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State Court of Fulton County

**E-FILED**
18EV003863
10/2/2018 1:13 PM
LeNora Ponzo, Clerk
Civil Division
IN THE STATE COURT OF FULTON COUNTY
STATE OF GEORGIA

DELICIA CORDON,

Plaintiff,

CIVIL ACTION FILE NO:


V.

18EV003863
LESHAWN KAMEL MCCOY, :

TAMARCUS JEROD PORTER, and LKM :

TRUST, '

Defendants.

PLAINTIFF’S FIRST AMENDED AND RECAST COMPLAINT FOR DAMAGES

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

her counsel ofrecord and pursuant t0 O.C.G.A. § 9-1 1-1 5(a), and prior to the entry of a pretrial order,

files this, her FIRST AMENDED AND RECAST COMPLAlNT FOR DAMAGES against Defendants

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

this Honorable Court as follows:

THE PARTIES. JURISDICTION AND VENUE

1.

This is a civil action seeking money damages against Defendants LESHAWN KAMEL
MCCOY, TAMARCUS JEROD PORTER and LKM TRUST, who are all joint tortfeasors causing

1
Defendant LeShawn Kamel McCoy’s first name is “LeShawn” on his driver’s license according to Plaintiffs
spelled
personal knowledge. Further, the same is spelled “LeShawn” on the application for eviction filed by Defendant
McCoy’s personal assistant, Defendant Tamarcus Porter, on or about June 6, 2018.

Belicia Cardon v. LeShawn McCoy, et al.


State Court of Fulton County
Civil Action File No. 18EV003863
Plaintifl’s First Amended and Recast Complaintfar Damages
Page 1 of 29
multiple injuries t0 the Plaintiff. Said injuries were sustained at 392 Hickory Pass, Milton, Georgia

30004, located in Fulton County.

2.

PlaintiffDELICIA CORDON is a self—made fashion designer and entrepreneur. In October,

2016, Plaintiff relocated to 392 Hickory Pass, Milton, Fulton County, Georgia 30004 (hereinafter

referred to sometimes as, the “Residence”), where she resided until on 0r about July 15, 201 8.

3.

Defendant LESHAWN KAMEL MCCOY (hereinafter referred to sometimes as,

“McCoy”) works in Buffalo, New York as a running back in the National Football League (NFL)

employed by the Buffalo Bills. Said Defendant controls the real property located at 392 Hickory

Pass, Milton, Fulton County, Georgia 30004 as the Trustee for Defendant LKM TRUST. McCoy
would reside at said real property during the NFL off—seasons. Defendant MCCOY, along with

Defendant PORTER, are joint tortfeasors who committed van'ous intentional torts as well as

negligent acts and/or omissions, which occurred at said Residence. Accordingly, McCoy is subject

to the jurisdiction and venue 0f this Honorable Court. McCoy may be served with a Summons and

a copy of this Complaint at his most notorious place 0f abode, or at any place where McCoy may

be found.

4.

Defendant TAMARCUS JEROD PORTER (hereinafier referred t0 as, “Porter”), is the

personal assistant 0f McCoy. Porter once occupied a bedroom in the real property located at 392

Hickory Pass, Milton, Fulton County, Georgia 30004. Defendant PORTER, along with Defendant

MCCOY, are joint tortfeasors who committed various intentional torts as well as negligent acts

Delicia Cordon v. LeShawn McCoy, et at.


State Court of Fulton County
Civil Action File No. 18EV003863
Plaintiff’s First Am ended and Recast Complaintfor Damages
Page 2 0f 29
and/or omissions, which occurred at said Residence. Accordingly, Porter is subj ect t0 the

jurisdiction and venue 0f this Honorable Court. Porter may be served with a Summons and a copy

of this Complaint at his most notorious place of abode, or at any place where Porter may be found.

5.

Defendant LKM TRUST (hereinafter referred to as, “LKM Trust”) is a grantor trust that

owns the real property located at 392 Hickory Pass, Milton, Fulton County, Georgia 30004. Said

Defendant may be served with a Summons and a copy of this Complaint upon the Trustee for said

Defendant, at any place where the Trustee for this Defendant said may be found. Alternatively, the

Trustee for this Defendant may acknowledge service of process for said Defendant as Trustee for

Defendant KLM Trust. Upon information and belief. Defendant McCoy is the sole Trustee for

LKM Trust.

6.

After discovery is conducted in this litigation, there may be one (1) 0r more party

Defendants added t0 this action and/or substituted as party Defendant(s) to this action.

INTRODUCTION

7.

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

ofbliss. 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.

Delicia Cordon v. LeShawn McCoy, et al.


State Court of Fulton County
Civil Action File No. 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages
Page 3 of 29
8.

Throughout Plaintiff’s 5-year acquaintance with McCoy and at all times relevant hereto,

Porter has always been McCoy’s personal assistant, overseeing the personal and business affairs

of McCoy. Porter has been substantially and directly involved in all 0f McCoy’s personal and

business matters. McCoy and Porter have been friends since playing football together during

college.

9.

At the beginning of the parties’ relationship, Plaintiff was a resident 0f Cobb County,

Georgia, and McCoy did not reside in the state of Georgia at all. Upon Plaintiff’s information and

belief, at that time, McCoy always maintained a home in Harrisburg, Pennsylvania, a condo in

Miami, Florida, and an apartment in Buffalo, New York.

10.

In August, 201 6, McCoy showered Plaintiff with multiple gifts for her birthday. Said gifis

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

gifts. McCoy has admitted that he gave Plaintiff several items ofjewelry for her birthday in 201 6.

Later in the relationship, McCoy would demand the return of these same gifis Whenever he and

Plaintiff had a disagreement.

11.

Around this time, McCoy and Plaintiff discussed living together, and McCoy promised t0

buy Plaintiff a home. Plaintiffbegan looking for a home during the 2016 NFL season.

Delicia Cordon v. LeShawn McCoy, et a1.


State Court of Fulton County
Civil Action File No. 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages
Page 4 of 29
8.

Throughout Plaintiff’s 5-year acquaintance with McCoy and at all times relevant hereto,

Porter has always been McCoy’s personal assistant, overseeing the personal and business affairs

of McCoy. Porter has been substantially and directly involved in all 0f McCoy’s personal and

business matters. McCoy and Porter have been friends since playing football together during

college.

9.

At the beginning of the parties’ relationship, Plaintiff was a resident 0f Cobb County,

Georgia, and McCoy did not reside in the state of Georgia at all. Upon Plaintiff’s information and

belief, at that time, McCoy always maintained a home in Harrisburg, Pennsylvania, a condo in

Miami, Florida, and an apartment in Buffalo, New York.

10.

In August, 201 6, McCoy showered Plaintiff with multiple gifts for her birthday. Said gifis

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

gifts. McCoy has admitted that he gave Plaintiff several items ofjewelry for her birthday in 201 6.

Later in the relationship, McCoy would demand the return of these same gifis Whenever he and

Plaintiff had a disagreement.

11.

Around this time, McCoy and Plaintiff discussed living together, and McCoy promised t0

buy Plaintiff a home. Plaintiffbegan looking for a home during the 2016 NFL season.

Delicia Cordon v. LeShawn McCoy, et a1.


State Court of Fulton County
Civil Action File No. 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages
Page 4 of 29
Porter, the home intruder, and others, occurred at the Residence, including, but not limited to, the

home invasion, aggravated battery, and armed robbery which occurred at the Residence on July

10, 201 8.

15.

Plaintiff and her children moved into the Residence in October, 201 6, during the 201 6 NFL

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

purchased new furniture and furnishings for the Residence in 201 6. Plaintiff completely furnished

the entire Residence and by the time the 2016 NFL season ended, and McCoy came home t0 a

fully-furnished home with the Plaintiff.

16.

