McKinney v. Combs et al
Crystal McKinney, a successful model since 1998, was invited by a fashion designer to a Sean John Fashion Show event at Cipriani Downtown, New York, on February 8, 2003, to meet Sean Combs. At the dinner, Combs flirted aggressively, promised career advancement, and plied her with alcohol. Later that night, he invited her to Daddy’s House Recordings at 321 W 44th St, New York, NY, where he pressured her to consume a laced joint and alcohol, rendering her disoriented. In the studio bathroom, Combs forced her to perform oral sex despite her refusal, visible to others through a glass pane. She lost consciousness, awoke in a taxi, and later found her modeling career sabotaged, allegedly by Combs blackballing her, leading to depression, addiction, and a suicide attempt in 2004.
Declaratory judgment that Combs and Corporate Defendants violated the NYC Gender-Motivated Violence Act; compensatory damages for mental, emotional, and reputational harm; damages for breach of contract; punitive damages; attorneys’ fees, costs, and expenses; other equitable relief as deemed proper.
| Date | No. | Description | |
|---|---|---|---|
| May 21, 2024 | 1 | COMPLAINT against Bad Boy Entertainment Holdings, Inc., Bad Boy Entertainment LLC, Sean Combs, Sean John Clothing LLC, Universal Music Entertainment Group Inc.. (Filing Fee $ 405.00, Receipt Number BNYSDC-29384854)Document filed by Crystal McKinney..(Caiola, Michelle) (Entered: 05/21/2024) | View PDF |
| May 21, 2024 | 2 | CIVIL COVER SHEET filed..(Caiola, Michelle) (Entered: 05/21/2024) | View PDF |
| May 21, 2024 | 3 | REQUEST FOR ISSUANCE OF SUMMONS as to Sean Combs, Bad Boy Entertainment LLC d/b/a Bad Boy Records, Bad Boy Entertainment Holdings Inc., and Sean John Clothing LLC, re: 1 Complaint,. Document filed by Crystal McKinney..(Caiola, Michelle) (Entered: 05/21/2024) | View PDF |
| May 21, 2024 | 4 | REQUEST FOR ISSUANCE OF SUMMONS as to Universal Music Entertainment Group, Inc., re: 1 Complaint,. Document filed by Crystal McKinney..(Caiola, Michelle) (Entered: 05/21/2024) | View PDF |
| May 21, 2024 | 5 | NOTICE OF APPEARANCE by Jonathan Martin Goldhirsch on behalf of Crystal McKinney..(Goldhirsch, Jonathan) (Entered: 05/21/2024) | View PDF |
| May 22, 2024 | 6 | ELECTRONIC SUMMONS ISSUED as to Bad Boy Entertainment Holdings, Inc., Bad Boy Entertainment LLC, Sean Combs, Sean John Clothing LLC. (vf) (Entered: 05/22/2024) | View PDF |
| May 22, 2024 | 7 | ELECTRONIC SUMMONS ISSUED as to Universal Music Entertainment Group Inc.. (vf) (Entered: 05/22/2024) | View PDF |
| Jun 27, 2024 | 8 | WAIVER OF SERVICE RETURNED EXECUTED. Universal Music Entertainment Group Inc. waiver sent on 6/21/2024, answer due 8/20/2024. Document filed by Crystal McKinney..(Caiola, Michelle) (Entered: 06/27/2024) | No document |
| Jul 18, 2024 | 9 | NOTICE OF APPEARANCE by Erica Ashley Wolff on behalf of Bad Boy Entertainment Holdings, Inc., Bad Boy Entertainment LLC, Sean Combs, Sean John Clothing LLC..(Wolff, Erica) (Entered: 07/18/2024) | No document |
| Jul 18, 2024 | 10 | NOTICE OF APPEARANCE by Michael Tremonte on behalf of Bad Boy Entertainment Holdings, Inc., Bad Boy Entertainment LLC, Sean Combs, Sean John Clothing LLC..(Tremonte, Michael) (Entered: 07/18/2024) | No document |
