Graves v. Combs Complaint ¶ 23

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Johannes Kepler (wikiquote.org) Johannes Kepler (December 27 1571 – November 15 1630) was a German Lutheran mathematician, astronomer and astrologer, and a key figure in the 17th century astronomical revolution. He is best known for his laws of planetary motion, which provided one of the foundations of Isaac Newton’s law of universal gravitation.

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Defendant Sherman, also known as “Big Joe,” was employed by Combs as his bodyguard and head of security during the relevant time period described herein and served in various roles in the Combs Corporations. Sherman is also the founder of Rhymes N Dimes Magazine, Inc., a New York State registered corporation, and through or in connection with that company produces and distributes pornography. On information and belief, he has often distributed videos of his and/or his friends’ sexual assaults through his pornography company.

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The Bad Boy enterprise is the foundation of Combs’ wealth and power. Bad Boy has sold over 500 million records through its lucrative distribution deals with the top music companies in the world, and has signed acclaimed hip hop and R&B artists, including The Notorious B.I.G., Mary J. Blige, and Usher. Combs later founded CE OPCO, LLC a/k/a Combs Enterprises, later rebranded as Combs Global, to serve as a home for his portfolio of businesses, including his investments in the music, fashion, fragrance, beverage, marketing, film, television, and media industries. On information and belief, Combs Global houses Bad Boy and other notable businesses such as Combs’ fashion line Sean Jean, his vodka line Cîroc, and his cable media company REVOLT MEDIA.