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.

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