Preview
DocuSign Envelope ID: 0B301D78-A8A9-4BC7-8D71-E93D3938DE75
FILED
Hearing Date: 10/9/2024 9:30 AM 6/11/2024 3:16 PM
Location: Court Room 2408 IRIS Y. MARTINEZ
Judge: Conlon, Alison C CIRCUIT CLERK
COOK COUNTY, IL
2024CH05491
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS Calendar, 4
COUNTY DEPARTMENT, CHANCERY DIVISION 28068165
MARCUS TAYLOR,
Plaintiff,
2024CH05491
Vv. N
MARQUIS L. JORDAN and
NICOLE LATICE WHITAKER,
JOHN DOE 1-4,
Defendants.
COMPLAINT AT LAW
AND PETITI ON FOR PRELIMINARY INJUNCTION
the Plaintiff, MARCUS TAYLOR. (hereinafter referred to as
NOW COMES
P.C., complains of
“PLAINTIFF”), by and through his attorneys, of the MILLER LAW FIRM,
(“NICOLE”) and
MARQUIS L. JORDAN (“JORDAN”) and NICOLE LATICE WHITAKER
as follows:
JOE DOE 1-4 (hereinafter jointly referred as “DEFENDANT: 'S”), states
NATURE
OF ACTION
for false
This is an action for injunctive relief and for damages against DEFENDANTS
PLAINTIFF under
and defamatory statements and published by DFEFENDANTS concerning
t to TBS
Ullinois Slander and Libel Act (740 ILCS 145) and a Preliminary Injunction pursuan
ILCS 5/11/1014.
PARTIES
1 PLAINTIFF is an individual who resides in Tennessee.
County,
2. Defendant, JORDAN is an individual who resides in Riverdale, Cook
Ulinois.
DocuSign Envelope ID: 0B301D78-A8A9-4BC7-8D71-E93D3938DE75
3 Defendant, WHITAKER, is an individual who resides in Toledo, Ohio.
JURISDICTION AND VENUE
4 This Court has jurisdiction over the subject matter hereof and the parties hereto
pursuant to 735 ILCS 5/2-209(a)(2), as the DEFENDANTS conducted tortious acts in Cook
County, Illinois.
5 Venue is proper pursuant to 735 ILCS 5/2-101 as the action arose, in part, out of
activities in Cook County, Illinois.
STATEMENT OF FACTS
6 On or about May 26, 2023, the PLAINTIFF and DEFENDANTS attended Combo
Breaker 2023, a gaming event located at the Schaumburg Convention Center, 1551 Thoreau
Drive, Schaumburg, Illinois.
7. On or about December 31, 2023, JORDAN knowingly and maliciously made false
statements against PLAINTIFF that were defamatory and were published on social platform
(formerly Twitter). (See Exhibit “A” attached hereto and are also found at
and httz://twitter.com/Shadow20z/status/ 1741367931215212544 and
http://twitter.com/Shadow20z/status/1741536184373743 756).
8 JORDAN’S defamatory statements impugned PLAINTIFF’S character and
damaged PLAINTIEF’S personal and professional reputation.
9. Onor about December 31, 2023, NICOLE knowingly and maliciously made false
platform
statements against PLAINTIFF that were defamatory and were published on social
(formerly Twitter). (See the following:
and htt:://twitter,com/Shadow20z/status/1741367931215212544 and
http://twitter.c m/Shadow20z/status/174 41536184373743756).
DocuSign Envelope ID: 0B301D78-A8A9-4BC7-8D71-E93D3938DE75
10, NICOLE’S defamatory statements impugned PLAINTIFF'S character and
damaged PLAINTIFF’S personal and professional reputation.
defamatory
11. Onorabout January 2, 2024, NICOLE made additional slanderous and
r Spaces). (See the
statements against PLAINTIFF in a public forum known as “Spaces” (Twitte
following: http://twitter.com/i/10dJrjMgoXkIX?s=20).
publish
12. On information and belief, both DEFENDANTS, continue to knowingly
false statements about PLAINTIFF to third parties.
in writing to cease
13. Onor about January 5, 2024, both DEFENDANT 'S were advised
to remove
and desist making false malicious statement about the PLAINTIFF and advised
all postings containing the defamatory statements.
