Dickerson-Neal v. Combs et al
On January 3, 1991, Joi Dickerson-Neal, a Syracuse University student, reluctantly agreed to dine with Sean Combs at Wells Restaurant in Harlem, New York. After dinner, Combs pressured her to accompany him, and during the drive, he insisted she smoke a blunt, which she believes was laced with a narcotic. She became incapacitated, unable to stand or walk, and Combs took her to a music studio and then a residence, where he sexually assaulted her while recording it. Days later, Devante Swing of Jodeci informed her that Combs had shown the 'sex tape' to multiple people, replying 'everyone' when asked who saw it. The assault led to severe emotional distress, forcing her to drop out of college after hospitalization for depression and suicidal ideation. She faced further humiliation as Combs confronted her publicly at a party in the 1990s, and his rising fame made it impossible for her to continue in the music industry, prompting a move to California. The trauma resurfaced in 2023 after Cassie Ventura’s lawsuit against Combs.
Declaratory judgment that Defendants violated New York laws; compensatory damages for mental and emotional injury, distress, pain, suffering, and reputational harm; punitive damages; attorneys’ fees, costs, and expenses; and other equitable relief as deemed just.
| Date | No. | Description | |
|---|---|---|---|
| Nov 23, 2023 | 1 | SUMMONS + COMPLAINT | View PDF |
| Nov 27, 2023 | 2 | NOTICE OF APPEARANCE (PRE RJI) | View PDF |
| Dec 13, 2023 | 3 | STIPULATION - SERVICE | View PDF |
| Mar 1, 2024 | 4 | STIPULATION - TIME TO ANSWER | View PDF |
| Apr 11, 2024 | 5 | STIPULATION - TIME TO ANSWER | View PDF |
| Apr 26, 2024 | 6 | NOTICE OF MOTION (Motion #001) | View PDF |
| Apr 26, 2024 | 7 | AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion #001) | View PDF |
| Apr 26, 2024 | 8 | EXHIBIT(S) - A (Motion #001) — Complaint | View PDF |
| Apr 26, 2024 | 9 | EXHIBIT(S) - B (Motion #001) — BBE Entity Information | View PDF |
| Apr 26, 2024 | 10 | EXHIBIT(S) - C (Motion #001) — CE Entity Information | View PDF |
| Apr 26, 2024 | 11 | EXHIBIT(S) - D (Motion #001) — Bellino v. Tallarico 24-cv-0712 Decision | View PDF |
| Apr 26, 2024 | 12 | MEMORANDUM OF LAW IN SUPPORT (Motion #001) | View PDF |
| Apr 26, 2024 | 13 | RJI -RE: NOTICE OF MOTION (Motion #001) | View PDF |
| May 16, 2024 | 14 | STIPULATION - OTHER (Motion #001) | View PDF |
| May 17, 2024 | 15 | COMPLAINT (AMENDED) *Corrected* — Amended Pre-RJI Summons + Amended Complaint | View PDF |
| May 30, 2024 | 16 | NOTICE OF APPEARANCE (POST RJI) | View PDF |
| May 30, 2024 | 17 | NOTICE OF APPEARANCE (POST RJI) | View PDF |
| May 31, 2024 | 18 | STIPULATION - OTHER - ( REQUEST TO SO ORDER ) (Motion #001) | View PDF |
| Jun 12, 2024 | 19 | DECISION + ORDER ON MOTION (Motion #001) | View PDF |
| Jun 10, 2024 | 20 | STIPULATION - AMENDING CAPTION — STIP TO FILE AMENDED COMPLAINT | View PDF |
| Jun 21, 2024 | 21 | NOTICE OF MOTION (Motion #002) | View PDF |
| Jun 21, 2024 | 22 | AFFIDAVIT OR AFFIRMATION IN SUPPORT OF MOTION (Motion #002) | View PDF |
| Jun 21, 2024 | 23 | EXHIBIT(S) - A (Motion #002) — Amended Complaint dated June 10, 2024 | View PDF |
| Jun 21, 2024 | 24 | MEMORANDUM OF LAW IN SUPPORT (Motion #002) | View PDF |
| Jul 17, 2024 | 25 | AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION (Motion #002) | View PDF |
| Jul 17, 2024 | 26 | MEMORANDUM OF LAW IN OPPOSITION (Motion #002) — MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANTS PARTIAL MOTION TO DISMISS THE AMENDED COMPLAINT | View PDF |
| Aug 2, 2024 | 27 | MEMORANDUM OF LAW IN REPLY (Motion #002) | View PDF |
| Oct 24, 2024 | 28 | NOTICE OF APPEARANCE (POST RJI) | View PDF |
| Dec 16, 2024 | 29 | NOTICE OF APPEARANCE (POST RJI) | View PDF |
| Dec 16, 2024 | 30 | NOTICE OF APPEARANCE (POST RJI) — Notice of Appearance - E. Bruder | View PDF |
| Dec 18, 2024 | 31 | NOTICE OF APPEARANCE (POST RJI) — Notice of Appearance - G. Allred | View PDF |
| Jan 14, 2025 | 32 | CONSENT TO CHANGE ATTORNEY (POST RJI) | View PDF |
| Feb 18, 2025 | 33 | DECISION + ORDER ON MOTION (Motion #002) | View PDF |
| Feb 28, 2025 | 34 | STIPULATION - TIME TO ANSWER | View PDF |
| Mar 20, 2025 | 35 | ANSWER | View PDF |
| Mar 28, 2025 | 36 | NOTICE OF MOTION (Motion #003) — Notice of Motion to Admit Adam M. Prom Pro Hac Vice | View PDF |
| Mar 28, 2025 | 37 | AFFIDAVIT OR AFFIRMATION IN SUPPORT OF MOTION (Motion #003) — Affirmation of Greg G. Gutzler in Support of Admitting Adam M. Prom Pro Hac Vice | View PDF |
| Mar 28, 2025 | 38 | AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion #003) — Affirmation of Adam M. Prom in Support of Pro Hac Vice Admission | View PDF |
| Mar 28, 2025 | 39 | EXHIBIT(S) - A (Motion #003) — Certificate of Good Standing - Illinois | View PDF |
| Mar 28, 2025 | 40 | ORDER ( PROPOSED ) (Motion #003) | View PDF |
| Apr 14, 2025 | 41 | DECISION + ORDER ON MOTION (Motion #003) | View PDF |
| Apr 22, 2025 | 42 | STIPULATION - DISCOVERY ( REQUEST TO SO ORDER ) | View PDF |
| Dec 16, 2025 | 43 | NOTICE OF APPEARANCE (POST RJI) | View PDF |
| Aug 20, 2026 | 44 | STIPULATION - OTHER — Stipulation and Order for the Production and Exchange of Confidential Information. Gutzler, G. | View PDF |