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

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

McCoy. First, Defendant McCoy became physically abusive to Plaintiff. McCoy is extremely

strong and was heavy-handed. He would ofien grab Plaintiff in a manner that was painful and

would leave Plaintiff s skin reddened. McCoy did not care who was around when he would become

enraged. McCoy once physically kicked Plaintiff out of the bed. To make up for his behavior,

McCoy would often apologize and even buy Plaintiffs gifts. Because she truly loved McCoy, and

she believed that he truly loved her, Plaintiff sought t0 make their relationship work despite the

fact that McCoy was physically abusive to her. Further, Plaintiff did not want to cause hurt or

damage to McCoy’s reputation as a professional football player, and she never revealed the

alarming realities 0f being in a relationship with McCoy before filing the instant litigation.

Delicia Cordon v. LeShawn McCoy, et al.


State Court of Fulton County
Civil Action File No. 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages
Page 6 of 29
17.

The offseason following the 2016 NFL season was also turbulent because McCoy would

constantly allow Porter and McCoy’s other male fn’ends to come and g0 into the Residence,

unannounced and without Plaintiff’s knowledge 0r consent. Porter even began to sporadically

occupy the bedroom directly above the master bedroom in the Residence. Plaintiff has a young

daughter and a minor son, and Plaintiff was very uncomfortable with the various men coming in

and out 0f the Residence without notice. However, Plaintiff tolerated this atmosphere during the

NFL offseason for the sake 0f maintaining stability and continuity in the lives of her children.

18.

Then, McCoy’s behavior became even more erratic during that 2016 NFL offseason as he

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

McCoy did not care who was present When he beat his dog. On one occasion, McCoy beat his dog

so badly, upon Plaintiff‘s belief, the dog’s ribs had broken. Whenever Plaintiff expressed concern

about McCoy beating his dog, he would turn his anger against the Plaintiff, often grabbing Plaintiff

and hurting her. The parties had numerous arguments over how McCoy beat his dog. When the

parties argued, McCoy would demand the return ofjewelry that he had given t0 Plaintiff for her

birthday. Thereafter, Plaintiff began t0 keep the majority of her jewelry in her safe deposit box, 0r

at one 0f her friend’s homes to avoid McCoy attempting to take the jewelry back when she was

either sleeping or not at home. Despite the turbulence of this relationship, Plaintiff never reported

McCoy’s violent behavior t0 any authorities because she, nonetheless, loved McCoy and wanted

to maintain her relationship with him. As stated hereinabove, Plaintiff did not want t0 cause hurt

or damage to McCoy’s reputation as a professional football player despite the fact that the home

Delicia Cordon v. LeShawn McCoy, et al.


State Court of Fulton County
Civil Action File No. 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages
Page 7 of 29
Porter, the home intruder, and others, occurred at the Residence, including, but not limited to, the

home invasion, aggravated battery, and armed robbery which occurred at the Residence on July

10, 201 8.

15.

Plaintiff and her children moved into the Residence in October, 201 6, during the 201 6 NFL

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

purchased new furniture and furnishings for the Residence in 201 6. Plaintiff completely furnished

the entire Residence and by the time the 2016 NFL season ended, and McCoy came home t0 a

fully-furnished home with the Plaintiff.

16.

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

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

McCoy. First, Defendant McCoy became physically abusive to Plaintiff. McCoy is extremely

strong and was heavy-handed. He would ofien grab Plaintiff in a manner that was painful and

would leave Plaintiff s skin reddened. McCoy did not care who was around when he would become

enraged. McCoy once physically kicked Plaintiff out of the bed. To make up for his behavior,

McCoy would often apologize and even buy Plaintiffs gifts. Because she truly loved McCoy, and

she believed that he truly loved her, Plaintiff sought t0 make their relationship work despite the

fact that McCoy was physically abusive to her. Further, Plaintiff did not want to cause hurt or

damage to McCoy’s reputation as a professional football player, and she never revealed the

alarming realities 0f being in a relationship with McCoy before filing the instant litigation.

Delicia Cordon v. LeShawn McCoy, et al.


State Court of Fulton County
Civil Action File No. 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages
Page 6 of 29
Plaintiff accompany him t0 a court hean'ng with his son’s mother in Harrisburg, PA. Although

Plaintiff did not testify for McCoy at that hearing, Plaintiffwas present in the courtroom as McCoy

told the Dauphin County, PA judge at the hearing What a great father he was to his son, and how

great of a mother the Plaintiff is t0 her two children. McCoy further told the judge that Plaintiff

treated his son very well. McCoy denied that he had ever physically abused his son, but both his

son’s mother and Plaintiff knew that claim was untrue. On more than one occasion, McCoy has

sent his son back t0 his mother after a Visitation period with bruises, which the boy’s mother has


confirmed (See Aflz‘davit ofStephanie Maisonet, attached hereto as Exhibit “A and incorporated

herein by this reference.) McCoy presents very well publicly, and the hearing was successful for

McCoy despite the fact that he lied about physically abusing his son. Plaintiff does not deny that

McCoy would treat his son very good on occasion, and McCoy would even treat Plaintiff’s

children well at times. However, when McCoy became enraged about even the smallest thing, he

would unreasonably strike his son.

21.

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 0n Plaintiff, so McCoy promised t0 purchase the earrings for her. Plaintiff

was ecstatic about her new earrings.

22.

McCoy did not reside at the Residence during most 0f the 2017 NFL season, and there

were no incidents between the parties during that time. However, by the summer of 2017, Plaintiff

and McCoy would argue again over McCoy beating his dog and beating his son frequently, as well

Belicia Cordon v. LeShawn McCoy, et al.


State Court
of Fulton County
Civil Action File No. 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages
Page 9 of 29
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 in Las Vegas. Once both parties returned to Atlanta, Plaintiff left

the Residence to go Visit one ofher friends. About an hour after Plaintifflefi the Residence, McCoy

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

Porter to begin t0 unlawfully remove Plaintiffs personal belongings from the Residence. When

police arrived on the scene it was explained t0 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

2017 eviction against the Plaintiff on 0r about July 3, 2017. At this time, McCoy demanded that

Plaintiff return the jewelry that he had given her. When Plaintiff discovered that McCoy never

actually purchased the diamond hoop earrings, she returned the eam'ngs to McCoy immediately in

July, 2017 so that he could return them to the jeweler. The parties ultimately reconciled their

relationship shortly afier this incident and stayed together. The 2017 eviction proceedings were

not pursued by McCoy any further.

23.

During the 2017 NFL offseason, McCoy returned to the Residence with Plaintiff and her

children. Their relationship seemed back on track (See, Instagram post ofPlaintijj’ and McCoy

from February, 2018, attached hereto as Exhibit “B and incorporated herein by this reference),

but that was short lived. The panics broke up again in April, 201 8; however, they got back together

shortly thereafter (See, Instagram post ofPlaintifi’and McCoyfrom May 20, 201 8, attached hereto

as Exhibit "C ” and incorporated herein by this reference). By May, 2018, the parties were even

discussing the possibility ofbecoming engaged, and they further discussed a possible engagement

Delicia Cordon v. LeShawn McCoy, et al.


State Court of Fulton County
Civil Action File No. 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages
Page 10 0f 29
that she shared With McCoy, even if during the NFL offseasons, was becoming increasingly

volatile and Violent.

19.

McCoy is the father to a young son who visited the Residence in Atlanta during the NFL

off-seasons. McCoy would aggressively and physically 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. Even though McCoy’s

son was of tender years, McCoy would try to make the young boy “man up,” and McCoy would

become enraged ifhis son cried. What McCoy called a “spanking”, Plaintiffwould call a “beating.”

On one occasion, McCoy put his son in the corner for “timeout” and when his son fell asleep in

the corner, McCoy beat the child for falling asleep. Plaintiff vehemently disagreed with how

McCoy physically disciplined his son, and the panics argued about it often. McCoy would demand

that Plaintiff return the jewelry gifis that he gave her upon said arguments. McCoy would beat his

son in the presence 0f Plaintiffs children. Plaintiff has seen numerous welts and bruises 0n

McCoy’s son, but never reported it t0 the police or to the Department of Family and Children’s

Services because she was unaware 0f any conversations or agreements between McCoy and the

child’s mother regarding corporal punishment.

