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On November 16, 2023, Casandra Ventura a/k/a “Cassie” filed a 35-page lawsuit in which she exposed Sean Combs for subjecting her to nearly a decade of physical, sexual and emotional abuse punctuated by rape, sex trafficking and being forced to engage in drug fueled nonconsensual sexual encounters with other men.

The Court has jurisdiction over this matter pursuant to 28 U.S.C. § 1332, as this action involves citizens of different states and the amount in controversy in this matter exceeds $75,000. The Court has supplemental jurisdiction over Plaintiff’s related claims arising under state and city law pursuant to 28 U.S.C. § 1367(a).

Pursuant to 28 U.S.C. § 1391(b), venue is proper in this Court because a substantial part of the events or omissions giving rise to this action, including the unlawful employment practices and intentional and negligent tortious conduct alleged herein, occurred in this district.

Plaintiff Jane Doe is a citizen of Canada.

Defendant Sean Combs is a citizen of the State of California.

Defendant Harve Pierre is a citizen of the State of New York.

Defendant the Third Assailant is, upon information and belief, a citizen of the State of New York.

Defendant Daddy’s House Recordings, Inc. (“Daddy’s House”) is a music, media, and entertainment company founded and owned by Defendant Sean Combs. Daddy’s House is incorporated and headquartered in New York, New York. During the relevant time period, Daddy’s House and/or Sean Combs owned and operated the Daddy’s House Recording Studio wherein Ms. Doe was raped by Mr. Combs, Mr. Pierre and Third Assailant.

Defendant Bad Boy Entertainment Holdings, Inc. (“Bad Boy”) is a music, media, and entertainment company founded and owned by Defendant Sean Combs. Bad Boy is incorporated and headquartered in New York, New York. During the relevant time period, Bad Boy and/or Sean Combs owned and operated the Daddy’s House Recording Studio wherein Ms. Doe was raped by Mr. Combs, Mr. Pierre and Third Assailant.

In 2003, Ms. Doe was a 17-year-old 11th grader residing in a suburb of Detroit Michigan.

At the time, Mr. Combs was 34 years old – twice the age of Ms. Doe – and one of the most well-known and influential music artists of all time.

Ordinarily, when a lawsuit such as Ms. Ventura’s is filed that involves events that took place long ago, witnesses are few and far between and evidence hard to muster. Not so for the claims brought against Mr. Combs. Within minutes of the filing, salient facts of Ms. Ventura’s claims were confirmed by various witnesses, including a rival musician whose car Mr. Combs blew up as well as various individuals who observed Mr. Combs beat Ms. Ventura.

A decade earlier, Mr. Combs founded Bad Boy and installed his longtime friend, Mr. Pierre, into the role of President.

At the time, Mr. Combs had many connections to Michigan, including, among others, to the Black Mafia Family (“BMF”), a drug trafficking and money laundering organization that is rumored to have seeded Bad Boy. Accordingly, upon information and belief, Mr. Combs’ associates, including Mr. Pierre and the Third Assailant, spent significant time in and around Detroit, Michigan.

On one evening between the spring and fall of 2003, Ms. Doe was out with friends. It was not uncommon for her and her friends to frequent bars and lounges in the Detroit area. Certain of Ms. Doe’s friends were well connected with people in the music industry.

On the evening in question, Ms. Doe was with friends in a lounge when she was approached by who she later learned was Mr. Pierre. Mr. Pierre was with his own friends, including the Third Assailant. Mr. Pierre, the Third Assailant and their friends were dressed in suits.

Mr. Pierre repeatedly complimented Ms. Doe’s appearance, saying that she was hot, among other things. He then began talking about his self-described “best friend” and “brother,” Mr. Combs.

Specifically, Mr. Pierre continually stated that Mr. Combs would love to meet Ms. Doe.

Mr. Pierre even called Mr. Combs and put Ms. Doe on the line. Mr. Combs told Ms. Doe that he would love to meet her, and that she should accompany Mr. Pierre to New York City in a private jet.

Shortly thereafter, Mr. Pierre directed Ms. Doe to go with him into the bathroom at the lounge. Once inside the bathroom, Mr. Pierre began to smoke crack cocaine from what appeared to be an aluminum can.

After he finished smoking crack, Mr. Pierre suddenly took out his penis, demanded that Ms. Doe “suck [his] dick” and forced Ms. Doe’s head down to perform oral sex on him.

After sexually assaulting Ms. Doe, Mr. Pierre directed her to accompany him, the Third Assailant and a third member of their group to an airport in Pontiac, Michigan, where Signature, a Fixed Base Operator, had prepared a private jet to take the four of them to New York City.

Only a few days later, two other lawsuits were filed against Mr. Combs. In one, plaintiff Joi Dickerson-Neal alleged that Mr. Combs drugged and sexually assaulted her when she was a college student. The other lawsuit accused Ms. Combs and singer Aaron Hall of forcing the plaintiff and another unidentified woman into nonconsensual sex.

Upon information and belief, the private jet landed at Teterboro Airport. Upon departing the jet, two black SUVs were awaiting the group.

Ms. Doe got into an SUV with Mr. Pierre, and the Third Assailant and the other member of the group went in the second SUV.

The SUVs brought the group to Daddy’s House Recording Studio, a recording studio and hangout owned and operated by Mr. Combs and Bad Boy.

When Ms. Doe arrived, she was escorted into the building, where she distinctly remembers seeing a sign for the company, Technicolor.

Upon entering the studio, Ms. Doe first encountered Mr. Combs. At the time she arrived, a female recording artist was using the studio as Mr. Combs and her parents watched on. She finished up shortly after Ms. Doe arrived and left.

While still in the studio section of Daddy’s House, Mr. Combs asked Ms. Doe to sit on his lap to take a picture. A copy of the photograph is below.

Mr. Combs, Mr. Pierre and the Third Assailant began to ply Ms. Doe – a 17-year-old child at the time – with copious amounts of drugs and alcohol.

While the evening became a blur, Ms. Doe does recall Mr. Combs, Mr. Pierre and the Third Assailant hitting on her incessantly, stroking her body, asking to see her “ass” and telling her how “hot” and “sexy” she was.

Various other pictures were taken in the studio that night, leaving no doubt that Ms. Doe was in Mr. Combs’ New York City studio, with Mr. Combs, on the night she was raped.

As the night wore on, the 17-year-old Ms. Doe became more and more inebriated, eventually to the point that she could not possibly have consented to having sex with anyone, much less someone twice her age.

At the same time, a fourth lawsuit was filed; this one against Mr. Combs’ companies and Defendant Harve Pierre, the longtime President of Bad Boy Entertainment Holdings, Inc. (“Bad Boy”). The suit alleged that Mr. Pierre used his position of power at Bad Boy to groom and sexually assault his former assistant, and that Bad Boy looked the other way at the time.

Nevertheless, that evening Mr. Combs directed Ms. Doe to accompany him to the bathroom at the studio. Once there, Mr. Combs removed Ms. Doe’s skirt and underwear and penetrated her from behind with his penis while she hung over the sink.

Ms. Doe did not consent to having sex with Mr. Combs, but he continued thrusting. At some point, Mr. Combs turned Ms. Doe around to face him. He told her that he could not orgasm and asked her to squeeze his nipples as hard as she could to help him “get off.” He then turned her back around and continued to rape her.

By this point, Ms. Doe was coming in and out of consciousness because of the drugs and alcohol she had been given by Defendants. Her next memory was looking up into the mirror above the sink to find that the Third Assailant had replaced Mr. Combs and was raping her from behind. Mr. Combs was watching the Third Assailant sexually assault Ms. Doe from a chair outside of the bathroom.

At this point, Ms. Doe mustered the energy to tell the Third Assailant to stop, and that she did not want to be having sex with him. The Third Assailant did not stop, and continued to rape Ms. Doe, who did not have the strength to force him off of her.

After the Third Assailant was finished, he was replaced by Mr. Pierre, who began by having nonconsensual vaginal sex with Ms. Doe before violently forcing her to give him oral sex. During the latter part of the sexual assault, Mr. Pierre forced his penis into Ms. Doe’s mouth without her consent. Ms. Doe remembers that Mr. Pierre was sweaty and that she had difficulty breathing.

When Mr. Pierre finished, he left Ms. Doe in the bathroom alone. Ms. Doe fell into the fetal position and lay on the floor. Her vagina was in pain.

Finally, after a period of time, Ms. Doe regained her bearings. However, she could barely stand up following the gang rape, and had to be helped to walk out of the building and back into a car. She was taken back to an airport and flown back to Michigan. However, she has very limited recollection of her transport home, and only remembers being in her car sometime early in the morning. Her underwear was missing.

