Case 1:24-cv-09857 Document 1 Filed 12/20/24 Page 1 of 45

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK
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LATROYA GRAYSON, :
:
Plaintiff, : Civil Case No.:
v. :
:
: COMPLAINT
SEAN COMBS a/k/a <P. DIDDY, DIDDY, PUFF, PUFF :
DADDY, PUFFY, BROTHER LOVE=, :
BAD BOY ENTERTAINMENT HOLDINGS, INC., :
ATLANTIC RECORDS, :
MIKE SAVAS, :
DELTA AIRLINES, :
KKJAMZ 105.3FM, : JURY TRIAL DEMAND
ROGER SMITH HOTEL, and :
JOHN AND JANE DOES 1-10 :
Defendants. :
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TRIGGER WARNING:
THIS DOCUMENT CONTAINS HIGHLY GRAPHIC INFORMATION.

Plaintiff, LATROYA GRAYSON (<PLAINTIFF= or <PLAINTIFF GRAYSON= or <MS.

GRAYSON=), by and through her attorneys, hereby alleges and avers of the Defendants, SEAN

COMBS a/k/a <P. DIDDY, DIDDY, PUFF, PUFF DADDY, PUFFY, BROTHER LOVE=

(<DIDDY= or <COMBS=), BAD BOY ENTERTAINMENT HOLDINGS, INC. (<BBE=),

ATLANTIC RECORDS (<ATLANTIC=), MIKE SAVAS (<SAVAS=), DELTA AIRLINES

(<DELTA=), KJAMZ 105.3 (<KJAMZ=), ROGER SMITH HOTEL (<HOTEL=) and JOHN

AND JANE DOES 1-10 (<DOES=) (collectively referred to as <DEFENDANTS=), alleges upon

information and belief as to all other matters as follows:

PRELIMINARY STATEMENT

1. On November 16, 2023, Casandra Ventura a/k/a <Cassie= filed a 35-page lawsuit in

which she exposed Defendant Combs of subjecting her to nearly a decade of physical,

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sexual and emotional abuse punctuated by rape, sex trafficking and being forced to

engage in drug fueled nonconsensual sexual encounters with other men.

2. Ordinarily, when a lawsuit such as Ms. Ventura9s is filed that involves events that took

place long ago, witnesses are few and far between and evidence hard to muster. Not so

for the claims brought against Defendant Combs. Within minutes of the filing Ms.

Ventura9s claims were confirmed by various witnesses, including a rival musician whose

car Defendant Combs blew up, various individuals who observed Defendant Combs beat

Ms. Ventura and a video released by CNN, showing Defendant Combs physically

abusing, battering and assaulting Ms. Ventura.

3. Since Ms. Ventura9s brave decision to file a lawsuit against Defendant Combs, Defendant

Combs has accumulated numerous lawsuits across the country for the same conduct

alleged by Ms. Ventura. The number is growing and continuous in various jurisdictions

throughout the United States.

4. In September 2024, Defendant Combs was arrested in the Southern District of New York

where he is currently being held with no bond while awaiting various serious criminal

charges.1

5. Plaintiff now alleges she too is one of the many victims of Defendants Combs and the

other Defendants named herein.

6. Plaintiff can support her allegations and has suffered extreme emotional distress

impacting nearly every aspect of Plaintiff9s life and personal relationships. Given all the

brave individuals who have come forward against Defendant Combs, Plaintiff is also

doing the same.

1
United States v. Combs, U.S.D.N.Y. 24-cr-542(AS)

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7. Plaintiff brings this action seeking injunctive, declaratory and monetary relief against

Defendants in violation of the Victims of Gender-Motivated Violence Protection Law,

Gender Motivated Violence Act, N.Y.C. Admin. Code §§ 10-1101, et seq.

(<VGMVPL=), .

JURISDICTION AND VENUE

8. This Court has personal jurisdiction over the Defendants under and consistent with the

Constitutional requirements of Due Process in that the Defendants, acting directly or

through his agents or apparent agents, committed one or more of the following:

a. The transaction of any business within the state;

b. The making of any contract within the state;

c. The commission of a tortious act within this District; and

d. The ownership, use, or possession of any real estate in this state.

