Oct 6, 2026

Combs v. NBCUniversal: Court Awards Defendants $477,700.50 in Attorneys’ Fees, Less Than Half of the $990,292 Sought

N.Y. Sup. Ct. · Index No. 151935/2025 · Decision and Order on Fee Motion Filed Oct. 6, 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.), Justice Phaedra F. Perry-Bond has ordered Sean “Diddy” Combs to pay the defendants $477,700.50 in attorneys’ fees for defeating his defamation suit over the documentary Diddy: The Making of a Bad Boy. The defendants had asked for $990,292. The court granted the motion in part and denied the rest, leaving the lawyers’ hourly rates untouched and cutting the hours it found excessive. (ECF No. 170.)

Background

The court dismissed Combs’s amended complaint on Apr. 20, 2026, finding the suit a strategic lawsuit against public participation, or SLAPP, under Civil Rights Law § 76-a. Because the defendants prevailed on their motion under CPLR 3211(g), the court held that they are entitled to fees under Civil Rights Law § 70-a(1)(a). (ECF No. 170 at 1; see Dispatch 7.) The defendants sought fees for 777.5 hours worked by six Gibson, Dunn & Crutcher LLP lawyers, plus 54.3 hours spent replying to Combs’s opposition. Combs argued for no more than $166,769.25 and asked the court to wait for his appeal. (Id. at 1–2; see Dispatch 16.)

Rates Upheld

The court “declines any reduction of the defendants’ hourly rates,” which run from $1,980 for Theodore Boutrous to $915 for Elise Blegen. It acknowledged the rates are “higher than the customary rates.” It cited the publicity of the case, its complexity, the $100 million in damages Combs sought, the experience of the attorneys, the result and the quality of the briefing and oral argument. It described the partners as “some of the country’s leading First Amendment litigators.” (Id. at 3–4.)

Hours Cut

The court found the hours billed “in some instances, unreasonable” and made four reductions. (Id. at 4–6.)

Internal communications. The defendants billed 79.1 hours, or $98,287.50, for meetings, discussions and calls among the six lawyers. The court called it “inequitable” for Combs to be billed nearly $100,000 on that and cut the amount by 80 percent, awarding $19,657.50. The order states the reduction as $78,360.00.

Oral argument. The court found 190 hours of preparation excessive, singling out the 84.5 hours, or $77,317.50, billed by Blegen, the junior associate. Only Boutrous and Connor Sullivan argued, and they billed 27.4 and 54.5 hours. The court cut Blegen’s time to 5.0 hours, or $4,575, a reduction of $72,742.50.

Motions to dismiss. The defendants billed 290.7 hours on the first motion, which Combs’s amended complaint superseded, and 130.2 on the second. The court found the defendants “over prepared” and noted that the arguments in the two motions were “not much different.” It left the 130.2 hours alone and cut the $344,301 billed on the first motion to $75,000, a reduction of $269,301.

Reply brief. The court found 138 hours unreasonable for a 14-page reply that could introduce no new arguments. It cut Sullivan from 39.8 hours to 20 and Connor Mui from 55.8 to 25, and declined to cut the other attorneys, none of whom billed more than 15 hours on it. The order states the reductions as $26,696 for Sullivan and $32,658 for Mui, and totals them at $59,344.

The order totals these four reductions at $479,747.50. (Id. at 4–6 & n.1.)

Fees on Fees

Combs had argued that the statute does not authorize fees for preparing the fee application. The court rejected that, joining “the growing number of other Supreme Court Justices in this County” that allow such fees, and cited decisions by Justices Lebovits, Hagler and Sattler. It then found “excessive” the $62,844 billed by five attorneys over 54.3 hours to reply to Combs’s opposition, and cut it to $30,000, a further reduction of $32,844. (Id. at 7.)

The Award

With that cut, the order puts the total reduction at $512,591.50 and the award at $477,700.50, about 48 percent of the amount requested. Within ten days of entry, defense counsel must submit a proposed judgment and serve the decision with notice of entry on all parties through NYSCEF. (Id. at 7–8.) The order does not address Combs’s request that the court wait for the First Department to rule on his appeal. The form on its last page marks the case as disposed and the motion as granted in part.

