jackie robinson west lawsuit 1/11/16
TRANSCRIPT
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ELECTRONICALLY FILED
2 11/2016 8:30AM
2016-L-001428
CALENDAR:H
PAGE 1 of43
CIRCUIT COURT OF
IN THE
CIRCUIT
COURT OF COOK
COUNTY
ILLINBBIS COUNTY;, ILLINOIS
, LAW
DIVbiON
COUNTY DEPARTMENT LAW
DIVISIQN CLERK DOROTHY BROW
DEVONA D. BENTON and FRANK JACKSON, )
individually, and on behalf of their minor child, J B.; )
ROBERTS. BUFFORD, JR., Individually, and on behalf )
of their minor child, C. B.; DAROLD BUTLER, SR. and )
DO NIT A BRUCE, individually, and on behalf of their )
minor child, D.B.; VENISA BEASLEY -GREEN and )
CHRISTOPHER GREEN, individually, and on behalf of )
their minor child, B.G.; CARLTON A. HONDRAS,
II
and )
SHEREE HONDRAS, individually, and on behalf
of
)
their minor child, C.H.; JERRY F. HOUSTON and )
MYRTLE HOUSTON, individually, and on behalf
of
)
their minor child, J.H.; EDWARD HOWARD III, and )
CALANDRA HOWARD, individually, and on behalf
of
)
their minor child, E H.; LINDA SNEED HARRIS, )
individually, and
on
behalf
of
her minor child, M.J.; )
NEDRA JONES and ALVIN JONES, individually, and )
on behalf
of
their minor child, P.J.; TAMMY KING and )
EDDIE KING, SR., Individually, and on behalf of their )
minor child, E.K.; PRENTISS LUSTER and DARLENE )
LUSTER individually, and on behalfof their minor child, )
P.R.; SANJA E. NOBLE, Individually, and on behalf
of
)
her minor child, L.N.; and CLAUDIA HARVEY, )
individually, and on behalfof her minor child, D.R.; )
Plaintiffs,
v.
LITTLE LEAGUE BASEBALL, INCORPORA TED;
JACKIE ROBINSON WEST LITTLE LEAGUE, INC.,
an Illinois Not-for-Profit Corporation; BILL HALEY,
Individually, and as agent and/or employee
of JACKIE
ROBINSON WEST LITTLE LEAGUE, INC.; ANNIE
HALEY, Individually, and as agent and/or employee of
JACKIE ROBINSON WEST LITTLE LEAGUE, INC.;
EVERGREEN PARK ATHLETIC ASSOCIATION, an
Illinois Not-for-Profit Corporation; CHRIS JANES,
Individually, and as agent and/or employee
of
EVERGREEN
PARK
ATHLETIC ASSOCIATION;
ESPN, INC., a Delaware corporation; and STEPHEN A.
SMITH, Individually, and as agent of ESPN, INC.,
Defendants.
)
)
Case No.
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COMPL INT T L W
NOW COME the Plaintiffs, DEVONA D. BENTON and
FRANK
JACKSON,
individually, and on
behalf
of their minor child, J B.;
ROBERTS.
BUFFORD, JR., Individually,
and on
behalfof
their minor child, C.B.; DAROLD BUTLER, SR. and DONITA BRUCE,
individually, and on
behalf of
their minor child, D.B.; VENISA BEASLEY -GREEN and
CHRISTOPHER GREEN, individually, and on
behalf
of their minor child, B.G.; CARLTON A
HONDRAS, II and SHEREE HONDRAS, individually, and on
behalf of
their minor child, C.H.;
JERRY F. HOUSTON and MYRTLE HOUSTON, individually, and on
behalf
of their minor
child, J.H.; EDWARD HOWARD III, and CALANDRA HOWARD, individually, and on
behalf
1
of
their minor child, E.H.; LINDA SNEED HARRIS, individually, and on behalf of her minor
Cl
LI l
~
00
1
child, M.J.; NEDRA JONES and ALVIN JONES, individually, and on
behalf of
their minor
><
( 1 ~ .
o :
child, P.J.; TAMMY KING and EDDIE KING, SR., Individually,
and
on
behalf
of their minor
U \ 0 N
LI.l
5 I child, E.K.; PRENTISS LUSTER and DARLENE LUSTER individually, and on
behalf of
their
cX:;:::;CQ.;'
f 4 N
~
LI l minor child, P.R.; SANJA E. NOBLE, Individually, and on
behalf
of her minor child, L.N.; and
l
·LI.l
CLAUDIA HARVEY, individually, and
on
behalfof
her minor child, D.R.; (hereinafter
; collectively referred to as the
JRW
Parents ); by and through their attorneys, Barney
Karamanis, LLP, and complaining of Defendants, LITTLE LEAGUE BASEBALL,
INCORPORATED (hereinafter referred to as LITTLE LEAGUE ); JACKIE ROBINSON
WEST LITTLE LEAGUE, INC. (hereinafter referred to as JRWLL ); BILL HALEY,
Individually, and as agent and/or employee of JRWLL; ANNIE HALEY, Individually, and as
agent and/or employee
of
JRWLL; EVERGREEN
PARK
ATHLETIC ASSOCIATION
(hereinafter referred to as
EP
AA''); CHRIS JANES, Individually, and as agent and/or
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employee ofEPAA; ESPN INC.; and STEPHEN
A
SMITH Individually and as agent and/or
employee
ofESPN
INC.; state as follows:
P RTIES
1 At all times relevant hereto Plaintiffs the JRW Parents acting on behalf of
themselves and their minor children.
