State Court of Fulton County **E-FILED** 18EV003863 8/10/2018 3:26 PM LeNora Ponzo, Clerk Civil Division IN THE STATE COURT OF FULTON COUNTY STATE OF GEORGIA DELICIA CORDON, : : Plaintiff, : : v. : : LESHAWN KAMEL MCCOY, : TAMARCUS JEROD PORTER, and LKM : TRUST, : : Defendants. : CIVIL ACTION FILE NO: ______________________ COMPLAINT FOR DAMAGES COMES NOW, DELICIA CORDON, Plaintiff in the above-styled action, and by and through her undersigned counsel, files this, her Complaint for Damages against Defendants LESHAWN KAMEL MCCOY, TAMARCUS JEROD PORTER and LKM TRUST, and shows this Honorable Court as follows: JURISDICTION AND VENUE 1. Plaintiff is the victim of multiple crimes and has suffered significant damages due to the intentional torts committed by either Defendant LESHAWN KAMEL MCCOY, Defendant TAMARCUS JEROD PORTER, or both of said Defendants, and others at Plaintiff’s former residence which is located at , Milton, Georgia 30004. Said residence is located in Fulton County. Defendant MCCOY and PORTER are joint tortfeasors who committed various intentional torts that occurred at said residence. Accordingly, said Defendants are subject to the jurisdiction and venue of this Honorable Court. Each Defendant may be served with a Summons COMPLAINT FOR DAMAGES CORDON 8/10/18 Page 1 of 14 and a copy of this Complaint at his residence address, or at any place where each Defendant may be found. Defendant LKM TRUST is the grantor trust that owns the residence located at , Milton, Georgia 30004, and may be served with a Summons and a copy of this Complaint upon the Trustee for said Defendant, at any place where said Trustee for this Defendant may be found. THE PARTIES 2. Plaintiff is a former resident of Milton, Georgia 30004, where she and her children lived from October, 2016 through and including July, 2018. Plaintiff was previously involved in a romantic relationship with Defendant, LESHAWN KAMEL MCCOY (hereinafter referred to as, “McCoy”) from June, 2016 until June 1, 2018; however, Plaintiff and McCoy have been acquainted for over five (5) years. 3. Defendant, TAMARCUS JEROD PORTER (hereinafter referred to as, “Porter”), is the best friend and/or personal assistant of McCoy. Throughout Plaintiff’s 5-year acquaintance with McCoy and at all times relevant hereto, Porter has always overseen, or been personally involved with McCoy’s personal business and affairs. 4. After discovery is conducted in this litigation, there may be one (1) or more party Defendants added to this action and/or substituted as party Defendant(s) to this action. COMPLAINT FOR DAMAGES CORDON 8/10/18 Page 2 of 14 INTRODUCTION 5. The relationship between Plaintiff and McCoy began with both parties in a perpetual state of bliss. McCoy, who had been an acquaintance and friend of Plaintiff’s for at least three (3) years before June, 2016, finally made his feelings for Plaintiff known to her. While Plaintiff was on a trip to Las Vegas in June, 2016, McCoy flew to Las Vegas and confessed his love for Plaintiff to her in person. Plaintiff and McCoy, who had been friends for years, began their romantic relationship immediately. 6. At the beginning of said relationship, Plaintiff was a resident of Cobb County, Georgia. McCoy did not reside in the state of Georgia at all in June, 2016. Upon information and belief, at the time, McCoy maintained a home in Harrisburg, Pennsylvania, a condo in Miami, Florida, and an apartment in Buffalo, New York. 7. In August, 2016, McCoy showered Plaintiff with multiple gifts for her birthday. Said gifts included several expensive articles of jewelry, some of which were custom-made, among other gifts. 