As a result of being raped by Mr. Combs, Mr. Pierre and the Third Assailant, Ms. Doe suffered significant emotional distress and feels of shame that have plagued her life and personal relationships for 20 years.

Ms. Doe knew that speaking out against Defendants would be extremely difficult and that she would likely be subjected to retaliation and defamatory slurs and attacks.

However, in November 2023, Ms. Doe read about a lawsuit filed against Mr. Combs by Casandra Ventura a/k/a “Cassie.” Ms. Ventura’s suit described a decade of physical, sexual and mental abuse. Most triggering for Ms. Doe was reading about Ms. Ventura’s allegations of sex trafficking and being forced to have sex with other men against her will. Ms. Doe obviously understands that she too had been sex trafficked, and that Mr. Combs’ behavior in forcing women into nonconsensual sex was not an isolated incident or unique only to Ms. Ventura.

This is now the fifth lawsuit filed against Mr. Combs in the last three weeks. Incredibly, the allegations brought by Ms. Doe are in many ways even more egregious than those brought by his prior victims.

Then, just days later, Ms. Doe read about a case filed against Mr. Pierre. The suit alleged that Mr. Pierre used his position of power at Bad Boy to groom and sexually assault his former assistant.

Seeing two other women bravely speak out against Mr. Combs and Mr. Pierre, respectively, gave Ms. Doe the confidence to tell her story as well. As such, she files this suit.

Plaintiff repeats and realleges each and every allegation in all of the preceding paragraphs as if fully set forth herein.

The above-described conduct of Defendant Mr. Combs, including, but not limited to, Mr. Combs’s sexual assault of Plaintiff in New York City, constitutes a “crime of violence” against Plaintiff and is a “crime of violence motivated by gender” as defined in § 10-1103 (“The term ‘crime of violence’ means an act or series of acts that would constitute a misdemeanor or felony against the person as defined in state or federal law or that would constitute a misdemeanor or felony against property as defined in state or federal law if the conduct presents a serious risk of physical injury to another, whether or not those acts have actually resulted in criminal charges, prosecution, or conviction,” and “The term ‘crime of violence motivated by gender’ means a crime of violence committed because of gender or on the basis of gender, and due, at least in part, to an animus based on the victim’s gender.”).

The above-described conduct of Defendant Mr. Pierre, including, but not limited to, Mr. Pierre’s sexual assault of Plaintiff in New York City, constitutes a “crime of violence” against Plaintiff and is a “crime of violence motivated by gender” as defined in § 10-1103 (“The term ‘crime of violence’ means an act or series of acts that would constitute a misdemeanor or felony against the person as defined in state or federal law or that would constitute a misdemeanor or felony against property as defined in state or federal law if the conduct presents a serious risk of physical injury to another, whether or not those acts have actually resulted in criminal charges, prosecution, or conviction,” and “The term ‘crime of violence motivated by gender’ means a crime of violence committed because of gender or on the basis of gender, and due, at least in part, to an animus based on the victim’s gender.”).

The above-described conduct of Defendant the Third Assailant, including, but not limited to, the Third Assailant’s sexual assault of Plaintiff in New York City, constitutes a “crime of violence” against Plaintiff and is a “crime of violence motivated by gender” as defined in § 10-1103 (“The term ‘crime of violence’ means an act or series of acts that would constitute a misdemeanor or felony against the person as defined in state or federal law or that would constitute a misdemeanor or felony against property as defined in state or federal law if the conduct presents a serious risk of physical injury to another, whether or not those acts have actually resulted in criminal charges, prosecution, or conviction,” and “The term ‘crime of violence motivated by gender’ means a crime of violence committed because of gender or on the basis of gender, and due, at least in part, to an animus based on the victim’s gender.”).

Defendant Bad Boy Entertainment Holdings, Inc. enabled Defendants’ commission of the crime of violence motivated by gender, and is therefore also liable under the VGMVPL.

As a direct and proximate result of the aforementioned crime of violence and gender-motivated violence, Plaintiff has sustained and will continue to sustain, monetary damages, physical injury, pain and suffering, and serious psychological and emotional distress, entitling her to an award of compensatory and punitive damages, injunctive and declaratory relief, attorneys fees and costs, and other remedies as this Court may deem appropriate damages, as set forth in § 10-1104.

The above-described conduct of Defendants constitutes a sexual offense as defined in Article 130 of the New York Penal Law.

Pursuant to § 10-1105(a), this cause of action is timely because it is commenced within “two years and six months after September 1, 2022.”

Specifically, in 2003, when she was only 17 years old and in the 11th grade, Ms. Doe was sex trafficked and gang raped by Mr. Combs, Mr. Pierre and the Third Assailant.^1 In short:

When she was just a teenager, Ms. Doe met Mr. Pierre and the Third Assailant in a lounge in the Detroit, Michigan area. While at the lounge, Mr. Pierre insisted that he was “best friends” with Mr. Combs, and even called Mr. Combs with Ms. Doe.

When Mr. Pierre finished, he left Ms. Doe in the bathroom alone. Ms. Doe fell into the fetal position and lay on the floor. Her vagina was in pain.

Finally, after a period of time, Ms. Doe regained her bearings. However, she could barely stand up following the gang rape, and had to be helped to walk out of the building and back into a car. She was taken back to an airport and flown back to Michigan. However, she has very limited recollection of her transport home, and only remembers being in her car sometime early in the morning.

Mr. Combs convinced Ms. Doe, who was half his age at the time, to accompany Mr. Pierre and the Third Assailant on a private jet to come to his studio in New York City.

Before they left for the private jet, Mr. Pierre smoked crack cocaine in a bathroom at the lounge, in which he also sexually assaulted Ms. Doe by forcing her to give him oral sex.

Mr. Pierre, Third Assailant and another gentleman then escorted the highschooler to a private jet, which flew them to Teterboro, New Jersey. There were SUVs awaiting the group at Teterboro, and the four of them were driven to Daddy’s House Recording Studio, a studio famously owned and operated by Mr. Combs and Bad Boy.

While at the studio, Mr. Combs and his associates, including Mr. Pierre, plied Ms. Doe with drugs and alcohol. As the night wore on, the 17-year-old Ms. Doe became more and more inebriated, eventually to the point that she could not possibly have consented to having sex with anyone, much less someone twice her age.

While at the studio, Ms. Doe was gang raped by Mr. Combs, the Third Assailant and Mr. Pierre, in that order.

While Mr. Combs was raping Ms. Doe, he complained that he could not “get off” unless she pinched his nipples as hard as she could.

Mr. Combs then watched on as Third Assailant, who Ms. Doe had not even realized had begun to have sex with her, raped Ms. Doe as she told him to stop.

After Third Assailant was finished, Mr. Pierre took his turn at raping Ms. Doe and then violently forced her to give him oral sex, during which Ms. Doe was choking and struggling to breathe.

Unlike many victims who have come forward after decades, Ms. Doe can prove that she not only met Mr. Combs on the night in question, but was in his studio, in New York City, with him on that night. Remember when viewing these, Ms. Doe was 17 years old.^2

Ms. Doe has lived with her memories of this fateful night for 20 years, during which time she has suffered extreme emotional distress that has impacted nearly every aspect of her life and personal relationships. Given the brave women who have come forward against Ms. Combs and Mr. Pierre in recent weeks, Ms. Doe is doing the same.

To that end, Ms. Doe brings this action seeking injunctive, declaratory and monetary relief against Defendants in violation of the Victims of Gender-Motivated Violence Protection Law, Gender Motivated Violence Act, N.Y.C. Admin. Code §§ 10-1101, et seq.(“VGMVPL”).

WHEREFORE, Plaintiff prays judgment be entered in her favor against Defendants, and each of them, as follows:

For a money judgment representing compensatory damages including consequential damages, lost wages, earning, and all other sums of money, together with interest on these amounts, according to proof;

For a money judgment for mental pain and anguish and severe emotional distress, according to proof;

For punitive and exemplary damages according to proof;

For attorneys’ fees and costs;

For prejudgment and post-judgment interest; and

For such other and further relief as the Court may deem just and proper.

Graves v. Combs Complaint

In or around the summer of 2001, Plaintiff’s life was violently knocked off course when Defendants Sean Combs and Joseph Sherman viciously raped her at the Bad Boy Records studio in New York City.

Defendant Joseph Sherman, a/k/a “Big Joe” is a male who, on information and belief, resides in Westchester County, New York. On information and belief, Sherman was employed by Combs and/or by the Combs Corporations during the relevant period. The facts of Combs’ ownership and titles and Sherman’s titles at the Combs Corporations enabled Sherman to commit the unlawful sexual violence against Plaintiff described herein and/or to harass and subsequently intimidate her into silence after the rape.

