The Combs Corporations further enabled Combs and/or Sherman to commit the crime of violence motivated by gender by actively placing, maintaining, and/or employing Combs and/or Sherman in positions of power and authority, despite the fact that they knew and/or should have known that Combs had a widespread and well-known practice of committing sexual assault and gender-motivated violence, including on premises owned and/or operated by Defendants. Combs and Sherman used their titles and authority conferred by the Combs Corporations, including as CEO, Founder, and Chairman (Combs) and Head of Security (Sherman), to facilitate and perpetuate the violent assault on Plaintiff, and to intimidate and force Plaintiff to keep quiet in subsequent years.

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The Combs Corporations also enabled Combs and/or Sherman to commit the crime of violence motivated by gender because Combs and Sherman used Plaintiff’s boyfriend’s employment as an executive for Bad Boy and Daddy’s House, and their stated concerns about his performance at work, to lure Plaintiff out of her home to meet with them alone.

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The Combs Corporations enabled Combs and/or Sherman to commit the crime of violence motivated by gender by failing to properly supervise Combs and/or Sherman. Further, Combs, as the owner of Bad Boy and Daddy’s House, watched Plaintiff being raped by his employee, on the premises of Bad Boy. The Combs Corporations had knowledge and/or should have had knowledge of Combs’ widespread and well-known practice of committing sexual assault and gender-motivated violence, including on premises owned and/or operated by Defendants, and did nothing to stop it.