14, Both DEFENDANTS have refused to remove their defamatory postings and
nts about the
continue to knowingly spread false and misleading defamatory stateme
PLAINTIFF.
NDANTS
15. The false, misleading and defamatory statements made by the DEFE
platforms.
have been communicated to more than 265,000 individuals on social media
COUNT I
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
of this count
16. PLAINTIFF repeats and realleges paragraphs 1-15 as paragraphs 1-16
and incorporates same by reference as though fully contained herein.
17. DEFENDANTS have engaged in a pattern of egregious misconduct with respect to
are defamatory in nature
knowingly making false and misleading statements to third parties that
against the PLAINTIFF.
18. DEFENDANTS?’ conduct was extreme and outrageous.
DocuSign Envelope ID: 0B301D78-A8A9-4BC7-8D71-E93D3938DE75
19. DEFENDANTS intended that their conduct inflict severe emotional distress (or
such distress); the conduct
knew that there was a high probability that the conduct would cause
knew that severe emotional distress would be certain or
was such that DEFENDANTS
substantially certain to result.
20. The conduct caused severe emotional distress to the PLAINTIFF.
d to
21. The distress inflicted was so severe that no reasonable person could be expecte
endure it.
22. As a direct and proximate cause of DEFENDANTS’ misconduct, PLAINTIFF
suffered tremendously, emotionally, and financially.
t in his favor and
Wherefore, Plaintiff, MARCUS TAYLOR, respectfully requests judgmen
E WHITAKER, in an amount
against Defendants, MARQUIS L. JORDAN and NICOLE LATIC
relief as it deems just
in excess of $50,000.00, plus costs, and that the Court awards such further
and equitable.
COUNT Il
DEFAMATION PER SE
of this count
23 PLAINTIFF repeats and realleges paragraphs 1-22 as paragraphs 1-23
and incorporates same by reference as though fully contained herein.
24. DEFENDANTS knowingly made false and misleading defamatory statements
which were published to
about the PLAINTIFF on December 31, 2023, and January 2, 2024,
and his personal and professional
numerous third parties, damaged the PLAINTIFF °§ character
reputation.
TIFF has
25. Asa direct and proximate cause of DEFENDANTS’ misconduct, PLAIN
suffered tremendously, emotionally and financially
DocuSign Envelope ID: 0B301D78-A8A9-4BC7-8D71-E93D3938DE75
knowledge
26. These defamatory statements were made by the DEFENDANTS with
e damages.
of their falsity and with actual malice, so as to justify an award of punitiv
nt in his favor and
Wherefore, Plaintiff, MARCUS TAYLOR, respectfully requests judgme
E WHITAKER, in an amount
against Defendants, MARQUIS L. JORDAN and NICOLE LATIC
relief as it deems just
in excess of $50,000.00, plus costs, and that the Court awards such further
and equitable.
COUNT It
PRELI MINAR Y INJUNCTION
of this count
27. PLAINTIFF repeats and realleges paragraphs 1-26 as paragraphs 1-27
and incorporates same by reference as though fully contained herein.
that that the
28. PLAINTIFF is likely to be successful on the merits of his argument
us third
DEFENDANTS knowingly made defamatory statements which were published to numero
profession reputation.
parties, damaged the PLAINTIFF’S character and his personal and
are
29. PLAINTIEF will be immediately and irreparably damaged if DEFENDANTS
not enjoined from making further derogatory statements to third parties.
