Case #1:24-cv-01457 · United States District Court, Southern District of New York

Jones v. Combs et al

Filed February 26, 2024 Judge Judge J. Paul Oetken
Open Sean Combs Justin Dior Combs Lucian Charles Grainge Cuba Gooding Jr. Kristina Khorram Love Records Motown Records Universal Music Group Combs Global Enterprises
Contains 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.
Parties
Rodney 'Lil' Rod' Jones Plaintiff
Sean Combs 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 became famous 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 is domiciled in California and Florida.
Justin Dior Combs 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 is domiciled in California.
Lucian Charles Grainge Defendant Lucian Charles Grainge is the CEO of Defendant Universal Music Group. Upon information and belief, Defendant Lucian Charles Grainge is domiciled in California. Defendant Lucian Charles Grainge, in his capacity as CEO of UMG, authorized Motown Records and Universal Music Group to enter into a general business partnership agreement and to provide financial resources to their general business partners, Defendants Sean Combs and Love Records, Inc.
Cuba Gooding Jr. Defendant Cuba Gooding, Jr. was a relevant actor who has fallen from grace due to several sexual assault lawsuits and a recent guilty plea for sexual assault. Upon information and belief, Defendant Gooding, Jr. is domiciled in New York.
Kristina Khorram Defendant Kristina Khorram is the Chief of Staff to Sean “Diddy” Combs, Combs Global Enterprises. Upon information and belief, she is domiciled in California. Defendant Khorram manages the day-to-day operation of the Combs RICO and TVPA Enterprises.
Love Records Defendant Love Records is a record label with a principal place of business located in California and Delaware. Defendant Combs founded Defendant Love Records. According to their website, Defendant Motown Records helped Sean Combs establish Love Records and had a distribution deal for the Love Album.
Motown Records Defendant Motown Records is a record label with a principal place of business located at 1750 Vine St, Los Angeles, CA. According to a Declaration by former Motown Chairwoman and CEO Ethiopia Habtemariam, Motown Records, with the consent of Defendant UMG, and presumably, Ms. Habtemariam's direct supervisor, Defendant Lucian Grainge, entered a general partnership, as that term is defined by the laws of the State of New York, with Defendants Love Records, Inc. and Sean Combs.
Universal Music Group Defendant Universal Music Group is a record label with a principal place of business located at 2220 Colorado Avenue in Santa Monica, California, and 1755 Broadway #6, New York, NY 10019. Lucian Grainge is the Chairman & CEO of Universal Music Group. Defendant Lucian Charles Grainge, as CEO of UMG, authorized Universal Music Group to enter a general business partnership with Love Records, Inc. and Sean Combs. Additionally, according to former Motown Records Chairwoman, Ms. Habtemariam, they provided funding and/or reimbursements for expenses associated with the recording cost of the Love Album. The Love Album was released on September 23, 2023.
Combs Global Enterprises Defendant Combs Global Enterprises is a diverse portfolio of businesses and investments, including music, fashion, fragrance, beverage, marketing, film, television, and media properties. They have a principal place of business located in New York, New York.
Dismissed defendants: ETHIOPIA HABTEMARIAM, CHALICE RECORDING STUDIOS, LUCIAN CHARLES GRAINGE, MOTOWN RECORDS, UNIVERSAL MUSIC GROUP, JUSTIN COMBS, CUBA GOODING, JR.
Factual Allegations
Disclaimer: allegations as pled by the plaintiff, summarized by Grok.

From September 2022 to November 2023, Rodney Jones produced nine songs for Sean Combs' 'The Love Album: Off the Grid,' living with Combs in Los Angeles, New York, Miami, and on a yacht in the U.S. Virgin Islands. During this period, Jones alleges Combs sexually harassed and assaulted him through unsolicited groping in multiple locations, attempted to groom him for homosexuality using producer Stevie J’s influence, and forced him to solicit sex workers, including an assault by Yung Miami’s cousin on Thanksgiving 2022 in Miami. On September 12, 2022, at Chalice Recording Studios in Los Angeles, Jones witnessed a shooting involving Combs and Justin Combs, where 'G' was shot in a restroom; Combs allegedly coerced Jones to lie to police about it being a drive-by. Jones claims Combs’ associates, including Kristina Khorram, facilitated drug distribution and sex trafficking, supported by Universal Music Group (UMG), Motown Records, and Love Records through cash payments and concealment, causing him PTSD, anxiety, and financial losses from an unpaid oral contract for $20,000 per song plus royalties.

Prayer for Relief

Declaratory judgment that Defendants' actions violate New York laws; compensatory damages for economic/non-economic losses (lost income, emotional distress, etc.); punitive damages; prejudgment interest; costs including attorneys' fees/expert fees; other just relief; jury trial demanded.

Causes of Action
FIRST 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)
SECOND SEXUAL ASSAULT AND SEXUAL HARASSMENT
THIRD SEXUAL ASSAULT
FOURTH PREMISES LIABILITY FOR THE SEXUAL ASSAULT COMMITTED BY JANE DOE 1 (YUNG MIAMI’S COUSIN)
FIFTH PREMISES LIABILITY FOR THE SEXUAL ASSAULT COMMITTED BY CUBA GOODING, JR.
SIXTH TRAFFICKING AND VICTIMS’ PROTECTION ACT
SEVENTH 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
EIGHTH NIED (FOR SEXUAL ASSAULT)
NINTH NIED (FOR SEXUAL ASSAULT)
TENTH IIED (FOR SEXUAL ASSAULT)
ELEVENTH IIED (FOR SEXUAL ASSAULT)
TWELFTH IIED (FOR SEXUAL ASSAULT)
THIRTEENTH NIED (FOR SEXUAL ASSAULT)
FOURTEENTH SEXUAL ASSAULT
FIFTEENTH KNOWING BENEFICIARY IN A SEX-TRAFFICKING VENTURE IN VIOLATION OF THE TRAFFICKING VICTIMS’ PROTECTION ACT, 18 U.S.C. §§ 1591(A)(2), 1595
SIXTEENTH OBSTRUCTION OF THE ENFORCEMENT OF THE TRAFFICKING VICTIM PROTECTION ACT, 18 U.S.C. § 1591(d)
SEVENTEENTH BREACH OF ORAL CONTRACT
Court Dates
DateTypeDescription
Jul 14, 2026 Other Conference to discuss the Requests for Admissions-related issues
Docket
Date No. Description
Feb 26, 2024 1 FILING ERROR DEFICIENT PLEADING - PDF ERROR - COMPLAINT against ABC CORPORATIONS. 1-10, CHALICE RECORDING STUDIOS, JUSTIN DIOR COMBS, SEAN COMBS, COMBS GLOBAL ENTERPRISES, LUCIAN CHARLES GRAINGE, ETHIOPIA HABTEMARIAM, JOHN and JANE DOES 1-10, KRISTINA KHORRAM, LOVE RECORDS, MOTOWN RECORDS, UNIVERSAL MUSIC GROUP. (Filing Fee $ 405.00, Receipt Number ANYSDC-28998805)Document filed by RODNEY JONES. (Attachments: # 1 Civil Cover Sheet Civil Cover Sheet).(Blackburn, Tyrone) Modified on 2/27/2024 (jgo). (Entered: 02/26/2024) View PDF Civil Cover Sheet Civil Cover Sheet).(Blackburn, Tyrone) Modified on 2/27/2024 (jgo). (Entered: 02/26/2024
Mar 4, 2024 2 COMPLAINT against ABC CORPORATIONS. 1-10, CHALICE RECORDING STUDIOS, JUSTIN DIOR COMBS, SEAN COMBS, COMBS GLOBAL ENTERPRISES, LUCIAN CHARLES GRAINGE, ETHIOPIA HABTEMARIAM, JOHN and JANE DOES 1-10, KRISTINA KHORRAM, LOVE RECORDS, MOTOWN RECORDS, UNIVERSAL MUSIC GROUP. (Filing Fee $ 405.00, Receipt Number ANYSDC-29026491)Document filed by RODNEY JONES..(Blackburn, Tyrone) (Entered: 03/04/2024) View PDF
Mar 4, 2024 3 CIVIL COVER SHEET filed..(Blackburn, Tyrone) (Entered: 03/04/2024) View PDF
Mar 4, 2024 4 FILING ERROR - SUMMONS REQUEST PDF ERROR - REQUEST FOR ISSUANCE OF SUMMONS as to SEAN COMBS, JUSTIN DIOR COMBS, ETHIOPIA HABTEMARIAM, LUCIAN CHARLES GRAINGE, KRISTINA KHORRAM, CHALICE RECORDING STUDIOS, LOVE RECORDS, MOTOWN RECORDS, UNIVERSAL MUSIC GROUP, COMBS GLOBAL ENTERPRISES, re: 2 Complaint,. Document filed by RODNEY JONES. (Attachments: # 1 Supplement Defendants List Rider-Summons).(Blackburn, Tyrone) Modified on 3/5/2024 (jgo). (Entered: 03/04/2024) View PDF Supplement Defendants List Rider-Summons).(Blackburn, Tyrone) Modified on 3/5/2024 (jgo). (Entered: 03/04/2024
