Oct 1, 2026

Combs v. NBCUniversal: Defendants Seek $990,292 in Attorneys’ Fees After Dismissal; Motion Fully Briefed

N.Y. Sup. Ct. · Index No. 151935/2025 · Fee Motion Filed May 20, 2026; Reply Filed Aug. 5, 2026

In the matter of Combs v. NBCUniversal Media, LLC, Peacock TV LLC and Ample, LLC, Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty.), the defendants have asked Justice Phaedra F. Perry-Bond to award them $990,292 in attorneys’ fees for defeating Sean “Diddy” Combs’s defamation suit over the documentary Diddy: The Making of a Bad Boy. Combs asks the court to wait for the First Department to decide his appeal and, if it rules now, to award no more than $166,769.25. Briefing closed on Aug. 5, 2026; the court’s calendar shows the motion fully submitted on its Aug. 6 return date, and no ruling appears on the docket. (ECF Nos. 148–152, 157–165.)

Background

The court dismissed Combs’s amended complaint on Apr. 20, 2026, and directed the defendants to file a fee application under Civil Rights Law § 70-a, the fee-shifting provision of New York’s anti-SLAPP law. (ECF No. 142 at 12; see Dispatch 7.) The defendants write that where a defendant prevails on such a motion, an award of fees is “mandatory, not discretionary.” (ECF No. 149 ¶ 4.) They filed the motion on May 20. Its notice set a July 21 return date, with opposition due June 19 and reply July 20 (ECF No. 148). Two stipulations, so-ordered by the court, moved the deadlines to July 6 and Aug. 5 (ECF Nos. 154, 156), and the court’s calendar shows the July 21 date adjourned to Aug. 6.

The Request

The defendants seek $927,448 for 777.5 hours worked by six Gibson, Dunn & Crutcher LLP lawyers from Feb. 25, 2025, through May 20, 2026, at hourly rates of $1,980 for Theodore Boutrous, $1,420 for Connor Sullivan and Katie Townsend, $1,165 for Zachary Freund, $1,060 for Connor Mui and $915 for Elise Blegen. (ECF No. 149 ¶¶ 5–7, 12.) They state that these rates are “significantly lower than Gibson Dunn’s customary billing rates.” (Id. ¶ 12.)

The affirmation breaks the hours into five phases: 290.7 on the first motion to dismiss, which Combs’s amended complaint superseded; 130.2 on the second; 138 on the reply; 190.2 preparing for the Apr. 17 argument; and 28.4 on the fee application itself. (Id. ¶¶ 23–36.) On Aug. 5, the defendants added $62,844 for 54.3 hours spent on the reply papers, for a total of $990,292. (ECF No. 163 ¶¶ 5–6.)

Combs’s Opposition

Combs opposed on July 6. His brief states that the Apr. 20 order “was wrongly decided,” points to his appeal (No. 2026-03017), and asks the court to “abstain from ruling on Defendants’ fee request until the First Department has ruled on Plaintiff’s appeal.” (ECF No. 157 at 1.) On the amount, he argues that the rates exceed those prevailing in New York for comparable work and proposes $800, $650, $500, $425 and $350 per hour, in descending order of seniority. (Id. at 8.) He cites Gibson Dunn’s fee request in a New Jersey defamation case, Satz v. Starr, at $460 an hour for a partner. (Id. at 6; ECF Nos. 158–160.)

On hours, he calls 777.5 “a staggering number of hours” for a pre-discovery motion on a single claim, argues that six lawyers duplicated one another’s work, and asks for a 50 percent across-the-board cut and removal of all of Townsend’s time. (Id. at 8, 23.) He compares the request with the $392,638.69 awarded in Trump v. Trump, which he describes as the largest such award in a New York state action that he knows of. (Id. at 17–18.) He also argues that the statute does not authorize fees for preparing the fee application: “Nowhere does the statute explicitly authorize fees on fees.” (Id. at 22.)

The Defendants’ Reply

The defendants write that Combs “does not dispute that Defendants are entitled to fees.” (ECF No. 162 at 1.) They cite New York federal decisions approving Gibson Dunn partner rates “up to $1,915 per hour,” adjust older awards for legal-services inflation using a Bureau of Labor Statistics index, and argue that Satz reflects New Jersey rates. (Id. at 3–7.) They state that Combs demanded “not less than $100,000,000” and that the fees sought are “less than 1%” of that amount. (Id. at 8.) On fees for the fee application, they cite Golan v. Daily News, in which a New York County court held that “fees on fees are permitted” under the statute. (Id. at 12.)

What Is Pending

Besides the fee motion, Combs’s appeal of the dismissal is pending in the First Department. (ECF No. 157 at 1.) On Sept. 18, Sher Tremonte moved by proposed order to show cause to withdraw as Combs’s counsel in this action. Michael Tremonte’s affirmation states that Combs “has deliberately disregarded his obligation to pay Sher Tremonte’s legal fees and expenses” and that there has been “a total breakdown in cooperation and communication.” (ECF No. 167 ¶¶ 4–5.) Justice Perry-Bond signed the order on Sept. 21. Its handwritten entries set Oct. 16 for answering papers and Oct. 23 as the return date, and note “Submission only - no appearance on return date.” (ECF No. 168.) The court’s calendar lists Oct. 23 as “SUBMISSIONS - NO APPEARANCE.”

