Graves v. Combs Complaint ¶ 68

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“We draw courage from those who bent the moral arc of the universe.”

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The Combs Corporations enabled Combs and/or Sherman to commit the crime of violence motivated by gender because Combs and Sherman raped Plaintiff at the Bad Boy studio, where on information and belief they routinely committed sexual assault and gender-motivated violence, as detailed in other civil lawsuits. Given Combs’ and Sherman’s long-standing pattern and practice of committing sexual violence against women, including at the same location where they raped Plaintiff, the Combs Corporations had and/or should have had knowledge of Combs and Sherman using the premises for this unlawful conduct, and did nothing to stop it.

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The requirement that the crime of violence be committed because of gender or on the basis of gender, and due, at least in part, to an animus based on the victim’s gender is satisfied because Defendants Combs and Sherman violently forced Plaintiff to engage in vaginal intercourse, and oral and anal sex without her consent. Gender animus inheres when consent is absent. Moreover, Combs’ long history of violence against women evinces a deep contempt for women, as does Sherman’s alleged pattern of committing his own sexual assaults, recording them, and selling them as pornography.