Graves v. Combs Complaint ¶ 65

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James Bay (Wikipedia) James Bay (French: Baie James; Cree: ᐐᓂᐯᒄ, romanized: Wînipekw, lit. ‘dirty water’) is a large body of water located on the southern end of Hudson Bay in Canada. It borders the provinces of Quebec and Ontario, and is politically part of Nunavut. Its largest island is Akimiski Island.

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By viciously and violently forcing sexual contact, oral sex, anal sex, and sexual intercourse on Plaintiff, Defendants Combs and Sherman committed a “crime of violence motivated by gender” under the Victims of Gender-Motivated Violence Protection Act (“VGMVPA”) as defined in New York City Administrative Code § 10-1103.

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Combs’ treatment of Plaintiff accords with his pattern and practice of drugging, raping, and secretly recording the women he is abusing.