2 At all times relevant hereto. Defendant LITTLE LEAGUE was a Not-for-Profit
corporation federally-chartered under 36 U.S.C.
§
13501 and headquartered in Williamsport
Pennsy vania.
3
At all times relevant hereto Defendant JRWLL was an Illinois Not-for-Profit
corporation engaged in the operation of a Little League chartered baseball league on the South
Side
of
Chicago Cook County Illinois.
4
On
information and belief. and at all times relevant hereto Defendant Bill Haley
was a resident ofCook County Illinois.
5 At all times relevant hereto Defendant Bill Haley was an agent and/or employee
of
Defendant JRWLL.
6
At all times relevant hereto Defendant Bill Haley was acting within the course
and scope of his agency and/or employment with Defendant JRWLL.
7 On
information and belief and at all times relevant hereto Defendant Annie
Haley was a resident ofCook County Illinois.
8
At all times relevant hereto Defendant Annie Haley was an agent and/or
employee ofDefendant JRWLL.
9
At all times relevant hereto Defendant Annie Haley was acting within the
course and scope of her agency and/or employment with Defendant JRWLL.
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10 At all times relevant hereto, Defendant,
EP
AA, was an Illinois Not-For-Profit
corporation organized under the laws
o
the State
o
Illinois, engaged in the operation
o
a Little
League chartered baseball league in Evergreen Park, Cook County, Illinois.
11 On
information and belief, and at all times relevant hereto, Defendant, Chris
Janes, was a resident
o
Cook County, Illinois.
12 At all times relevant hereto, Defendant, Chris Janes, was an agent and/or
employee ofDefendant, EPAA.
13 At all times relevant hereto, Defendant, Chris Janes, was acting within the course
and scope
o
his agency and/or employment with Defendant, EPAA.
14 At all times relevant hereto, Defendant, ESPN, was a Delaware corporation, based
in Bristol, Connecticut, which owned and operated various sports broadcasting outlets, including
, cable channels, sports radio network, an accompanying website and other assets.
15 At all times relevant hereto, Defendant, Stephen A. Smith, was an agent and/or
employee o Defendant, ESPN, INC.
16
At all times relevant hereto, Defendant, Stephen
A
Smith, was acting within the
- course and scope o his agency and/or employment with Defendant, ESPN INC.
F CTS COMMON TO LL COUNTS
17 At all times relevant hereto, Defendant, Little League, organized and administered
local youth baseball and softball leagues throughout the U.S. and the rest
o
the world pursuant
to its official rules and regulations, with these official rules and regulations administered and
enforced by agents and/or employees in its Pennsylvania headquarters and District
Administrator s offices.
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18. At all times relevant hereto, Defendant, Little League, published its official rules
and regulations in a book entitled Little League® Rules and Regulations for Baseball Divisions-
2014 (hereinafter referred to as the Rule Book ). A copy o the relevant provisions o said Rule
Book are attached hereto as Exhibit A.
1
19. At all times relevant hereto, Defendant, Little League, issued charters
to
local
leagues on an annual basis with the requirement that the local league adhere scrupulously to all
rules and regulations established by Little League.
Ex.
A Administration,
p. 12.
20. At all times relevant hereto, Defendant, Little League, placed the responsibility o
revtewmg, granting, suspending and/or revoking the privileges and conditions
o
the local
league's charter and the authority to grant any written requests o a local charter to waive a
specific rule or regulation with its Charter Committee.
Ex.
A Charter Committee/Waivers
o
Rules and Regulations, p. 12.
21.
In
order to be eligible, under the rules o Defendant, Little League, a player must
qualify under the Little League's definition o residence printed in Section 2 o this book, must
be
the correct 'league age' for the division, and must have parental consent.
Ex. A
Player
Eligibility, p. 12.
22. According
to
the Rule Book, [ e ]ach local Little League determines
the
actual
geographic boundaries o the area from within which it shall select players and these
boundaries must be described in detail and shown on a map and dated when making application
for a Little League charter. Ex. A, Residence and School Attendance Player Eligibility
Requirements,
p. 16.
1
ue
to
its length Plaintiffs have not attached a copy of the Rule Book in its enti rety to this Complaint. However
a complete copy of this Rule Book will
be
made available for inspection
and/or
copying upon request
of
any party.
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23 Section 2
o
the Rule Book, further provides that in order to be eligible to play
with a particular league, only players who reside or the physical location o the school where
they attend classes is within the boundaries provided
to
and approved by Little League Baseball,
Incorporated. d
24 Section 2 then lists the supporting documents which would be acceptable to
determine the residence
o
a player's parent or legal guardian, which included, for example,
driver's license, utility bills and medical records.
