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‘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, 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 Plaintif's former residence which is located at [EE 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 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 i TR 2216 s22y 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 A, 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, “MeCoy") from June, 2016 until June 1, 2018; however, Plaintiff and MeCoy have bbeen 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 aequaintance with MeCoy and at all times relevant hereto, Porter has always overseen, or been personally involved with MeCoy’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, Page 2 of 14 INTRODUCTION 5. The relationship between Plaintiff and MeCoy 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 NEL player for the Buffalo Bills. Page 3 of 14

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