Case #24SMCV06298 · California Superior Court, Los Angeles County

Phillip Pines v. Sean Combs et al

Filed December 24, 2024 Judge Judge Edward B. Moreton, Jr.
Open Sean Combs Kristina Khorram Combs Enterprises Daddy's House Recordings Inc. CE OPCO, LLC d/b/a Combs Global
Contains Sexual Assault · Violence · Sexual Harassment · Drug Use
Parties
Phillip Pines Plaintiff
Sean Combs Individual residing in Los Angeles County, California, founder/owner of Combs Enterprises and related entities, Chairman of Bad Boy entities, Plaintiff's immediate supervisor, currently incarcerated in Metropolitan Detention Center, Brooklyn.
Kristina Khorram Sean Combs' Chief of Staff, residing in Los Angeles County, California, works for all named Defendants, Plaintiff's supervisor.
Combs Enterprises Entity headquartered at 9200 West Sunset Blvd., Suite 300, West Hollywood, CA 90069, owned by Sean Combs, issued Plaintiff's paychecks.
Daddy's House Recordings Inc. New York corporation with principal place of business at 9255 Sunset Boulevard, 2nd Floor, West Hollywood, CA 90069, part of Combs Enterprises, Sean Combs as CEO.
CE OPCO, LLC d/b/a Combs Global Delaware LLC with principal place of business at 9255 Sunset Boulevard, 2nd Floor, West Hollywood, CA 90069, alter ego of Sean Combs.
Dismissed defendants: COMBS ENTERPRISES, BAD BOY RECORDS LLC
Factual Allegations
Disclaimer: allegations as pled by the plaintiff, summarized by Grok.

Phillip Pines, an African American male, began working for Defendants on December 19, 2019, after a probationary period, formally employed as a senior executive assistant to Sean Combs but misclassified as exempt. His duties included personal errands for Combs, such as fetching food, clothing, and illicit drugs, and preparing for 'Wild King Nights'—events involving red lights, alcohol, marijuana, illegal drugs, and sex toys—at Combs’ residences and hotels in Los Angeles, Miami, New York, Italy, Turks and Caicos, and other locations. Pines alleges he was coerced into sexual acts, including a 'loyalty test' involving intercourse with a female guest, and faced violence from Combs, such as witnessing Combs kick a guest in Miami. He was instructed to conceal Combs’ activities, manage an 'MVP' bag with drugs and sex toys during travel, and work 24/7 schedules without breaks, overtime pay, or rest days, often under threats of termination and blackballing. During COVID, Pines worked with an infected Combs, including a trip to Turks and Caicos for Combs’ 51st birthday, and was told to keep it secret. These intolerable conditions, including sexual harassment and labor violations, led to his constructive termination on December 29, 2021.

Prayer for Relief

Plaintiff seeks non-economic and economic damages, punitive damages, pain and suffering, attorneys' fees, statutory civil penalties ($25,000 under Civ. Code § 52(b)), declarations of Labor Code violations (e.g., §§ 201, 203, 204, 510, 1194, 226.7, 512, 515, 551, 552), overtime and meal/rest break premiums, waiting time penalties, restitution, injunctive relief, prejudgment/post-judgment interest, and reimbursement for expenses, all to be proven at trial.

