Case #22STCV31383 · California Superior Court, Los Angeles County

Wales-Walden v. Sean Combs et al

Filed September 27, 2022 Judge Judge Maureen Duffy-Lewis
Closed 200 S. Mapleton Drive LLC CE OPCO LLC Combs Enterprises LLC Sean Combs Tri Star Sports and Entertainment Group Inc.
Contains Discrimination · Retaliation · Pregnancy Discrimination · Emotional Distress
Parties
Jane Roe (Raven Wales-Walden) Plaintiff
200 S. Mapleton Drive LLC
CE OPCO LLC
Combs Enterprises LLC
Sean Combs
Tri Star Sports and Entertainment Group Inc.
Factual Allegations
Disclaimer: allegations as pled by the plaintiff, summarized by Grok.

Plaintiff began working as a personal assistant to Kim Porter, Sean Combs’ former partner, in September 2018, assisting with creative projects and childcare for Combs’ twin daughters. Following Porter’s death on November 15, 2018, Combs personally asked Plaintiff to live at his estate at 200 S. Mapleton Drive, Los Angeles, to become a full-time nanny, which she accepted. Plaintiff provided 24/7 care, living in the same bedroom as the twins, performing duties like household chores, meal preparation, and transportation. In August 2020, Plaintiff announced her pregnancy and need for maternity leave, prompting hostility from Combs and his family manager, April Butler, who initiated a campaign to fire her, spreading false rumors of her resignation. Plaintiff protested the retaliation, and Combs promised medical and dental insurance for two years and coverage for pregnancy-related costs. However, Defendants presented a 'transition agreement' that would terminate her employment, which she refused to sign. In January 2021, while eight months pregnant, Plaintiff was fired, allegedly for being pregnant and unmarried, deemed a bad example for Combs’ daughters. Combs refused to honor promised healthcare benefits. Plaintiff was misclassified as a salaried employee, worked overtime without compensation, and was denied required meal and rest periods and accurate wage statements. Defendants’ actions violated California labor laws and constituted discrimination and retaliation based on sex, pregnancy, and maternity leave requests.

Prayer for Relief

Plaintiff seeks general, actual, consequential, and incidental damages for financial losses (e.g., lost wages, benefits, and career opportunities), emotional distress, punitive damages, statutory and civil penalties, restitution, equitable relief, prejudgment interest, attorneys’ fees, expert witness fees, costs of lawsuit, and injunctive relief requiring Defendants to conduct FEHA and CFRA training, refrain from further discriminatory/retaliatory acts, and other relief to prevent unlawful employment practices.

Causes of Action
FIRST CAUSE OF ACTION Discrimination On the Basis of Sex and Pregnancy (Gov. Code §§ 12940(a) & 12926(r)) (Against all Defendants)
SECOND CAUSE OF ACTION Violation of California Family Rights Act (Gov. Code § 12945.2) (Against all Defendants)
THIRD CAUSE OF ACTION Retaliation (Gov. Code § 12940(h)) (Against all Defendants)
FOURTH CAUSE OF ACTION Failure to Prevent Discrimination and Retaliation (Gov. Code § 12940(k)) (Against all Defendants)
FIFTH CAUSE OF ACTION Wrongful Termination in Violation of Public Policy (Against all Defendants)
SIXTH CAUSE OF ACTION Failure to Pay for All Hours Worked at the Correct Rate(s) of Pay (Lab. Code §§ 204 510, 1194 & 1198) (Against all Defendants)
SEVENTH CAUSE OF ACTION Failure to Provide Meal and Rest Periods (Lab. Code §§ 226.7 512 & 1198) (Against all Defendants)
EIGHTH CAUSE OF ACTION Failure to Provide Accurate Written Wage Statements (Lab. Code § 226) (Against all Defendants)
NINTH CAUSE OF ACTION Failure to Timely Pay All Wages at Termination (Lab. Code §§ 201-203) (Against all Defendants)
Disposition
Request for Dismissal — April 02, 2024

Request for dismissal filed; court has a statutory lien on any recovery of $10,000 or more until waived court fees and costs are satisfied, as per Gov. Code, § 68637. Declaration concerning waived court fees not fully completed in the provided document.