Mar 19, 2024 5 FILING ERROR - DEFICIENT DOCKET ENTRY - FIRST MOTION for Rodney Diggs, Esq. to Appear Pro Hac Vice For Plaintiff Rodney Jones. Filing fee $ 200.00, receipt number ANYSDC-29102400. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Rodney Jones. (Attachments: # 1 Proposed Order Proposed Order).(Blackburn, Tyrone) Modified on 3/20/2024 (rju). (Entered: 03/19/2024) View PDF Proposed Order Proposed Order).(Blackburn, Tyrone) Modified on 3/20/2024 (rju). (Entered: 03/19/2024
Mar 23, 2024 6 NOTICE OF VOLUNTARY DISMISSAL pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff(s) and or their counsel(s), hereby give notice that the above-captioned action is voluntarily dismissed, with prejudice and without costs against the defendant(s) Ethiopia Habtemariam. Document filed by Rodney Jones. Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers)...(Blackburn, Tyrone) (Entered: 03/23/2024) View PDF
Mar 23, 2024 7 NOTICE OF VOLUNTARY DISMISSAL pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff(s) and or their counsel(s), hereby give notice that the above-captioned action is voluntarily dismissed, without prejudice and without costs against the defendant(s) Chalice Recording Studios. Document filed by Rodney Jones. Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers)...(Blackburn, Tyrone) (Entered: 03/23/2024) View PDF
Mar 23, 2024 8 FIRST MOTION to Amend/Correct 6 Notice of Voluntary Dismissal, . Document filed by Rodney Jones..(Blackburn, Tyrone) (Entered: 03/23/2024) View PDF
Mar 23, 2024 9 FIRST LETTER addressed to Judge J. Paul Oetken from Tyrone A. Blackburn, Esq. dated 03/23/24 re: Voluntary Dismissal of Defendants Ethiopia Habtemariam, and Chalice Recording Studios pursuant to F.R.C.P. 41(a)(1)(A)(i). Document filed by Rodney Jones..(Blackburn, Tyrone) (Entered: 03/23/2024) View PDF
Mar 25, 2024 10 NOTICE OF APPEARANCE by Donald S. Zakarin on behalf of Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Universal Music Group..(Zakarin, Donald) (Entered: 03/25/2024) View PDF
Mar 25, 2024 11 LETTER addressed to Judge J. Paul Oetken from Donald S. Zakarin, Esq. dated March 25, 2024 Document filed by Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Universal Music Group..(Zakarin, Donald) (Entered: 03/25/2024) View PDF
Mar 25, 2024 12 NOTICE OF APPEARANCE by James A. Janowitz on behalf of Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Universal Music Group..(Janowitz, James) (Entered: 03/25/2024) View PDF
Mar 25, 2024 13 NOTICE OF APPEARANCE by William Laurence Charron on behalf of Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Universal Music Group..(Charron, William) (Entered: 03/25/2024) View PDF
Mar 25, 2024 14 NOTICE OF APPEARANCE by Nicholas George Saady on behalf of Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Universal Music Group..(Saady, Nicholas) (Entered: 03/25/2024) View PDF
Mar 25, 2024 15 NOTICE OF APPEARANCE by Alina Jamil Mian on behalf of Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Universal Music Group..(Mian, Alina) (Entered: 03/25/2024) View PDF
Mar 25, 2024 16 FILING ERROR - WRONG EVENT TYPE SELECTED FROM MENU - SECOND AMENDED COMPLAINT amending 2 Complaint, against ABC Corporations. 1-10, Justin Dior Combs, Sean Combs, Combs Global Enterprises, Lucian Charles Grainge, John and Jane Does 1-10, Kristina Khorram, Love Records, Motown Records, Universal Music Group, Cuba Gooding, Jr. with JURY DEMAND.Document filed by Rodney Jones. Related document: 2 Complaint,. (Attachments: # 1 Affidavit B, # 2 Affidavit A).(Blackburn, Tyrone) Modified on 3/26/2024 (jgo). (Entered: 03/25/2024) View PDF Affidavit B
Mar 26, 2024 17 ORDER granting 8 Motion to Amend/Correct: Granted. So ordered. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (nhb) (Entered: 03/26/2024) No document
Mar 26, 2024 18 NOTICE OF VOLUNTARY DISMISSAL PURSUANT TO F.R.C.P. 41(a)(1)(A)(i). Pursuant to F.R.C.P. 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff Rodney Jones hereby gives notice that the above-captioned action is voluntarily dismissed, WITHOUT prejudice, against Defendant Chalice Recording Studios only. Plaintiff will refile against Defendant Chalice Recording Studios in Los Angeles, California. So ordered. The Clerk of Court is directed to terminate the below-named defendant from this case., (Chalice Recording Studios terminated.) (Signed by Judge J. Paul Oetken on 3/26/24) (yv) (Entered: 03/26/2024) View PDF
Mar 26, 2024 19 NOTICE OF VOLUNTARY DISMISSAL PURSUANT TO F.R.C.P. 41(a)(1)(A)(ii). Pursuant to F.R.C.P. 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff Rodney Jones hereby gives notice that the above-captioned action is voluntarily dismissed, with prejudice, against Defendant Ethiopia Habtemariam only. So ordered. The Clerk of Court is directed to terminate the below-named defendant from this case., (Ethiopia Habtemariam terminated.) (Signed by Judge J. Paul Oetken on 3/26/24) (yv) (Entered: 03/26/2024) View PDF
Mar 27, 2024 20 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Corporate Parent Universal Music Group N.V., Other Affiliate Compagnie de Cornouaille SAS, Other Affiliate PS VII Master, L.P. for Motown Records, Universal Music Group. Document filed by Motown Records, Universal Music Group..(Saady, Nicholas) (Entered: 03/27/2024) View PDF
Mar 27, 2024 21 WAIVER OF SERVICE RETURNED EXECUTED. Document filed by Universal Music Group..(Saady, Nicholas) (Entered: 03/27/2024) View PDF
Mar 27, 2024 22 WAIVER OF SERVICE RETURNED EXECUTED. Document filed by Motown Records..(Saady, Nicholas) (Entered: 03/27/2024) View PDF
Mar 27, 2024 23 WAIVER OF SERVICE RETURNED EXECUTED. Document filed by Lucian Charles Grainge..(Saady, Nicholas) (Entered: 03/27/2024) View PDF
Mar 27, 2024 24 MOTION to Dismiss the First Amended Complaint. Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group. Responses due by 4/10/2024 Return Date set for 4/17/2024 at 11:59 PM..(Saady, Nicholas) (Entered: 03/27/2024) View PDF
Mar 27, 2024 25 MEMORANDUM OF LAW in Support re: 24 MOTION to Dismiss the First Amended Complaint. . Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group..(Saady, Nicholas) (Entered: 03/27/2024) View PDF
Mar 27, 2024 26 DECLARATION of Donald S. Zakarin in Support re: 24 MOTION to Dismiss the First Amended Complaint.. Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group. (Attachments: # 1 Exhibit 1 - Declaration of Sir Lucian Grainge, # 2 Exhibit 2 - Declaration of Martha Braithwaite, # 3 Exhibit 3 - Declaration of Ethiopia Habtemariam, # 4 Exhibit 4 - First Amended Complaint, # 5 Exhibit 5 - Love Records Incorporation, # 6 Exhibit 6 - Discover Music Article, # 7 Exhibit 7 - List of UMG Labels, # 8 Exhibit 8 - Billboard & Revolt Articles, # 9 Exhibit 9 - Ventura v. Combs et al, # 10 Exhibit 10 - March 4, 2024 Letter from D. Zakarin to T. Blackburn).(Saady, Nicholas) (Entered: 03/27/2024) View PDF Exhibit 1 - Declaration of Sir Lucian Grainge Exhibit 2 - Declaration of Martha Braithwaite Exhibit 3 - Declaration of Ethiopia Habtemariam Exhibit 4 - First Amended Complaint Exhibit 5 - Love Records Incorporation Exhibit 6 - Discover Music Article Exhibit 7 - List of UMG Labels Exhibit 8 - Billboard & Revolt Articles Exhibit 9 - Ventura v. Combs et al
