Case #1:24-cv-08024 · United States District Court, Southern District of New York

Kelly v. Combs et al

Filed October 22, 2024 Judge Judge Valerie E. Caproni
Open Sean Combs Daddy's House Recordings Inc. CE OPCO, LLC d/b/a Combs Global f/k/a Combs Enterprises LLC Bad Boy Entertainment Holdings, Inc. Bad Boy Productions Holdings, Inc. Bad Boy Books Holdings, Inc. Bad Boy Records LLC Bad Boy Entertainment LLC Bad Boy Productions LLC Organizational Does 1-10 Individual Does 1-10
Contains Sexual Assault · Rape · Drugging · Physical Restraint
Parties
Jane Doe (Shante Kelly) Plaintiff
Sean Combs A male who, on information and belief, resides in New York City, currently incarcerated at the Metropolitan Detention Center in Brooklyn; owns and/or controls the named Combs Corporations.
Daddy's House Recordings Inc. A New York corporation with its principal place of business at 9255 Sunset Boulevard, 2nd Floor, West Hollywood, CA 90069; a world-class recording studio owned by Combs, previously located at 321 W 44th Street, Suite 201, New York, NY 10036.
CE OPCO, LLC d/b/a Combs Global f/k/a Combs Enterprises LLC A Delaware LLC with its principal place of business at 9255 Sunset Boulevard, 2nd Floor, West Hollywood, CA 90069; an alter ego for Combs and/or used to insulate his assets.
Bad Boy Entertainment Holdings, Inc. A New York corporation with its principal place of business at 9255 Sunset Boulevard, 2nd Floor, West Hollywood, CA 90069; part of the Bad Boy enterprise founded and owned by Combs.
Bad Boy Productions Holdings, Inc. A New York corporation with its principal place of business at 9255 Sunset Boulevard, 2nd Floor, West Hollywood, CA 90069; part of the Bad Boy enterprise founded and owned by Combs.
Bad Boy Books Holdings, Inc. A New York corporation with its principal place of business at 1440 Broadway, 3rd Floor, New York, NY 10018; part of the Bad Boy enterprise founded and owned by Combs.
Bad Boy Records LLC A Delaware LLC headquartered in New York and/or California; part of the Bad Boy enterprise founded and owned by Combs.
Bad Boy Entertainment LLC A New York LLC headquartered in New York and/or California; part of the Bad Boy enterprise founded and owned by Combs.
Bad Boy Productions LLC A New York LLC headquartered in New York and/or California; part of the Bad Boy enterprise founded and owned by Combs.
Organizational Does 1-10 Currently unknown entities owned by and/or employed by Combs that enabled and conspired with the alleged conduct.
Individual Does 1-10 Currently unknown celebrities and/or persons of interest who enabled and/or conspired with the alleged conduct.
Factual Allegations
Disclaimer: allegations as pled by the plaintiff, summarized by Grok.

In December 2022, Jane Doe, a 29-year-old independent music artist from North Carolina, was invited with friends to a house party hosted by Sean Combs in Manhattan, New York City. The lavish white residence featured upscale decor and numerous celebrities, with staff offering food, drinks, and drugs like cocaine and marijuana, which Doe declined, consuming only one glass of wine. Combs approached Doe, expressed interest in her music career, and lured her to his private office to discuss opportunities. There, Doe became disoriented, realizing she was drugged (likely with GHB), and Combs raped and sexually assaulted her while she was unable to resist. She awoke at 6:00 AM in the office with blood on her legs, bruises on her lips, arm imprints suggesting restraint, and vaginal pain. Unable to find her belongings, she dressed in found clothes and fled, suffering lasting emotional distress and trauma.

Prayer for Relief

Plaintiff seeks: (a) compensatory damages for physical injuries, emotional distress, psychological harm, anxiety, humiliation, pain and suffering, family and social disruption, and other harms, in an amount to be determined at trial; (b) punitive damages in an amount to be determined at trial; (c) attorneys’ fees and costs under applicable statutes; (d) pre- and post-judgment interest on damages, fees, and costs; (e) attachment of Defendants’ real property and assets in New York per Federal Rule of Civil Procedure 64; and (f) any other relief the Court deems just and proper.