Docket
Date No. Description
Sep 27, 2022 1 Voluntary Efficient Litigation Stipulation Packet. Filed by Clerk No document
Sep 27, 2022 2 Summons on Complaint. Filed by Jane Roe (Plaintiff) No document
Sep 27, 2022 3 Notice of Case Assignment - Unlimited Civil Case. Filed by Clerk No document
Sep 27, 2022 4 First Amended General Order re: Mandatory Electronic Filing. Filed by Clerk No document
Sep 27, 2022 5 Complaint. Filed by Jane Roe (Plaintiff) No document
Sep 27, 2022 6 Civil Case Cover Sheet. Filed by Jane Roe (Plaintiff) No document
Sep 27, 2022 7 Alternative Dispute Resolution Packet. Filed by Clerk No document
Sep 30, 2022 8 Notice of Case Management Conference. Filed by Clerk No document
Oct 4, 2022 9 Challenge To Judicial Officer - Peremptory (170.6). Filed by Jane Roe (Plaintiff) No document
Oct 5, 2022 10 Minute Order (Court Order). Filed by Clerk No document
Oct 5, 2022 11 Certificate of Mailing for (Court Order) of 10/05/2022. Filed by Clerk No document
Oct 20, 2022 12 Notice of Case Management Conference. Filed by Clerk No document
Oct 24, 2022 13 Summons on First Amended Complaint. Filed by Jane Roe (Plaintiff) No document
Oct 24, 2022 14 First Amended Complaint. Filed by Jane Roe (Plaintiff) No document
Nov 22, 2022 15 Proof of Service by Substituted Service. Filed by Jane Roe (Plaintiff) No document
Nov 22, 2022 16 Proof of Service by Substituted Service. Filed by Jane Roe (Plaintiff) No document
Nov 22, 2022 17 Proof of Service by Substituted Service. Filed by Jane Roe (Plaintiff) No document
Nov 22, 2022 18 Proof of Service by Substituted Service. Filed by Jane Roe (Plaintiff) No document
Nov 22, 2022 19 Proof of Service by Substituted Service. Filed by Jane Roe (Plaintiff) No document
Dec 14, 2022 20 Answer DEFENDANT TRI-STAR SPORTS AND ENTERTAINMENT GROUP, INC.'S ANSWER TO PLAINTIFF JANE ROE'S COMPLAINT. Filed by Tri Star Sports and Entertainment Group, Inc. (Defendant) No document
Dec 15, 2022 21 Motion to Strike (not initial pleading). Filed by CE OPCO, LLC (Defendant); Sean Combs (Defendant); Combs Enterprises, LLC (Defendant) et al. No document
Dec 15, 2022 22 Demurrer - without Motion to Strike. Filed by CE OPCO, LLC (Defendant); Sean Combs (Defendant); Combs Enterprises, LLC (Defendant) et al. No document
Jan 5, 2023 23 Answer DEFENDANT TRI-STAR SPORTS AND ENTERTAINMENT GROUP, INC.'S AMENDED ANSWER TO PLAINTIFF JANE ROE'S COMPLAINT. Filed by Tri Star Sports and Entertainment Group, Inc. (Defendant) No document
Feb 10, 2023 24 Case Management Statement. Filed by Tri Star Sports and Entertainment Group, Inc. (Defendant) No document
Feb 14, 2023 25 Notice of Posting of Jury Fees. Filed by Jane Roe (Plaintiff) No document
Feb 14, 2023 26 Case Management Statement. Filed by Jane Roe (Plaintiff) No document
Feb 14, 2023 27 Case Management Statement. Filed by CE OPCO, LLC (Defendant); Sean Combs (Defendant); Combs Enterprises, LLC (Defendant) et al. No document
Feb 28, 2023 28 Minute Order (Case Management Conference). Filed by Clerk No document
Mar 9, 2023 29 Opposition TO DEFENDANTS' MOTION TO STRIKE PORTIONS OF PLAINTIFF'S FIRST AMENDED COMPLAINT. Filed by Jane Roe (Plaintiff) No document
Mar 9, 2023 30 Opposition TO DEFENDANTS' DEMURRER TO PLAINTIFF'S FIRST AMENDED COMPLAINT. Filed by Jane Roe (Plaintiff) No document