| Jul 18, 2024 | 11 | LETTER addressed to Judge Naomi Reice Buchwald from Erica A. Wolff dated July 18, 2024 re: Stipulation Regarding Service and Response Schedule. Document filed by Bad Boy Entertainment Holdings, Inc., Bad Boy Entertainment LLC, Sean Combs, Sean John Clothing LLC. (Attachments: # 1 Exhibit A).(Wolff, Erica) (Entered: 07/18/2024) | No document |
| Jul 21, 2024 | 12 | RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Bad Boy Entertainment Holdings, Inc...(Wolff, Erica) (Entered: 07/21/2024) | No document |
| Jul 21, 2024 | 13 | FILING ERROR - CORPORATE PARENT/OTHER AFFILIATE NOT ADDED - RULE 7.1 CORPORATE DISCLOSURE STATEMENT.. Document filed by Bad Boy Entertainment LLC..(Wolff, Erica) Modified on 7/24/2024 (lb). (Entered: 07/21/2024) | No document |
| Jul 21, 2024 | 14 | FILING ERROR - CORPORATE PARENT/OTHER AFFILIATE NOT ADDED - RULE 7.1 CORPORATE DISCLOSURE STATEMENT.. Document filed by Sean John Clothing LLC..(Wolff, Erica) Modified on 7/24/2024 (lb). (Entered: 07/21/2024) | No document |
| Jul 24, 2024 | 15 | RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Corporate Parent 1169 Group Holdings LLC, Other Affiliate 1169 Corp for Sean John Clothing LLC. Document filed by Sean John Clothing LLC..(Wolff, Erica) (Entered: 07/24/2024) | No document |
| Jul 25, 2024 | 16 | RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Corporate Parent Bad Boy Entertainment Holdings, Inc. for Bad Boy Entertainment LLC. Document filed by Bad Boy Entertainment LLC..(Wolff, Erica) (Entered: 07/25/2024) | No document |
| Jul 29, 2024 | 17 | 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, against the defendant(s) Universal Music Entertainment Group Inc. pursuant to Rule 41(a)(1)(A)(ii) of the Federal Rules of Civil Procedure. Document filed by Crystal McKinney. Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers)...(Goldhirsch, Jonathan) (Entered: 07/29/2024) | View PDF |
| Jul 30, 2024 | 18 | STIPULATION AND ORDER OF DISMISSAL WITH PREJUDICE: Plaintiff, CRYSTAL MCKINNEY, through her attorneys, PHILLIPS & ASSOCIATES, PLLC, and Defendant UMG RECORDINGS, INC. (incorrectly named herein as Universal Music Entertainment Group, Inc.), by and through its attorneys, PRYOR CASHMAN, LLP, hereby stipulate and agree, pursuant to Rule 41 of the Federal Rules of Civil Procedure, that the Complaint in this Action, as against UMG Recordings, Inc. be and it hereby is dismissed with prejudice and without costs. All references to Universal Music Entertainment Group, Inc. in the Complaint, including in the caption, shall be deemed to be deleted. SO ORDERED. Universal Music Entertainment Group Inc. terminated. (Signed by Judge Naomi Reice Buchwald on 7/30/2024) (mml) (Entered: 07/31/2024) | No document |
| Aug 1, 2024 | 19 | FIRST AMENDED COMPLAINT amending 1 Complaint, against Bad Boy Entertainment Holdings, Inc., Bad Boy Entertainment LLC, Sean Combs, Sean John Clothing LLC, Daddy's House Recordings, Inc. with JURY DEMAND.Document filed by Crystal McKinney. Related document: 1 Complaint,..(Caiola, Michelle) (Entered: 08/01/2024) | View PDF |
| Aug 16, 2024 | 20 | REQUEST FOR ISSUANCE OF SUMMONS as to Daddy's House Recordings, Inc., re: 19 Amended Complaint,. Document filed by Crystal McKinney..(Caiola, Michelle) (Entered: 08/16/2024) | No document |