20.

Plaintiff thought she could help change McCoy’s Violent and aggessive behavior, and he

actually seemed to gradually change his disciplinary tactics regarding his son. However, Plaintiff

realized that McCoy only changed his physical abuse towards his son temporarily as he was

approaching court proceedings with his son’s mother. During one such period, McCoy even had

Delicia Cordon v. LeShawn McCoy, et al.


State Court of Fulton County
Civil Action File N0. 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages
Page 8 of 29
and there is no empirical evidence that McCoy can produce to show that he asked Plaintiff t0

move out 0fthe Residence prior t0 said date.

27.

On June 1, 2018, upon Viewing McCoy’s fi'iends, family and associates 0n the doorbell

camera, Plaintiff also saw an individual cover the doorbell camera with an article of clothing to

conceal the activities that were taking place at the Residence. Plaintiff instructed her neighbor to call

the authorities t0 prevent the unlawful removal ofher items flom the Residence. Police arrived 0n 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 and, to date, have not been returned to Plaintiff despite Plaintiff’s requests therefor


(See August 7, 2018 letter t0 McCoy ’s eviction attorney, attached hereto as Exhibit ”E and

incorporated herein by this reference).

28.

Apparently, in his usual erratic and unpredictable behavior, McCoy had decided that he

wanted Plaintiffto move out 0fthe Residence again, similarly to the abrupt decision McCoy made

in July, 201 7, nearly eleven (1 1) months before. This time, however, Plaintiffhad decided that her

tumultuous relationship with McCoy needed to end for good, and when she returned t0 Atlanta on

the night 0f June 1, 2018, she decided to make plans to find a new residence for herself and her

two (2) minor children. Coincidentally, McCoy had the electricity t0 the Residence disconnected

sometime on June 1, 201 8 because there was no electn'city at the Residence when Plaintiff returned

Delicia v. LeShawn McCoy, et aL


Cordon
Court of Fulton County
State
Civil Action File N04 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages

Page 12 of 29
to the Residence. Plaintiff began looking for a new home 0n June 2, 2018, the day after these

incidents took place.

29.

On June 2, 2018, according to the police audio recording 0f the 91 1 call, Porter, McCoy, and

McCoy’s mother were on a “conference call” and contacted the police so that the dispatcher could

hear all three (3) individuals during the call. The police were informed that Porter was requesting a

police escort to retrieve items from the Residence. At this time, Porter had not lived in the Residence

since the 201 7 NFL offseason. Nonetheless, Porter entered the Residence without wamjng. 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 g0 into the Residence, there

was nothing the police could do about Porter’s unlimited access t0 the Residence.

30.

On June 3, 2018, McCoy had Potter change the locks to the doors of the Residence, remove

the doorbell camera that was linked to the Plaintiff’s cell phone, and deactivate the security

monitoring service that was in place. There was nothing wrong with the cameras, and n0 apparent

reason for the cameras t0 be removed fiom the Residence. Based upon Plaintiff‘s information and

belief, McCoy had Porter remove the cameras to purposefully make Plaintiff and her minor children

feel unsafe in the Residence.

31.

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

Elizabeth Donald (hereinafter referred to as “Ms. Donald”), was at the home caring for Plaintiff‘s

minor child while Plaintiff travelled out of the country. Porter and McCoy’s other fn'end, Thomas

Delicia Cordon v. LeShawn McCoy, e1 al.


State Court of Fulton County
Civil Action File No. 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages

Page 13 of 29
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 in Las Vegas. Once both parties returned to Atlanta, Plaintiff left

the Residence to go Visit one ofher friends. About an hour after Plaintifflefi the Residence, McCoy

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

Porter to begin t0 unlawfully remove Plaintiffs personal belongings from the Residence. When

police arrived on the scene it was explained t0 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

2017 eviction against the Plaintiff on 0r about July 3, 2017. At this time, McCoy demanded that

Plaintiff return the jewelry that he had given her. When Plaintiff discovered that McCoy never

actually purchased the diamond hoop earrings, she returned the eam'ngs to McCoy immediately in

July, 2017 so that he could return them to the jeweler. The parties ultimately reconciled their

relationship shortly afier this incident and stayed together. The 2017 eviction proceedings were

not pursued by McCoy any further.

23.

During the 2017 NFL offseason, McCoy returned to the Residence with Plaintiff and her

children. Their relationship seemed back on track (See, Instagram post ofPlaintijj’ and McCoy

from February, 2018, attached hereto as Exhibit “B and incorporated herein by this reference),

but that was short lived. The panics broke up again in April, 201 8; however, they got back together

shortly thereafter (See, Instagram post ofPlaintifi’and McCoyfrom May 20, 201 8, attached hereto

as Exhibit "C ” and incorporated herein by this reference). By May, 2018, the parties were even

discussing the possibility ofbecoming engaged, and they further discussed a possible engagement

Delicia Cordon v. LeShawn McCoy, et al.


State Court of Fulton County
Civil Action File No. 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages
Page 10 0f 29
01d bedroom and/or in the attic, as well as further undisclosed activities in the basement 0f the

Residence. By the time Plaintiff met with her counsel on June 22, 201 8, Plaintiff was seeking more

time to relocate into her new residence, Which would not be ready until mid-July 2018. On June

22, 2018, Plaintiff filed her Motion t0 Quash the improper eviction proceeding filed by Porter 0n

behalf of McCoy, Porter no longer entered the Residence unannounced.

34.

On July 3, 201 8, Plaintiff left the Residence for another international trip. Ms. Donald came

to the Residence t0 care for Plaintiffs son While she would be out 0f town. Plaintiff returned to the

Residence on the evening 0f July 9, 201 8. Ms. Donald stayed at the Residence overnight.

35.

On July 10, 2018, Plaintiff and McCoy were scheduled to be in Court regarding the eviction

proceedings. That morning, between approximately 3:00 AM and 3:23 AM, a home invasion occurred
at the Residence While Plaintiff and Ms. Donald were sleeping. The assailant entered the Residence

without forcible entry. Plaintiff was startled by loud noises in the Residence in Porter’s old bedroom,

directly above her master bedroom. Plaintiff exited the master bedroom to check 0n her minor son,

whose room was located upstairs. While calling for her son, the assailant revealed himself, chased

Plaintiff back into the master bedroom and began to assault her. The assailant held Plaintiff at

gunpoint, struck Plaintiff in the face several times with his firearm, demanded specific articles of

jewelry given to Plaintiff by McCoy for her birthday in 2016, and indicated that he knew McCoy.

The assailant cut one 0f Plaintiff’s bracelets from her wrist with wire cutters, and struck Ms. Donald

on the back of the head with the gun. Once the assailant secured the jewelry that McCoy had gified

to Plaintiff in 2016 he demanded cash, but when he was informed that Plaintiff did not have cash, he

Belicia Cordon v. LeShawn McCoy, et al.


State Court of Fulton County
Civil Action File No. 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages
Page 15 of 29
put Plaintiff and Ms. Donald in a bathroom and threatened to kill them if they did not stay there. The

assailant then left in a white Chevy Malibu or white Chevy Impala.

36.

On July 10, 201 8, Plaintiff was a Victim of burglary, aggravated battery, and armed robbery.

Plaintiffwas physically struck by a firearm by the assailant who invaded the Residence. Said assailant

also physically assaulted Ms. Donald and burglarized the Residence, stealing approximately One

Hundred, Thirty-Three Thousand Dollars ($133,000. 00) in jewelry fiom the Plaintiff, most ofwhjch

was purchased by McCoy. Based upon Plaintiff’s information and belief, McCoy had insured

Plaintist jewelry; however, McCoy has yet to provide Plaintiff with the name of the correct

insurance company so that Plaintiff can file a claim to receive the value of her stolen jewelry (See

August 8, 2018 letter t0 McCoy’s criminal defense attorney, attached hereto as Exhibit “F” and

incorporated herein by this reference).

