Graves v. Combs Complaint ¶ 25

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In or around the summer of 2001, Plaintiff received a call from Combs concerning her boyfriend’s employment at Bad Boy. He told her he wanted to meet with her in person to discuss her boyfriend’s supposed performance issues. Her boyfriend was determined to climb up the ladder at Combs’ records label and as his romantic partner, Plaintiff was committed to helping him. Plaintiff agreed to meet with Combs. In retrospect, it was evidently a sick and twisted way of using his ownership of and title at Bad Boy and its affiliate entities to abuse Plaintiff and also show his power and ability to humiliate her boyfriend, his executive.

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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.