Causes of Action
FIRST CAUSE OF ACTION Violation of New York City Victims of Gender-Motivated Violence Protection Act (New York City Administrative Code § 10-1103) (All Defendants)
Court Dates
DateTypeDescription
Aug 26, 2026 Filing Deadline Case Management Plan and Scheduling Order due
Docket
Date No. Description
Oct 22, 2024 1 COMPLAINT against Bad Boy Books Holdings, Inc, Bad Boy Entertainment Holdings, Inc., Bad Boy Entertainment LLC, Bad Boy Productions Holdings, Inc., Bad Boy Productions LLC, Bad Boy Records LLC, CE OPCO, LLC, Sean Combs, Daddy's House Recordings Inc., Individual Does 1-10, Organizational Does 1-10. Document filed by Jane Doe..(Curis, Antigone) Modified on 10/23/2024 (pc). Modified on 10/23/2024 (pc). (Entered: 10/22/2024) View PDF
Oct 22, 2024 2 CIVIL COVER SHEET filed..(Curis, Antigone) (Entered: 10/22/2024) No document
Oct 22, 2024 3 REQUEST FOR ISSUANCE OF SUMMONS as to Sean Combs, re: 1 Complaint,. Document filed by Sean Combs..(Curis, Antigone) (Entered: 10/22/2024) No document
Oct 22, 2024 4 FILING ERROR - DUPLICATE DOCKET ENTRY - REQUEST FOR ISSUANCE OF SUMMONS as to Sean Combs, re: 1 Complaint,. Document filed by Jane Doe..(Curis, Antigone) Modified on 1/6/2025 (gp). (Entered: 10/22/2024) No document
Oct 22, 2024 5 REQUEST FOR ISSUANCE OF SUMMONS as to Daddy's House Recordings Inc, re: 1 Complaint,. Document filed by Jane Doe..(Curis, Antigone) Modified on 1/7/2025 (gp). Modified on 1/16/2025 (gp). (Entered: 10/22/2024) No document
Oct 22, 2024 6 REQUEST FOR ISSUANCE OF SUMMONS as to CE Opco, LLC d/b/a Combs Global f/k/a Combs Enterprises LLC, re: 1 Complaint,. Document filed by Jane Doe..(Curis, Antigone) Modified on 1/7/2025 (gp). Modified on 1/16/2025 (gp). (Entered: 10/22/2024) No document
Oct 22, 2024 7 FILING ERROR - PDF ERROR REQUEST FOR ISSUANCE OF SUMMONS as to Bad Boy Entertainment Holdings, Inc, re: 1 Complaint,. Document filed by Jane Doe..(Curis, Antigone) Modified on 1/7/2025 (gp). (Entered: 10/22/2024) No document
Oct 22, 2024 8 FILING ERROR - PDF ERROR REQUEST FOR ISSUANCE OF SUMMONS as to Bad Boy Productions Holdings, Inc, re: 1 Complaint,. Document filed by Jane Doe..(Curis, Antigone) Modified on 1/7/2025 (gp). (Entered: 10/22/2024) No document
Oct 22, 2024 9 FILING ERROR - PDF ERROR REQUEST FOR ISSUANCE OF SUMMONS as to Bad Boy Books Holdings, Inc, re: 1 Complaint,. Document filed by Jane Doe..(Curis, Antigone) Modified on 1/7/2025 (gp). (Entered: 10/22/2024) No document
Oct 22, 2024 10 FILING ERROR - PDF ERROR REQUEST FOR ISSUANCE OF SUMMONS as to Bad Boy Records LLC, re: 1 Complaint,. Document filed by Jane Doe..(Curis, Antigone) Modified on 1/7/2025 (gp). (Entered: 10/22/2024) No document
Oct 22, 2024 11 REQUEST FOR ISSUANCE OF SUMMONS as to Bad Boy Entertainment LLC, re: 1 Complaint,. Document filed by Jane Doe..(Curis, Antigone) Modified on 1/7/2025 (gp). Modified on 1/16/2025 (gp). (Entered: 10/22/2024) No document
Oct 22, 2024 12 REQUEST FOR ISSUANCE OF SUMMONS as to Bad Boy Productions LLC, re: 1 Complaint,. Document filed by Jane Doe..(Curis, Antigone) Modified on 1/7/2025 (gp). Modified on 1/16/2025 (gp). (Entered: 10/22/2024) No document
Oct 22, 2024 13 FIRST MOTION Motion for Leave to Appear Anonymously re: 1 Complaint, Notice of Motion. Document filed by Jane Doe..(Curis, Antigone) (Entered: 10/22/2024) No document
Oct 22, 2024 14 DECLARATION of Anthony G. Buzbee in Support re: 13 FIRST MOTION Motion for Leave to Appear Anonymously re: 1 Complaint, Notice of Motion.. Document filed by Jane Doe..(Curis, Antigone) (Entered: 10/22/2024) No document
Oct 22, 2024 15 FIRST MEMORANDUM OF LAW in Support re: 13 FIRST MOTION Motion for Leave to Appear Anonymously re: 1 Complaint, Notice of Motion. . Document filed by Jane Doe..(Curis, Antigone) (Entered: 10/22/2024) No document
Oct 22, 2024 16 PROPOSED ORDER. Document filed by Jane Doe. Related Document Number: [13-17]..(Curis, Antigone) Proposed Order to be reviewed by Clerk's Office staff. (Entered: 10/22/2024) No document
Oct 23, 2024 17 NOTICE OF INITIAL PRETRIAL CONFERENCE: Initial Conference set for 1/10/2025 at 10:00 AM in Courtroom 443, 40 Centre Street, New York, NY 10007 before Judge Valerie E. Caproni. (Signed by Judge Valerie E. Caproni on 10/23/2024) (tg) (Entered: 10/23/2024) No document