NDANTS are
30. LAINTIFF will be immediately and irreparably damaged if DEFE
posts.
not immediately ordered to remove the false and misleading social media
31. PLAINTIFF has no adequate remedy at law to protect his interests if the
social media
DEFENDANTS are not enjoined from knowingly making additionally defamatory
posts and removing the current defamatory social media posts.
injunction should issue, as DEFENDANTS knowingly made
32. A preliminary
TIFF
defamatory social media posts, will irreparably damage the PLAIN
quo during the
33. The entry of a preliminary injunction will preserve the status
adjudicate rights of the parties.
pendency of these proceedings and will enable the court to properly
DocuSign Envelope ID: 0B301D78-A8A9-4BC7-8D7 1-E93D3938DE75
y.
34. Damage to the DEFENDANTS as a result of this injunction are unlikel
Preliminary
35. Plaintiff's affidavit is attached hereto as Exhibit 5 in support of the
Injunction.
as follows:
WHEREFORE, the Plaintiff, MARCUS TAYLOR, respectfully prays
ion.
That this Honorable Court grant Plaintiff s Petition for a Preliminary Injunct
Preliminary
That this Court issue a written order stating the reasons for granting the
Injunction.
ning and Ordering the
That this Court issue a Preliminary Injunction, enjoining, restrai
Defendants to cease making derogatory statements and removi ng the current derogatory
statements on social media regarding the Plaintiff.
may deem
For such other and further relief in the premises as this Honorable Court
equitable and just.
\
leas tfully submitted,
_ YG | LL,
/
MaR{ Us TAY /))
/
lA
By
“One of its attofleys
Richards J. Miller
Miller Law Firm, P.C.
1051 Perimeter Drive, Suite 400
Schaumburg, IL 60173
847-995-1205
Attorney No. 44336
richard. miller@millerlawfirm.org
DocuSign Envelope ID: 0B301D78-A8A9-4BC7-8D71 |-E93D3938DE75
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, CHANCERY DIVISION
MARCUS TAYLOR,
Plaintiff,
Vv.
No
MARQUIS L. JORDAN and
NICOLE LATICE WHITAKER,
JOHN DOE 1-4,
Defendants.
AFFIDAVIT OF MARCUS TAYLOR
this
I, MARCUS TAYLOR, the undersigned, being first duly sworn on oath, submits
s Code of Civil Procedure
affidavit under penalties provided by law pursuant to Section 1- 109 of the Illinoi
correct.
and certifies that the statements set forth in this Affidavit are true and
1 Lam the Plaintiff in the above captioned action.
ents
2. Defendants knowingly made false and misleading defamatory statem
were published to numerous third
about the me on December 31, 2023, and January 2, 2024, which
ion.
parties, damaged my character and my personal and profession reputat
are not
3 I will be immediately and irreparably be damaged if the Defendants
defamatory statements against
enjoined from knowingly making any further false and misleading
ding defamatory statements
me and from being ordered to remove the current false and mislea
on social media.
if the Defendants
4 Ihave no adequate remedy at law to at law to protect my interests
DocuSign Envelope ID: 0B301D78-A8A9-4BC7-8D71-E93D3938DE75
atory social media posts and not
are not enjoined from knowingly making additionally defam
ordered to remove the current defamatory social media posts
5 If called to testify, I would testify to the above facts.
AFFIANT FURTHER SAYETH NAUGHT
DgcuSigned by:
MARCUS TAYLOR
SUBSCRIBED and Swom to before
me this 28th day of May 2024.
.
Public
MARY ELLEN SUMMERVILLE
Notary Public, State of tilinois
Commission No. 897189
‘My Commission Expires June 27, 2027
Miller Law Firm, P.C.
1051 Perimeter Drive, Suite 400
Schaumburg, IL 60173
847-995-1205
Attomey No. 44336
richard.miller@millerlawfirm.org
DocuSign Envelope ID: 0B301D78-A8A9-4BC7-8D7 1-E93D3938DE7S 1 me trash etc. so | responded by... https://t.co/qPV2yUrYrN* / X
2424/24, 10:49 AM
€
x Post
o
New to X?