9. As of the date of this filing, Defendants have consistently and purposefully availed

themselves of the privilege of conducting activities within New York, thus invoking the

benefits and protections of New York law. In return for these benefits and protections,

Defendants must submit to the burdens of litigation in New York.

10. This litigation arises from or relates to the tortious activities the Defendants visited upon

Plaintiff in New York. This tortious conduct violated United States Federal Rico Laws

and other laws.

11. Requiring Defendants to litigate these claims in this District does not offend traditional

notions of fair play and substantial justice. Plaintiffs9 claims arise from conduct occurring

by Defendants in New York.

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12. This Court has jurisdiction over this action pursuant to 28 U.S.C. §1332 for original

jurisdiction over civil actions where the matter in controversy exceeds to the sum and

value of $75,000 and is between citizens of different states. This Court also has subject

matter jurisdiction under 28 U.S. Code § 1332 and supplemental jurisdiction under 28

U.S. Code § 1367 because the state law claim forms part of the same case and

controversy as the claim arising under the federal statute.

13. Pursuant to 28 U.S.C. § 1391(b), (c) and 1400(a), venue is proper in this Court because a

substantial part of the events or omissions giving rise to this action, alleged herein,

occurred in this district.

14. Plaintiff brings suit against Defendants pursuant to the NYC Gender Motivated Violence

Act, N.Y.C. Admin. Code §§ 8-901 et. seq, to redress the substantial and lifetime injuries

she has suffered.

15. This Court has personal jurisdiction over Defendants and each of them because

Defendants have purposefully directed their unlawful conduct to this judicial district and

have conducted substantial business in this judicial district.

PROCEDURAL REQUIREMENTS

THE N.Y.C. VICTIMS OF GENDER MOTIVATED VIOLENCE PROTECTION ACT

16. The N.Y.C. Victims of Gender Motivated Violence Protection Act (<NYC Gender

Motivated Violence Act=) created a lookback window on March 01, 2023, which runs for

two years, for survivors of gender motivated violence, allowing them to sue their abusers

regardless of when the abuse occurred. N.Y.C. Admin. Code § 10-1105(a).

17. The NYC Gender Motivated Violence Act revives any claims against <a party who

commits, directs, enables, participates in, or conspires in the commission of a crime of

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violence motivated by gender has a cause of action against such party in any court of

competent jurisdiction.= N.Y.C. Admin. Code § 10-1104.

18. The Appellate Division has held that sexual assault is an act of gender-motivated

violence under the law as <Coerced sexual activity is dehumanizing and fear-inducing.

Malice or ill will based on gender is apparent from the alleged commission of the act

itself. Animus inheres where consent is absent.= Breest v. Haggis, 180 A.D.3d 83, 94

(App. Div. 2019).

19. The conduct of Defendants in battering and assaulting Plaintiff constitutes a <crime of

violence= and a <crime of violence motivated by gender= against Plaintiff as well as

specifically at Defendant Combs direction, enabling, participation and conspiring in the

commission of a crime of violence motivated by gender as defined by the NYC Gender

Motivated Violence Act.

20. Given the extensive media coverage of the criminal trial brought by the Southern District

of New York and numerous civil lawsuits filed in both Federal and State against

Defendant Combs, Defendants were put on notice of the multiple allegations made

against Defendant Combs including drug trafficking, sex trafficking and racketeering.

PARTIES

DEFENDANT SEAN COMBS

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21. Defendant Combs is currently an inmate Metropolitan Detention Center in Brooklyn,

NY. Defendant Combs maintains residences in California and Florida and is believed to

be a resident of the State of California.

22. At all relevant times to the occurrences herein, Defendant Combs was a citizen and

resident of the State of New York.

23. Defendant Combs is a rapper and record executive popularly known by his stage names

Puff Daddy, Puffy, Puff, P. Diddy, Diddy, Brother Love or Love. Defendant Combs rose

to prominence in the music and entertainment industry over the decades and is regularly

referred to as a hip-hop mogul. Defendant Combs was first accused of acts described in

this complaint by his long-time paramour and former BBE artist, Cassie Ventura as

pictured above, on November 16, 2023.