Mar 27, 2024 27 FILING ERROR - DEFICIENT PLEADING - FRCP RULE 15 NON-COMPLIANCE -SECOND AMENDED COMPLAINT amending 16 Amended Complaint,, against ABC Corporations. 1-10, Justin Dior Combs, Sean Combs, Combs Global Enterprises, Cuba Gooding, Jr., Lucian Charles Grainge, John and Jane Does 1-10, Kristina Khorram, Love Records, Motown Records, Universal Music Group with JURY DEMAND.Document filed by Rodney Jones. Related document: 16 Amended Complaint,,. (Attachments: # 1 Affidavit Attachment B, # 2 Exhibit Attachment A).(Blackburn, Tyrone) Modified on 3/28/2024 (vf). (Entered: 03/27/2024) View PDF Affidavit Attachment B
Mar 28, 2024 28 FIRST LETTER addressed to Judge J. Paul Oetken from Tyrone A. Blackburn, Esq. dated 3/27/24 re: Defendants Bad Faith Motion To Dismiss. Document filed by Rodney Jones..(Blackburn, Tyrone) (Entered: 03/28/2024) View PDF
Mar 28, 2024 29 LETTER addressed to Judge J. Paul Oetken from Donald S. Zakarin, Esq. dated March 28, 2024 Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group. (Attachments: # 1 Exhibit A - March 4, 2024 Letter from D. Zakarin to T. Blackburn).(Saady, Nicholas) (Entered: 03/28/2024) View PDF Exhibit A - March 4, 2024 Letter from D. Zakarin to T. Blackburn).(Saady, Nicholas
Mar 28, 2024 30 FIRST LETTER MOTION for Leave to File Second Amended Complaint addressed to Judge J. Paul Oetken from Tyrone A. Blackburn, Esq. dated 3/28/24. Document filed by Rodney Jones. (Attachments: # 1 Supplement Proposed Second Amended Complaint, # 2 Exhibit A, # 3 Exhibit B).(Blackburn, Tyrone) (Entered: 03/28/2024) View PDF Supplement Proposed Second Amended Complaint Exhibit A
Apr 1, 2024 31 LETTER RESPONSE in Opposition to Motion addressed to Judge J. Paul Oetken from Donald S. Zakarin dated April 1, 2024 re: 30 FIRST LETTER MOTION for Leave to File Second Amended Complaint addressed to Judge J. Paul Oetken from Tyrone A. Blackburn, Esq. dated 3/28/24. . Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group. (Attachments: # 1 Exhibit 1 - Declaration of Ethiopia Habtemariam, # 2 Exhibit 2 - Lin Letter to Blackburn, # 3 Exhibit 3 - Declaration of Martha Braithwaite, # 4 Exhibit 4 - Blackburn X Statement).(Saady, Nicholas) (Entered: 04/01/2024) View PDF Exhibit 1 - Declaration of Ethiopia Habtemariam Exhibit 2 - Lin Letter to Blackburn Exhibit 3 - Declaration of Martha Braithwaite Exhibit 4 - Blackburn X Statement).(Saady, Nicholas
Apr 2, 2024 32 ORDER: Counsel for the parties shall appear for a telephone conference on April 9, 2024, at 3:30 p.m. At the scheduled time, counsel should call (888) 557-8511 and enter passcode 9300838. So ordered. (HEREBY ORDERED by Judge J. Paul Oetken) (Text Only Order) (nhb) (Entered: 04/02/2024) No document
Apr 4, 2024 33 LETTER addressed to Judge J. Paul Oetken from Donald S. Zakarin, Esq. dated April 4, 2024 Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group. (Attachments: # 1 Exhibit 1 - Judge Cote Order).(Saady, Nicholas) (Entered: 04/04/2024) View PDF Exhibit 1 - Judge Cote Order).(Saady, Nicholas
Apr 9, 2024 34 FIRST REPLY MEMORANDUM OF LAW in Support re: 30 FIRST LETTER MOTION for Leave to File Second Amended Complaint addressed to Judge J. Paul Oetken from Tyrone A. Blackburn, Esq. dated 3/28/24. . Document filed by Rodney Jones. (Attachments: # 1 Exhibit A, # 2 Exhibit B).(Blackburn, Tyrone) (Entered: 04/09/2024) View PDF Exhibit A Exhibit B).(Blackburn, Tyrone
Apr 9, 2024 35 FIRST LETTER addressed to Judge J. Paul Oetken from Tyrone A. Blackburn, Esq. dated 04/09/24 re: Response to Defendants letter dated 4/4/24. Document filed by Rodney Jones..(Blackburn, Tyrone) (Entered: 04/09/2024) View PDF
Apr 9, 2024 36 ORDER granting 30 Letter Motion for Leave to File Document: As discussed during the telephone conference held on April 9, 2024, Plaintiff's motion for leave to file a second amended complaint is granted. Plaintiff shall file the proposed second amended complaint on ECF as a separate docket entry. The UMG Defendants shall file their motion to dismiss by April 30, 2024. Plaintiff's opposition shall be filed within three weeks of the filing of Defendants' motion and any reply shall be filed within two weeks of the filing of Plaintiff's opposition. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (Oetken, J.) (Entered: 04/09/2024) No document
Apr 9, 2024 37 ORDER denying without prejudice 24 Motion to Dismiss. The UMG Defendants' motion to dismiss the First Amended Complaint is denied as moot and without prejudice to re-filing in light of the filing of a Second Amended Complaint. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (Oetken, J.) (Entered: 04/09/2024) No document
Apr 12, 2024 38 SECOND AMENDED COMPLAINT amending 27 Amended Complaint,, 16 Amended Complaint,, against ABC Corporations. 1-10, Justin Dior Combs, Sean Combs, Combs Global Enterprises, Cuba Gooding, Jr., Lucian Charles Grainge, John and Jane Does 1-10, Kristina Khorram, Love Records, Motown Records, Universal Music Group with JURY DEMAND.Document filed by Rodney Jones. Related document: 27 Amended Complaint,, 16 Amended Complaint,,. (Attachments: # 1 Exhibit B, # 2 Exhibit A).(Blackburn, Tyrone) (Entered: 04/12/2024) View PDF Exhibit B
Apr 17, 2024 39 FILING ERROR - DEFICIENT - SUMMONS REQUEST PDF ERROR - REQUEST FOR ISSUANCE OF SUMMONS as to Sean Combs, Justin Combs, Cuba Gooding, Jr., Kristina Khorram, Love Records, Combs Global, re: 38 Amended Complaint,,. Document filed by Rodney Jones. (Attachments: # 1 Supplement Defendant List).(Blackburn, Tyrone) Modified on 4/18/2024 (vf). (Entered: 04/17/2024) View PDF Supplement Defendant List).(Blackburn, Tyrone) Modified on 4/18/2024 (vf). (Entered: 04/17/2024
Apr 24, 2024 40 MOTION to Dismiss Plaintiff's Second Amended Complaint. Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group..(Saady, Nicholas) (Entered: 04/24/2024) No document
Apr 24, 2024 41 MEMORANDUM OF LAW in Support re: 40 MOTION to Dismiss Plaintiff's Second Amended Complaint. . Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group..(Saady, Nicholas) (Entered: 04/24/2024) View PDF
Apr 24, 2024 42 DECLARATION of Donald S. Zakarin in Support re: 40 MOTION to Dismiss Plaintiff's Second Amended Complaint.. Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group. (Attachments: # 1 Exhibit 1 - Declaration of Sir Lucian Grainge, # 2 Exhibit 2 - Declaration of Martha Braithwaite, # 3 Exhibit 3 - Declaration of Ethiopia Habtemariam, # 4 Exhibit 4 - Second Amended Complaint, # 5 Exhibit 5 - Ventura v. Combs et al, # 6 Exhibit 6 - Transcript of April 9, 2024 Court Telephone Conference, # 7 Exhibit 7 - Blackburn 3/25 Email to Davis, # 8 Exhibit 8 - Zakarin 3/4 Letter to Blackburn).(Saady, Nicholas) (Entered: 04/24/2024) View PDF Exhibit 1 - Declaration of Sir Lucian Grainge Exhibit 2 - Declaration of Martha Braithwaite Exhibit 3 - Declaration of Ethiopia Habtemariam Exhibit 4 - Second Amended Complaint Exhibit 5 - Ventura v. Combs et al Exhibit 6 - Transcript of April 9, 2024 Court Telephone Conference Exhibit 7 - Blackburn 3/25 Email to Davis Exhibit 8 - Zakarin 3/4 Letter to Blackburn).(Saady, Nicholas
Apr 24, 2024 43 FILING ERROR - SUMMONS REQUEST PDF ERROR - REQUEST FOR ISSUANCE OF SUMMONS as to Sean Combs, Justin Combs, Cuba Gooding, Jr., Lucian Charles Grainge, Kristina Khorram, Love Records, Motown Records, Universal Music Group, and Combs Global Enterprises, re: 38 Amended Complaint,,. Document filed by Rodney Jones. (Attachments: # 1 Supplement Defendants List Rider-Summons).(Blackburn, Tyrone) Modified on 4/25/2024 (jgo). (Entered: 04/24/2024) View PDF Supplement Defendants List Rider-Summons).(Blackburn, Tyrone) Modified on 4/25/2024 (jgo). (Entered: 04/24/2024
Apr 25, 2024 44 REQUEST FOR ISSUANCE OF SUMMONS as to Sean Combs, Justin Dior Combs, Cuba Gooding, Jr., Lucian Charles Grainge, Kristina Khorram, Love Records, Motown Records, Universal Music Group, Combs Global Enterprises, re: 38 Amended Complaint,,. Document filed by Rodney Jones. (Attachments: # 1 Supplement Defendants List Rider-Summons).(Blackburn, Tyrone) (Entered: 04/25/2024) View PDF Supplement Defendants List Rider-Summons).(Blackburn, Tyrone
