Laworiceor CHRISTOPHER C. ROBERTS, LLC "OU7000 AVE BAST ota NE SEY 77 onsn6o FAX O73}6734627 December 5,2022 (Via Regular and Certified Mail) Frank Leanza, Es. [New Jersey Sports & Exposition Authority (One DeKorte Pak Plaza P.O. Box 640) Lyndhurst, NI 07071 William Helle, sq, New York Football Giants, ne, 1925 Giants Drive East Rutherford, NI 07073, RE: Notice of Claim (Claimant: Byron Marshall Date of Incident: September 26, 2022 Dear Counsel Please accept this letter asa Notice of Claim on behalf of Byron Marshall, younger brother to former NY Football Giants player Leonard Marshall. Mr, Bryon Marshall (DOB 5/15/1968), the claimant, who resides in Louisiana, makes this notice claiz against the New York Football Giants, Inc. and its employce Josnn Lamneck, who isthe Director of Alumni Relations forthe ‘Now York Football Giants, Inc for her September 26, 2022 actions that were committed during the scope of her employment forthe New York Football Giants, Ine, Given thatthe New Tersey ‘Sports and Exposition Authority (NJSEA) holds the land lease for and provides for the ongoing ‘operations for the Metlife Sports Complex and that some of Ms, Lameneck’s actions occurred at ‘he Metlife Sports Complex, Claimant Byron Marshall eso files this notice of eleim ageinst the NISEA. Tae following facts give rise to Mr. Marshall's notice of claim. First as previously stated, ‘Mr. Marshall is the younger brother of N.Y, Giants player Leonard Marshall whose football career with the NY Giants spanned ftom approximately 1983 to 1992. During said years, Claimant ‘Marshall as the younger brother of Leonard Marshall and spending time with his brother during ‘is brother’s playing career, was able to spend a great deal of time interacting with the N.Y. Football Giants organization and with his brother's teammates during Claimant's teenage and early ‘adult yeas. In fact, Claimant Marshall bonded with many players, coaches and administrators over 1‘those years and has established lifelong friendships with those past N.Y. Giant players, which makes the following sequence of events so disturbing. On or about September 26, 2022, the NY Footbell Giants, Ine, was honoring Claimant's brother Leonard Marshall by inductng im inthe Ring of Honor ceremony at MetLife Stadium at halfime of the Giaats vs. Dallas Cowboys game. Claiment’s brother had texted bim stating *You need tobe here with ws litle brother. ts important that you're right beside me/us.” Former player Jerrod Bunch texted Claimant to verify that Claimant was attending. Claimant was gifted a ticket to the game and ceremony by former Giants player Lance Smith, Claimant was definitely invited {oattend the game ad fellowship withthe former players on thei personal rented bus an to attend the pre-ceremiony parties honoring the all Ring of Honor inductees. However, on or about September 26, 2022, atthe hotel at the Meadowlands, Ms, Joann Lammeck, Director of Alumni Relations confronted Claimant as he was approaching the team bus and eccused Claimant of being involved in a brawW/fight at aloes bar and specifically stated that Claimant had been arrested forthe brewiight, Ms. Lamneck communicated this falsehood to [Lane Smith and ordered Mr. Smith o retrieve the game ticket froma Claimant. Also, Ms, Lamecke prohibited Claimant from boarding the bus in front of Claimant's family and ftiends and acquaintances. Her false allegations caused Claimant to be humiliated and embarrassed, Ms. ‘Lamnesk then directed Claimant to talk tothe New Jersey State Police who were onsite to escort ‘the buses 1o MetLife stadium, Also on September 26, 2022, Claimant was informed by the wife of former NY Gients player and another ring inductes, Rodney Hampton that Ms, Lamneck had approached her oa Mr. Hampton’ s personal bus tothe game stating that Claimant had been erested for a brawh/ight and was looking Zor Claimant so he could be removed from the bus. Claimant acknowledges that he had aitended Reddis Sport Bar for Ring of Honor party for former players Rodney Hampton and Ottis Anderson on or about September 25, 2022 but was never ina fight or brawl as Ms, Lamneck falsely stated, Claimant along with witnesses at the event ean attest that Claimant was not in any bar fight ot brawl, As a result of Ms, Lamencok’s tortious actions, Claimant hus suffered embarrassment, ‘damage to his reputation and name, caused him to miss once ina lifetime event, ha put him feat ‘of being arested, damaged his character, cause him to suffer mental anguish, which he has o seek ‘medical treatment, Ms, Lamneck’s false statements and her dislosuse of said falsehoods to others, constitute defamation, defamation per se, slander, slander per se and intentional infliction of «emotional distress and an invasion of privacy by putting Claimant in a false light. Given that Ms, ‘Larneck engaged in said tortious conduct during the scope ofher duties, the NY Football Giants, Inc are viesriously liable for Ms. Lamneck’s actions under the theory of respondeat superior and negligent retention, As result of these damages which potentially can be ongoing and potentially ‘permanent, Claimant seeks damages in excess of $10,000,000.00 and Claimant seeks season lickets to NY Giants home games in perpetsity slong with a public apology from Ms. Lemnecie and the NY Football Giants. Hopefully this matter ean be amicably resolved. | |