24. Defendant Combs is a Grammy-awarded musician, rapper and producer.

25. Defendant Combs founded Defendant BBE.

26. In 2008, two years after the assault and battery on Plaintiff, Defendant Combs was the

first male rapper to get a star on the Hollywood Walk of Fame.

27. In 2022, Forbes estimated that Defendant Combs is one of the wealthiest hip-hop artists

in America and that his net worth is over $1 billion.

28. Upon information and belief, Defendant Combs has a long history of committing

physical and sexual violence against women and men, similarly alleged in this complaint,

as documented in publicly available in nine lawsuits across the country and extensive

media coverage.

DEFENDANT BAD BOY ENTERTAINMENT HOLDINGS, INC.

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29. Defendant Bad Boy Entertainment Holdings, Inc., is a domestic business corporation

license to do business in New York and headquartered at 1440 Broadway, Third Floor,

New York, NY 10018.

30. Defendant Bad Boy Entertainment Holdings, Inc. is a domestic business corporation

licensed to do business in New York since 1992.

31. Defendant Bad Boy Entertainment Holdings, Inc. is a music, media, and entertainment

company founded and owned by Defendant Sean Combs. Bad Boy is incorporated and

headquartered in New York, New York.

32. Defendant BBE has been named in several lawsuits where Defendant Combs has been

accused of claims of sexual abuse and sex trafficking as alleged in the instant complaint.

DEFENDANT ATLANTIC RECORDS

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33. Defendant Atlantic Recording Corporation is a domestic business corporation licensed to

do business in New York and headquartered at either 1290 Ave of Americas, New York,

NY 10104 or 1633 Broadway, New York, NY 10019.

34. Defendant Atlantic Recording Corporation is a domestic business corporation licensed to

do business in New York since 1967.

35. Defendant Atlantic Recording Corporation is a music, media, and entertainment company

incorporated and headquartered in New York, New York.

36. Defendant Atlantic was responsible for and facilitated the event that lured Plaintiff to

Defendant Combs in New York where she was injured.

DEFENDANT MIKE SAVAS

37. Defendant Savas, upon information and belief, is a citizen, resident and is domiciled in

the State of New York.

38. Defendant Savas, upon information and belief and confirmed by Defendant Savas9

LinkedIn page, was an employee of Defendant Atlantic at all relevant times.

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39. Defendant Savas, in his employment capacity with Defendant Atlantic, was responsible

for promoting, coordinating and arranging the promotional contest which was the cause

of Plaintiff9s injuries.

DEFENDANT DELTA AIRLINES

40. Defendant Delta operates an airline, license to do business in New York with its

headquarters located at 1030 Delta Blvd., Atlanta, GA 30354.

41. Defendant Delta9s ongoing relationship and participation with Defendants Combs,

Atlantic and KJAMZ was to transport potential victims to Defendant Combs, was

corrupt, exploitive to Plaintiff and to benefit Defendant Delta and other members of the

enterprise.

42. Defendant Delta, in their capacity as a common carrier, was responsible for transporting

and arranging the delivery of Plaintiff, and possibly all contest winners, to Defendants

which ultimately led to Plaintiff9s injuries.

DEFENDANT KKJAMZ 105.3

43. Defendant KJAMZ is a radio broadcast station in Oklahoma.

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44. Upon information and belief Defendant KJAMZ is an Oklahoma domestic business

corporation licensed to do business in Oklahoma since 1991.

45. Defendant KJAMZ was responsible for and facilitated the event that fraudulently enticed

Plaintiff to New York where she was injured.

DEFENDANT ROGER SMITH HOTEL

46. Defendant Roger Smith Hotel operates a hotel, license to do business in New York and

located at 501 Lexington Ave., New York, NY 10017.

47. Defendant Roger Smith Hotel9s ongoing relationship and participation with Defendants

Combs, Atlantic and KJAMZ was to provide lodging to potential victims to Defendant

Combs, was corrupt, exploitive to Plaintiff and to benefit Defendant Hotel and other

members of the enterprise.

48. Defendant Roger Smith Hotel, in their capacity as a common carrier, was responsible for

the accommodations of Plaintiff, and all contest winners, which ultimately led to

Plaintiff9s injuries.

