Case #952341/2023 · Supreme Court of the State of New York, County of New York

Dickerson-Neal v. Combs et al

Filed November 23, 2023 Justice Lyle E. Frank
Open Sean Combs a/k/a 'P. Diddy' Bad Boy Entertainment d/b/a Bad Boy Records Combs Enterprises, LLC
Contains Sexual Assault · Drugging · Revenge Porn · Emotional Abuse
Parties
Joi Dickerson-Neal Plaintiff
Sean Combs a/k/a 'P. Diddy' A Grammy-winning musician and prominent figure in the New York hip-hop community, resident of New York State during the events, founder of Bad Boy Records.
Bad Boy Entertainment d/b/a Bad Boy Records A domestic limited liability company licensed in New York, founded by Sean Combs in 1992, a record label that produced artists like The Notorious B.I.G.
Combs Enterprises, LLC A domestic limited liability company licensed in New York, a business conglomerate founded by Sean Combs, parent company of Bad Boy Entertainment.
Factual Allegations
Disclaimer: allegations as pled by the plaintiff, summarized by Grok.

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.

Prayer for Relief

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.

Causes of Action
FIRST CAUSE OF ACTION Assault and Battery
SECOND CAUSE OF ACTION Intentional Infliction of Emotional Distress
THIRD CAUSE OF ACTION Sex Trafficking
FOURTH CAUSE OF ACTION Violation of New York State Revenge Porn Law
FIFTH CAUSE OF ACTION Violation of the NYC Victims of Gender-Motivated Violence Protection Act
SIXTH CAUSE OF ACTION Violation of New York City Revenge Porn Law
Docket
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
Attorneys
Greg G. Gutzler
DiCello Levitt LLP
for Joi Dickerson-Neal
Plaintiff
Emma Bruder
DiCello Levitt LLP
for Joi Dickerson-Neal
Plaintiff
Gloria Rachel Allred
Allred Maroko & Goldberg
for Joi Dickerson-Neal
Plaintiff
Jonathan D. Davis
Jonathan D. Davis P.C.
for Sean Combs a/k/a 'P. Diddy'
Civil Defense
Michael Tremonte
Sher Tremonte
for Sean Combs a/k/a 'P. Diddy'
co-counsel Civil Defense
Erica A. Wolff
Sher Tremonte
for Sean Combs a/k/a 'P. Diddy'
co-counsel Civil Defense
Colin James Steele
Sher Tremonte
for Sean Combs a/k/a 'P. Diddy'
co-counsel Civil Defense
David Russell
Jonathan D. Davis, P.C.
for Sean Combs a/k/a 'P. Diddy'
co-counsel Civil Defense