Defendant Daddy’s House Recordings, Inc. (“Daddy’s House”) is a domestic business corporation that is incorporated in New York and on information and belief now has its principal place of business at 9255 Sunset Boulevard, 2nd Floor, West Hollywood, California 90069. Combs is listed as the CEO in public filings, with a listed address of 1710 Broadway, New York, New York 10019. At the time of the events alleged herein, Daddy’s House was a world-class recording studio owned by Combs located at 321 W 44th Street, Suite 201, New York, New York 10036. On information and belief, at all relevant times, Bad Boy and Combs together owned and operated Daddy’s House. On information and belief, the Bad Boy recording studio was located on the premises of Daddy’s House. Combs and Sherman used the Daddy’s House premises and their ownership and titles at Daddy’s House to commit the unlawful sexual violence against Plaintiff described herein and/or to harass and subsequently intimidate her into silence after the rape.

Defendant CE OPCO, LLC d/b/a Combs Global, f/k/a Combs Enterprises LLC (“Combs Global”) is a limited liability company incorporated in Delaware that has its principal place of business at 9255 Sunset Boulevard, 2nd Floor, West Hollywood, California 90069. On information and belief, all members of Combs Global are citizens of Delaware, New York, and/or California. On information and belief, Combs Global is an alter ego for Combs and/or a successor in interest to Combs’ other corporations and/or was established or used by Combs for the purpose of moving, disposing of, and/or insulating his assets, including in connection with his criminal activities and to avoid liability. Combs Global currently owns, controls, and/or oversees Bad Boy and Combs’ other business ventures in the music, fashion, fragrance, beverage, marketing, film, television, and media industries.

As part of his renowned Bad Boy record label and brand, Combs has established several corporate entities under the “Bad Boy” name over the past few decades, including but not limited to Bad Boy Entertainment Holdings, Inc., Bad Boy Productions Holdings, Inc., Bad Boy Books Holdings, Inc., Bad Boy Records LLC, Bad Boy Entertainment LLC, and Bad Boy Productions LLC (together, “Bad Boy”). On information and belief, all Bad Boy corporate entities are alter egos for Combs, are controlled and/or directed by Combs, and/or were established or used by Combs for the purpose of moving, disposing of, and/or insulating his assets, including in connection with his criminal activities and to avoid liability. On information and belief, all active Bad Boy entities are now owned and/or controlled by Combs and/or by Combs Global. Combs and Sherman used the Bad Boy premises/recording studio and their ownership and titles at Bad Boy to commit the unlawful sexual violence against Plaintiff described herein and/or to harass and subsequently intimidate her into silence after the rape.

Defendant Bad Boy Entertainment Holdings, Inc. is a domestic business corporation incorporated in New York, that on information and belief now has its principal place of business at 9255 Sunset Boulevard, 2nd Floor, West Hollywood, California 90069. Bad Boy Entertainment Holdings, Inc. is part of the Bad Boy enterprise founded and owned by Combs, and on information and belief is now owned and/or controlled by Combs and/or by Combs Global. Combs is listed as the CEO in public filings, with a listed address of 1710 Broadway, New York, New York 10019.

Defendant Bad Boy Productions Holdings, Inc. is a domestic business corporation incorporated in New York, that on information and belief now has its principal place of business at 9255 Sunset Boulevard, 2nd Floor, West Hollywood, California 90069. Bad Boy Productions Holdings, Inc. is part of the Bad Boy enterprise founded and owned by Combs, and on information and belief is now owned and/or controlled by Combs and/or by Combs Global. Combs is listed as the CEO in public filings, with a listed address of 1710 Broadway, New York, New York 10019.

Defendant Bad Boy Books Holdings, Inc. is a domestic business corporation incorporated in New York, that on information and belief now has its principal place of business at 1440 Broadway, 3rd Floor, New York, New York 10018. Bad Boy Books Holdings, Inc. is part of the Bad Boy enterprise founded and owned by Combs, and on information and belief is now owned and/or controlled by Combs and/or by Combs Global. The CEO listed on public filings is Eddie Norward Jr., with a listed address of 1710 Broadway, New York, New York 10019, the same address listed for Sean Combs in public filings for Bad Boy Entertainment Holdings, Inc., Bad Boy Productions Holdings, Inc., and Daddy’s House Recordings, Inc.

Defendant Bad Boy Records LLC is a Delaware limited liability company that on information and belief is headquartered in New York and/or California. On information and belief, all members of Bad Boy Records LLC are citizens of Delaware, New York, and/or California. On information and belief, Bad Boy Records LLC is part of the Bad Boy enterprise and/or a successor-in-interest to other Bad Boy Defendants that comprise the Bad Boy enterprise founded and owned by Combs. On information and belief, Bad Boy Records LLC is now owned and/or controlled by Combs and/or by Combs Global.

Defendant Bad Boy Entertainment LLC is a New York limited liability company that on information and belief is headquartered in New York and/or California. On information and belief, all members of Bad Boy Entertainment LLC are citizens of New York and/or California. Bad Boy Entertainment LLC is part of the Bad Boy enterprise and/or a successor-in-interest to other Bad Boy Defendants that comprise the Bad Boy enterprise founded and owned by Combs. On information and belief, Bad Boy Entertainment LLC is now owned and/or controlled by Bad Boy Entertainment Holdings, Inc. and/or by Combs, and/or by Combs Global.

Defendant Bad Boy Productions LLC is a New York limited liability company that on information and belief is headquartered in New York and/or California. On information and belief, all members of Bad Boy Productions LLC are citizens of New York and/or California. Bad Boy Productions LLC is part of the Bad Boy enterprise and/or a successor-in-interest to other Bad Boy Defendants that comprise the Bad Boy enterprise founded and owned by Combs. On information and belief, Bad Boy Productions LLC is now owned and/or controlled by Combs and/or by Combs Global.

Defendants Organizational Does 1-10 are currently unknown entities who were owned by and/or employed Defendants Combs and/or Sherman and enabled the commission of the conduct complained of herein. As the parties engage in discovery, Plaintiff retains the right to amend the Complaint to add these entities by name.

Each of the Combs Corporations (a) aided and abetted Combs and Sherman in committing the unlawful sexual violence against Plaintiff described herein and/or in harassing and subsequently intimidating her into silence after the rape, (b) provided Combs and Sherman with the studio/office space where they committed the rape, and/or with chattel including recording equipment, storage equipment, etc. to record the rape and disseminate it; (c) are alter egos for Combs, completely dominated by him and used for his personal interests and to engage in wrongdoing which harmed Plaintiff and others, and/or (d) serve or have served as vehicles for Combs to move, dispose of, and/or insulate his assets, including in connection with his criminal activities and to avoid compensating the victims of his many crimes, including Plaintiff.

This Court has subject-matter jurisdiction pursuant to 28 U.S.C. § 1332 because this case is between citizens of different states, and the amount in controversy exceeds $75,000.

This Court has specific personal jurisdiction over Defendants because the acts giving rise to Plaintiff’s claims took place in New York State, and because several of the Defendants are domiciled in New York State and/or regularly transact business in New York State.

Venue is proper in this District pursuant to 28 U.S.C. § 1391(b) because a substantial part of the events or omissions giving rise to the claims occurred in this District.

Plaintiff hereby demands a trial by jury on her claims in this action.

Plaintiff was twenty-five at the time and dating one of Combs’ employees, a relationship that Combs exploited to lure Plaintiff into meeting him and Sherman alone. Once they successfully sequestered Plaintiff, Combs and Sherman gave Plaintiff a drink, likely laced with a drug that eventually caused her briefly to lose consciousness. She awoke to find herself bound and restrained.

Plaintiff’s family immigrated to New York City when Plaintiff was a teenager in connection with her mother’s work. Her family ultimately settled in Rego Park, Queens, where she completed her education, and where she was living when she met Combs.

Defendant Combs, also known by his stage names Puff Daddy, Puffy, P. Diddy, Diddy, Brother Love, or Love, is a prominent rapper, record executive, and businessman. He rose to fame in the 1990s with his record label Bad Boy, and continued to be a notable figure in the music and entertainment industry in the following years. Combs has continued to amass wealth and power through his business ventures in the music, fashion, fragrance, beverage, marketing, film, television, and media industries.

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.

As detailed below, see infra ¶¶ 57 through 64, Combs has a long history of violence and of abusing and raping women, and there have been several civil lawsuits filed against Combs in the past year alleging sexual violence and abuse. On September 16, 2024 Combs was arrested and charged with racketeering and sex trafficking. He was denied bail.

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.

Plaintiff met Defendant Combs in or around late 1999 or early 2000 through her then-boyfriend, who was an executive at Bad Boy. In addition to working together, Plaintiff’s boyfriend and Combs had a close personal relationship. Plaintiff frequently visited her boyfriend at the Bad Boy studio in New York City and attended events hosted at Combs’ residences. Over time, Plaintiff became familiar with Combs, and he knew about her relationship with her boyfriend.