DEFENDANTS JOHN AND JANE DOES 1-10

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49. Upon information and belief, Plaintiff alleges that Defendant Does 1 through 10,

inclusive, are other parties not yet identified who have violated Plaintiff by assaulting,

battering and threatening her, conspired, and/or aided and abetted the Defendant Combs

and the other Defendants in their participation in a corrupt organization that caused

Plaintiff9s injuries. The true names, whether corporate, individual or otherwise, of

Defendants 1 through 10, inclusive, are presently unknown to Plaintiff, which therefore

sues said Defendants by such fictitious names, and will seek leave to amend this

Complaint to show their true names and capacities when same have been ascertained,

pursuant to CPLR §1024.

50. Upon information and belief, Plaintiff believes all of the Defendant Does 1-10 are

citizens of the State of New York.

51. Upon information and belief, Plaintiff believes and thereon alleges that at all times

relevant hereto each of the Defendant l Does 1-10 were the agent, affiliate, officer,

director, manager, principal, alter-ego, and/or employee of Defendants Combs, BBE,

Atlantic, Delta, Hotel and/or KJAMZ and was at all times acting within the scope of such

agency, affiliation, alter-ego relationship and/or employment; and actively participated in

or subsequently ratified and adopted, or both, each and all of the acts or conduct alleged,

with full knowledge of all the facts and circumstances, including, but not limited to, full

knowledge of each and every violation of Plaintiff9s rights and the damages to Plaintiff9s

proximately caused thereby.

52. The limitations Article 16 of the CPLR do not apply because one or more of the

exceptions set forth in CPLR §1601 and/or §1602 apply.

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PLAINTIFF LATROYA GRAYSON

53. Plaintiff is an individual who is a citizen of the United States and a resident and

domiciled in Oklahoma.

54. Plaintiff, at all times relevant to the action, was a resident and domiciled in the State of

Oklahoma.

55. Plaintiff, at all times relevant to the action, was 23 years old.

56. Plaintiff had never traveled to New York City prior to the events described herein and

otherwise would not have traveled to New York City without being enticed by the

scheme of Defendants.

57. Plaintiff was the guest of her half sibling who won the contest on Defendant KJAMZ9s

radio station and agreed to accompany her sibling on what she believed to be legitimate

all-expenses paid trip to a Diddy <white partie= in New York in 2006 and her life has

been detrimentally impacted ever since.

FACTUAL ALLEGATIONS

The Radio Contest

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58. In late 2006, Defendant KJAMZ began promoting a contest on its radio station, 105.3

Jamz in Oklahoma sponsored by Defendants Combs, BBE, Atlantic and Delta, offering

the winner a prize of an all-expenses paid vacation for two to New York City to attend a

<Diddy White Party.=

59. At this point, Defendant Comb9s <White Parties= were legendary and ongoing as they had

begun in 1998 and were in full swing by 2006.

60. Eagerly, Plaintiff and her sibling tried to win the KJAMZ radio contest.

61. Eventually, Plaintiff9s sibling was able to win the contest.

62. The contest included round trip airfare for the winner and a guest, one hotel room in New

York and two tickets to attend Diddy9s <White Party= in New York.

63. Upon information and belief this was not a traditional <White Party= thrown by

Defendant Combs, as those typically occurred during Labor Day holiday, but a separate

promotional party.

64. Initially, the party was scheduled for October 6, 2006, but was then rescheduled without

warning or explanation. Plaintiff received an initial letter from Atlantic providing

instructions on how to attend the party and the details of the party, dated for the original

date of the <White Party.=

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65. The party was then rescheduled for October 16, 2006. Plaintiff was provided a plane

ticket, issued by Delta, for departure on October 16, 2006 from Tulsa to New York JFK

airport returning to Tulsa the next day on October 17, 2006.

66. In addition to the date of the party being rescheduled, the theme of the party was also

changed from a <White Party= to a <Black Party.=

67. Due to the change of required colored attire to attend the party, Plaintiff was forced to

purchase a new outfit that was within the new theme and dress requirements for

admittance.

68. Plaintiff and her sibling had never been to New York City and were very excited about

their trip and their attendance at a celebrity party hosted by Defendant Combs.

69. Plaintiff and her sibling rented a limousine to transport them from the airport to the hotel

in an effort to make the most of their free trip.