Sign up now to get your owns
Liquid
| Shadow 202
Settings @Shadow20z
Sign up with
Extremely long thread:
© Sign
up wit
A coupie weeks ago | entered the spirit realm weekly online tournament,
during that time | teabagged another player which you guys all know by
Create aca:
the name of shinblade. This made him upset in which he responded by
EXHIBIT calling me trash etc. so | responded by saying tell them why you got By signing up, you agree to th
bagged. He then switched up his attitude & it’s time to tell the truth Privacy Policy, including Coot
behind this “beef” He’s tried to say the reason I’m doing this is over a
tournament even though we both know the truth, & we both know my
emotions within tekken would never evoke something like this so I’m Relevant people
going to tell it all.
Liquid | Shadow 2
@Shadow20z
Ijust want to start this by saying that I deeply apologize to my long time
Competitive Tekke
best friend and the women of the fgc that have been affected by this
‘8 Teamtiquio Eme
individual. As a man | find it my responsibilityto protect and honor the Shadow20z@yaht
women of our community. This has been weighing heavy on me&l
always tryto find the most non confrontational ways to handling
problems but with some situations and with some people you HAVE to
Trends are unavaifable
do the right thing. So with that being said this is what happened.
During the tournament combo breaker shinblade sexually assaulted my
best friend in his car & once outside of the car. When she told me what
happened | immediately was pissed because this is someone that I care Terms of Service Privacy Po
Accessibility Adsinfo Mor
deeply about and | also cared about him & never would’ve thought he
would disrespect me or her in that way. She never cared about the
situation initially considering her history with men engaging her sexually
out the gates due to her sex work history. But for me it made me sick
because no matter what or how a woman presents herself it doesn’t give
any man the right to take consent away from that woman. My best friend
doesn’t know him, & has no reason to lie especially to me. She trusted
him because I did. He was under the impression that she was my
girlfriend (which makes this worse tbh) so when confronted him the first
time he immediately sald “What are you talking about” He then changed
his story to “She came onto me” now months later he’s claiming “I have
a witness that seen us in the car” even tho you had tinted windows.
Everything up to this point has been lies, he can’t answer simple yes or
no questions whereas her story has never changed. He’s also sexually
KIT.
assaulted another woman | personally know at the tournament
of
Pve tried MULTIPLE times to talkto him and try to come to some type
of mine. | had to
understanding considering this was once a good friend
record our conversation because from the very beginning this is exactly
how he’s reacted to my questioning. Even tho | know my best friend isn’t
lying and never would | just wanted to hear his side but he can’t even
me
give me that. | even reached out to his girlfriend who even informed
2 women | know of for
that he’s had previous allegations outside of the
any
sexual assault which was then deemed a “lie” but | don’t know
honest man who gets random sexual allegations pinned on them back to
back. She begged me not to say anything even though I never was & my
jntontinns fram the hadinning wae ta det an annlady far me and nicki &
Dontmiss what’s appening ogin
Page 1 of 2
KTKBGAS9Q5dX 7A
https://twitter.com/shadow20z/status/174136793 1215212544 ?S=468t=xkEQO3vq
DocuSign Envelope ID: 0B301D78-A8A9-4BC7-8D71 |-E93D3938DE75 me trash ete. so | responded by... https://t.cofqPV2yUrvrn” | X 2/24)24, 10:49 AM
poyrriena was more important. ir! m peng compretely Nonest snes Te
straw that broke the camels back. She made me realize that he’s been
doing this for YEARS & she’s been enabling this behavior.
?'m so sorry for holding this information but going forward | will always
put the victim first, and this is not to say that women don'tlie & that men
feel
aren't falsely accused but I'd be lying if! didn’t say that women don’t
comfortable speaking about these situation s because this isamale
dominated space and it’s on us to hold each other accountable and to
create a safe space for EVERYBODY. | havea platform & | have a voice
and | will always make the right choice in these matters.