8. Around this time, McCoy and Plaintiff discussed living together, and McCoy promised to buy Plaintiff a home. Plaintiff began looking for a home while McCoy was actively working as an NFL player for the Buffalo Bills. COMPLAINT FOR DAMAGES CORDON 8/10/18 Page 3 of 14 9. Plaintiff located a home for herself, her children and McCoy which was located at , Milton, Fulton County, Georgia 30004 (hereinafter referred to as, the “Residence”). Plaintiff and McCoy both liked the Residence, and McCoy initially informed Plaintiff that the Residence would be titled in both names. However, within two days of the scheduled home closing for the Residence in October 2016, McCoy informed Plaintiff that his financial advisor instructed him not to include Plaintiff on the deed for their new home. Instead, McCoy purchased the Residence himself, and based upon Plaintiff’s information and belief, either at the closing or immediately thereafter, McCoy transferred the title of the Residence into the name of Defendant LKM Trust. The address associated with the trust was identical to the address for the apartment that McCoy resided in at the time in Buffalo, New York. 10. Based upon Plaintiff’s information and belief, McCoy is the Trustmaker of the LKM Trust. 11. Plaintiff is unaware how long McCoy and Porter have been friends; however, since Plaintiff has been acquainted with McCoy, Porter has always been McCoy’s best friend and/or personal assistant. 12. Based upon Plaintiff’s information and belief, Porter has maintained a residence in or about West Palm Beach, Florida; in or about Orchard Park, New York; and/or in or about Philadelphia, Pennsylvania. COMPLAINT FOR DAMAGES CORDON 8/10/18 Page 4 of 14 FACTUAL ALLEGATIONS AND CLAIMS 13. Plaintiff hereby incorporates Paragraphs 1-12 set forth hereinabove as if each paragraph were fully stated herein. 14. Plaintiff and her children moved into the Residence in October, 2016, during the 2016 NFL season. Plaintiff brought furniture from her Cobb County residence into the home, and also purchased new furniture and furnishings for the Residence in 2016. Plaintiff completely furnished the entire Residence and by the time the 2016 season ended, McCoy came home to a fullyfurnished home with the Plaintiff. 15. Plaintiff’s fairytale relationship with McCoy did not last long. During the offseason subsequent to the 2016 NFL season, Plaintiff began to notice some disturbing behavior exhibited by McCoy. Because she truly loved McCoy, and she believed that he truly loved her, Plaintiff sought to make their relationship work for several months. 16. The offseason following the 2016 NFL season was a turbulent time for Plaintiff’s and McCoy’s relationship. First, McCoy would constantly allow Porter and other friends to enter the Residence, without Plaintiff’s consent. In fact, Porter sporadically occupied an upstairs bedroom in the Residence, which had a total of five (5) bedrooms. Plaintiff has a young daughter and a minor son, and did not feel comfortable with various men coming in and out of the home unannounced. However, Plaintiff tolerated this for the sake of the relationship. COMPLAINT FOR DAMAGES CORDON 8/10/18 Page 5 of 14 17. McCoy’s behavior became erratic during the offseason after the 2016 NFL season. He would exhibit rage and often brutally beat his dog in the presence of the Plaintiff and her friends. McCoy did not care who was present. When Plaintiff expressed concern about McCoy beating his dog, he would turn his anger against the Plaintiff. 18. McCoy is the father to a young son who visited the Residence during the offseason after the 2016 NFL season. McCoy would aggressively, physically discipline and beat his young son over minor mistakes that all young children make. When Plaintiff questioned McCoy about beating his son, he would yell and scream at Plaintiff for commenting on how he should raise his son. Plaintiff disagreed with how McCoy physically disciplined his son, but McCoy gradually changed his behavior and disciplinary tactics regarding his son as he was approaching court proceedings with his son’s mother. 19. During February, 2017, Plaintiff and McCoy attended 6th Annual NFL Honors. As a surprise for Plaintiff, McCoy rented some diamond hoop earrings. Both Plaintiff and McCoy loved how the earrings looked on Plaintiff, so McCoy promised to purchase the earrings for her. Plaintiff was ecstatic about her new earrings. 