DiddyDocket Dispatch
Doe v. Combs et al. + 2 related cases
U.S. District Court, Southern District of New York No. 1:24-cv-07778 Judge Jennifer L. Rochon
Oct 21, 2026

Doe v. Combs and Sapp v. Combs: Court Lets Sher Tremonte Withdraw in Two Cases and Denies Its Motion in a Third

S.D.N.Y. · Nos. 1:24-cv-07778, 1:24-cv-09852 and 1:25-cv-00996 · Orders Filed Oct. 20, 2026

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In the matter of Doe v. Combs et al., No. 1:24-cv-07778, Doe v. Combs et al., No. 1:24-cv-09852, and Sapp v. Combs, No. 1:25-cv-00996 (S.D.N.Y.), United States District Judge Jennifer L. Rochon has ruled on three motions by Sher Tremonte LLP to withdraw as counsel for Sean “Diddy” Combs. In the two Doe cases she granted the motions and a retaining lien, which is a law firm’s right to keep a client’s case files until its fees are paid. In Sapp she denied the motion “without prejudice,” meaning the firm may ask again. (No. 1:24-cv-07778, ECF No. 91; No. 1:24-cv-09852, ECF No. 67; No. 1:25-cv-00996, ECF No. 90.)

Background

Plaintiffs John Doe (No. 1:24-cv-07778) and Jane Doe (No. 1:24-cv-09852) each sue Combs and several companies, among them Daddy’s House Recordings Inc., CE OpCo, LLC and Bad Boy entities. John Doe’s complaint alleges that Combs sexually assaulted Doe at a 1998 party at Combs’s New York home when Doe was a minor. Jane Doe’s alleges a sexual assault in December 1991 at a charity basketball game at City College in New York. (No. 1:24-cv-07778, ECF No. 1 at 1, 13; No. 1:24-cv-09852, ECF No. 1 at 1, 14–15.) Both cases are stayed, meaning paused. Julian Sapp’s case was dismissed on Sept. 18 (see the earlier Dispatch). The rulings follow Judge Valerie Caproni’s Oct. 13 grant in Kelly v. Combs (see that Dispatch).

The Two Doe Orders

The orders are identical apart from docket numbers. Each rests on “the reasons stated on the record at the October 20, 2026 conference” and states none in writing. The court:

  1. Grants the motion to withdraw (Dkt. 82 in the John Doe case; Dkt. 63 in the Jane Doe case) and the firm’s “related request for a retaining lien against Defendants’ case files.”
  2. Declines to fix the lien’s amount: “Because Sher Tremonte has not submitted documentation establishing the amounts owed, the Court does not presently fix the amount of the lien.” The firm “may submit appropriate billing records and other supporting evidence if it seeks to fix that amount.”
  3. States that “Defendants are now deemed to be proceeding without counsel.”
  4. Notes that a corporation, LLC or partnership “must appear through licensed counsel” (Lattanzio v. COMTA, 481 F.3d 137, 140 (2d Cir. 2007)) and orders that, because each case “is presently stayed,” the company defendants “shall obtain new counsel in due course and no later than fourteen days after the stay is lifted.”
  5. Directs the clerk to terminate the motion and “terminate Sher Tremonte as counsel of record.” (John Doe, ECF No. 91 at 1–2; Jane Doe, ECF No. 67 at 1–2.)

In the John Doe case, the firm filed its motion on Sept. 29. On Oct. 1 the court set an Oct. 20 video hearing and wrote that “[u]nless and until the Court grants the motion, Sher Tremonte LLP remains counsel of record.” (ECF No. 85 at 1.) On Oct. 7 the firm wrote that it had “inadvertently omitted our representation of the Company Defendants” and that they “are also significantly behind in their payments to Sher Tremonte.” Judge Rochon endorsed the letter “Request GRANTED.” (ECF No. 88 at 1.) On Oct. 14 the firm cited Kelly as supplemental authority; its Exhibit A is not in our library. (ECF No. 89 at 1.) The firm’s statements about payment are its own, not findings. In the Jane Doe case the motion was filed Oct. 15 (ECF Nos. 63–65). The docket for neither case lists an opposition.

Sapp v. Combs

The docket lists a clerk’s judgment on Sept. 23 (ECF No. 79) and, on Oct. 2, an entry titled “Reconsideration” (ECF No. 80), which the new order calls “Plaintiff’s pending motion for reconsideration.” Sher Tremonte moved to withdraw on Oct. 9 (ECF No. 81). The one-page order states that the motion “is DENIED without prejudice and with leave to renew via letter motion after the Court’s ruling on Plaintiff’s pending motion for reconsideration,” again citing only the Oct. 20 conference. (ECF No. 90 at 1.) It does not terminate the firm as counsel. The firm’s papers and the briefing that followed (ECF Nos. 82–86 and 88–89) are not in our library, so the grounds the firm gave and the plaintiff’s position are not reported here.

What Remains

The orders do not say who is right about the fees, name new counsel, lift the stay or address the plaintiffs’ allegations. The company defendants’ fourteen days start when the stay ends. The firm may file billing records to fix its lien. In Sapp, the reconsideration motion is undecided and the firm may renew by letter. No transcript of the Oct. 20 conference is in our library.

Counsel and Sources

Counsel: Sher Tremonte LLP for Combs and the company defendants until the Oct. 20 orders in the Doe cases; The Buzbee Law Firm filed both Doe complaints; the docket lists The Bloom Firm for Sapp. Source: ECF Nos. 1, 85, 88, 89 and 91 on the No. 1:24-cv-07778 docket, ECF Nos. 1 and 67 on the No. 1:24-cv-09852 docket and ECF No. 90 on the No. 1:25-cv-00996 docket. Dates for papers not in our library come from the docket sheets. Related: Güzel, NBCUniversal, Burgess.

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

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