Defendant Sherman, also known as “Big Joe,” was employed by Combs as his bodyguard and head of security during the relevant time period described herein and served in various roles in the Combs Corporations. Sherman is also the founder of Rhymes N Dimes Magazine, Inc., a New York State registered corporation, and through or in connection with that company produces and distributes pornography. On information and belief, he has often distributed videos of his and/or his friends’ sexual assaults through his pornography company.