Doe v. Combs Complaint ¶ 20

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As to what remains, I am now in a position to discern, as I think, with sufficient clearness what course must be taken to make the majority of those experiments which may conduce to this end: but I perceive likewise that they are such and so numerous, that neither my hands nor my income, though it were a thousand times larger than it is, would be sufficient for them all; so that, according as henceforward I shall have the means of making more or fewer experiments, I shall in the same proportion make greater or less progress in the knowledge of nature.

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Doe v. Combs Complaint

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20

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At the time, Mr. Combs had many connections to Michigan, including, among others, to the Black Mafia Family (“BMF”), a drug trafficking and money laundering organization that is rumored to have seeded Bad Boy. Accordingly, upon information and belief, Mr. Combs’ associates, including Mr. Pierre and the Third Assailant, spent significant time in and around Detroit, Michigan.

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At the time, Mr. Combs was 34 years old – twice the age of Ms. Doe – and one of the most well-known and influential music artists of all time.