Apr 26, 2024 45 ELECTRONIC SUMMONS ISSUED as to Justin Dior Combs, Sean Combs, Combs Global Enterprises, Cuba Gooding, Jr., Lucian Charles Grainge, Kristina Khorram, Love Records, Motown Records, Universal Music Group..(jgo) (Entered: 04/26/2024) View PDF
May 13, 2024 46 SUMMONS RETURNED EXECUTED Summons and Amended Complaint,, served. Kristina Khorram served on 4/29/2024, answer due 5/20/2024. Service was accepted by John Doe, Receptionist. Service was made by Mail. Document filed by Rodney Jones..(Blackburn, Tyrone) (Entered: 05/13/2024) View PDF
May 13, 2024 47 FILING ERROR - WRONG EVENT TYPE SELECTED FROM MENU - STIPULATION OF VOLUNTARY DISMISSAL It is hereby stipulated and agreed by and between the parties and/or their respective counsel(s) that the above-captioned action is voluntarily dismissed, with prejudice against the defendant(s) Lucian Charles Grainge, Motown Records, Universal Music Group and without costs pursuant to Rule 41(a)(1)(A)(ii) of the Federal Rules of Civil Procedure. Document filed by Rodney Jones. Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers).. (Attachments: # 1 Affidavit Declaration of Tyrone Blackburn).(Blackburn, Tyrone) Modified on 5/14/2024 (tp). (Entered: 05/13/2024) View PDF Affidavit Declaration of Tyrone Blackburn).(Blackburn, Tyrone) Modified on 5/14/2024 (tp). (Entered: 05/13/2024
May 13, 2024 48 FIRST LETTER addressed to Judge J. Paul Oetken from Tyrone Blackburn, Esq. dated 5/13/24 re: Update the Court on the status of service of the Summons and Complaint. Document filed by Rodney Jones..(Blackburn, Tyrone) (Entered: 05/13/2024) View PDF
May 14, 2024 49 FIRST MOTION to Dismiss with prejudice of all claims made in the Second Amended Complaint against Lucian Charles Grainge, Motown Records and Universal Music Group. Document filed by Rodney Jones. (Attachments: # 1 Affidavit Declaration Tyrone Blackburn).(Blackburn, Tyrone) (Entered: 05/14/2024) View PDF Affidavit Declaration Tyrone Blackburn).(Blackburn, Tyrone
May 14, 2024 50 DECLARATION of Donald S. Zakarin in Support re: 49 FIRST MOTION to Dismiss with prejudice of all claims made in the Second Amended Complaint against Lucian Charles Grainge, Motown Records and Universal Music Group.. Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group..(Saady, Nicholas) (Entered: 05/14/2024) View PDF
May 14, 2024 51 NOTICE OF MOTION FOR DISMISSAL OF ALL CLAIMS AND ALLEGATIONS AGAINST LUCIAN CHARLES GRAINGE, MOTOWN RECORDS AND UMG RECORDINGS, INC. (INCORRECTLY NAMED AS UNIVERSAL MUSIC GROUP): PLEASE TAKE NOTICE that, upon the supporting Declaration of Tyrone A. Blackburn dated May 13, 2024, and all prior proceedings heretofore had and all papers filed herein, Plaintiff Rodney Jones will move this Court, at a date and time to be determined by the Court, for an Order, pursuant to Rules 15, 21 and 41 of the Federal Rules of Civil Procedure, dismissing all claims and striking all allegations made against Lucian Charles Grainge, Motown Records, UMG Recordings, Inc. (incorrectly named as Universal Music Group) in the Second Amended Complaint with prejudice and removing Lucian Charles Grainge, Motown Records, UMG Recordings, Inc. (incorrectly named as Universal Music Group) from the caption of this action. Granted and so ordered. The Clerk of Court is directed to terminate the below-named defendants from this case. The motion at ECF No. 40 is denied as moot. The Clerk is directed to close ECF Nos. 40 and 49. Universal Music Group, Lucian Charles Grainge and Motown Records terminated. (Signed by Judge J. Paul Oetken on 5/14/2024) (ate) (Entered: 05/14/2024) View PDF
May 17, 2024 52 MOTION for Sanctions . Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group..(Saady, Nicholas) (Entered: 05/17/2024) View PDF
May 17, 2024 53 MEMORANDUM OF LAW in Support re: 52 MOTION for Sanctions . . Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group..(Saady, Nicholas) (Entered: 05/17/2024) View PDF
May 17, 2024 54 DECLARATION of Donald S. Zakarin in Support re: 52 MOTION for Sanctions .. Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group. (Attachments: # 1 Exhibit A (Part 1 of 3) - Zakarin Rule 11 Declaration and Exhibits, # 2 Exhibit A (Part 2 of 3) - Zakarin Rule 11 Declaration and Exhibits, # 3 Exhibit A (Part 3 of 3) - Zakarin Rule 11 Declaration and Exhibits, # 4 Exhibit B - March 4, 2024 Zakarin Letter to Blackburn, # 5 Exhibit C - Blackburn Twitter / X Post).(Saady, Nicholas) (Entered: 05/17/2024) View PDF Exhibit A (Part 1 of 3) - Zakarin Rule 11 Declaration and Exhibits Exhibit A (Part 2 of 3) - Zakarin Rule 11 Declaration and Exhibits Exhibit A (Part 3 of 3) - Zakarin Rule 11 Declaration and Exhibits Exhibit B - March 4, 2024 Zakarin Letter to Blackburn Exhibit C - Blackburn Twitter / X Post).(Saady, Nicholas
May 20, 2024 55 FIRST LETTER addressed to Judge J. Paul Oetken from Tyrone A. Blackburn, Esq. dated 5/20/2024 re: Khorram Stip to Answer. Document filed by Rodney Jones. (Attachments: # 1 Supplement Khorram Stip to Answer).(Blackburn, Tyrone) (Entered: 05/20/2024) View PDF Supplement Khorram Stip to Answer).(Blackburn, Tyrone
May 23, 2024 56 STIPULATION: The deadline for Ms. Khorram to answer or otherwise respond to the Second Amended Complaint shall be August 26, 2024. (Signed by Judge J. Paul Oetken on 5/23/2024) (tro) (Entered: 05/23/2024) View PDF
May 24, 2024 57 ORDER: Counsel for Plaintiff and counsel for the UMG Defendants have submitted a number of letters to the Court by email, without a proper request for filing under seal. It is unclear what purpose these letters are intended to serve, other than to accuse the other side of improper conduct in various forms, and the letters do not ask for any relief or action by the Court. The Court will consider the UMG Defendant's motion for sanctions through proper briefing and not through these improperly submitted letters. With respect to the request that the Court "set a schedule for that [sanctions] motion," the Court notes that under SDNY Local Rule 6.1(b), Plaintiff's brief in opposition to the UMG Defendants' motion for sanctions is automatically due in 14 days from the filing of the motion, i.e., on May 31, 2024, and the UMG Defendants' reply brief is due 7 days from the filing of the opposition (absent any order setting a different schedule, which no one has requested). The Court will consider scheduling a hearing or oral argument on the motion after further briefing. (HEREBY ORDERED by Judge J. Paul Oetken) (Text Only Order) (Oetken, J.) (Entered: 05/24/2024) No document
Jun 3, 2024 58 FIRST REPLY MEMORANDUM OF LAW in Opposition re: 52 MOTION for Sanctions . . Document filed by Rodney Jones. (Attachments: # 1 Affidavit Rodney Jones Dec., # 2 Affidavit Declaration-Tyrone Blackburn, # 3 Exhibit 1, # 4 Exhibit 2, # 5 Exhibit 3, # 6 Exhibit 4, # 7 Exhibit 5.1, # 8 Exhibit 5.2, # 9 Exhibit 5.3, # 10 Exhibit 6, # 11 Exhibit 7, # 12 Exhibit 8, # 13 Exhibit 9, # 14 Exhibit 10, # 15 Exhibit 11, # 16 Exhibit 12).(Blackburn, Tyrone) (Entered: 06/03/2024) View PDF Affidavit Rodney Jones Dec. Affidavit Declaration-Tyrone Blackburn Exhibit 1 Exhibit 2 Exhibit 3 Exhibit 4 Exhibit 5.1 Exhibit 5.2 Exhibit 5.3 Exhibit 6 Exhibit 7 Exhibit 8 Exhibit 9 Exhibit 10 Exhibit 11 Exhibit 12).(Blackburn, Tyrone
Jun 3, 2024 59 FIRST LETTER addressed to Judge J. Paul Oetken from Tyrone A. Blackburn, Esq. dated 6/3/2024 re: Opposition to Sanctions Motion Delayed Filing. Document filed by Rodney Jones..(Blackburn, Tyrone) (Entered: 06/03/2024) View PDF