37.

In the June 6, 2018, 91 1 audio recording, Porter admitted to police 0n that he had seen people

packing because he could see them 0n the “cameras” inside of the Residence. Yet, afier the July 10,

2018, Defendants have refused to cooperate with providing information and/or access to the new

security system and cameras t0 the Milton Police. As such, Defendant McCoy had actual and

constructive knowledge of criminal activity existing 0n the property on July 10, 201 8 due t0 the direct

knowledge ofhis employee and/or agent, Porter.

38.

Plaintiff suffered numerous injuries and lacerations t0 her face and wn'st which were

proximately caused by McCoy and Porter, jointly and severally, in concert and in conspiracy with the

Delicia Cordon v. LeShawn McCoy, et a1.


State Court ofFulton County
Civil Action File No. 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages
Page 16 of 29
and there is no empirical evidence that McCoy can produce to show that he asked Plaintiff t0

move out 0fthe Residence prior t0 said date.

27.

On June 1, 2018, upon Viewing McCoy’s fi'iends, family and associates 0n the doorbell

camera, Plaintiff also saw an individual cover the doorbell camera with an article of clothing to

conceal the activities that were taking place at the Residence. Plaintiff instructed her neighbor to call

the authorities t0 prevent the unlawful removal ofher items flom the Residence. Police arrived 0n 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 and, to date, have not been returned to Plaintiff despite Plaintiff’s requests therefor


(See August 7, 2018 letter t0 McCoy ’s eviction attorney, attached hereto as Exhibit ”E and

incorporated herein by this reference).

28.

Apparently, in his usual erratic and unpredictable behavior, McCoy had decided that he

wanted Plaintiffto move out 0fthe Residence again, similarly to the abrupt decision McCoy made

in July, 201 7, nearly eleven (1 1) months before. This time, however, Plaintiffhad decided that her

tumultuous relationship with McCoy needed to end for good, and when she returned t0 Atlanta on

the night 0f June 1, 2018, she decided to make plans to find a new residence for herself and her

two (2) minor children. Coincidentally, McCoy had the electricity t0 the Residence disconnected

sometime on June 1, 201 8 because there was no electn'city at the Residence when Plaintiff returned

Delicia v. LeShawn McCoy, et aL


Cordon
Court of Fulton County
State
Civil Action File N04 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages

Page 12 of 29
“a licensee is a person who: (1) is neither a customer, a servant, nor a trespasser; (2) does not stand in

any contractual relation with the owner of the premises; and (3) is permitted, expressly or impliedly,

to go on the premises merely for [her] own interests, convenience, or gatification.” Further, at no

time has there ever been a writ 0f possession entered against Plaintiff, and there has never been any

Order evicting Plaintiff from the Residence.

42.

Defendant LKM Trust, as the owner of the Residence, is liable to Plaintiff for willful 0r

wanton injuries caused directly and indirectly by Defendants McCoy and Porter.

COUNT I— ASSAULT AND BATTERY

43.

Plaintiff hereby incorporates Paragraphs 1-42 set forth hereinabove as if each paragraph

were fully stated herein.

44.

On July 10, 2018, suddenly, without provocation 0r legal justification, and in no manner

whatsoever due to any act 0r failure to act on the part of Plaintiff, based upon Plaintist information

and belief, McCoy through his personal assistant, Porter, arranged for the assailant who attacked

Plaintiff and Ms. Donald to come into the home without forced entry to specifically retn'eve the very

same jewelry that McCoy has demanded that Plaintiff return to him 0n multiple occasions. The

intruder knew exactly what jewelry that he came to get, and the intruder began to beat Plaintiff in her

face with a handgun before even allowing her to comply with his demands as if the intruder wanted

to purposefully disfigure Plaintiff‘s face.

Delicia Cordon v. LeShawn McCoy, et aI.


State Court of Fulton County
Civil Action File No. 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages
Page l8 of 29
45.

In addition to the physical lacerations that Plaintiff suffered to her face and wrist, Plaintiffhas

been further subjected t0 great pain, humiliation, mental anguish, panic attacks, stress, and emotional

distress.

46.

Defendants are liable t0 Plaintifffor the assault, battery, and intentional infliction 0f emotional

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

Plaintiff Without necessity, privilege, or consent. Said assault and battery outlined hereinabove was

carried out unlawfully, negligently, and maliciously.

47.

As a direct and proximate result of the intentional, unlawful, reckless, and malicious acts

caused by Defendants, Plaintiff shall continue to suffer serious mental anguish, emotional distress,

and lost income, all 0f which will continue indefinitely into the future, for which Defendants should

be liable.

48.

Further, McCoy should be held liable and responsible for the intentional and negligent, acts

and omissions of his employees, agents, servants, workers, and representatives such as Porter.

WHEREFORE, Plaintiff respectfully requests judgment against Defendants for damages

suffered from the assault and battery that occurred on July 10, 201 8, at the Residence in an amount to

be proven at tn'al, but in n0 event less than Ten Million Dollars ($10,000,000.00), and that Plaintiff

be awarded such additional relief as this Honorable Court deems just and appropriate under the

circumstances.

Belicia Cordon v. LeShawn McCoy, et aL


State Court of Fulton County
Civil Action File No. 18EV003863
Plaintiffs First Amended and Recast Complaintfor Damages
Page 19 0f 29
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, Plaintiffwas not informed 0fthe new security codes and did

not have the ability to aIm 0r disarm the new secun'ty system. Plaintiff further did not have the ability

to access the new security camera(s). Based upon Plaintiff’s information and belief, McCoy had

Porter withhold access to the new security system and new security camera(s) t0 purposefully make

Plaintiff and her minor children feel unsafe in the Residence.

32.

On June 6, 2018, according t0 the police audio recording of the 911 call, Porter and McCoy

called police together 0n 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. McCoy and Porter were on the

call to police attempting to get Ms. Donald and Plaintiff‘s teenage son removed fiom the Residence

while Plaintiff was out 0f the country. After Ms. Donald communicated with the Milton Police who

arrived on the scene, Porter and McCoy were informed that they could not lawfully put Plaintiff s son

out 0fthe Residence because he lived there, and Porter and McCoy could not lawfully put Ms. Donald

out 0f the Residence because Ms. Donald 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.

33.

Porter entered the residence, unannounced on June 8, 201 8, and again, accompanied by

Williams on June 19, 2018. Porter and Williams were involved in undisclosed activities in Porter’s

Delicia Cordon v. LeShawn McCoy, et aL


State Court of Fulton County
Civil Action File No. 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages
Page 14 0f 29
53.

Further, McCoy should be held liable and responsible for Porter’s breach of duty owed t0

licensees at the Residence, as McCoy’s employee, agent, servant, worker, and representative.

WHEREFORE, Plaintiff respectfully requests judgment against Defendants for damages

suffered based upon a breach 0f duty of care owed to Plaintiff as a licensee in the Residence in an

amount to be proven at trial, but in n0 event less than Ten Million Dollars ($10,000,000.00), and that

Plaintiff be awarded such additional relief as this Honorable Court deems just and appropriate under

the circumstances.

COUNT III —THEFT OF PEIJLSONAL PROPERTY


AND DAMAGE TO PERSONAL PROPERTY
54.

Plaintiff hereby incorporates Paragraphs 1-53 set forth hereinabove as if each paragraph

were fully stated herein.

55.

McCoy caused Porter t0 remove Plaintiff’s personal property, furniture, and fumishings fiom

the Residence on June 1, 2018. Even though Police advised Porter to return Plaintiffs personal

property, fumiture, and filmishings into the Residence, Plaintiff‘s couch, coffee table, and two (2)

area rugs, which were valued at approximately Thirteen Thousand Dollars ($13,000.00) were not

returned t0 the Plaintiff at any time relevant hereto.