Oct 24, 2024 18 ORDER granting 13 Motion. IT IS HEREBY ORDERED that Plaintiffs motion to appear anonymously is GRANTED. IT IS FURTHER ORDERED that Plaintiff shall file a renewed motion to continue to proceed anonymously by not later than 30 days after service of the Complaint to provide Defendants an opportunity to respond to her motion. If Plaintiff fails to timely file this motion, the Court shall order the disclosure of her identity. SO ORDERED. (Signed by Judge Valerie E. Caproni on 10/24/2024) (tg) (Entered: 10/24/2024) View PDF
Dec 30, 2024 19 FIRST LETTER addressed to Judge Valerie E. Caproni from Plaintiff dated December 30, 2024 re: Conference. Document filed by Jane Doe..(Curis, Antigone) (Entered: 12/30/2024) View PDF
Jan 2, 2025 20 MEMO ENDORSEMENT on re: 19 Letter filed by Jane Doe. ENDORSEMENT: Application GRANTED. The Initial Pretrial Conference scheduled for Friday, January 10, 2025, at 10:00 A.M. is ADJOURNED to Friday, February 14, 2025, at 10:00 A.M. The parties' deadline to submit a joint letter and proposed case management plan in accordance with the Court's prior Order at Dkt. 17 is extended from Thursday, January 2, 2025, to Thursday, February 6, 2025. SO ORDERED. ( Initial Conference set for 2/14/2025 at 10:00 AM before Judge Valerie E. Caproni.) (Signed by Judge Valerie E. Caproni on 1/2/2025) (tg) (Entered: 01/02/2025) No document
Jan 10, 2025 21 NOTICE OF APPEARANCE by Donald S. Zakarin on behalf of Bad Boy Records LLC..(Zakarin, Donald) (Entered: 01/10/2025) No document
Jan 10, 2025 22 NOTICE OF APPEARANCE by William Laurence Charron on behalf of Bad Boy Records LLC..(Charron, William) (Entered: 01/10/2025) No document
Jan 10, 2025 23 NOTICE OF APPEARANCE by Nicholas George Saady on behalf of Bad Boy Records LLC..(Saady, Nicholas) (Entered: 01/10/2025) No document
Jan 10, 2025 24 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Other Affiliate Atlantic Recording Corporation, Other Affiliate AI Entertainment Holdings LLC, Other Affiliate Bad Boy Records, Other Affiliate BB Investments, LLC, Other Affiliate Warner Music Group Corp. for Bad Boy Records LLC. Document filed by Bad Boy Records LLC..(Saady, Nicholas) (Entered: 01/10/2025) No document
Jan 13, 2025 25 SECOND MOTION Motion for Leave to Appear Anonymously . Document filed by Jane Doe..(Curis, Antigone) (Entered: 01/13/2025) No document
Jan 13, 2025 26 DECLARATION of Anthony G. Buzbee in Support re: 25 SECOND MOTION Motion for Leave to Appear Anonymously .. Document filed by Jane Doe..(Curis, Antigone) (Entered: 01/13/2025) No document
Jan 13, 2025 27 FIRST MEMORANDUM OF LAW in Support re: 25 SECOND MOTION Motion for Leave to Appear Anonymously . . Document filed by Jane Doe..(Curis, Antigone) (Entered: 01/13/2025) No document
Jan 13, 2025 28 PROPOSED ORDER. Document filed by Jane Doe. Related Document Number: [25-28]..(Curis, Antigone) Proposed Order to be reviewed by Clerk's Office staff. (Entered: 01/13/2025) No document
Jan 14, 2025 29 JOINT LETTER MOTION for Extension of Time to File Answer re: 1 Complaint, 25 SECOND MOTION Motion for Leave to Appear Anonymously . addressed to Judge Valerie E. Caproni from Counsel for All Parties dated 1/14/2025. Document filed by Bad Boy Entertainment LLC, Bad Boy Productions LLC, Sean Combs, Daddy's House Recordings Inc., CE OPCO, LLC, Bad Boy Entertainment Holdings, Inc., Bad Boy Productions Holdings, Inc., Bad Boy Books Holdings, Inc..(Cuccaro, Mark) (Entered: 01/14/2025) No document
Jan 14, 2025 30 ORDER granting 29 Letter Motion for Extension of Time to Answer re 1 Complaint,. Application GRANTED. Defendants' deadline to answer or otherwise respond to the Complaint is ADJOURNED to Tuesday, March 11, 2025. Defendants' deadline to file opposition papers to Plaintiff's Second Motion for Leave to Appear Anonymously at Dkt. 25 is also Tuesday, March 11, 2025. Plaintiff's deadline to file reply papers, if any, is Tuesday, March 25, 2025. IT IS FURTHER ORDERED that Plaintiff must serve Defendants and file proof of service on ECF by Tuesday, January 21, 2025. SO ORDERED. Bad Boy Books Holdings, Inc answer due 3/11/2025; Bad Boy Entertainment Holdings, Inc. answer due 3/11/2025; Bad Boy Entertainment LLC answer due 3/11/2025; Bad Boy Productions Holdings, Inc. answer due 3/11/2025; Bad Boy Productions LLC answer due 3/11/2025; Bad Boy Records LLC answer due 3/11/2025; CE OPCO, LLC answer due 3/11/2025; Sean Combs answer due 3/11/2025; Daddy's House Recordings Inc. answer due 3/11/2025. (Signed by Judge Valerie E. Caproni on 1/14/2025) (tg) (Entered: 01/15/2025) View PDF
Jan 16, 2025 31 ELECTRONIC SUMMONS ISSUED as to Sean Combs..(gp) (Entered: 01/16/2025) View PDF
Jan 16, 2025 32 ELECTRONIC SUMMONS ISSUED as to Daddy's House Recordings Inc...(gp) (Entered: 01/16/2025) No document
