garland, Samuel & Loeb, P.C.
3 151 Maple Drive, N.E.
Atlanta, Georgia 30305

RE: NOTICE OF REPRESENTATION AND DEMAND FOR HOMEOWNER’S

INSURANCE POLICY INFORMATION/VERIFICATION OF INSURANCE
COVERAGE
YOUR CLIENT: LESHAWN MCCOY
OUR CLIENTS: DELICIA CORDON and ELIZABETH DONALD
DATE OF LOSS: JULY 10, 2018
LOCATION OF LOSS: 392 HICKORY PASS, MILTON, GEORGIA 30004
Dear Mr. Samuel:

As you may know, Firm has been retained by Delicia Cordon and Elizabeth Donald as legal
this
counsel
to representthem regarding personal injuries and other damages they both suffered as
a result of an
incident that occuned on a property owned by your client, Leshawn
McCoy, on July 10, 2018. Ms.
Cordon and Ms. Donald were injured during a home invasion at 392 Hickory
Pass, Milton, Georgia
30004. Any and all communications regarding this matter should be directly to this
office. '

I am certain that you are aware that this Firm is further representing Ms. Cordon in the eviction
proceeding which was filed by Mr. Tamarcus Porter on June 6, 2018 0n behalf
of Mr. McCoy. Based
upon our information and belief, you were retained almost immediately after the home invasion that
occurred on July 10, 2018, over four (4) weeks ago. For that reason, I
was expecting t0 receive
correspondence from you by now because of the injuries that our clients suffered
in Mr. McCoy’s home,
and the fact that Ms. Cordon’s Cartier bracelets, diamond stud earrings, and ring
given to her in 201 6 as
birthday presents from Mr. McCoy were stolen. Based upon our fufiher information
and belief, Mr.
McCoy spent over One Hundred Thousand Dollars ($100,000.00) for said jewelry that was stolen.
Doesn’t he want to know what happened to that jewelry? Is he not at all
concerned that a Violent home
invasion and aggravated battery took place in his home?

As you know, Georgia Law requires Mr. McCoy to identify and provide all insurance policies available
to satisfy any and all damages related to the above-referenced incident that occurred
on July 10, 2018.

FINAL REPRESENTAnoN LETrER To Am DON SAMUEmaoals

8/8/18
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 Don F. Samuel, Esquire
Garland, Samuel & Loeb, P.C.
August 8, 2018
N0 TICE 0F REPRESENTA TIONAND WRIFIQ HON 0F INSURANCE C0 VERA GE ~

Our Chants: Delicia Cordon and Elizabeth Donald

Page 2 of 3

See 0.C'.G.A. § 33—3—28. Mr. McCoy, 0r his insurance agent, is required to forward to our attention, the
name of the insurer, the name of each insured, and the limits of coverage. In the alternative, the
insurer
may provide a copy ofthe declaration page of each such policy, including excess or umbrella insurance;
Based upon our information and belief, Mr. McCoy had Ms. Gordon’s jewelry appraised, and he added
a rider to his homeowner’s insurance policy covering said jewelry. Accordingly, pleaseforward a
copy
0fthis letter to Mr. McCoy’s homeowner’s insurance agent or carrier with instructions t0 contact this
office via telephone and in writing within ten (10) days ofreceipt ofthis correspondence. If there was
no relevant valid homeowner’s insurance policy in effect on the date of the incident, Mr. McCoy must
forward a written, signed, and notarized statement to our attention stating same.