Causes of Action
FIRST CAUSE OF ACTION Sexual Battery Civil Code § 1708.5 (All Defendants and Does 1-25)
SECOND CAUSE OF ACTION Sex Trafficking 18 U.S.C. §§ 1591, 1595 (All Defendants and Does 1-25)
THIRD CAUSE OF ACTION Gender Violence Cal. Civ. Code § 52.4 (All Defendants and Does 1-25)
FOURTH CAUSE OF ACTION Sexual Harassment (Quid Pro Quo); Hostile Work Environment; Failure to Prevent Harassment Cal. Gov’t Code § 12940 et seq. (All Defendants and Does 1-25)
FIFTH CAUSE OF ACTION Constructive Discharge (All Defendants and Does 1-25)
SIXTH CAUSE OF ACTION Intentional Infliction of Emotional Distress (All Defendants and Does 1-25)
SEVENTH CAUSE OF ACTION Negligent Infliction of Emotional Distress (All Defendants and Does 1-25)
EIGHTH CAUSE OF ACTION Failure to Pay Overtime/Earned Wages California Labor Code §§ 201, 203, 204, 510, 1194 (All Defendants)
NINTH CAUSE OF ACTION Violation of California Labor Code §§ 226.7 and 512(a) Failure to Provide Meal Periods (All Defendants)
TENTH CAUSE OF ACTION Violation of California Labor Code § 226.7 Failure to Provide Rest Periods (All Defendants)
ELEVENTH CAUSE OF ACTION Waiting Time Penalties California Labor Code §§ 201, 202, and 203 (All Defendants)
TWELFTH CAUSE OF ACTION Misclassification (All Defendants)
THIRTEENTH CAUSE OF ACTION Violation of California Business and Professions Code § 17200 (All Defendants)
FOURTEENTH CAUSE OF ACTION Violation of California Labor Code § 226 Failure to Provide Accurate Wage Statements (All Defendants)
FIFTEENTH CAUSE OF ACTION Violation of California Labor Code §§ 551 and 552 Failure to Allow One Day of Rest in Seven (All Defendants)
SIXTEENTH CAUSE OF ACTION Failure to Reimburse (All Defendants)
Court Dates
DateTypeDescription
Jun 5, 2026 Hearing Demurrer - without Motion to Strike
Mar 23, 2027 Status Conference Status Conference
Mar 23, 2027 Status Conference Pretrial conference
Jun 16, 2028 Status Conference Final Status Conference
Jun 26, 2028 Trial Jury trial
Docket
Date No. Description
Dec 24, 2024 1 Notice of Case Assignment - Unlimited Civil Case. Filed by Clerk No document
Dec 24, 2024 2 Complaint. Filed by Phillip Pines (Plaintiff) No document
Dec 24, 2024 3 Civil Case Cover Sheet. Filed by Phillip Pines (Plaintiff) No document
Dec 24, 2024 4 Alternative Dispute Resolution Packet. Filed by Clerk No document
Dec 26, 2024 5 Notice of Case Management Conference. Filed by Clerk No document
Mar 5, 2025 6 Declaration re: Due Diligence. Filed by Phillip Pines (Plaintiff) No document
Mar 5, 2025 7 Declaration re: Due Diligence. Filed by Phillip Pines (Plaintiff) No document
Mar 5, 2025 8 Declaration re: Due Diligence. Filed by Phillip Pines (Plaintiff) No document
Mar 5, 2025 9 Declaration re: Due Diligence. Filed by Phillip Pines (Plaintiff) No document
Mar 5, 2025 10 Declaration re: Due Diligence. Filed by Phillip Pines (Plaintiff) No document
Mar 5, 2025 11 Declaration re: Due Diligence. Filed by Phillip Pines (Plaintiff) No document
Mar 5, 2025 12 Declaration re: Due Diligence. Filed by Phillip Pines (Plaintiff) No document
Mar 5, 2025 13 Declaration re: Due Diligence. Filed by Phillip Pines (Plaintiff) No document
Mar 5, 2025 14 Declaration re: Due Diligence. Filed by Phillip Pines (Plaintiff) No document
Mar 5, 2025 15 Declaration re: Due Diligence. Filed by Phillip Pines (Plaintiff) No document
Apr 9, 2025 16 Declaration re: Due Diligence. Filed by Phillip Pines (Plaintiff) No document
Apr 9, 2025 17 Declaration re: Due Diligence. Filed by Phillip Pines (Plaintiff) No document
Apr 9, 2025 18 Declaration re: Due Diligence. Filed by Phillip Pines (Plaintiff) No document
Apr 9, 2025 19 Declaration re: Due Diligence. Filed by Phillip Pines (Plaintiff) No document
Apr 9, 2025 20 Declaration re: Due Diligence. Filed by Phillip Pines (Plaintiff) No document