Jan 16, 2025 33 ELECTRONIC SUMMONS ISSUED as to CE OPCO, LLC..(gp) (Entered: 01/16/2025) No document
Jan 16, 2025 34 ELECTRONIC SUMMONS ISSUED as to Bad Boy Productions LLC..(gp) (Entered: 01/16/2025) No document
Jan 16, 2025 35 ELECTRONIC SUMMONS ISSUED as to Bad Boy Entertainment LLC..(gp) (Entered: 01/16/2025) No document
Jan 16, 2025 36 REQUEST FOR ISSUANCE OF SUMMONS as to SEAN COMBS, DADDYS HOUSE RECORDINGS INC., CE OPCO, LLC d/b/a COMBS GLOBAL f/k/a COMBS ENTERPRISES LLC, BAD BOY ENTERTAINMENT HOLDINGS, INC., BAD BOY PRODUCTIONS HOLDINGS, INC., BAD BOY BOOKS HOLDINGS, INC., BAD BOY RECORDS LLC, BAD BOY ENTERTAINMENT LLC, BAD BOY PRODUCTIONS LLC,, re: 1 Complaint,. Document filed by Jane Doe..(Curis, Antigone) (Entered: 01/16/2025) View PDF
Jan 17, 2025 37 ELECTRONIC SUMMONS ISSUED as to Bad Boy Books Holdings, Inc, Bad Boy Entertainment Holdings, Inc., Bad Boy Entertainment LLC, Bad Boy Productions Holdings, Inc., Bad Boy Productions LLC, Bad Boy Records LLC, CE OPCO, LLC, Sean Combs, Daddy's House Recordings Inc...(gp) (Entered: 01/17/2025) No document
Jan 21, 2025 38 AFFIDAVIT OF SERVICE. Document filed by Jane Doe..(Curis, Antigone) (Entered: 01/21/2025) No document
Jan 22, 2025 39 NOTICE OF APPEARANCE by Mark Elliot Cuccaro on behalf of Bad Boy Entertainment LLC, Bad Boy Productions LLC, Sean Combs, Daddy's House Recordings Inc., CE OPCO, LLC, Bad Boy Entertainment Holdings, Inc., Bad Boy Productions Holdings, Inc., Bad Boy Books Holdings, Inc..(Cuccaro, Mark) (Entered: 01/22/2025) View PDF
Jan 23, 2025 40 NOTICE OF APPEARANCE by Erica Ashley Wolff on behalf of Bad Boy Entertainment LLC, Bad Boy Productions LLC, Sean Combs, Daddy's House Recordings Inc., CE OPCO, LLC, Bad Boy Entertainment Holdings, Inc., Bad Boy Productions Holdings, Inc., Bad Boy Books Holdings, Inc..(Wolff, Erica) (Entered: 01/23/2025) No document
Jan 23, 2025 41 NOTICE OF APPEARANCE by Michael Tremonte on behalf of Bad Boy Entertainment LLC, Bad Boy Productions LLC, Sean Combs, Daddy's House Recordings Inc., CE OPCO, LLC, Bad Boy Entertainment Holdings, Inc., Bad Boy Productions Holdings, Inc., Bad Boy Books Holdings, Inc..(Tremonte, Michael) (Entered: 01/23/2025) No document
Jan 28, 2025 42 JOINT LETTER MOTION to Adjourn Conference addressed to Judge Valerie E. Caproni from Counsel for All Parties dated 1/28/2025. Document filed by Bad Boy Entertainment LLC, Bad Boy Productions LLC, Sean Combs, Daddy's House Recordings Inc., CE OPCO, LLC, Bad Boy Entertainment Holdings, Inc., Bad Boy Productions Holdings, Inc., Bad Boy Books Holdings, Inc..(Cuccaro, Mark) (Entered: 01/28/2025) View PDF
Jan 29, 2025 43 ORDER granting 42 Letter Motion to Adjourn Conference. Application GRANTED. The Initial Pretrial Conference scheduled for Friday, February 14, 2025, is ADJOURNED sine die. Discovery in this matter is STAYED pending resolution of Defendants' forthcoming motions to dismiss. SO ORDERED. (Signed by Judge Valerie E. Caproni on 1/29/2025) (tg) (Entered: 01/29/2025) View PDF
Feb 18, 2025 44 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Bad Boy Books Holdings, Inc..(Cuccaro, Mark) (Entered: 02/18/2025) No document
Feb 18, 2025 45 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Bad Boy Entertainment Holdings, Inc...(Cuccaro, Mark) (Entered: 02/18/2025) No document
Feb 18, 2025 46 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..(Cuccaro, Mark) (Entered: 02/18/2025) No document
Feb 18, 2025 47 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Bad Boy Productions Holdings, Inc...(Cuccaro, Mark) (Entered: 02/18/2025) No document
Feb 18, 2025 48 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Corporate Parent Bad Boy Productions Holdings, Inc. for Bad Boy Productions LLC. Document filed by Bad Boy Productions LLC..(Cuccaro, Mark) (Entered: 02/18/2025) No document
Feb 18, 2025 49 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Corporate Parent 1169 Group Holdings LLC, Other Affiliate 1169 Corp. for CE OPCO, LLC. Document filed by CE OPCO, LLC..(Cuccaro, Mark) (Entered: 02/18/2025) No document
Feb 18, 2025 50 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Daddy's House Recordings Inc...(Cuccaro, Mark) (Entered: 02/18/2025) No document
Mar 7, 2025 51 FIRST LETTER addressed to Judge Valerie E. Caproni from Plaintiff dated March 7, 2025 re: Stipulation for Bad Boy Records LLC. Document filed by Jane Doe..(Curis, Antigone) (Entered: 03/07/2025) No document
