Complaint: Rodney Jones v. Sean Combs, Et Al

Case 1:24-cv-01457 Document 1 Filed 02/26/24 Page 1 of 73
UNITED STATES FEDERAL COURT

SOUTHERN DISTRICT OF NEW YORK
RODNEY JONES,
Plaintiff, Case Number: 24-1457
v. Civil Action
SEAN COMBS, Jury Demand

JUSTIN DIOR COMBS,
ETHIOPIA HABTEMARIAM,
LUCIAN CHARLES GRAINGE,
KRISTINA KHORRAM,
CHALICE RECORDING STUDIOS,
LOVE RECORDS,
MOTOWN RECORDS,
UNIVERSAL MUSIC GROUP,
COMBS GLOBAL ENTERPRISES,
JOHN and JANE DOES 1-10 and
ABC CORPORATIONS. 1-10
Defendants.
TRIGGER WARNING:
THIS DOCUMENT CONTAINS HIGHLY GRAPHIC INFORMATION OF A
SEXUAL NATURE, INCLUDING SEXUAL ASSAULT. ADDITIONALLY,
THERE ARE GRAPHIC IMAGES OF THE AFTERMATH OF A SHOOTING,
REDACTED IMAGES OF SEXUAL INTERCOURSE, REDACTED IMAGES OF
MINORS, SEX WORKERS, AND PROSTITUTES, DETAILS OF SEX
TRAFFICKING, AND THE ILLEGAL DISTRIBUTION OF GUNS, AND DRUGS
Plaintiff Rodney “Lil Rod” Jones (“Mr. Jones”) hereby alleges, as and for his Complaint
against Defendant Sean Combs (“Mr. Combs”), Defendant Justin Dior Combs (“J. Combs”),
Defendant Lucian Charles Grainge (“Mr. Grainge”), Defendant Ethiopia Habtemariam (“Ms.
Habtemariam”), Defendant Kristina Khorram (“Ms. Khorram”), Defendant Chalice Recording
Studios (“CRS”), Defendant Love Records (“LR”), Defendant Motown Records (“MR”),
Defendant Universal Music Group (“UMG”), Defendant Combs Global Enterprises (“CGE”),
John and Jane Does 1-10, ABC Corporations 1-10, as follows:
JURISDICTION AND VENUE

1. This Court has personal jurisdiction over the Defendants under and consistent with the
Constitutional requirements of Due Process in that the Defendants, acting directly or through
his agents or apparent agents, committed one or more of the following:
a. The transaction of any business within the state;
b. The making of any contract within the state;
c. The commission of a tortious act within this district and
d. The ownership, use, or possession of any real estate in this state.
2. From September 2022 to the date of this filing, Defendants have consistently and purposefully
availed themselves of the privilege of conducting activities within New York, thus invoking
the benefits and protections of New York law. In return for these benefits and protections,
Defendants must submit to the burdens of litigation in New York.
3. This litigation arises from or relates to the tortious activities defendants visited upon
defendants in the states of New York, California, Florida, and the United States Virgin Island.
This tortious conduct violated United States Federal Rico Laws.
4. Requiring Defendants to litigate these claims in this District does not offend traditional
notions of fair play and substantial justice. Plaintiffs’ claims arise from some conduct
occurring by Defendants in New York.
PARTIES
5. Plaintiff Rodney Jones is an American artist and music producer. Mr. Jones resides in the
states of New York, and California.
6. Defendant Sean Combs is a rapper and record executive popularly known by his stage names
Puff Daddy, Puffy, P. Diddy, Diddy, Brother Love or Love. Mr. Combs came to fame in the
early 1990s with his record label Bad Boy Records. He rose to prominence in the music and
entertainment industry over the decades and is regularly referred to as a hip-hop mogul. Mr.
Combs resides at 200 South Mapleton Dr., Beverly Hills, California 90024.
2
Defendant Sean Combs

7. Defendant Justin Dior Combs is the son of Mr. Combs and Misa Hylton. J. Combs was born
on December 30, 1993. J. Combs is a producer and actor. He has appeared on TV series like
Catfish: The TV Show, Wild' N Out and Hip-Hop Squares. Defendant Justin Dior Combs
resides at 1550 N El Centro Ave, Los Angeles, CA 90028.
Defendant Justin Dior Combs

8. Defendant Lucian Charles Grainge is the CEO of Defendant Universal Music Group.
Defendant Lucian Charles Grainge resides at 53551 Ross Ave Unit 34A, La Quinta, CA
92253; and 668 Chautauqua Blvd, Pacific Palisades, CA 90272.
3
Lucian Charles Grainge

9. Defendant Ethiopia Habtemariam is the Former CEO of Defendant Motown Records the
parent company of Defendant Love Records. Defendant Habtemariam resides at 13701
Riverside Dr Apt 8Flr, Sherman Oaks, CA 91423-2430.
Ethiopia Habtemariam
10. Defendant Kristina Khorram is the Chief of Staff to Sean “Diddy” Combs, Combs Global
Enterprises. She resides at 10445 Wilshire Blvd Apt 501, Los Angeles, CA 90024.
Kristina Khorram, Chief of Staff to Sean "Diddy" Combs

11. Defendant Chalice Recording Studios is a popular recording studio located at 845 Highland
Ave, Los Angeles, CA 90038, United States.
4
12. Defendant Motown Records is a record label with a principal place of business located at 1750
Vine St, Los Angeles, CA. Ethiopia Habtemariam was the chairman and CEO of Universal
Music Group’s Motown Records.
13. Defendant Universal Music Group is a record label with a principal place of business located
at 2220 Colorado Avenue in Santa Monica, California. Lucian Grainge is the Chairman &
CEO, Universal Music Group.
14. Defendant Love Records is a record label with a principal place of business located at 6255
Sunset Boulevard Suite 713. Los Angeles, CA, United States 90028. Defendant Love Records
was founded by Mr. Combs and Defendant Motown Records.
5
15. Defendant Combs Enterprises is a diverse portfolio of businesses and investments

that includes music, fashion, fragrance, beverage, marketing, film, television, and media
properties. They have a principal place of business located in New York, New York.
Combs Global
RODNEY LIL ROD JONES

16. Rodney “Lil Rod” Jones Jr. is from the Windy City [Chi-town]. He was born and raised in
Chicago, Illinois. Mr. Jones is the second oldest son and fourth child out of nine siblings. Mr.
Jones comes from a long line of Gospel Music influencers.
17. Mr. Jones started playing instruments at the age of five. He began playing drums in church,
and at the age of thirteen he picked up playing the guitar. From thirteen to present day, Mr.
Jones has taught himself to play over thirteen instruments.
Mr. Jones, the Child Prodigy
6
18. Mr. Jones is considered a musical prodigy. His talents have led him to produce and create a
commercial marketplace for music that has been recorded by some of the most prestigious
and highly acclaimed artists in music history.
19. Throughout the duration of his career, Mr. Jones has worked the south side of Chicago Music
scene, playing with the following legendary greats: Georgia Mass Choir, Donald Lawrence,
The Clark Sisters and The Smokie Norful.
20. On or about, August 2022 Mr. Jones received a call from Mr. Combs requesting that he
produce several songs on a rhythm and blues album titled, “The Love Album: Off the Grid,”
(“Love Album”).
21. Mr. Jones agreed, and his life has been detrimentally impacted ever since.
SUMMARY OF EVENTS
22. From September 2022 to November 2023, Mr. Jones produced nine songs on Mr. Combs'
Love album.
23. Mr. Jones lived with Mr. Combs for months at a time, spending holidays, birthdays, and
missing major family events.
24. Mr. Jones resided at Mr. Combs residence located in Los Angeles, California, New York City,
and Miami, Florida. Mr. Jones also spent several weeks on a yacht rented by Mr. Combs in
the US Virgin Islands.
25. Throughout his time with Mr. Combs, Mr. Jones witnessed, experienced, and endured many
things that went far beyond his role as a Producer on the Love album.
26. The claims raised in this complaint have been corroborated through witness statements,
video/audio recordings, and images that Mr. Jones has in his possession.
27. Mr. Combs required Mr. Jones to record him constantly. On several occasions, Mr. Combs
took Mr. Jones cellphone and began recording himself. As a result, Mr. Jones has secured
HUNDREDS of hours of footage and audio recordings of Mr. Combs, his staff, and his guests
engaging in serious illegal activity.
28. Mr. Jones has secured irrefutable evidence of:
a. The acquisition, use, and distribution of ecstasy, cocaine, GHB, ketamine, marijuana,
and mushrooms,
b. The displaying and distribution of unregistered illegal firearms,
7
c. Mr. Combs providing laced alcoholic beverages to minors and sex workers at his
homes in California, New York, the U. S. Virgin Islands1, and Florida,
d. Mr. Combs Chief of Staff, Kristina Khorram (“KK”) instructing her staff to retrieve
drugs so she can provide it to Mr. Combs for his consumption,
e. Christian Combs drugging and sexually assaulting a woman2,
f. Mr. Combs detailing how he planned to leverage his relationship with Bishop T.D.
Jakes to soften the impact on his public image of Cassie Ventura’s lawsuit,
g. Yung Miami’s cousin, and or assistant sexually assaulting Mr. Jones,
h. Actor Cuba Gooding Jr. sexually harassing and assaulting Mr. Jones,
i. Rapper3 (REDACTED) on Mr. Combs yacht consorting with underaged girls, sex
workers, and
j. R&B Singer4 (REDACTED) in Mr. Combs Los Angeles home consorting with
underaged girls and sex workers.
CHALICE RECORDING STUDIOS SHOOTING

29. On or about September 12, 2022, Mr. Combs held a writers and producers camp at Chalice
Recording Studio at 845 Highland Ave, Los Angeles, CA 90038.
30. Present at this camp were Mr. Combs, his son Justin Combs, and Justin's friend named G.
31. Mr. G is a 30-year-old tall African American male.
32. In addition to these individuals, other musicians were present at the camp. This writer has
spoken to several musicians who attended the camp.
33. One evening during this camp, Mr. Combs, J. Combs, and G were in a heated conversation.
34. That conversation was moved out of the studio and into a restroom adjacent to where Mr.
Jones was sitting.
35. Mr. Jones was approximately 2 feet away from the bathroom when gunshots rang out. Mr.
Jones recalls hearing multiple gunshots.
1
This writer spoke with several employees of the yacht rented my Mr. Combs in the U.S. Virgin Islands who
personally witnessed Defendant Khorram instruct her staff, Brendan Paul, Frankie Santella, and Moy Baun spike
bottles of champagne with ecstasy.
2
A complaint is forthcoming.
3
He is a Philadelphia Rapper who dated Nicki Minaj.
4
He is a Grammy Award winning R&B singer who had trouble with law enforcement after assaulting a Bajan
Billionaire.
8
36. Mr. Jones immediately went into a state of shock and feared that he would be shot next. Mr.
Jones genuinely believed that he would be shot through the door due to how close he was.
37. After the shooting ended, a crowd gathered around the restroom.
38. When the door finally opened, Mr. Combs and J. Combs exited.
39. G was lying on the restroom floor in a fetal position, holding his stomach and bleeding out of
his leg/hip area.
40. Everyone stood around looking upon G. Frustrated by the lack of aid to G, Mr. Jones dropped
everything, ran to G, and immediately began placing pressure on G’s gunshot wound to his
stomach.
41. As he was applying pressure on his stomach, Mr. Jones realized that G was gushing blood
from another area near his leg/hip.
42. He decided to lift G and placed him to sit on the toilet. Mr. Jones asked the crowd to call the
ambulance.
43. Mr. Jones lifted G and brought him to the ambulance at the studio's front. At this time, Mr.
Combs and Justin disappeared to another part of the studio.
44. Mr. Combs gave strict instructions to inform the police that he had nothing to do with the
shooting. He also forced Mr. Jones to lie to the police by telling them that G was shot standing
outside the studio by a drive-by assailant.
9
45. Mr. Jones has several corroborating witnesses who spoke with this writer anonymously due
to fear of retaliation from Mr. Combs. They have agreed to speak publicly when subpoenaed.
10
46. Mr. Jones has the clothing he wore that day and believes it may still have the stains and DNA
of G’s blood.
47. The following are screenshots of the aftermath of the restroom where G was shot by either
Mr. Combs or J. Combs:
Aftermath of the Shooting of G

48. Clearly, G was NOT shot outside of the studio as Mr. Combs instructed his team to report to
law enforcement.
49. Mr. Combs and Defendant’s LR, MR, UMG, and CRS provided private security for the writers
camp at Defendant CRS.
50. The Security was porous and lackluster at best.
51. The fact that either Mr. Combs and J. Combs were allowed to enter CRS with guns, and those
guns were not confiscated by security is a clear breach of duty by Mr. Combs, Defendant’s
LR, MR, and UMG to protect Mr. Jones and the other attendees of this writers camp.
52. As a result of this shooting, Mr. Jones is severely traumatized. Mr. Jones now suffers from
PTSD, severe anxiety, depression, and insomnia.
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MR. JONES WAS SEXUALLY HARASSED, AND ASSAULTED BY MR. COMBS

53. Throughout his time living with Mr. Combs, Mr. Jones was the victim of constant unsolicited
and unauthorized groping and touching of his anus by Mr. Combs.
54. These events took place in LA, NY, FL, and the United States Virgin Islands.
55. In addition to the unsolicited and unauthorized touching, Mr. Jones was forced by Mr. Combs
to work in Mr. Combs' bathroom as Mr. Combs walked around naked and showered in a clear
glass enclosure.
56. As a heterosexual Christian man, Mr. Jones was uncomfortable with Mr. Combs’ advances
and expressed his discomfort to Mr. Combs Chief of Staff, Kristina Khorram (“KK”).
57. KK responded to Mr. Jones complaint with, “you know, Sean will be Sean.”
58. KK also attempted to downplay Mr. Combs groping of Mr. Jones anus and genitals, as friendly
horseplay, stating that those acts were Mr. Combs way of “showing that he likes you [Mr.
Jones]”.
59. Despite these assurances, on several occasions when Mr. Combs began to undress and walk
around his house naked, KK would say, “okay, I am leaving now,” and she would disappear.
60. KK’s hypocrisy is breathtaking at best or enabling at worst.
61. Mr. Jones believes that KK aided and abetted Mr. Combs’ sexual assault of him and was
working with Mr. Combs to groom him into accepting a homosexual relationship.
62. Through these sexually deviant acts, one would say Mr. Combs has a pattern and practice of
engaging in such nefarious activity. This ongoing conduct shows that Mr. Combs cannot be
rehabilitated.
MR. COMBS ATTEMPTED TO GROOM MR. JONES INTO ENGAGING IN GAY SEX
63. Mr. Combs was aware that Mr. Jones looked up to, and idolized music Producer Steven Aaron
Jordan (“Stevie J”).
64. Stevie J is an American DJ, record producer, and television personality.
65. Stevie J was part of the Bad Boy Records production team the Hitmen.
66. In 1997, Stevie J won a Grammy Award for his work on Puff Daddy's debut album.
67. Throughout the late 1990s, Stevie J produced for several artists including Mariah Carey, Tevin
Campbell, The Notorious B.I.G., 112, Jodeci, Faith Evans, Jay-Z, and Eve.
68. Stevie J was one of the producers on the Love Album.
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69. Mr. Combs used access to Stevie J, and his knowledge of Mr. Jones admiration of Stevie J to
groom and entice Mr. Jones to engage in homosexuality.
70. Mr. Combs went so far as to share a video of Stevie J anally penetrating a Caucasian male
without a condom. This was done to ease Mr. Jones’ anxiety concerning homosexuality.
According to Mr. Combs, “this is a normal practice in the music industry, look even Stevie J
is doing it.”
71. Mr. Combs informed Mr. Jones that he had engaged in sexual intercourse with rapper5
(REDACTED), R&B singer6 (REDACTED), and Stevie J.
72. Mr. Combs promised to make sure that Mr. Jones wins producer of the year at the Grammys
if he engaged in homosexuality.
73. The following are screenshots of the video7 of Stevie J anally penetrating a Caucasian male,
that Mr. Combs provided to Mr. Jones:
5
He is a Philadelphia Rapper who dated Nicki Minaj.
6
He performed at the Superbowl and had a successful Vegas residency.
7
This writer is in possession of the video and will provide a copy to the court.
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THANKSGIVING 2022, MR. JONES IS SEXUALLY ASSAULTED BY