20. By the summer of 2017, Plaintiff and McCoy would argue over McCoy beating his dog and beating his son frequently, as well as other issues. The parties would “break up” and get back together again, but Plaintiff was never asked to leave the Residence until July, 2017. Plaintiff and McCoy had the most serious argument of their relationship at the time, and Plaintiff left the COMPLAINT FOR DAMAGES CORDON 8/10/18 Page 6 of 14 Residence to go visit one of her friends. About an hour after Plaintiff left the Residence, McCoy called the police to have Plaintiff permanently removed from the Residence. McCoy instructed Porter to begin to unlawfully remove Plaintiff’s personal belongings from the home. When police arrived on the scene it was explained to McCoy that he could not simply remove Plaintiff’s belongings from the home because she and her children resided in the Residence. McCoy filed the first eviction against the Plaintiff on or about July 3, 2017. At this time, Plaintiff found out that McCoy never paid for the diamond hoop earrings, and she returned the earrings to McCoy in July, 2017 so that he could return them to the jeweler. However, the parties reconciled their relationship immediately thereafter and stayed together. The 2017 eviction proceedings were not pursued by McCoy any further. 21. McCoy did not reside at the Residence during most of the 2017 NFL season, and there were no incidents between the parties during that time. 22. After the 2017 season ended, McCoy returned to the Residence with Plaintiff and her children. Their relationship seemed back on track, but that was short lived. The parties broke up again in April, 2018, only to get back together shortly thereafter. By May, 2018, the parties were discussing the possibility of becoming engaged, and they discussed a possible engagement in depth on May 28, 2018, which was Memorial Day. 23. On or about May 30, 2018, McCoy left the Residence and traveled to Miami, Florida to begin training for the upcoming 2018 NFL Season. Plaintiff left the Residence to attend the out of state graduation for a family member. COMPLAINT FOR DAMAGES CORDON 8/10/18 Page 7 of 14 24. The last direct communication that Plaintiff had from McCoy was in the early morning hours of June 1, 2018 via text message. Plaintiff expressed her excitement about spending the summer with McCoy. He responded with what appeared to be an innocuous message stating that Plaintiff “already started” so he will “finish it” before texting her saying, “we gon kill it” at 12:23 a.m. on June 1, 2018, followed by “love u” at 12:35 a.m. to which Plaintiff responded, “Love you more bae!!” at 12:58 a.m. By 9:00 a.m. on June 1, 2018, however, Plaintiff was alerted by the doorbell camera video feed on her cell phone. She could see Porter and others removing her furniture from the Residence on the live-streamed video footage on her phone. 25. This Complaint arises from several intentional acts committed by Porter against the Plaintiff, either on his own, or at the direction of McCoy beginning on June 1, 2018, and continuing thereafter. Most of the intentional acts committed by McCoy and/or Porter occurred at the Residence, or have been in reference to the Residence and/or the home invasion which occurred at the Residence. 26. On June 1, 2018, upon viewing McCoy’s friends, family and associates on the doorbell camera, Plaintiff viewed an individual cover the doorbell camera with an article of clothing to conceal the activities that were taking place. Plaintiff instructed her neighbor to call the authorities to prevent the unlawful removal of her items from the Residence. Police arrived on the scene and instructed the individuals to place Plaintiff’s items back inside the Residence. Most of the furniture was placed in the basement of the Residence. However, a couch, coffee table, and two (2) area rugs, totaling approximately