56.

Approximately One Hundred, Thirty-Three Thousand Dollars ($133,000.00) in jewelry

owned by Plaintiff which was gified to her by McCoy was stolen by a home intruder into the

Residence on July 10, 2018 as a direct and proximate result of Defendant McCoy’s and Defendant

Delicia Cordon v. LeShawn McCoy, et al.


State Court ofFulton County
Civil Action File N0. 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages
Page 21 of 29
LKM Trust’s failure t0 make the Residence secure, which is a duty Defendants owned to Plaintiff as
a licensee.

57.

McCoy should be held liable and responsible for the breach of duty owed to Plaintiff as a

licensee at the Residence, and McCoy should be ordered to pay Plaintiff for her jewelry, furniture,

and furnishings stolen at the Residence on July 1, 201 8 and July 10, 201 8, respectively.

WHEREFORE, Plaintiff respectfully requests judgment against Defendants McCoy and

LKM Trust for damages suffered based upon a breach of duty owed to Plaintiff as a licensee in the

Residence in the amount of One Hundred, Forty-Six Thousand Dollars ($146,000.00), and that

Plaintiff be awarded such additional relief as this Honorable Court deems just and appropriate under

the circumstances.

COUNT IV — NEGLIGENCE
58.

Plaintiff hereby incorporates Paragraphs 1-57 set forth hereinabove as if each paragraph

were fully stated herein.

59.

Defendants’ negligent and wanton conduct was a cause in fact and the proximate cause 0fthe

multiple injuries suffered by Plaintiff during the home invasion at the Residence 0n July 10, 201 8.

60.

As a result of Defendants’ negligent and wanton conduct, Plaintiff is entitled t0 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 0f damages allowed under Georgia Law,

Delicia Cordon v. LeShawn McCoy, et al.


State Court of Fulton County
Civil Action File No. 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages
Page 22 0f 29
put Plaintiff and Ms. Donald in a bathroom and threatened to kill them if they did not stay there. The

assailant then left in a white Chevy Malibu or white Chevy Impala.

36.

On July 10, 201 8, Plaintiff was a Victim of burglary, aggravated battery, and armed robbery.

Plaintiffwas physically struck by a firearm by the assailant who invaded the Residence. Said assailant

also physically assaulted Ms. Donald and burglarized the Residence, stealing approximately One

Hundred, Thirty-Three Thousand Dollars ($133,000. 00) in jewelry fiom the Plaintiff, most ofwhjch

was purchased by McCoy. Based upon Plaintiff’s information and belief, McCoy had insured

Plaintist jewelry; however, McCoy has yet to provide Plaintiff with the name of the correct

insurance company so that Plaintiff can file a claim to receive the value of her stolen jewelry (See

August 8, 2018 letter t0 McCoy’s criminal defense attorney, attached hereto as Exhibit “F” and

incorporated herein by this reference).

37.

In the June 6, 2018, 91 1 audio recording, Porter admitted to police 0n that he had seen people

packing because he could see them 0n the “cameras” inside of the Residence. Yet, afier the July 10,

2018, Defendants have refused to cooperate with providing information and/or access to the new

security system and cameras t0 the Milton Police. As such, Defendant McCoy had actual and

constructive knowledge of criminal activity existing 0n the property on July 10, 201 8 due t0 the direct

knowledge ofhis employee and/or agent, Porter.

38.

Plaintiff suffered numerous injuries and lacerations t0 her face and wn'st which were

proximately caused by McCoy and Porter, jointly and severally, in concert and in conspiracy with the

Delicia Cordon v. LeShawn McCoy, et a1.


State Court ofFulton County
Civil Action File No. 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages
Page 16 of 29
Plaintiff’s phone alerted her any time someone entered the Residence. Defendant McCoy was

aware of this feature 0n Plaintiff’s phone. On July 10, 2018, Plaintiff did not receive an alert

regarding the assailant unlawfully entering the Residence, due to the actions 0f Defendant Porter

at the direction of Defendant McCoy. Neither McCoy nor Porter were living in the Residence at

the time, and neither McCoy nor Porter live in the Residence now. As stated herein about, Porter

n0 longer occupied a room at the Residence at the time 0f the home invasion, aggravated battery

and armed robbery that took place on July 10, 201 8, and McCoy has never principally lived in

Georgia, had a Georgia driver’s license or a Georgia voter registration. McCoy only stayed at the

Residence for a portion of the NFL offseason each year.

65.

Defendants had exclusive control 0f the Residence wherein Plaintiff suffered her injuries.

66.

As a direct and proximate result of the negligence 0f the Defendants, Plaintiff shall continue

to suffer serious mental anguish, emotional distress, and lost income, all of which will continue

indefinitely into the future, for which Defendants should be liable.

67.

Further, McCoy should be held liable and responsible for the negligent acts and omissions of

his employees, agents, servants, workers, and representatives such as Porter.

WHEREFORE, Plaintiff respectfully requests judgment against Defendants for damages

suffered from as a result 0f the negligence 0fthe Defendants in an amount to be proven at tn'al, but in

n0 event less than Ten Million Dollars ($10,000,000.00), and that Plaintiff be awarded such

additional relief as this Honorable Court deems just and appropriate under the circumstances.

Delicia Cordon v. LeShawn McCoy, et al.


State Court 0f Fulton County
Civil Action File N0. 18EV003863
Plaintiffs First Amended and Recast Complaintfor Damages
Page 24 of 29
COUNT V — INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

68.

Plaintiff hereby incorporates Paragraphs 1-67 set forth hereinabove as if each paragraph

were fully stated herein.

69.

The assault and battery, theft 0f Plaintiff’s furniture and furnishings, home invasion,

aggravated battery, armed robbery of Plaintiff’s jewelry, negligence, and other wrongful acts and/or

omissions committed by McCoy and Porter constitute extreme and outrageous conduct, which were

inflicted upon Plaintiff intentionally 0r recklessly for the purpose of cause Plaintiff emotional distress.

70.

McCoy is vicariously liable and otherwise responsible for the intentional, negligent, and

tortious acts or failures to act committed by his employees, agents, agents, servants, workers, and

representatives, including Porter. Plaintiff has been subjected to great pain, humiliation, mental

anguish, panic attacks, stress, and emotional distress due to the actions or inactions of Porter as

directed by McCoy.

71.

Defendants McCoy and Porter are liable t0 Plaintiff for the intentional infliction of emotional

distress suffered by the Plaintiff. Said emotional distress was inflicted upon Plaintiff without

necessity, privilege, 0r consent. Said intentional infliction 0f emotional distress outlined hereinabove

was carried out unlawfully, negligently, and maliciously.

Delicia Cordon v. LeShawn McCoy, et al.


State Court of Fulton County
Civil Action File No. 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages

Page 25 of 29
“a licensee is a person who: (1) is neither a customer, a servant, nor a trespasser; (2) does not stand in

any contractual relation with the owner of the premises; and (3) is permitted, expressly or impliedly,

to go on the premises merely for [her] own interests, convenience, or gatification.” Further, at no

time has there ever been a writ 0f possession entered against Plaintiff, and there has never been any

Order evicting Plaintiff from the Residence.

42.

Defendant LKM Trust, as the owner of the Residence, is liable to Plaintiff for willful 0r

wanton injuries caused directly and indirectly by Defendants McCoy and Porter.

COUNT I— ASSAULT AND BATTERY

43.

Plaintiff hereby incorporates Paragraphs 1-42 set forth hereinabove as if each paragraph

were fully stated herein.

44.