Mar 10, 2025 52 NOTICE OF APPEARANCE by Raphael Asher Friedman on behalf of Bad Boy Entertainment LLC, Bad Boy Productions LLC, Sean Combs, Daddy's House Recordings Inc., CE OPCO, LLC, Bad Boy Entertainment Holdings, Inc., Bad Boy Productions Holdings, Inc., Bad Boy Books Holdings, Inc..(Friedman, Raphael) (Entered: 03/10/2025) No document
Mar 10, 2025 53 STIPULATION: IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned attorneys for the parties identified below, that the time of the Defendant BAD BOY RECORDS LLC, in which to answer, move or otherwise respond to the Summons and Complaint of the Plaintiff JANE DOE, has been extended up to and April 4, 2025; and SO ORDERED. Bad Boy Records LLC answer due 4/4/2025. (Signed by Judge Valerie E. Caproni on 3/10/2025) (tg) (Entered: 03/11/2025) View PDF
Mar 11, 2025 54 MEMORANDUM OF LAW in Opposition re: 25 SECOND MOTION Motion for Leave to Appear Anonymously . . Document filed by Bad Boy Entertainment LLC, Bad Boy Productions LLC, Sean Combs, Daddy's House Recordings Inc., CE OPCO, LLC, Bad Boy Entertainment Holdings, Inc., Bad Boy Productions Holdings, Inc., Bad Boy Books Holdings, Inc..(Cuccaro, Mark) (Entered: 03/11/2025) View PDF
Mar 11, 2025 55 MOTION to Dismiss the Complaint. Document filed by Bad Boy Entertainment LLC, Bad Boy Productions LLC, Sean Combs, Daddy's House Recordings Inc., CE OPCO, LLC, Bad Boy Entertainment Holdings, Inc., Bad Boy Productions Holdings, Inc., Bad Boy Books Holdings, Inc..(Cuccaro, Mark) (Entered: 03/11/2025) View PDF
Mar 11, 2025 56 DECLARATION of Mark Cuccaro in Support re: 55 MOTION to Dismiss the Complaint.. Document filed by Bad Boy Entertainment LLC, Bad Boy Productions LLC, Sean Combs, Daddy's House Recordings Inc., CE OPCO, LLC, Bad Boy Entertainment Holdings, Inc., Bad Boy Productions Holdings, Inc., Bad Boy Books Holdings, Inc. (Attachments: # 1 Exhibit A - Aerial View Images of Manhattan, # 2 Exhibit B Amended Complaint in Doe v. Sean Combs et al., No. 24-cv-07776 (NRB) (S.D.N.Y), # 3 Exhibit C Complaint in Doe v. Sean Combs et al., No. 24-cv-07778 (JLR) (S.D.N.Y), # 4 Exhibit D Complaint in Doe v. Sean Combs et al., No. 24-cv-08813 (JGK) (S.D.N.Y), # 5 Exhibit E Complaint in Doe v. Sean Combs et al., No. 152725/2025 (Sup. Ct. N.Y. Cnty.), # 6 Exhibit F Complaint in Doe v. Sean Combs et al., No. 152726/2025 (Sup. Ct. N.Y Cnty.), # 7 Exhibit G Complaint in Doe v. Sean Combs et al., No. 152727/2025 (Sup. Ct. N.Y. Cnty.), # 8 Exhibit H Deed Record and Photo of Long Island Property, # 9 Exhibit I Images of Three Manhattan Properties, # 10 Exhibit J Delgado v. Donald J. Trump for President, Inc., No. 952333/2023 (Sup. Ct. N.Y. Cnty.)).(Cuccaro, Mark) (Entered: 03/11/2025) No document
Mar 11, 2025 57 MEMORANDUM OF LAW in Support re: 55 MOTION to Dismiss the Complaint. . Document filed by Bad Boy Entertainment LLC, Bad Boy Productions LLC, Sean Combs, Daddy's House Recordings Inc., CE OPCO, LLC, Bad Boy Entertainment Holdings, Inc., Bad Boy Productions Holdings, Inc., Bad Boy Books Holdings, Inc..(Cuccaro, Mark) (Entered: 03/11/2025) No document
Mar 14, 2025 58 JOINT LETTER MOTION for Extension of Time to File Response/Reply as to 55 MOTION to Dismiss the Complaint. addressed to Judge Valerie E. Caproni from Mark Cuccaro dated March 14, 2025. Document filed by Bad Boy Entertainment LLC, Bad Boy Productions LLC, Sean Combs, Daddy's House Recordings Inc., CE OPCO, LLC, Bad Boy Entertainment Holdings, Inc., Bad Boy Productions Holdings, Inc., Bad Boy Books Holdings, Inc..(Cuccaro, Mark) (Entered: 03/14/2025) No document
Mar 17, 2025 59 ORDER granting 58 Letter Motion for Extension of Time to File Response/Reply. Application GRANTED. Plaintiff's deadline to oppose Defendants' motion to dismiss is ADJOURNED from Tuesday, March 25, 2025, to Tuesday, April 29, 2025. Defendants' deadline to file reply papers is ADJOURNED from Tuesday, April 1, 2025, to Friday, May 30, 2025. The Court is highly unlikely to further adjourn the above deadlines. SO ORDERED. Responses due by 4/29/2025 Replies due by 5/30/2025. (Signed by Judge Valerie E. Caproni on 3/17/2025) (tg) (Entered: 03/17/2025) No document
Mar 19, 2025 60 FIRST MOTION to Withdraw . Document filed by Jane Doe..(Curis, Antigone) (Entered: 03/19/2025) No document
Mar 20, 2025 61 MEMO ENDORSEMENT granting 60 Motion to Withdraw. ENDORSEMENT: Application GRANTED. The Clerk of Court is respectfully directed to terminate the open motion at Dkt. 60. SO ORDERED. (Signed by Judge Valerie E. Caproni on 3/20/2025) (tg) (Entered: 03/20/2025) No document