YUNG MIAMI’S COUSIN
74. On Thanksgiving Day 2022, Mr. Jones was in Mr. Combs house located in Miami, Florida.
Yung Miami and her female cousins were also present.
75. Mr. Combs was intoxicated and offered cocaine to Mr. Jones. Mr. Jones rejected him and
proceeded to walk to the restroom.
76. While using the restroom Yung Miami’s cousin burst into the bathroom and began groping
Mr. Jones. Mr. Jones believes that Mr. Combs sent her in there to sexually assault Mr. Jones.
77. As she entered the bathroom she dropped to her knees and began performing oral sex on Mr.
Jones exposed penis. Mr. Jones pushed her away and exited the bathroom.
78. Yung Miami’s cousin did not accept Mr. Jones rejection, as she proceeded to follow Mr. Jones
out of the bathroom.
79. She started undressing and attempted to straddle him and have sex with him in the presence
of Mr. Combs and his staff.
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80. Once again Mr. Jones pushed her off. The following are images from a video8 of Yung Miami,
her cousin, Mr. Jones, and Mr. Combs:
Mr. Jones and Mr. Combs on Thanksgiving Day right before Mr. Combs invites Mr. Jones
into the restroom and attempted to force him to take cocaine.
Yung Miami, and her female cousin who sexually assaulted Mr. Jones on
Thanksgiving Day 2022
TRAFFICKING AND VICTIMS’ PROTECTION ACT

81. Throughout his time with Mr. Combs, Mr. Jones was transported from California to New
York, Florida, and the United States Virgin Islands.
82. During this time, Mr. Jones was forced to solicit sex workers and perform sex acts to the
pleasure of Mr. Combs.
83. On or about February 4, 2023, Mr. Combs forced Mr. Jones to bring prostitutes and sex
workers back to his home in Miami, Florida.
8
15
The Sex Workers That Mr. Combs Forced Mr. Jones To Bring Back To His Home
84. On or about, February 2, 2023, incident, Mr. Jones believes Mr. Combs drugged him. Mr.
Jones recalls waking up naked, dizzy, and confused. He was in bed with two sex workers and
Mr. Combs. He also recalls aimlessly wandering around the house with no clothes on.
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Sex Workers In Mr. Jones Bed The Morning After Being Drugged
85. On another occasion in Miami, Florida, on Thanksgiving night of 2022, Mr. Combs asked Mr.
Jones and DeForrest Taylor to enter the studio bathroom.
86. He asked them for a hundred-dollar bill because he wanted them to do cocaine with him.
87. Mr. Jones was scared, but luckily, he didn’t have a hundred-dollar bill, so Mr. Combs waited
a little later to do coke with Yung Miami.
88. Later that evening, he required Mr. Jones to solicit sex workers from Booby Trap on the River
located at 3615 NW S River Dr, Miami, FL 33142. Mr. Jones did so, and Mr. Combs forced
him to engage in unsolicited sex acts with these workers.
17
Booby Trap on the River

89. As part of Mr. Jones sex worker recruitment tools, Mr. Combs provided Mr. Jones with an
exclusive Bad Boy baseball cap and required him to wear it to Booby Trap on the River as a
signal to any sex worker he approached that Mr. Combs was in town and had sent Mr. Jones
to recruit them.
90. Mr. Jones had no desire to visit Booby Trap on the River. Mr. Jones had no desire to solicit
sex workers from Booby Trap on the River. Mr. Combs used his power and influence, to
intimidate and force Mr. Jones into soliciting sex workers from Booby Trap on the River. As
detailed below, Mr. Combs used many tactics to maintain dominion and control of Mr. Jones.
91. Apparently, these workers were accustomed to servicing Mr. Combs, and would know that he
is in town by the sight of the Bad Boys baseball cap.
92. The following are Instagram Profiles of two of the sex workers that Mr. Combs required Mr.
Jones to solicit and have sex with at his home in Miami, Florida:
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93. Mr. Jones had no desire to solicit and or have sex with the individuals in the previous
paragraph. Mr. Combs used his power and influence, to intimidate and force Mr. Jones into
soliciting and sleeping with these women.
94. The following is the phone number of another sex worker that Mr. Combs required Mr. Jones
to solicit and perform sex acts with at his home in Miami, Florida:
95. Mr. Jones had no desire to solicit and or have sex with the individual in the previous
paragraphs. Mr. Combs used his power, and influence, to intimidate and force Mr. Jones into
soliciting and sleeping with the individuals above.
96. Mr. Combs used many tactics to maintain dominion and control of Mr. Jones. He promised
him a Grammy for Producer of the Year for the Love Album. He offered him $250,000.00 to
purchase all the instruments he wanted. He promised him ownership of his $20,000,000
property, 1 Star Island, in Miami, Florida. He promised access to record label executives like
Defendants Lucian Charles Grainge and Ethiopia Habtemariam.
97. Mr. Combs would often switch up his approach. He would go from promising Mr. Jones the
world to threatening Mr. Jones with physical harm. Mr. Combs threatened to eat Mr. Jones
face and informed Mr. Jones that he is willing to kill his mother, Janice Combs, if he must in
order to get what he wants, so he wouldn’t think twice to harm Mr. Jones.
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MR. COMBS AND J. COMBS SOLICITS, DRUGS AND ENGAGES IN ILLICIT SEX
ACTS WITH MINORS AND SEX WORKERS
98. On or about July 2, 2023, in California, Mr. Combs had a "listening party" at his home.
99. Present at this party was a R&B artist9 (REDACTED), J. Combs, sex workers, and some
underaged girls.
100. The event began at 7 pm. Mr. Combs requested female sex workers and required Mr. Jones
to solicit them. An hour later, several sex workers appeared.
101. In addition to sex workers, there were at least five women in the crowd that were under the
age of sixteen.
102. Mr. Combs forced all the women to drink laced DeLeon liquor. Upon information and
belief, Mr. Combs laced the liquor with ecstasy.
103. Mr. Combs did not check the identification of any of these underage girls.
104. The presence of these underage women made Mr. Jones very uncomfortable.
105. He attempted to leave, and Mr. Combs forced him to stay.
106. Mr. Combs went so far as to take Mr. Jones' car keys to prevent him from leaving.
107. After being forced to drink laced DeLeon shots Mr. Jones began feeling lightheaded and
recalls passing out and waking up at 4 am the following morning naked with a sex worker
sleeping next to him.
108. Screenshots of a video10 from that night is imbedded below:
9
He is a Grammy Award winning R&B singer who had trouble with law enforcement after assaulting a Bajan
Billionaire.
10
20
Mr. Combs With an Underage Female Sex Worker

Underage Female
Justin Combs With an

Underage Female
MR. COMBS ATTEMPTS TO PASS OFF MR. JONES TO CUBA GOODING JR.
109. Mr. Jones believes that Mr. Combs was grooming him to pass him off to his friends.
110. This fear became reality when Mr. Combs introduced Mr. Jones to Cuba Gooding Jr. while
they were on Mr. Combs’ yacht.
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111. During the introduction, Mr. Combs suggested that Cuba “get to know” Mr. Jones better.
He then left them alone in a makeshift studio on the yacht.
Mr. Combs and Cuba Gooding Jr. Moments Before Mr. Jones is Assaulted
112. As evidenced by a video, of which screenshots are imbedded below, Cuba Gooding Jr.
began touching, groping, and fondling Mr. Jones’ legs, his upper inner thighs near his groin,
the small of his back near his buttocks and his shoulders.
113. Mr. Jones was extremely uncomfortable, and proceeded to lean away from Mr. Gooding Jr.
114. He rejected his advances and Mr. Gooding Jr. did not stop until Mr. Jones forcibly pushed
him away. The following is a screenshot11 of the encounter with Cuba Gooding Jr.:
11
22
Cuba Gooding Jr12. Forcibly Touching Mr. Jones on Mr. Combs yacht
THE LOVE ALBUM

115. Throughout his time with Mr. Combs, Mr. Jones was under an implied work-for-hire
agreement.
116. He was not compensated for his time living with Mr. Combs or for the songs he produced.
117. As evidence, he was listed as a producer for the following songs on the Love Albums final
release: Deliver Me, Stay PT 1, Reaching, What’s Love, Stay Awhile, Moments, Need
Somebody, Homecoming, and Tough Love.
118. Mr. Combs and Defendants LR, MR, UMG all benefited from Mr. Jones’ work product.
119. They failed to compensate Mr. Jones for his work.
120. As a result, Mr. Combs, and Defendants LR, MR, UMG were all unjustly enriched at the
expense of Mr. Jones.
121. Mr. Jones attempted to work with Mr. Combs to secure his publishing and royalty rights
for the work he completed on the Love album. Mr. Combs only offered Mr. Jones $29,000.00
for 13 months, thousands of hours of work, and 9 songs that made it to the Love album.
Ironically, Mr. Jones was willing to take $50,000.00, his publishing and royalties. Mr. Combs
self-serving greed would not allow him to pay13 Mr. Jones an additional $21,000.
12
Mr. Gooding Jr. has a storied history of sexually assaulting and forcibly touching individuals against their well.
https://www.usatoday.com/story/entertainment/celebrities/2023/11/22/cuba-gooding-jr-lawsuits-sexual-assault-
battery/71682417007/
13
This writer has retained other creatives, artists, and writers who have experienced this same treatment from Mr.
Combs and will file suit in the coming weeks.
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122. Mr. Combs deceptive business practices became so bad that Mr. Jones was left with no
choice other than to make a public plea on social media for Mr. Combs to pay him for his
work.
123. After publicly requesting that Mr. Combs do the right thing, and pay him fairly, Mr. Jones
received an onslaught of threating messages from Stevie J and Love Records A&R DeForrest
Taylor14.
DeForrest Taylor Threatening Mr. Jones
MR. COMBS USED HIS POWER, AND INFLUENCE TO

THREATEN AND INTIMIDATE MR. JONES
124. According to Mr. Jones, Mr. Combs is very forceful and demanding.
125. Mr. Combs does not take no for an answer and would often threaten to inflict bodily harm
on Mr. Jones if Mr. Jones did not comply with his demands.
126. As detailed above, Mr. Combs threatened to eat Mr. Jones' face.
14
As the A&R of Love Records, DeForrest Taylor did not require Mr. Jones or any of the other creatives, musicians,
or artists to sign an NDA.
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127. On another occasion, while standing in Mr. Combs' bedroom, Mr. Jones was forced to
watch as Mr. Combs displayed his guns and bragged about getting away with shooting people.
128. Mr. Combs shared that he was responsible for the shooting in the nightclub in New York
City with rapper Shyne.
129. He shared that artist, and Mr. Combs’ girlfriend at the time, Jennifer Lopez, aka, J-Lo
carried the gun into the club for him and passed him the gun after he got into an altercation
with another individual.
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130. The shooting in Chalice Recording Studios confirmed Mr. Combs' statements.
131. These statements reinforced Mr. Jones’s fear of Mr. Combs and strengthened Mr. Combs
dominion and control of Mr. Jones.
132. Mr. Jones was terrified of Mr. Combs. He felt like he could not tell him no.
133. Mr. Combs consistently made it clear that he has immense power in the music industry and
with law enforcement.
134. Mr. Combs made it clear that his head of security, Faheem Muhammad (“Mr. Muhammad”)
had the power to make people and problems disappear.
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Faheem Muhammad
135. Mr. Combs instructs his staff to always contact Mr. Muhammad if they are ever pulled over
by the police in Miami or California.
136. Upon information and belief, Mr. Muhammad spoke with the LAPD after G was shot at
CRS. The LAPD was in CRS and witnessed the blood in the restroom, and they went with
the bogus claim that the shooting of G occurred outside of the studio. This was all thanks to
Mr. Muhammad’s connections within law enforcement.
137. Mr. Jones had no reason to disbelieve Mr. Combs as he had seen firsthand through the
shooting of G and the subsequent silence of the LAPD and the media that Mr. Combs indeed
had the power to harm him.
138. The LAPD spent HOURS in CRS after the shooting of G, yet there were no arrests. Mr.
Jones witnessed the LAPD in the restroom pictured above, yet no arrests were made.
139. The morning after the shooting, Mr. Jones and several others arrived at CRS and G’s blood
was still on the floor of the restroom, and Mr. Combs hired a cleaning crew to clean it up.
DEFENDANTS ETHIOPIA HABTEMARIAM, LUCIAN CHARLES GRAINGE,

MOTOWN RECORDS, LOVE RECORDS, AND UNIVERSAL MUSIC GROUP
AIDED, ABETTED, AND PROFITED OFF OF
SEAN COMBS RICO ENTERPRISE
140. Mr. Jones recalls seeing Defendant Grainge15 visiting Mr. Combs home in Miami, Florida,
and Los Angeles, California.
15
TikTok is one of the most important short video platforms in the world. It has a significant impact on the spread of
global music. Today it is believed that artists are paying more and more attention to producing music suitable for
dissemination on TikTok. Due to failed contractual renewal negotiations between Universal and TikTok, a lot of music
27
141. According to Mr. Jones, whenever Defendant Grainge visited Mr. Combs at his homes, it
would be in the evening, and he and Mr. Combs would disappear for hours in Mr. Combs
bedroom.
142. Defendant Grainge sponsored and attended several Love Album listening parties at Mr.
Combs’ home in Los Angeles, California. These parties were sponsored by Defendants MR,
LR, and UMG. As evidence above, these parties had sex workers and underage girls present.
143. During these parties, Defendant Grainge knew or should have known that Mr. Combs was
drugging the attendees through laced bottles of DeLeon Tequila, and Ciroc Vodka.
144. It is no secret that Mr. Combs had specific bottles of alcohol designated for females, and
other bottles designated for his staff, his artists, and himself. This fact was detailed by former
artists and bodyguards of Mr. Combs.
145. As a sponsor of these events, Defendant Grainge had a duty and obligation to ensure that
sex workers and underaged girls were not present, and that Mr. Combs was not spiking the
alcohol with date rape drugs.
146. On YouTube Channel, the Art of Dialogue, former bodyguard Gene Deal exposed Mr.
Combs Pill Mixing method used to spike cranberry juice and orange juice. According to Mr.
Deal, Mr. Combs would place ecstasy and other date rape drugs in the juices16.
147. On YouTube, the Art of Dialogue, former artist Mark Curry exposed Mr. Combs spiking
bottles of Moet champagne in the VIP section of night clubs. Mr. Combs would have a set of
Moet champagne bottles for his artists, and a set for women17.
had to be removed from TikTok. This comes from the alleged lack of protection TikTok takes to ensure UMG artists’
rights and creativity is preserved as well as fair compensation. On the contrary it has been alleged that the renewal
failed due to UMG’s own financial agenda and putting their interest first before the artist. This move has costs artists
affected huge opportunities to further their growth and development within their art as well as huge financial loss.
However, UMG will still continue to profit off these artist whether their music will be released back to TikTok or not.
16
https://youtu.be/MFIP8b2IDeg?si=VVM397WmKXlnbHU-
17
https://youtu.be/pjvhfwUmMQw?si=6-5_W6evemGP_AI0
28
148. This writer has spoken with several former employees of Mr. Combs who witnessed
Defendant Khorram instruct her staff to lace Champagne, DeLeon, and Ciroc liquor bottles
with ecstasy and other elicit drugs.
149. Mr. Jones recalls seeing Defendant Habtemariam visiting Mr. Combs home in Miami,
Florida, and Los Angeles, California.
150. According to Mr. Jones, whenever Defendant Habtemariam visited Mr. Combs at his
homes, it would be in the evening, and she and Mr. Combs would disappear for hours in Mr.
Combs bedroom.
151. According to Mr. Jones, Defendant Habtemariam visited Mr. Combs at Defendant CRS
during Mr. Combs writing camp.
152. Defendant Habtemariam sponsored and attended several Love Album listening parties at
Mr. Combs’ home in Los Angeles, California. These parties were sponsored by Defendants
MR, LR, and UMG. As evidence above, these parties had sex workers and underage girls
present.
153. During these parties, Defendant Habtemariam knew or should have known that Mr. Combs
was drugging the attendees through laced bottles of DeLeon Tequila, and Ciroc Vodka.
154. As a sponsor of these events, Defendant Habtemariam had a duty and obligation to ensure
that sex workers and underaged girls were not present, and that Mr. Combs was not spiking
the alcohol with date rape drugs.
DEFENDANT KRISTINA KHORRAM IS THE GHISLAINE MAXWELL