On July 10, 2018, suddenly, without provocation 0r legal justification, and in no manner

whatsoever due to any act 0r failure to act on the part of Plaintiff, based upon Plaintist information

and belief, McCoy through his personal assistant, Porter, arranged for the assailant who attacked

Plaintiff and Ms. Donald to come into the home without forced entry to specifically retn'eve the very

same jewelry that McCoy has demanded that Plaintiff return to him 0n multiple occasions. The

intruder knew exactly what jewelry that he came to get, and the intruder began to beat Plaintiff in her

face with a handgun before even allowing her to comply with his demands as if the intruder wanted

to purposefully disfigure Plaintiff‘s face.

Delicia Cordon v. LeShawn McCoy, et aI.


State Court of Fulton County
Civil Action File No. 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages
Page l8 of 29
WHEREFORE, Plaintiff respectfully requests that this Honorable Court award Plaintiff

punitive damages against the Defendants in an amount t0 be proven at trial, but in no event less than

Ten Million Dollars ($10,000,000.00), and that Plaintiff be awarded such additional relief as this

Honorable Court deems just and appropriate under the circumstances.

COUNT VII — ATTORNEY’S FEES PURSUANT T0 O.C.G.A. 8 13-6-11


>

76.

Plaintiff hereby incorporates Paragraphs 1-76 set forth hereinabove as if each paragraph

were fully stated herein.

77.

Even before the filing 0f this lawsuit, specifically, since June 1, 201 8, McCoy and Porter

have acted in bad faith. McCoy caused Plaintiff’s personal property, furniture and furnishings t0

be damaged or stolen when the parties’ relationship came to an abrupt end. Then, McCoy caused

Porter to file an application for an eviction on June 6, 201 8 even though (1) McCoy was not living

in the Residence, and (2) Porter had confirmed through his cameras that Plaintiff was packing t0

relocate from the Residence. Further, since the home invasion, aggravated battery and armed

robbery that took place at the Residence 0n July 10, 2018, neither McCoy nor Porter have done

anything t0 assist in the criminal investigation relating to said brutal attack at the Residence,

wherein Plaintiff suffered serious injuries.

78.

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

Plaintiff is entitled to recover her reasonable and necessary expenses of litigation 0n account in a

Delicia Cordon v. LeShawn McCoy, et aL


of Fulton County
State Court
Civil Action File No. 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages
Page 27 of 29
minimum amount of One Hundred Thousand Dollars ($100,000.00) pursuant to O.C.G.A. § 13-6-

11.

79.

Plaintiffhereby 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.

WHEREFORE, Plaintiffprays:

a) That process issue;

b) That Defendants be served as the law provides;


C) That the case be heard by a jury;
d) That this Honorable Court enter judgment against Defendants, jointly and severally,
in favor 0f Plaintiff for damages suffered by Plaintiff as a result of the assault and
battery that occurred on July 10, 2018, at the Residence in an amount to be proven at

trial, but in no event less than Ten Million Dollars ($10,000,000. 00);
That this Honorable Court enterjudgment against Defendants McCoy and LKM Trust
in favor of Plaintiff for damages suffered by Plaintiff as a result 0f Defendant
McCoy’s and Defendant LKM Trust’s breach of duty of care owed t0 Plaintiff as a
licensee in the Residence in an amount to be proven at trial, but in no event less than
an additional Ten Million Dollars ($10,000,000. 00);
That this Honorable Court enter judgnent against Defendants, jointly and severally,
in favor of Plaintiff for damages to and theft of her personal property 0n June 1,

201 8, in an amount to be proven at trial, but in no event less than Thirteen Thousand
Dollars ($13,000. 00);

g) That this Honorable Coufi enter judgment against Defendants, jointly and severally,
in favor 0f Plaintiff for theft of her jewelry 0n July 10, 2018, in an amount t0 be
proven at trial, but in no event less than One Hundred, Thirty—Three Thousand
Dollars ($133,000. 00);
h) That this Honorable Court enter judgment against Defendants, jointly and severally,
in favor 0f Plaintiff fordamages suffered by Plaintiff as a result 0f Defendants’
negligence in an amount to be proven at trial, but in no event less than an additional
Ten Million Dollars ($10,000,000.00);
That this Honorable Court enter judgment against Defendants, jointly and severally,
in favor of Plaintiff for damages suffered by Plaintiff as a result of Defendants’
intentional infliction 0f emotional distress in an amount to be proven at trial, but in n0
event less than an additional Ten Million Dollars ($10,000,000.00);

Delicia Cordon v. LeShawn McCoy, et al.


State Court of Fulton County
Civil Action File N0. 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages
Page 28 of 29
COUNT II — PREMISES LIABILITY
49.

Plaintiff hereby incorporates Paragaphs 1-48 set forth hereinabove as if each paragraph

were fully stated herein.

50.

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

McCoy breached his duty owed t0 Plaintiff not to injure her willfillly or wantonly. McCoy

intentionally permitted a hazardous condition t0 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 t0 Plaintiff, prohibiting her ability to arm or disarm the alarm for

the Residence.

51 .

Defendant McCoy breached his duty to use ordinary care t0 protect Plaintiff from dangerous

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

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

their own home.

52.

As a direct and proximate result of Defendant McCoy’s and Defendant LKM Trust’s failure
to make the Residence safe, which is a duty Defendants owned to Plaintiff as a licensee pursuant to

O.C.G.A. § 51-3-2, Plaintiff shall continue t0 suffer serious mental anguish, emotional distress, and

lost income, all of which will continue indefinitely into the future.

Delicia Cordon v. LeShawn McCoy, et al.


of Fulton County
State Court
Civil Action File No. 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages
Page 20 0f 29
EXHIBIT “A”
State Court of Fulton County
**E-FILED**
18EV003863
8/2018 12:57 PM
9/1
LeNora Ponzo, Clerk
Civil Division
IN THE STATE COURT OF FULTON COUNTY
STATE 0F GEORGIA
DELICIA CORDON,

Plaintiff, 2 CIVIL ACTION


FILE N0.: 18EV003863
V.

LESHAWN KAMEL MCCOY, .

TAMARCUS JEROD PORTER, and :

LKM TRUST, -

Defendants.

AFFIDAVIT 0F STEPHANIE MAISONET

PERSONALLY APPEARED before me, an officer duly authorized by law to administer

oaths, STEPHANIE MAISONET, who after being duly sworn, files this Affidavit and states

the following facts:

1. My name is STEPHANIE MAISONET, and I am competent in all respects to testify

regarding the matters set forth herein. I am a United States citizen over 18 years of age. I

have personal knowledge of the facts stated herein and know them to be true. I have no

interest in the outcome of this case.

2. I am the mother of LeShawn McCoy’s six (6) year 01d son.

3. I lived at LeShawn McCoy’s residence in 201 1, until he kicked me out, along with our

son. LeShawn McCoy refused to let me back into the residence to retrieve any of our

son’s clothes. He also took back certain items that he purchased for me.

4. On July 9, 201 8, I was with LeShawn McCoy and Tamarcus Porter to receive a passport

for our son.

5. I overheard LeShawn McCoy speaking on the phone with someone in which he stated, “I

need to get this bitch out 0f my house”.


LKM Trust’s failure t0 make the Residence secure, which is a duty Defendants owned to Plaintiff as
a licensee.

57.

McCoy should be held liable and responsible for the breach of duty owed to Plaintiff as a

licensee at the Residence, and McCoy should be ordered to pay Plaintiff for her jewelry, furniture,

and furnishings stolen at the Residence on July 1, 201 8 and July 10, 201 8, respectively.

WHEREFORE, Plaintiff respectfully requests judgment against Defendants McCoy and

LKM Trust for damages suffered based upon a breach of duty owed to Plaintiff as a licensee in the

Residence in the amount of One Hundred, Forty-Six Thousand Dollars ($146,000.00), and that

Plaintiff be awarded such additional relief as this Honorable Court deems just and appropriate under

the circumstances.

COUNT IV — NEGLIGENCE
58.

Plaintiff hereby incorporates Paragraphs 1-57 set forth hereinabove as if each paragraph

were fully stated herein.

59.