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.

A few hours later, Combs arrived at Plaintiff’s mother’s residence in Queens with Sherman, who was employed by Combs as his bodyguard at the time. Sherman was driving an SUV and Combs was in the backseat. After Plaintiff entered the vehicle, Combs offered her a glass of wine, which she accepted.

Combs began discussing his alleged concerns about her boyfriend’s performance at work. Meanwhile, as Plaintiff drank what had been handed to her, she started to feel lightheaded, dizzy, and physically weak. In retrospect, it is clear that Combs had caused a drug to be put into Plaintiff’s drink, as a few sips of wine had never impacted her that way.

Combs and Sherman drove Plaintiff to the Bad Boy studio in Manhattan. When they arrived and Plaintiff tried to get out of the car, she realized that she was feeling odd, and found it difficult to walk. She assumed this was her fault, and did her best to act normal, and followed Combs as he led her eventually to a couch in a private room in the Bad Boy studio. She later came to understand this was Combs’s personal lounge and office at the Bad Boy studio. Combs sat on the couch next to Plaintiff and continued speaking to her. Plaintiff began feeling even more woozy and sedated. She then lost consciousness.

Combs and Sherman proceeded to brutally sexually abuse and violate Plaintiff. Combs mercilessly raped her, anally and vaginally. Sherman forcefully slammed Plaintiff onto a table, slapped her, and repeatedly thrust his penis into her mouth. Both men were undeterred by Plaintiff’s cries for help throughout the attack.

When Plaintiff regained consciousness, she was naked, and her hands were tied behind her back with what felt like a plastic grocery bag. Plaintiff shouted for help. In response Sherman lifted her up from the couch and forcefully slammed her face down on what was apparently a pool table. Shortly thereafter, Combs entered the room naked.

Combs reached for a container of lubricant that smelled like menthol, and proceeded to apply it to his penis. He then bent Plaintiff over the table causing her feet to dangle above the floor, forcefully held her down, and anally penetrated her without her consent. Plaintiff is 4 feet 11 inches tall and weighed only 103 pounds at the time. Plaintiff was unable to move, totally overpowered physically, in addition to being drugged and bound.

Plaintiff screamed out in pain, but Combs continued to violently anally rape her. He easily physically overpowered her, smashing her head down on the pool table while she futilely tried to wriggle out from under him.

During the brutal attack, Plaintiff vomited into her mouth and on the table. At one point, she involuntarily defecated. Combs was undeterred. He wiped himself off, applied more lubricant, and without any acknowledgement of Plaintiff’s distress, proceeded to vaginally penetrate Plaintiff.

Plaintiff experienced intense pain and burning sensations in her vagina and anus. Plaintiff continued to scream for help because of the extreme pain she felt as Combs penetrated her over and over. She then lost consciousness again.

The next time she regained consciousness, Plaintiff was on the couch and Sherman was standing in front of her with his bare penis in her face. Sherman slapped Plaintiff in the face and forcefully inserted his penis into her mouth. Sherman slapped her yet again, and continued to thrust his penis into Plaintiff’s mouth. Plaintiff once again lost consciousness.

When she next awoke, Plaintiff was on the couch naked and alone in the room.

Plaintiff was in severe pain and distress. Her anus and vagina burned, her face and wrists were bruised, and her genital area smelled strongly of menthol. She felt a liquid, presumably semen, dripping out from inside of her.

Her dress was thrown over her, her purse was on the couch next to her, and her bra was on the floor nearby. She did not see her underpants.

Terrified that Combs and Sherman would return, Plaintiff quickly got dressed and bolted out of the studio room where she had been raped.

Plaintiff never recovered from Defendants’ violent rape. She had suicidal thoughts and ideation and has received extensive psychological treatment because of Defendants’ attack. For decades, she remained silent and did not report the crime out of fear that Defendants would use their power to ruin her life, as they had repeatedly, explicitly threatened to do. To this day, Plaintiff suffers from severe depression, anxiety, and panic attacks, and still lives in fear of Defendants.

Still dizzy and weak, Plaintiff called a livery driver that her family regularly hired and knew well. The driver picked her up from outside Bad Boy studio. She was disheveled, crying uncontrollably and suffering from agonizing pain.

The driver drove her to the hospital and tried to convince her to report the rape and get a rape kit, but she was unable to leave the car, “shaking and crying hysterically” and terrified of what Combs would do to her and her family if she reported him.

Plaintiff sustained serious physical injuries in the aftermath of the rape. As noted, she had burning in her vagina and anus, and bruising on her wrists and face. In the days after the assault, she suffered prolonged anal bleeding and hemorrhoids.

Because of Combs’ power and notoriety, Plaintiff was afraid to report what had happened. She was involved in a contentious divorce and custody battle at the time and feared that reporting the rape would cause her to lose custody of her young child.

Plaintiff confided in her boyfriend, Combs’ employee, hoping he would comfort and support her. But instead of supporting her, he discouraged her from disclosing the assault, telling her that it could negatively impact his own career.

Following the assault and multiple times over the years, both Combs and Sherman contacted Plaintiff and warned her to be silent, threatening repercussions including Plaintiff potentially losing custody of her son if she ever disclosed the assault. Because of their enormous power in the industry, including through their ownership of and positions at the Combs Corporations, Plaintiff knew that they could follow through on their threats.

Plaintiff told close friends that Combs and Sherman had drugged and savagely raped her, but as noted was afraid to report the attack to the police out of fear that Defendants would follow through on their threats. She was even afraid to stay in New York City while Combs lived there, so with the help of a friend, she fled to Pennsylvania. Plaintiff has in fact relocated multiple times throughout the years in an effort to stay away from Combs.

Plaintiff has suffered irreparable harm because of the brutal rape by Defendants Combs and Sherman. She suffers from severe depression and post-traumatic stress disorder. She also has suffered suicidal ideation and intrusive thoughts, and has attempted to end her life.

Plaintiff lives in constant fear. She struggles with hypervigilance and experiences anxiety and panic attacks in social settings, preferring to be alone. Her need to hide to feel safe has strained her relationships with friends and family.

Defendants’ rape has also impacted Plaintiff’s ability to engage in sexual acts with her intimate partners. To this day, she cannot be in certain sexual positions without experiencing flashbacks of Combs violently penetrating her from behind.

Any progress Plaintiff had made in healing from the attack over the years was dramatically reversed on or around November 27, 2023, when she learned for the first time that Combs and Sherman had video-recorded the horrific rape twenty-two years before and had shown the video to multiple men, seeking to publicly degrade and humiliate both Plaintiff and her boyfriend.

On or around November 27, 2023, all the trauma of the rape came flooding back to Plaintiff when her former boyfriend revealed to her for the first time that Combs and Sherman had recorded and published the video of the horrific attack.

Earlier that month, Cassie Ventura had come forward and filed a lawsuit against Combs for subjecting her to years of severe sexual and physical abuse. The case had been settled one day after it had been filed. Plaintiff’s former boyfriend invoked Ms. Ventura’s effort to hold Combs’ accountable and for the first time confessed that years earlier, but sometime after the actual rape itself, Sherman and Combs had showed him and a group of men – some of whom were also employed by Combs’ companies and/or their related entities – the video of Plaintiff being raped. He disclosed that Combs and Sherman had a pattern and practice of non-consensually recording women engaging in sexual acts and making those videos available to the public, including by selling tapes as pornography. A Bad Boy artist later corroborated in a text message that Sherman “use[d] to sell porn of him doing this to chix” and that Sherman “did that to a lot of women.”

Plaintiff’s former boyfriend reported that he and the other men watched the recording of Plaintiff’s rape on a handheld camera while at the Bad Boy studio in New York City. Combs, Sherman, and some of the other men made derogatory comments about the former boyfriend’s relationship with Plaintiff, in an attempt to shame him into cutting ties with Plaintiff and to cause her further emotional harm and embarrassment.

On information and belief, Defendants continued to show the video of the rape to others over the years and through to the present and/or sold the video as pornography.

Plaintiff was shocked and horrified that Combs and Sherman had recorded and publicized the video of them raping her. After over two decades spent trying to heal and distance herself from the experience, Plaintiff was devastated by the news. She felt as if her life had been turned upside down, again, and like the rape had been happening again and again even as she was trying to forget it. She experienced acute psychological distress, plunging into a deep depression and having suicidal ideations. She felt intense fear, anger, and anxiety.

Plaintiff lives with the distress of knowing that the video of her brutal rape is in circulation and that anyone, including her family, friends, and peers, could view it at any time.

In a panic, she reached out to Sherman after learning about the tape, hoping to protect herself from further humiliation by convincing him to destroy the tape or provide it to her, but he did not respond.