TO SEAN COMBS JEFFREY EPSTEIN
155. According to Mr. Jones during the thirteen months he lived and traveled with Mr. Combs,
he witnessed Mr. Combs display and distribute guns from his bedroom closet in Miami,
Florida and Los Angeles, California to questionable individuals dressed in all black.
29
156. According to Mr. Jones during the thirteen months he lived and traveled with Mr. Combs,
he witnessed Defendant Khorram openly order her assistants to keep Mr. Combs “high” off
gummies and pills18.
157. Defendant Khorram required all employees from the butler, the chef to the housekeepers,
to walk around with a pouch or fanny pack filled with cocaine, GHB, ecstasy, marijuana
gummies (100 - 250 mg’s each), and Tuci (a pink drug that is a combination of ecstasy and
cocaine).
TUCI
158. It was important to Defendant Khorram to have Mr. Combs’ drug of choice immediately
ready when he asks for it.
159. Defendant Khorram ordered sex workers, and prostitutes for Mr. Combs.
160. Defendant Khorram ordered and distributed ecstasy, cocaine, GHB, ketamine, marijuana,
and mushrooms to Mr. Combs and his celebrity guests who were present on his rented yacht,
and in his homes in LA, NYC, and Miami.
161. On multiple occasions, Defendant Khorram forced Mr. Jones to carry Mr. Combs drug
pouch against his will.
162. As the Chief of Staff, Defendant Khorram was instrumental in organizing and executing
the RICO Enterprise. Defendant Khorram had the following individuals execute the
following tasks for the RICO enterprise:
a. Stevie J: Recruits sex workers and attends and participates in freak offs19.
b. Justin Combs: Solicits Prostitutes, Underaged Girls, and Sex Workers. Would
engage in Freak Offs.
c. Brendan Paul: Works as Mr. Combs Mule. He acquires, and distributes, Mr. Combs
Drugs, and Guns.
18
We have a recording of this and will provide it to the court.
19
We have a video of Mr. Combs, Stevie J, and Plaintiff Jones at a strip club. Mr. Combs is recording the video,
while coaching and training Plaintiff Jones how to recruit the sex workers.
30
Brendan Paul and Mr. Combs
d. Frankie Santella20: Works alongside Brendan. While Brendan acquires, and

distributes, Mr. Combs Drugs, and Guns. Frankie carries the money and pays for the
Guns and Drugs.
Frankie Santella and Sean Combs
e. Moy Baun: Hires sex workers, attends and participates in freak offs.
20
Vice President of Music Management & Strategic Partnerships Vice President of Music Management & Strategic
Partnerships, Combs Global.
31
Moy Baun, Thanksgiving 2022 When Mr. Combs Offered Mr. Jones Cocaine.
163. Mr. Combs funded and used his affiliation with local gangs and gang leaders21 who would
frequent his homes in LA, and Miami to secure the drugs and guns he obtained and distributed
out of his homes in LA and Miami.
164. Defendants executed their RICO Enterprise with threats of violence: threatening to eat
Plaintiff’s face, displaying and distributing guns in Plaintiff’s presence, bragging about having
law enforcement under control, bragging about murdering people, and bragging about bribing
witnesses, and jurors in the criminal case concerning the 1999 NYC nightclub shooting with
Shyne.
165. Defendants executed their RICO Enterprise with threats of isolation from the music and
entertainment industry: parading powerful music industry executives such as Defendants
Lucian Charles Grainge, Ethiopia Habtemariam at his parties filled with sex workers, minors,
and illegal drugs, such as ecstasy, cocaine, GHB, ketamine, marijuana, and mushrooms.
166. Defendants executed their RICO Enterprise with threats of nonpayment for work
completed, fake promises of cash payments ($250,000), producer of the year Grammy awards,
and guaranteed access to future projects, and a $20 million dollar home on Star Island in
Miami.
///
///
21
Plaintiff has intentionally left the names, and images of these individuals out of the pleading out of fear of retaliation.
32
MR. COMBS IS ALLOWED TO WREAK HAVOC

167. While living and traveling with Mr. Combs, Mr. Jones discovered that Mr. Combs has
hidden cameras in every room of his homes.
168. Mr. Jones believes that Mr. Combs has recordings of Defendants Lucian Charles Grainge,
Ethiopia Habtemariam, as well as other celebrities, music label executives, politicians, and
athletes.
169. Upon information and belief, these individuals were recorded without their knowledge and
consent, and as is the case with the homosexual sex tape of Stevie J that Mr. Combs provided
to Mr. Jones, Mr. Combs possesses compromising footage of every person that has attended
his freak off parties, and his house parties.
170. Upon information and belief, due to this treasure trove of evidence he has in his possession,
Mr. Combs believes that he is above the law and is untouchable.
171. Upon information and belief, Mr. Combs employs Jose Cruz as his IT director. This writer
has spoken to several former employees of Mr. Combs, who confirmed that Jose Cruz is the
gatekeeper to all of Mr. Coms recordings.
172. Upon information and belief, Jose Cruz intentionally hides behind the camera, and from
social media and the internet due to all of the incriminating acts he was required to record for
Mr. Combs.
///
33
FIRST CAUSE OF ACTION

CONDUCT AND PARTICIPATE IN A RICO ENTERPRISE
THROUGH A PATTERN OF RACKETEERING ACTIVITY
VIOLATION OF RACKETEER INFLUENCED AND
CORRUPT ORGANIZATION ACT, CODIFIED AT 18 U.S.C. § 1962(A), (C)-(D)
(against, Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Sean Combs, Justin
Combs, Kristina Khorram, Combs Global, Motown Records, Love Records, And
Universal Music Group)
173. Mr. Jones incorporates by reference all preceding paragraphs and re-alleges them as if set
forth fully herein.
174. As respondent superior, Defendants Lucian Charles Grainge, Ethiopia Habtemariam,
Combs Global, Motown Records, Love Records, and Universal Music Group (“the
respondent superior collective”) are 100% liable for the actions of Sean Combs, Justin Combs,
Kristina Khorram as they were acting in their capacities as the respondent superior collectives’
employees when they committed the acts detailed below. The respondent superior collective
failed to adequately monitor, warn, or supervise the actions of Sean Combs, Justin Combs and
Kristina Khorram.
175. Defendants are individuals and/or entities within the meaning of “person” as defined in 18
U.S.C. § 1961(3) because each is capable of holding, and does hold, “a legal or beneficial
interest in property.” The association is composed of Lucian Charles Grainge, Ethiopia
Habtemariam, Sean Combs, Justin Combs, Kristina Khorram, Combs Global, Motown
Records, Love Records, Universal Music Group, JOHN, and JANE DOES 1-10, and ABC
CORPORATIONS 1-10.
176. Section 1962(a) makes it:
unlawful for any person who has received any income derived, directly or indirectly, from
a pattern of racketeering activity or through a collection of an unlawful debt in which such
person has participated as a principal within the meaning of Section 2, Title18, United
States Code, to use or invest, directly or indirectly, any part of such income, or the proceeds
of such income, in the acquisition of any interest in, or the establishment or operation of,
any enterprise which is engaged in, or the activities of which affect interstate or foreign
commerce. 18 U.S.C. § 1962(a).
177. Section 1962(c) makes it:
unlawful for any person employed by or associated with any enterprise engaged in, or the
activities of which affect, interstate or foreign commerce, to conduct or participate, directly
or indirectly, in the conduct of such enterprise’s affairs through a pattern of racketeering
activity. 18 U.S.C. §1962(c).
34
178. Section 1962(d) makes it unlawful for “any person to conspire to violate” Section 1962(a)
and (c), among other provisions. 18 U.S.C. § 1962(d).
179. Defendants are associated with each other as an enterprise within the meaning of
“enterprise” as defined in 18 U.S.C. § 1961(4).
180. Defendants have unlawfully increased their profits by luring, and deceiving producers,
musicians, writers, creators, and artists such as Plaintiff to transport drugs (ecstasy, cocaine,
GHB, ketamine, marijuana, and mushrooms), transport firearms, solicit minors, exotic
dancers, sex workers, and to utilize their talents and labor to produce music, and other tangible
goods and services without compensation.
181. The RICO enterprise, which all Defendants have engaged in, and the activities of which
affected interstate and foreign commerce, is comprised of an association, in fact, of persons,
including each Defendant and other unnamed co-conspirators. That association, in fact, was
structured by various contracts and non-contractual relationships between the Defendants, by
which Defendants assumed different roles in agreeing to carry out a mail and wire fraud
scheme to acquire drugs, firearms, prostitutes, minors, sex workers and the labor of producers,
musicians, writers, creators, and artists such as Plaintiff to utilize their talents and labor to
produce music, and other tangible goods and services without compensation.
182. The members of the RICO enterprise all share a common purpose: to enrich themselves
financially and sexually at the expense of producers, musicians, writers, creators, and artists
by maximizing Defendants’ revenues through fraudulent means. As set forth herein,
Defendants benefitted financially from their scheme to defraud Plaintiff, by intimidating
Plaintiff with threats of violence (threatening to eat Plaintiff’s face, displaying and distributing
guns in Plaintiff’s presence, bragging about having law enforcement under control, bragging
about murdering people, and bragging about bribing witnesses, and jurors in the criminal case
concerning the 1999 NYC nightclub shooting with Shyne), threats of isolation from the music
and entertainment industry (parading powerful music industry executives such as Defendants
Lucian Charles Grainge, Ethiopia Habtemariam at his parties filled with sex workers, minors,
and illegal drugs, such as ecstasy, cocaine, GHB, ketamine, marijuana, and mushrooms),
threats of nonpayment for work completed, fake promises of cash payments ($250,000),
producer of the year Grammy awards, and guaranteed access to future projects, a $20 million
35
dollar home on Star Island in Miami, which Defendants would not have done but for the
existence of the scheme.
183. The members of the RICO enterprise all share a common purpose: to enrich themselves
financially and sexually at the expense of producers, musicians, writers, creators, and artists
by maximizing Defendants’ revenues through fraudulent means. As set forth herein,
Defendants benefitted financially from their scheme to defraud Plaintiff, including by making
false representations that claim that loyalty and obedience to Mr. Combs will result in cash
payments ($250,000), Grammy awards, access to future projects, access to famous celebrities,
access to famous athletes, a $20 million home on Star Island in Miami. Promises that Plaintiff
can increase his chances of securing cash payments ($250,000), Grammy awards, access to
future projects, access to famous celebrities, access to famous athletes, a $20 million home
on Star Island in Miami by soliciting sex workers, by soliciting prostitutes, by engaging is
homosexual acts, by distributing and transporting firearms, by distributing and transporting
drugs (ecstasy, cocaine, GHB, ketamine, marijuana, and mushrooms), by involuntarily
sleeping with sex workers in the presence of Mr. Combs, and by utilizing their talents and
labor to produce music, and other tangible goods and services without compensation, which
Defendants would not have done but for the existence of the scheme.
184. Upon information and belief, this RICO enterprise has existed for at least 20 years, dating
back to the 1999 Nightclub shooting in NYC, when Mr. Combs required his then-girlfriend,
Jennifer Lopez, to transport his illegal firearm into the NYC nightclub. Mr. Combs forced his
then-artist, Shyne, to assume responsibility for the shooting of several individuals. Mr. Combs
used his power, money, and influence to bribe jurors and witnesses, such as the friend of the
shooting victim, Natania Reuben, who reported to law enforcement that she saw Mr. Combs
and not Shyne pull the trigger and shoot her friend in the face. Natania Reuben later testified
at Mr. Combs’ criminal trial that she was tying her shoe and may not have seen who shot the
gun. She later confessed that Mr. Combs paid her.
185. The RICO enterprise continued throughout the years, including during Mr. Combs's ten-
year relationship with his girlfriend, Cassie Ventura. According to Ms. Ventura’s civil
complaint, this RICO enterprise continued in her relationship when Mr. Combs forced her to
carry his gun in her purse, forced her to engage in unwanted sexual acts with male
prostitutes/sex workers, forced her to consume dangerous amounts of ecstasy, cocaine, GHB,
36
ketamine, marijuana and alcohol, and paying a member of his security team $5,000, to blow
up the vehicle of Kid Cudi because he was jealous and insecure of their relationship.
186. The RICO enterprise continued from September 2022 to the present day. As evidenced by
the hundreds of hours of video and audio recordings in Plaintiff’s possession, Defendants
Sean Combs, Justin Combs, Kristina Khorram, his assistants and staff all orchestrated,
participated, managed and executed the RICO Enterprise by purchasing and distributing
ecstasy, cocaine, GHB, ketamine, marijuana, and mushrooms, by purchase and distributing
firearms, by requiring the solicitation of sexual encounters with prostitutes, sex workers, and
minors, and by forcing artists, creatives, musicians, and producers to utilize their talents and
labor to produce music, and other tangible goods and services without compensation. The
RICO enterprise has functioned as a continuing unit and maintains an ascertainable structure
separate and distinct from the pattern of racketeering activity.
187. The enterprise was characterized by the Defendants' pattern of false representations and
omissions made by Defendants Sean Combs, Justin Combs, Kristina Khorram, and other
current and former members of the Defendants' associates and staff to Defendants' artists,
creatives, musicians, and producers. These false representations and omissions were designed
to induce Defendants' artists, creatives, musicians, and producers to utilize their talents and
labor to produce music and other tangible goods and services without compensation, as well
as the solicitation of sexual encounters with prostitutes, sex workers, and minors, and the
purchasing and distribution of illegal firearms and drugs.
188. As part of this scheme, Defendants required their artists, creatives, musicians, and
producers to visit strip clubs wearing exclusive authentic Bad Boy merchandise and to use the
name and reputation of Mr. Combs to solicit sex workers and prostitutes. Additionally, Mr.
Combs used the prospects of winning Grammy awards, purchasing $20 million dollar homes,
participating in future projects, making $250,000 cash payments, and meeting influential
music industry executives such as Defendants Lucian Charles Grainge and Ethiopia
Habtemariam. This pattern of false representations was disseminated to artists, creatives,
musicians, and producers who reside in California, Florida, New York, and around the country
by Defendants based in California and New York under the direction and on behalf of
Defendants in New York. The dissemination typically used interstate telephone wires, social
media messages, and electronic mail.
37
189. The true nature of Defendants’ scheme was left undisclosed, was omitted, and/or was
affirmatively misrepresented, all to fraudulently increase Defendants’ profits, at least some of
which were used to expand the enterprise, causing further injury to Plaintiff Jones and other
unwitting artists, creatives, musicians, and producers.
190. Defendants profited from the enterprise, and Plaintiff Jones suffered because the enterprise
diminished Plaintiff Jones finances due to 13 months of nonpayment and diminished Plaintiff
Jones health through consistent drugging and forced sexual encounters with prostitutes and
sex workers. Defendants used the proceeds from this scheme to advance the scheme by
funding and operating their marketing machine, including through the use of the mail, social
media, word of mouth, and interstate wires to sell the illusion that Mr. Combs was serious
about the talents and skills of the artists, creatives, musicians, and producers, and wanted to
use those skills to make music when nothing could be further from the truth. Defendants
provided their artists, creatives, musicians, and producers with this misrepresentative
information, including via email all over interstate wireline communications systems and
obtaining free labor, the distribution of drugs and firearms, as well as prostitutes, sex workers,
and minors. Defendants obtained revenue via wire transfers, documents, and banking
transactions that were exchanged via electronic means over interstate wires, thereby growing
the enterprise and causing further injury to Plaintiff Jones as described throughout.
191. The Defendants’ scheme was reasonably calculated to deceive Plaintiff Jones, artists,
creatives, musicians, and producers of ordinary prudence and comprehension through the
execution of their complex and illegal scheme to misrepresent the effectiveness of soliciting
prostitutes, sex workers, and minors and distributing drugs and guns that did not, would not,
and could not lead to securing Grammy Awards, purchasing $20 million homes, participating
on future projects, $250,000 cash payments, and meeting influential music industry
executives such as Defendants Lucian Charles Grainge, and Ethiopia Habtemariam. Plaintiff
Jones would not have lived with Mr. Combs for 13 months, missing birthdays, holidays, and
family events, but for the illegal racketeering scheme operated by Defendants.
192. Defendants each had the specific intent to participate in the overall RICO enterprise and
the scheme to defraud Plaintiff Jones and each participated in the enterprise as follows:
193. Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Combs Global, Motown
Records, Love Records, and Universal Music Group control and participate in the activities
38
of the enterprise in a variety of ways as set forth herein, including but not limited to developing
and marketing scores of writing camps, and listening parties services that are marketed to
innocent, unassuming artists, creatives, musicians, and producers who are vulnerable and in
seek of opportunities to work and share their craft.
194. Throughout the relevant period, Defendants Lucian Charles Grainge, Ethiopia
Habtemariam, Combs Global, Motown Records, Love Records, and Universal Music Group
oversaw the activities of Defendants Sean Combs, Justin Combs, Kristina Khorram and other
current and former members of the Defendants’ associates and staff (collectively, “Individual
Defendants”). Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Combs Global,
Motown Records, Love Records, and Universal Music Group has an ethical obligation as
respondent superior to supervise the actions and activities of the individual defendants.
Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Combs Global, Motown
Records, Love Records, and Universal Music Group failed miserably to do so. Individual
defendants relied on the mail, email, social media, and the telephone to distribute
advertisements to secure artists, creatives, musicians, and producers whom they would
promise Grammy Awards, purchasing $20 million dollar homes, participating on future
projects, $250,000 cash payments, and meeting powerful music industry executives such as
Defendants Lucian Charles Grainge, Ethiopia Habtemariam. These advertisements originated
from and were sent from Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Combs
Global, Motown Records, Love Records, and Universal Music Group’s offices in the state of
New York to consumers in New York and around the country, relying on the mail, email. social
media messenger, and telephone to distribute and interstate wires to disseminate the
misleading information described herein as well as to receive profits from the artists,
creatives, musicians, and producers.
195. In connection with Defendants acting from New York, these Defendants used the mail and
interstate wires to solicit Plaintiff Jones and artists, creatives, musicians, and producers, and
to use Plaintiff Jones and the artists, creatives, musicians, and producers to utilize their talents
and labor to produce music, and other tangible goods and services without compensation, as
well as the solicitation of sexual encounters with prostitutes, sex workers, and minors, and the
purchasing and distribution of illegal firearms and drugs. Each of these acts was undertaken
39
with the knowledge and approval of all other Defendants in furtherance of the goals of their
conspiracy.
196. Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Combs Global, Motown
Records, Love Records, and Universal Music Group, directs, controls, and participates in the
activities of the enterprise in a variety of ways as set forth herein, including as the employer,
parent company, sponsor and respondent superior of Defendants Sean Combs, Justin Combs,
Kristina Khorram and other current and former members of the Defendants’ associates and
staff. Throughout the relevant period, Defendants Lucian Charles Grainge, Ethiopia
Habtemariam, Combs Global, Motown Records, Love Records, and Universal Music Group,
oversaw the marketing and soliciting of potential artists, creatives, musicians, and producers
from their Headquarters in New York, California and Florida to consumers in New York,
California and Florida, and around the country, relying on the mail, email, social media, text
messages, and WhatsApp messages to distribute, interstate wires to disseminate the
misleading information described herein as well as to receive profits from the artists,
creatives, musicians, and producers from their forced solicitation of sex workers, and the
solicitation of sexual encounters with prostitutes, sex workers, and minors, and the purchasing
and distribution of illegal firearms and drugs. Each of these acts was undertaken with the
knowledge and approval of all other Defendants in furtherance of the goals of their conspiracy.
197. Robin Greenhill, the accountant, would ensure the wiring, funds transfer, or cash payments
to sex workers. Frankie Santella, Moy Baun, Brendan Paul, and KK would also be responsible
for ensuring payment to sex workers in cash. Yung Miami, Jade, and Daphne Joy were paid a
monthly fee to work as Mr. Combs’ sex workers and received payment via wire transfer from
Robin Greenhill which outlined Defendants ongoing criminal operation.
198. During the ten (10) years preceding the filing of this action and to the present, all
Defendants did cooperate jointly and severally in the commission of three (3) or more of the
predicate acts that are itemized at 18 U.S.C. §§ 1961(1)(A) and (B), in violation of 18 U.S.C.
1962(d), as described in this Complaint.
199. Beginning at an exact date unknown to Plaintiff, but within ten (10) years preceding the
filing of this action, Defendants have knowingly, willfully, and unlawfully participated in a
pattern of racketeering activity that continues to this day.
40
200. The acts set below (“Racketeering Acts”) had the same pattern and purpose to defraud
Plaintiff for the benefit of Defendants. Each Racketeering Act involved the same or similar
methods of commission and participants.
201. Without the repeated predicate acts, the ability to conduct their fraud using the mail and
telecommunications wires, and the money laundering, the Defendants’ business would not
have succeeded.
202. The separate Racketeering Acts all relate to each other in that they were part of concerted
actions by Defendants to use the endorsement and channels of the enterprise to operate their
businesses to fraudulently induce Plaintiff Jones and the artists, creatives, musicians, and
producers to utilize their talents and labor to produce music, and other tangible goods and
services without compensation, as well as the solicitation of and sexual encounters with
prostitutes, sex workers, and minors, and the purchasing and distribution of illegal firearms
and drugs.
203. The separate Racketeering Acts all relate to each other in that they were part of concerted
actions by Defendants to use the endorsement and channels of the enterprise to operate their
businesses to fraudulently induce Plaintiff Jones and the artists, creatives, musicians, and
producers to utilize their talents and labor to produce music, and other tangible goods and
services without compensation, as well as the solicitation of and sexual encounters with
prostitutes, sex workers, and minors, and the purchasing and distribution of illegal firearms
and drugs.
204. The Defendants’ wrongful conduct has caused injury to Plaintiff Jones, remains a part of
their ongoing business practices, and remains a continuing threat to Plaintiff Jones and the
public.
205. Defendants’ association with the enterprise enabled Defendants to conduct, direct, and
control a pattern of fraudulent, illegal activities over a substantial number of years, which
continues to this day.
206. To further their goals, Defendants, working in concert, engaged in various forms of
criminal activity, including the solicitation of and sexual encounters with prostitutes, sex
workers, and minors, and the purchasing and distribution of illegal firearms and drugs.
207. Defendants’ ongoing pattern of racketeering activity has injured and continues to injure
Plaintiff Jones. The Defendants’ pattern of forcing Plaintiff Jones and the artists, creatives,
41
musicians, and producers to solicit sexual encounters with prostitutes, sex workers, and
minors, and to purchase and distribute illegal firearms and drugs was the proximate cause of
the injuries suffered by Plaintiff.
Defendants Committed Multiple Acts of Mail Fraud in Violation of 18 U.S.C. § 1341 in
Furtherance of the Enterprise
208. Defendants voluntarily and intentionally devised and participated in a scheme to defraud
Plaintiffs out of money, in reliance on the mail. Defendants committed these acts with the
intent to defraud Plaintiff Jones and the artists, creatives, musicians, and producers.
209. Defendants used the mail for the purpose of executing the fraudulent scheme herein.
210. Specifically, Defendants agreed to each of the acts of mail fraud described throughout this
Complaint. In addition, Defendants agreed to rely on the mail to secure wire frauds, cash
payments from purchasers of the illegal firearms and drugs Defendants required others to sell
and distribute.
211. In furtherance of and for purposes of executing the above-described fraudulent and illegal
course of conduct and scheme to defraud, Defendants, either individually or in combination
with themselves, used and caused to be used the U.S. mail by both placing and causing to be
placed cash, letters, marketing materials, advertisements, agreements and other matters in
depositories and by removing or causing to be removed letters and other mailable matters
from depositories, in violation of the mail fraud statute, 18 U.S.C. § 1341.
212. Defendants could not have furthered their fraud without the use of the mail. For example,
Defendants sought to acquire wire transfers, cash payments, and to utilize their talents and
labor to produce music, and other tangible goods and services without compensation.
Defendants also required the mail to distribute misleading advertisements to various states,
including New York. For these reasons, the use of mail to conduct fraudulent activity was
necessary and inevitable.
Defendants Committed Multiple Acts of Wire Fraud in Violation of 18 U.S.C. § 1343 in
Furtherance of the Enterprise
213. Defendants voluntarily and intentionally devised and participated in a scheme to defraud
Plaintiff out of money, in reliance on the mail. Defendants committed these acts with the
intent to defraud Plaintiff Jones and the artists, creatives, musicians, and producers.
214. Specifically, Defendants agreed to each of the acts of wire fraud described throughout this
Complaint. In addition, Defendants agreed to rely on interstate wires to disseminate funds and
42
to submit payment to sex workers and prostitutes, as well as to transfer payment for the
distribution and procurement of drugs and guns. Defendants illegally acquired wire transfers,
money transfers, credit cards, and bank cards via search engines and other online platforms
to further their collective goal of furthering their RICO enterprise. Defendants knew that these
online purchases were illegally made.
215. Additionally, Defendants agreed that Defendants should facilitate these fraudulent
purchases over interstate wires in furtherance of the fraud. Sex workers, and prostitutes
nationwide have received payment from Defendants.
216. In furtherance of and for purposes of executing the above-described fraudulent and illegal
course of conduct and scheme or artifice to defraud, Defendants, either individually or in
combination with themselves, used or caused to be used interstate wire communications to
transmit or disseminate false, fraudulent, and misleading communications and information, in
violation of the wire fraud statute, 18 U.S.C. § 1343.
217. Defendants could not have furthered their fraud without the ability to use
telecommunications to share information with clients and retailers nationwide. Because
Defendants needed to communicate with clients and retailers around the country, the use of
interstate telecommunications wires to conduct the fraudulent activity was necessary and
inevitable.
218. Plaintiffs have been damaged in their business or property because Defendants violated 18
U.S.C. § 1962(a), (c)-(d)), and, therefore, he is entitled to recover the damages and other
remedies enumerated therein.
219. Defendants’ acts or omissions were actuated by actual malice and/or a willful and wanton
disregard for the consequences suffered by the Plaintiff and/or with knowledge of a high
degree of probability of harm to the Plaintiff and reckless indifference to the consequences of
their acts or omissions.
220. Compensatory damages alone will be insufficient to deter such conduct in the future. There
needs to be a criminal referral to the United States Justice Department, as well as to the States
Attorney General’s Office.
WHEREFORE, Plaintiff requests that the Court issue an Order and grant Judgment to the
Plaintiffs as follows:
43
a. Granting Plaintiff statutory, common law, and punitive damages, and applicable pre-
and post-judgment interest, in full recompense for damages;22
b. Entering judgment according to the declaratory relief sought;
c. Granting Plaintiff such other and further relief, including, without limitation,
injunctive and equitable relief, as the Court deems just in all the circumstances; and
d. Granting Plaintiff an Incentive or Service Award reflective of the work done in
prosecuting this action, the time spent, the effort and hard costs invested, and results
obtained, in light of the Court's judgment informed by awards in other similar cases
of comparable difficulty and complexity.
SECOND CAUSE OF ACTION