Counsel and Sources

Sean Combs is represented by Michael Tremonte, Erica A. Wolff and Benjamin J. Shack Sackler of Sher Tremonte LLP, which has moved to withdraw. NBCUniversal Media, LLC, Peacock TV LLC and Ample, LLC are represented by Theodore J. Boutrous Jr., Katie Townsend and Connor S. Sullivan of Gibson, Dunn & Crutcher LLP. Source: ECF Nos. 142, 148, 149, 154, 156, 157–160, 162, 163 and 166–168 on the Combs v. NBCUniversal docket.

Diddy Docket reports on public court records. Parties are presumed innocent or not liable unless proven otherwise. This is not legal advice.

Related cases

151935/2025

Sourcing

p. 12 — Decision and Order on Motion No. 002 (Perry-Bond, J.), Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Apr. 20, 2026) (NYSCEF Doc. No. 142), p. 12 -- "ORDERED that within thirty days of entry, Defendants shall file their fee application pursuant to Civil Rights Law § 70-a"
¶ 4 — Affirmation of Connor S. Sullivan in Support of Defendants' Motion for Attorneys' Fees, Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. May 20, 2026) (NYSCEF Doc. No. 149) -- "mandatory, not discretionary."
¶¶ 5-7 — Affirmation of Connor S. Sullivan in Support of Defendants' Motion for Attorneys' Fees, Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. May 20, 2026) (NYSCEF Doc. No. 149) -- "Defendants are seeking through this motion an award of $927,448 for the fees incurred ... from February 25, 2025 ... through May 20, 2026 ... It reflects a total of 777.5 attorney hours"
¶ 12 — Affirmation of Connor S. Sullivan in Support of Defendants' Motion for Attorneys' Fees, Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. May 20, 2026) (NYSCEF Doc. No. 149) -- "significantly lower than Gibson Dunn’s customary billing rates for fee-paying clients ... [rate table: Theodore Boutrous $1,980; Connor Sullivan $1,420; Katie Townsend $1,420; Zachary Freund $1,165; Connor Mui $1,060; Elise Blegen $915]"
¶ 23 — Affirmation of Connor S. Sullivan in Support of Defendants' Motion for Attorneys' Fees, Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. May 20, 2026) (NYSCEF Doc. No. 149) -- "the six attorneys working on the case spent 290.7 hours preparing to file Defendants’ initial Motion to Dismiss Plaintiff’s original Complaint."
¶ 28 — Affirmation of Connor S. Sullivan in Support of Defendants' Motion for Attorneys' Fees, Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. May 20, 2026) (NYSCEF Doc. No. 149) -- "the attorneys working on the case spent 130.2 hours preparing to file Defendants’ ultimately successful Motion to Dismiss the Amended Complaint."
¶ 32 — Affirmation of Connor S. Sullivan in Support of Defendants' Motion for Attorneys' Fees, Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. May 20, 2026) (NYSCEF Doc. No. 149) -- "the attorneys working on the case spent 138 hours preparing Defendants’ reply brief"
¶ 35 — Affirmation of Connor S. Sullivan in Support of Defendants' Motion for Attorneys' Fees, Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. May 20, 2026) (NYSCEF Doc. No. 149) -- "the attorneys working on the case spent 190.2 hours preparing for the April 17, 2026 hearing"
¶ 36 — Affirmation of Connor S. Sullivan in Support of Defendants' Motion for Attorneys' Fees, Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. May 20, 2026) (NYSCEF Doc. No. 149) -- "the attorneys working in the case spent 28.4 hours preparing Defendants’ application for fees"
p. 2 — Notice of Motion for Attorneys' Fees, Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. May 20, 2026) (NYSCEF Doc. No. 148), p. 2 -- "affidavits, if any, are to be served upon the undersigned no later than June 19, 2026, while reply papers and affidavits, if any, are to be served no later than July 20, 2026."
¶ 1-2 — Stipulation and Order Further Revising Fee Application Briefing Schedule, Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. June 17, 2026) (NYSCEF Doc. No. 156) -- "Plaintiff's deadline to file any opposition to Defendants’ fee application is July 6, 2026. ... Defendants’ deadline to file any reply to any such opposition is August 5, 2026."
p. 1 — Memorandum of Law in Opposition to Defendants' Motion for Attorneys' Fees, Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. July 6, 2026) (NYSCEF Doc. No. 157), p. 1 -- "was wrongly decided ... Plaintiff has appealed the Order to the First Department. NYSCEF No. 144; Case No. 2026-03017. Therefore, this Court should abstain from ruling on Defendants’ fee request until the First Department has ruled on Plaintiff’s appeal ... a reasonable fee for Gibson Dunn’s work on this matter is no more than $166,769.25."
p. 6 — Memorandum of Law in Opposition to Defendants' Motion for Attorneys' Fees, Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. July 6, 2026) (NYSCEF Doc. No. 157), p. 6 -- "Gibson Dunn sought and was awarded fees at rates of $460 for a partner, $425 for a senior associate, and $265 for junior associates"
