Sep 30, 2026

Güzel v. Combs: Plaintiff Demands Details Behind Combs’s and Sony Music’s Affirmative Defenses

N.Y. Sup. Ct. · Index No. 152568/2025 · Discovery Demands Served Sept. 29, 2026

In the matter of Güzel v. Combs, et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty.), plaintiff Seven Güzel on Sept. 29, 2026 served three discovery demands: a demand that Sean Combs and five affiliated companies serve a verified bill of particulars on their affirmative defenses (ECF No. 173), a similar demand to Sony Music Entertainment (ECF No. 174), and 38 demands for documents and information (ECF No. 175). A bill of particulars is a party’s sworn, itemized statement of the facts behind a claim or defense that a pleading states only generally. An affirmative defense is a ground for defeating or reducing a claim beyond denying it.

Background

Güzel’s amended complaint alleges sexual assault by Combs. (ECF No. 23.) On Sept. 3, 2026, Combs, Bad Boy Entertainment LLC, Bad Boy Entertainment Holdings, Inc., Daddy’s House Recordings Inc., CE OpCo, LLC and Revolt Media and TV LLC, which the demands call the “Combs Defendants,” filed a verified answer pleading twelve affirmative defenses. (ECF No. 151 at 39–40.) Sony Music, which states that only the Eighth Cause of Action remains against it, answered the same day with six. (ECF No. 150 ¶ 1.)

The Demand to the Combs Defendants

Most of the Combs Defendants’ defenses run a sentence or two. The demand takes up five in nine items and asks for what the pleading does not say. (ECF No. 173 ¶¶ 1–9.)

The Fifth Defense states that any injuries “were the result of acts of third parties over which Defendants have no responsibility or control.” (ECF No. 151 ¶ 5.) Item 1 asks for their names and addresses; the answer does not identify them.

The Seventh states in one sentence that Güzel “voluntarily engaged in or otherwise consented to the alleged conduct at issue.” (Id. ¶ 7.) Item 2 asks the defendants to state the “alleged conduct” they mean.

The Eighth invokes “waiver and/or estoppel,” meaning giving up a right and being barred from contradicting conduct someone relied on. (Id. ¶ 8.) Items 3 through 5 ask for the “acts or omissions” said to be her waiver, the claims she waived, and the “prior act or statement” the defendants relied on. Item 6 asks which claims are “subject to the doctrine of laches,” and attributes laches to the Eighth Defense; the answer pleads laches as its Third. (Id. ¶ 3.)

The Ninth pleads “unclean hands” and the Tenth “failure to mitigate,” meaning a failure to reduce her own losses. (Id. ¶¶ 9–10.) Item 7 asks for the acts behind the first; items 8 and 9 ask for the acts behind the second and “the damages that Plaintiff failed to mitigate.” Apart from laches, the demand does not address the First, Second, Fourth, Sixth, Eleventh or Twelfth Defenses, which include limitations, no damages and group pleading.

The Demand to Sony Music

Sony Music’s Fourth Affirmative Defense, titled “Intervening Cause of Harm or Loss,” states that Güzel’s harm or loss, “if any, was the result of independent acts or omissions by third parties, and SME had no involvement in such actions.” (ECF No. 150 ¶ 223.) The demand asks Sony Music to identify the “third parties” by name and address and to state the “independent acts or omissions” attributed to them. (ECF No. 174 ¶¶ 1–2.) Sony Music’s answer likewise does not name them, and the demand reaches none of Sony Music’s other five defenses. Both demands ask for a verified bill within 30 days of service. (ECF No. 173 at 1; ECF No. 174 at 1.)

The Document Demand

One of the 38 items has 23 lettered subjects, among them the relationships among Sony Music, Combs and the companies from 2017 through 2021, Combs’s role at each, and “allegations of Sexual Conduct or misconduct against Combs by any person or entity prior to and including 2021.” (ECF No. 175 ¶ 4.) Others seek recordings depicting Güzel (¶¶ 5–6), Combs’s personnel file (¶ 24) and insurance agreements (¶ 38). Four ask for signed authorizations for Combs’s mental-health, pharmacy, “sexual addiction” and sexually-transmitted-disease treatment records. (Id. ¶¶ 16–19.) The notice is addressed to Combs and the five companies, but it defines “Defendants” to include Sony Music, and item 4 reaches documents in Sony Music’s possession. (Id. at 1, 3, 5.)