Jun 7, 2024 60 REPLY MEMORANDUM OF LAW in Support re: 52 MOTION for Sanctions . . Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group..(Saady, Nicholas) (Entered: 06/07/2024) View PDF
Jun 7, 2024 61 DECLARATION of Donald S. Zakarin in Support re: 52 MOTION for Sanctions .. Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G).(Saady, Nicholas) (Entered: 06/07/2024) View PDF Exhibit A Exhibit B Exhibit C Exhibit D Exhibit E Exhibit F Exhibit G).(Saady, Nicholas
Jul 15, 2024 62 ORDER: The parties are directed to appear for a hearing on the UMG Defendants Motion for Sanctions (ECF No. 52) on October 16, 2024, at 10:00 a.m. in Courtroom 706 of the Thurgood Marshall United States Courthouse, 40 Foley Square, New York, NY 10007.SO ORDERED. Set Deadlines/Hearing as to ( Motion Hearing set for 10/16/2024 at 10:00 AM in Courtroom 706, 40 Centre Street, New York, NY 10007 before Judge J. Paul Oetken.) (Signed by Judge J. Paul Oetken on 7/15/2024) (sgz) (Entered: 07/15/2024) View PDF
Aug 26, 2024 63 NOTICE OF APPEARANCE by Avraham Chaim Moskowitz on behalf of Kristina Khorram..(Moskowitz, Avraham) (Entered: 08/26/2024) View PDF
Aug 26, 2024 64 NOTICE OF APPEARANCE by Deborah Austern Colson on behalf of Kristina Khorram..(Colson, Deborah) (Entered: 08/26/2024) View PDF
Aug 26, 2024 65 NOTICE OF APPEARANCE by Erica Ashley Wolff on behalf of Sean Combs, Combs Global Enterprises, Love Records..(Wolff, Erica) (Entered: 08/26/2024) No document
Aug 26, 2024 66 MOTION to Dismiss the Second Amended Complaint. Document filed by Sean Combs, Combs Global Enterprises, Love Records. Responses due by 9/9/2024.(Wolff, Erica) (Entered: 08/26/2024) View PDF
Aug 26, 2024 67 MEMORANDUM OF LAW in Support re: 66 MOTION to Dismiss the Second Amended Complaint. . Document filed by Sean Combs, Combs Global Enterprises, Love Records..(Wolff, Erica) (Entered: 08/26/2024) View PDF
Aug 26, 2024 68 NOTICE OF APPEARANCE by Michael Tremonte on behalf of Sean Combs, Combs Global Enterprises, Love Records..(Tremonte, Michael) (Entered: 08/26/2024) No document
Aug 26, 2024 69 NOTICE OF APPEARANCE by Mark Elliot Cuccaro on behalf of Sean Combs, Combs Global Enterprises, Love Records..(Cuccaro, Mark) (Entered: 08/26/2024) No document
Aug 26, 2024 70 NOTICE OF APPEARANCE by Katie Elizabeth Renzler on behalf of Sean Combs, Combs Global Enterprises, Love Records..(Renzler, Katie) (Entered: 08/26/2024) No document
Aug 26, 2024 71 MOTION for Joinder in co-defendants' motion to dismiss. Document filed by Kristina Khorram..(Moskowitz, Avraham) (Entered: 08/26/2024) View PDF
Aug 26, 2024 72 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Love Records..(Wolff, Erica) (Entered: 08/26/2024) View PDF
Aug 26, 2024 73 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Corporate Parent 1169 Group Holdings LLC, Other Affiliate 1169 Corp. for Combs Global Enterprises. Document filed by Combs Global Enterprises..(Wolff, Erica) (Entered: 08/26/2024) View PDF
Sep 9, 2024 74 FIRST LETTER MOTION for Extension of Time to perfect the service of process on Justin Dior Combs and Cuba Gooding, Jr. addressed to Judge J. Paul Oetken from Tyrone Blackburn, Esq. dated September 9, 2024. Document filed by Rodney Jones. (Attachments: # 1 Exhibit Attachment A, # 2 Exhibit Attachment B, # 3 Exhibit Attachment C).(Blackburn, Tyrone) (Entered: 09/09/2024) View PDF Exhibit Attachment A Exhibit Attachment B Exhibit Attachment C).(Blackburn, Tyrone
Sep 17, 2024 75 FIRST LETTER MOTION for Extension of Time to File Response/Reply as to 66 MOTION to Dismiss the Second Amended Complaint., 67 Memorandum of Law in Support of Motion addressed to Judge J. Paul Oetken from Tyrone Blackburn, Esq. dated 9/16/2024. Document filed by Rodney Jones..(Blackburn, Tyrone) (Entered: 09/17/2024) View PDF
Sep 19, 2024 76 ORDER granting 74 Letter Motion for Extension of Time: Granted. Plaintiff shall serve Defendants Justin Dior Combs and Cuba Gooding, Jr. on or before November 8, 2024. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (djh) (Entered: 09/19/2024) No document
Sep 19, 2024 77 ORDER granting 75 Letter Motion for Extension of Time to File Response/Reply: Granted. Plaintiff shall file any opposition to the Combs Defendants' Motion to Dismiss the Second Amended Complaint on or before September 30, 2024. Counsel for Plaintiff is reminded to review and heed all applicable deadlines moving forward. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (djh) (Entered: 09/19/2024) No document
Sep 30, 2024 78 FIRST MEMORANDUM OF LAW in Opposition re: 66 MOTION to Dismiss the Second Amended Complaint. . Document filed by Rodney Jones..(Blackburn, Tyrone) (Entered: 09/30/2024) View PDF
Oct 1, 2024 79 DECLARATION of Tyrone A. Blackburn Esq. in Opposition re: 66 MOTION to Dismiss the Second Amended Complaint.. Document filed by Rodney Jones. (Attachments: # 1 Exhibit 1-Criminal Indictment, # 2 Exhibit 2-SDNY Civil Cases).(Blackburn, Tyrone) (Entered: 10/01/2024) View PDF
Oct 1, 2024 80 LETTER MOTION for Extension of Time to file reply brief addressed to Judge J. Paul Oetken from Erica A. Wolff dated October 1, 2024. Document filed by Sean Combs, Combs Global Enterprises, Love Records..(Wolff, Erica) (Entered: 10/01/2024) View PDF
Oct 2, 2024 81 ORDER granting 80 Motion for Extension of Time: Granted. The Combs Defendants shall file any reply brief in support of their motion to dismiss on or before October 18, 2024. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (djh) (Entered: 10/02/2024) No document
Oct 8, 2024 82 LETTER addressed to Judge J. Paul Oetken from Donald S. Zakarin dated October 8, 2024 Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group..(Saady, Nicholas) (Entered: 10/08/2024) View PDF
Oct 18, 2024 83 REPLY MEMORANDUM OF LAW in Support re: 66 MOTION to Dismiss the Second Amended Complaint. . Document filed by Sean Combs, Combs Global Enterprises, Love Records..(Wolff, Erica) (Entered: 10/18/2024) View PDF
Oct 18, 2024 84 NOTICE of request for permission to join in the Reply Memorandum of Law filed on 10/18/24 on behalf of Mr. Combs. Document filed by Kristina Khorram..(Moskowitz, Avraham) (Entered: 10/18/2024) View PDF
Dec 13, 2024 85 MEMORANDUM AND ORDER granting 49 Motion to Dismiss; denying 52 Motion for Sanctions. For the foregoing reasons, the UMG Defendants' motion for sanctions (ECF No. 52) is DENIED. Plaintiff's motion to voluntarily dismiss all claims in the second amended complaint against Grainge, Motown Records, and UMG (ECF No. 49) is GRANTED, and those claims are dismissed with prejudice. The Clerk of Court is directed to close the motions at Docket Numbers 49 and 52. SO ORDERED. (Signed by Judge J. Paul Oetken on 12/13/2024) (vfr) (Entered: 12/13/2024) View PDF
Mar 24, 2025 86 OPINION AND ORDER re: 71 MOTION for Joinder in co-defendants' motion to dismiss. filed by Kristina Khorram, 66 MOTION to Dismiss the Second Amended Complaint. filed by Love Records, Sean Combs, Combs Global Enterprises, 40 MOTION to Dismiss Plaintiff's Second Amended Complaint. filed by Motown Records, Lucian Charles Grainge, Universal Music Group. For the foregoing reasons, the Combs Defendants' motion to dismiss is GRANTED IN PART and DENIED IN PART. The motion is granted as to Jones's RICO claims, negligent and intentional infliction of emotional distress claims, and contract claims. The motion is also granted as to Jones's TVPA claims against Combs Global. The motion is otherwise denied. Jones shall file a letter within two weeks of the entry of this opinion explaining the status of service as to Justin Combs and Cuba Gooding, Jr. Jones's claims are dismissed as to John and Jane Does 1-10 and ABC Corporations 1-10. Defendants who have been served shall file an answer to the surviving claims with 14 days after the date of this opinion. The Clerk of Court is directed to close the motions at Docket Numbers 40, 66, and 71. SO ORDERED. ABC Corporations. 1-10 and John and Jane Does 1-10 terminated. (Signed by Judge J. Paul Oetken on 3/24/2025) (vfr) (Entered: 03/24/2025) View PDF
