John YH Roe v. Sean Combs et al.

In or around 2004, Plaintiff launched his career as a child actor and later hired talent managers/agents Lang Talent, Diedre Lang, and Amsel (the “Agents”) to advance his career. The Agents undertook to represent the minor Plaintiff, controlled or influenced the industry events he attended, and stood in a special relationship of trust. In or around May 2007, while Plaintiff was a minor under age 18, the Agents sent him an invitation to a networking event in the Hollywood Hills, California (the “Event”). Neither of the Agents attended or arranged a chaperone. At the Event, Defendant Sean Combs approached Plaintiff, made small talk about acting opportunities, guided him to a back room, shut the door, offered him alcohol (which Plaintiff sipped and felt the effects of), then began touching Plaintiff’s arm and body despite Plaintiff stating he was uncomfortable. Combs pulled down Plaintiff’s pants and underwear, fondled Plaintiff’s genitalia while touching himself, and performed oral copulation on the minor Plaintiff while continuing to touch himself. Combs then left the room. Plaintiff exited in shock and left the Event. The Agents allegedly knew or should have known of Combs’ sexually predatory propensities and prior misconduct, failed to vet the Event, warn Plaintiff or his guardian, supervise, or protect him, and allegedly conspired with Combs to create the Event as an opportunity for contact with minors. Entity Does and Industry Does failed to supervise, warn, control, chaperone, or protect Plaintiff. As a result, Plaintiff suffered extreme psychological harm, economic loss, professional ruin, and irreparable emotional trauma.

Plaintiff prays for judgment against all Defendants for special and general damages in excess of the jurisdictional minimum according to proof; exemplary/punitive damages against all Defendants according to proof; prejudgment interest according to proof; costs of suit according to proof; attorney’s fees pursuant to Code of Civil Procedure § 1021.5; and any other and further relief as the Court deems just and proper. Plaintiff also demands a jury trial on all causes of action.