Howard v. Combs: Howard and Combs Jointly Ask Court to Extend Answer and Reconsideration Deadlines Until 20 Days After the Oct. 21 Hearing Transcript

In the matter of Howard v. Combs et al., No. 2:25-cv-06031 (C.D. Cal.), plaintiff Clayton Howard, who represents himself, and defendant Sean “Diddy” Combs filed a joint stipulation on Oct. 29, 2026. They ask United States District Judge Anne Hwang to move two deadlines, each now Nov. 4, 2026, to “20 days after obtaining a copy of the 10/21 Hearing transcript.” A stipulation is a written agreement between parties that asks the court to enter it as an order.

Background

Howard sued on June 30, 2025. The stipulation states that the Fifth Amended Complaint was served Aug. 3, 2026; it abbreviates that complaint “FAC.” Judge Hwang heard two motions to dismiss it on Oct. 21 and ruled from the bench, as reported in an earlier Dispatch.

The Parties’ Account of the Hearing

The stipulation states that at the hearing “all claims were dismissed from the bench with prejudice against Defendants Casandra Ventura, CeOpco, LLC f/k/a Combs Enterprises LLC and d/b/a Combs Global, and Bad Boy Entertainment LLC.” It adds that the court dismissed with prejudice, meaning without a chance to refile, Howard’s first and third causes of action against Combs, “leaving only the Second Cause of Action under 18 U.S.C. § 1595 and the Fourth Cause of Action under N.Y. Soc. Servs. Law § 483-bb, both in limited respects” (ECF No. 186 at 2).

The minutes entered Oct. 23 state that Ventura’s motion “is hereby granted, this will be the order as stated on the record,” and that the motion by Combs, Bad Boy Entertainment LLC and CeOpco, LLC is “granted in part and denied in part, with leave to amend within 14 days. Defendant Combs shall file an answer within 14 days” (ECF No. 181 at 1).

Why the Parties Ask for More Time

The stipulation states that the court “ordered Mr. Combs to respond to the FAC by November 4, 2026 (i.e., 14 days after the ruling).” It states that Combs’s counsel tried to obtain the hearing transcript the next day, that Howard also tried, and that neither has received it (ECF No. 186 at 2).

On Oct. 26, according to the stipulation, Combs moved for more time. That motion asked to extend his answer deadline “to 20 days after either (i) entry of the order on Defendants’ motions to dismiss, or (ii) alternatively, his receipt of the 10/21 Hearing transcript if no order is entered” (ECF No. 186 at 2, citing Dkt. No. 184). The stipulation states that “[t]he earliest available hearing date for the Motion was after Mr. Combs’s current deadline to answer the FAC” (ECF No. 186 at 3). It states that Combs’s counsel contacted Howard on Oct. 27 and the two sides agreed to the joint request.

What They Ask the Court to Order

Two changes. Combs’s time to answer the FAC, and both sides’ time to move for reconsideration of the order on the motions to dismiss, would each become “20 days after obtaining a copy of the 10/21 Hearing transcript” (ECF No. 186 at 4). The stipulation gives the purpose as “to evaluate the Court’s order, assess the remaining allegations in the FAC, and formulate an appropriate strategy and response to the Court’s order (in whatever form that may take)” (ECF No. 186 at 3).

The parties also state that they are prepared to meet the Nov. 4 deadlines if necessary, and that the request is without prejudice to any defense or remedy. If the order is not signed before Nov. 4, they agree that “Plaintiff shall not argue that Mr. Combs’s answer to the FAC was untimely” if the answer or any reconsideration motion is filed within the 20 days (ECF No. 186 at 3–4). A declaration from Combs’s attorney Jonathan D. Gottlieb repeats these facts and states that the stipulation “is their first request to extend Mr. Combs’s time to answer the FAC (excluding the Motion)” (ECF No. 186-1 at 4).

The Transcript Order

The same day, Combs’s counsel filed a transcript order form for the Oct. 21 hearing on behalf of Combs, CeOpco and Bad Boy Entertainment, with “3-Day” delivery (ECF No. 187). In the comments section, the form states that defendants seek the transcript to “ensure compliance with Judge Hwang’s detailed, 10/21/26 oral order,” and to “assess the specifics underlying the Subject Order in the event defendants seek to appeal the Subject Order” (ECF No. 187 at 1).

What’s Next

No order on the stipulation has been entered on the docket, and the Nov. 4 deadlines stand until the court rules. Under the stipulation, both new dates would run from the date the parties obtain the transcript, which the docket does not yet show.

Counsel and Sources

Counsel: Clayton Howard, pro se, for Plaintiff. Michael Schonbuch, Jonathan D. Gottlieb and Lilah N. Cook, Schonbuch Hallissy LLP, for Combs, Bad Boy Entertainment LLC and CeOpco, LLC. Mélodie Han and Douglas H. Wigdor, Wigdor LLP, for Cassandra Ventura. Sources: ECF Nos. 181, 186, 186-1 and 187 on the No. 2:25-cv-06031 docket.

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