Mar 26, 2025 62 REPLY AFFIRMATION of Antigone Curis, Esq. in Opposition re: 25 SECOND MOTION Motion for Leave to Appear Anonymously .. Document filed by Jane Doe. (Attachments: # 1 Exhibit Affidavit).(Curis, Antigone) (Entered: 03/26/2025) No document
Mar 28, 2025 63 LETTER addressed to Judge Valerie E. Caproni from Mark Cuccaro dated March 28, 2025 re: Notice of Supplemental Authority to Combs Defendants' Opposition (ECF No. 54). Document filed by Bad Boy Books Holdings, Inc, Bad Boy Entertainment Holdings, Inc., Bad Boy Entertainment LLC, Bad Boy Productions Holdings, Inc., Bad Boy Productions LLC, CE OPCO, LLC, Sean Combs, Daddy's House Recordings Inc.. (Attachments: # 1 Exhibit A - Opinion and Order in Doe v. Combs et al., No. 24-cv-09852 (JLR) (S.D.N.Y. Mar. 27, 2025)).(Cuccaro, Mark) (Entered: 03/28/2025) No document
Apr 1, 2025 64 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) Bad Boy Records LLC. Document filed by Jane Doe. Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers)...(Curis, Antigone) (Entered: 04/01/2025) View PDF
Apr 2, 2025 65 NOTICE OF VOLUNTARY DISMISSAL SOLELY OF DEFENDANT BAD BOY RECORDS LLC, PURSUANT TO RULE 41(a)(1)(A)(i) OF THE FEDERAL RULES OF CIVIL PROCEDURE: Pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the Plaintiff Jane Doe, by and through her undersigned counsel, hereby gives notice that the above-captioned Action is voluntarily dismissed, without prejudice, solely as against Defendant Bad Boy Records LLC ("BBRLLC"). This voluntary dismissal is not with respect to any Defendant other than BBRLLC in the above-captioned Action. The same is acknowledged and agreed by BBRLLC, by and through its undersigned counsel. SO ORDERED. Bad Boy Records LLC terminated. (Signed by Judge Valerie E. Caproni on 4/2/2025) (tg) (Entered: 04/02/2025) No document
Apr 4, 2025 66 FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION for David C. Fortney to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-30883699. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Jane Doe. (Attachments: # 1 Affidavit of David C. Fortney, # 2 Exhibit Certificate of Good Standing-TX, # 3 Exhibit Certificate of Good Standing-CA, # 4 Exhibit Certificate of Good Standing-TX, # 5 Proposed Order ).(Fortney, David) Modified on 4/4/2025 (rju). (Entered: 04/04/2025) No document
Apr 9, 2025 67 MOTION for David C. Fortney to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Jane Doe. (Attachments: # 1 Affidavit of David C. Fortney, # 2 Exhibit Certificate of Good Standing-TX, # 3 Exhibit Certificate of Good Standing-CA, # 4 Exhibit Certificate of Good Standing-TX, # 5 Proposed Order ).(Fortney, David) (Entered: 04/09/2025) No document
Apr 11, 2025 68 ORDER FOR ADMISSION PRO HAC VICE granting 67 Motion to Appear Pro Hac Vice. The motion of David C. Fortney for admission to practice pro hac vice in the above-captioned action is granted. As further set forth by this Order. (Signed by Judge Valerie E. Caproni on 4/11/2025) (tg) (Entered: 04/11/2025) No document
Apr 29, 2025 69 FIRST MEMORANDUM OF LAW in Opposition re: 55 MOTION to Dismiss the Complaint. . Document filed by Jane Doe..(Curis, Antigone) (Entered: 04/29/2025) View PDF
May 13, 2025 70 MEMORANDUM OPINION AND ORDER re: 25 SECOND MOTION Motion for Leave to Appear Anonymously . filed by Jane Doe. For the foregoing reasons, Plaintiff's motion for the leave to proceed anonymously is DENIED. Although Plaintiff's lawsuit involves a highly sensitive and personal subject matter and her identity has heretofore apparently remained secret, the remaining Sealed Plaintiff factors weigh against anonymity. Plaintiff's showing of risk of harm is too speculative, and the prejudice to Defendants too great, to allow her to proceed anonymously. The public interest factors and the availability of another mechanism to provide protection of sensitive information further buttress the conclusion that Plaintiff has not rebutted the presumption that her identity must be disclosed. By Wednesday, May 28, 2025, Plaintiff must refile the Complaint in her own name. The Clerk of Court is respectfully directed to terminate the open motion at Dkt. 25. (Signed by Judge Valerie E. Caproni on 5/13/2025) (rro) (Entered: 05/14/2025) View PDF
May 28, 2025 71 FIRST AMENDED COMPLAINT amending 1 Complaint, against Bad Boy Books Holdings, Inc, Bad Boy Entertainment Holdings, Inc., Bad Boy Entertainment LLC, Bad Boy Productions Holdings, Inc., Bad Boy Productions LLC, CE OPCO, LLC, Sean Combs, Daddy's House Recordings Inc., Individual Does 1-10, Organizational Does 1-10 with JURY DEMAND.Document filed by Shante Kelly. Related document: 1 Complaint,. (Attachments: # 1 Exhibit Redline Amended Complaint).(Curis, Antigone) (Entered: 05/28/2025) View PDF