SEXUAL ASSAULT AND SEXUAL HARASSMENT
(against Mr. Combs)
forth fully herein.
222. As described above, Mr. Combs frightened and placed Plaintiff in apprehension of harm
when he physically and sexually assaulted him from October 2022 to October 2023 in Mr.
Combs home in Miami, New York, United States Virgin Islands, and Los Angeles.
223. Mr. Combs forcibly touched and attempted and/or threatened to touch Plaintiff’s intimate
areas and/or touched Plaintiff with his own intimate body parts.
224. Mr. Combs violently gripped and palmed Mr. Jones anus and crotch without consent. Mr.
Combs forced Mr. Jones to work in Mr. Combs’ bathroom and watch Mr. Combs as he
showered. Mr. Combs forced Mr. Jones to work in the studio while Mr. Combs stripped naked
to get his body massaged. Mr. Combs forced Mr. Jones to work while Mr. Combs walked
around naked.
225. As a result of Mr. Combs’ conduct, Plaintiff has suffered and continues to suffer harm,
including physical injury, severe emotional distress, humiliation, anxiety, and other
consequential damages for which he is entitled to an award of monetary damages and other
relief.
226. The conduct of Mr. Combs described above was willful, wanton, and malicious. At all
relevant times, Mr. Combs acted with conscious disregard for Plaintiff's rights and feelings,
acted with the knowledge of or with reckless disregard for the fact that his conduct was certain
to cause injury and/or humiliation to Plaintiff, and intended to cause fear, physical injury
22
Damages shall include, but not be limited to, all damages permitted under the New Jersey Racketeer Influenced and
Corrupt Organizations Act.
44
and/or pain and suffering to Plaintiff. By virtue of the foregoing, Plaintiff is entitled to recover
punitive damages.
THIRD CAUSE OF ACTION
CALIFORNIA’S BYSTANDER NEGLIGENT INFLICTION OF
EMOTIONAL DISTRESS
(against, Mr. Combs and Defendant Justin Combs)
forth fully herein.
228. Mr. Jones brings this claim against Mr. Combs and J. Combs for the CRS shooting of G.
229. The elements of Bystander NIED are: 1) is closely related to the injury victim; (2) is present
at the scene of the injury-producing event at the time it occurs and is then aware that it is
causing injury to the victim; and (3) as a result suffers serious emotional distress—a reaction
beyond that which would be anticipated in a disinterested witness and which is not an
abnormal response to the circumstances.” Ra v. Superior Court, 154 Cal. App. 4th 142, 148,
64 Cal. Rptr. 3d 539, 542 (2007).
230. As detailed above, Mr. Jones was 2 feet away from G, as either J. Combs or Mr. Combs
shot him multiple times in the restroom of CRS. As detailed above, Mr. Jones was the only
individual that aided G as he laid on the bathroom floor in a fetal position bleeding out. As
detailed above, Mr. Combs and J. Combs orchestrated a coverup, and through Faheem
Muhammad, lied to the LAPD and forced Mr. Jones and all of the other attendees of the
writers camp to lie to the police as well. Mr. Combs and J. Combs knew that they shot G in
the restroom, and that G was shot as he was leaving the studio.
231. Mr. Combs and J. Combs’ intentional deception caused a delay in G receiving immediate
medical care, as the ambulance parked 3 blocks away from CRS out of fear that there was an
active shooting. Mr. Jones had to run down the block and convince them that the shooting
had ended.
232. These events traumatized Mr. Jones. It caused Mr. Jones to suffer from insomnia, PTSD,
severe anxiety, and depression. Additionally, the fear and silence from the remaining
witnesses aided in the reinforcement of Mr. Combs statements that he is untouchable.
233. As a result of Mr. Combs and J. Combs conduct, Plaintiff Jones has suffered and continues
to suffer harm, including severe emotional distress, anxiety, and other consequential damages
for which he is entitled to an award of monetary damages and other relief.
45
234. The conduct of Mr. Combs and J. Combs described above was willful, wanton, and
malicious. At all relevant times, Mr. Combs and J. Combs acted with conscious disregard for
Plaintiff's rights and feelings, acted with the knowledge of or with reckless disregard for the
fact that their conduct was certain to cause injury to Plaintiff, and intended to cause fear,
physical injury and/or pain and suffering to Plaintiff. By virtue of the foregoing, Plaintiff is
entitled to recover punitive damages.
FOURTH CAUSE OF ACTION

SEXUAL ASSAULT
(against Jane Doe 1 (Yung Miami’s Cousin))
forth fully herein.
236. As described above, Jane Doe 1 frightened and placed Plaintiff in apprehension of harm
when she physically and sexually assaulted him on Thanksgiving Day 2022, in Mr. Combs
home in Miami Florida.
237. Jane Doe 1 forcibly touched and attempted and/or threatened to touch Plaintiff’s intimate
areas and/or touched Plaintiff with her own intimate body parts. Jane Doe 1 used her mouth
and performed oral sex on Plaintiff while he was urinating in the restroom. Plaintiff fought
her off, while Mr. Combs and his associates sat outside loudly laughing. Jane Doe 1 then
followed Mr. Jones outside of the restroom and began undressing in front of Mr. Combs and
his associates, straddled Mr. Jones and attempted to have forced sexual intercourse with him.
238. As a result of Jane Doe 1’s conduct, Plaintiff has suffered and continues to suffer harm,
including physical injury, severe emotional distress, humiliation, anxiety, and other
consequential damages for which he is entitled to an award of monetary damages and other
relief.
239. The conduct of Jane Doe 1 described above was willful, wanton, and malicious. At all
relevant times, Jane Doe 1 acted with conscious disregard for Plaintiff's rights and feelings,
acted with the knowledge of or with reckless disregard for the fact that her conduct was certain
to cause injury and/or humiliation to Plaintiff, and intended to cause fear, physical injury
and/or pain and suffering to Plaintiff. By virtue of the foregoing, Plaintiff is entitled to recover
punitive damages.
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FIFTH CAUSE OF ACTION

PREMISES LIABILITY FOR THE SEXUAL ASSAULT COMMITTED BY
JANE DOE 1 (YUNG MIAMI’S COUSIN)
(against Mr. Combs)
forth fully herein.
241. Mr. Jones was sexually assaulted by Jane Doe 1 in Miami, Florida on Thanksgiving 2022.
Mr. Combs was present while Mr. Jones was being assaulted by Jane Doe 1. Mr. Jones was
legally on the premises as a guest and invitee of Mr. Combs. Jane Doe 1 was legally on the
premises as a guest and invitee of Mr. Combs. Mr. Combs owned the premises and had
dominion and control over the premises where Mr. Jones was harmed. Mr. Combs had
dominion and control over the actions of Jane Doe 1 and failed to step in and stop Jane Doe
1 from sexually assaulting Mr. Jones.
242. As the owner of the property, Mr. Combs had a duty to protect Mr. Jones from the harm he
suffered at the hands of Jane Doe 1. Mr. Combs breached his duty when he failed to stop Jane
Doe 1 from sexually assaulting Mr. Jones. In furtherance of this breach, Mr. Combs was
laughing and encouraging Jane Doe 1 to continue her assault of Mr. Jones. Mr. Jones has
suffered immensely because of Mr. Combs intentional breach of his duty to him.
243. As a result of Mr. Combs breach of his duty, Mr. Jones has suffered and continues to suffer
harm, including severe emotional distress, anxiety, and other consequential damages for
which he is entitled to an award of monetary damages and other relief.
acted with the knowledge of or with reckless disregard for the fact that their conduct was
certain to cause injury to Plaintiff, and intended to cause fear, physical injury and/or pain and
suffering to Plaintiff. By virtue of the foregoing, Plaintiff is entitled to recover punitive
damages.
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SIXTH CAUSE OF ACTION