Combs has a long history of violence and abuse. This long-standing behavior has been enabled by his ownership of and titles at the Combs Corporations and their affiliated entities and the immense wealth and power he has amassed through such business dealings.

Among a long list of allegations: In 1996 he was found guilty of criminal mischief for threatening a photographer from the New York Post with a gun. In 1999 he was arrested and charged with second-degree assault and criminal mischief in connection with the beating of a record executive, and arrested again the same year in relation to a shooting at a club in New York; that female victim has consistently stated that Combs shot her in the face at point-blank range.

Combs also has a pattern and practice of using his power and influence in the music and entertainment industries to submit people to sexual violence, often drugging his victims and/or coercing them to consume drugs and recording the assaults, often without the victim’s knowledge, just as he did with Plaintiff. In the past year, a number of these people have come forward to accuse Combs of sexual assault, violent rapes and/or sex trafficking:

In November 2023, three lawsuits were filed against Combs under the New York Adult Survivors Act. As noted above, Cassie Ventura, an artist signed to Bad Boy, sued Combs in the Southern District of New York for rape and years-long physical abuse, facilitated in part by Combs having supplied Ms. Ventura with copious amounts of drugs and urging her to take them, beginning in 2006. Combs regularly recorded Ms. Ventura engaging in sex acts he forced her to engage in.

Joi Dickerson-Neal, who had appeared with Combs in a music video, sued Combs in New York County Supreme Court alleging Combs drugged her, sexually assaulted her, and secretly recorded the assault in 1991.

Liza Gardner, whom Combs met at an event hosted by a record label affiliated with Bad Boy, sued him for raping her and a friend in 1990 or 1991 when she was only 16.

In December 2023, an anonymous plaintiff sued Combs in the Southern District of New York for drugging and gang-raping her in 2003 when she was only 17 years old. That complaint alleges that Combs and one of his business associates and employees lured the plaintiff to Daddy’s House through their affiliations with the Bad Boy enterprise and its related entities, and raped her at the same location where Plaintiff was raped.

In February 2024, Rodney “Lil Rod” Jones, one of Combs’ former producers, sued Combs for forcing him to engage in unwanted sex acts and sex trafficking, among other allegations. In that complaint, Mr. Jones alleges that Combs regularly drugged others including minors by giving them alcoholic beverages laced with ecstasy and other date rape drugs, that he believes he himself was drugged by Combs, and that Combs routinely secretly recorded sexual encounters.

In May 2024, two more women sued Combs. Former model Crystal McKinney sued Combs in the Southern District of New York for drugging and sexually assaulting her at his recording studio in 2003. Combs had promised to help advance Ms. McKinney’s modeling career, a promise she believed he would fulfill because of his ownership of and/or titles at the Bad Boy enterprise and its related entities. April Lampros, an intern at Arista Records, which was an owner of Bad Boy, also sued Combs in May 2024 in New York County Supreme Court for raping her on multiple occasions, secretly filming at least one of the assaults, and showing the recording to multiple people. Ms. Lampros alleges that Combs ordered her to take drugs on one occasion before he raped her.

In July 2024, former adult film star Adria English – who was employed by Combs as an entertainer at his infamous White Parties that brought together the biggest names in the music and entertainment industries – sued Combs in the Southern District of New York for sex trafficking, alleging that he required her to consume drinks laced with ecstasy and secretly recorded the sexual acts he forced her to engage in.

In September 2024, singer and songwriter Dawn Angelique Richard also sued Combs. Richard was employed by Combs as part of the girl group Danity Kane, formed by Combs, and later as a key member of Combs’ band Diddy – Dirty Money. She sued Combs in the Southern District of New York for sexual assault, false imprisonment, and for subjecting her to hostile working conditions due to her gender, including degrading comments and threats. Ms. Richard has alleged that Combs regularly supplied others including minors with copious amounts of drugs and alcohol, and subjected them to sexual acts while they were sedated and/or unconscious due to the drugs and alcohol.

Plaintiff could not believe that Defendants would record themselves committing such a gruesome crime and then proceed proudly and widely to disseminate the recording of it. She was distraught and sunk into a deep depression. She again considered ending her life.

On September 16, 2024, Combs was arrested at a Manhattan hotel after a grand jury indicted him on charges of sex trafficking and racketeering. The indictment details how “[f]or decades, [Combs] abused, threatened, and coerced women and others around him to fulfill his sexual desires, protect his reputation, and conceal his conduct.” See United States of America v. Sean Combs, a/k/a Puff Daddy,” a/k/a “P. Diddy,” a/k/a “Diddy,” a/k/a “PD,” a/k/a “Love,” Index No. 24 Crim. 542, Indictment (SDNY), at ¶ 1. ^1 It notes that Combs’ abuse of women was enabled by “the employees, resources, and influence of the multi-faceted business empire that he led and controlled—creating a criminal enterprise whose members and associates engaged in, and attempted to engage in, among other crimes, sex trafficking, forced labor, kidnapping, arson, bribery, and obstruction of justice.” Id.

The indictment notes that Combs’ “business” was operated at various times in both Manhattan and Los Angeles, “under a variety of United States-based corporate entities, including Bad Boy Entertainment, Combs Enterprises, and Combs Global (collectively, the ‘Combs Business’).” Id. at ¶ 2.

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.

Combs’ long history of violence against women makes unmistakably clear that his actions, including his attack of Plaintiff, have been motivated by gender. Specifically, he has a profound contempt for women and an ongoing practice of denigrating and trying to humiliate them.

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

Plaintiff hereby incorporates each of the foregoing paragraphs as if fully set forth herein.

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.

The requirement that the crime of violence be committed because of gender or on the basis of gender, and due, at least in part, to an animus based on the victim’s gender is satisfied because Defendants Combs and Sherman violently forced Plaintiff to engage in vaginal intercourse, and oral and anal sex without her consent. Gender animus inheres when consent is absent. Moreover, Combs’ long history of violence against women evinces a deep contempt for women, as does Sherman’s alleged pattern of committing his own sexual assaults, recording them, and selling them as pornography.

Defendants Combs’ and Sherman’s rapes of Plaintiff presented a serious risk of physical injury to her and in fact caused her significant physical injuries including burning and pain in her vagina and anus, anal bleeding, and bruising to her face and wrists.

The Combs Corporations enabled Combs and/or Sherman to commit the crime of violence motivated by gender because Combs and Sherman raped Plaintiff at the Bad Boy studio, where on information and belief they routinely committed sexual assault and gender-motivated violence, as detailed in other civil lawsuits. Given Combs’ and Sherman’s long-standing pattern and practice of committing sexual violence against women, including at the same location where they raped Plaintiff, the Combs Corporations had and/or should have had knowledge of Combs and Sherman using the premises for this unlawful conduct, and did nothing to stop it.

This action seeks redress for Defendants’ brutalizing, misogynistic, and violent attacks on Plaintiff, starting in 2001 with their rape and continuing in the subsequent years as they compounded her humiliation by showing the video of the sexual assault to others.

The Combs Corporations enabled Combs and/or Sherman to commit the crime of violence motivated by gender by failing to, among other things, protect Plaintiff from a known danger and/or have sufficient policies and procedures in place to prevent sexual assault and/or train their employees on identifying and preventing sexual assault. Given Combs’ and Sherman’s long-standing pattern and practice of committing sexual violence against women, including on premises owned and/or operated by Defendants, the Combs Corporations had and/or should have had knowledge that Combs and Sherman were a danger to Plaintiff, and did nothing to stop Combs and Sherman.

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.

The Combs Corporations further enabled Combs and/or Sherman to commit the crime of violence motivated by gender by actively placing, maintaining, and/or employing Combs and/or Sherman in positions of power and authority, despite the fact that they knew and/or should have known that Combs had a widespread and well-known practice of committing sexual assault and gender-motivated violence, including on premises owned and/or operated by Defendants. Combs and Sherman used their titles and authority conferred by the Combs Corporations, including as CEO, Founder, and Chairman (Combs) and Head of Security (Sherman), to facilitate and perpetuate the violent assault on Plaintiff, and to intimidate and force Plaintiff to keep quiet in subsequent years.

The Combs Corporations also enabled Combs and/or Sherman to commit the crime of violence motivated by gender because Combs and Sherman used Plaintiff’s boyfriend’s employment as an executive for Bad Boy and Daddy’s House, and their stated concerns about his performance at work, to lure Plaintiff out of her home to meet with them alone.

On information and belief, Plaintiff alleges that Defendant Organizational Does 1 through 10, inclusive, are other parties not yet identified who have enabled Combs and/or Sherman to commit the crime of violence motivated by gender, in the ways articulated above and/or in other ways.

As a result of Defendants’ actions, Plaintiff suffered damages in an amount to be determined at trial and pursuant to the fee-shifting provision of the statute.