Mar 15, 2023 31 Request for Judicial Notice IN SUPPORT OF DEFENDANTS' REPLY RE DEMURRER AND MOTION TO STRIKE FIRST AMENDED COMPLAINT. Filed by CE OPCO, LLC (Defendant); Sean Combs (Defendant); Combs Enterprises, LLC (Defendant) et al. No document
Mar 15, 2023 32 Reply MEMORANDUM IN SUPPORT OF DEMURRER TO THE FIRST AMENDED COMPLAINT. Filed by CE OPCO, LLC (Defendant); Sean Combs (Defendant); Combs Enterprises, LLC (Defendant) et al. No document
Mar 15, 2023 33 Reply IN SUPPORT OF MOTION TO STRIKE FIRST AMENDED COMPLAINT PURSUANT TO CAL. CIV. PROC. CODE 435-437. Filed by CE OPCO, LLC (Defendant); Sean Combs (Defendant); Combs Enterprises, LLC (Defendant) et al. No document
Mar 22, 2023 34 Notice of Ruling. Filed by CE OPCO, LLC (Defendant); Sean Combs (Defendant); Combs Enterprises, LLC (Defendant) et al. No document
Mar 22, 2023 35 Minute Order (Hearing on Demurrer - with Motion to Strike (CCP 430.10); Cas...). Filed by Clerk No document
Apr 11, 2023 36 Amended Complaint (2nd). Filed by Raven Wales-Walden (Plaintiff) No document
Apr 13, 2023 37 Substitution of Attorney. Filed by Sean Combs (Defendant) No document
Apr 13, 2023 38 Substitution of Attorney. Filed by Combs Enterprises, LLC (Defendant) No document
Apr 13, 2023 39 Substitution of Attorney. Filed by CE OPCO, LLC (Defendant) No document
Apr 13, 2023 40 Substitution of Attorney. Filed by 200 S. Mapleton Drive, LLC (Defendant) No document
Apr 14, 2023 41 Notice of Appearance. Filed by CE OPCO, LLC (Defendant); Sean Combs (Defendant); Combs Enterprises, LLC (Defendant) et al. No document
May 5, 2023 42 Case Management Statement. Filed by Raven Wales-Walden (Plaintiff); Jane Roe (Plaintiff); CE OPCO, LLC (Defendant) et al. No document
May 15, 2023 43 Answer. Filed by CE OPCO, LLC (Defendant); Sean Combs (Defendant); Combs Enterprises, LLC (Defendant) et al. No document
May 19, 2023 44 Minute Order (Non-Appearance Case Review re: Stipulation and [Proposed] Pro...). Filed by Clerk No document
May 19, 2023 45 Certificate of Mailing for (Non-Appearance Case Review re: Stipulation and [Proposed] Pro...) of 05/19/2023. Filed by Clerk No document
May 22, 2023 46 Substitution of Attorney. Filed by Tri Star Sports and Entertainment Group, Inc. (Defendant) No document
May 22, 2023 47 Proof of Service (not Summons and Complaint). Filed by Tri Star Sports and Entertainment Group, Inc. (Defendant) No document
May 22, 2023 48 Minute Order (Case Management Conference). Filed by Clerk No document
May 22, 2023 49 Case Management Order. Filed by Clerk No document
Jul 21, 2023 50 Separate Statement. Filed by Raven Wales-Walden (Plaintiff) No document
Jul 21, 2023 51 Separate Statement. Filed by Raven Wales-Walden (Plaintiff) No document
Jul 21, 2023 52 Motion to Compel Further Discovery Responses. Filed by Raven Wales-Walden (Plaintiff) No document
Jul 21, 2023 53 Motion to Compel Further Discovery Responses. Filed by Raven Wales-Walden (Plaintiff) No document
Jul 27, 2023 54 Minute Order (Informal Discovery Conference). Filed by Clerk No document
Sep 28, 2023 55 Stipulation and Order JOINT STIPULATION RE: COMBS DEFENDANTS' DISCOVERY RESPONSES & ORDER. Filed by Raven Wales-Walden (Plaintiff) No document