Thirteen Thousand Dollars ($13,000.00) in value, were not placed in the basement COMPLAINT FOR DAMAGES CORDON 8/10/18 Page 8 of 14 and, to date, have not been returned to Plaintiff despite Plaintiff’s request therefor (See August 7, 2018 letter to McCoy’s eviction attorney, attached hereto as Exhibit “A” and incorporated herein by this reference). The electricity to the Residence was also disconnected on this date. 27. On June 2, 2018, Porter, McCoy, and McCoy’s mother were on a “conference call” and contacted the police so that the dispatcher could hear all three individuals during the call. The police were informed that Porter was requesting a police escort to retrieve items from the Residence. Porter would enter the Residence without warning. Plaintiff later called police about feeling uncomfortable with Porter and others having unfettered access to the Residence. Because Porter was given permission by McCoy to come and go into the Residence, there was nothing the police could do about Porter’s unlimited access to the Residence. Plaintiff began making plans to relocate herself and her minor children from the Residence. 28. On June 3, 2018, Porter changed the locks to the doors of the residence and deactivated the doorbell camera that was linked to the Plaintiff’s cell phone. 29. On June 5, 2018, Plaintiff’s close childhood friend, who Plaintiff refers to as her “cousin”, Elizabeth Donald, was at the home caring for Plaintiff’s minor child while Plaintiff was out of the state. Porter and McCoy’s other friend, Thomas Williams, entered the Residence unannounced through a side door and installed a new security system, along with new security camera(s), at the direction of McCoy. Although Plaintiff and her children were residents at the Residence, Plaintiff was not informed of the new security codes and did not have the ability to arm or disarm the new security system. Plaintiff further did not have the ability to access the new security camera(s). COMPLAINT FOR DAMAGES CORDON 8/10/18 Page 9 of 14 30. On June 6, 2018. Porter and McCoy called police together on a conference call requesting assistance with removing individuals from the Residence. When asked how he knew that individuals were inside of the residence, Porter advised that he and McCoy were not at the Residence, but that he (Porter) had access to cameras inside the Residence which showed that people were present in the Residence. Porter proceeded to file an improper eviction petition on behalf of McCoy on this date. McCoy and Porter were on the call to police attempting to get Plaintiff’s cousin, and Plaintiff’s teenage son, removed from the Residence while Plaintiff as out of town. After Plaintiff’s cousin communicated with the police who arrived on the scene, Porter and McCoy were informed that they could not lawfully put Plaintiff’s son out of the Residence because he lived there, Porter and McCoy could not put Plaintiff’s cousin out of the Residence because she had Plaintiff’s permission to be there. On this same day, June 6, 2018, Porter filed an eviction proceeding against Plaintiff on behalf of McCoy. 31. Porter entered the residence, unannounced on June 8, 2018, and again, accompanied by Williams on June 19, 2018. Porter and Williams seemed to be doing something in Porter’s old bedroom and/or in the attic, as well as something in the basement of the Residence. Once Plaintiff filed her Motion to Quash the improper eviction proceeding filed by Porter on behalf of McCoy, Porter no longer entered the Residence unannounced. 