This legal action has been commenced within the statutory timeframe provided by the two-year look-back window for VGMVPA claims. See New York City Administrative Code § 10-1105.

Plaintiff hereby incorporates each of the foregoing paragraphs as if fully set forth herein.

By raping Plaintiff and recording it, Defendants caused Plaintiff to be depicted in a video image unclothed and with intimate body parts exposed, and engaging in sexual conduct with another person in violation of New York Civil Rights Law § 52-B.

Defendants published and/or disseminated the video without Plaintiff’s knowledge or consent. On information and belief, Defendants have continued to disseminate the video, including by selling it as pornography, through the present.

Plaintiff Thalia Graves is a female who resides in Harris County, Texas.

Plaintiff was fully identifiable in the video.

Plaintiff had a reasonable expectation that Defendants would not secretly record a violent rape of her and disseminate the video to others.

By intentionally publicly humiliating Plaintiff and trying to ruin Plaintiff’s romantic relationship with her then-boyfriend when they published the video, Defendants had the purpose of harassing, annoying, and/or alarming Plaintiff.

As a direct and proximate result of Defendants’ actions in violation of New York Civil Rights Law § 52-B, Plaintiff has suffered and continues to suffer emotional harm, including mental anguish, emotional distress, and humiliation in an amount to be determined at trial.

Defendants’ violations of New York Civil Rights Law § 52-B were malicious, willful, wanton, and outrageous, entitling Plaintiff to an award of punitive damages.

Defendants should be ordered to account for and destroy all copies of the video that are in their actual or constructive possession, custody, or control.

Defendants should be temporarily and permanently enjoined from further disseminating or publishing any intimate images of Plaintiff.

Plaintiff hereby incorporates each of the foregoing paragraphs as if fully set forth herein.

By recording and showing others the video of themselves violently raping Plaintiff, Defendants disclosed an intimate image of Plaintiff without her consent in violation of New York City Administrative Code § 10-180.

Defendants are covered recipients because they recorded and/or caused the video to be recorded themselves.

Defendant Sean Combs is a male who, on information and belief, resides in Los Angeles County, California, though at the time of filing was incarcerated in the Metropolitan Detention Center in Brooklyn. On information and belief, at all relevant times Combs owned and/or controlled Bad Boy Entertainment Holdings, Inc., Bad Boy Productions Holdings, Inc., Bad Boy Books Holdings, Inc., Bad Boy Records LLC, Bad Boy Entertainment LLC, Bad Boy Productions LLC, (collectively “Bad Boy”), Daddy’s House Recording Studio, Inc., and CE OPCO, LLC d/b/a Combs Global, f/k/a Combs Enterprises LLC (all together, the “Combs Corporations”). The facts of Combs’ ownership and titles at the Combs Corporations enabled him to commit the unlawful sexual violence against Plaintiff described herein and/or to harass and subsequently intimidate her into silence after the rape.

On information and belief, Defendants have continued to disseminate the video, including by selling it as pornography, through the present.

Such intimate images depicted Plaintiff unclothed and with intimate body parts exposed, and engaging in sexual conduct with another person, in violation of § 10-180.

Plaintiff was fully identifiable in the video.

Plaintiff had a reasonable expectation that Defendants would not secretly record a violent rape of her and disseminate the video to others and certainly did not intend for the recording to be disclosed to anyone.

Defendants intentionally disclosed and disseminated the video to Plaintiff’s then-boyfriend and others without Plaintiff’s consent with the intent to publicly humiliate Plaintiff and ruin her relationship with her then-boyfriend, causing her economic, hysical, and/or substantial emotional harm.

Defendants’ intention in disseminating and publishing the video was to harass, annoy, alarm, and humiliate Plaintiff, and to cause her economic, physical, and/or substantial emotional harm.

As a direct and proximate result of Defendants’ actions in violation of New York City Administrative Code § 10-180, Plaintiff has suffered and continues to suffer emotional harm, including mental anguish, emotional distress, and humiliation in an amount to be determined at trial.

Defendants’ violations of New York City Administrative Code § 10-180 were malicious, willful, wanton, and outrageous, entitling Plaintiff to an award of punitive damages.

Defendants should be ordered to account for and destroy all copies of the video that are in their actual or constructive possession, custody, or control.

Defendants should be temporarily and permanently enjoined from further disclosing and disseminating any intimate images of Plaintiff.

WHEREFORE, Plaintiff respectfully requests that judgment be entered against Defendants as follows:

Awarding compensatory damages for all physical injuries, emotional distress, psychological harm, anxiety, humiliation, physical and emotional pain and suffering, family and social disruption, and other harm, in an amount to be determined at trial;

Awarding punitive damages in an amount to be determined at trial;

Awarding attorneys’ fees and costs pursuant to any applicable statute or law, including under New York City Administrative Code § 10-1104, New York Civil Rights Law § 52-B(2), New York City Administrative Code § 10-180, and any other applicable statute or law;

Awarding pre- and post-judgment interest on all such damages, fees, and/or costs;

Attaching any and all of Defendants’ real property and other assets located in the State of New York pursuant to Federal Rule of Civil Procedure 64;

Ordering Defendants to account for and destroy all copies of any and all images and videos taken of or in connection with Combs’ and Sherman’s sexual assault of Plaintiff that are in their actual or constructive possession, custody, or control, and enjoining Defendants temporarily and permanently from further disseminating or publishing any intimate images or videos of Plaintiff; and

Awarding such other and further relief as this Court may deem just and proper.

For decades, SEAN COMBS, a/k/a “Puff Daddy,” a/k/a “P. Diddy,” a/k/a “Diddy,” a/k/a “PD,” a/k/a “Love,” the defendant, abused, threatened, and coerced women and others around him to fulfill his sexual desires, protect his reputation, and conceal his conduct. To do so, COMBS relied on the employees, resources, and influence of the multi-faceted business empire that he led and controlled–creating a criminal enterprise whose members and associates engaged in, and attempted to engage in, among other crimes, sex trafficking, forced labor, kidnapping, arson, bribery, and obstruction of justice.

SEAN COMBS, a/k/a “Puff Daddy,” a/k/a “P. Diddy,” a/k/a “Diddy,” a/k/a “PD,” a/k/a “Love,” the defendant, and others known and unknown, participated in unlawful and other activities related to the conduct of the Combs Enterprise’s affairs. These individuals included certain Combs Business employees, such as members of COMBS’ security staff, household staff, personal assistants, and high-ranking supervisors, as well as other close associates of COMBS.

The purposes of the Combs Enterprise included the following:

Operating a global business in the media, entertainment, and lifestyle industries, including, among other things, record labels, a recording studio, an apparel line, an alcoholic spirits business, a marketing agency, and a television network and media company;

Preserving, protecting, promoting, and enhancing the power, reputation, and brand of SEAN COMBS, a/k/a “Puff Daddy,” a/k/a “P. Diddy,” a/k/a “Diddy,” a/k/a “PD,” a/k/a “Love,” the defendant, as a musician, entrepreneur, and figure in the entertainment industry;

Enriching members and associates of the Enterprise, including its leader, COMBS, and in particular those who demonstrated loyalty to COMBS and willingness to conceal his crimes;

Preserving, protecting, promoting, and enhancing the power of the Combs Enterprise, including the power of its leader, COMBS, through violence, use of firearms, threats of violence, coercion, and verbal, emotional, physical, and sexual abuse;

Fulfilling the personal desires of COMBS, particularly those related to COMBS’ sexual gratification, including through the exploitation of women and the use of commercial sex workers;

Enabling COMBS and other members and associates of the Combs Enterprise to engage in unlawful acts of violence, including sexual violence; sex trafficking; forced labor; interstate transportation for purposes of prostitution; coercion and enticement to engage in prostitution; narcotics distribution; and other crimes, and concealing the commission of such acts;

Securing absolute loyalty from members of the Combs Enterprise, including through acts of violence and threats; and

Protecting the Combs Enterprise and its members and associates, including COMBS, from detection and prosecution by law enforcement authorities through acts of intimidation, manipulation, bribery, and threats of retaliation against individuals who witnessed the crimes committed by members and associates of the Enterprise.