& bad bitch Nyc wf
@ Last edited 4:57 AM Dec 31, 2023 262.8K Views
469 Reposts 76Quotes 774Likes 342 Bookmarks
oO a 9 fA sz a
Page2 of 2
75=468t=xkE9OSvqKTKBGASIQSAX7A
httos://twitter.com/shadow20z/status/1741367931215212544
Preview
DocuSign Envelope ID: 0B301D78-A8A9-4BC7-8D71-E93D3938DE75 FILED Hearing Date: 10/9/2024 9:30 AM 6/11/2024 3:16 PM Location: Court Room 2408 IRIS Y. MARTINEZ Judge: Conlon, Alison C CIRCUIT CLERK COOK COUNTY, IL 2024CH05491 IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS Calendar, 4 COUNTY DEPARTMENT, CHANCERY DIVISION 28068165 MARCUS TAYLOR, Plaintiff, 2024CH05491 Vv. N MARQUIS L. JORDAN and NICOLE LATICE WHITAKER, JOHN DOE 1-4, Defendants. COMPLAINT AT LAW AND PETITI ON FOR PRELIMINARY INJUNCTION the Plaintiff, MARCUS TAYLOR. (hereinafter referred to as NOW COMES P.C., complains of “PLAINTIFF”), by and through his attorneys, of the MILLER LAW FIRM, (“NICOLE”) and MARQUIS L. JORDAN (“JORDAN”) and NICOLE LATICE WHITAKER as follows: JOE DOE 1-4 (hereinafter jointly referred as “DEFENDANT: 'S”), states NATURE OF ACTION for false This is an action for injunctive relief and for damages against DEFENDANTS PLAINTIFF under and defamatory statements and published by DFEFENDANTS concerning t to TBS Ullinois Slander and Libel Act (740 ILCS 145) and a Preliminary Injunction pursuan ILCS 5/11/1014. PARTIES 1 PLAINTIFF is an individual who resides in Tennessee. County, 2. Defendant, JORDAN is an individual who resides in Riverdale, Cook Ulinois. DocuSign Envelope ID: 0B301D78-A8A9-4BC7-8D71-E93D3938DE75 3 Defendant, WHITAKER, is an individual who resides in Toledo, Ohio. JURISDICTION AND VENUE 4 This Court has jurisdiction over the subject matter hereof and the parties hereto pursuant to 735 ILCS 5/2-209(a)(2), as the DEFENDANTS conducted tortious acts in Cook County, Illinois. 5 Venue is proper pursuant to 735 ILCS 5/2-101 as the action arose, in part, out of activities in Cook County, Illinois. STATEMENT OF FACTS 6 On or about May 26, 2023, the PLAINTIFF and DEFENDANTS attended Combo Breaker 2023, a gaming event located at the Schaumburg Convention Center, 1551 Thoreau Drive, Schaumburg, Illinois. 7. On or about December 31, 2023, JORDAN knowingly and maliciously made false statements against PLAINTIFF that were defamatory and were published on social platform (formerly Twitter). (See Exhibit “A” attached hereto and are also found at and httz://twitter.com/Shadow20z/status/ 1741367931215212544 and http://twitter.com/Shadow20z/status/1741536184373743 756). 8 JORDAN’S defamatory statements impugned PLAINTIFF’S character and damaged PLAINTIEF’S personal and professional reputation. 9. Onor about December 31, 2023, NICOLE knowingly and maliciously made false platform statements against PLAINTIFF that were defamatory and were published on social (formerly Twitter). (See the following: and htt:://twitter,com/Shadow20z/status/1741367931215212544 and http://twitter.c m/Shadow20z/status/174 41536184373743756). DocuSign Envelope ID: 0B301D78-A8A9-4BC7-8D71-E93D3938DE75 10, NICOLE’S defamatory statements impugned PLAINTIFF'S character and damaged PLAINTIFF’S personal and professional reputation. defamatory 11. Onorabout January 2, 2024, NICOLE made additional slanderous and r Spaces). (See the statements against PLAINTIFF in a public forum known as “Spaces” (Twitte following: http://twitter.com/i/10dJrjMgoXkIX?s=20). publish 12. On information and belief, both DEFENDANTS, continue to knowingly false statements about PLAINTIFF to third parties. in writing to cease 13. Onor about January 5, 2024, both DEFENDANT 'S were advised to remove and desist making false malicious statement about the PLAINTIFF and advised all postings containing the defamatory statements. 