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70. Upon arrival in NYC, Plaintiff checked into the prearranged hotel, The Roger Smith

Hotel.

71. Plaintiff was required to pay a cash deposit to the hotel which was provided and paid by

Atlantic.

The <Black Party=

72. Plaintiff changed into her requisite black outfit and met the transportation van, arranged

by Atlantic employee Mike Savas, downstairs at the hotel.

73. Along with Plaintiff in the transportation van, arranged by Atlantic employee Mike

Savas, were several other contest winners who won the same contest in their home cities

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and were subsequently flown to New York as radio contest winners for this <Diddy Black

Party.=

74. Upon arrival at the location where the <Black Party= was thrown, Plaintiff, and the other

contest winners, were forced to wait in line for entrance into the party.

75. Plaintiff, and other contest winners, were approved for entry by security based on their

appearances and their attire. Individuals were not let into the party based on their position

in line but based on their attractiveness and attire.

76. After waiting in the line for approximately forty-five minutes, Plaintiff was finally

granted entry into the party. Even though Plaintiff was granted entry her sibling was not

and Plaintiff was separated from her sibling before realizing her sibling had not also

granted entry into the party.

77. Plaintiff did not see nor does she remember seeing her sibling at the partym during

Plaintiff9s time inside the party.

78. While inside the party, Plaintiff took pictures with some of the celebrities in attendance

including rappers Babz, from Making the Band, and Bonecrusher.

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79. At one point Plaintiff met an individual who purported to be Defendant Combs9 assistant

and he befriended Plaintiff, who was alone.

80. While at the party, there was no bar for partygoers to get drinks. Instead premade drinks

were being circulated throughout the party by waitresses.

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81. After less than two premade drinks, provided by the waitresses, Plaintiff began to feel

sick and tried to go to the restroom.

82. The next memory Plaintiff has is awaking at Saint Vincent9s Medical Center of New

York.

83. Plaintiff has no memory or no recollection on how she ended up at the hospital.

84. When Plaintiff9s regained consciousness at the hospital she noticed her shirt was ripped,

her underwear was missing, she was not wearing any shoes and the money she had

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traveled with was stolen. The only money Plaintiff had remaining was a twenty-dollar

bill.

85. Plaintiff was admitted to the Saint Vincent9s hospital, treated and released.

86. Upon her release from the hospital, Plaintiff, a tourist, had no way of knowing how to

return to her hotel as smartphones were not commonplace at the time.

87. Plaintiff remained in the waiting area of the lobby of the hospital after her release for so

long she was eventually forced out by hospital security.

88. Plaintiff was able to find a book of matches in her purse bearing the name of the hotel she

was domiciled.

89. Plaintiff then hailed a taxi and returned to the hotel using the twenty-dollar bill she had

left in her purse.

90. When Plaintiff returned to her hotel, she called a friend and explained she was not sure

what happened to her, but Plaintiff believed she was drugged, assaulted, robbed with no

memory of how she arrived at the hospital as her last memory was being at < Diddy9s

Black Party.=

91. Plaintiff had virtually no time to process or further determine what happened to her as her

flight back to Oklahoma left at 3:50pm October 17, 2024. Less than 24 hours after

Plaintiff arrived in New York City.

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92. The day after Plaintiff returned home from New York, she received a call from a new

York area code with an anonymous female caller.

93. The anonymous female caller asked to speak to Plaintiff. The anonymous female caller

then threatened Plaintiff telling her that any attempts to pursue anything about Plaintiff9s

assault would be futile because Defendant Combs was a <celebrity= and that Plaintiff

would <just be wasting her time.=

94. Plaintiff was confused and scared as she did not know what happened to her. Plaintiff

hearing from this anonymous female caller was further jarring and traumatizing as

Plaintiff learned that not only was she viciously assaulted, leading to her waking up at the

hospital, but that Defendant Combs was involved and Plaintiff would be unable to seek

justice for her injuries because of Defendant Combs celebrity status.

95. When Plaintiff tried to ask the anonymous female caller her name and how she obtained

Plaintiff9s phone number the anonymous female caller hung up.