Apr 9, 2025 21 Declaration re: Due Diligence. Filed by Phillip Pines (Plaintiff) No document
Apr 9, 2025 22 Declaration re: Due Diligence. Filed by Phillip Pines (Plaintiff) No document
Apr 9, 2025 23 Declaration re: Due Diligence. Filed by Phillip Pines (Plaintiff) No document
Apr 9, 2025 24 Declaration re: Due Diligence. Filed by Phillip Pines (Plaintiff) No document
Apr 9, 2025 25 Declaration re: Due Diligence. Filed by Phillip Pines (Plaintiff) No document
Apr 21, 2025 26 Proof of Personal Service. Filed by Phillip Pines (Plaintiff) No document
May 9, 2025 27 Stipulation - No Order STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT. Filed by Sean Combs (Defendant) No document
May 9, 2025 28 Notice of Appearance. Filed by Sean Combs (Defendant) No document
May 14, 2025 29 Proof of Service by Substituted Service. Filed by Phillip Pines (Plaintiff) No document
May 14, 2025 30 Proof of Personal Service. Filed by Phillip Pines (Plaintiff) No document
May 14, 2025 31 Proof of Personal Service. Filed by Phillip Pines (Plaintiff) No document
May 14, 2025 32 Proof of Personal Service. Filed by Phillip Pines (Plaintiff) No document
May 14, 2025 33 Proof of Personal Service. Filed by Phillip Pines (Plaintiff) No document
May 14, 2025 34 Proof of Personal Service. Filed by Phillip Pines (Plaintiff) No document
May 14, 2025 35 Proof of Personal Service. Filed by Phillip Pines (Plaintiff) No document
May 27, 2025 36 Motion to Compel Arbitration. Filed by Sean Combs (Defendant) No document
Jun 13, 2025 37 Opposition DEFENDANTS' MOTION TO COMPEL ARBITRATION OF PLAINTIFF'S CLAIMS AND FOR STAY OF ACTION OR PROCEEDINGS. Filed by Phillip Pines (Plaintiff) No document
Jun 16, 2025 38 Case Management Statement. Filed by Phillip Pines (Plaintiff) No document
Jun 20, 2025 39 Reply DEFENDANTS' REPLY IN SUPPORT OF MOTION TO COMPEL ARBITRATION OF PLAINTIFF'S CLAIMS AND FOR STAY OF ACTION OR PROCEEDINGS. Filed by Sean Combs (Defendant) No document
Jun 23, 2025 40 Minute Order (Court Order Rescheduling Hearing Currently Set for June 24, 2025). Filed by Clerk No document
Jun 23, 2025 41 Certificate of Mailing for (Court Order Rescheduling Hearing Currently Set for June 24, 2025) of 06/23/2025. Filed by Clerk No document
Jun 27, 2025 42 Minute Order (Ruling on Submitted Matter Re Motion to Compel Arbitration). Filed by Clerk No document
Jun 27, 2025 43 Minute Order (Hearing on Motion to Compel Arbitration; Case Management Conf...). Filed by Clerk No document
Jun 27, 2025 44 Certificate of Mailing for (Ruling on Submitted Matter Re Motion to Compel Arbitration) of 06/27/2025. Filed by Clerk No document
Jul 1, 2025 45 Notice of Ruling. Filed by Phillip Pines (Plaintiff) No document
Jul 1, 2025 46 Notice of Continuance. Filed by Phillip Pines (Plaintiff) No document
Jul 23, 2025 47 Stipulation and Order to Extend Time for Defendants to Respond to Complaint. Filed by Sean Combs (Defendant) No document
Jul 31, 2025 48 Proof of Personal Service. Filed by Phillip Pines (Plaintiff) No document
Aug 13, 2025 49 Declaration re: Due Diligence. Filed by Phillip Pines (Plaintiff) No document
Aug 14, 2025 50 Request for Dismissal. Filed by Phillip Pines (Plaintiff) No document
Aug 14, 2025 51 Amendment to Complaint (Fictitious/Incorrect Name). Filed by Phillip Pines (Plaintiff) No document
Aug 15, 2025 52 Answer. Filed by Sean Combs (Defendant) No document
Sep 5, 2025 53 Substitution of Attorney. Filed by Daddy's House Recordings Inc. (Defendant) No document
Sep 5, 2025 54 Substitution of Attorney. Filed by CE OPCO, LLC (Defendant) No document
Sep 5, 2025 55 Substitution of Attorney. Filed by Bad Boy Productions LLC (Defendant) No document
Sep 5, 2025 56 Substitution of Attorney. Filed by Bad Boy Productions Holdings, Inc. (Defendant) No document
Sep 5, 2025 57 Substitution of Attorney. Filed by Bad Boy Entertainment LLC (Defendant) No document
