Clayton Howard v. Sean Combs et al

In late 2009, Clayton Howard met Casandra Ventura, who used the alias 'Jackie Star,' at The London hotel in New York City, where she concealed her identity and invited him as a male companion for an agreed-upon hourly rate. Ventura offered Howard alcohol and marijuana, then revealed the presence of her 'husband,' Sean Combs, introduced as 'Frank,' who was involved in voyeuristic activities and directed sexual encounters. Between 2009 and 2019, Howard was subjected to systematic sexual exploitation, involving drugging with substances like MDMA, coercion, and non-consensual sexual acts, orchestrated by Combs and Ventura. Ventura manipulated Howard into unprotected sex, including during her menstrual cycle at the Beverly Hills Hotel, resulting in physical injuries and a Chlamydia infection. Howard was flown across state lines (New York to Miami and Los Angeles) for commercial sexual exploitation, with hotel staff misled to believe he was 'security' for Bad Boy Records. Combs and Ventura used drugs (Ecstasy, GHB, Ketamine, Cocaine, MDMA, Marijuana) to lower Howard’s inhibitions, with Ventura admitting to tripling his MDMA dosage to intensify encounters. Howard witnessed domestic violence by Combs against Ventura, driven by jealousy and other factors, but not due to her refusal to engage in sexual activities. Defendants recorded Howard in compromising encounters without consent, using the recordings for mutual gratification. Howard was coerced into prolonged sexual activities, causing physical injuries such as skin tears and scabbing, and was detained for days without access to his belongings. In December 2023, Howard cooperated with the U.S. Attorney’s Office for the Southern District of New York, providing evidence of illegal activities, but his allegations against Ventura were not pursued to protect her credibility as a witness. Howard’s former counsel, Tyrone Blackburn, delayed filing a civil action to protect Ventura’s image, compromising Howard’s legal rights under New York’s statute of limitations.

Plaintiff seeks compensatory damages for past and future medical expenses, lost earnings, diminished earning capacity, pain and suffering, and emotional distress; punitive damages to punish defendants and deter similar conduct; pre- and post-judgment interest; reasonable attorney’s fees and costs; and other relief deemed just and proper.