What Remains

Combs’s appeal of the Apr. 20 dismissal (No. 2026-03017) is pending in the First Department. (See ECF No. 157 at 1.) Sher Tremonte’s motion to withdraw as his counsel in this action, which the court set for submission on Oct. 23 with no appearance, also remains pending. (ECF No. 168.)

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. 157, 168 and 170 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. 1 — Decision and Order on Motion No. 003 (Perry-Bond, J.), Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Oct. 6, 2026) (NYSCEF Doc. No. 170), p. 1 -- "defendants’ motion for attorneys’ fees in the amount of $990,292 pursuant to Civil Rights Law § 70-a(1)(a) is granted in part and denied in part. ... Because defendants succeeded on their CPLR 3211(g) motion, they are entitled to fees incurred in defending this action pursuant to Civil Rights Law § 70-a(1)(a)."
p. 1 — Decision and Order on Motion No. 003 (Perry-Bond, J.), Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Oct. 6, 2026) (NYSCEF Doc. No. 170), p. 1 -- "which found this lawsuit constituted a strategic lawsuit against public participation (“SLAPP”) as defined in Civil Rights law § 76-a"
pp. 1-2 — Decision and Order on Motion No. 003 (Perry-Bond, J.), Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Oct. 6, 2026) (NYSCEF Doc. No. 170), pp. 1-2 -- "the six attorneys billed 777.5 hours ... an additional 54.3 hours spent assessing plaintiff’s opposition to this fee request and preparing a reply. The hourly rates requested by defendants include $1,980 for partner Theodore Boutrous, $1,420 for partners Connor Sullivan and Katie Townsend, $1,165 for senior associate Zachary Freund, $1,060 for mid-level associate Connor Mui, and $915 for junior associate Elise Blegen."
p. 2 — Decision and Order on Motion No. 003 (Perry-Bond, J.), Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Oct. 6, 2026) (NYSCEF Doc. No. 170), p. 2 -- "defendants should be awarded no more than $166,769.25 for their work on this case."
p. 4 — Decision and Order on Motion No. 003 (Perry-Bond, J.), Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Oct. 6, 2026) (NYSCEF Doc. No. 170), p. 4 -- "the Court declines any reduction of the defendants’ hourly rates."
p. 3 — Decision and Order on Motion No. 003 (Perry-Bond, J.), Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Oct. 6, 2026) (NYSCEF Doc. No. 170), p. 3 -- "some of the country’s leading First Amendment litigators"
p. 4 — Decision and Order on Motion No. 003 (Perry-Bond, J.), Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Oct. 6, 2026) (NYSCEF Doc. No. 170), p. 4 -- "higher than the customary rates"
p. 4 — Decision and Order on Motion No. 003 (Perry-Bond, J.), Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Oct. 6, 2026) (NYSCEF Doc. No. 170), p. 4 -- "the Court finds the hours billed in this case to be, in some instances, unreasonable."
p. 4 — Decision and Order on Motion No. 003 (Perry-Bond, J.), Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Oct. 6, 2026) (NYSCEF Doc. No. 170), p. 4 -- "The 79.1 hours on meetings, discussions, and calls amounts to $98,287.50. The Court finds it would be inequitable for plaintiff to be billed nearly $100,000 due to six attorneys’ decision to bill that amount on internal meetings and discussions. Therefore, the Court reduces the amount billed for internal meetings and discussions by 80%. Thus, of the $98,287.50 billed for internal meetings, discussions, and calls, the Court awards only $19,657.50 for a fee reduction of $78,360.00."
pp. 4-5 — Decision and Order on Motion No. 003 (Perry-Bond, J.), Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Oct. 6, 2026) (NYSCEF Doc. No. 170), pp. 4-5 -- "190 hours billed to prepare for oral argument to be excessive. ... who each argued the motion and respectively billed 27.4 and 54.5 hours, the Court finds the 84.5 hours billed by Ms. Blegen, the junior associate, at a cost of $77,317.50 to be excessive. ... the Court reduces Ms. Blegen’s hours to 5.0, which at a rate of $915 equates to $4,575. Thus, the amount billed for oral argument preparation is reduced by $72,742.50."
p. 5 — Decision and Order on Motion No. 003 (Perry-Bond, J.), Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Oct. 6, 2026) (NYSCEF Doc. No. 170), p. 5 -- "to bill 290.7 hours on their initial motion to dismiss, and after the complaint was amended, to bill another 130.2 hours in connection with a subsequent motion to dismiss"
