Defendant Daddy’s House Recordings, Inc. (“Daddy’s House”) is a domestic business corporation that is incorporated in New York and on information and belief now has its principal place of business at 9255 Sunset Boulevard, 2nd Floor, West Hollywood, California 90069. Combs is listed as the CEO in public filings, with a listed address of 1710 Broadway, New York, New York 10019. At the time of the events alleged herein, Daddy’s House was a world-class recording studio owned by Combs located at 321 W 44th Street, Suite 201, New York, New York 10036. On information and belief, at all relevant times, Bad Boy and Combs together owned and operated Daddy’s House. On information and belief, the Bad Boy recording studio was located on the premises of Daddy’s House. Combs and Sherman used the Daddy’s House premises and their ownership and titles at Daddy’s House to commit the unlawful sexual violence against Plaintiff described herein and/or to harass and subsequently intimidate her into silence after the rape.

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Defendant CE OPCO, LLC d/b/a Combs Global, f/k/a Combs Enterprises LLC (“Combs Global”) is a limited liability company incorporated in Delaware that has its principal place of business at 9255 Sunset Boulevard, 2nd Floor, West Hollywood, California 90069. On information and belief, all members of Combs Global are citizens of Delaware, New York, and/or California. On information and belief, Combs Global is an alter ego for Combs and/or a successor in interest to Combs’ other corporations and/or was established or used by Combs for the purpose of moving, disposing of, and/or insulating his assets, including in connection with his criminal activities and to avoid liability. Combs Global currently owns, controls, and/or oversees Bad Boy and Combs’ other business ventures in the music, fashion, fragrance, beverage, marketing, film, television, and media industries.

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Defendant Joseph Sherman, a/k/a “Big Joe” is a male who, on information and belief, resides in Westchester County, New York. On information and belief, Sherman was employed by Combs and/or by the Combs Corporations during the relevant period. The facts of Combs’ ownership and titles and Sherman’s titles at the Combs Corporations enabled Sherman to commit the unlawful sexual violence against Plaintiff described herein and/or to harass and subsequently intimidate her into silence after the rape.