p. 8 — Memorandum of Law in Opposition to Defendants' Motion for Attorneys' Fees, Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. July 6, 2026) (NYSCEF Doc. No. 157), p. 8 -- "should not exceed $800 per hour for the most senior partner, $650 per hour for the other partners, $500 per hour for the senior associate, $425 per hour for the mid-level associate, and $350 per hour for the junior associate ... This is a staggering number of hours for a pre-discovery motion to dismiss on a single defamation claim."
p. 17 — Memorandum of Law in Opposition to Defendants' Motion for Attorneys' Fees, Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. July 6, 2026) (NYSCEF Doc. No. 157), p. 17 -- "Plaintiff is unaware of any New York state court decision that has awarded fees remotely approaching this amount under Civil Rights Law Section 70-a."
p. 17-18 — Memorandum of Law in Opposition to Defendants' Motion for Attorneys' Fees, Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. July 6, 2026) (NYSCEF Doc. No. 157), p. 17-18 -- "Justice Reed ordered Donald Trump to pay $392,638.69 in legal fees"
p. 22 — Memorandum of Law in Opposition to Defendants' Motion for Attorneys' Fees, Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. July 6, 2026) (NYSCEF Doc. No. 157), p. 22 -- "Nowhere does the statute explicitly authorize fees on fees."
p. 23 — Memorandum of Law in Opposition to Defendants' Motion for Attorneys' Fees, Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. July 6, 2026) (NYSCEF Doc. No. 157), p. 23 -- "an across the board 50% reduction in the number of hours billed, along with the complete elimination the hours billed by Ms. Townsend"
p. 1 — Memorandum of Law in Reply in Support of Defendants' Motion for Attorneys' Fees, Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Aug. 5, 2026) (NYSCEF Doc. No. 162), p. 1 -- "Combs does not dispute that Defendants are entitled to fees."
p. 3 — Memorandum of Law in Reply in Support of Defendants' Motion for Attorneys' Fees, Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Aug. 5, 2026) (NYSCEF Doc. No. 162), p. 3 -- "approving rates up to $1,915 per hour for Gibson Dunn partners"
p. 7 — Memorandum of Law in Reply in Support of Defendants' Motion for Attorneys' Fees, Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Aug. 5, 2026) (NYSCEF Doc. No. 162), p. 7 -- "Satz v. Starr, No. BER-L-005596-23 (N.J. Super. Ct. Law Div. Bergen Cnty. 2026) is also irrelevant."
p. 8 — Memorandum of Law in Reply in Support of Defendants' Motion for Attorneys' Fees, Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Aug. 5, 2026) (NYSCEF Doc. No. 162), p. 8 -- "Combs sought “not less than $100,000,000” in damages. ... Defendants’ requested fees—less than 1% of that amount—are reasonable given that potential exposure."
p. 12 — Memorandum of Law in Reply in Support of Defendants' Motion for Attorneys' Fees, Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Aug. 5, 2026) (NYSCEF Doc. No. 162), p. 12 -- "the Court finds that fees on fees are permitted."
¶¶ 5-6 — Supplemental Affirmation of Connor S. Sullivan in Support of Defendants' Motion for Attorneys' Fees, Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Aug. 5, 2026) (NYSCEF Doc. No. 163) -- "Defendants request an award of $62,844 for work performed from July 6, 2026 to August 5, 2026 ... this yields $990,292."
¶¶ 4-5 — Affirmation of Michael Tremonte in Support of Motion to Withdraw, Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 18, 2026) (NYSCEF Doc. No. 167) -- "Mr. Combs has deliberately disregarded his obligation to pay Sher Tremonte’s legal fees and expenses. ... there has been a total breakdown in cooperation and communication"
pp. 1-2 — Order to Show Cause re: Withdrawal of Counsel, as signed (Perry-Bond, J.), Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 21, 2026) (NYSCEF Doc. No. 168), pp. 1-2 -- "[Handwritten on the signed order, read from a render, not machine-checkable: return date “10-23”; answering papers “10-16”; “Submission only - no appearance on return date”; signed and dated 9-21-2026. Paragraph staying the case is struck through and overwritten by hand; not characterised.]"
calendar — NYSCEF court calendar, Index No. 151935/2025 (pasted by the editor Oct. 1, 2026) -- "[07/21/2026 9:30 AM Motion-Notice of Motion, Mot. Seq. 3: Adjourned. 08/06/2026 9:30 AM Motion-Notice of Motion, Mot. Seq. 3: Fully Submitted, “SUBMISSIONS - NO APPEARANCE ... NYSCEF DOC. # 161.” 10/23/2026 9:30 AM Motion-Order to Show Cause (Initial Application), Mot. Seq. 4: “SUBMISSIONS - NO APPEARANCE NYSCEF DOC. #168.”]"

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