Defendants’ negligent and wanton conduct was a cause in fact and the proximate cause 0fthe

multiple injuries suffered by Plaintiff during the home invasion at the Residence 0n July 10, 201 8.

60.

As a result of Defendants’ negligent and wanton conduct, Plaintiff is entitled t0 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 0f damages allowed under Georgia Law,

Delicia Cordon v. LeShawn McCoy, et al.


State Court of Fulton County
Civil Action File No. 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages
Page 22 0f 29
pending. Our son would often come heme With bruises in which I would consistently

receive outlandish excuses as to where the bruises would come from.

13. Our son would cry hysten'cally whenever he had ta spend time with LeShawn McCoy.

Our son would cxy even harder if he knew that Belicia Cordon was not going to be

present during LeShawn McCoy’s parenting time.

14. I regret ever agreeing to help LeShaWn McCoy in this case. He should not get await with

potentially orchestrating this hcinous incident.


-

15. I feel like I am sending our sen to a monster every two weeks. LeShaWn McCoy should

be held accountable fox his actions, regardlesspf his career choice or his income.

FURTHER AFFIANT SAYS NOT.

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Sworn and subscri
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NOTARY PUBLIC m nu
Plaintiff’s phone alerted her any time someone entered the Residence. Defendant McCoy was

aware of this feature 0n Plaintiff’s phone. On July 10, 2018, Plaintiff did not receive an alert

regarding the assailant unlawfully entering the Residence, due to the actions 0f Defendant Porter

at the direction of Defendant McCoy. Neither McCoy nor Porter were living in the Residence at

the time, and neither McCoy nor Porter live in the Residence now. As stated herein about, Porter

n0 longer occupied a room at the Residence at the time 0f the home invasion, aggravated battery

and armed robbery that took place on July 10, 201 8, and McCoy has never principally lived in

Georgia, had a Georgia driver’s license or a Georgia voter registration. McCoy only stayed at the

Residence for a portion of the NFL offseason each year.

65.

Defendants had exclusive control 0f the Residence wherein Plaintiff suffered her injuries.

66.

As a direct and proximate result of the negligence 0f the Defendants, Plaintiff shall continue

to suffer serious mental anguish, emotional distress, and lost income, all of which will continue

indefinitely into the future, for which Defendants should be liable.

67.

Further, McCoy should be held liable and responsible for the negligent acts and omissions of

his employees, agents, servants, workers, and representatives such as Porter.

WHEREFORE, Plaintiff respectfully requests judgment against Defendants for damages

suffered from as a result 0f the negligence 0fthe Defendants in an amount to be proven at tn'al, but in

n0 event less than Ten Million Dollars ($10,000,000.00), and that Plaintiff be awarded such

additional relief as this Honorable Court deems just and appropriate under the circumstances.

Delicia Cordon v. LeShawn McCoy, et al.


State Court 0f Fulton County
Civil Action File N0. 18EV003863
Plaintiffs First Amended and Recast Complaintfor Damages
Page 24 of 29
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EXHIBIT “C”
72.

As a direct and proximate result of the intentional infliction of emotional caused by

Defendants, Plaintiff shall continue to suffer serious mental anguish, emotional distress, and lost

income, all ofwhjch will continue indefinitely into the future, for which Defendants should be liable.

WHEREFORE, Plaintiff respectfully requests judgment against Defendants for damages

suffered from the intentional infliction 0f emotional distress in an amount t0 be proven at trial, but in

n0 event less than Ten Million Dollars ($10,000,000.00), and that Plaintiff be awarded such

additional relief as this Honorable Court deems just and appropriate under the circumstances.

COUNT VI - PUNITIVE DAMAGES


73.

Plaintiff hereby incorporates Paragraphs 1-72 set forth hereinabove as if each paragraph

were fully stated herein.

74.

Plaintiff is entitled t0 an award 0f punitive damages without restriction or cap, because the

actions 0f Defendants and their agents and/or employees showed willful misconduct, malice,

wantonness, and an entire want of care, which raise the presumption 0f conscious indifference t0 the

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

75.

As a result of such wilful conduct, wantonness, and entire want 0f care, which would raise

the presumption of conscious indifference to the consequences, Plaintiff is entitled to punitive

damages against all the Defendants pursuant to O.C.G.A.§ 51-12—5.1 er. seq.

Delicia Cordon v. LeShawn McCoy,et aL


State Court of Fulton County
Civil Action File No. 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages

Page 26 of 29
EXHIBIT “D”
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minimum amount of One Hundred Thousand Dollars ($100,000.00) pursuant to O.C.G.A. § 13-6-

11.

79.

Plaintiffhereby 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.

WHEREFORE, Plaintiffprays:

a) That process issue;

b) That Defendants be served as the law provides;


C) That the case be heard by a jury;
d) That this Honorable Court enter judgment against Defendants, jointly and severally,
in favor 0f Plaintiff for damages suffered by Plaintiff as a result of the assault and
battery that occurred on July 10, 2018, at the Residence in an amount to be proven at

trial, but in no event less than Ten Million Dollars ($10,000,000. 00);
That this Honorable Court enterjudgment against Defendants McCoy and LKM Trust
in favor of Plaintiff for damages suffered by Plaintiff as a result 0f Defendant
McCoy’s and Defendant LKM Trust’s breach of duty of care owed t0 Plaintiff as a
licensee in the Residence in an amount to be proven at trial, but in no event less than
an additional Ten Million Dollars ($10,000,000. 00);
That this Honorable Court enter judgnent against Defendants, jointly and severally,
in favor of Plaintiff for damages to and theft of her personal property 0n June 1,

201 8, in an amount to be proven at trial, but in no event less than Thirteen Thousand
Dollars ($13,000. 00);

g) That this Honorable Coufi enter judgment against Defendants, jointly and severally,
in favor 0f Plaintiff for theft of her jewelry 0n July 10, 2018, in an amount t0 be
proven at trial, but in no event less than One Hundred, Thirty—Three Thousand
Dollars ($133,000. 00);
h) That this Honorable Court enter judgment against Defendants, jointly and severally,
in favor 0f Plaintiff fordamages suffered by Plaintiff as a result 0f Defendants’
negligence in an amount to be proven at trial, but in no event less than an additional
Ten Million Dollars ($10,000,000.00);
That this Honorable Court enter judgment against Defendants, jointly and severally,
in favor of Plaintiff for damages suffered by Plaintiff as a result of Defendants’
intentional infliction 0f emotional distress in an amount to be proven at trial, but in n0
event less than an additional Ten Million Dollars ($10,000,000.00);

Delicia Cordon v. LeShawn McCoy, et al.


State Court of Fulton County
Civil Action File N0. 18EV003863
Plaintiff’s First Amended and Recast Complaintfor Damages
Page 28 of 29
EXHIBIT “E”
THE LAW OEFJCE op
TANYA MITCHELL GRAHAM, RC.
3212 NORTHLAKE PKWY,- N.E.
Box T450929
ATLANIAg GEORGIA31145
0mm r _

(77.0) 492.9013
> I I
u V. ~
’FAcsu/flm (770) 492,901?