25
Section 2
o
the Rule Book, further provides that [i]t is recommended that the
league require some proof
o
residence or school attendance with the league's boundaries at the
time the player registers. Id., p 17
26 The Rule Book further provides that [i]f a claim for residency or school
· attendance
is
challenged, the above materials must
be
submitted
to
Little League Baseball,
Incorporated, with an affidavit o residency or school attendance from the parent(s) or guardian.
27
At all times relevant hereto, Defendant, JRWLL, was within the geographic
boundaries
o
the Defendant, Little League's, District Administrator for Illinois District Four
(hereinafter referred
to
as Illinois District Four ).
28. Sometime prior to April 30, 2014, Defendant, Little League, issued a charter to
Defendant, JRWLL.
29. On or about April 30, 2014, Defendant, JRWLL, submitted its 2014 boundary
map (hereinafter referred to as the JRW Map ) to Illinois District Four n compliance with the
Little League's rules and regulations.
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30. Sometime thereafter, Illinois District Four emailed the JRW Map to the Little
League Central Region Headquarters in Indianapolis, and the Little League Central Region
confirmed that the JRW Map had been received.
31. n or about May
1
2014, the 2014 regular season for the Defendant, JRWLL,
began.
32. Defendant, JRWLL, played regular season games from May
1
2014, to June 30,
2014.
33. During this regular season, the League coaches, Plaintiff, Darold Butler, along
-
1
with the other coaches Houston and Little, selected a Tournament Team from the best players
.
in
the League.
34. According
to
the tournament rules o the Little League, [i]t shall be the league
president's responsibility
to
review and certify the birth records (league age) by viewing the
original birth record and residence (as defined by Little League Baseball, Incorporated) o all
players. When the league finally decides on the makeup o the team, names must be entered on
the league's Eligibility Affidavit. Once the District Administrator certifies the Eligibility
Affidavit, the tournament team will be required
to
have in its possession: (1) the Eligibility
Affidavit; (2) a map showing the actual boundaries
o
the league, with locations noted for the
residences o the parent or legal guardian (court appointed) or location o the school for every
participant named on the affidavit; (3) tournament verification form for each player (strongly
recommended); (4) three or more documents
to
determine residency o the parent(s) or legal
guardian (court appointed) or a document
to
support school attendance/enrollment for each
player named on the tournament affidavit; (5) waivers .. .. Ex.
A
Tournament Eligibility
Affidavit, p. T -4
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35. Prior to every tournament level game the Eligibility Affidavit o each team must
e
certified by the District Administrator or his/her appointee and presented
to
the Tournament
Director.
36. The JRW Parents along with the rest
o
the Tournament Team parents then
submitted residency documents and birth certificates
to
Defendant Bill Haley.
37. At no time did Bill Haley inform the JRW Parents that their children were
ineligible
to play due to residency requirements.
38. At no time from April 2014 to August
o
2014 were any
o
the JRW Parents
aware o any residency issues that may have existed under rules o Defendant Little League.
39. From July 3 2014 to July 7 2014 the JRW League hosted the Illinois District
Four Tournament and advanced to the next tournament round.
40. From July 14 2014 to July 21 2014 the JRW Tournament Team participated in
the Illinois Section Three Tournament in Hegewisch Illinois which they won and again
· advanced.
41. The Illinois Section Three Tournament is where the JRW Tournament team
encountered Defendants Evergreen Park Athletic Association and Defendant Chris Janes.
42. From July 22 2014 to July 27 2014 th JRW Tournament Team attended and
won the Illinois State Championship in Manteno Illinois and earned a spot in th Great Lakes
Regional Tournament in Indianapolis.
43. At the Illinois State Championship volunteers working for the event were
charged with verifying the eligibility
o
the players on each participating team including the
JRW Tournament Team.
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44. From July 31, 2014, to August 9, 2014, the Great Lakes Regional Tournament
was held, which included participating teams from six states, and was televised by ESPN.
45. Plaintiff Darold Butler, as Coach o the JRW Tournament Team, submitted a
residency binder to Defendant Little League through its Central Region Tournament Director,
Scott Spillman (hereinafter referred
to
as Spillman ).
46. That residency binder included the JRW Map, the birth certificates o each
participating player, and the proo o residency documents for each JRW Tournament Team
player.
47. Defendant Little League was responsible for revtewmg and scrutinizing the
• residency documents with the boundary map, and then confirming the eligibility o each player
participating in the tournament.
48.
On information and belief, Little League was aware o the potential residency
issues o the children
o
the JRW Parents, but chose to ignore and/or deliberately conceal these
I
: facts in order to garner higher ratings, publicity, and money for Defendant Little League.
49. On or about August 9, 2014, the JRW Tournament Team defeated Indiana and
won the Great Lakes Regional Tournament; thereby advancing to the Little League World Series
Tournament.
50. From August
10
2014, to August 23, 2014, the JRW Tournament Team
continued to advance and succeeded in winning the United States Championship.