| Aug 19, 2024 | 21 | ELECTRONIC SUMMONS ISSUED as to Daddy's House Recordings, Inc...(pc) (Entered: 08/19/2024) | No document |
| Aug 19, 2024 | 22 | NOTICE OF APPEARANCE by Michael Tremonte on behalf of Daddy's House Recordings, Inc...(Tremonte, Michael) (Entered: 08/19/2024) | No document |
| Aug 19, 2024 | 23 | NOTICE OF APPEARANCE by Erica Ashley Wolff on behalf of Daddy's House Recordings, Inc...(Wolff, Erica) (Entered: 08/19/2024) | No document |
| Aug 19, 2024 | 24 | RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Daddy's House Recordings, Inc...(Wolff, Erica) (Entered: 08/19/2024) | No document |
| Aug 19, 2024 | 25 | LETTER addressed to Judge Naomi Reice Buchwald from Erica A. Wolff dated August 19, 2024 re: Stipulation Regarding Service and Response Schedule. Document filed by Bad Boy Entertainment Holdings, Inc., Bad Boy Entertainment LLC, Sean Combs, Daddy's House Recordings, Inc., Sean John Clothing LLC. (Attachments: # 1 Exhibit A).(Wolff, Erica) (Entered: 08/19/2024) | No document Exhibit A).(Wolff, Erica |
| Sep 20, 2024 | 26 | LETTER addressed to Judge Naomi Reice Buchwald from Erica A. Wolff dated 09/20/2024 re: Pre-Motion Conference. Document filed by Bad Boy Entertainment Holdings, Inc., Bad Boy Entertainment LLC, Sean Combs, Daddy's House Recordings, Inc., Sean John Clothing LLC..(Wolff, Erica) (Entered: 09/20/2024) | View PDF |
| Sep 25, 2024 | 27 | LETTER addressed to Judge Naomi Reice Buchwald from Michelle A. Caiola dated 09/25/2024 re: Pre-Motion Conference Request. Document filed by Crystal McKinney..(Caiola, Michelle) (Entered: 09/25/2024) | View PDF |
| Oct 1, 2024 | 28 | ORDER. Having reviewed the parties' pre-motion letters, dated September 20, 2024 and September 25, 2024, the Court has determined that defendants may bring their motion without the necessity of a pre-motion conference. Plaintiff is thus granted leave to file an amended complaint within two weeks of this Order. At that time, if no amended complaint has been filed, the parties should confer on a briefing schedule agreeable to both sides, in which no more than sixty days elapse from the filing of defendants' motion to the filing of defendants' reply. SO ORDERED. (Signed by Judge Naomi Reice Buchwald on 10/1/24) (yv) (Entered: 10/01/2024) | View PDF |
| Oct 17, 2024 | 29 | LETTER addressed to Judge Naomi Reice Buchwald from Michelle A. Caiola dated 10/17/2024 re: Briefing Schedule for Motion To Dismiss. Document filed by Crystal McKinney..(Goldhirsch, Jonathan) (Entered: 10/17/2024) | View PDF |
| Oct 18, 2024 | 30 | MEMO ENDORSEMENT on re: 29 Letter Briefing Schedule for Motion To Dismiss filed by Crystal McKinney. ENDORSEMENT : Application granted. So ordered., ( Motions due by 11/8/2024., Replies due by 1/7/2025., Responses due by 12/6/2024) (Signed by Judge Naomi Reice Buchwald on 10/18/24) (yv) (Entered: 10/18/2024) | No document |
| Nov 8, 2024 | 31 | NOTICE OF APPEARANCE by Katie Elizabeth Renzler on behalf of Sean Combs, Bad Boy Entertainment LLC, Sean John Clothing LLC, Bad Boy Entertainment Holdings, Inc., Daddy's House Recordings, Inc...(Renzler, Katie) (Entered: 11/08/2024) | No document |
| Nov 8, 2024 | 32 | MOTION to Dismiss . Document filed by Sean Combs, Bad Boy Entertainment LLC, Sean John Clothing LLC, Bad Boy Entertainment Holdings, Inc., Daddy's House Recordings, Inc...(Wolff, Erica) (Entered: 11/08/2024) | View PDF |