The Other Side

No response to the demands appears on the docket. The Combs Defendants deny she is entitled to “any damages,” and Sony Music “specifically denies that there is any basis” for the claim against it. (ECF No. 151 at 38; ECF No. 150 ¶ 1.) Both have asked the court to stay “any discovery” of them while they appeal its July 9 decision. (ECF Nos. 140, 148.)

What’s Next

Thirty days from service is Oct. 29, 2026, after the depositions noticed for Combs on Oct. 5 and for Sony Music and the five companies on Oct. 8. (ECF Nos. 152–160.) The stay motions were noticed for Sept. 10; no ruling on either appears among the docket entries through Sept. 29. Justice Leslie A. Stroth declined on Sept. 16 to sign Sher Tremonte’s proposed withdrawal order (see the earlier Dispatch); the demands were served on that firm.

Counsel and Sources

Güzel is represented by Merson Law, PLLC (Jordan Rutsky signed the demands), the Combs Defendants by Sher Tremonte LLP and Sony Music by Pryor Cashman LLP. No demand is directed to defendant Kristina Khorram. Source: ECF Nos. 23, 140, 148, 150–160 and 173–175 on the Güzel v. Combs 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

152568/2025

Sourcing

ECF No. 23 — Amended Verified Complaint, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty.) (NYSCEF Doc. No. 23) -- "Sean Combs (hereinafter “Combs”) and the people and entities that enabled him in his gender-motivated violence, sexual assaults, rapes, and other torts directed at Plaintiff"
ECF No. 151 at 1 — Defendants’ Verified Answer and Affirmative Defenses to the Amended Complaint, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 3, 2026) (NYSCEF Doc. No. 151), at 1 -- "Defendants Sean Combs (“Mr. Combs”), Bad Boy Entertainment LLC, Bad Boy Entertainment Holdings, Inc., Daddy’s House Recordings Inc., CE OpCo, LLC (d/b/a Combs Global) f/k/a Combs Enterprises, LLC, and Revolt Media and TV LLC (hereinafter collectively, the “Defendants,”"
ECF No. 151 ¶ 3 — Defendants’ Verified Answer and Affirmative Defenses to the Amended Complaint, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 3, 2026) (NYSCEF Doc. No. 151), at 39 -- "Plaintiff’s claims are barred in whole or in part by the doctrine of laches."
ECF No. 151 ¶ 5 — Defendants’ Verified Answer and Affirmative Defenses to the Amended Complaint, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 3, 2026) (NYSCEF Doc. No. 151), at 39 -- "such injuries or damages were the result of acts of third parties over which Defendants have no responsibility or control."
ECF No. 151 ¶ 7 — Defendants’ Verified Answer and Affirmative Defenses to the Amended Complaint, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 3, 2026) (NYSCEF Doc. No. 151), at 40 -- "Plaintiff voluntarily engaged in or otherwise consented to the alleged conduct at issue."
ECF No. 151 ¶ 8 — Defendants’ Verified Answer and Affirmative Defenses to the Amended Complaint, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 3, 2026) (NYSCEF Doc. No. 151), at 40 -- "Plaintiff’s claims are barred in whole or in part by the doctrines of waiver and/or estoppel."
ECF No. 151 ¶ 9 — Defendants’ Verified Answer and Affirmative Defenses to the Amended Complaint, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 3, 2026) (NYSCEF Doc. No. 151), at 40 -- "Plaintiff’s claims are barred by the doctrine of unclean hands."
ECF No. 151 ¶ 10 — Defendants’ Verified Answer and Affirmative Defenses to the Amended Complaint, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 3, 2026) (NYSCEF Doc. No. 151), at 40 -- "Plaintiff’s claims are barred by Plaintiff’s failure to mitigate."
ECF No. 151 ¶ 12 — Defendants’ Verified Answer and Affirmative Defenses to the Amended Complaint, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 3, 2026) (NYSCEF Doc. No. 151), at 40 -- "The Amended Complaint improperly groups the Company Defendants with numerous unrelated entities as undifferentiated “Institutional Defendants”"
ECF No. 151 at 38 — Defendants’ Verified Answer and Affirmative Defenses to the Amended Complaint, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 3, 2026) (NYSCEF Doc. No. 151), at 38 -- "deny that Plaintiff is entitled to any damages, relief, judgment, award, fees, or costs whatsoever."