PREMISES LIABILITY FOR THE SEXUAL ASSAULT COMMITTED
BY CUBA GOODING, JR.
(against, Mr. Combs)
forth fully herein.
246. Here, Mr. Jones was sexually assaulted by Cuba Gooding Jr. on a yacht rented by Mr.
Combs in the US Virgin Islands in January 2023. Mr. Combs was present while Mr. Jones
was being assaulted by Cuba Gooding Jr. Mr. Jones was legally on the premises as a guest
and invitee of Mr. Combs. Cuba Gooding Jr was legally on the premises as a guest and invitee
of Mr. Combs. Mr. Combs owned (through renting) the premises and had dominion and
control over the premises where Mr. Jones was harmed. Mr. Combs had dominion and control
over the actions of Cuba Gooding Jr and failed to step in and stop Cuba Gooding Jr from
sexually assaulting Mr. Jones.
247. As the owner of the property, Mr. Combs had a duty to protect Mr. Jones from the harm he
suffered at the hands of Cuba Gooding Jr. Mr. Combs breached his duty when he failed to
stop Cuba Gooding Jr from sexually assaulting Mr. Jones. In furtherance of this breach, Mr.
Combs encouraged Cuba Gooding Jr to continue his assault of Mr. Jones when he said that
Cuba Gooding Jr should privately get to know Mr. Jones better. Mr. Jones has suffered
immensely because of Mr. Combs intentional breach of his duty to him.
248. As a result of Mr. Combs breach of his duty, Mr. Jones has suffered and continues to suffer
harm, including severe emotional distress, anxiety, and other consequential damages for
which he is entitled to an award of monetary damages and other relief.
acted with the knowledge of or with reckless disregard for the fact that their conduct was
certain to cause injury to Plaintiff, and intended to cause fear, physical injury and/or pain and
suffering to Plaintiff. By virtue of the foregoing, Plaintiff is entitled to recover punitive
damages.
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SEVENTH CAUSE OF ACTION

TRAFFICKING AND VICTIMS’ PROTECTION ACT
(against, Defendants Sean Combs, Justin Combs, Kristina Khorram, And
Combs Global)
forth fully herein.
251. Defendants Sean Combs, Justin Combs, Kristina Khorram, and Combs Global knowingly
and intentionally participated in, perpetrated, assisted, supported, facilitated a sex-trafficking
venture that was in and affecting interstate and foreign commerce, together and with others,
in violation of 18 U.S.C. § 1591(a)(1).
252. Among other things, Defendants Sean Combs, Justin Combs, Kristina Khorram, and
Combs Global knowingly and intentionally recruited, enticed, provided, obtained, advertised,
and solicited by various means Mr. Jones, as well as other Class Members, knowing that
Defendants Sean Combs, Justin Combs, Kristina Khorram, and Combs Global would use
means of force, threats of force, fraud, coercion, and a combination of such means to cause
Mr. Jones, as well as others, some of whom were under the age of seventeen, to engage in
commercial sex acts.
253. Defendants Sean Combs, Justin Combs, Kristina Khorram, and Combs Global and its
employees had actual knowledge that they were perpetrating and facilitating Mr. Combs’
sexual abuse and sex trafficking conspiracy to recruit, solicit, entice, coerce, harbor, transport,
obtain, and provide Mr. Jones as well as others whom were under the age of seventeen, into
commercial sex acts, through the means of force, threats of force, fraud, abuse of process, and
coercion.
254. Despite such knowledge, Defendants Sean Combs, Justin Combs, Kristina Khorram, and
Combs Global intentionally paid for, facilitated, perpetrated, and participated in Mr. Combs’
violations of 18 U.S.C. § 1591(a)(1), which Defendants Sean Combs, Justin Combs, Kristina
Khorram, and Combs Global knew, and were in reckless disregard of the fact that, Mr. Combs
would coerce, defraud, and force Mr. Jones to engage in commercial sex acts.
255. Defendants Sean Combs, Justin Combs, Kristina Khorram, and Combs Global’s actions
were in and affecting interstate and foreign commerce, including its music distributing and
publishing activities which were in and affecting interstate and foreign commerce.
49
256. By taking the concrete steps alleged in this complaint, Defendants Sean Combs, Justin
Combs, Kristina Khorram, and Combs Global knowingly participated in sex trafficking and
furthered the Combs’ sex-trafficking venture. The concrete steps constituted taking part in the
sex-trafficking venture and were necessary for its success. The concrete steps constituted
active engagement by Defendants Sean Combs, Justin Combs, Kristina Khorram, and Combs
Global in Mr. Combs’s sex-trafficking venture. Defendants Sean Combs, Justin Combs,
Kristina Khorram, and Combs Global knew that its active engagement would lead to and
cause coercive commercial sex-trafficking.
257. As part of perpetrating TVPA violations, between on or about September 12, 2022, and
through about November 2023, Defendants Sean Combs, Justin Combs, Kristina Khorram,
and Combs Global concealed its delivery of hundreds of thousands of dollars in cash to Mr.
Combs and his associates.
258. As part of perpetrating TVPA violations, Defendants Sean Combs, Justin Combs, Kristina
Khorram, and Combs Global also willfully failed to file required taxes with the federal
government.
259. Defendants Sean Combs, Justin Combs, Kristina Khorram, and Combs Global’s
affirmative conduct was committed knowing, and in reckless disregard of the facts, that Mr.
Combs would use cash and the financial support provided by Defendants Love Records,
Motown Records, and the Universal Music Group as a means of defrauding, forcing, and
coercing sex acts from Plaintiff Jones as well as others. Defendants Sean Combs, Justin
Combs, Kristina Khorram, and Combs Global’s conduct was outrageous and intentional. On
or about January 2023 Justin Combs engaged in a freak off session on a yacht with his father
and sex workers.
260. Defendants Sean Combs, Justin Combs, Kristina Khorram, and Combs Global’s knowing
and intentional conduct has caused Mr. Jones serious harm including, without limitation,
physical, psychological, emotional, financial, and reputational harm.
261. Defendants Sean Combs, Justin Combs, Kristina Khorram, and Combs Global’s knowing
and intentional conduct has caused Mr. Jones harm that is sufficiently serious, under all the
surrounding circumstances, to compel a reasonable person of the same background and in the
same circumstances to perform or to continue performing commercial sexual activity, in order
to avoid incurring that harm.
50
262. This case does not involve mere fraud. Instead, Defendants Sean Combs, Justin Combs,
Kristina Khorram, and Combs Global’s criminal conduct in perpetrating TVPA violations
was outrageous and intentional, because it was in deliberate furtherance of a widespread and
dangerous criminal sex trafficking organization. Defendants Sean Combs, Justin Combs,
Kristina Khorram, and Combs Global’s criminal conduct also evinced a high degree of moral
turpitude and demonstrated such wanton dishonesty as to imply a criminal indifference to
civil obligations. Defendants Sean Combs, Justin Combs, Kristina Khorram, and Combs
Global’s criminal conduct was directed specifically at Mr. Jones who was the victim of Mr.
Combs’ sexual abuse and sex trafficking harassment.
263. Defendants Sean Combs, Justin Combs, Kristina Khorram, and Combs Global’s
outrageous and intentional conduct in this case is part of a pattern and practice of Defendants
Sean Combs, Justin Combs, Kristina Khorram, and Combs Global profiting by undertaking
illegal “high risk, high reward” actions.
264. By virtue of these knowing and intentional violations of 18 U.S.C. §§ 1591(a)(1), 1595,
Defendants Sean Combs, Justin Combs, Kristina Khorram, and Combs Global is liable to Mr.
Jones for the damages they sustained and reasonable attorneys’ fees.
265. By virtue of these intentional and outrageous violations of 18 U.S.C. § 1591(a)(1), 1595,
Defendants Sean Combs, Justin Combs, Kristina Khorram is liable to Mr. Jones.
EIGHT CAUSE OF ACTION

CALIFORNIA PREMISE LIABILITY - INADEQUATE OR NEGLIGENT SECURITY
(against, Defendants LR, MR, UMG, CRS, and Sean Combs)
forth fully herein.
267. At all times herein mentioned, Defendants LR, MR, UMG, CRS, AND SEAN COMBS,
acting in the course and scope of their agency, employment, and representation of each other
and with the knowledge, consent, direction, approval, and ratification of each other's act,
omissions and conduct, on or about September 12, 2022 at the Chalice Recording Studios
located at 845 Highland Ave, Los Angeles, CA 90038, did so negligently, carelessly and
without due care, regard and concern for the rights, safety and health of the Plaintiff, and in
regard to such premises did so control, own, supervise, manage, lease and had responsibility
51
for the safety of Plaintiff and adequate security, security personnel and security devices of the
CRS.
268. At the aforementioned time and place, Defendants LR, MR, UMG, CRS, AND SEAN
COMBS, and each of them, negligently maintained, managed, controlled, and operated the
Chalice Recording Studios, in that they did not maintain and provide adequate security for the
Plaintiff or the other artists, producers, and songwriters and creatives who attended Sean
Combs Love Album writers camp. Defendants knew, or in the exercise of reasonable care
should have known, security was required and necessary and the lack of such security could
constitute a dangerous condition and unreasonable risk of harm of which Plaintiff was at all
times herein mentioned unaware. Defendants LR, MR, UMG, CRS, AND SEAN COMBS
had security check the song writers, producers, and artists, but neglected to search Justin
Combs and Sean Combs for the possession of firearms when they entered CRS. Defendants
LR, MR, UMG, CRS, AND SEAN COMBS negligently failed to take steps to either provide
adequate security and make the condition safe or warn Plaintiff of the dangerous condition,
all of which caused Plaintiff to suffer injuries.
269. As a proximate result of the negligence of defendants, and each of them, Plaintiff was hurt
and injured in his health, strength, and activity, sustaining injuries to their nervous system and
person, all of which injuries have caused, and continue to cause, Plaintiff great mental,
physical, and nervous pain and suffering. As a result of such injuries, Plaintiff have suffered
general damages in an amount according to proof.
270. As a further proximate result of the negligence of defendants Plaintiff has incurred, and
will continue to incur, medical and related expenses in an amount according to proof.
WHEREFORE, Plaintiff pray for judgment against Defendants, and each of them, as follows:
a. General damages according to proof;
b. For actual medical expenses incurred;
c. For future medical expenses, according to proof;
d. For loss of earning;
e. For interest, according to law;
f. For costs of suit incurred herein; and
g. For such other and further relief as the Court may deem just and proper.
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NINTH CAUSE OF ACTION

AIDING, ABETTING, AND INDUCING A SEX-TRAFFICKING VENTURE IN
VIOLATION OF THE TRAFFICKING VICTIMS’
PROTECTION ACT, 18 U.S.C. §§ 2, 1591(a)(1) & (2), 1595
(against Defendants Lucian Charles Grainge, Ethiopia Habtemariam,
Motown Records, Love Records, Universal Music Group)
forth fully herein.
272. Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Love
Records, Universal Music Group aided, abetted, and induced Sean Combs’ sex-trafficking
venture that was in and affecting interstate and foreign commerce, together and with others,
in violation of 18 U.S.C. §§ 2, 1591(a)(1) & (a)(2).
273. The crimes that Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown
Records, Love Records, Universal Music Group aided and abetted are (1) Mr. Combs’s
perpetrating of coercive sex trafficking, in violation of 18 U.S.C. § 1591(a)(1), and (2) Mr.
Combs’ co-conspirators knowingly benefitting from coercive sex trafficking, in violation of
18 U.S.C. § 1591(a)(2). These crimes were in and affecting interstate and foreign commerce.
274. Mr. Combs’ co-conspirators benefitted financially and received things of value from their
participation in the Combs sex-trafficking venture, including payments and other
compensation from Mr. Combs. The co-conspirators who benefitted financially include
Defendants J. Combs, Khorram and her direct reports: Brendan Paul, Frankie Santella, and
Moy Baun.
275. Under 18 U.S.C. § 2, Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown
Records, Love Records, Universal Music Group are punishable as a principal under 18 U.S.C.
§§ 1591(a)(1) & (a)(2) and thereby committed and perpetrated violations of Chapter 77, Title
18, U.S. Code, when it aided, abetted, counseled, commanded, induced, and procured Combs’
and his co-conspirators sex-trafficking venture and sex trafficking of Plaintiff Jones, as well
as other underaged persons.
276. Under 18 U.S.C. § 2, Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown
Records, Love Records, Universal Music Group committed and perpetrated crimes in
violation of 18 U.S.C. §§ 1591(a)(1) & (a)(2) by aiding, abetting, inducing, and procuring
Combs’ and his co-conspirator’s sex-trafficking venture and the sex trafficking of Mr. Jones.
As a consequence, Mr. Jones is a victim of Defendants J. Combs, Khorram and her direct
53
reports: Brendan Paul, Frankie Santella, and Moy Baun’s criminally aided, abettted, and
inducing Combs’ and his co-conspirators’ violations of 18 U.S.C. §§ 1591(a)(1) & (a)(2).
277. Defendants J. Combs, Khorram and her direct reports: Brendan Paul, Frankie Santella, and
Moy Baun itself directly committed and perpetrated violations of Chapter 77, Title 18, U.S.
Code, including 18 U.S.C. §§ 1591(a)(1) & (a)(2), by aiding, abetting, and inducing the sex-
trafficking venture and the sex trafficking of Plaintiff Jones. Defendants J. Combs, Khorram
and her direct reports: Brendan Paul, Frankie Santella, and Moy Baun themselves directly
violated Chapter 77 by committing and perpetrating these violations.
278. Among other things, Defendants J. Combs, Khorram and her direct reports: Brendan Paul,
Frankie Santella, and Moy Baun aided, abetted, and induced Combs’ and his co-conspirators’
sex-trafficking venture and sex trafficking of Plaintiff Jones knowing that Combs and his-
conspirators would use means of force, threats of force, fraud, coercion, and a combination of
such means to cause Mr. Jones some of whom were under the age of eighteen, to engage in
commercial sex acts.
279. By aiding, abetting, and inducing Mr. Combs’ and his co-conspirators’ sex-trafficking
venture and sex trafficking of Plaintiff. Defendants J. Combs, Khorram and her direct reports:
Brendan Paul, Frankie Santella, and Moy Baun benefited, both financially and by receiving
things of value, from participating in Combs’ sex-trafficking venture.
280. Defendants J. Combs, Khorram and her direct reports: Brendan Paul, Frankie Santella, and
Moy Baun and its employees had actual knowledge that they were aiding, abetting, and
inducing Combs’ and his co-conspirators’ sexual abuse and sex trafficking conspiracy to
recruit, solicit, entice, coerce, harbor, transport, obtain, and provide Mr. Jones as well as
others, into commercial sex acts, through the means of force, threats of force, fraud, abuse of
process, and coercion. Defendants knew, and should have known, that Mr. Combs had
engaged in acts in violation of the TVPA.
281. Despite such knowledge, Defendants Lucian Charles Grainge, Ethiopia Habtemariam,
Motown Records, Love Records, Universal Music Group intentionally paid for and aided,
abetted, and induced Combs’ violations of 18 U.S.C. §§ 1591(a)(1) & (a)(2), which
constituted perpetrating violations of those laws under 18 U.S.C. § 2. Defendants Lucian
Charles Grainge, Ethiopia Habtemariam, Motown Records, Love Records, Universal Music
54
Group knew, and acted in reckless disregard of the fact that, Combs would coerce, defraud,
and force Mr. Jones to engage in commercial sex acts.
Records, Universal Music Group’s affirmative conduct of aiding, abetting, and inducing
Combs’ violations was committed knowingly, and in reckless disregard of the facts, that Mr.
Combs would use cash and financial support provided by Defendants Lucian Charles Grainge,
Ethiopia Habtemariam, Motown Records, Love Records, Universal Music Group as a means
of defrauding, forcing, and coercing sex acts from Mr. Jones. Defendants Lucian Charles
Grainge, Ethiopia Habtemariam, Motown Records, Love Records, Universal Music Group’s
conduct was outrageous and intentional.
Records, Universal Music Group’s knowing and intentional conduct of aiding, abetting, and
inducing Combs’s violations has caused Mr. Jones serious harm including, without limitation,
physical, psychological, emotional, financial, and reputational harm.
Records, Universal Music Group’s knowing and intentional conduct of aiding, abetting, and
inducing Combs’s violations has caused Mr. Jones harm that is sufficiently serious, under all
the surrounding circumstances, to compel a reasonable person of the same background and in
the same circumstances to perform or to continue performing commercial sexual activity, in
order to avoid incurring that harm.
285. This case does not involve mere fraud. Instead, Defendants’ criminal conduct in aiding,
abetting, and inducing Combs’s violations of the TVPA was outrageous and intentional,
because it was in deliberate furtherance of a widespread and dangerous criminal sex
trafficking organization. Defendants Lucian Charles Grainge, Ethiopia Habtemariam,
Motown Records, Love Records, Universal Music Group’s criminal conduct also evinced a
high degree of moral turpitude and demonstrated such wanton dishonesty as to imply a
criminal indifference to civil obligations. Defendants Lucian Charles Grainge, Ethiopia
Habtemariam, Motown Records, Love Records, Universal Music Group’s criminal conduct
was directed specifically at Mr. Jones, who was the victim of Mr. Combs’s sexual abuse and
sex trafficking organization.
55
Records, Universal Music Group’s outrageous and intentional conduct in this case is part of
a pattern and practice of Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown
Records, Love Records, Universal Music Group profiting by undertaking illegal “high risk,
high reward” sponsorships, and partnerships.
Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Love Records,
Universal Music Group is liable to Mr. Jones for the damages he sustained and reasonable
attorneys’ fees.
288. By virtue of these intentional and outrageous violations of 18 U.S.C. §§ 1591(a)(1), 1595,
Universal Music Group is liable to Mr. Jones for punitive damages.
TENTH CAUSE OF ACTION