14, Both DEFENDANTS have refused to remove their defamatory postings and nts about the continue to knowingly spread false and misleading defamatory stateme PLAINTIFF. NDANTS 15. The false, misleading and defamatory statements made by the DEFE platforms. have been communicated to more than 265,000 individuals on social media COUNT I INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS of this count 16. PLAINTIFF repeats and realleges paragraphs 1-15 as paragraphs 1-16 and incorporates same by reference as though fully contained herein. 17. DEFENDANTS have engaged in a pattern of egregious misconduct with respect to are defamatory in nature knowingly making false and misleading statements to third parties that against the PLAINTIFF. 18. DEFENDANTS?’ conduct was extreme and outrageous. DocuSign Envelope ID: 0B301D78-A8A9-4BC7-8D71-E93D3938DE75 19. DEFENDANTS intended that their conduct inflict severe emotional distress (or such distress); the conduct knew that there was a high probability that the conduct would cause knew that severe emotional distress would be certain or was such that DEFENDANTS substantially certain to result. 20. The conduct caused severe emotional distress to the PLAINTIFF. d to 21. The distress inflicted was so severe that no reasonable person could be expecte endure it. 22. As a direct and proximate cause of DEFENDANTS’ misconduct, PLAINTIFF suffered tremendously, emotionally, and financially. t in his favor and Wherefore, Plaintiff, MARCUS TAYLOR, respectfully requests judgmen E WHITAKER, in an amount against Defendants, MARQUIS L. JORDAN and NICOLE LATIC relief as it deems just in excess of $50,000.00, plus costs, and that the Court awards such further and equitable. COUNT Il DEFAMATION PER SE of this count 23 PLAINTIFF repeats and realleges paragraphs 1-22 as paragraphs 1-23 and incorporates same by reference as though fully contained herein. 24. DEFENDANTS knowingly made false and misleading defamatory statements which were published to about the PLAINTIFF on December 31, 2023, and January 2, 2024, and his personal and professional numerous third parties, damaged the PLAINTIFF °§ character reputation. TIFF has 25. Asa direct and proximate cause of DEFENDANTS’ misconduct, PLAIN suffered tremendously, emotionally and financially DocuSign Envelope ID: 0B301D78-A8A9-4BC7-8D71-E93D3938DE75 knowledge 26. These defamatory statements were made by the DEFENDANTS with e damages. of their falsity and with actual malice, so as to justify an award of punitiv nt in his favor and Wherefore, Plaintiff, MARCUS TAYLOR, respectfully requests judgme E WHITAKER, in an amount against Defendants, MARQUIS L. JORDAN and NICOLE LATIC relief as it deems just in excess of $50,000.00, plus costs, and that the Court awards such further and equitable. COUNT It PRELI MINAR Y INJUNCTION of this count 27. PLAINTIFF repeats and realleges paragraphs 1-26 as paragraphs 1-27 and incorporates same by reference as though fully contained herein. that that the 28. PLAINTIFF is likely to be successful on the merits of his argument us third DEFENDANTS knowingly made defamatory statements which were published to numero profession reputation. parties, damaged the PLAINTIFF’S character and his personal and are 29. PLAINTIEF will be immediately and irreparably damaged if DEFENDANTS not enjoined from making further derogatory statements to third parties. NDANTS are 30. LAINTIFF will be immediately and irreparably damaged if DEFE posts. not immediately ordered to remove the false and misleading social media 31. PLAINTIFF has no adequate remedy at law to protect his interests if the social media DEFENDANTS are not enjoined from knowingly making additionally defamatory posts and removing the current defamatory social media posts. injunction should issue, as DEFENDANTS knowingly made 32. A preliminary TIFF defamatory social media posts, will irreparably damage the PLAIN quo during the 33. The entry of a preliminary injunction will preserve the status adjudicate rights of the parties. pendency