51. On or about August 24, 2014, the Jackie Robinson West Tournament Team was
defeated by South Korea in the International Championship game.
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52. From April 30, 2014, to August 24, 2014,
no
complaints were lodged against the
JRW Tournament team for ineligibility, and no one informed any of the JRW Parents that there
was any problem with the residency
of
the players.
53. Instead of alerting the JRW Parents, the JRW Tournament Coach Darold Butler,
or the JRW Tournament Team members, Defendant Little League and Defendant JRWLL chose
to conceal and/or ignore any and all potential residency issues that existed during the
tournament.
54. In or around August of2014 Defendant JRWLL submitted its map and boundary
information to the Central Regional Assistant Tournament Director, Scott Spillman ( Spillman ).
55. In or around August
of
2014, Spillman expressly approved the information
submitted by Defendant JRWLL.
56. At all times relevant, Spillman was the assistant to the Tournament Director, Nina
Johnson.
57. At no time during the tournament was any protest or complaint raised against
JRWLL.
58.
n
September 9, 2014, Nina Johnson sent an email
to
JRW Coach Bill Haley,
indicating that there were ineligible players on the JRW Tournament Team.
59. In or around this time, Central Region Tournament Director Nina Johnson
contacted JRW owner Bill Haley about the JRW Map, but only after JRW had won the United
States Little League World Series.
60. In that September 9, 2014, email, Nina Johnson informed Defendant Bill Haley
that she had examined the map herself and told Coach Haley that eleven
of
the JRW players
lived within the proper boundaries and that two players lived outside of the boundaries.
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61. Nina Johnson and Pat Wilson expressly informed Bill Haley in September and
October 2014 that there were JRW players who lived outside the proper boundaries, however,
neither Defendant Little League, Defendants JRWLL, Bill Haley, nor Annie Haley take any
further steps to acknowledge the potential problem.
62. On or around November 6 2014, Defendant Little League organized a trip for the
JRW Tournament Team
to visit the White House and arranged for the JRW Team to attend the
Major League Baseball World Series in San Francisco.
63. Defendant Little League CEO Steve Keener and Rules Chairman Pat Wilson
accompanied the JRW Team to the White House and are included in the picture with President
Barack Obama.
64. After the visit with the President, Little League distributed the pictures from the
visit worldwide.
65. On information and belief, Defendant Little League deliberately capitalized on the
notoriety
o
the JRW Team and the JRW Parents
in
order
to
bolster its corporate image, gain
donations and otherwise profit from the unique appeal
o
the JRW Tournament Team.
66. On information and belief, Little League motivation
to
enhance its corporate
image
to
raise, among other things, the value o its television deal with ESPN.
67. At no time relevant did Defendant Little League contact JRW Coach Darold
Butler
to
determine what he knew or did not know regarding the childrens residency.
68. Defendant Little League did not contact any o the JRW Parents
to
investigate
further
as to
the residency issues.
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69. Defendant Little League did not attempt to meet with the children, directly or
even through their parents,
to
explain
to
them that there were concerns regarding their respective
residency issues.
70. Defendant Little League did not meet with District Four Administrator Michael
Kelly to determine what was known about the boundary issues.
71 Defendant Little League did not expressly meet with anyone affiliated with JRW
and provide an explanation as
to
which rule or rules n the relevant rulebook were at issue and
potentially violated.
72
Defendant Little League failed
to
perform an adequate investigation either
, Individually, or
in
compliance with its own rules, policies or procedures.
73. In December o 2014, Steve Keener, ( Keener ) made public statements clearing
JR W
o
any wrongdoing.
74. Even
i
there were boundary issues with JRW, Keener himself either determined
: that the JRW Tournament Team's eligibility was not violating
o
Little League Rules or
: deliberately canceled the boundary issues
so
that could profit through the unique appeal o the
JRW Tourmament Team
in
its contract with Little League and ESPN.
75. During this period, Chris Janes, Individually and as agent o Evergreen Park
Athletic Association, had filed a grievance with the Little League about the JRW player
residences.
76 According
to
the Little League Rules o play any Protest regarding Rule
violations and player ineligibility must have been raised before the subject Tournament
is
completed.
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77. Keener himself publicly acknowledged that no protests or complaints were raised
in a timely manner and in accordance with Little League rules.
78. On information and belief following the success o the JRW Team Defendant
Little League through its agent and CEO Steve Keener entered into a television rights
agreement with ESPN.
79. On or about December 23 2014 Defendant JRWLL through its agent Bill Haley
had attempted to absorb territories around Chicago-land from other leagues
in
order to
retroactively legitimize the eligibility
o
all the JRW Team members.
80. On or about February 11 2015 Defendant Little League announced that it was
• stripping the title from the JRW Tournament Team without giving the JRW Team or the JRW
Parents advance notice due process or an opportunity to be heard and
in
contravention to the
rules outlined
in
the Little League Handbook.
81
Immediately prior to Defendant Little League announcing that the title had been
I stripped ESPN broke the story before any o the JRW players or their families were informed.