NIED (FOR SEXUAL ASSAULT)
(against Defendant Jane Doe 1 (Yung Miami’s Cousin))
forth fully herein.
290. Jane Doe 1’s conduct created an unreasonable risk of causing emotional distress to Plaintiff,
and Jane Doe 1 knew or should have known that such conduct was likely to result in emotional
distress that might and/or likely would cause illness or bodily harm.
291. Plaintiff’s emotional distress was foreseeable to Jane Doe 1.
292. As a direct and proximate result of the negligent conduct of Jane Doe 1, Plaintiff suffered
and will continue to suffer severe emotional distress.
293. Jane Doe 1’s conduct was wanton, malicious, willful, and/or cruel, entitling the plaintiff to
punitive damages.
ELEVENTH CAUSE OF ACTION
NIED (FOR SEXUAL ASSAULT)
(against Mr. Combs)
forth fully herein.
56
295. Mr. Combs’ conduct created an unreasonable risk of causing emotional distress to Plaintiff,
and Mr. Combs knew or should have known that such conduct was likely to result in emotional
distress that might and/or likely would cause illness or bodily harm.
296. Plaintiff’s emotional distress was foreseeable to Mr. Combs.
297. As a direct and proximate result of the negligent conduct of Mr. Combs, Plaintiff suffered
and will continue to suffer severe emotional distress.
298. Mr. Combs’ conduct was wanton, malicious, willful, and/or cruel, entitling the plaintiff to
punitive damages.
TWELFTH CAUSE OF ACTION
IIED (FOR SEXUAL ASSAULT)
Defendant Jane Doe 1 (Yung Miami’s Cousin)
forth fully herein.
300. Jane Doe 1 engaged in conduct toward Plaintiff that is extreme and outrageous to exceed
the Baunds of decency in a civilized society, namely by, inter alia, subjecting him to sexual
assault and misconduct.
301. The sexual assault and misconduct by Jane Doe 1 were extreme and outrageous conduct
that shocks the conscience.
302. These actions were taken with the intent to cause or disregard for the substantial probability
of causing severe emotional distress.
303. As a direct and proximate result of Jane Doe 1’s extreme and outrageous conduct, Plaintiff
has suffered severe emotional distress.
304. The Defendant's conduct was wanton, malicious, willful, and/or cruel, entitling the Plaintiff
to punitive damages.
THIRTEENTH CAUSE OF ACTION

IIED (FOR SEXUAL ASSAULT)
(against Mr. Combs)
forth fully herein.
306. Mr. Combs engaged in conduct toward Plaintiff that is extreme and outrageous to exceed
the Baunds of decency in a civilized society, namely by, inter alia, subjecting him to sexual
assault and misconduct.
57
307. The sexual assault and misconduct by Mr. Combs were extreme and outrageous conduct
that shocks the conscience.
308. These actions were taken with the intent to cause or disregard for the substantial probability
of causing severe emotional distress.
309. As a direct and proximate result of Mr. Combs’ extreme and outrageous conduct, Plaintiff
has suffered severe emotional distress.
310. The Defendant's conduct was wanton, malicious, willful, and/or cruel, entitling the Plaintiff
to punitive damages.
FOURTEENTH CAUSE OF ACTION
KNOWING BENEFICIARY IN A SEX-TRAFFICKING VENTURE IN VIOLATION OF
THE TRAFFICKING VICTIMS’ PROTECTION ACT, 18 U.S.C. §§ 1591(A)(2), 1595
(against Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records,
Love Records, and Universal Music Group)
forth fully herein.
Records, and Universal Music Group knowingly and intentionally benefitted, financially and
by receiving things of value, from participating in, assisting, supporting, and facilitating an
illegal coercive sex-trafficking venture that was in and affecting interstate and foreign
commerce, together and with others, in violation of 18 U.S.C. § 1591(a)(2).
Records, and Universal Music Group took many concrete steps to aid and participate in Mr.
Combs’ sex-trafficking venture. Among the concrete steps that Defendants Lucian Charles
Grainge, Ethiopia Habtemariam, Motown Records, Love Records, and Universal Music
Group took to aid Mr. Combs was providing vast sums of cash, which made the sex-
trafficking venture possible. Providing Mr. Combs with large sum of U.S. currency caused
and Universal Music Group to receive financial benefits. Defendants Lucian Charles Grainge,
Ethiopia Habtemariam, Motown Records, Love Records, and Universal Music Group
willingness to provide large amounts of cash to Mr. Combs was the quid pro quo for it
receiving financial benefits from Mr. Combs.
314. The cash that Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown
Records, Love Records, and Universal Music Group provided was necessary for Mr. Combs
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to coerce Plaintiff Jones to engage in commercial sex acts. The cash directly formed part of
the commercial nature of the sex acts. The cash was also a necessary and required part of Mr.
Combs’ recruitment of Plaintiff Jones, as well as other sex workers, prostitutes and underage
minors. By providing cash that Defendants Lucian Charles Grainge, Ethiopia Habtemariam,
Motown Records, Love Records, and Universal Music Group knew would be used to fund
the sex trafficking venture, Defendants Lucian Charles Grainge, Ethiopia Habtemariam,
Motown Records, Love Records, and Universal Music Group actively participated in the
recruitment of victims of the venture.
315. The cash that Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown
Records, Love Records, and Universal Music Group provided went far beyond providing
routine sponsorship, partnership, and employer compensation for a subordinate. It was far
from routine for Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown
Records, Love Records, and Universal Music Group to provide substantial sums of cash per
year to Mr. Combs, who did not have an apparent legitimate need for such extravagant sums.
The sheer number of “listening parties,” yacht parties, and nighttime writers camp after parties
which Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Love
Records, and Universal Music Group sponsored, went far beyond normal for the music
industry. Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Love
Records, and Universal Music Group knew or should have known that they were feeding Mr.
Combs sexual deviancy. Moreover, the circumstances in which Mr. Combs was requesting
such large amounts were far from routine and should have raised numerous “red flags”—
taking it well outside routine circumstances.
Records, and Universal Music Group providing large sums of cash to Mr. Combs, under the
circumstances of this case, was entirely inconsistent with the ordinary duties of a record label,
music group, publishing partner or as an employer employee.
317. The reason that Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown
Records, Love Records, and Universal Music Group ignored the numerous red flags about
Mr. Combs was to receive financial benefits from Mr. Combs and his sex-trafficking venture.
and Universal Music Group knew that it would gain far-from-routine financial benefits by
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ignoring the red flags associated with Mr. Combs and by participating in his sex- trafficking
venture.
a. Among the concrete steps that Defendants Lucian Charles Grainge, Ethiopia
Habtemariam, Motown Records, Love Records, and Universal Music Group took to
aid and participate in the Combs sex-trafficking venture were opening up numerous
lines of credit for Mr. Combs’s production of the Love Album, his related entities, and
associates. By opening these lines of credit, and by consistently sponsoring his freak
off parties, Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown
Records, Love Records, and Universal Music Group received many benefits from
participating in Mr. Combs’s venture. The sponsoring of these events was affirmative
conduct that caused Defendants Lucian Charles Grainge, Ethiopia Habtemariam,
Motown Records, Love Records, and Universal Music Group to receive those
benefits.
b. Among the concrete steps that Defendants Lucian Charles Grainge, Ethiopia
aid the Combs sex- trafficking venture, between about 2000 and continuing through
about November 2023, Defendants Lucian Charles Grainge, Ethiopia Habtemariam,
Motown Records, Love Records, and Universal Music Group concealed its delivery
of vast sums of cash (likely millions of dollars) to Mr. Combs and his associates. In
order to benefit from the Combs sex- trafficking venture, Defendants Lucian Charles
Grainge, Ethiopia Habtemariam, Motown Records, Love Records, and Universal
Music Group willfully failed to timely file required tax disclosures surrounding the
funding of these sex trafficking parties with the federal government, because doing so
would imperil its ability to profit from the sex-trafficking venture. Defendants Lucian
Charles Grainge, Ethiopia Habtemariam, Motown Records, Love Records, and
Universal Music Group concealment of the cash transactions caused it to receive
financial benefits through continuation of the Combs sex-trafficking venture.
c. Among the concrete steps that Defendants Lucian Charles Grainge, Ethiopia
aid the Combs sex- trafficking venture were its failure to follow AML requirements.
This failure was not just passive facilitation, but a deliberate omission by Defendants
Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Love Records, and
Universal Music Group. This omission was specific act of concealment, which
allowed Combs to continue funding his sex- trafficking venture through suspicious
transactions that would have otherwise been prevented.
d. By taking the concrete steps outlined above (along with the others alleged in this
complaint), Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown
Records, Love Records, and Universal Music Group knowingly participated in sex
trafficking and furthered the Combs sex-trafficking venture. The concrete steps above
constituted taking part in the sex-trafficking venture and were necessary for its
success. The concrete steps above constituted active engagement by Defendants
Universal Music Group in Combs’s sex- trafficking venture.
e. Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Love
Records, and Universal Music Group knowingly and intentionally benefited
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financially from, and received value for, its participation in the sex-trafficking venture,
in which Mr. Combs, with Defendants Lucian Charles Grainge, Ethiopia
Habtemariam, Motown Records, Love Records, and Universal Music Group’s
knowledge, or their reckless disregard of the fact, that Combs would use means of
force, threats of force, fraud, coercion, and a combination of such means to cause
Plaintiff Jones, as well as others, some of whom were under the age of seventeen, to
engage in commercial sex acts.
f. Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Love
Records, and Universal Music Group knew, through years of lawsuits, hush money
settlements, and notice that was provided by Ms. Cassie Venture at the beginning of
2023, that Mr. Combs was engaging in sex trafficking, and that Defendants Lucian
Universal Music Group was participating in a particular sex-trafficking venture—i.e.,
the coercive Combs sex-trafficking venture outlined above. Defendants Lucian
Universal Music Group’s knowledge went far beyond having an abstract awareness
of sex trafficking in general. Indeed, Defendants Lucian Charles Grainge, Ethiopia
Habtemariam, were present at Chalice Recording Studios and in Mr. Combs Miami,
LA, and NYC homes while he was actively engaging in freak off parties and sex
trafficking and the large amounts of cash that Defendants Lucian Charles Grainge,
were giving him. Thus, Defendants Lucian Charles Grainge, Ethiopia Habtemariam,
Motown Records, Love Records, and Universal Music Group did not simply fail to
adequately detect signs of Combs’ sex trafficking; it did detect multiple signs of
Combs’ coercive sex-trafficking venture and continued to participate in the venture.
Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Love
Records, and Universal Music Group knew that the venture was on-going, which was
why Combs required vast sums of cash.
g. Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Love
Records, and Universal Music Group’s actions extend well beyond a situation of
failing to train themselves and their staff about recognizing the warning signs of sex
trafficking. Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown
Records, Love Records, and Universal Music Group’s employees did recognize the
signs of Combs’ sex trafficking. Indeed, Defendants Lucian Charles Grainge, Ethiopia
employees knew about Combs’ sex-trafficking venture. But Defendants Lucian
Universal Music Group decided to continue facilitating the Combs sex-trafficking
venture rather than ending its participation in the venture.
h. Among the signs that Defendants Lucian Charles Grainge, Ethiopia Habtemariam,
Motown Records, Love Records, and Universal Music Group was facilitating Combs
sex trafficking venture were those facts that came to the attention of Defendants
Universal Music Group from the reporting of Mr. Cassie Ventura mentioned above.
i. Among the signs that Defendants Lucian Charles Grainge, Ethiopia Habtemariam,
Motown Records, Love Records, and Universal Music Group was facilitating Combs’
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sex trafficking venture were those facts that came to the attention of Defendants
Universal Music Group were those facts that came to its attention through complaints
filed by Cassie Ventura of Combs’ sex trafficking. Because of those complaints,
Records, and Universal Music Group — knew to a certainty that Combs was engaged
in sex trafficking.
j. Defendants Lucian Charles Grainge, Ethiopia Habtemariam’s are officers of
Defendants Motown Records, Love Records, and Universal Music Group and knew
the names of the many of Combs’ sex trafficking/ freak off participates (Yung Miami,
Daphne Joy, Stevie J, and Jade).
k. Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Love
Records, and Universal Music Group helped to conceal the names of Combs’ victims
from the public and from law enforcement and prosecuting agencies by helping to
conceal the existence of the sex-trafficking venture. Among the ways in which
Records, and Universal Music Group helped to conceal the venture’s existence was
by providing the cash necessary for the venture to avoid leaving a visible “paper trail.”
Additionally, they employed and empowered Faheem Muhammad, and Defendant
Khorram to pay off law enforcement, and to compensate the sex workers with cash.
l. Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Love
Records, and Universal Music Group’s concealment included failing to provide
enhanced monitoring that was required for someone like Combs. Defendants Lucian
Universal Music Group failed to implement an enhanced monitoring of Mr. Combs
sexual parties to ensure that underaged girls and sex workers were not present. They
failed to do this specifically to help conceal Combs’ ongoing sex-trafficking.
Records, and Universal Music Group knew that if it implemented that enhanced
monitoring, it would have to stop providing Combs with the cash needed to run his
sex-trafficking venture.
m. Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Love
Records, and Universal Music Group ’s concealment included failing to report Mr.
Combs’ suspicious sex trafficking activities to law enforcement, and for failing to
report their financial support and sponsorship of Mr. Combs sex trafficking parties to
the federal government for tax purposes.
n. In addition to having actual knowledge that it was participating in Combs’ sex
trafficking venture, Defendants Lucian Charles Grainge, Ethiopia Habtemariam,
Motown Records, Love Records, and Universal Music Group had constructive
knowledge that it was participating in Combs’ sex trafficking venture. Defendants
Universal Music Group also had constructive knowledge that Plaintiff James, and
other underaged minors were being coercively sex trafficked by Combs. Its
constructive knowledge extended to the names of Combs’ victims, because Combs
and his associates knew the names of the victims. Mr. Combs had hundreds of cameras
in his homes in LA, NYC, and Miami. Mr. Combs required the sex workers, and
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underaged girls to sign NDAs prior entering his parties, and prior to being drugged
and sex trafficked at these parties.
o. Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Love
Records, and Universal Music Group had constructive knowledge of Combs’ sex-
trafficking venture because of specific acts by Mr. Combs that put it on notice of a
particular and ongoing sex trafficking venture. Among the specific acts were Combs’
use of vast sums of cash, drugs, fake promises of career opportunities and access to
music industry executives in circumstances that should have prompted Defendants
Universal Music Group employees to specifically raise questions about Combs’s sex-
trafficking.
p. Also, among the specific acts giving rise to constructive knowledge were the facts that
associates of Mr. Combs made numerous cash withdrawals from Defendants Lucian
Universal Music Group accounts through Mr. Combs accountant Robin Greenhill. The
circumstances of these withdrawals gave Defendants notice that Mr. Combs’ sex-
trafficking enterprise was being funded.
q. Among the financial benefits that the Defendants Lucian Charles Grainge, Ethiopia
Habtemariam, Motown Records, Love Records, and Universal Music Group received
for participating in and facilitating Combs’ sex-trafficking venture were the affiliation
and access to Mr. Combs popularity. Mr. Combs was known for throwing the “best”
parties. Affiliation with, and or sponsorship of Mr. Combs sex-trafficking parties
garnered legitimacy and access to celebrities such as famous athletes, political figures,
artist, musicians, and international dignitaries like British Royal, Prince Harry. Mr.
Combs and Combs-controlled entities made to Defendants Lucian Charles Grainge,
Ethiopia Habtemariam, Motown Records, Love Records, and Universal Music Group.
Records, and Universal Music Group profited from their affiliation with Mr. Combs
and their sponsorship of his sex-trafficking parties. Mr. Combs and Combs-controlled
entities used the sponsorship funds in exchange for Defendants Lucian Charles
Music Group’s facilitation and participation in the sex trafficking venture, including
its willingness to provide large amounts of cash in suspicious circumstances and to
allow their failure to report these sponsorships on their taxes to the US Federal
Government to avoid triggering suspicions of the Federal Government.
r. Among the financial benefits that Defendants Lucian Charles Grainge, Ethiopia
Habtemariam, Motown Records, Love Records, and Universal Music Group received
for participating in Combs’ sex-trafficking venture was referral of business
opportunities from Mr. Combs and his co-conspirators. Access to up-and-coming
artist, producers, song writers and creatives. Defendants Lucian Charles Grainge,
profited from these referred business opportunities. Mr. Combs referred business
entities and business opportunities to Defendants Lucian Charles Grainge, Ethiopia
Habtemariam, Motown Records, Love Records, and Universal Music Group in
exchange for its facilitation and participation in the sex trafficking venture. These
referrals were a quid pro quo for Defendants Lucian Charles Grainge, Ethiopia
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participation in the sex-trafficking venture.
s. Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Love
Records, and Universal Music Group financially profited from the deposits made by
Combs and Combs-controlled entities and from the business opportunities referred to
Records, and Universal Music Group by Combs in exchange for its facilitation and
participation in Combs’ sex trafficking venture.
t. Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Love
Records, and Universal Music Group knowingly received financial benefits in return
for its assistance, support, and facilitation of Combs’ sex-trafficking venture.
Records, and Universal Music Group knew that if it stopped assisting, supporting, and
facilitating of Combs’ sex-trafficking venture, it would no longer receive those
benefits.
u. Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Love
Records, and Universal Music Group knew, and was in reckless disregard of the fact,
that it was Combs’s pattern and practice to use the channels and instrumentalities of
interstate and foreign commerce (private jets, yachts, and commercial airplanes) to
entice, recruit, solicit, harbor, provide, obtain, and transport young women, young
men, and underage girls for purposes of causing commercial sex acts, in violation of
18 U.S.C. § 1591(a)(1).
v. Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Love
Records, and Universal Music Group and its employees had actual knowledge that
they were facilitating Combs’ sexual abuse and sex trafficking conspiracy to recruit,
solicit, entice, coerce, harbor, transport, obtain and provide Mr. Jones into commercial
sex acts, through the means of force, threats of force, fraud, abuse of process, and
coercion, and a combination of all these means.
w. Despite such knowledge, Defendants Lucian Charles Grainge, Ethiopia Habtemariam,
Motown Records, Love Records, and Universal Music Group intentionally paid for,
facilitated, and participated in Combs’ violations of 18 U.S.C. § 1591(a)(1), which
Records, and Universal Music Group knew, and were in reckless disregard of the fact
that, Combs would coerce, defraud, and force Mr. Jones to engage in commercial sex
acts.
x. Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Love
Records, and Universal Music Group, through its employees and agents, actively
participated in the sex trafficking conspiracy and led Mr. Jones, sex workers, and
underage girls to believe that they would be rewarded if they cooperated and
acquiesced to Mr. Combs’ coercive demands.
y. Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Love
Records, and Universal Music Group’s affirmative conduct was committed
knowingly, and in reckless disregard of the facts, that Mr. Combs would use cash and
financial support provided by Defendants Lucian Charles Grainge, Ethiopia
Habtemariam, Motown Records, Love Records, and Universal Music Group as a
means of defrauding, forcing, and coercing sex acts from Mr. Jones. Defendants
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Universal Music Group’s conduct was outrageous and intentional.
z. In addition to actual knowledge that it was participating in and facilitating the Combs
sex-trafficking venture, Defendants Lucian Charles Grainge, Ethiopia Habtemariam,
Motown Records, Love Records, and Universal Music Group also should have known
that it was participating in and facilitating a venture that had engaged in coercive sex
trafficking, as covered by 18 U.S.C. § 1595(a).
aa. In exchange for facilitating and covering up Combs’ commercial sex trafficking, the
Defendants Lucian Charles Grainge, Ethiopia Habtemariam advanced in their careers
at Defendants Motown Records, Love Records, and Universal Music Group and
received financial benefits therefrom by securing the Defendants Motown Records,
Love Records, and Universal Music Group – Sean Combs relationship.
bb. Facilitating and covering up Combs’ sexual trafficking and misconduct was a means
of obtaining economic success and promotion within the Defendants Lucian Charles
Music Group hierarchy.
cc. Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Love
Records, and Universal Music Group’s knowing, and intentional conduct has caused
Mr. Jones serious harm including, without limitation, physical, psychological,
emotional, financial, and reputational harm.
dd. Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Love
Records, and Universal Music Group’s knowing, and intentional conduct has caused
Mr. Jones harm that is sufficiently serious, under all the surrounding circumstances,
to compel a reasonable person of the same background and in the same circumstances
to perform or to continue performing commercial sexual activity, to avoid incurring
that harm.
ee. This case does not involve mere fraud. Instead, Defendants Lucian Charles Grainge,
Ethiopia Habtemariam, Motown Records, Love Records, and Universal Music
Group’s criminal conduct in violating the TVPA was outrageous and intentional
Motown Records, Love Records, and Universal Music Group ’s criminal conduct also
evinced a high degree of moral turpitude and demonstrated such wanton dishonesty as
to imply a criminal indifference to civil obligations. Defendants Lucian Charles
Music Group’s criminal conduct was directed specifically at Mr. Jones who was the
victim of Combs’ sexual abuse and sex trafficking organization.
ff. Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Love
Records, and Universal Music Group’s outrageous and intentional conduct in this case
is part of a pattern and practice of Defendants Lucian Charles Grainge, Ethiopia
Habtemariam, Motown Records, Love Records, and Universal Music Group profiting
by undertaking illegal “high risk, high reward” partnerships and sponsorships.
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and Universal Music Group is liable to Mr. Jones for the damages he sustained and reasonable
attorneys’ fees.
FIFTEENTH CAUSE OF ACTION

