Graves v. Combs Complaint ¶ 44

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Nevada (Wikipedia) Nevada (/nɪˈvædə/ nih-VAD-ə; Spanish: [neˈβaða]) is a state in the Western region of the United States. It is bordered by Oregon to the northwest, Idaho to the northeast, California to the west, Arizona to the southeast, and Utah to the east. Nevada is the 7th-most extensive, the 32nd-most populous, and the 9th-least densely populated of the U.S. states. Nearly three-quarters of Nevada’s people live in Clark County, which contains the Las Vegas–Paradise metropolitan area, including three of the state’s four largest incorporated cities. Nevada’s capital is Carson City. Las Vegas is the largest city in the state.

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Following the assault and multiple times over the years, both Combs and Sherman contacted Plaintiff and warned her to be silent, threatening repercussions including Plaintiff potentially losing custody of her son if she ever disclosed the assault. Because of their enormous power in the industry, including through their ownership of and positions at the Combs Corporations, Plaintiff knew that they could follow through on their threats.

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Because of Combs’ power and notoriety, Plaintiff was afraid to report what had happened. She was involved in a contentious divorce and custody battle at the time and feared that reporting the rape would cause her to lose custody of her young child.