The Combs Corporations enabled Combs and/or Sherman to commit the crime of violence motivated by gender by failing to properly supervise Combs and/or Sherman. Further, Combs, as the owner of Bad Boy and Daddy’s House, watched Plaintiff being raped by his employee, on the premises of Bad Boy. The Combs Corporations had knowledge and/or should have had knowledge of Combs’ widespread and well-known practice of committing sexual assault and gender-motivated violence, including on premises owned and/or operated by Defendants, and did nothing to stop it.

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