Among the means and methods by which SEAN COMBS, a/k/a “Puff Daddy,” a/k/a “P. Diddy,” a/k/a “Diddy,” a/k/a “PD,” a/k/a “Love,” the defendant, and other members and associates of the Combs enterprise conducted and participated in the conduct of the affairs of the Combs Enterprise included the following:

COMBS, and other members and associates of the Combs Enterprise, wielded the power and prestige of COMBS’ role at the Combs Business to intimidate, threaten, and lure female victims into COMBS’ orbit, often under the pretense of a romantic relationship. COMBS then used force, threats of force, and coercion, to cause victims to engage in extended sex acts with male commercial sex workers that COMBS referred to as, among other things, “Freak Offs.” Freak Offs were elaborate and produced sex performances that COMBS arranged, directed, masturbated during, and often electronically recorded. In arranging these Freak Offs, COMBS, with the assistance of members and associates of the Combs Enterprise, transported, and caused to be transported, commercial sex workers across state lines and internationally. Freak Offs occurred regularly, sometimes lasted multiple days, and often involved multiple commercial sex workers. During Freak Offs, COMBS distributed a variety of controlled substances to victims, in part to keep the victims obedient and compliant. Sometimes unbeknownst to the victims, COMBS kept videos he filmed of victims engaging in sex acts with commercial sex workers. After Freak Offs, COMBS and the victims typically received IV fluids to recover from the physical exertion and drug use.

Members and associates of the Combs Enterprise, including high-ranking supervisors, security staff, household staff, personal assistants, and other Combs Business employees, facilitated the Freak Offs by, among other things, booking hotel rooms for the Freak Offs; stocking the hotel rooms in advance with the required Freak Off supplies, including controlled substances, baby oil, lubricant, extra linens, and lighting; cleaning the hotel rooms after the Freak Offs to try to mitigate room damage; arranging for travel for victims, commercial sex workers, and COMBS to and from Freak Offs; resupplying COMBS with requested supplies; delivering large sums of cash to COMBS to pay the commercial sex workers; and scheduling the delivery of IV fluids. In or about March 2024, during searches of COMBS’ residences in Miami, Florida and Los Angeles, California, law enforcement seized various Freak Off supplies, including narcotics and more than 1,000 bottles of baby oil and lubricant.

COMBS subjected victims to physical, emotional, and verbal abuse to cause the victims to engage in Freak Offs. COMBS maintained control over his victims through, among other things, physical violence, promises of career opportunities, granting and threatening to withhold financial support, and by other coercive means, including tracking their whereabouts, dictating the victims’ appearance, monitoring their medical records, controlling their housing, and supplying them with controlled substances. During and separate from Freak Offs, COMBS, among other things, hit, kicked, threw objects at, and dragged victims, at times, by their hair. These assaults often resulted in injuries that took days or weeks to heal. COMBS also threatened victims’ careers and livelihoods, including if they resisted participating in Freak Offs. Victims believed they could not refuse COMBS’ demands without risking their financial or job security or without repercussions in the form of physical or emotional abuse. COMBS also used the sensitive, embarrassing, and incriminating recordings that he made during Freak Offs as collateral to ensure the continued obedience and silence of the victims.

Members and associates of the Combs Enterprise, including COMBS’ security personnel, at times carried firearms. On more than one occasion, COMBS himself carried or brandished firearms to intimidate and threaten others, including victims of and witnesses to his abuse. In or about March 2024, during searches of COMBS’ residences in Miami, Florida and Los Angeles, California, law enforcement seized firearms and ammunition, including three AR-15s with defaced serial numbers, as well as a drum magazine.

Members and associates of the Combs Enterprise enabled COMBS’ control over victims by following his directions regarding financial payments to victims, advancing or suppressing the victims’ career opportunities, and acquiring the controlled substances COMBS used to keep the victims compliant. Members and associates of the Combs Enterprise at times witnessed COMBS’ violence toward the victims, or the victims’ injuries caused by Combs, without intervening. Instead, members and associates of the Combs Enterprise helped conceal the violence and abuse by, among other things, assisting COMBS in monitoring and preventing victims from leaving locations, such as hotels or COMBS’ residences. These occasions included instances in which a victim was required to remain in hiding-sometimes for several days at a time-to recover from injuries COMBS inflicted, without being publicly observed. Members and associates of the Combs Enterprise also assisted COMBS in locating and contacting victims who attempted to flee his abuse.

When employees, witnesses to his abuse, or others threatened COMBS’ authority or reputation, COMBS and members and associates of the Enterprise engaged in acts of violence, threats of violence, threats of financial and reputational harm, and verbal abuse. These acts of violence included kidnapping and arson. In addition, on multiple occasions, COMBS threw both objects and people, as well as hit, dragged, choked, and shoved others.

When COMBS’ authority or reputation was threatened by the possibility of negative publicity or legal or law enforcement action against him, including in or about late 2023 following public allegations of COMBS’ crimes, COMBS and members and associates of the Enterprise pressured witnesses and victims, including through attempted bribery, to stay silent and not report what they experienced or knew to law enforcement. On phone calls, COMBS and other members and associates of the Enterprise, among other things, provided these victims and witnesses with a false narrative of events in an effort to conceal COMBS’ crimes. COMBS caused these calls to be recorded on at least two occasions.

From at least in or about 2008, through on or about the date of the filing of this Indictment, in the Southern District of New York and elsewhere, SEAN COMBS, a/k/a “Puff Daddy,” a/k/a “P. Diddy,” a/k/a “Diddy,” a/k/a “PD,” a/k/a “Love,” the defendant, and others known and unknown, being persons employed by and associated with the Combs Enterprise described in paragraphs 6 through 12 of this Indictment, an enterprise engaged in, and the activities of which affected, interstate and foreign commerce, knowingly combined, conspired, confederated, and agreed together and with each other to violate the racketeering laws of the United States, to wit, Title 18, United States Code, Section 1962( c ), that is, to conduct and participate, directly and indirectly, in the conduct of the affairs of the Combs Enterprise through a pattern of racketeering activity, as that term is defined in Title 18, United States Code, Sections 1961(1) and 1961 ( 5), consisting of:

multiple acts involving kidnapping, chargeable under the following provisions of state law: California Penal Code § 207 (kidnapping), California Penal Code §§ 21 (a), 664 (attempt), California Penal Code § 31 ( aiding and abetting), and California Penal Code § 182 (conspiracy);

multiple acts involving arson, chargeable under the following provisions of state law: California Penal Code§ 451 (arson), California Penal Code§§ 21(a), 664 (attempt), California Penal Code § 31 ( aiding and abetting), and California Penal Code § 182 (conspiracy);

multiple acts involving bribery, chargeable under the following provisions of state law: California Penal Code § 137(a) (bribery of a witness), California Penal Code §§ 21(a), 664 (attempt), California Penal Code§ 31 (aiding and abetting), and California Penal Code § 182 (conspiracy);

multiple acts indictable under Title 18, United States Code, Section 1512 (relating to tampering with a witness, victim, or an informant)

multiple acts indictable under Title 18, United States Code, Sections 1589 and 2 (relating to forced labor);

multiple acts indictable under Title 18, United States Code, Sections 1591 and 2 (relating to sex trafficking);

multiple acts indictable under Title 18, United States Code, Sections 2421 , 2422, and 2 (relating to transportation and inducement to travel for purposes of prostitution and other illegal sexual activities); and

multiple offenses involving the possession with intent to distribute, or distribution of narcotics and controlled substances, including cocaine, oxycodone, alprazolam, 3,4-Methy lenedioxymethamphetamine, 4-Bromo-2,5-dimethoxyphenethy lamine, gamma hydroxybutyric acid, and ketamine, in violation of Title 21 , United States Code, Sections 841 (a)(l ), (b )(1 )(C), (b )(1 )(E), (b )(2), and 846 ( distribution and possession with intent to distribute and conspiracy to do the same), and Title 18, United States Code, Section 2 ( aiding, abetting, and willfully causing).

It was a part of the conspiracy that SEAN COMBS, a/k/a “Puff Daddy,” a/k/a “P. Diddy,” a/k/a “Diddy,” a/k/a “PD,” a/k/a “Love,” the defendant, agreed that a conspirator would commit at least two acts of racketeering activity in the conduct of the affairs of the Combs Enterprise.

From at least in or about 2009, up to and including in or about 2018, in the Southern District of New York and elsewhere, as part of his agreement to conduct and participate in the conduct of the affairs of the Combs Enterprise through a pattern of racketeering activity, SEAN COMBS, a/k/a “Puff Daddy,” a/k/a “P. Diddy,” a/k/a “Diddy,” a/k/a “PD,” a/k/a “Love,” the defendant, agreed to, in and affecting interstate and foreign commerce, knowingly recruit, entice, harbor, transport, provide, obtain, advertise, maintain, patronize, and solicit by any means a person, knowing and in reckless disregard of the fact that means of force, threats of force, fraud, and coercion, as described in Title 18, United States Code, Section 1591(e)(2), and any combination of such means, would be used to cause the person to engage in a commercial sex act, in violation of Title 18, United States Code, Section 1591(a)(l) and (b)(l).

