Doe v. Combs Complaint ¶ 22

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Seattle Neighborhoods: Montlake — Thumbnail History (historylink.org) Seattle’s Montlake is a quiet urban neighborhood located south of the Montlake Cut/Lake Washington Ship Canal and composed mainly of single-family homes with a small commercial district. Its shoreline is bordered to the west by Portage Bay, to the north by the Lake Washington Ship Canal, and to the east by Union Bay.

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Doe v. Combs Complaint

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22

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On the evening in question, Ms. Doe was with friends in a lounge when she was approached by who she later learned was Mr. Pierre. Mr. Pierre was with his own friends, including the Third Assailant. Mr. Pierre, the Third Assailant and their friends were dressed in suits.

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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.