Delicia Cordon Files Lawsuit Against LeSean McCoy

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.

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.

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.

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.

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.

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.

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

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.

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
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

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

Civil Action File N0. 18EV003863
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
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.

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

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.

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
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

State Court ofFulton County
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
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
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.

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

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

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.
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.
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

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
the circumstances.
COUNT IV — NEGLIGENCE
58.
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,

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
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

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.
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.

State Court 0f Fulton County
Page 24 of 29
COUNT V — INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
68.
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.

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.
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.

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.
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
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);

Page 28 of 29
COUNT II — PREMISES LIABILITY
49.
Plaintiff hereby incorporates Paragaphs 1-48 set forth hereinabove as if each paragraph
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.

of Fulton County
State Court
Page 20 0f 29
EXHIBIT “A”
**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
the circumstances.
COUNT IV — NEGLIGENCE
58.
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,

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

State Court 0f Fulton County
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.
suffered from the intentional infliction 0f emotional distress in an amount t0 be proven at trial, but in
COUNT VI - PUNITIVE DAMAGES

73.
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

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);

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
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’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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Point Furniture
Nevember 6, 2016 at 3:29 PM
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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.
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.
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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North
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November 6, 2016 at 3:29 PM
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1/1

Delicia Cordon Files Lawsuit Against LeSean McCoy

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Delicia Cordon Files Lawsuit Against LeSean McCoy

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State Court of Fulton County

CIVIL ACTION FILE NO:

TAMARCUS JEROD PORTER, and LKM :

PLAINTIFF’S FIRST AMENDED AND RECAST COMPLAINT FOR DAMAGES

this Honorable Court as follows:

THE PARTIES. JURISDICTION AND VENUE

Belicia Cardon v. LeShawn McCoy, et al.

30004, located in Fulton County.

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

Defendant LESHAWN KAMEL MCCOY (hereinafter referred to sometimes as,

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

Delicia Cordon v. LeShawn McCoy, et at.

Delicia Cordon v. LeShawn McCoy, et al.

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

Plaintiff had a disagreement.

Delicia Cordon v. LeShawn McCoy, et a1.

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

Plaintiff had a disagreement.

Delicia Cordon v. LeShawn McCoy, et a1.

fully-furnished home with the Plaintiff.

Delicia Cordon v. LeShawn McCoy, et al.

Delicia Cordon v. LeShawn McCoy, et al.

fully-furnished home with the Plaintiff.

Delicia Cordon v. LeShawn McCoy, et al.

would unreasonably strike his son.

During February, 2017, Plaintiff and McCoy attended 6th

was ecstatic about her new earrings.

Belicia Cordon v. LeShawn McCoy, et al.

not pursued by McCoy any further.

Delicia Cordon v. LeShawn McCoy, et al.

volatile and Violent.

child’s mother regarding corporal punishment.

Delicia Cordon v. LeShawn McCoy, et al.

move out 0fthe Residence prior t0 said date.

incorporated herein by this reference).

Delicia v. LeShawn McCoy, et aL

incidents took place.

feel unsafe in the Residence.

Delicia Cordon v. LeShawn McCoy, e1 al.

not pursued by McCoy any further.

Delicia Cordon v. LeShawn McCoy, et al.

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

Belicia Cordon v. LeShawn McCoy, et al.

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

incorporated herein by this reference).

knowledge ofhis employee and/or agent, Porter.

Delicia Cordon v. LeShawn McCoy, et a1.

move out 0fthe Residence prior t0 said date.

incorporated herein by this reference).

Delicia v. LeShawn McCoy, et aL

Order evicting Plaintiff from the Residence.

COUNT I— ASSAULT AND BATTERY

were fully stated herein.

to purposefully disﬁgure Plaintiff‘s face.

Delicia Cordon v. LeShawn McCoy, et aI.

carried out unlawfully, negligently, and maliciously.

WHEREFORE, Plaintiff respectfully requests judgment against Defendants for damages

Belicia Cordon v. LeShawn McCoy, et aL

Plaintiff and her minor children feel unsafe in the Residence.

Delicia Cordon v. LeShawn McCoy, et aL

WHEREFORE, Plaintiff respectfully requests judgment against Defendants for damages

COUNT III —THEFT OF PEIJLSONAL PROPERTY

were fully stated herein.

returned t0 the Plaintiff at any time relevant hereto.