32. On July 3, 2018, Plaintiff left the Residence for a vacation trip. Ms. Donald came to the Residence to care for Plaintiff’s son while she would be out of town. Plaintiff returned to the Residence on the evening of July 9, 2018. Ms. Donald stayed at the Residence overnight. COMPLAINT FOR DAMAGES CORDON 8/10/18 Page 10 of 14 33. On July 10, 2018, Plaintiff and McCoy were scheduled to be in Court regarding the eviction proceedings. That morning, between approximately 3:00a and 3:23a, 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. Plaintiff exited the master bedroom to check on her minor son. While calling for her son, the assailant 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 of Plaintiff’s bracelets from her wrist with wire cutters, and struck Mc. Donald on the back of the head with the gun. Once the assailant secured some of the jewelry that McCoy had given to Plaintiff as gifts in 2016, the assailant asked for money, put Plaintiff and Ms. Donald in an upstairs room, and vacated the Residence. 34. On July 10, 2018, Plaintiff was a victim of burglary, aggravated assault, aggravated battery, and was 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 from the Plaintiff, most of which was purchased by McCoy. Even though McCoy has insured Plaintiff’s jewelry, he has yet to provide Plaintiff with the name of his insurance company so that Plaintiff can file a claim to receive the value of her stolen jewelry (See August 8, 2018 letter to McCoy’s criminal defense attorney, attached hereto as Exhibit “B” and incorporated herein by this reference). COMPLAINT FOR DAMAGES CORDON 8/10/18 Page 11 of 14 35. Porter admitted to police on June 6, 2018 that he had access to live video footage from cameras inside of the Residence. Defendants further refused to provide information and access to the new security system and cameras to Plaintiff. As such, Defendant McCoy had actual and constructive knowledge of criminal activity existing on the property on July 10, 2018 due to the direct knowledge of his employee and/or agent, Porter. 36. At all times mentioned herein, Defendant McCoy owned and controlled the Residence. Defendant McCoy breached his duty owed to Plaintiff not to injure her willfully or wantonly. 37. Defendant McCoy intentionally permitted a hazardous condition to exist on the premises when he caused the new security system and cameras to be installed at the Residence and refused to provide information and access of said system and cameras to Plaintiff, prohibiting her ability to arm or disarm the Residence. 38. Defendant McCoy breached his duty to use ordinary care to protect Plaintiff from dangerous activities being conducted at the Residence. By changing the security system and preventing Plaintiff’s access thereto, Defendants effectively left Plaintiff and her minor children defenseless in their own home. 39. Defendants are liable for the assault, battery, and intentional infliction of emotional distress suffered by the Plaintiff. Said assault, battery, and emotional distress were inflicted upon Plaintiff without necessity, privilege, or consent. COMPLAINT FOR DAMAGES CORDON 8/10/18 Page 12 of 14 40. Defendant’s wanton conduct was a cause in fact and the proximate cause of the injuries suffered by Plaintiff during the home invasion at the Residence on July 10, 2018. 41. As a result of Defendants’ wanton conduct, Plaintiff is entitled to recover for the injuries sustained, pain and suffering, expenses of treatment, costs of future care and treatment, lost wages and ability to labor, and all remaining elements of damages allowed under Georgia Law, including special damages, compensatory damages, consequential damages, and economic damages. 42. Plaintiff is entitled to an award of punitive damages without restriction or cap, because the actions of Defendants and their agents and/or employees showed willful misconduct, malice, wantonness, and an entire want of care, which raise the presumption of conscious indifference to the consequences, equivalent in spirit to actual intent to cause harm. 43. Because Defendants’ bad faith and stubborn litigiousness has caused Plaintiff undue expense, Plaintiff is entitled to recover her necessary expenses of litigation, including an award of reasonable attorney’s fees and expenses on account, required by this action pursuant to O.C.G.A. § 13-6-11. Additionally, Plaintiff is entitled to all expenses of litigation and