Apr 4, 2025 87 NOTICE OF APPEARANCE by Reuven Cohen on behalf of Kristina Khorram..(Cohen, Reuven) (Entered: 04/04/2025) View PDF
Apr 7, 2025 88 ANSWER to 38 Amended Complaint,, with JURY DEMAND. Document filed by Kristina Khorram..(Cohen, Reuven) (Entered: 04/07/2025) View PDF
Apr 7, 2025 89 ANSWER to 38 Amended Complaint,, with JURY DEMAND. Document filed by Sean Combs, Combs Global Enterprises, Love Records..(Wolff, Erica) (Entered: 04/07/2025) View PDF
Apr 7, 2025 90 FIRST LETTER addressed to Judge J. Paul Oetken from Tyrone Blackburn, Esq. dated 4/7/2025 re: Motion to serve Justin Dior Combs, and Cuba Gooding, Jr. via publication. Document filed by Rodney Jones..(Blackburn, Tyrone) (Entered: 04/07/2025) View PDF
Apr 8, 2025 91 FIRST MOTION for Service by Publication as to DEFENDANTS CUBA GOODING JR. and JUSTIN DIOR COMBS. Document filed by Rodney Jones. (Attachments: # 1 Proposed Order Proposed Order, # 2 Supplement Memorandum of Law, # 3 Affidavit Tyrone Blackburn, # 4 Exhibit A, # 5 Exhibit B, # 6 Exhibit C, # 7 Exhibit D, # 8 Exhibit E, # 9 Exhibit F, # 10 Exhibit G, # 11 Exhibit J).(Blackburn, Tyrone) (Entered: 04/08/2025) View PDF Proposed Order Proposed Order Supplement Memorandum of Law Affidavit Tyrone Blackburn Exhibit A Exhibit B Exhibit C Exhibit D Exhibit E Exhibit F
May 6, 2025 92 ORDER re: 86 Memorandum & Opinion, Add and Terminate Parties Motions terminated: 91 FIRST MOTION for Service by Publication as to DEFENDANTS CUBA GOODING JR. and JUSTIN DIOR COMBS. In sum, for both Gooding and Justin Combs, Blackburn waited until the service deadline was imminent to make meaningful efforts to effect service, and then failed to notify the Court or request a further extension when his efforts failed. The Court therefore determines that Plaintiff has not shown "good cause" for failing to serve Gooding and Justin Combs, as required by Rule 4(m) of the Federal Rules of Civil Procedure. Accordingly, Plaintiff's motion to effectuate service by alternative means is DENIED, and Plaintiff's claims against Gooding and Justin Combs are dismissed without prejudice. The Clerk of Court is directed to close the motion at Docket Number 91, and to terminate Cuba Gooding, Jr. and Justin Combs as parties in this action. SO ORDERED. (Signed by Judge J. Paul Oetken on 5/6/2025) Justin Dior Combs and Cuba Gooding, Jr. terminated. (ar) (Entered: 05/06/2025) View PDF
May 16, 2025 93 ORDER: Initial Conference set for 8/6/2025 at 11:00 AM before Judge J. Paul Oetken. Counsel should call (855) 244-8681 at the scheduled time. The attendee ID number is 23128287066. Counsel who appear at the pretrial conference must be authorized to negotiate terms of settlement. Members of the public may join but are instructed to place their phones on mute. SO ORDERED. (Signed by Judge J. Paul Oetken on 5/16/2025) (vfr) (Entered: 05/16/2025) View PDF
Jul 17, 2025 94 MOTION for Neil S. Jahss to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-31395826. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Kristina Khorram. (Attachments: # 1 Affidavit of Neil S. Jahss in Support of Motion for Pro Hac Vice Admission, # 2 Exhibit A to Affidavit of Neil S. Jahss (Certificate of Good Standing), # 3 Proposed Order for Pro Hac Vice Admission of Neil S. Jahss).(Jahss, Neil) (Entered: 07/17/2025) View PDF
Jul 17, 2025 95 MOTION for Marc S. Williams to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-31397618. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Kristina Khorram. (Attachments: # 1 Affidavit of Marc S. Williams in Support of Motion for Pro Hac Vice Admission, # 2 Exhibit A (Certificate of Good Standing), # 3 Proposed Order for Pro Hac Vice Admission of Marc S. Williams).(Williams, Marc) (Entered: 07/17/2025) View PDF
Jul 21, 2025 96 ORDER granting 94 Motion to Appear Pro Hac Vice. Granted. So ordered. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (bh) (Entered: 07/21/2025) No document
Jul 21, 2025 97 ORDER granting 95 Motion to Appear Pro Hac Vice. Granted. So ordered. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (bh) (Entered: 07/21/2025) No document
Jul 28, 2025 98 FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION for Rodney Sean Diggs to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-31440477. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Rodney Jones. (Attachments: # 1 Affidavit Affidavit of RSD in Support of Motion to Appear PHV, # 2 Proposed Order Proposed Order).(Diggs, Rodney) Modified on 7/28/2025 (bc). (Entered: 07/28/2025) No document
Jul 28, 2025 99 FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Rodney Jones. (Attachments: # 1 Affidavit Affidavit of RSD in Support of Motion to Appear PHV, # 2 Exhibit Certificate of Good Standing, # 3 Proposed Order Proposed Order).(Diggs, Rodney) Modified on 7/28/2025 (bc). (Entered: 07/28/2025) View PDF
Jul 31, 2025 100 PROPOSED CASE MANAGEMENT PLAN. Document filed by Sean Combs, Combs Global Enterprises, Love Records..(Wolff, Erica) (Entered: 07/31/2025) View PDF
Jul 31, 2025 101 MOTION for Rodney Sean Diggs to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Rodney Jones. (Attachments: # 1 Affidavit Affidavit of RSD in Support of Motion to Appear PHV, # 2 Exhibit Certificate of Good Standing, # 3 Proposed Order Proposed Order).(Diggs, Rodney) (Entered: 07/31/2025) No document
Aug 1, 2025 102 CIVIL CASE MANAGEMENT PLAN AND SCHEDULING ORDER: All parties do not consent to conducting all further proceedings before a United States Magistrate Judge, including motions and trial. 28 U.S.C. § 636(c). Any motion for leave to amend or to join additional parties shall be filed within 30 days from the date of this Order. All fact discovery shall be completed no later than 180 days. Depositions shall be completed by 180 days from the start of discovery. The parties agree that there is need for expert discovery. All expert discovery, including reports, production of underlying documents, and depositions, shall be completed no later than 75 days after the close of fact discovery. The parties shall be ready for trial on 14 days after the deadline for the proposed Joint Pretrial Order. This case is to be tried to a jury. Counsel for the parties have conferred and their present best estimate of the length of trial is 5-7 days. The initial pretrial conference scheduled for Aug. 6, 2025 is adjourned sine die. SO ORDERED. (Signed by Judge J. Paul Oetken on 8/1/2025) (vfr) (Entered: 08/01/2025) View PDF
Aug 15, 2025 103 ORDER granting 101 Motion to Appear Pro Hac Vice. Granted. So ordered. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (bh) (Entered: 08/15/2025) No document
Dec 17, 2025 104 NOTICE OF APPEARANCE by Benjamin Jared Shack Sackler on behalf of Sean Combs..(Shack Sackler, Benjamin) (Entered: 12/17/2025) No document
Jan 15, 2026 105 PROPOSED PROTECTIVE ORDER. Document filed by Sean Combs..(Wolff, Erica) (Entered: 01/15/2026) No document
Jan 15, 2026 106 STIPULATED PROTECTIVE ORDER...regarding procedures to be followed that shall govern the handling of confidential material... SO ORDERED. (Signed by Judge J. Paul Oetken on 1/15/2026) (vfr) (Entered: 01/15/2026) View PDF
Apr 13, 2026 107 JOINT LETTER MOTION for Extension of Time to Complete Discovery addressed to Judge J. Paul Oetken from Counsel for All Parties dated April 13, 2026. Document filed by Sean Combs. (Attachments: # 1 Exhibit A).(Wolff, Erica) (Entered: 04/13/2026) View PDF