OBSTRUCTION OF THE ENFORCEMENT OF THE TRAFFICKING VICTIM
PROTECTION ACT, 18 U.S.C. § 1591(d)
(against, Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records,
Love Records, and Universal Music Group)
forth fully herein.
Records, and Universal Music Group and its officers and employees knowingly and
intentionally obstructed, attempted to obstruct, interfered with, and prevented the enforcement
of 18 U.S.C. §§ 1591(a)(1) & (a)(2), all in violation of 18 U.S.C. § 1591(d). This activity is
hereinafter referred to collectively simply as “obstruction.”
Records, and Universal Music Group’s obstruction of the enforcement of 18 U.S.C. §§
1591(a)(1) and (a)(2) was forbidden by 18 U.S.C. § 1591(d), and Defendants Lucian Charles
Group thereby violated Chapter 77, Title 18. Defendants Lucian Charles Grainge, Ethiopia
Habtemariam, Motown Records, Love Records, and Universal Music Group’s obstruction
described here and in the preceding paragraph directly, proximately, and foreseeably harmed
Mr. Jones by directly resulting in him coercively being caused to engage in commercial sex
acts and in other ways.
322. Defendant Sean Combs has a well-documented history of criminal investigations.
and Universal Music Group were on notice of Mr. Combs proclivity to criminal activity. They
knew or should have known that Mr. Combs sex-trafficking operation would or could result
in a criminal investigation by State and Federal prosecutors for violating (among other laws)
the TVPA. Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records,
Love Records, and Universal Music Group should have taken a que from the Federal
Prosecutors arrest and prosecution of Jeffrey Epstein on or about July 8, 2019. On or about
that date, the U.S. Attorney’s Office for the Southern District of New York indicted Epstein
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(and unnamed “associates”) for violating the TVPA. Later, on about June 29, 2020, the same
Office indicted Epstein’s co-conspirator, Ghislaine Maxwell, for conspiracy to entice minor
victims to travel to be abused by Epstein. Mr. Combs, Defendants J. Combs, Khorram and
her direct reports: Brendan Paul, Frankie Santella, and Moy Baun all engaged in the same
activities as Mr. Epstein and Ms. Maxwell. In fact, Mr. Combs, Defendants J. Combs,
Khorram and her direct reports: Brendan Paul, Frankie Santella, and Moy Baun may have
done worse.
323. By providing financing for Mr. Combs’ sex trafficking organization, and concealing its
actions thereafter, Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown
Records, Love Records, and Universal Music Group obstructed, interfered with, and
prevented the state and federal government enforcement of the TVPA against Mr. Combs,
Defendants J. Combs, Khorram and her direct reports: Brendan Paul, Frankie Santella, and
Moy Baun. To the extent that the federal government was able to ultimately charge Mr.
Combs, Defendants J. Combs, Khorram and her direct reports: Brendan Paul, Frankie
Santella, and Moy Baun with TVPA violations, the filing of those charges was delayed by
and Universal Music Group’s actions. Because of that delay, Mr. Jones was coercively caused
to engage in commercial sex acts.
324. As one example of how Defendants Lucian Charles Grainge, Ethiopia Habtemariam,
Motown Records, Love Records, and Universal Music Group obstructed, attempted to
obstruct, interfered with, and prevented state and federal government’s enforcement of the
TVPA, Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Love
Records, and Universal Music Group provided large amounts of cash to Mr. Combs and his
associates so that the coercive commercial sex acts would escape the detection of state and
federal law enforcement and prosecuting agencies. Defendants Lucian Charles Grainge,
provided large amounts of cash to further the Mr. Combs, Defendants J. Combs, Khorram and
her direct reports: Brendan Paul, Frankie Santella, and Moy Baun sex-trafficking venture and
with the purpose of helping Mr. Combs, Defendants J. Combs, Khorram and her direct reports:
Brendan Paul, Frankie Santella, and Moy Baun evade criminal liability for violating the
TVPA.
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325. As an example of how Defendants Lucian Charles Grainge, Ethiopia Habtemariam,

Motown Records, Love Records, and Universal Music Group obstructed, attempted to
obstruct, interfered with, and prevented state and federal government’s enforcement of the
TVPA, Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Love
Records, and Universal Music Group failed to timely file with the state and federal
government the required tax forms that detailed the sponsorship and partnership payments
provided by defendants to Mr. Combs. Timely filing of these reports is required by the United
States Tax code and related laws and regulations. These reports are tools that the state and
federal government uses to detect and prosecute, among other illegal activities, sex trafficking
in violation of the TVPA. By failing to timely file, the required tax reporting documents
regarding Mr. Combs’ sponsorship cash transactions, Defendants Lucian Charles Grainge,
obstructed, attempted to obstruct, interfered with, and prevented the government’s
enforcement of the TVPA by concealing from the government’s attention Mr. Combs’ cash
transaction in aid of sex trafficking.
326. By providing large amounts of cash to Mr. Combs and his associates, Defendants Lucian
Charles Grainge, Ethiopia Habtemariam, Motown Records, Love Records, and Universal
Music Group intended and knew that Mr. Combs’ coercive commercial sex acts would escape
the detection of law enforcement and prosecuting agencies for some period of time.
and Universal Music Group provided large amounts of cash to further the Combs sex-
trafficking venture and with the purpose of helping Mr. Combs evade criminal liability for
violating the TVPA.
Records, and Universal Music Group’s obstruction, attempted obstruction, interference with,
and prevention of the enforcement of the TVPA were all done intentionally and knowingly.
For example, Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records,
Love Records, and Universal Music Group knew that Mr. Combs was high risk—specifically,
high risk to violate the TVPA through continuing criminal sex trafficking activities. As
evidenced by Cassie Ventura’s civil complaint, she informed members of Mr. Combs parent
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label about the abuses he was visiting upon her, and instead of coming to her rescue, they
forced her to return his calls and to return to his sex trafficking enterprise.
Records, and Universal Music Group was aware Mr. Combs had a laundry list of criminal
charges, and barely escaped serving prison time. Upon information and belief Mr. Combs
engaged in witness intimidation, and bribery to escape criminal liability for shooting Natania
Reuben in the face. Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown
Records, Love Records, and Universal Music Group was aware that there were public
allegations that Mr. Combs illegal conduct was facilitated by several named co- conspirators.
They were made aware of this through complaints made my Cassie Ventura, and the lawsuit
by former Diddy sex worker Jonathan Oddi. Defendants Lucian Charles Grainge, Ethiopia
Habtemariam, Motown Records, Love Records, and Universal Music Group concealed from
state and federal government its numerous cash payments to those co-conspirators.
and Universal Music Group continued its affirmative conduct of providing cash to Mr. Combs,
and his associates so that he could make those cash payments to his co- conspirators with
knowledge that such cash transaction did not produce a clear paper trail. Defendants Lucian
Charles Grainge, Ethiopia Habtemariam, Motown Records, Love Records, and Universal
Music Group’s intentional conduct obstructed, attempted to obstruct, in many ways interfered
with, and prevented the enforcement of the TVPA by investigators and prosecuting agencies.
Records, and Universal Music Group’s relationship with Mr. Combs in providing to his sex-
trafficking venture with vast sums of cash each year went far beyond a normal (and lawful)
sponsorship, partnership, and employer employee relationships. Defendants Lucian Charles
Group knew, and intended, that its relationship with Mr. Combs would go far beyond a normal
music industry relationship. Defendants Lucian Charles Grainge, Ethiopia Habtemariam,
Motown Records, Love Records, and Universal Music Group knew that its decision to go
beyond a normal music relationship with Mr. Combs obstructed the ability of law enforcement
and prosecuting agencies to enforce the TVPA.
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Records, and Universal Music Group’s obstruction of the government’s TVPA and other law
enforcement efforts was intentional and willful and, therefore, Defendants Lucian Charles
Group intentionally and willfully caused Mr. Combs’ commission of the forcible commercial
sex acts with Mr. Jones through its obstruction supporting the concealment of Mr. Combs’
sex-trafficking venture. Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown
Records, Love Records, and Universal Music Group knew that Mr. Combs and his other co-
conspirators would use means of force, threats of force fraud, coercion, and a combination of
such means to cause Mr. Jones to engage in commercial sex acts.
Records, and Universal Music Group knew, acted in reckless disregard of the fact, and should
have known, that its obstruction in violation of 18 U.S.C. § 1591(d) would directly and
proximately lead to unlawful coercive commercial sex acts by Mr. Combs with men, like
Plaintiff Jones, young men, women and young girls.
Records, and Universal Music Group’s obstruction has caused Mr. Jones serious harm,
including, without limitation, physical, psychological, financial, and reputational harm. That
harm was directly and proximately caused by the obstruction and the harm resulting from
obstruction was foreseeable.
Records, and Universal Music Group’s obstruction has caused Mr. Jones harm that is
sufficiently serious, under all the surrounding circumstances, to compel a reasonable person
of the same background and in the same circumstances to perform or to continue performing
commercial sexual activity to avoid incurring that harm.
334. This case does not involve mere fraud. Instead, Defendants Lucian Charles Grainge,
Ethiopia Habtemariam, Motown Records, Love Records, and Universal Music Group’s
criminal conduct in obstructing enforcement of the TVPA was outrageous and intentional
Motown Records, Love Records, and Universal Music Group’s obstruction also evinced a
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high degree of moral turpitude and demonstrated such wanton dishonesty as to imply a
criminal indifference to civil obligations. Defendants Lucian Charles Grainge, Ethiopia
Habtemariam, Motown Records, Love Records, and Universal Music Group’s obstruction
was directed specifically at Mr. Jones who was the victim of Mr. Combs’ sex trafficking
organization.
335. By virtue of these violations of 18 U.S.C. § 1591(d), Defendants Lucian Charles Grainge,
Ethiopia Habtemariam, Motown Records, Love Records, and Universal Music Group is liable
to Mr. Jones for the damages he sustained and reasonable attorneys’ fees by operation of 18
U.S.C. § 1595. Defendants Lucian Charles Grainge, Ethiopia Habtemariam, Motown
Records, Love Records, and Universal Music Group perpetrated an obstruction of the TVPA,
and therefore perpetrated a violation of Chapter 77, Title 18.
PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays that the Court enter judgment in her favor and against Defendants,
containing the following relief:
a. A declaratory judgment that the actions, conduct, and practices of Defendants
complained of herein violate the laws of the State of New York;
b. An award of damages against Defendant, in an amount to be determined at Trial,
plus prejudgment interest, to compensate Plaintiff for all monetary and/or economic
damages, including, but not limited to, loss of past and future income, wages,
compensation, seniority, and other benefits of employment;
c. An award of damages against Defendant, in an amount to be determined at Trial,
plus prejudgment interest, to compensate Plaintiff for all non-monetary and/or
compensatory damages, including, but not limited to, compensation for her mental
anguish, humiliation, embarrassment, stress and anxiety, emotional pain and
suffering, and emotional distress;
d. An award of punitive damages, in an amount to be determined at Trial;
e. Prejudgment interest on all amounts due;
f. An award of costs that Plaintiff has incurred in this action, including, but not limited
to, expert witness fees, as well as Plaintiff’s reasonable attorneys’ fees and costs to
the fullest extent permitted by law; and,
g. Such other and further relief as the Court may deem just and proper.
JURY DEMAND
Plaintiff hereby demands a trial by jury on all issues of fact and damages stated herein.
Dated: February 26, 2024

Brooklyn, New York
T. A. BLACKBURN LAW, PLLC.
By:
Tyrone A. Blackburn, Esq.
71
PRESERVATION NOTICE
The term "you," "your," or "yours" as used herein shall refer to you (the recipient of this letter), as
well as to the respondents and any individuals responsible for the custody and control of the below
information, including, but not limited to, those individuals' administrative assistants, secretaries,
agents, employees, information technology personnel and third-party vendors. From this point
forward, you are directed to prevent "spoliation," defined as altering, changing, updating,
destroying (even if periodically), editing, or deleting any information set forth hereafter.
If you cause any such alteration, destruction, or change, direct it, or allow it to occur, you may be
charged with discovery rule violations for which sanctions may be imposed. Further, your failure
to abide by this request could result in severe penalties against you and form the basis of legal
claims for spoliation.
Electronically Stored Information:

