DiddyDocket Dispatch
Louis Reed v. Sean Combs et al. + 2 related cases
New York Supreme Court No. 161676/2024 Justice Arlene P. Bluth
Oct 15, 2026

Reed v. Combs: Combs Served at Fort Dix as Sher Tremonte’s Withdrawal Motion Goes Before Justice Bluth

N.Y. Sup. Ct., N.Y. County · Index Nos. 161676/2024, 161674/2024, 161671/2024 · Mot. Seq. 004 · Return Date Oct. 14, 2026

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Sher Tremonte LLP’s motion to withdraw as counsel for Sean “Diddy” Combs reached its Oct. 14, 2026 return date in three related New York County cases before Justice Arlene P. Bluth: Reed v. Combs (Index No. 161676/2024), Dunn v. Combs (161674/2024) and Taylor v. Combs et al. (161671/2024). A report from the Burlington County, N.J., Sheriff states that Combs was personally served with the order to show cause at FCI Fort Dix on Oct. 2. On Oct. 14 the firm also filed Judge Valerie Caproni’s Oct. 13 decision in Kelly v. Combs as supplemental authority. The dockets show no opposition papers and no ruling. Filings are cited from Reed, the lead case; the other two carry the same filings on the same dates.

The Motion

Sher Tremonte filed the application on Sept. 15 as a proposed order to show cause. In a supporting affirmation, partner Michael Tremonte asks the court under CPLR 321(b)(2) to relieve four of the firm’s lawyers — Mark Cuccaro, Michael Tremonte, Erica Wolff and Raphael Friedman — and to stay all deadlines for 30 days so Combs can find new counsel. The affirmation names the dates a stay would touch: Oct. 30, 2026 to serve discovery demands, Nov. 30 to respond, and May 31, 2027 for depositions. (NYSCEF Doc. No. 75 at 1.)

The firm gives two grounds, in its own words. It says 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” with him, adding that he “has declined to make himself available for timely, substantive, and direct communications about his cases for over four months.” (Id. at 2.) It says it warned Combs by mail, and his power of attorney by email, on Sept. 3 and again on Sept. 11; that it made no earlier application to withdraw; and that it is “prepared to provide additional details to the Court,” in camera or otherwise, if asked. (Id. at 3.) The affirmation states no dollar amount.

In Taylor the firm represents Combs and four companies — Bad Boy Entertainment Holdings, Inc., Bad Boy Entertainment LLC, Bad Boy Productions Holdings, Inc. and Daddy’s House Recordings Inc. — and the motion is made for all five. (Taylor, NYSCEF Doc. No. 78 at 1.)

The Order to Show Cause

Justice Bluth signed the order on Sept. 17, with handwritten changes to the proposed form. As signed, the return date is Oct. 14 “on submission only”; answering papers were due Oct. 13; and Combs was to be served personally on or before Sept. 30. The “oral argument directed” stamp and the paragraph for reply papers are struck out. (NYSCEF Doc. No. 76 at 1–2.)

Service at Fort Dix

On Sept. 30, the service deadline, Combs’s lawyers wrote to the court. They said they had mailed Combs the order and the underlying papers on Sept. 24, so he has “actual notice.” But a process server who tried Fort Dix that day, they wrote, “was informed that under the facility’s latest policies, only the Burlington County Sheriff’s Department can serve inmates,” and the Sheriff’s Department then said it “will not be able to complete service by September 30, 2026.” The firm asked for more time and said it would file an affidavit of service once service was made. (NYSCEF Doc. No. 77 at 1.)

No order on that request appears on the docket. On Oct. 13 the firm filed a Burlington County Sheriff’s Report of Service. It records personal service on Combs at the Fort Dix address on Oct. 2, 2026, at 9:55 a.m., of the order to show cause and Michael Tremonte’s affirmation. (NYSCEF Doc. No. 79.) That is two days after the date in the signed order. The record does not say whether the court treats the Oct. 2 service as timely.

The Supplemental Authority

On Oct. 14 the firm filed a letter in each case, signed by Cuccaro, bringing “Judge Caproni’s October 13, 2026 decision in Kelly v. Combs” to the court’s attention “as supplemental authority in further support” of the motion, with the decision attached. The letter says the federal court “granted Sher Tremonte’s motion to withdraw as counsel in a similar matter involving Defendant Combs,” granted a retaining lien “pending submission of supporting documentation,” and agreed that lack of payment and the breakdown in the relationship “are sufficient to justify Sher Tremonte’s withdrawal from this matter.” (NYSCEF Doc. No. 80 at 1.)

The Kelly ruling was made under the Southern District’s Local Civil Rule 1.4 (see the earlier Dispatch). The state motions rely on CPLR 321(b)(2) and the New York Rules of Professional Conduct.

What Is Not Decided

Justice Bluth has not ruled. The dockets show no papers from the plaintiffs or from anyone else opposing the motion, and no decision on the requested 30-day stay. The filings do not say who would represent Combs or the four companies if the motion is granted. Sher Tremonte has also sought to withdraw in appeals before the Appellate Division, First Department (see this earlier Dispatch).

Sources

Source: NYSCEF Doc. Nos. 75–77, 79 and 80 on the Reed v. Combs docket, and the matching filings on the Dunn v. Combs and Taylor v. Combs dockets. The firm’s statements about fees and communication are its own and are not findings.

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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