Final complaint for damages

1. COMPLAINT FOR DAMAGES CORDON
8/10/18
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IN THE STATE COURT OF FULTON COUNTY
STATE OF GEORGIA
DELICIA CORDON, :
:
Plaintiff, :
: CIVIL ACTION FILE NO:
v. :
: ______________________
LESHAWN KAMEL MCCOY, :
TAMARCUS JEROD PORTER, and LKM :
TRUST, :
:
Defendants. :
COMPLAINT FOR DAMAGES
COMES NOW, DELICIA CORDON, Plaintiff in the above-styled action, and by and
through her undersigned counsel, files this, her Complaint for Damages against Defendants
LESHAWN KAMEL MCCOY, TAMARCUS JEROD PORTER and LKM TRUST, and shows
this Honorable Court as follows:
JURISDICTION AND VENUE
1.
Plaintiff is the victim of multiple crimes and has suffered significant damages due to the
intentional torts committed by either Defendant LESHAWN KAMEL MCCOY, Defendant
TAMARCUS JEROD PORTER, or both of said Defendants, and others at Plaintiff’s former
residence which is located at 392 Hickory Pass, Milton, Georgia 30004. Said residence is located
in Fulton County. Defendant MCCOY and PORTER are joint tortfeasors who committed various
intentional torts that occurred at said residence. Accordingly, said Defendants are subject to the
jurisdiction and venue of this Honorable Court. Each Defendant may be served with a Summons
State Court of Fulton County
**E-FILED**
18EV003863
8/10/2018 3:26 PM
LeNora Ponzo, Clerk
Civil Division

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and a copy of this Complaint at his residence address, or at any place where each Defendant may
be found. Defendant LKM TRUST is the grantor trust that owns the residence located at 392
Hickory Pass, Milton, Georgia 30004, and may be served with a Summons and a copy of this
Complaint upon the Trustee for said Defendant, at any place where said Trustee for this Defendant
may be found.
THE PARTIES
2.
Plaintiff is a former resident of 392 Hickory Pass, Milton, Georgia 30004, where she and
her children lived from October, 2016 through and including July, 2018. Plaintiff was previously
involved in a romantic relationship with Defendant, LESHAWN KAMEL MCCOY (hereinafter
referred to as, “McCoy”) from June, 2016 until June 1, 2018; however, Plaintiff and McCoy have
been acquainted for over five (5) years.
3.
Defendant, TAMARCUS JEROD PORTER (hereinafter referred to as, “Porter”), is the
best friend and/or personal assistant of McCoy. Throughout Plaintiff’s 5-year acquaintance with
McCoy and at all times relevant hereto, Porter has always overseen, or been personally involved
with McCoy’s personal business and affairs.
4.
After discovery is conducted in this litigation, there may be one (1) or more party
Defendants added to this action and/or substituted as party Defendant(s) to this action.

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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.

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9.
Plaintiff located a home for herself, her children and McCoy which was located at 392
Hickory Pass, Milton, Fulton County, Georgia 30004 (hereinafter referred to as, the “Residence”).
Plaintiff and McCoy both liked the Residence, and McCoy initially informed Plaintiff that the
Residence would be titled in both names. However, within two days of the scheduled home closing
for the Residence in October 2016, McCoy informed Plaintiff that his financial advisor instructed
him not to include Plaintiff on the deed for their new home. Instead, McCoy purchased the
Residence himself, and based upon Plaintiff’s information and belief, either at the closing or
immediately thereafter, McCoy transferred the title of the Residence into the name of Defendant
LKM Trust. The address associated with the trust was identical to the address for the apartment
that McCoy resided in at the time in Buffalo, New York.
10.
Based upon Plaintiff’s information and belief, McCoy is the Trustmaker of the LKM Trust.
11.
Plaintiff is unaware how long McCoy and Porter have been friends; however, since
Plaintiff has been acquainted with McCoy, Porter has always been McCoy’s best friend and/or
personal assistant.
12.
Based upon Plaintiff’s information and belief, Porter has maintained a residence in or about
West Palm Beach, Florida; in or about Orchard Park, New York; and/or in or about Philadelphia,
Pennsylvania.

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FACTUAL ALLEGATIONS AND CLAIMS
13.
Plaintiff hereby incorporates Paragraphs 1-12 set forth hereinabove as if each paragraph
were fully stated herein.
14.
Plaintiff and her children moved into the Residence in October, 2016, during the 2016 NFL
season. Plaintiff brought furniture from her Cobb County residence into the home, and also
purchased new furniture and furnishings for the Residence in 2016. Plaintiff completely furnished
the entire Residence and by the time the 2016 season ended, McCoy came home to a fully-
furnished home with the Plaintiff.
15.
Plaintiff’s fairytale relationship with McCoy did not last long. During the offseason
subsequent to the 2016 NFL season, Plaintiff began to notice some disturbing behavior exhibited
by McCoy. Because she truly loved McCoy, and she believed that he truly loved her, Plaintiff
sought to make their relationship work for several months.
16.
The offseason following the 2016 NFL season was a turbulent time for Plaintiff’s and
McCoy’s relationship. First, McCoy would constantly allow Porter and other friends to enter the
Residence, without Plaintiff’s consent. In fact, Porter sporadically occupied an upstairs bedroom
in the Residence, which had a total of five (5) bedrooms. Plaintiff has a young daughter and a
minor son, and did not feel comfortable with various men coming in and out of the home
unannounced. However, Plaintiff tolerated this for the sake of the relationship.

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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

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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.

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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

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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).

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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.

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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).

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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.

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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 herebyspecifically reserves the right to amend her Complaint for Damages to include
additional grounds for recovery if the parties do not settle this case immediately.

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WHEREFORE, Plaintiff prays:
a) That process issue;
b) That Defendants be served as the law provides;
c) That the case be heard by a jury;
d) That Plaintiff be awarded special, general, compensatory, punitive, and all further
permissible damages in harmony with the enlightened conscience of an impartial jury;
e) That Plaintiff be awarded attorney’s fees on account and expenses of litigation; and
f) That Plaintiff be awarded such other and further relief as this Court deems necessary
and proper.
RESPECTFULLY SUBMITTED, this 10th
day of August, 2018.
3212 Northlake Parkway, N.E. THE LAW OFFICE OF
Box 450929 TANYA MITCHELL GRAHAM, P.C.
Atlanta, Georgia 31145 Attorneys for Plaintiff
770.492.9013 Telephone
770.492.9017 Facsimile
Tanya Mitchell Graham, Esquire
Georgia Bar No.: 513595
Demetrius J. Price, Esquire
Georgia Bar No.: 518237