of these proceedings and will enable the court to properly DocuSign Envelope ID: 0B301D78-A8A9-4BC7-8D7 1-E93D3938DE75 y. 34. Damage to the DEFENDANTS as a result of this injunction are unlikel Preliminary 35. Plaintiff's affidavit is attached hereto as Exhibit 5 in support of the Injunction. as follows: WHEREFORE, the Plaintiff, MARCUS TAYLOR, respectfully prays ion. That this Honorable Court grant Plaintiff s Petition for a Preliminary Injunct Preliminary That this Court issue a written order stating the reasons for granting the Injunction. ning and Ordering the That this Court issue a Preliminary Injunction, enjoining, restrai Defendants to cease making derogatory statements and removi ng the current derogatory statements on social media regarding the Plaintiff. may deem For such other and further relief in the premises as this Honorable Court equitable and just. \ leas tfully submitted, _ YG | LL, / MaR{ Us TAY /)) / lA By “One of its attofleys Richards J. Miller Miller Law Firm, P.C. 1051 Perimeter Drive, Suite 400 Schaumburg, IL 60173 847-995-1205 Attorney No. 44336 richard. miller@millerlawfirm.org DocuSign Envelope ID: 0B301D78-A8A9-4BC7-8D71 |-E93D3938DE75 IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, CHANCERY DIVISION MARCUS TAYLOR, Plaintiff, Vv. No MARQUIS L. JORDAN and NICOLE LATICE WHITAKER, JOHN DOE 1-4, Defendants. AFFIDAVIT OF MARCUS TAYLOR this I, MARCUS TAYLOR, the undersigned, being first duly sworn on oath, submits s Code of Civil Procedure affidavit under penalties provided by law pursuant to Section 1- 109 of the Illinoi correct. and certifies that the statements set forth in this Affidavit are true and 1 Lam the Plaintiff in the above captioned action. ents 2. Defendants knowingly made false and misleading defamatory statem were published to numerous third about the me on December 31, 2023, and January 2, 2024, which ion. parties, damaged my character and my personal and profession reputat are not 3 I will be immediately and irreparably be damaged if the Defendants defamatory statements against enjoined from knowingly making any further false and misleading ding defamatory statements me and from being ordered to remove the current false and mislea on social media. if the Defendants 4 Ihave no adequate remedy at law to at law to protect my interests DocuSign Envelope ID: 0B301D78-A8A9-4BC7-8D71-E93D3938DE75 atory social media posts and not are not enjoined from knowingly making additionally defam ordered to remove the current defamatory social media posts 5 If called to testify, I would testify to the above facts. AFFIANT FURTHER SAYETH NAUGHT DgcuSigned by: MARCUS TAYLOR SUBSCRIBED and Swom to before me this 28th day of May 2024. . Public MARY ELLEN SUMMERVILLE Notary Public, State of tilinois Commission No. 897189 ‘My Commission Expires June 27, 2027 Miller Law Firm, P.C. 1051 Perimeter Drive, Suite 400 Schaumburg, IL 60173 847-995-1205 Attomey No. 44336 richard.miller@millerlawfirm.org DocuSign Envelope ID: 0B301D78-A8A9-4BC7-8D7 1-E93D3938DE7S 1 me trash etc. so | responded by... https://t.co/qPV2yUrYrN* / X 2424/24, 10:49 AM € x Post o New to X? Sign up now to get your owns Liquid | Shadow 202 Settings @Shadow20z Sign up with Extremely long thread: © Sign up wit A coupie weeks ago | entered the spirit realm weekly online tournament, during that time | teabagged another player which you guys all know by Create aca: the name of shinblade. This made him upset in which he responded by EXHIBIT calling me trash etc. so | responded by saying tell them why you got By signing up, you agree to th bagged. He then switched up his attitude & it’s time to tell the truth Privacy Policy, including Coot behind this “beef” He’s tried to say the reason I’m doing this is over a tournament even though we both know the truth, & we both know my emotions within tekken would never evoke something like this