96. When Plaintiff tried to call the number back the number was disconnected.

97. For approximately a week after Plaintiff returned home she felt constant pain in the inside

and outside of her vagina. Pain she believed was from rough intercourse, however

Plaintiff had no memory of engaging in intercourse with anyone.

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98. Plaintiff did not seek medical treatment or otherwise report her assault to law

enforcement because she was scared and confused. First, because she did not know

exactly what happened to her. Second, because of the threats she received from the

anonymous female caller of Defendant Comb9s involvement and it being a waste of time

due to his celebrity status

99. Plaintiff became severely depressed and felt shame despite not fully remembering what

happened to her.

100. Plaintiff felt betrayed by Defendants, specifically Defendants Combs, Atlantic

and KJAMZ, because she believed attending a party thrown by Defendant Combs would

be a safe environment. Plaintiff felt betrayed by Defendants Atlantic and KJAMZ

because they failed to protect her despite creating, promoting and financing a contest that

lead to her injuries and lured her to an unsafe place without warning.

101. The assault and fear after the assault led Plaintiff into a tailspin of anxiety and

depression.

102. Plaintiff was unable to maintain employment or otherwise be a productive

member of society for at least a year after her assault and battery in New York City.

103. Plaintiff believes Defendants committed the assault and battery against her solely

because of her gender.

104. Plaintiff has been reminded of her assault by Defendant Combs, as he is an

inescapable presence in music, television, and film.

105. Plaintiff has also experienced intimacy issues, struggling to maintain emotional

and romantic relationships.

106. Defendant Combs has altered the trajectory of Plaintiff9s life.

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107. To this day, Plaintiff experiences bouts of depression, anxiety, body image issues,

feelings of worthlessness, and intimacy issues because of her trauma stemming from her

assault.

108. Plaintiff feared further violence and/or retaliation from Defendant Combs in filing

this lawsuit, but since Defendant Combs has been incarcerated with no bond Plaintiff

feels safe to seek redress for her injuries.

109. Plaintiff seeks justice for herself and for any of other Defendant Combs9 victims

including the countless victims who have already filed suit against Defendant.

FIRST CAUSE OF ACTION

CONDUCT AND PARTICIPATE IN A RICO ENTERPRISE THROUGH A PATTERN
OF RACKETEERING ACTIVITY A VIOLATION OF RACKETEER INFLUENCED
ANDCORRUPT ORGANIZATION ACT, CODIFIED AT 18 U.S.C. § 1962(A), (C)-(D)
(Against ALL Defendants)

110. Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as

if set forth fully herein.

111. Defendants (<RICO orchestrators=) are 100% liable for the actions of Defendant

Combs. Defendants financially benefited through their partnership with Defendant

Combs. The RICO orchestrators provided Defendant Combs with unfettered access to

resources and failed to adequately investigate, supervise, and or monitor how those

resources were being used, who was using those resources and the purpose of use of

those resources.

112. The support provided by the RICO orchestrators to Defendant Combs was a

lifeline that spearheaded and maintained the Defendant Combs9 depraved actions. Upon

information and belief, the establishment of a business relationship with a prominent

record label, Atlantic, prominent common carriers, Delta and Roger Smith Hotel, allowed

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for a distribution platform for all Defendant Combs business endeavors to disguise his

true intentions with overly broad and vague in nature description of activities. Defendants

knew or should have known that Defendant Combs had no intention to utilize the

resources he received for business related purposes and they did not put any mechanism

in place to ensure that their resources, specifically their publication, were not being used

for any illegal activity. Defendants9 willful blindness resulted in Plaintiff suffering the

harm detailed herein.

113. Defendants are individuals and entities within the meaning of <person= as defined

in 18 U.S.C. § 1961(3) because each is capable of holding, and does hold, <a legal or

beneficial interest in property.= The RICO orchestrators association was composed of

Defendants Combs, BBE, Atlantic, Savas, Delta, KJAMZ, Hotel and Does.