I
I
82.
The press release issued by Little League on February 11 20
15
failed to mention
- -- its Official Regulations and/or procedures for stripping the title from the JRW Team.
83. The memorandum sent by Little League to JRW on February 12 2015 also failed
to mention the Official Regulations.
84.
The Official Regulations contain the rules that govern all teams that play Little
League baseball.
85. ESPN continually aired the Jackie Robinson West tournaments and reported on
circumstances surrounding the stripping o the World Series Title from the JRW Tournament
Team.
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86. At all times relevant, neither the players on the JRW Tournament Team, nor the
JRW Parents submitted any boundary maps
to
JRWLL or Little League.
87. At all times relevant, neither the players on the JRW Tournament Team, nor the
JRW Parents accepted any boundary maps from JRWLL or Little League.
88. At all times relevant, neither the players on the JRW Tournament Team, nor the
JRW Parents approved any boundary maps for JRWLL or Little League.
89 Finally, Defendant Little League misrepresented the facts involved by asserting
that an altered boundary map was the boundary map submitted in the tournaments.
90. In reality, the original JRW Map submitted
to
at the tournaments and
to
· Defendant Little League was true and correct, and for that reason Defendant Little League was
· aware of the eligibility issues with the JRW Players as soon as the original JRW Boundary Map
, was submitted in August
of2014.
COUNT ULTRA VIRES
Against Little League)
1.-90. Plaintiffs repeat and reallege Paragraphs 1 through 90 of Common Facts as
· Paragraphs 1 through 90
of
Count I as though set forth fully herein.
91. The stripping of the World Series Title was contrary
to
the rules and procedures
established by Defendant Little League, thereby not affording Plaintiffs JRW Parents and/or the
JRW Team sufficient due process.
92. Pursuant to the Little League 2014 Baseball Official Regulations with Playing and
Tournament Rules if the facts establishing or verifying the ineligibility
of
a player become
known AFTER [sic] a game, and the ineligible player participated in the game, that team shall
forfeit the game in question, subject to the following conditions: a) A protest may be lodged by
the manager or coach with the Tournament Director or District Administrator.
uch protest
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must be made before either team affected by the protest begins another game.
(b) The
Tournament Director or District Administrator must contact the Regional Director (or his/her
appointed agent), who shall contact the Tournament Committee for a decision.
The decision
of
the Tournament Committee shall be
fin l nd
binding. Little League 2014 Baseball Official
Regulations with Playing and Tournament Rules at T-11 Conditions ofTournament Play §C(3)
(emphasis added).
93. No protests were made against the JRW Tournament Team until after the
tournament was completely over; including both national and international tournament play.
94. On information and belief, the facts
of
this matter were never submitted to any
Tournament Committee, but instead the decision was made unilaterally by the administration
of
i
Defendant Little League.
95. Defendant Little League was influenced by bias, prejudice, and/or did not act in
: good faith when it stripped Plaintiffs of the World Series title, and it did not follow the
prescribed procedures.
96. Little League s actions are contrary to rudimentary due process and natural
- justice.
97. As a result ofDefendant Little League s disregard for their own procedures,
Plaintiffs were severely damaged both emotionally and economically when the title was stripped.
WHEREFORE, Plaintiffs, DEVONA
D.
BENTON and FRANK JACKSON,
individually, and on behalfof their minor child, J. B.; ROBERTS BUFFORD, JR., Individually,
and on behalf
of
their minor child, C.B.; DAROLD BUTLER, SR. and DONITA BRUCE,
individually, and on behalf
of
their minor child, D.B.; VENISA BEASLEY -GREEN and
CHRISTOPHER GREEN, individually, and on behalf
of
their minor child, B.G.; CARLTON A.
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HONDRAS,
II
and SHEREE HONDRAS, individually, and on behalf o their minor child, C.H.;
JERRY F HOUSTON and MYRTLE HOUSTON, individually, and on behalf
o
their minor
child, J.H.; EDWARD HOWARD III, and CALANDRA HOWARD, individually, and
on
behalf
o their minor child, E.H.; LINDA SNEED HARRIS, individually, and on behalf o her minor
child, M.J.; NEDRA JONES and ALVIN JONES, individually, and on behalf o their minor
child, P.J.; TAMMY KING and EDDIE KING, SR., Individually, and on behalf o their minor
child, E.K.; PRENTISS LUSTER and DARLENE LUSTER individually, and on behalf o their
minor child, P.R.; SANJA E NOBLE, Individually, and on behalf
o
her minor child, L.N.; and
CLAUDIA HARVEY, individually, and on behalf o her minor child, D.R.; respectfully request
that this Honorable Court award Plaintiffs an amount
in
excess o 50,000.00 for pain and
suffering and lost prospective economic benefits, reinstate the World Series Title to JRW, and
for such other and further relief as this Court deems just and proper.
COUNT UNJUST ENRICHMENT
Against JRWLL and Little League)
1.-97. Plaintiffs repeat and reallege Paragraphs 1 through 97 o Count I
as
Paragraphs 1
through 97 o Count
II
as though set forth fully herein.