August. 7,. 201s

Michael LaScala, Esquire


‘75 W. MeucaRoad, NnE.
Atlanta, Georgia 30342

RE: LeShawn MCC'oy'V; Belicia Cordonj


Case'No: 18ED0781693’
FINAL DEWND FOR STOLEN FURNITIRE AND
PERSONAL PROPERTY DAM GED
Dear Attorney LaScala:

LaSt W661i, this QffiCe informed


yop that Ms. Cordon has left the
residenceshared with MI,
MCCOY; however, MS- Cordon Still needed to retfieveisome of'her items fi'om
then said residence. Since
your pliant has 01.1mged the locks ’to
the residence; films, preventing
Ms. Cordon fiom

In addition to your client having his


family and fiends remove Ms_ Gordon’s
and 1W0 (2) area rugs 'fiom the rgsidence on June mushy table,
1, 2018, your client’s
family, fiends and laborers
caused criminal damage to M37 Gordon’s dining
room table, kitchen table, and two
paid for during the mon‘gful evicfion‘. chairs that. she

of same, by :fli'e close of business 6h this


cost.
Thnxédaiy, August 9, 2.018, then}
a cmnma] wanaht
shall be filed againstall persons 0n the security
video footagg fiom June
1, 20.18, who we‘re
involved in thethefi of client’spersonal ._

property. ,

PLEASE TAKE FURTHER NOTICE that if your client


does not compensateOW client
the 01111111131 damage t0 fiil’niturc that for
11561”
was moved out of thehouseon June 1'“,
the house in the bmmefit 0n June 1’“ (Which our client moved back: into
had moved upstairs ‘on' June 4‘5),
thrown back info the“ basement on June S‘h- by Tamarcus Porter and fhen
and Thomas Williams, then phage
‘take‘nptice that criminal Warrants will be ’

filed against an parties involved.»


EXHIBIT “A”
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Later that day, LeShawn McCoy was supposed t0 exercise his parenting time with our

son, pursuant to our custody agreement. I received notice through Tamarcus Porter that

he and LeShawn McCoy would be unable to pick up our son that day.

July 9, 2018 was the first time that LeShawn McCoy has gm had to reschedule picking
up our son.

On July 10, 2018, I heard about the home invasion that took place at LeShawn McCoy’s

residence.

Normally, LeShawn McCoy requires thatI speak directly With Tamarcus Porter in regard

to our son. This mangement has been in place for years.

10. Afier the home invasion, LeShawn McCoy decided to contact me directly for the first

time in years. LeShawn McCoy talked badly about Delicia Cordon and proffered that if I

help him with this home invasion, he will concede in our custody case
by allowing me to

enroll my son in school in Miami. I found this to be odd because he has been fighting so

hard against that during our custody battle. Also, if he did not have any involvement in

the home invasion, there is no need to make such an extreme offer. LeShawn McCoy’s

mother also contacted me and tried to persuade me into being a character witness for

LeShawn McCoy. Reluctantly, I agreed to help him because I believed that I was acting

in the best interest of our son.

11. I gave Tamarcus Porter my Instagram password and he wrote a comment pretending to be

me. The comment stated that the allegations about LeShawn McCoy abusing our son

were false and that Delicia Cordon was trying to ruin him.

12. However, I knew the allegations were true and even made a report about LeShawn

McCoy abusing our son to child services, prior to the home invasion. That case is still
“”F
EXHIBIT
THELAW OmCE or

NoamGm,
TANYA MITCHELL P.-C‘.
3212‘ PKWYNE.
Box 45019.29
omen (770) 492.9013 Arm GEORGIA-alms
I

FAcsnmm (770,) 492—9017


www.tmgesqcom

August 8, 2018

CERTIFIED MAIL
'VIA
RETURN RECEIPT N0.: 7018 068.0 0000 1719 1195

Don F Samuel, Esquire


Garland, Samuel & Loch? P.C.
3 151 Maple Drive, NE.
Atlanta, Georgia 30305

RE: NOTICE OF REPRESENTATION AND DEMAND


FOR HOMEOWNER’S
INSURANCE POLICY INFORMATION/VERIFICATION
COVERAGE 0F INSURANCE

YOUR CLIENT: LESHAWN MCCOY


OUR. CLIENTS: DELICIA CORDON and ELIZABETH
DATE OF LOSS: JULY 10, 2918
DONALD
LOCATION 0F LOSS: 392 HICKORY PASS, MILTON,
GEORGIA 30004
Dear Mr. Samuel:

As you may know, this Firm has been retained


by .Delicia Cordon a_nd Elizabeth Donald
to represent them regarding personal injuries and other as legal counsel
damages "they both suffered as a
incident that occurred on a propeny 0Wned result of ah
by yeur client; LeShawn McCoy, on
Cordon and M‘s.. Donald were injured during a home July 10 2018'. Ms
invasion at 392 Hickory
Pass, Mfltzm Georgia.
30004. Any and all communications regarding this ’ I A

matter should b‘e directly to this office.

McCoy spent over One Hundred Thousand Dollars ($100,000.00) for


said jewelry- that
Doesn’t he want to know what happened to that was ,s101en.
jewelry? Is he not at all cOncemed
that a violent home
invasion and aggravated battery took place in hishome? -
V

As yqu. know, Georgia Law requires Mr. McCoy t'o identify


and provide all insurance
policies available
to satisfy any and all damages related to the above-referenced
incident that occurred 'on Ju'ly 10, 2018.

FINAL REPRESENTATION LETTER T0 ATTY. DON SAMUELDBOBIB


3/fl/13
EXHIBIT “B”
THE LAW OFFICE. 0F
TANYA MITCHELL GW,P._C.
3212 Nek‘mmxg» PKWY, NE.
Box 450929
omen ATLANTA, GEORGIA 31145
(770)4919013
.

mesmg mo) 492.9917

August 7, 201 8

Michael LaScal‘a, Esquire


’75 W. Wieuca Road, NQE.
Atlanta, Georgia 30342

RE: LeShawn McCoy v. Belicia Cordon


Case N0: 18ED078693
FINAL DEMND FOR STOLEN FURNITURE
PERSONAL PROPERTY AND DAWGED
Dear Attorney LaScaIa:

Last week, this office informed


you that Ms. Cordon has lefi the
McCoy; however, Ms. Cordon still needed to residence shared with Mr.
retn'eve some of her items fiom
then, your client has changed the said
residence, smog
leeks 'to the residence;
thus, prevenfing
rem'eving the remaining items, WhiCh Ms, Cordon fi—om
incluiie photos of her
children throughout
ofher son’s personal items". This case is the years and some
still pending and this constructive
eviction by your client is
items be retumad immediately.

In addition to your client having


his family and fiiends remove Ms.
and two (2) area rugs fiom the residence Gordon’s couch, table,
on June 1, 2018, your client’s
caused aimina‘ damage t0 MS- Gordon’s family, mends and labomrs
dining room table, kitchen table,
paid for during the wrongful eviction and rm chairs that she
ACCORDINGLY, PLEASE TAKE NOTICE that if your client
arrangements through your office to retum does not make
Ms. Gordon’s finm'ture and
cost of same, by'the close of business personal items, or
on this Thuz‘sday,
pay for the
August 9, 2018, then a criminal
shallbe filed against all persons on the
secun‘t-y video footage
wmam
involved in the thefi 'of client’s personal fiom June '1,
2018, who were
property,

PLEASE TAKE FURTHER NOTICE that if your client does


not compensate
the cnminal damage to her furniture that
was moved out of the house our client for
the houserin the basement on June 1“ on June lst’moved back
(which our client had moved into
thrown back into the basement on June 5"“ Upstairs on June 4th),
and then
by Tmcus Porter and Thomas
take notice that criminal warrants will be Williams, then Please
filed against all parties involved. '
Michacl LaScala, Esquire
{MAL DZEW FOR STOLEN FU J’TUREAW DAM GED PERSONAL
‘ ugust 7', PROPERTY
Page 2

Should yofir client decide to


_l reimburse our client for the dama
,getohervroeqsh'
_

gathermg the rgcelpts for the 09st of the


damaged kitchen table, dining
Should your'chent further dead: to mom table’Pané’ £3) Chair:
pay for om. diemas furniture that
your convenience, I have attached the receipts was Stalen on June Is: f(‘n:
and pictures ost. Gordon’s
to you lastwcek. furniture
” that were ,sent
' '
'

PLEASE HA VE YOUR CLIENT 00 VERN


HIMSELFA CCORDHVGLK

Tanya Mitchell Graham,


Esquire

Kiania L. Brown, Esquire

TMG/KLB/kj

Enclosures

Cc: Addresses (via electronic mail and


certified mail, w/ ends.)
Delicia Cordon (via electronic mail, w/ ends.)
EXHIBIT “C”
3/172078
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