p. 5 — Decision and Order on Motion No. 003 (Perry-Bond, J.), Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Oct. 6, 2026) (NYSCEF Doc. No. 170), p. 5 -- "finds defendants “over prepared” and finds the 290.7 hours billed for the first motion to dismiss to be unreasonable ... despite there being not much different in the arguments made between the two motions."
pp. 5-6 — Decision and Order on Motion No. 003 (Perry-Bond, J.), Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Oct. 6, 2026) (NYSCEF Doc. No. 170), pp. 5-6 -- "while the Court does not reduce the 130.2 hours spent on the second motion to dismiss, the Court reduces the $344,301 based on 290.7 hours spent in connection with the first motion to dismiss to $75,000.00. Thus, the billing in connection with the motions to dismiss are reduced by $269,301.00"
p. 6 — Decision and Order on Motion No. 003 (Perry-Bond, J.), Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Oct. 6, 2026) (NYSCEF Doc. No. 170), p. 6 -- "the Court finds the 138 hours billed to submit a 14-page reply brief to be unreasonable. ... the Court therefore reduces Mr. Sullivan’s billed hours from 39.8 to 20 and reduces Mr. Mui’s billed hours from 55.8 to 25. Considering each other attorney spent less than fifteen hours on the reply brief"
p. 6 — Decision and Order on Motion No. 003 (Perry-Bond, J.), Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Oct. 6, 2026) (NYSCEF Doc. No. 170), p. 6 -- "an overall fee reduction of $26,696. Mr. Mui’s hours were reduced by 30.8 at a rate of $1,060 for an overall fee reduction of $32,658. Thus, the total amount of fees reduced in connection with the reply brief is $59,344."
p. 6 & n.1 — Decision and Order on Motion No. 003 (Perry-Bond, J.), Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Oct. 6, 2026) (NYSCEF Doc. No. 170), p. 6 & n.1 -- "the Court reduces the fee request by $479,747.50. ... Collectively, this equates to a reduction of $479,747.50."
p. 7 — Decision and Order on Motion No. 003 (Perry-Bond, J.), Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Oct. 6, 2026) (NYSCEF Doc. No. 170), p. 7 -- "the growing number of other Supreme Court Justices in this County faced with the same question and finds fees on fees are allowed under Civil Rights Law § 70-a."
p. 7 — Decision and Order on Motion No. 003 (Perry-Bond, J.), Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Oct. 6, 2026) (NYSCEF Doc. No. 170), p. 7 -- "Lebovits, J.] ... Hagler, J.] ... Sattler, J.]"
p. 7 — Decision and Order on Motion No. 003 (Perry-Bond, J.), Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Oct. 6, 2026) (NYSCEF Doc. No. 170), p. 7 -- "the Court finds excessive the additional $62,844 billed by five attorneys from July 6, 2026 through August 5, 2026 ... Thus, the Court reduces the $62,844 in additional fees to $30,000 for a further fee reduction of $32,844. ... the total fee reduction is $512,591.50. Thus, of the $990,292 requested, defendants are awarded $477,700.50."
p. 8 — Decision and Order on Motion No. 003 (Perry-Bond, J.), Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Oct. 6, 2026) (NYSCEF Doc. No. 170), p. 8 -- "within ten days of entry, counsel for defendants shall submit a proposed judgment to the Court reflecting the $477,700.50 awarded in their favor and against plaintiff ... within ten days of entry, counsel for defendants shall serve a copy of this Decision and Order, with notice of entry, on all parties via NYSCEF."
p. 8 — Decision and Order on Motion No. 003 (Perry-Bond, J.), Combs v. NBCUniversal Media, LLC et al., Index No. 151935/2025 (N.Y. Sup. Ct., N.Y. Cnty. Oct. 6, 2026) (NYSCEF Doc. No. 170), p. 8 -- "[Form boxes, read from the page image: “Case Disposed” and “Granted in Part” checked; signed and dated 10/6/26. Not machine-checkable.]"
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 -- "this Court should abstain from ruling on Defendants’ fee request until the First Department has ruled on Plaintiff’s appeal ... Case No. 2026-03017."
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”; “Submission only - no appearance on return date”.]"
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"

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