Sep 5, 2025 58 Substitution of Attorney. Filed by Bad Boy Entertainment Holdings, Inc. (Defendant) No document
Sep 5, 2025 59 Substitution of Attorney. Filed by Bad Boy Books Holdings, Inc. (Defendant) No document
Sep 9, 2025 60 Case Management Statement. Filed by Phillip Pines (Plaintiff) No document
Sep 24, 2025 61 Order - Dismissal. Filed by Court No document
Sep 24, 2025 62 Minute Order (Case Management Conference; Order to Show Cause Re: Proof of...). Filed by Clerk No document
Sep 25, 2025 63 Request DEFENDANT CE OPCO'S REQUEST FOR PRIOR PLEADINGS AND DISCOVERY. Filed by CE OPCO, LLC (Defendant) No document
Sep 30, 2025 64 Substitution of Attorney. Filed by Sean Combs (Defendant) No document
Dec 1, 2025 65 Informal Discovery Conference. Filed by Phillip Pines (Plaintiff) No document
Dec 5, 2025 66 Minute Order (Informal Discovery Conference (IDC)). Filed by Clerk No document
Jan 6, 2026 67 Stipulation and Order PROTECTIVE CONFIDENTIAL DESIGNATION ONLY. Filed by CE OPCO, LLC (Defendant) No document
Jan 8, 2026 68 Case Management Statement. Filed by Sean Combs (Defendant); Kristina Khorram (Defendant); Combs Enterprises (Defendant) et al. No document
Jan 8, 2026 69 Case Management Statement. Filed by Phillip Pines (Plaintiff) No document
Jan 9, 2026 70 Proof of Service by Substituted Service. Filed by Phillip Pines (Plaintiff) No document
Jan 22, 2026 71 Trial Preparation Order (Jury Trial). Filed by Clerk No document
Jan 22, 2026 72 Notice of Posting of Jury Fees. Filed by Phillip Pines (Plaintiff) No document
Jan 22, 2026 73 Minute Order (Case Management Conference). Filed by Clerk No document
Jan 22, 2026 74 Clerks Certificate of Service By Electronic Service. Filed by Clerk No document
Feb 2, 2026 75 Notice and Acknowledgment of Receipt. Filed by Phillip Pines (Plaintiff) No document
Feb 4, 2026 76 Notice of Posting of Jury Fees. Filed by Sean Combs (Defendant); Combs Enterprises (Defendant); Daddy's House Recordings Inc. (Defendant) et al. No document
Mar 12, 2026 77 Notice and Acknowledgment of Receipt. Filed by Phillip Pines (Plaintiff) No document
Mar 23, 2026 78 Declaration OF CLARISSE PETERSEN PURSUANT TO CALIFORNIA CODE OF CIVIL PROCEDURE SECTIONS 430.41 AND 435.5 RE DEFENDANT KRISTINA KHORRAM'S RESPONSIVE PLEADING DEADLINE. Filed by Kristina Khorram (Defendant) No document
Apr 22, 2026 79 Memorandum of Points & Authorities. Filed by Kristina Khorram (Defendant) No document
Apr 22, 2026 80 Demurrer - without Motion to Strike. Filed by Kristina Khorram (Defendant) No document
Apr 22, 2026 81 Declaration DECLARATION OF CLARISSE C. PETERSEN IN SUPPORT OF KRISTINA KHORRAM'S DEMURRER TO PLAINTIFF'S COMPLAINT. Filed by Kristina Khorram (Defendant) No document
May 22, 2026 82 Opposition TO DEFENDANT KRISTINA KHORRAM'S DEMURRER. Filed by Phillip Pines (Plaintiff) No document
May 29, 2026 83 Reply DEFENDANT KRISTINA KHORRAM'S REPLY TO PLAINTIFF'S OPPOSITION TO DEFENDANT'S DEMURRER TO PLAINTIFF'S COMPLAINT. Filed by Kristina Khorram (Defendant) No document
Jun 5, 2026 84 Order Appointing Court Approved Reporter as Official Reporter Pro Tempore Tanya Rogers, CSR #10178. Filed by Sean Combs (Defendant); Kristina Khorram (Defendant); Combs Enterprises (Defendant) et al. No document
Jun 5, 2026 85 Minute Order (Hearing on Demurrer - without Motion to Strike). Filed by Clerk No document
Jun 16, 2026 86 Notice of Ruling. Filed by Kristina Khorram (Defendant) No document
Attorneys
Charles Graham
The Graham Firm
Plaintiff
Gene H. Shioda
Shioda Langley & Chang, LLP
Plaintiff
Steven P. Chang
Shioda Langley & Chang, LLP
Plaintiff
Heidi M. Cheng
Shioda Langley & Chang, LLP
Plaintiff
Jason A. Feazell
Shioda Langley & Chang, LLP
Plaintiff
Tina Glandian
Geragos & Geragos
Civil Defense
Katherine Frances Pratty
Geragos & Geragos
Civil Defense