| Nov 8, 2024 | 33 | MEMORANDUM OF LAW in Support re: 32 MOTION to Dismiss . . Document filed by Sean Combs, Bad Boy Entertainment LLC, Sean John Clothing LLC, Bad Boy Entertainment Holdings, Inc., Daddy's House Recordings, Inc...(Wolff, Erica) (Entered: 11/08/2024) | View PDF |
| Nov 8, 2024 | 34 | DECLARATION of Erica A. Wolff in Support re: 32 MOTION to Dismiss .. Document filed by Sean Combs, Bad Boy Entertainment LLC, Sean John Clothing LLC, Bad Boy Entertainment Holdings, Inc., Daddy's House Recordings, Inc.. (Attachments: # 1 Exhibit A - First Amended Complaint, # 2 Exhibit B - Original VGM, # 3 Exhibit C - Amended VGM).(Wolff, Erica) (Entered: 11/08/2024) | View PDF |
| Nov 8, 2024 | 35 | DECLARATION of Samantha Luevanos in Support re: 32 MOTION to Dismiss .. Document filed by Sean Combs, Bad Boy Entertainment LLC, Sean John Clothing LLC, Bad Boy Entertainment Holdings, Inc., Daddy's House Recordings, Inc.. (Attachments: # 1 Exhibit A - Search Result for All Counties, # 2 Exhibit B - Search Results for NYC).(Wolff, Erica) (Entered: 11/08/2024) | No document |
| Dec 6, 2024 | 36 | RESPONSE in Opposition to Motion re: 32 MOTION to Dismiss . . Document filed by Crystal McKinney. (Attachments: # 1 Exhibit A - Affidavit From NYS Senator Brad Holyman, # 2 Exhibit B - GMVA 2000 Legislative Jacket, # 3 Exhibit C - GMVA 2021 Amendment Legislative Jacket, # 4 Exhibit D - GMVA 11/29/2021 Hearing Written Testimony Submitted for Hearing).(Goldhirsch, Jonathan) (Entered: 12/06/2024) | View PDF |
| Dec 6, 2024 | 37 | DECLARATION of Michelle A. Caiola, Esq. in Opposition re: 32 MOTION to Dismiss .. Document filed by Crystal McKinney..(Caiola, Michelle) (Entered: 12/06/2024) | View PDF |
| Jan 7, 2025 | 38 | REPLY MEMORANDUM OF LAW in Support re: 32 MOTION to Dismiss . the Amended Complaint. Document filed by Sean Combs, Bad Boy Entertainment LLC, Sean John Clothing LLC, Bad Boy Entertainment Holdings, Inc., Daddy's House Recordings, Inc...(Wolff, Erica) (Entered: 01/07/2025) | View PDF |
| Jan 7, 2025 | 39 | DECLARATION of Erica A. Wolff in Support re: 32 MOTION to Dismiss .. Document filed by Sean Combs, Bad Boy Entertainment LLC, Sean John Clothing LLC, Bad Boy Entertainment Holdings, Inc., Daddy's House Recordings, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B).(Wolff, Erica) (Entered: 01/07/2025) | View PDF Exhibit A Exhibit B).(Wolff, Erica |
| Jan 7, 2025 | 40 | LETTER addressed to Judge Naomi Reice Buchwald from Erica A. Wolff dated 01/07/2025 re: Pursuant to Individual Practice Rule 2(c). Document filed by Sean Combs, Bad Boy Entertainment LLC, Sean John Clothing LLC, Bad Boy Entertainment Holdings, Inc., Daddy's House Recordings, Inc...(Wolff, Erica) (Entered: 01/07/2025) | View PDF |
| Jan 8, 2025 | 41 | LETTER MOTION for Extension of Time to File Supplemental Motion Letters addressed to Judge Naomi Reice Buchwald from Michelle A. Caiola dated 1/8/2025. Document filed by Crystal McKinney..(Caiola, Michelle) (Entered: 01/08/2025) | View PDF |
| Jan 9, 2025 | 42 | ORDER granting 41 Letter Motion for Extension of Time to File. Application granted. SO ORDERED. (Signed by Judge Naomi Reice Buchwald on 01/09/2025) (ar) (Entered: 01/10/2025) | View PDF |