Apr 14, 2026 108 ORDER granting 107 Letter Motion for Extension of Time to Complete Discovery: Granted. The parties' discovery deadline is adopted. Plaintiff shall serve a revised first set of interrogatories by April 15, 2026. Plaintiff shall provide HIPAA-compliant medical records release authorizations for the Defendants by April 24, 2026. Defendant Combs shall file an amended answer to assert counterclaims pursuant to Fed. R. Civ. P. 15(a)(2) by June 30, 2026. The parties shall complete fact discovery by December 18, 2026. The parties shall complete depositions by December 18, 2026. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (clf) (Entered: 04/14/2026) No document
Jun 3, 2026 109 LETTER MOTION to Stay Deadline to respond to Plaintiff's First Set of Requests for Admission and for a Protective Order addressed to Judge J. Paul Oetken from Erica A. Wolff dated June 3, 2026. Document filed by Sean Combs. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8).(Wolff, Erica) (Entered: 06/03/2026) View PDF Exhibit 1 Exhibit 2 Exhibit 3 Exhibit 4 Exhibit 5 Exhibit 6 Exhibit 7 Exhibit 8).(Wolff, Erica
Jun 3, 2026 110 LETTER MOTION to Stay Deadline to respond to Plaintiff's First Set of Requests for Admission and for a Protective Order addressed to Judge J. Paul Oetken from Neil S. Jahss dated June 3, 2026. Document filed by Kristina Khorram. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2).(Jahss, Neil) (Entered: 06/03/2026) View PDF Exhibit 1 Exhibit 2).(Jahss, Neil
Jun 9, 2026 111 ORDER granting 109 Letter Motion to Stay ; granting 110 Letter Motion to Stay : Defendants Combs' and Khorram's letter motions to stay (ECF Nos. 109 and 110) are GRANTED. Their requests for an immediate stay of the June 12, 2026 deadlines to respond to the RFAs are granted. Counsel for all parties are directed to appear for a telephonic conference on July 14, 2026, at 11:00 a.m. to discuss the RFA-related issues identified in ECF Nos. 109 and 110. At the scheduled time, counsel shall call (855) 244-8681 and enter access code 2312 828 7066. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (clf) (Entered: 06/09/2026) No document
Jun 24, 2026 112 MOTION for Michael J. Fisher to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-33040467. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Kristina Khorram. (Attachments: # 1 Affidavit of Michael J. Fisher, # 2 Exhibit A, # 3 Proposed Order Granting Pro Hac Vice Motion).(Fisher, Michael) (Entered: 06/24/2026) No document
Jun 24, 2026 113 FIRST LETTER MOTION for Extension of Time to file amended answer and counterclaims addressed to Judge J. Paul Oetken from Erica A. Wolff dated June 24, 2026. Document filed by Sean Combs..(Wolff, Erica) (Entered: 06/24/2026) View PDF
Jun 25, 2026 114 ORDER granting 113 Letter Motion for Extension of Time: GRANTED. Defendant Sean Combs shall file his amended answer and counterclaims by July 21, 2026. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (clf) (Entered: 06/25/2026) No document
Jul 6, 2026 115 ORDER granting 112 Motion to Appear Pro Hac Vice. Granted. So ordered. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (bh) (Entered: 07/06/2026) No document
Feb 27, 2024 1.1 ***NOTICE TO ATTORNEY REGARDING DEFICIENT CIVIL COVER SHEET. Notice to attorney Tyrone Anthony Blackburn to RE-FILE Civil Cover Sheet. The filing is deficient for the following reason(s): the PDF attached to the docket entry for the civil cover sheet is not correct; all of the party names must be listed on the PDF case caption. If all of the party names do not fit, include 'et al'; the event wrong event type was used to file the civil cover sheet; the PDF must be filed separately. Re-file the document using the event type Civil Cover Sheet found under the event list Other Documents and attach the correct PDF. Use civil cover sheet issued by S.D.N.Y. dated October 1, 2020. The S.D.N.Y. Civil Cover Sheet dated October 1, 2020 is located athttp://nysd.uscourts.gov/file/forms/civil-cover-sheet.. (jgo) No document
Feb 27, 2024 1.2 ***NOTICE TO ATTORNEY REGARDING DEFICIENT PLEADING. Notice to Attorney Tyrone Anthony Blackburn to RE-FILE Document No. 1 Complaint. The filing is deficient for the following reason(s): the PDF attached to the docket entry for the pleading is not correct; the PDF must be titled to correspond with the event type used. Re-file the pleading using the event type Complaint found under the event list Complaints and Other Initiating Documents - attach the correct signed PDF - select the individually named filer/filers - select the individually named party/parties the pleading is against. If the deficiency/deficiencies are not corrected within five (5) days per Amended Standing Order 15-mc-00131 this case will be administratively closed. Initial Pleading due by 3/4/2024. (jgo) No document
Jul 31, 2025 101.1 >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. 101 MOTION for Rodney Sean Diggs to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bc) No document
Jun 24, 2026 113.1 >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. 112 MOTION for Michael J. Fisher to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-33040467. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (rju) No document
Jul 14, 2026 115.1 Minute Entry for proceedings held before Judge J. Paul Oetken: Telephonic Status Conference held on 7/14/2026. See transcript. (bh) No document
Mar 25, 2024 16.1 ***NOTICE TO COURT REGARDING NOTICE OF VOLUNTARY DISMISSAL Document No. 6 Notice of Voluntary Dismissal, 7 Notice of Voluntary Dismissal,, was reviewed and referred to Judge J. Paul Oetken for approval for the following reason(s): the plaintiff(s) filed their voluntary dismissal and it did not dismiss all of the parties or the action in its entirety;. (nd) No document
Mar 26, 2024 19.1 ***NOTICE TO ATTORNEY REGARDING DEFICIENT PLEADING. Notice to Attorney Tyrone Anthony Blackburn to RE-FILE Document No. 16 Second Amended Complaint. The filing is deficient for the following reason(s): the PDF attached to the docket entry for the pleading is not correct; the Court name contains a typographical error; the PDF must be titled to correspond with the proper event type; the wrong event type was used to file the pleading. Re-file the pleading using the event type Amended Complaint found under the event list Complaints and Other Initiating Documents - attach the correct signed PDF - select the individually named filer/filers - select the individually named party/parties the pleading is against. (jgo) No document
Mar 28, 2024 30.1 ***NOTICE TO ATTORNEY REGARDING DEFICIENT PLEADING. Notice to Attorney Tyrone Anthony Blackburn to RE-FILE re: Document No. 27 Second Amended Complaint. The filing is deficient for the following reason(s): Court's leave has not been granted; the order granting permission to file the pleading was not attached; The pleading is not linked to a First Amended Complaint. Re-file the pleading using the event type Amended Complaint found under the event list Complaints and Other Initiating Documents - attach the correct signed PDF - select the individually named filer/filers - select the individually named party/parties the pleading is against. File the Exhibit to Pleading event found under the event list Other Documents and attach either opposing party's written consent or Court's leave. (vf) No document
Apr 9, 2024 37.1 Minute Entry for proceedings held before Judge J. Paul Oetken: Telephonic Pretrial Conference held on 4/9/2024. See Order. See transcript. (bh) No document