ECF No. 150 ¶ 1 — Verified Answer and Affirmative Defenses of Defendant Sony Music Entertainment, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 3, 2026) (NYSCEF Doc. No. 150), at 1 -- "only one of which, the Eighth Cause of Action, remains pled against SME as a purported member of the “Institutional Defendants,” and specifically denies that there is any basis for such Eighth Cause of Action as against SME."
ECF No. 150 ¶ 223 — Verified Answer and Affirmative Defenses of Defendant Sony Music Entertainment, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 3, 2026) (NYSCEF Doc. No. 150), at 38 -- "(Intervening Cause of Harm or Loss) ... Plaintiff’s claim is barred because the harm or loss suffered by Plaintiff, if any, was the result of independent acts or omissions by third parties, and SME had no involvement in such actions."
ECF No. 173 at 1 — Demand of Verified Bill of Particulars to the Combs Defendants, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 29, 2026) (NYSCEF Doc. No. 173), at 1 -- "serve upon the undersigned within thirty (30) days from the date of service of this demand, a verified bill of particulars as to affirmative defenses, pursuant to CPLR 3041, et seq."
ECF No. 173 ¶ 1 — Demand of Verified Bill of Particulars to the Combs Defendants, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 29, 2026) (NYSCEF Doc. No. 173), at 1 -- "Identify, by name and address, the “third parties over which Defendants have no responsibility or control,” who the Combs Defendants allege caused Plaintiff’s injuries and damages, as alleged in the Combs Defendants’ Fifth Affirmative Defense."
ECF No. 173 ¶ 2 — Demand of Verified Bill of Particulars to the Combs Defendants, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 29, 2026) (NYSCEF Doc. No. 173), at 2 -- "State the “alleged conduct” which the Combs Defendants allege “Plaintiff voluntarily engaged in or otherwise consented to,” as alleged in the Combs Defendants’ Seventh Affirmative Defense."
ECF No. 173 ¶ 3 — Demand of Verified Bill of Particulars to the Combs Defendants, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 29, 2026) (NYSCEF Doc. No. 173), at 2 -- "State the acts or omissions of Plaintiff that the Combs Defendants allege constitute her “waiver” of the claims in this action, as alleged by the Combs Defendants in their Eighth Affirmative Defense."
ECF No. 173 ¶ 4 — Demand of Verified Bill of Particulars to the Combs Defendants, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 29, 2026) (NYSCEF Doc. No. 173), at 2 -- "State the claims that Plaintiff waived, as alleged by the Combs Defendants in their Eighth Affirmative Defense."
ECF No. 173 ¶ 5 — Demand of Verified Bill of Particulars to the Combs Defendants, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 29, 2026) (NYSCEF Doc. No. 173), at 2 -- "State the prior act or statement of Plaintiff upon which Defendant relied such that Defendant alleges that the doctrine of estoppel applies, as alleged by the Combs Defendants in their Eighth Affirmative Defense."
ECF No. 173 ¶ 6 — Demand of Verified Bill of Particulars to the Combs Defendants, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 29, 2026) (NYSCEF Doc. No. 173), at 2 -- "State the claims that are subject to the doctrine of laches, as alleged by the Combs Defendants in their Eighth Affirmative Defense."
ECF No. 173 ¶ 7 — Demand of Verified Bill of Particulars to the Combs Defendants, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 29, 2026) (NYSCEF Doc. No. 173), at 2 -- "State the acts or omissions of Plaintiff that constitute her “unclean hands,” as alleged by the Combs Defendants in their Ninth Affirmative Defense."
ECF No. 173 ¶ 8 — Demand of Verified Bill of Particulars to the Combs Defendants, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 29, 2026) (NYSCEF Doc. No. 173), at 2 -- "State the acts or omissions of Plaintiff that constitutes her “failure to mitigate,” as alleged by the Combs Defendants in their Tenth Affirmative Defense."
ECF No. 173 ¶ 9 — Demand of Verified Bill of Particulars to the Combs Defendants, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 29, 2026) (NYSCEF Doc. No. 173), at 2 -- "State the damages that Plaintiff failed to mitigate, as alleged by the Combs Defendants in their Tenth Affirmative Defense."
ECF No. 174 at 1 — Demand of Verified Bill of Particulars to Sony Music Entertainment, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 29, 2026) (NYSCEF Doc. No. 174), at 1 -- "serve upon the undersigned within thirty (30) days from the date of service of this demand, a verified bill of particulars as to affirmative defenses, pursuant to CPLR 3041, et seq."