In terms of electronically stored information, you are directed to prevent any destructive,
alternative or other change to any web pages, virtual profiles or identical (including, but not limited
to, Facebook, Instagram, Pinterest, Twitter, Tumblr, LinkedIn, Snapchat, Google Plus+, Flickr,
Vine, About.me, ask.fm etc., or any other social media-based web profile or networking site
account), emails, voice messages, text messages, instant messages or messaging systems,
recordings, digital recordings, media images and videos, temporary memory, memory sticks,
portable memory devices, laptops or computers, CDs, DVDs, USB devices, databases, computer
activity logs, internet browsing history (including cookies), network access and server activity
logs, word processing files and file fragments, backup and archival files, imaging and facsimile
files, electronic calendar and scheduling program files and file fragments as well as any other
contact and relationship management data (e.g., Outlook), electronic spreadsheet files and file
fragments, pertaining in any way to this controversy of the parties or any potential witnesses. This
includes a request that such information not be modified, altered, or deleted due to data
compression or disk fragmentation (or other optimization procedures), which processes you are
hereby directed to suspend until that data can be preserved, copied, and produced.
You are directed not to modify, alter, or delete or allow modifications, alterations, or deletions to
be made to any electronically stored information. You are further directed to preserve all, and not
to destroy any, passwords, decryption productions (including, if necessary, the software to decrypt
the files), network access codes, manuals, tutorials, written instructions, decompression or
reconstruction software, and any other information and things necessary to access, view and (if
necessary) reconstruct the electronic data we will request through discovery.
Paper Information:
Regarding the paper information, you are directed to preserve any emails, videos, texts, memos,
reports, documents, notes, correspondence, photographs, investigative information, or other
documents about the controversy, parties, or witnesses. We expect to obtain several documents
and other data from you through discovery, including text messages, emails, photographs, and
other information stored on computers, electronic devices, and telephones.
Although we may bring a motion with a court for order-preserving documents and other data from
destruction or alteration, your obligation to preserve documents and other data for discovery, in
this case, arises independently from any order on such motion. Electronic documents and the
72
storage media, including but not limited to telephones on which they reside, contain relevant,
discoverable information beyond what may be found in printed documents. Therefore, even where
a paper copy exists, we will likely seek all documents in their original, electronic form, along with
metadata or information about those documents on the media. We will seek paper printouts of
only those documents that contain unique information created after they were printed (e.g., paper
documents containing handwriting, signatures, marginalia, drawings, annotations, highlighting,
and redactions) and any paper documents for which no corresponding electronic files exist.
The laws and rules prohibiting the destruction of evidence apply to electronically stored
information in the same manner they apply to other evidence. Due to its format, electronic
information is quickly deleted, modified, or corrupted. Accordingly, the demand is made that you
take every reasonable step to preserve this information until the final resolution of this matter.
This may include, but would not be limited to, an obligation to discontinue all data destruction and
backup tape recycling policies.
Concerning electronic data created after this Complaint's delivery date, relevant evidence should
not be destroyed. You must take the steps necessary to avoid the destruction of such evidence.

Brooklyn, New York
By:
DEMAND FOR INSURANCE COVERAGE

Defendants are demanded to provide a complete copy of their applicable insurance policies and
declaration sheets demonstrating coverage within thirty (30) days of service of this Complaint.

Brooklyn, New York
By:
73
JS 44C/SDNY Case 1:24-cv-01457 Document 1-1 SHEET
CIVIL COVER Filed 02/26/24 Page 1 of 2
REV.
10/01/2020 The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or
other papers as required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the
United States in September 1974, is required for use of the Clerk of Court for the purpose of initiating the civil docket sheet.
PLAINTIFFS DEFENDANTS
RODNEY JONES SEAN COMBS,JUSTIN DIOR COMBS, ETHIOPIA HABTEMARIAM, LUCIAN
CHARLES GRAINGE, KRISTINA KHORRAM, CHALICE RECORDING
STUDIOS, LOVE RECORDS, MOTOWN RECORDS, UNIVERSAL MUSIC
ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER GROUP, COMBS
ATTORNEYS GLOBAL ENTERPRISES
(IF KNOWN)
Tyrone A. Blackburn, Esq., T. A. Blackburn Law, PLLC
1242 E. 80th Street, 3rd Floor
Brooklyn, NY 11236; P:347-342-7432
CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE)
(DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY)
TVPA, Fed. Rico
Judge Previously Assigned

Has this action, case, or proceeding, or one essentially the same been previously filed in SDNY at any time? No ✔ Yes
If yes, was this case Vol. Invol. Dismissed. No Yes If yes, give date _______________________ & Case No. ______________________
IS THIS AN INTERNATIONAL ARBITRATION CASE? No Yes
(PLACE AN [x] IN ONE BOX ONLY) NATURE OF SUIT

TORTS ACTIONS UNDER STATUTES
CONTRACT PERSONAL INJURY PERSONAL INJURY FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES

[ ] 367 HEALTHCARE/
PHARMACEUTICAL PERSONAL [ ] 375 FALSE CLAIMS
[ ] 110 INSURANCE [ ] 310 AIRPLANE [ ] 625 DRUG RELATED [ ] 422 APPEAL
[ ] 120 MARINE [ ] 315 AIRPLANE PRODUCT INJURY/PRODUCT LIABILITY 28 USC 158 [ ] 376 QUI TAM
SEIZURE OF PROPERTY
[ ] 130 MILLER ACT LIABILITY [ ] 365 PERSONAL INJURY 21 USC 881 [ ] 423 WITHDRAWAL [ ] 400 STATE
[ ] 140 NEGOTIABLE [ ] 320 ASSAULT, LIBEL & PRODUCT LIABILITY 28 USC 157 REAPPORTIONMENT
[ ] 690 OTHER
INSTRUMENT SLANDER [ ] 368 ASBESTOS PERSONAL [ ] 410 ANTITRUST
[ ] 150 RECOVERY OF [ ] 330 FEDERAL INJURY PRODUCT [ ] 430 BANKS & BANKING
OVERPAYMENT & EMPLOYERS' LIABILITY PROPERTY RIGHTS [ ] 450 COMMERCE
ENFORCEMENT LIABILITY [ ] 460 DEPORTATION
OF JUDGMENT [ ] 340 MARINE PERSONAL PROPERTY [ ] 820 COPYRIGHTS [ ] 880 DEFEND TRADE SECRETS ACT [ ✖] 470 RACKETEER INFLU-
[ ] 151 MEDICARE ACT [ ] 345 MARINE PRODUCT [ ] 830 PATENT ENCED & CORRUPT
[ ] 152 RECOVERY OF LIABILITY [ ] 370 OTHER FRAUD ORGANIZATION ACT
[ ] 835 PATENT-ABBREVIATED NEW DRUG APPLICATION
DEFAULTED [ ] 350 MOTOR VEHICLE [ ] 371 TRUTH IN LENDING (RICO)
STUDENT LOANS [ ] 355 MOTOR VEHICLE [ ] 840 TRADEMARK [ ] 480 CONSUMER CREDIT
(EXCL VETERANS) PRODUCT LIABILITY SOCIAL SECURITY
[ ] 153 RECOVERY OF [ ] 485 TELEPHONE CONSUMER
[ ] 360 OTHER PERSONAL
OVERPAYMENT INJURY [ ] 380 OTHER PERSONAL LABOR [ ] 861 HIA (1395ff) PROTECTION ACT
OF VETERAN'S [ ] 362 PERSONAL INJURY - PROPERTY DAMAGE [ ] 862 BLACK LUNG (923)
BENEFITS MED MALPRACTICE [ ] 385 PROPERTY DAMAGE [ ] 710 FAIR LABOR [ ] 863 DIWC/DIWW (405(g)) [ ] 490 CABLE/SATELLITE TV
[ ] 160 STOCKHOLDERS PRODUCT LIABILITY STANDARDS ACT [ ] 864 SSID TITLE XVI [ ] 850 SECURITIES/
SUITS [ ] 720 LABOR/MGMT [ ] 865 RSI (405(g)) COMMODITIES/
[ ] 190 OTHER PRISONER PETITIONS RELATIONS EXCHANGE
CONTRACT [ ] 463 ALIEN DETAINEE [ ] 740 RAILWAY LABOR ACT [ ] 890 OTHER STATUTORY
[ ] 195 CONTRACT [ ] 510 MOTIONS TO [ ] 751 FAMILY MEDICAL FEDERAL TAX SUITS
ACTIONS
PRODUCT ACTIONS UNDER STATUTES VACATE SENTENCE LEAVE ACT (FMLA)
LIABILITY 28 USC 2255 [ ] 870 TAXES (U.S. Plaintiff or [ ] 891 AGRICULTURAL ACTS
[ ] 196 FRANCHISE CIVIL RIGHTS [ ] 530 HABEAS CORPUS [ ] 790 OTHER LABOR Defendant) [ ] 893 ENVIRONMENTAL
[ ] 535 DEATH PENALTY LITIGATION [ ] 871 IRS-THIRD PARTY MATTERS
[ ] 540 MANDAMUS & OTHER [ ] 791 EMPL RET INC 26 USC 7609 [ ] 895 FREEDOM OF
[ ] 440 OTHER CIVIL RIGHTS
SECURITY ACT (ERISA) INFORMATION ACT
(Non-Prisoner)
REAL PROPERTY [ ] 896 ARBITRATION
[ ] 441 VOTING IMMIGRATION [ ] 899 ADMINISTRATIVE
[ ] 210 LAND [ ] 442 EMPLOYMENT PRISONER CIVIL RIGHTS
CONDEMNATION [ ] 443 HOUSING/ [ ] 462 NATURALIZATION PROCEDURE ACT/REVIEW OR
[ ] 220 FORECLOSURE ACCOMMODATIONS [ ] 550 CIVIL RIGHTS APPLICATION APPEAL OF AGENCY DECISION
[ ] 230 RENT LEASE & [ ] 445 AMERICANS WITH [ ] 555 PRISON CONDITION [ ] 465 OTHER IMMIGRATION [ ] 950 CONSTITUTIONALITY OF
EJECTMENT DISABILITIES - [ ] 560 CIVIL DETAINEE ACTIONS
EMPLOYMENT STATE STATUTES
[ ] 240 TORTS TO LAND CONDITIONS OF CONFINEMENT
[ ] 245 TORT PRODUCT [ ] 446 AMERICANS WITH
LIABILITY DISABILITIES -OTHER
[ ] 290 ALL OTHER [ ] 448 EDUCATION
REAL PROPERTY
Check if demanded in complaint:

DO YOU CLAIM THIS CASE IS RELATED TO A CIVIL CASE NOW PENDING IN S.D.N.Y.
CHECK IF THIS IS A CLASS ACTION AS DEFINED BY LOCAL RULE FOR DIVISION OF BUSINESS 13?
UNDER F.R.C.P. 23 IF SO, STATE:
30,000,000
DEMAND $______________ OTHER ______________ JUDGE _________________________________ DOCKET NUMBER_________________
Check YES only if demanded in complaint

JURY DEMAND: ✖ YES NO NOTE: You must also submit at the time of filing the Statement of Relatedness form (Form IH-32).
Case 1:24-cv-01457 Document 1-1 Filed 02/26/24 Page 2 of 2
(PLACE AN x IN ONE BOX ONLY) ORIGIN
Multidistrict Appeal to District
✖ 1 Original 2 Removed from 3 Remanded 4 Reinstated or 5 Transferred from 6 Litigation
7 Judge from
Proceeding State Court from Reopened (Specify District)
(Transferred) Magistrate Judge
Appellate
a. all parties represented Court
8 Multidistrict Litigation (Direct File)
b. At least one party
is pro se.
(PLACE AN x IN ONE BOX ONLY) BASIS OF JURISDICTION IF DIVERSITY, INDICATE
1 U.S. PLAINTIFF 2 U.S. DEFENDANT ✖ 3 FEDERAL QUESTION 4 DIVERSITY CITIZENSHIP BELOW.
(U.S. NOT A PARTY)
CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES ONLY)

(Place an [X] in one box for Plaintiff and one box for Defendant)
PTF DEF PTF DEF PTF DEF

CITIZEN OF THIS STATE [ ]1 [ ]1 CITIZEN OR SUBJECT OF A [ ]3[ ]3 INCORPORATED and PRINCIPAL PLACE [ ]5 [ ]5
FOREIGN COUNTRY OF BUSINESS IN ANOTHER STATE
CITIZEN OF ANOTHER STATE [ ]2 [ ]2 INCORPORATED or PRINCIPAL PLACE [ ]4[ ]4 FOREIGN NATION [ ]6 [ ]6

OF BUSINESS IN THIS STATE
PLAINTIFF(S) ADDRESS(ES) AND COUNTY(IES)
DEFENDANT(S) ADDRESS(ES) AND COUNTY(IES)
DEFENDANT(S) ADDRESS UNKNOWN

REPRESENTATION IS HEREBY MADE THAT, AT THIS TIME, I HAVE BEEN UNABLE, WITH REASONABLE DILIGENCE, TO ASCERTAIN
THE RESIDENCE ADDRESSES OF THE FOLLOWING DEFENDANTS:
COURTHOUSE ASSIGNMENT
I hereby certify that this case should be assigned to the courthouse indicated below pursuant to Local Rule for Division of Business 18, 20 or 21.
Check one: THIS ACTION SHOULD BE ASSIGNED TO: WHITE PLAINS ✖ MANHATTAN
DATE 2/26/2024 ADMITTED TO PRACTICE IN THIS DISTRICT

SIGNATURE OF ATTORNEY OF RECORD [ ] NO
[✖] YES (DATE ADMITTED Mo.02
_______ Yr. 2024
_______)
RECEIPT # Attorney Bar Code #
Magistrate Judge is to be designated by the Clerk of the Court.
Magistrate Judge _________________________________________________________ is so Designated.
Ruby J. Krajick, Clerk of Court by _____________ Deputy Clerk, DATED _____________________.
UNITED STATES DISTRICT COURT (NEW YORK SOUTHERN)
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Case 1:24-cv-01457 Document 1 Filed 02/26/24 Page 1 of 73

UNITED STATES FEDERAL COURT

Plaintiff, Case Number: 24-1457

SEAN COMBS, Jury Demand

JURISDICTION AND VENUE

Defendant Sean Combs

Defendant Justin Dior Combs

Lucian Charles Grainge

Kristina Khorram, Chief of Staff to Sean "Diddy" Combs

15. Defendant Combs Enterprises is a diverse portfolio of businesses and investments

RODNEY LIL ROD JONES

Mr. Jones, the Child Prodigy

CHALICE RECORDING STUDIOS SHOOTING

Aftermath of the Shooting of G

MR. JONES WAS SEXUALLY HARASSED, AND ASSAULTED BY MR. COMBS

THANKSGIVING 2022, MR. JONES IS SEXUALLY ASSAULTED BY

TRAFFICKING AND VICTIMS’ PROTECTION ACT

Booby Trap on the River

Mr. Combs With an Underage Female Sex Worker

Justin Combs With an

THE LOVE ALBUM

DeForrest Taylor Threatening Mr. Jones

MR. COMBS USED HIS POWER, AND INFLUENCE TO

DEFENDANTS ETHIOPIA HABTEMARIAM, LUCIAN CHARLES GRAINGE,

DEFENDANT KRISTINA KHORRAM IS THE GHISLAINE MAXWELL

Brendan Paul and Mr. Combs

d. Frankie Santella20: Works alongside Brendan. While Brendan acquires, and

Frankie Santella and Sean Combs

MR. COMBS IS ALLOWED TO WREAK HAVOC

FIRST CAUSE OF ACTION

SECOND CAUSE OF ACTION

FOURTH CAUSE OF ACTION

FIFTH CAUSE OF ACTION

SIXTH CAUSE OF ACTION

SEVENTH CAUSE OF ACTION

EIGHT CAUSE OF ACTION

NINTH CAUSE OF ACTION

TENTH CAUSE OF ACTION

THIRTEENTH CAUSE OF ACTION

Habtemariam, Motown Records, Love Records, and Universal Music Group’s

FIFTEENTH CAUSE OF ACTION

325. As an example of how Defendants Lucian Charles Grainge, Ethiopia Habtemariam,

PRAYER FOR RELIEF

Dated: February 26, 2024

Electronically Stored Information:

Dated: February 26, 2024

DEMAND FOR INSURANCE COVERAGE

Dated: February 26, 2024

TVPA, Fed. Rico

Judge Previously Assigned

IS THIS AN INTERNATIONAL ARBITRATION CASE? No Yes

(PLACE AN [x] IN ONE BOX ONLY) NATURE OF SUIT

CONTRACT PERSONAL INJURY PERSONAL INJURY FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES

Check if demanded in complaint:

Check YES only if demanded in complaint

CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES ONLY)

PTF DEF PTF DEF PTF DEF

CITIZEN OF ANOTHER STATE [ ]2 [ ]2 INCORPORATED or PRINCIPAL PLACE [ ]4[ ]4 FOREIGN NATION [ ]6 [ ]6

PLAINTIFF(S) ADDRESS(ES) AND COUNTY(IES)

Ruby J. Krajick, Clerk of Court by _ Deputy Clerk, DATED _________.