114. In the relevant part, 18 U.S. Code 1961 defines a racketeering activity as:

(1) (A) any act or threat involving murder, kidnapping, gambling, arson, robbery,
bribery, extortion, dealing in obscene matter, or dealing in a controlled substance or
listed chemical (as defined in section 102 of the Controlled Substances Act), which is
chargeable under State law and punishable by imprisonment for more than one year;
(B) any act which is indictable under any of the following provisions of title 18,
United States Code: ... section 933 (relating to trafficking in firearms), section 1341
(relating to mail fraud), section 1343 (relating to wire fraud), sections 146131465
(relating to obscene matter), section 1511 (relating to the obstruction of State or
local law enforcement), sections 158131592 (relating to peonage, slavery, and
trafficking in persons), section 1952 (relating to racketeering), section 1956 (relating
to the laundering of monetary instruments), (D) any offense involving fraud
connected with a case under title 11...the felonious manufacture, importation,
receiving, concealment, buying, selling, or otherwise dealing in a controlled
substance or listed chemical.

115. Section 1962(a) makes it: unlawful for any person who has received any income

derived, directly or indirectly, from a pattern of racketeering activity or through a

collection of an unlawful debt in which such person has participated as a principal within

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the meaning of Section 2, Title18, United States Code, to use or invest, directly or

indirectly, any part of such income, or the proceeds of such income, in the acquisition of

any interest in, or the establishment or operation of, any Enterprise which is engaged in,

or the activities of which affect interstate or foreign commerce. 18 U.S.C. § 1962(a).

116. Section 1962(c) makes it: unlawful for any person employed by or associated

with any Enterprise engaged in, or the activities of which affect, interstate or foreign

commerce, to conduct or participate, directly or indirectly, in the conduct of such

Enterprise9s affairs through a pattern of racketeering activity. 18 U.S.C. §1962(c).

117. Section 1962(d) makes it: unlawful for <any person to conspire to violate=

Section 1962(a) and (c), among other provisions. 18 U.S.C. § 1962(d).

118. Defendants mentioned herein are associated with each other as an Enterprise

within the meaning of <Enterprise= as defined in 18 U.S.C. § 1961(4).

119. Plaintiff, in its pleading, has detailed acts by Defendants which are prohibited

under 18 U.S.C. §1962.

120. Defendants have unlawfully increased their profits by luring and deceiving

individuals such as Plaintiff under false pretenses for Defendants9 personal desires,

deviances and gain.

121. The RICO Enterprise activities affected interstate commerce, is comprised of an

association of persons, including each Defendant and other unnamed co-conspirators

herein. That association was structured by various agreements, deals, contracts, and non-

contractual relationships between the Defendants, by which Defendants assumed

different roles in knowingly and directly or indirectly participating in the acts necessary

to carry out the directives of the Enterprise. As detailed herein, Plaintiff was a guest of a

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contest winner who won an all-expenses paid trip to New York City to attend a <Diddy

party.= Defendant Atlantic arranged for travel of Plaintiff with Defendant Delta and

lodging accommodations with Defendant Hotel.

122. Defendant Atlantic further arranged for transportation to the party while providing

NO transportation from the party.

123. Defendants all share a common purpose: to use deception, coercion, force, and the

threat of violence to enrich themselves at the expense of individuals like the Plaintiff. As

set forth herein, although all Defendants may not have directly threatened coerced, forced

or violently threatened Plaintiff, they financially benefitted from the scheme. It is

reasonable to believe Defendants would not have engaged in these acts of threats but for

the existence of the RICO scheme and their understanding that they would have

unfettered access to engage in their illegal and corrupt Enterprise without question.

124. As evidenced in Plaintiff9s complaint herein, Defendants all orchestrated,

participated, managed, and executed the RICO Enterprise.

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125. Defendant Delta transported victims, including Plaintiff, on commercial airlines

to New York City to be a guests of the <Black Party= and/or to Defendant Combs

directly.

126. The RICO Enterprise has functioned as a continuing unit and maintains an

ascertainable structure separate and distinct from the pattern of racketeering activity.

127. This jurisdiction has criminally accused Defendant Combs of engaging in

racketeering, and both cases have similar fact patterns and descriptions of racketeering

activities.

128. Defendants disseminated their concealed scheme to Plaintiff in Oklahoma using

interstate telephone wires and radio waves.

129. The true nature of Defendants9 Enterprise was left undisclosed, was omitted,

and/or was affirmatively misrepresented, all to fraudulently increase Defendants9 profits,

at least some of which were used to expand the Enterprise, causing further injury to

Plaintiff and possibly many others.