May 30, 2025 72 REPLY MEMORANDUM OF LAW in Support re: 55 MOTION to Dismiss the Complaint. . Document filed by Bad Boy Books Holdings, Inc, Bad Boy Entertainment Holdings, Inc., Bad Boy Entertainment LLC, Bad Boy Productions Holdings, Inc., Bad Boy Productions LLC, CE OPCO, LLC, Sean Combs, Daddy's House Recordings Inc...(Cuccaro, Mark) (Entered: 05/30/2025) View PDF
Oct 22, 2025 73 OPINION AND ORDER re: 55 MOTION to Dismiss the Complaint. filed by Bad Boy Books Holdings, Inc, Bad Boy Productions Holdings, Inc., CE OPCO, LLC, Bad Boy Entertainment LLC, Daddy's House Recordings Inc., Bad Boy Product ions LLC, Sean Combs, Bad Boy Entertainment Holdings, Inc..In sum, the Amended Complaint lacks any allegations from which the Court can infer that the Corporate Defendants engaged in any misconduct. Additionally, Plaintiff's Opposition rai ses serious doubts about the reasonableness of counsel's inquiry into whether the events alleged in the Amended Complaint occurred in New York City - a fact necessary to state a claim pursuant to the GMVPA. Accordingly, Defendants' Motion to Dismiss is GRANTED. The Clerk of the Court is respectfully directed to terminate the open motion at Dkt. 55. It is possible that Plaintiff may, upon further investigation, be able to allege additional facts to allow the Court plausibly to infer that (1) the Corporate Defendants are liable pursuant to the GMVPA and (2) the events alleged in the Amended Complaint occurred in New York City. The Court, therefore, grants Plaintiff leave to file a Second Amended Complaint. Any such amended complaint must be filed not later than Friday, November 21, 2025, and must comply with the Court's Local Rules and the Undersigned's Individual Practices in Civil Case. SO ORDERED. ( Amended Pleadings due by 11/21/2025.) (Signed by Judge Valerie E. Caproni on 10/22/2025) (tg) View PDF
Nov 21, 2025 74 FILING ERROR - DEFICIENT PLEADING - FILED AGAINST PARTY ERROR SECOND AMENDED COMPLAINT amending 71 Amended Complaint, 1 Complaint, against All Defendants with JURY DEMAND.Document filed by Shante Kelly. Related document: 71 Amended Complaint, 1 Complaint,. (Attachments: # 1 Exhibit Redline Amended Complaint).(Curis, Antigone) Modified on 11/24/2025 (jgo). (Entered: 11/21/2025) View PDF
Nov 24, 2025 75 ORDER: IT IS HEREBY ORDERED that, not later than Tuesday, December 9, 2025, the parties must meet and confer and file a joint letter. If Defendants intend to move to dismiss the Second Amended Complaint, the joint letter must contain a proposed brie fing schedule and indicate the parties' positions on whether it is appropriate to continue the stay of discovery pending resolution of the second motion to dismiss. If Defendants intend to answer the Second Amended Complaint, the joint letter must propose a deadline for Defendants to do so, and the parties must file a proposed Civil Case Management Plan and Scheduling Order (the template for which is available at https://nysd.uscourts.gov/hon-valerie-e-caproni). (Signed by Judge Valerie E. Caproni on 11/24/2025) (rro) View PDF
Nov 25, 2025 76 SECOND AMENDED COMPLAINT amending 71 Amended Complaint, 74 Amended Complaint, 1 Complaint, against Bad Boy Books Holdings, Inc, Bad Boy Entertainment Holdings, Inc., Bad Boy Entertainment LLC, Bad Boy Productions Holdings, Inc., Bad Boy Productions LLC, Bad Boy Records LLC, CE OPCO, LLC, Sean Combs, Daddy's House Recordings Inc., Jane Doe, Individual Does 1-10, Organizational Does 1-10 with JURY DEMAND.Document filed by Shante Kelly. Related document: 71 Amended Complaint, 74 Amended Complaint, 1 Complaint,. (Attachments: # 1 Exhibit Redline Amended Complaint).(Curis, Antigone) (Entered: 11/25/2025) View PDF Exhibit Redline Amended Complaint).(Curis, Antigone
Dec 9, 2025 77 JOINT LETTER addressed to Judge Valerie E. Caproni from Mark Cuccaro dated December 9, 2025 re: ECF #75 Order. Document filed by Bad Boy Books Holdings, Inc, Bad Boy Entertainment Holdings, Inc., Bad Boy Entertainment LLC, Bad Boy Productions Holdings, Inc., Bad Boy Productions LLC, CE OPCO, LLC, Sean Combs, Daddy's House Recordings Inc...(Cuccaro, Mark) (Entered: 12/09/2025) View PDF