| Jan 10, 2025 | 43 | LETTER addressed to Judge Naomi Reice Buchwald from Michelle A. Caiola dated 01/10/2025 re: Pursuant to Individual Practice Rule 2(c). Document filed by Crystal McKinney..(Caiola, Michelle) (Entered: 01/10/2025) | View PDF |
| Jan 27, 2025 | 44 | LETTER addressed to Judge Naomi Reice Buchwald from Erica A. Wolff dated January 27, 2025 re: Notice of Supplemental Authority. Document filed by Sean Combs, Bad Boy Entertainment LLC, Sean John Clothing LLC, Bad Boy Entertainment Holdings, Inc., Daddy's House Recordings, Inc.. (Attachments: # 1 Exhibit Exhibit A: 01/22/2025 Memorandum Opinion in Parker v. Alexander et al.).(Wolff, Erica) (Entered: 01/27/2025) | View PDF |
| Feb 3, 2025 | 45 | LETTER addressed to Judge Naomi Reice Buchwald from Erica A. Wolff dated February 3, 2025 re: Notice of Supplemental Authority. Document filed by Sean Combs, Bad Boy Entertainment LLC, Sean John Clothing LLC, Bad Boy Entertainment Holdings, Inc., Daddy's House Recordings, Inc.. (Attachments: # 1 Exhibit A: 01/23/2025 Opinion and Order in ORear v. Diaz).(Wolff, Erica) (Entered: 02/03/2025) | No document |
| Feb 4, 2025 | 46 | LETTER MOTION for Leave to File Strike Unauthorized Surreplies addressed to Judge Naomi Reice Buchwald from Michelle A. Caiola dated 2/4/2025. Document filed by Crystal McKinney..(Caiola, Michelle) (Entered: 02/04/2025) | View PDF |
| Feb 6, 2025 | 47 | ORDER: denying 46 Letter Motion for Leave to File Document. ENDORSEMENT: Application Denied.. See e.g. Fed. R. App. P. 28(j). SO ORDERED. (Signed by Judge Naomi Reice Buchwald on 2/6/2025) (ar) (Entered: 02/06/2025) | View PDF |
| Apr 8, 2025 | 48 | ENDORSED LETTER addressed to Counsel from Naomi Reice Buchwald United States District Judge dated 4/8/2025 re: McKinney v. Combs et al. ENDORSEMENT: As the parties are aware, there is a fully briefed motion to dismiss presently before the Court. See ECF No. 32. Moreover, as the parties are aware, the complaint contains a single cause of action, which is rooted in the New York City Victims of Gender-Motivated Violence Protection Act (VGMVPL). See ECF No. 1. The thrust of defendants motion to dismiss is that the VGMVPL claim is time-barred. See ECF Nos. 26, 33, 38. As the parties likely know, there are at least two pending appeals before the Second Circuit that raise the same statute of limitations issues, see Parker v. Alexander, No. 24 Civ 4813 (LAK), 2025 WL 268436 (S.D.N.Y. Jan. 22, 2025); Doe v. Black, No. 23 Civ. 6418 (JGLC), 2024 WL 4335453 (S.D.N.Y. Sept. 27, 2024). Since the Circuits decision on this dispositive issue of law will be binding on the Court, we propose staying the motion pending the Circuits resolution of the issue. If either party has any reservations about this proposal, please let us know promptly. (Signed by Judge Naomi Reice Buchwald on 4/8/2025) (sgz) (Entered: 04/08/2025) | View PDF |
| Apr 24, 2025 | 49 | ORDER: It is hereby ORDERED that a formal stay is imposed until the Circuit's resolution of the pending appeals. Case stayed. (Signed by Judge Naomi Reice Buchwald on 4/24/2025) (jjc) (Entered: 04/24/2025) | View PDF |
| Sep 29, 2025 | 50 | MOTION for Jonathan Goldhirsch to Withdraw as Attorney . Document filed by Crystal McKinney..(Caiola, Michelle) (Entered: 09/29/2025) | View PDF |