Oct 6, 2023 56 Motion to Compel DEFENDANT SEAN COMBS TO PRODUCE DOCUMENTS AND TANGIBLE THINGS IN COMPLIANCE WITH HIS STATEMENTS OF COMPLIANCE IN RESPONSE TO PLAINTIFF'S REQUESTS FOR PRODUCTION, SET ONE; REQUEST FOR MONETARY SANCTIONS. Filed by Raven Wales-Walden (Plaintiff) No document
Oct 6, 2023 57 Motion to Compel DEFENDANT COMBS ENTERPRISES, LLC TO PRODUCE DOCUMENTS AND TANGIBLE THINGS IN COMPLIANCE WITH ITS STATEMENTS OF COMPLIANCE IN RESPONSE TO PLAINTIFF'S REQUESTS FOR PRODUCTION, SET ONE; REQUEST FOR MONETARY SANCTIONS. Filed by Raven Wales-Walden (Plaintiff) No document
Oct 6, 2023 58 Motion to Compel DEFENDANT CE OPCO, LLC TO PRODUCE DOCUMENTS AND TANGIBLE THINGS IN COMPLIANCE WITH ITS STATEMENTS OF COMPLIANCE IN RESPONSE TO PLAINTIFF'S REQUESTS FOR PRODUCTION, SET ONE; REQUEST FOR MONETARY SANCTIONS. Filed by Raven Wales-Walden (Plaintiff) No document
Oct 6, 2023 59 Motion to Compel DEFENDANT 200 S. MAPLETON DRIVE, LLC TO PRODUCE DOCUMENTS AND TANGIBLE THINGS IN COMPLIANCE WITH ITS STATEMENTS OF COMPLIANCE IN RESPONSE TO PLAINTIFF'S REQUESTS FOR PRODUCTION, SET ONE; REQUEST FOR MONETARY SANCTIONS. Filed by Raven Wales-Walden (Plaintiff) No document
Oct 13, 2023 60 Notice of Appearance. Filed by CE OPCO, LLC (Defendant); Sean Combs (Defendant); Combs Enterprises, LLC (Defendant) et al. No document
Oct 13, 2023 61 Notice NOTICE OF WITHDRAWAL OF CHRISTINA DAVIS. Filed by CE OPCO, LLC (Defendant); Sean Combs (Defendant); Combs Enterprises, LLC (Defendant) et al. No document
Oct 17, 2023 62 Separate Statement. Filed by Raven Wales-Walden (Plaintiff) No document
Oct 17, 2023 63 Separate Statement. Filed by Raven Wales-Walden (Plaintiff) No document
Oct 17, 2023 64 Separate Statement. Filed by Raven Wales-Walden (Plaintiff) No document
Oct 17, 2023 65 Separate Statement. Filed by Raven Wales-Walden (Plaintiff) No document
Oct 17, 2023 66 Motion to Compel Further Discovery Responses. Filed by Raven Wales-Walden (Plaintiff) No document
Oct 17, 2023 67 Motion to Compel Further Discovery Responses. Filed by Raven Wales-Walden (Plaintiff) No document
Oct 17, 2023 68 Motion to Compel Further Discovery Responses. Filed by Raven Wales-Walden (Plaintiff) No document
Oct 17, 2023 69 Motion to Compel Further Discovery Responses. Filed by Raven Wales-Walden (Plaintiff) No document
Oct 19, 2023 70 Separate Statement. Filed by Raven Wales-Walden (Plaintiff) No document
Oct 19, 2023 71 Motion to Compel Further Discovery Responses. Filed by Raven Wales-Walden (Plaintiff) No document
Oct 20, 2023 72 Separate Statement. Filed by Raven Wales-Walden (Plaintiff) No document
Oct 20, 2023 73 Motion to Compel Further Discovery Responses. Filed by Raven Wales-Walden (Plaintiff) No document
Oct 26, 2023 74 Ex Parte Application for Order Advancing Hearings on Plaintiff's Motions to Compel. Filed by Raven Wales-Walden (Plaintiff) No document
Oct 30, 2023 75 Minute Order (Ex Parte Application for Order Advancing Hearings on Plaintif...). Filed by Clerk No document
Dec 27, 2023 76 Proof of Service (not Summons and Complaint). Filed by CE OPCO, LLC (Defendant); Sean Combs (Defendant); Combs Enterprises, LLC (Defendant) et al. No document