attorney’s fees on account pursuant to all applicable statutory law. 44. Plaintiff hereby specifically reserves the right to amend her Complaint for Damages to include additional grounds for recovery if the parties do not settle this case immediately. COMPLAINT FOR DAMAGES CORDON 8/10/18 Page 13 of 14 WHEREFORE, Plaintiff prays: a) That process issue; b) That Defendants be served as the law provides; c) That the case be heard by a jury; d) That Plaintiff be awarded special, general, compensatory, punitive, and all further permissible damages in harmony with the enlightened conscience of an impartial jury; e) That Plaintiff be awarded attorney’s fees on account and expenses of litigation; and f) That Plaintiff be awarded such other and further relief as this Court deems necessary and proper. RESPECTFULLY SUBMITTED, this 10th day of August, 2018. 3212 Northlake Parkway, N.E. Box 450929 Atlanta, Georgia 31145 770.492.9013 Telephone 770.492.9017 Facsimile THE LAW OFFICE OF TANYA MITCHELL GRAHAM, P.C. Attorneys for Plaintiff Tanya Mitchell Graham, Esquire Georgia Bar No.: 513595 Demetrius J. Price, Esquire Georgia Bar No.: 518237 COMPLAINT FOR DAMAGES CORDON 8/10/18 Page 14 of 14 THE LAW OFFICE 0F TANYA MITCHELL GRAHAM,P. 3212 NORTHLAKE PKWY, N.E. C. Box 450929 Omen MW ATLANTA, GEORGIA 31145 (770)492.9013 August 7, FACSIMILE (770) 492-9017 201 8 Michael LaScala, Esquire 75 W. Wieuca Road, N,E. Atlanta, Georgia RE: 30342 LeShawn McCoy v. Belicia Cordon Case No: 1 8ED078693 FINAL DEMAND FOR STOLEN FURNITURE AND PERSONAL PROPERTY DAWGED Dear Attorney LaScala: Last week, this office informed you that Ms. Cordon has lefl the residence shared with Mr. still needed to retrieve some of her items fiom said residence. Since then, your client has changed the locks to the residence; thus, preventing Ms, Cordon fiom retrieving the remaining items, Which include photos of her children throughout the years and some of her son’s personal items. This case is still pending and this constructive McCoy; however, Ms. Cordon illegal. Our client hereby demands that items be returned immediately. eviction by your client is her remaining personal photogaphs and her son’s personal In addition to your client having his family and friends remove Ms‘ Cordon’s couch, table, and two (2) area rugs from the residence on June 1, 2018, your client’s family, friends and laborers caused criminal damage to Ms. Gordon’s dining room table, kitchen table, and two chairs that she paid for during the wrongful eviction. ACCORDINGLY, PLEASE TAKE NOTICE that if your client does not make arrangements through your office to return Ms. Gordon’s furniture and persona] items, or pay for the cost of same, by the close of business on this Thursday, August 9, 2018, then a cn'minal wanant shall be filed against all persons on the security video footage from June 1, 2018, who were involved in the thefi of client’s personal property. PLEASE TAKE FURTHER NOTICE that if your client does not compensate our client for 15‘, moved back into the house in the basement on June 15‘ (which our client had moved upstairs on June 4th), and then thrown back into the basement on June 5m by Tamarcus Porter and Thomas Williams, then please take notice that criminal wanants will be filed against all parties involved. the criminal damage to her fiJmiture that was moved out of the house on June E] COP 5208 EXHIBIT No. Blumberq A Michael LaScala. Esquire fmAL g‘igéiND FOR S TOLEN FURNITURE AND DAMA GED PERSONAL PR OPERTY n ", ugust Page 2 . Should yofir client decide to reimburse our client for the dama ge to her r0 e she Is gathermg the rgcelpts for the ogst of the damaged kitchen table, dining room table,pan§ twig) chairs Should your. chent fimher decxde to pay for our client’s fumiture that was stolen on June 15‘ for. your convemence, I have attached the receipts and pictures of Ms. Gordon’s fumjture that wereasent t0 you last week. 