98. Defendant JRWLL and Defendant Little League orchestrated and/or concealed
the ineligibility o the JRW Team Members
in
order to reap the benefits o the notoriety and
media attention.
99. Defendant JRWLL and Defendant Little League earned hundreds o thousands o
dollars
as
a result o their concealment and deception.
100
Plaintiffs JRW Parents paid league fees and costs
to
Defendant JRWLL and
Defendant Little League.
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·o
LI l
I 0 I. This benefit
of
these earned monies and fees were retained to the detriment
of
JRW Parents.
102. Defendant JRWLL's and Defendant Little League's retention of these benefits
violates the fundamental principles of ustice, equity, and good conscience.
WHEREFORE, Plaintiffs, DEVONA D BENTON and FRANK JACKSON,
individually, and on
behalf of
their minor child, J B.; ROBERTS. BUFFORD, JR., Individually,
and on behalf of their minor child, C.B.; DAROLD BUTLER, SR. and DONITA BRUCE,
individually, and on behalf of their minor child, D.B.; VENISA BEASLEY -GREEN and
CHRISTOPHER GREEN, individually, and on behalf of their minor child, B.G.; CARLTON A
HONDRAS, II and SHEREE HONDRAS, individually, and on behalf of their minor child,
C
H ;
::
JERRY
F
HOUSTON and MYRTLE HOUSTON, individually, and on behalf
of
their minor
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103 Defendant JRWLL through its agents Bill Haley and Annie Haley deliberately
ignored and/or concealed the eligibility problems
o
the JRW Tournament Team in conjunction
with Defendant Little League in order
to reap the rewards o the short-lived fame and media
attention.
104 Defendant Chris Janes individually and as agent, servant, or employee
o
Evergreen Park Athletic Association, and Evergreen Park Athletic Association, individually and
through its agent, servant, or employee Chris Janes, intentionally investigated the JRW
Tournament Team and delayed until after the tournament was over to raise their complaints.
105 Defendant Little League despite reviewing the boundary map and eligibility
documents o the JRW Parents failed to alert any
o
the parents or coaches that the JRW players
1 were ineligible
to
play.
106
Defendant JRWLL and Defendant Little League failed
to
act until after JRW
Tournament Team won the Little League World Series.
107 Furthermore, following the discovery
o
the residency problems, Defendant Little
: League failed to follow appropriate prescribed procedures and stripped Plaintiffs World Series
Title without due process
o
law.
108
Subsequently, JRWLL through its agent Bill Haley perpetuated the distress by
stating that he was organizing a petition to send to Defendant Little League in an attempt to
reinstate the title.
109 Despite the players and family having collected thousands o signatures and
delivering them to Bill Haley, JRWLL failed
to
send those petitions to Defendant Little League.
110 On information and belief, these petitions were nothing more than a fiction
created by Defendant JRWLL to placate the JRW Parents.
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0
u l
Il l . ESPN then failed to heed the warning ofDefendant Little League and released the
news that the JRW Team was being stripped
of
its title before the team even knew.
112. The young players first became aware through the news that the title they had
worked
so
hard
to
achieve had been stripped from them over an alleged technicality.
113. In the ensuing media coverage, ESPN and Stephen Smith accused the JRW
Parents
of
falsifying documents and perpetrating a fraud upon the Little League.
114. Those statements were patently false and were baseless and without merit.
115. All of these events were deliberate acts by Defendants, while they ignored the
well being
of
Plaintiff JRW Parents and their participating minor children.
116. The conduct ofDefendants referenced above was extreme and outrageous.
l ::1 117. Defendants knew or had reason to know that there was a high probability that
~ < Q O M
• . . . . l o ~ ;
•
: ; § g .
their conduct would cause the JRW team members severe emotional distress.
U\O_J
ZO ~ lb
~
118. Plaintiff JRW Parents, Individually and on behalf
of
their minor children, have
: : : ; ; ~
1- -NQ. . ;
~
•
:
been severely emotionally damaged as a result ofDefendants conduct. .
u . l
WHEREFORE, Plaintiffs, DEVONA D BENTON and FRANK JACKSON,
individually, and on
behalf
of their minor child, J B.; ROBERTS. BUFFORD, JR., Individually,
and on behalf
of
their minor child, C.B.; DAR OLD BUTLER, SR. and DO NIT A BRUCE,
individually, and on behalf
of
their minor child, D.B.; VENISA BEASLEY-GREEN and
CHRISTOPHER GREEN, individually, and on behalf of their minor child, B.G.; CARLTON A
HONDRAS, II and SHEREE HONDRAS, individually, and on behalf
of
their minor child, C.H.;
JERRY
F
HOUSTON and MYRTLE HOUSTON, individually, and on behalf
of
their minor
child, J.H.; EDWARD HOWARD III, and CALANDRA HOWARD, individually, and on behalf
of
their minor child, E.H.; LINDA SNEED HARRIS, individually, and on behalf
of
her minor
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child, M.J.; NEDRA JONES and ALVIN JONES, individually, and on behalf of their minor
child, P.J.; TAMMY KING and EDDIE KING, SR., Individually, and on behalf of their minor
child, E.K.; PRENTISS LUSTER and DARLENE LUSTER individually, and on behalf of their
minor child, P.R.; SANJA
E
NOBLE, Individually, and on behalf of her minor child, L.N.; and
CLAUDIA HARVEY, individually, and on behalfofher minor child, D.R.; respectfully request
that this Honorable Court award Plaintiffs an amount in excess
of
$50,000.00 for pain and
suffering, award amounts due for lost prospective economic benefits, reinstate the World Series
Title upon the JRW, and for such other and further relief as this Court deems just and proper.