Dec 9, 2025 78 MEMO ENDORSEMENT on re: 77 Letter, filed by Bad Boy Books Holdings, Inc, Bad Boy Productions Holdings, Inc., CE OPCO, LLC, Bad Boy Entertainment LLC, Daddy's House Recordings Inc., Bad Boy Productions LLC, Sean Combs, Bad Boy Entertainment Holdings, Inc.. ENDORSEMENT: Application GRANTED. SO ORDERED. ( Motions due by 1/30/2026., Responses due by 2/27/2026, Replies due by 3/20/2026.) (Signed by Judge Valerie E. Caproni on 12/9/2025) (tg) (Entered: 12/09/2025) No document
Jan 30, 2026 79 Dismiss (Document #79, filed 01/30/2026) No document
Jan 30, 2026 80 Memorandum of Law in Support of Motion (Document #80, filed 01/30/2026) No document
Feb 27, 2026 81 Memorandum of Law in Opposition to Motion (Document #81, filed 02/27/2026) No document
Mar 20, 2026 82 Reply Memorandum of Law in Support of Motion (Document #82, filed 03/20/2026) No document
Oct 23, 2024 17.1 ***NOTICE TO ATTORNEY REGARDING CIVIL. CASE OPENING STATISTICAL ERROR CORRECTION: Notice to attorney Antigone Curis. 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;. (pc) No document
Oct 23, 2024 17.2 ***NOTICE TO ATTORNEY TO PAY THE FILING FEE. Notice to Attorney Antigone Curis. Civil Case Opening Fee of Due: for 1 Complaint,. The filing fee due was not paid; either in whole or in part. If the filing fee is not paid within five (5) days, per Amended Standing Order 15-mc-131, this case will be administratively closed. Filing Fee due by 10/28/2024..(pc) No document
Oct 23, 2024 17.3 Civil Case Opening Fee Payment: for 1 Complaint,. Filing fee $ 405.00, receipt number ANYSDC-30081155..(Curis, Antigone) No document
Oct 23, 2024 17.4 CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Valerie E. Caproni. 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..(pc) No document
Oct 23, 2024 17.5 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. (pc) No document
Oct 23, 2024 17.6 ***NOTICE TO COURT REGARDING PROPOSED ORDER. Document No. 16 Proposed Order was reviewed and approved as to form. (tp) No document
Oct 23, 2024 17.7 Case Designated ECF. (pc) No document
Jan 7, 2025 20.1 ***NOTICE TO ATTORNEY REGARDING DEFICIENT REQUEST FOR ISSUANCE OF SUMMONS. Notice to Attorney Antigone Curis to RE-FILE Document No. [4-12] Request for Issuance of Summons. The filing is deficient for the following reason(s): the case number on the PDF is incorrect. 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. (gp) No document
Jan 7, 2025 20.2 ***DELETED DOCUMENT. Deleted document number [21-25] Issuance of Summons. The document was incorrectly filed in this case, the PDF have the wrong case number on them. (gp) No document
Jan 7, 2025 20.3 ***NOTICE TO ATTORNEY REGARDING DEFICIENT REQUEST FOR ISSUANCE OF SUMMONS. Notice to Attorney Antigone Curis to RE-FILE Document No. [7-10] Request for Issuance of Summons. The filing is deficient for the following reason(s): the case number on the PDF is incorrect. 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. (gp) Modified on 1/16/2025 (gp). No document
Jan 14, 2025 30.1 Set/Reset Deadlines: Responses due by 3/11/2025 Replies due by 3/25/2025. (tg) No document
Jan 14, 2025 30.2 ***NOTICE TO COURT REGARDING PROPOSED ORDER. Document No. 28 Proposed Order was reviewed and approved as to form. (tp) No document
Apr 2, 2025 65.1 ***NOTICE TO COURT REGARDING NOTICE OF VOLUNTARY DISMISSAL Document No. 64 Notice of Voluntary Dismissal, was reviewed and referred to Judge Valerie E. Caproni 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. (tp) No document
Apr 4, 2025 66.1 >>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. 66 MOTION for David C. Fortney to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-30883699. 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.. (rju) No document
Apr 10, 2025 67.1 >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. 67 MOTION for David C. Fortney 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
Nov 24, 2025 75.1 ***NOTICE TO ATTORNEY REGARDING DEFICIENT PLEADING. Notice to Attorney Antigone Curis to RE-FILE Document No. 74 Second Amended Complaint,. The filing is deficient for the following reason(s): the All Defendant radio button was selected;. Re-file the pleading using the event type Second 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
Attorneys
Christopher J. Leavitt
The Buzbee Law Firm
Plaintiff
Ryan S. Pigg
The Buzbee Law Firm
Plaintiff
David C. Fortney
The Buzbee Law Firm
Plaintiff
Thomas Colby Holler
The Buzbee Law Firm
Plaintiff
Lionel Sims III
The Buzbee Law Firm
Plaintiff
Crystal Del Toro
The Buzbee Law Firm
Plaintiff
Andrew Van Arsdale
AVA Law Group
Plaintiff
Antigone Curis
Curis Law, PLLC
Plaintiff
Erica A. Wolff
Sher Tremonte
Civil Defense