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I cation _.. “HDH'S Pflom: AZCBIVER‘S Wham art easy Iryou Wm PIM( nan mullahs. wok m Qo loam mm 8 " mmy. Ituy‘l F3 eunomlr SIN!” a @Q {:4 httsz/mailgoogle.conalUu/OMnboxM641631W989de3700mpoae=1 64770548eb21803%26new&prolec‘or=1&messageParfld=0.4 1/1 8/1/2018 IMG_SOSQ‘jpg htmsd/maugooglaoomlmail/u/OMI "box“64f561W989d93?wmpose=1smomebm603%2Cnewapm1ecror-m - messageParfld=o 2 1/1 THE LAW OFFICE 0F TANYA MITCHELL GRAHAM, P. C. 3212 NORTHLAEE PKWY N.E. Box OFFICE (770) 4-92-9018 4.50929 ATLANTA, GEORGIA 31145 FACSDma (770) 4492-9017 www.tmgesq.com August VIA CERTIFIED MAIL RETURN RECEIPT N0.: 7018 0680 0000 Don F. 20 1 8 1719 1195 Samuel, Esquire & Loeb, P.C. Garland, Samuel 3 151 8, Maple Drive, N.E. Atlanta, Georgia RE: 30305 NOTICE OF REPRESENTATION AND DEMAND FOR HOMEOWNER’S INSURANCE POLICY INFORMATION/VERIFICATION OF INSURANCE COVERAGE YOUR CLIENT: OUR CLIENTS: DATE OF LOSS: LOCATION OF LOSS: LESHAWN MCCOY DELICIA CORDON and ELIZABETH DONALD JULY 10, 2018 , MILTON, GEORGIA 30004 Dear Mr. Samuel: As you may know, Firm has been retained by Delicia Cordon and Elizabeth Donald as legal counsel them regarding personal injuries and other damages they both suffered as a result of an incident that occuned on a property owned by your client, Leshawn McCoy, on July 10, 2018. Ms. Cordon and Ms. Donald were injured during a home invasion at , Milton, Georgia 30004. Any and all communications regarding this matter should be directly to this office. this to represent ' I am certain that you are aware that this Firm is further representing Ms. Cordon in the eviction proceeding which was filed by Mr. Tamarcus Porter on June 6, 2018 0n behalf of Mr. McCoy. Based upon our information and belief, you were retained almost immediately after the home invasion that occurred on July 10, 2018, over four (4) weeks ago. For that reason, I was expecting t0 receive correspondence from you by now because of the injuries that our clients suffered in Mr. McCoy’s home, and the fact that Ms. Cordon’s Cartier bracelets, diamond stud earrings, and ring given to her in 201 6 as birthday presents from Mr. McCoy were stolen. Based upon our fufiher information and belief, Mr. McCoy spent over One Hundred Thousand Dollars ($100,000.00) for said jewelry that was stolen. Doesn’t he want to know what happened to that jewelry? Is he not at all concerned that a Violent home invasion and aggravated battery took place in his home? As you know, Georgia Law requires Mr. McCoy any and all REPRESENTAnoN LETrER To Am to satisfy FINAL 8/8/18 damages to identify and provide all insurance policies available related to the above-referenced incident that occurred on July 10, 2018. DON SAMUEmaoals m 8 .n zd 9 3 E a m EXHIBIT B Don F. Samuel, Esquire Garland, Samuel August 8, & Loeb, P.C. 2018 N0 TICE 0F REPRESENTA TIONAND WRIFIQ HON 0F INSURANCE C0 VERA GE Our Chants: Delicia ~ Cordon and Elizabeth Donald Page 2 of 3 See 0.C'.G.A. § 33—3—28. Mr. McCoy, 0r his insurance agent, is required to forward to our attention, the insurer, the name of each insured, and the limits of coverage. In the alternative, the insurer may provide a copy ofthe declaration page of each such policy, including excess or umbrella insurance; Based upon our information and belief, Mr. McCoy had Ms. Gordon’s jewelry appraised, and he added name of the a rider to his homeowner’s insurance policy covering said jewelry. Accordingly, pleaseforward a copy 0fthis letter to Mr. McCoy’s homeowner’s insurance agent or carrier with instructions t0 contact this office via telephone and in writing within ten (10) days ofreceipt ofthis correspondence. If there was no relevant valid homeowner’s insurance policy in effect on the date of the incident, Mr. forward a written, signed, and notarized statement to our attention stating same. McCoy must Please be further advised that this letter serves as a formal demand for the preservation of certain evidence relating to the above—referenced incident. We specifically demand that the following evidence