COUNT
IV-DEFAMATION
P R S
(Against Defendants ESPN, Inc.
and
STEPHEN
A
SMITH)
1.-118. Plaintiffs repeat and reallege Paragraphs 1 through
118
of Count III as Paragraphs
1 through
118
of Count IV as though set forth fully herein.
119 On or about February
11,2014,
ESPN2 aired an episode
of First
Take with
Stephen A Smith.
120 During that episode, Stephen
A
Smith directly accused the JRW Parents
of
perpetrating a fraud against the Little League.
121 Specifically, Stephen A Smith stated that the JRW Parents falsified documents
and engaged in deceit when referencing the ineligible residences of the players.
122. Stephen
A
Smith stated that the picture ofDarold Butler was throw kids into the
wind like this and that his face should be put on the screen and treat[ed] it like the mug shot it
deserves to be treated like.
123
Stephen
A
Smith, Individually and as agent, servant, or employee of ESPN,
defamed and slandered Darold Butler by indirectly and directly stating that he had engaged in
criminal, fraudulent acts.
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0
U l
124 Stephen A. Smith Individually and as agent servant or employee of ESPN
accused the JRW Parents of falsifying documents and perpetrating a fraud upon the Little
League.
125 Stephen A. Smith Individually and as agent servant or employee of ESPN
defamed the JRW Parents by indirectly and directly stating that they had engaged in criminal
fraudulent acts.
126 These statements and inferences by Stephen A Smith and ESPN were false when
made and Defendants Smith and ESPN knew or had reason
to know that they were false when
made.
127
The statements of Stephen
A
Smith showed a reckless disregard for the
d
individuals involved and the facts
of
the case
.
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child, M.J.; NEDRA JONES and ALVIN JONES, individually, and on behalf
of
their minor
child, P.J.; TAMMY KING and EDDIE KING, SR., Individually, and on behalf of their minor
child, E.K.; PRENTISS LUSTER and DARLENE LUSTER individually, and on behalf
of
their
minor child, P.R.; SANJA E. NOBLE, Individually, and on behalf
of
her minor child, L.N.; and
CLAUDIA HARVEY, individually, and on behalf
of
her minor child, D.R.; respectfully request
that this Honorable Court award Plaintiffs an amount in excess
of
$50,000.00 for pain and
suffering, award amounts due for lost prospective economic benefits and loss
of
reputation, and
for such other and further relief as this Court deems just and proper.
COUNT FALSE LIGHT
(Against Defendants Little League, ESPN,
and
Stephen A. Smith)
G
l.-128. Plaintiffs repeat and reallege Paragraphs 1 through
128
ofCount IV as Paragraphs
d
~ ~
~
~
1
1 through
128 of
Count V
as
though set forth fully herein .
....lOoo:t.._.
....l
t ; l ~
0
•
:t:oo N
· U1 N 129. On or about February 11 2014, Defendant Little League stripped
the
mmor
z 8 ~ ' - l ,
. ~ S ; ~
• E < - N
Q.4
Plaintiffs
of
their Championship title.
· ~
'- 1
....l
'- 1
130.
Defendant Little League publically announced that the title had been stripped
because some
of
the team members did not qualify under the residency requirements
of
Little
League.
131. Defendant Little League would go on to discuss that the JRW boundary map had
been altered, and publically questioned the residences
of
the JRW Parents.
132. These acts portrayed the JRW Parents and the minor Plaintiffs in a false light and
damaged their reputation.
133.
On or about February 11, 2014, ESPN2 aired an episode
of
First Take with
Stephen A. Smith.
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U l
134 During that episode, Stephen
A
Smith directly accused the JRW Parents of
perpetrating a fraud against the Little League.
135 Specifically, Stephen A Smith stated that the JRW Parents falsified documents
and engaged in deceit when referencing the ineligible residences of the players.
136 Stephen A Smith stated that the picture
of
Darold Butler was throw kids into the
wind like this and that his face should be put on the screen and treat[ ed] it like the mug shot it
deserves
to
be treated like.
137 Stephen A Smith, Individually and as agent, servant, or employee of ESPN,
defamed and slandered Darold Butler by indirectly and directly stating that he had engaged
in
criminal, fraudulent acts.
1 I 138 Stephen
A
Smith, Individually and as agent, servant, or employee
of
ESPN,
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Darold Butler and the other JRW Parents were tarnished irreparably, and all have been damaged
emotionally and economically as a result.