ECF No. 174 ¶ 1 — Demand of Verified Bill of Particulars to Sony Music Entertainment, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 29, 2026) (NYSCEF Doc. No. 174), at 1 -- "Identify, by name and address, the “third parties” whose “independent acts or omissions” caused Plaintiff’s injuries, as alleged in SME’s Fourth Affirmative Defense."
ECF No. 174 ¶ 2 — Demand of Verified Bill of Particulars to Sony Music Entertainment, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 29, 2026) (NYSCEF Doc. No. 174), at 1 -- "State the “independent acts or omissions” attributable to the “third parties” that caused Plaintiff’s injuries, as alleged in SME’s Fourth Affirmative Defense."
ECF No. 175 at 1 — Plaintiff’s Initial Demands for Discovery & Inspection, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 29, 2026) (NYSCEF Doc. No. 175), at 1 -- "Plaintiff demands that Defendants produce the following documents or information at Merson Law, PLLC, 950 Third Avenue, 18th Floor, New York, New York, within thirty days."
ECF No. 175 at 3 — Plaintiff’s Initial Demands for Discovery & Inspection, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 29, 2026) (NYSCEF Doc. No. 175), at 3 -- "The term “Defendants” means and refers to Sean Combs, Bad Boy Entertainment LLC (d/b/a “Bad Boy Records”), Bad Boy Entertainment Holdings, Inc., Sony Music Entertainment, Daddy’s House Recordings Inc., Revolt Media and Tv LLC, and Ce Opco, LLC"
ECF No. 175 ¶ 4 — Plaintiff’s Initial Demands for Discovery & Inspection, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 29, 2026) (NYSCEF Doc. No. 175), at 5 -- "Documents, writings, visual recordings, or audio recordings in the possession of defendants Combs, Bad Boy Entertainment LLC (d/b/a “Bad Boy Records”), Bad Boy Entertainment Holdings, Inc., Sony Music Entertainment"
ECF No. 175 ¶ 4(o) — Plaintiff’s Initial Demands for Discovery & Inspection, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 29, 2026) (NYSCEF Doc. No. 175), at 7 -- "allegations of Sexual Conduct or misconduct against Combs by any person or entity prior to and including 2021;"
ECF No. 175 ¶ 16 — Plaintiff’s Initial Demands for Discovery & Inspection, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 29, 2026) (NYSCEF Doc. No. 175), at 10 -- "Duly executed original authorization to obtain full access to and copies of Comb’s mental and psychological healthcare providers"
ECF No. 175 ¶ 18 — Plaintiff’s Initial Demands for Discovery & Inspection, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 29, 2026) (NYSCEF Doc. No. 175), at 11 -- "Comb’s records related to treatment for sexual addiction."
ECF No. 175 ¶ 38 — Plaintiff’s Initial Demands for Discovery & Inspection, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 29, 2026) (NYSCEF Doc. No. 175), at 14 -- "State whether Defendants are covered by any insurance agreement"
ECF No. 140 — Notice of Motion to Stay Discovery (Sony Music Entertainment), Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 2, 2026) (NYSCEF Doc. No. 140), at 1 -- "staying any discovery of SME in this Action, pending the determination of SME’s appeal of this Court’s Decision and Order dated July 9, 2026 and entered July 22, 2026"
ECF No. 148 — Notice of Motion to Stay Discovery (Combs Defendants), Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 2, 2026) (NYSCEF Doc. No. 148), at 1 -- "staying any discovery of Defendants in this action pending resolution of Defendants’ appeal of this Court’s Decision and Order dated July 9, 2026 and entered July 22, 2026"
ECF No. 152 — Notice of Deposition of Sean Combs, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 3, 2026) (NYSCEF Doc. No. 152; Doc. No. 154 is the amended notice), at 1 -- "on October 5, 2026"
ECF No. 153 — Notice of Deposition of Sony Music Entertainment, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 3, 2026) (NYSCEF Doc. No. 153; Doc. No. 155 is the amended notice), at 1 -- "on October 8, 2026"
ECF Nos. 156-160 — Notice of Videotaped Deposition of Bad Boy Entertainment LLC, Güzel v. Combs et al., Index No. 152568/2025 (N.Y. Sup. Ct., N.Y. Cnty. Sept. 4, 2026) (NYSCEF Doc. No. 156; Doc. Nos. 157-160 are the parallel notices to the four other companies), at 2 -- "on October 8, 2026 at 10:00 a.m."

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