Please be further advised that this letter serves as a formal demand for the preservation of
certain
evidence relating to the above—referenced incident. We
specifically demand that the following
evidence be maintained and preserved, and not be destroyed, modified, altered, repaired,
or
changed in any manner:

1. Any and all physical evidence regarding the home invasion on July 10, 2018 at Mr. McCoy’s
residence located at 392 Hickory Pass, Milton, Georgia 30004, including the bloodied
sheets
where Ms. Cordon was physically attacked by the intruder. Mr. McCoy wrongfully changed the
locks on the residence before Ms. Cordon could completely remove all ofher belongings.
In fact,
the hearing pertaining to the eviction scheduled for Tuesday, August 14, 2018, at 1:00 p.m., at
is

which time we were going t0 address the wrongful eviction filed by Mr. Porter 0n behalf 0f
your
client. We have sent correspondence to Attorney Michael LaScala in this regard, which is
attached hereto. Attorney LaScala offered no response other than to offer Mr. McCoy‘s false
claim that Ms. Cordon took a pair of his Kobe Bryant sneakers;
2. Any and all physicalor electronic documents regarding the purchase and installation of
cameras,
alanns, and/or any other security or monitoring devices and/or services from.

'_ __
or any other security provider, regarding the residence at 392
Hickory Pass, Milton, Georgia 30004 from June 1, 2018, going forward;
3. Any and all photographs or surveillance videos from any security 0r monitoring system regarding
the residence at 392 Hickory Pass, Milton, Georgia 30004 on July 9-10, 2018;
4. Incident reports, witness statements, and other documentation regarding the
July 10, 201 8 home
invasion at Mr. McCoy’s home located at 392 Hickory Pass, Milton, Georgia 30004;
5. Any other documentary or tangible evidence referencing, concerning, or describing the home
invasion at Mr. McCoy’s home on July 10, 2018;
6. Any and all audio or video recordings, or documents related to the above-referenced home
invasion at Mr. McCoy’s home located at 392 Hickory Pass, Milton, Georgia 30004 n
July 10,
201 8; and
7. Any and audio or video recordings, or documents establishing or disproving Mr. McCoy’s
all

above-referenced home invasion at that occuned at his home located at

liability for the
392
Hickory Pass, Milton, Georgia 30004 n July 10, 201 8.

FINAL REPRESENTATION LETTER TO ATTY. DON SAMUELOSOSIB

8/8/18
 Don F. Samuel, Esquire
Garland, Samuel & Locb, P.C.
August 8, 201 8
NOTICE OFKEPRESENTA TIONAND VERIFICATION OFJZVSURANCE C0 VERAGE
Oux Clients: Delicia Cordon and Elizabeth Donald
Page 3 of 3

If your client fails to preserve these items, he will be contributing to the destruction 0f
evidence critical
to this matter, and subjecting himself t0 substantial legal consequences. Mr. McCoy’s failure
to preserve
and maintain the requested evidence may result in the imposition of legal sanctions. See R.A. Siege] C0.
v. Bowen,_246 Ga. App. 177 (2000).

As the above statute, please produce the Declaration page 0f Mr. McCoy’s homeowner’s
directed by
insurance policy for the residence located at 392 Hickory Pass, Milton, Georgia 30004
by the close 0f
business on tomorrow, August 9, 2018. Alternatively, please provide a notarized statement
of a
corporate officer or claims manager of the insurance company, indicating the name of the
insurer, the
name of each insured, the policy number(s) for any and all policies of insurance insuring Mr. McCoy’s
residence and the contents therein, including, but not limited to any excess or umbrella
riders to said
homeowner’s insurance, and the policy’s limits ofcoverage. Ifwe do not receive
any response from your
office or your client’s insurance carrier by the close ofbusiness on tomorrow, August
9, 2018, further
legal remedies will be pursued immediately.

If you have any questions or concerns regarding this matter, do not hesitate to contact one of us directly.

1L4 VE Y0 UR CLIENT G0 VERN HIMSELFACCORDINGL Y.

Sincerely,

THE LAW OFFICE OF

TANYA MITCH;LL GRAHAM, P.C.

Tanya Mitchell/G

Demetrius}. Price, Esquire

TMG/DJP/al

Enclosures

Cc: Garland, Samuel & Loeb, P.C. (via e-mail: w/ encls.)

Delicia Cordon (via electronic mail, w/ encls.)
Elizabeth Donald (via electronic mail, w/ encls.)

FINAL REPRESENTATION LETTER TO ATTY. DON SAMUELDBOMS

8/8/18