WHEREFORE, Plaintiffs, DEVONA
D
BENTON and FRANK JACKSON,
individually, and on behalf
of
their minor child,
J
B.; ROBERTS. BUFFORD, JR., Individually,
and on behalf of their minor child, C.B.; DAROLD BUTLER, SR. and DONITA BRUCE,
individually, and on behalf of their minor child, D.B.; VENISA BEASLEY -GREEN and
CHRISTOPHER GREEN, individually, and on behalf of their minor child, B.G.; CARLTON
A
HONDRAS,
II
and SHEREE HONDRAS, individually, and on behalf of their minor child, C.H.;
JERRY
F
HOUSTON and MYRTLE HOUSTON, individually, and on behalf of their minor
: child, J.H.; EDWARD HOWARD III, and CALANDRA HOWARD, individually, and
on
behalf
of their minor child, E.H.; LINDA SNEED HARRIS, individually, and on behalf of her minor
child, M.J.; NEDRA JONES and ALVIN JONES, individually, and on behalf of their minor
child, P.J.; TAMMY KING and EDDIE KING, SR., Individually, and on behalf of their minor
child, E.K.; PRENTISS LUSTER and DARLENE LUSTER individually, and on behalf of their
minor child, P.R.; SANJA
E
NOBLE, Individually, and on behalf of her minor child, L.N.; and
CLAUDIA HARVEY, individually, and on behalf of her minor child, D.R.; respectfully request
that this Honorable Court award Plaintiffs an amount in excess of 50,000.00 for pain and
suffering, award amounts due for lost prospective economic benefits, and for such other and
further relief as this Court deems just and proper.
COUNT
VI-INVASION OF PRIVACY
(Against
CHRIS
JANES, individually
and
as agent, servant,
or
employee
of
Evergreen
Park Athletic Association,
and EVERGREEN
PARK ATHLETIC ASSOCIATION,
individually and through its agent, servant, or employee Chris Janes
1-142. Plaintiffs repeat and reallege Paragraphs 1 through
142 of
Count V
as
Paragraphs
1 through 142
of
Count
VI
as though set forth fully herein.
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143 The JRW parents home addresses were obtained without lawful authority.
144
Janes committed
an
invasion or privacy against the JRW parents when he used
their license plates to discover their home addresses to report them to Little League.
145 At all relevant times, Chris Janes knew that the addresses were obtained through
questionable and potentially illegal means.
146
Chris Janes publicized Plaintiffs private addresses and information
to
Defendant
Little League.
14
7 As a result o the actions o Chris Janes, Plaintiffs were publicized
in
a false light
and painted as criminals.
148 As
a direct and proximate result o the actions o Chris Janes, individually and as
agent, servant, or employee
o
Evergreen Park Athletic Association, and Evergreen Park Athletic
: Association, individually and through its agent, servant, or employee Chris Janes, Plaintiffs were
severely damaged.
WHEREFORE, Plaintiffs, DEVONA
D
BENTON and FRANK JACKSON,
individually, and on behalfo their minor child, J B.; ROBERTS. BUFFORD, JR., Individually,
and on behalf
o their minor child, C.B.; DAROLD BUTLER, SR. and DONITA BRUCE,
individually, and on behalf
o
their minor child, D.B.; VENISA BEASLEY-GREEN and
CHRISTOPHER GREEN, individually, and on behalf
o
their minor child, B.G.; CARLTON
A
HONDRAS,
II
and SHEREE HONDRAS, individually, and on behalf
o
their minor child,
C H ;
JERRY
F
HOUSTON and MYRTLE HOUSTON, individually, and on behalf o their minor
child, J.H.; EDWARD HOWARD III, and CALANDRA HOWARD, individually, and
on
behalf
o their minor child, E.H.; LINDA SNEED HARRIS, individually, and on behalf o her minor
child, M.J.; NEDRA JONES and ALVIN JONES, individually, and on behalf o their minor
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child, P.J.;
TAMMY
KING and EDDIE KING, SR., Individually, and on behalf of their minor
child, E.K.; PRENTISS LUSTER and DARLENE LUSTER individually, and on
behalf of
their
minor child, P.R.; SANJA E NOBLE, Individually, and on
behalf of
her minor child, L.N.; and
CLAUDIA HARVEY, individually, and on
behalf
of her minor child, D.R.; respectfully request
that this Honorable Court award Plaintiffs an amount in excess of 50,000.00 for pain and
suffering, award amounts due for lost prospective economic benefits, and for such other and
further relief as this Court deems just and proper.
i James A Karamanis
I
Shane M. Bradwell
: Kenneth A. Nazarian
I •
1 Barney Karamams, LLP
• Two Prudential Plaza
: 180 N. Stetson, Suite
3 5
: Chicago, Illinois 60601
Phone: 312-553-5300
Attorney No.: 48525
26
Respectfully submitted,
By:
Is
James A. Karamanis
One
of
Plaintiffs' Attorneys