so I’m Relevant people going to tell it all. Liquid | Shadow 2 @Shadow20z Ijust want to start this by saying that I deeply apologize to my long time Competitive Tekke best friend and the women of the fgc that have been affected by this ‘8 Teamtiquio Eme individual. As a man | find it my responsibilityto protect and honor the Shadow20z@yaht women of our community. This has been weighing heavy on me&l always tryto find the most non confrontational ways to handling problems but with some situations and with some people you HAVE to Trends are unavaifable do the right thing. So with that being said this is what happened. During the tournament combo breaker shinblade sexually assaulted my best friend in his car & once outside of the car. When she told me what happened | immediately was pissed because this is someone that I care Terms of Service Privacy Po Accessibility Adsinfo Mor deeply about and | also cared about him & never would’ve thought he would disrespect me or her in that way. She never cared about the situation initially considering her history with men engaging her sexually out the gates due to her sex work history. But for me it made me sick because no matter what or how a woman presents herself it doesn’t give any man the right to take consent away from that woman. My best friend doesn’t know him, & has no reason to lie especially to me. She trusted him because I did. He was under the impression that she was my girlfriend (which makes this worse tbh) so when confronted him the first time he immediately sald “What are you talking about” He then changed his story to “She came onto me” now months later he’s claiming “I have a witness that seen us in the car” even tho you had tinted windows. Everything up to this point has been lies, he can’t answer simple yes or no questions whereas her story has never changed. He’s also sexually KIT. assaulted another woman | personally know at the tournament of Pve tried MULTIPLE times to talkto him and try to come to some type of mine. | had to understanding considering this was once a good friend record our conversation because from the very beginning this is exactly how he’s reacted to my questioning. Even tho | know my best friend isn’t lying and never would | just wanted to hear his side but he can’t even me give me that. | even reached out to his girlfriend who even informed 2 women | know of for that he’s had previous allegations outside of the any sexual assault which was then deemed a “lie” but | don’t know honest man who gets random sexual allegations pinned on them back to back. She begged me not to say anything even though I never was & my jntontinns fram the hadinning wae ta det an annlady far me and nicki & Dontmiss what’s appening ogin Page 1 of 2 KTKBGAS9Q5dX 7A https://twitter.com/shadow20z/status/174136793 1215212544 ?S=468t=xkEQO3vq DocuSign Envelope ID: 0B301D78-A8A9-4BC7-8D71 |-E93D3938DE75 me trash ete. so | responded by... https://t.cofqPV2yUrvrn” | X 2/24)24, 10:49 AM poyrriena was more important. ir! m peng compretely Nonest snes Te straw that broke the camels back. She made me realize that he’s been doing this for YEARS & she’s been enabling this behavior. ?'m so sorry for holding this information but going forward | will always put the victim first, and this is not to say that women don'tlie & that men feel aren't falsely accused but I'd be lying if! didn’t say that women don’t comfortable speaking about these situation s because this isamale dominated space and it’s on us to hold each other accountable and to create a safe space for EVERYBODY. | havea platform & | have a voice and | will always make the right choice in these matters. & bad bitch Nyc wf @ Last edited 4:57 AM Dec 31, 2023 262.8K Views 469 Reposts 76Quotes 774Likes 342 Bookmarks oO a 9 fA sz a Page2 of 2 75=468t=xkE9OSvqKTKBGASIQSAX7A httos://twitter.com/shadow20z/status/1741367931215212544