From at least in or about 2009, up to and including in or about 2018, in the Southern District of New York and elsewhere, SEAN COMBS, a/k/a “Puff Daddy,” a/k/a “P. Diddy,” a/k/a “Diddy,” a/k/a “PD,” a/k/a “Love,” the defendant, in and affecting interstate and foreign commerce, knowingly recruited, enticed, harbored, transported, provided, obtained, advertised, maintained, patronized, and solicited by any means a person, knowing and in reckless disregard of the fact that means of force, threats of force, fraud, and coercion, as described in Title 18, United States Code, Section 1591(e)(2), and any combination of such means, would be used to cause the person to engage in a commercial sex act, and attempted, aided and abetted, and willfully caused the same, to wit, COMBS recruited, enticed, harbored, transported, and maintained a person (“Victim-1 “), and attempted, aided and abetted, and willfully caused Victim-1 , to engage in commercial sex acts, knowing and in reckless disregard of the fact that Victim-1 was engaging in commercial sex acts as a result of force, fraud, and coercion.

From at least in or about 2009, up to and including in or about 2024, in the Southern District of New York and elsewhere, SEAN COMBS, a/k/a “Puff Daddy,” a/k/a “P. Diddy,” a/k/a “Diddy,” a/k/a “PD,” a/k/a “Love,” the defendant, knowingly transported an individual in interstate and foreign commerce with intent that the individual engage in prostitution, and attempted, aided and abetted, and willfully caused the same, to wit, COMBS transported, aided and abetted, and willfully caused the transportation of female victims and commercial sex workers in interstate and foreign commerce on multiple occasions with the intent that they engage in prostitution.

As a result of committing the offense alleged in Count One of this Indictment, SEAN COMBS, a/k/a “Puff Daddy,” a/k/a “P. Diddy,” a/k/a “Diddy,” a/k/a “PD,” a/k/a “Love,” the defendant, shall forfeit to the United States, pursuant to Title 18, United States Code, Section 1963, any and all interests the defendant acquired or maintained in violation of Title 18, United States Code, Section 1962; any and all interests in, securities of, claims against, and property or contractual rights of any kind affording a source of influence over, the enterprise named and described herein which the defendant established, operated, controlled, conducted, and participated in the conduct of, in violation of Title 18·, United States Code, Section 1962; and any and all property constituting and derived from proceeds obtained, directly and indirectly, said offense, including but not limited to a sum of money in United States currency representing the amount of proceeds traceable to the commission of said offense.

As a result of committing the offense alleged in Count Two of this Indictment, SEAN COMBS, a/k/a “Puff Daddy,” a/k/a “P. Diddy,” a/k/a “Diddy,” a/k/a “PD,” a/k/a “Love,” the defendant, shall forfeit to the United States, pursuant to Title 18, United States Code, Section 1594, any and all property, real and personal, involved in, used, or intended to be used to commit or to facilitate the commission of said offense and any and all property traceable to such property; any and all property, realand personal, constituting or derived from proceeds obtained, directly or indirectly, as a result of said offense, including but not limited to a sum of money in United States currency representing the amount of property involved in said offense and proceeds traceable to the commission of said offense.

SEAN COMBS, a/k/a “Puff Daddy,” a/k/a “P. Diddy,” a/k/a “Diddy,” a/k/a “PD,” a/k/a “Love,” the defendant, operated his business, headquartered at various times in Manhattan and Los Angeles, under a variety of United States-based corporate entities, including Bad Boy Entertainment, Combs Enterprises, and Combs Global (collectively, the “Combs Business”). Corporate entities in the Combs Business included, among other things, record labels, a recording studio, an apparel line, an alcoholic spirits business, a marketing agency, and a television network and media company.

As a result of committing the offense alleged in Count Three of this Indictment, SEAN COMBS, a/k/a “Puff Daddy,” a/k/a “P. Diddy ,” a/k/a “Diddy ,” a/k/a “PD,” a/k/a “Love,” the defendant, shall forfeit to the United States, pursuant to (i) Title 18, United States Code, Section 2428, any and all property, real and personal, constituting or derived from proceeds obtained, directly or indirectly, as a result of said offense; and any and all property, real or personal, that was used or intended to be used to commit or facilitate the commission of said offense, and (ii) Title 18, United States Code, Section 981(a)(l)(C) and Title 28, United States Code, Section 2461 , any and all property, real and personal, that constitutes or is derived from proceeds traceable to the commission of said offense, including but not limited to a sum of money in United States currency representing the amount of proceeds traceable to the commission of said offense.

If any of the above described forfeitable property, as a result of any act or omission of the defendant:

cannot be located upon the exercise of due diligence;

has been transferred or sold to, or deposited with, a third person;

has been placed beyond the jurisdiction of the Court;

has been substantially diminished in value; or

has been commingled with other property which cannot be subdivided without difficulty;

it is the intent of the United States, pursuant to Title 18, United States Code, Section 1963(m), Title 21, United States Code, Section 853(p), and Title 28, United States Code, Section 2461(c), to seek forfeiture of any other property of the defendant up to the value of the above forfeitable property

At all times relevant to this Indictment, SEAN COMBS, a/k/a “Puff Daddy,” a/k/a “P. Diddy,” a/k/a “Diddy,” a/k/a “PD,” a/k/a “Love,” the defendant, engaged in a persistent and pervasive pattern of abuse toward women and other individuals. This abuse was, at times, verbal, emotional, physical, and sexual. As part of his pattern of abuse, COMBS manipulated women to participate in highly orchestrated performances of sexual activity with male commercial sex workers. At times, COMBS, and others acting at his direction, made arrangements for women and commercial sex workers to fly to COMBS’ location. COMBS ensured participation from the women by, among other things, obtaining and distributing narcotics to them, controlling their careers, leveraging his financial support and threatening to cut off the same, and using intimidation and violence.

Physical abuse by SEAN COMBS, a/k/a “Puff Daddy,” a/k/a “P. Diddy,” a/k/a “Diddy ,” a/k/a “PD,” a/k/a “Love,” the defendant, was recurrent and widely known. On numerous occasions from at least in or about 2009 and continuing for years, COMBS assaulted women by, among other things, striking, punching, dragging, throwing objects at, and kicking them. These assaults were, at times, witnessed by others and included one instance at a Los Angeles hotel in or about March 2016, which was captured on video and later publicly reported, where COMBS kicked, dragged, and threw a vase at a woman as she was attempting to leave. When a member of the hotel security staff intervened, COMBS attempted to bribe the staff member to nsure silence.COMBS’ violence was also not limited to these women. It extended to his employees, witnesses to his abuse, and others.

SEAN COMBS, a/k/a “Puff Daddy,” a/k/a “P. Diddy,” a/k/a “Diddy,” a/k/a “PD,” a/k/a “Love,” the defendant, used the Combs Business, including certain employees, to carry out, facilitate, and cover up his abuse and commercial sex. Those employees-including security staff, household staff, personal assistants, and high-ranking supervisors-and other close associates acted as COMBS’ intermediaries, and their conduct was facilitated and assisted by COMBS’ control of the Combs Business.

From at least in or about 2008, through on or about the date of the filing of this Indictment, SEAN COMBS, a/k/a “Puff Daddy,” a/k/a “P. Diddy,” a/k/a “Diddy,” a/k/a “PD,” a/k/a “Love,” the defendant, and others known and unknown, were members and associates of a criminal organization (the “Combs Enterprise” or the “Enterprise”). Members and associates of the Combs Enterprise engaged in, and attempted to engage in, among other activities, sex trafficking, forced labor, interstate transportation for purposes of prostitution, coercion and enticement to engage in prostitution, narcotics offenses, kidnapping, arson, bribery, and obstruction of justice.

The Combs Enterprise, including its leadership, its members, and its associates, constituted an “enterprise,” as defined by Title 18, United States Code, Section 1961 ( 4 ), that is, a group of individuals associated in fact, although not a legal entity. The Combs Enterprise consisted of: (i) SEAN COMBS, a/k/a “Puff Daddy,” a/k/a “P. Diddy,” a/k/a “Diddy,” a/k/a “PD,” a/k/a “Love,” the defendant; (ii) entities within the Combs Business, including but not limited to Bad Boy Entertainment, Combs Enterprises, and Combs Global; (iii) individuals employed by and associated with the Combs Business; and (iv) others known and unknown.

The Combs Enterprise constituted an ongoing organization whose members functioned as a continuing unit for a common purpose of achieving the objectives of the Combs Enterprise. The Combs Enterprise was engaged in, and its activities affected, interstate and foreign commerce. The Combs Enterprise operated in the Southern District of New York and elsewhere.

At all times relevant to this Indictment, SEAN COMBS, a/k/a “Puff Daddy,” a/k/a “P. Diddy,” a/k/a “Diddy,” a/k/a “PD,” a/k/a “Love,” the defendant, was the leader of the Combs Enterprise.

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