Dec 27, 2023 77 Opposition to Plaintiff's Motion to Compel to Produce Documents and Tangible Things in Compliance with Its Statements of Compliance in Response to Plaintiff's Requests for Production, Set One and Request for Monetary Sanctions. Filed by Combs Enterprises, LLC (Defendant) No document
Dec 27, 2023 78 Opposition to Plaintiff's Motion to Compel to Produce Documents and Tangible Things in Compliance with Its Statements of Compliance in Response to Plaintiff's Requests for Production, Set One and Request for Monetary Sanctions. Filed by CE OPCO, LLC (Defendant) No document
Dec 27, 2023 79 Opposition to Plaintiff's Motion to Compel to Produce Documents and Tangible Things in Compliance with Its Statements of Compliance in Response to Plaintiff's Requests for Production, Set One and Request for Monetary Sanctions. Filed by 200 S. Mapleton Drive, LLC (Defendant) No document
Dec 27, 2023 80 Opposition to Plaintiff's Motion to Compel to Produce Documents and Tangible Things in Compliance with His Statements of Compliance in Response to Plaintiff's Requests for Production, Set One and Request for Monetary Sanctions. Filed by Sean Combs (Defendant) No document
Dec 27, 2023 81 Declaration of Matthew D. Caplan in Support of Defendants' Oppositions to Motions to Compel Defendants to Produce Documents and Tangible Things in Compliance with Its Statements of Compliance in Response to Plaintiff's Requests for Production. Filed by CE OPCO, LLC (Defendant); Sean Combs (Defendant); Combs Enterprises, LLC (Defendant) et al. No document
Jan 3, 2024 82 Reply PLAINTIFF'S REPLY BRIEF IN SUPPORT OF MOTION TO COMPEL DEFENDANT 200 S. MAPLETON DRIVE, LLC TO PRODUCE DOCUMENTS AND TANGIBLE THINGS IN COMPLIANCE WITH ITS STATEMENTS OF COMPLIANCE IN RESPONSE TO PLAINTIFF'S REQUESTS FOR PRODUCTION, SET ONE. Filed by Raven Wales-Walden (Plaintiff) No document
Jan 8, 2024 83 Reply PLAINTIFF'S REPLY BRIEF IN SUPPORT OF MOTION TO COMPEL DEFENDANT COMBS ENTERPRISES, LLC TO PRODUCE DOCUMENTS AND TANGIBLE THINGS IN COMPLIANCE WITH ITS STATEMENTS OF COMPLIANCE IN RESPONSE TO PLAINTIFF'S REQUESTS FOR PRODUCTION, SET ONE. Filed by Raven Wales-Walden (Plaintiff) No document
Jan 9, 2024 84 Reply PLAINTIFF'S REPLY BRIEF IN SUPPORT OF MOTION TO COMPEL DEFENDANT SEAN COMBS TO PRODUCE DOCUMENTS AND TANGIBLE THINGS IN COMPLIANCE WITH ITS STATEMENTS OF COMPLIANCE IN RESPONSE TO PLAINTIFF'S REQUESTS FOR PRODUCTION, SET ONE. Filed by Raven Wales-Walden (Plaintiff) No document
Jan 9, 2024 85 Reply PLAINTIFF'S REPLY BRIEF IN SUPPORT OF MOTION TO COMPEL DEFENDANT CE OPCO, LLC TO PRODUCE DOCUMENTS AND TANGIBLE THINGS IN COMPLIANCE WITH ITS STATEMENTS OF COMPLIANCE IN RESPONSE TO PLAINTIFF'S REQUESTS FOR PRODUCTION, SET ONE. Filed by Raven Wales-Walden (Plaintiff) No document
Jan 10, 2024 86 Order Appointing Court Approved Reporter as Official Reporter Pro Tempore. Filed by Clerk No document
Jan 10, 2024 87 Minute Order (Hearing on Motion to Compel Plaintiff's Motion to Compel Defe...). Filed by Clerk No document
Jan 16, 2024 88 Notice of Ruling. Filed by Raven Wales-Walden (Plaintiff) No document
Feb 13, 2024 89 Minute Order (Informal Discovery Conference (IDC)). Filed by Clerk No document
Apr 2, 2024 90 Request for Dismissal. Filed by Raven Wales-Walden (Plaintiff) No document
Attorneys
Afshin Mozaffari
Mozaffari Law
Plaintiff