IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND
DADE COUNTY, FLORIDA
CASE NUMBER: 15-05345 CA 30
MADONNA CICCONE p/k/a MADONNA,
ROBYN FENTY p/k/a RIHANNA,
SHAWN CARTER p/k/a JAY-Z,
BEYONCE KNOWLES p/k/a BEYONCE,
JESSICA CORNISH p/k/a JESSIE J,
ROC NATION LLC,
ROC NATION MANAGEMENT, LLC,
ROC NATION RECORDS, LLC,
ROC NATION SPORTS, LLC,
ROC NATION SPORTS - ROC NATION BOXING, LLC,
KABBALAH CENTRES OF THE UNITED STATES, INC.
AFFIDAVIT OF MILLICENT (PLAINTIFF’S MOTHER)
I am in fear for my safety and that of my family, particularly my daughter,
who is being maliciously harassed, stalked and approached by members of the
Kabbalah Center and others engaged by them on Madonna’s behalf. They have
communicated threats, racial slurs, sexist statements and xenophobic insults in
person and in writing that have greatly upset and distressed my family.
They have showed up at our home uninvited and under false pretenses, trying to
gain entry while we were present. On several other occasions our home suffered
break-ins documented by police, where intruders stole computer DVDs and CDs
containing my daughter’s preexisting copyrighted works stolen out of her home
studio by the burglars, then used without her permission in the public
marketplace. My daughter retained back up copies, in addition to the ones on
deposit with the Library of Congress in Washington, DC, under copyright
For years singer Madonna and her cronies have infringed my daughters copyrighted
works, copying items from my child’s website and using them for commercial gain
without permission, in conduct that evolved into outright commissioned stalking,
harassment, bullying, threats, computer hacking, phone hacking, menacing emails
and strange phone calls.
I have witnessed as my daughter’s computers were hacked right in front of my
eyes. On different occasions, the cursor began erratically moving on its own
without anyone touching the computer. The computers are abruptly shutdown as we
read items online, when no one is touching the laptops or PCs.
Our mobile phones have been hacked as well, in incidents where they are on the
table, with no one touching them, yet they are remotely activated by a hacker to
call the other phone, in acts of creepy harassment. We have received a number of
strange telephone calls, such as an intimidating company called Strong Arm
Security, who kept calling our unlisted phone number and hanging up. We have
also received a number of crank calls.
A racist death threat was sent to my daughter’s website by a computer hacker
named Randy Vaughn, who is affiliated with the defendants. He made violent
statements and death threats against my daughter, while claiming Madonna is not
stealing her copyrights, some of which were stolen by a hacker in acts of
computer intrusion, as verified by two computer security companies.
There have been incidents when we were out dining, running errands or going to
appointments and red string bracelet wearing Kabbalah Center members have
followed us and approached us and always against our wishes. My daughter has
been repeatedly stalked and confronted by members of the Kabbalah Center on
Madonna’s behalf and harassed.
For example, a man affiliated with the Kabbalah Center stalked my daughter on
different days at the North Miami Beach Walmart, Aventura Barnes And Noble
bookstore, the Miami Shores Public Library and recently appeared after a real
estate meeting that took place at a home in Miami Shores we were interested in
purchasing. He keeps showing up at disparate places and stating inappropriate
things to my daughter.
During the Barnes And Noble bookstore incident, he kept circling my daughter as
she looked at items she later purchased in the store. He kept trying to brush
against her and repeatedly stood behind and beside her chair in very close
proximity, as she perused items. He did so in a serious and menacing manner. It
offended me to the point I walked over and sternly stared at him, which caused
him to walk away.
Recently in another incident, a menacing man affiliated with the Kabbalah Center
aggressively approached and tried to drag my daughter off by her arm in Downtown
Miami, against her will.
There are days when my daughter leaves our home to tend to her business and I am
genuinely afraid she may not come home, due to being fatally attacked over the
harassment and stalking that is transpiring unabated. It is a concern her father
in Jamaica shares as well, as we have all witnessed and can attest to the
copyright thefts, as well as harassing misconduct she is being subjected to on a
regular basis. It has greatly damaged our family’s health via stress. No parent
should have to go through this.
My daughter suffered a stress related aneurysm due to the stalking, harassment,
assault and copyright thefts. She has completely recovered from the aneurysm,
but the undue stress and distress being caused by the ongoing commissioned
stalking, harassment and copyright thefts is endangering her health and that of
This intolerable situation has greatly upset Aisha’s father in Jamaica, who is
appalled and very concerned over what is transpiring against her. I have
experienced frightening heart palpitations, headaches and sleeplessness over
what is being done to my daughter.
We have no sense of security in our home, due to the multiple burglaries to
steal copies of copyrighted discs, the crank calls, unauthorized people knocking
on our door for prolonged periods of time and trying to gain entry under false
pretenses and the chronic hacking of our computers, smart phones, smart TVs and
emails . It is greatly disrupting our lives. We do not want this in our lives in
any measure. We need this to stop at once.
We have made no contact with the defendants and expressed no interest in their
sect or work in the entertainment industry, but they will not stop this
misconduct geared towards us.
Signed by: Millicent (last name redacted for privacy in online document)