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.

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