| Sep 30, 2025 | 51 | MEMO ENDORSEMENT granting 50 Motion to Withdraw as Attorney. ENDORSEMENT: Application granted. Attorney Jonathan Martin Goldhirsch terminated. (Signed by Judge Naomi Reice Buchwald on 9/30/2025) (rro) (Entered: 09/30/2025) | View PDF |
| Jan 23, 2026 | 52 | LETTER addressed to Judge Naomi Reice Buchwald from Michelle Caiola, Esq. dated 01/23/2026 re: Counsel Change of Firm Affiliation. Document filed by Crystal McKinney..(Caiola, Michelle) (Entered: 01/23/2026) | View PDF |
| Mar 24, 2026 | 53 | NOTICE OF CHANGE OF ADDRESS by Michelle Anne Caiola on behalf of Crystal McKinney. New Address: Phillips & Associates, PLLC, 45 Broadway, 28th Floor, New York, New York, 10006, 212-248-7431..(Caiola, Michelle) (Entered: 03/24/2026) | No document |
| Jul 24, 2024 | 15.1 | ***NOTICE TO ATTORNEY REGARDING DEFICIENT RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Notice to Attorney Erica Ashley Wolff to RE-FILE Document Nos. 13 Rule 7.1 Corporate Disclosure Statement and 14 Rule 7.1 Corporate Disclosure Statement. These filings are deficient for the following reason(s): the corporate parent/other affiliate was not added;. Re-file these documents using the event type Rule 7.1 Corporate Disclosure Statement found under the event list Other Documents - select the correct filer/filers - attach the correct signed PDF - when prompted with the message "Are there any corporate parents or other affiliates?", select the Yes or No radio button - If Yes - enter the corporate parent/other affiliate, click the Search button - select the correct corporate parent/other affiliate name from the search results list or if no person found, create a new corporate parent/other affiliate - select the party to whom the corporate parent/other affiliate should be linked - add corporate parent/other affiliate names one at a time. (lb) | No document |
| Jul 30, 2024 | 18.1 | ***NOTICE TO COURT REGARDING NOTICE OF VOLUNTARY DISMISSAL Document No. 17 Stipulation of Voluntary Dismissal,, was reviewed and referred to Judge Naomi Reice Buchwald 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 |
| May 22, 2024 | 7.1 | ***NOTICE TO ATTORNEY REGARDING CIVIL. CASE OPENING STATISTICAL ERROR CORRECTION: Notice to attorney Michelle Anne Caiola. The following case opening statistical information was erroneously selected/entered: County code New York. The following correction(s) have been made to your case entry: the County code has been modified to XX Out of State. (vf) | No document |
| May 22, 2024 | 7.2 | CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Naomi Reice Buchwald. 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..(vf) | No document |
| May 22, 2024 | 7.3 | Magistrate Judge Sarah Netburn 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. (vf) | No document |
| May 22, 2024 | 7.4 | Case Designated ECF. (vf) | No document |
| May 22, 2024 | 7.5 | ***NOTICE TO ATTORNEY REGARDING PARTY MODIFICATION. Notice to attorney Michelle Anne Caiola. The party information for the following party/parties has been modified: Sean Combs, Bad Boy Entertainment LLC. The information for the party/parties has been modified for the following reason/reasons: alias party name was omitted. (vf) | No document |