Apr 18, 2024 39.1 ***NOTICE TO ATTORNEY REGARDING DEFICIENT REQUEST FOR ISSUANCE OF SUMMONS. Notice to Attorney Tyrone Anthony Blackburn to RE-FILE Document No. 39 Request for Issuance of Summons. The filing is deficient for the following reason(s): Defendant party name errors. Defendant party names listed on Summons PDF and ECF docket entry do not correspond exactly to pleading caption. Re-file the document using the event type Request for Issuance of Summons found under the event list Service of Process - select the correct filer/filers - and attach the correct summons form PDF. (vf) No document
Mar 5, 2024 4.1 ***NOTICE TO ATTORNEY REGARDING DEFICIENT REQUEST FOR ISSUANCE OF SUMMONS. Notice to Attorney Tyrone Anthony Blackburn to RE-FILE Document No. 4 Request for Issuance of Summons,. The filing is deficient for the following reason(s): the PDF attached to the docket entry for the issuance of summons is not correct; party name on the attached rider does not match exactly as it appears on the pleading caption (Combs Enterprises). Re-file the document using the event type Request for Issuance of Summons found under the event list Service of Process - select the correct filer/filers - and attach the correct summons form PDF. (jgo) No document
Mar 5, 2024 4.2 Magistrate Judge Valerie Figueredo is designated to handle matters that may be referred in this case. Pursuant to 28 U.S.C. Section 636(c) and Fed. R. Civ. P. 73(b)(1) parties are notified that they may consent to proceed before a United States Magistrate Judge. Parties who wish to consent may access the necessary form at the following link: https://nysd.uscourts.gov/sites/default/files/2018-06/AO-3.pdf. (jgo) No document
Mar 5, 2024 4.3 CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge J. Paul Oetken. Please download and review the Individual Practices of the assigned District Judge, located at https://nysd.uscourts.gov/judges/district-judges. Attorneys are responsible for providing courtesy copies to judges where their Individual Practices require such. Please download and review the ECF Rules and Instructions, located at https://nysd.uscourts.gov/rules/ecf-related-instructions..(jgo) No document
Mar 5, 2024 4.4 ***NOTICE TO ATTORNEY REGARDING PARTY MODIFICATION. Notice to attorney Tyrone Anthony Blackburn. The party information for the following party/parties has been modified: RODNEY JONES; SEAN COMBS; 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 ; ABC CORPORATIONS. 1-10. The information for the party/parties has been modified for the following reason/reasons: party name was entered in all caps;. (jgo) No document
Mar 5, 2024 4.5 ***NOTICE TO ATTORNEY REGARDING CIVIL CASE OPENING STATISTICAL ERROR CORRECTION: Notice to attorney Tyrone Anthony Blackburn. The following case opening statistical information was erroneously selected/entered: Dollar Demand $30,000,000,000;. The following correction(s) have been made to your case entry: the Dollar Demand has been modified to none;. (jgo) No document
Mar 5, 2024 4.6 Case Designated ECF. (jgo) No document
Mar 5, 2024 4.7 Magistrate Judge Valerie Figueredo is designated to handle matters that may be referred in this case. Pursuant to 28 U.S.C. Section 636(c) and Fed. R. Civ. P. 73(b)(1) parties are notified that they may consent to proceed before a United States Magistrate Judge. Parties who wish to consent may access the necessary form at the following link: https://nysd.uscourts.gov/sites/default/files/2018-06/AO-3.pdfEditSign. (jgo) No document
Mar 13, 2024 4.8 Minute Entry for proceedings held before Magistrate Judge Andrew E. Krause: Settlement Conference held on 3/13/2024. Parties appeared by video. Settlement reached. Defendants will provide an initial draft of a proposed settlement agreement by March 20, 2024. Plaintiffs will file the proposed infant compromise order with Judge Karas by April 19, 2024. (sbr) No document
Apr 25, 2024 44.1 ***NOTICE TO ATTORNEY REGARDING DEFICIENT REQUEST FOR ISSUANCE OF SUMMONS. Notice to Attorney Tyrone Anthony Blackburn to RE-FILE Document No. 43 Request for Issuance of Summons,. The filing is deficient for the following reason(s): the PDF attached to the docket entry for the issuance of summons is not correct; party name on the docket text and the attached rider does not match exactly as it appears on the pleading caption (Justin Combs). Re-file the document using the event type Request for Issuance of Summons found under the event list Service of Process - select the correct filer/filers - and attach the correct summons form PDF. (jgo) No document
Mar 20, 2024 5.1 >>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. 5 FIRST MOTION for Rodney Diggs, Esq. to Appear Pro Hac Vice For Plaintiff Rodney Jones. Filing fee $ 200.00, receipt number ANYSDC-29102400. Motion and supporting papers to be reviewed by Clerk's Office staff.</FO. The filing is deficient for the following reason(s): missing Certificate of Good Standing from Supreme Court of California; Must provide a Declaration or a signed and notarized affidavit; Re-file the motion as a Motion to Appear Pro Hac Vice - attach the correct signed PDF - select the correct named filer/filers - attach valid Certificates of Good Standing issued within the past 30 days - attach Proposed Order. (rju) No document
May 14, 2024 51.1 ***NOTICE TO ATTORNEY REGARDING DEFICIENT VOLUNTARY DISMISSAL. Notice to Attorney Tyrone Blackburn. RE-FILE Document No. 47 Stipulation of Voluntary Dismissal. The filing is deficient for the following reason(s): (1) the wrong event type was used to file the voluntary dismissal; (2) the documents were not filed separately. Re-file the document using the event type Motion found under the event list Motions - select to Dismiss - select the correct filer/filers - select the correct party/parties the voluntary dismissal is against - and attach the correct signed PDF. (tp) No document
May 23, 2024 56.1 Set/Reset Deadlines: Kristina Khorram answer due 8/26/2024. (tro) No document
Oct 16, 2024 82.1 Minute Entry for proceedings held before Judge J. Paul Oetken: Oral Argument held on 10/16/2024 re: 52 MOTION for Sanctions . Decision Reserved. See transcript. (bh) No document
Jul 17, 2025 95.1 >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. 94 MOTION for Neil S. Jahss to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-31395826. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bc) No document
Jul 18, 2025 95.2 >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. 95 MOTION for Marc S. Williams to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-31397618. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bc) No document
Jul 28, 2025 99.1 >>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. 99 MOTION to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff. The filing is deficient for the following reason(s): missing Certificate of Good Standing from SUPREME COURT of California, not state bar;. Re-file the motion as a Motion to Appear Pro Hac Vice - attach the correct signed PDF - select the correct named filer/filers - attach valid Certificates of Good Standing issued within the past 30 days - attach Proposed Order.. (bc) No document
Jul 28, 2025 99.2 >>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. 98 MOTION for Rodney Sean Diggs to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-31440477. Motion and supporting papers to be reviewed by Clerk's Office staff. The filing is deficient for the following reason(s): missing Certificate of Good Standing from Supreme Court of California;. Re-file the motion as a Motion to Appear Pro Hac Vice - attach the correct signed PDF - select the correct named filer/filers - attach valid Certificates of Good Standing issued within the past 30 days - attach Proposed Order.. (bc) No document
Attorneys
Tyrone A. Blackburn
T. A. Blackburn Law, PLLC
Plaintiff
Erica A. Wolff
Sher Tremonte
Civil Defense