According to the indictment, “[p]hysical abuse by [Combs] was recurrent and widely known.” Id. at ¶ 4. It notes that Combs’ assaults on women included “striking, punching, dragging, throwing objects at, and kicking them.” Id. Combs was also charged with “us[ing] the Combs Business, including certain employees, to carry out, facilitate, and cover up his abuse and commercial sex” and the indictment notes that his employees’ conduct “was facilitated and assisted by Combs’ control of the Combs Business.” Id. at ¶ 5. The indictment specifically refers to the involvement of “Combs’ security staff,” likely referring to Sherman. Id. It notes that Combs and his affiliates recorded sexual assaults and controlled victims through the use of drugs. See id. at ¶ 12. In or about March 2024, law enforcement seized narcotics and more than 1,000 bottles of baby oil and lubricant from Combs’ residences. Id.

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