In or around the summer of 2001, Plaintiff received a call from Combs concerning her boyfriend’s employment at Bad Boy. He told her he wanted to meet with her in person to discuss her boyfriend’s supposed performance issues. Her boyfriend was determined to climb up the ladder at Combs’ records label and as his romantic partner, Plaintiff was committed to helping him. Plaintiff agreed to meet with Combs. In retrospect, it was evidently a sick and twisted way of using his ownership of and title at Bad Boy and its affiliate entities to abuse Plaintiff and also show his power and ability to humiliate her boyfriend, his executive.

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John 1:35

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A few hours later, Combs arrived at Plaintiff’s mother’s residence in Queens with Sherman, who was employed by Combs as his bodyguard at the time. Sherman was driving an SUV and Combs was in the backseat. After Plaintiff entered the vehicle, Combs offered her a glass of wine, which she accepted.

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Plaintiff met Defendant Combs in or around late 1999 or early 2000 through her then-boyfriend, who was an executive at Bad Boy. In addition to working together, Plaintiff’s boyfriend and Combs had a close personal relationship. Plaintiff frequently visited her boyfriend at the Bad Boy studio in New York City and attended events hosted at Combs’ residences. Over time, Plaintiff became familiar with Combs, and he knew about her relationship with her boyfriend.