be maintained and preserved, and not be destroyed, modified, altered, repaired, or changed in any manner: 1. Any and all physical evidence regarding the residence located at home invasion on July 10, 2018 at Mr. McCoy’s , Milton, Georgia 30004, including the bloodied sheets physically attacked by the intruder. Mr. McCoy wrongfully changed the where Ms. Cordon was locks on the residence before Ms. Cordon could completely remove all ofher belongings. In fact, the hearing pertaining to the eviction is scheduled for Tuesday, August 14, 2018, at 1:00 p.m., at which time we were going t0 address the wrongful eviction filed by Mr. Porter 0n behalf 0f your client. We have sent correspondence to Attorney Michael LaScala in this regard, which is attached hereto. Attorney LaScala offered no response other than to offer Mr. McCoy‘s false claim that Ms. Cordon took a pair of his Kobe Bryant sneakers; 2. Any and all physical 3. or any other security provider, regarding the residence at __ Milton, Georgia 30004 from June 1, 2018, going forward; Any and all photographs or surveillance videos from any security 0r monitoring system regarding the residence at Milton, Georgia 30004 on July 9-10, 2018; Incident reports, witness statements, and other documentation regarding the 201 8 July or electronic documents regarding the purchase and installation of cameras, alanns, and/or any other security or monitoring devices and/or services from. '_ 4. 10, 5. 6. 7. at liability for the above-referenced home invasion at that occuned at his Milton, Georgia 30004 n July 10, 201 8. FINAL REPRESENTATION LETTER TO ATTY. 8/8/18 home Mr. McCoy’s home located at Milton, Georgia 30004; Any other documentary or tangible evidence referencing, concerning, or describing the home invasion at Mr. McCoy’s home on July 10, 2018; Any and all audio or video recordings, or documents related to the above-referenced home invasion at Mr. McCoy’s home located at Milton, Georgia 30004 n July 10, 201 8; and Any and all audio or video recordings, or documents establishing or disproving Mr. McCoy’s invasion DON SAMUELOSOSIB home located at Don F. Samuel, Esquire Garland, Samuel August 8, & Locb, P.C. 201 8 NOTICE OFKEPRESENTA TIONAND VERIFICATION OFJZVSURANCE C0 VERAGE Oux Clients: Page Delicia Cordon and Elizabeth Donald 3 of 3 If your client fails to preserve these items, he will be contributing to the destruction 0f evidence critical to this matter, and subjecting himself t0 substantial legal consequences. Mr. McCoy’s failure to preserve and maintain the requested evidence may Bowen,_246 Ga. App. 177 (2000). result in the imposition of legal sanctions. See R.A. Siege] C0. v. As the above statute, please produce the Declaration page 0f Mr. McCoy’s homeowner’s insurance policy for the residence located at , Milton, Georgia 30004 by the close 0f directed by business on tomorrow, August 9, 2018. Alternatively, please provide a notarized statement of a corporate officer or claims manager of the insurance company, indicating the name of the insurer, the name of each insured, the policy number(s) for any and all policies of insurance insuring Mr. McCoy’s residence and the contents therein, including, but not limited to any excess or umbrella riders to said homeowner’s insurance, and the policy’s limits ofcoverage. Ifwe do not receive any response from your office or your client’s insurance carrier by the close ofbusiness on tomorrow, August 9, 2018, further legal remedies will be pursued immediately. If you have any questions or concerns regarding 1L4 VE this matter, do not hesitate to contact one of us Y0 UR CLIENT G0 VERN HIMSELFACCORDINGL Y. Sincerely, THE LAW OFFICE OF TANYA MITCH;LL GRAHAM, P.C. Tanya Mitchell/G Demetrius}. Price, Esquire TMG/DJP/al Enclosures Cc: Garland, Samuel & Loeb, P.C. (via e-mail: Cordon (via electronic mail, w/ encls.) Elizabeth Donald (via electronic mail, w/ encls.) Delicia FINAL REPRESENTATION LETTER TO ATTY. 8/8/18 DON SAMUELDBOMS w/ encls.) directly.