130. Upon information and belief, Defendants profited from the Enterprise, and used

the proceeds from the Enterprise to advance the Enterprise by funding and operating their

marketing machine, including through the use of the mail, magazine coverage, word of

mouth, and interstate wires to sell the illusion that Defendant Combs was a serious and

legitimate businessman who held exclusive parties and networking events that were safe

and fun to attend, when nothing could be further from the truth.

131. Defendants Atlantic, Savas, KJAMZ, Delta and Hotel were a direct participant in

the marketing aspect of the scheme as it was Defendant Atlantic9s contest promotion

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executed by its employee, Defendant Savas, the promotions coordinator, with Defendants

Delta and Defendant Hotel providing travel and lodging.

132. Defendant KJAMZ provided the general public at large misrepresentative

information, including over interstate wireline communications systems via their radio

program on 105.3FM radio in Oklahoma.

133. Upon information and belief, Defendants obtained revenue via wire transfers,

documents, and banking transactions that were exchanged via electronic means over

interstate wires, thereby growing the Enterprise and causing further injury to Plaintiff as

described throughout.

134. Defendants9 scheme was reasonably calculated to deceive Plaintiff of ordinary

prudence and comprehension through the execution of their complex and illegal scheme

to misrepresent the true purpose of Defendant Combs9 parties and that attending those

parties would lead to assault, battery or overall danger to Plaintiff. Plaintiff would have

never engaged in any regard with Defendant Combs if not but for the complex and illegal

racketeering scheme operated by Defendants.

135. Upon information and belief, Defendants each had the specific intent to

participate in the overall RICO Enterprise scheme and each participated in the Enterprise

as follows:

a. Upon information and belief, Defendants control and participate in the activities

of the Enterprise in a variety of ways as set forth herein, including but not limited

to, developing marketing campaigns to legitimize Defendant Combs9 parties to

the general public.

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b. Upon information and belief, throughout the relevant period, Defendants

Atlantic, KJAMZ, Delta, and Hotel entered into a partnership agreement with

Defendant Combs and BBE as general business partners, each member is

responsible for the partners9 actions in the partnership. Defendants have an ethical

obligation to ensure their business partners were not using the partnership to

engage in illegal activity.

c. Defendants Atlantic, KJAMZ, Delta, and Hotel provided resources to their

general business partners, Defendants Combs and BBE. Defendants Combs and

BBE used the resources provided by their general business partners to entice the

public to desire to attend his lavish and exclusive parties. Defendants Combs and

his coconspirators, relied on the mail, world wide web and telephone to

disseminate the misleading information described herein. Defendants did not

disclose to the individuals they solicited the fact that they would be drugged,

assaulted or battered while attending events sponsored by and starring Defendants

and their business.

d. Defendants authorized the resources to their general business partner, Defendant

Combs in furtherance of the goals of their conspiracy. Defendants used the

contest promotion and party as a ruse to provide Defendants Combs and BBE

cover to disguise their covert RICO Enterprise. Throughout the relevant period,

Defendants used their collective resources relying on the mail, email, radio and

world wide web to disseminate the misleading information described herein. As

the general business partner of Defendants Combs and BBE, Defendants are

equally liable for the commission of these acts.

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e. Defendant Atlantic ensured cash payments to Plaintiff, were executed. Plaintiff

does not recall receiving appropriate United States federal tax documents for

payments or the value of the trip as if they independently declared these payments

on their taxes. It is unclear if Defendants requested an audit of Defendant Combs

business financial records to ensure the resources provided to Defendant Combs

was not being used to fund illegal activities.

136. During the ten (10) years preceding the filing of this action and to the present, all

Defendants did cooperate jointly and severally in the commission of predicate acts

itemized at 18 U.S.C. §§ 1961(1), in violation of 18 U.S.C. 1962(d), as described in this

Complaint.

137. Beginning at an exact date unknown to Plaintiff, but within ten (10) years

preceding the filing of this action, Defendants have knowingly, willfully, and unlawfully

participated in a pattern of racketeering activity that continues possibly to this day.

138. The <Racketeering Acts= followed the same pattern and purpose: to defraud the

Plaintiff for the Defendants9 benefit. Each Racketeering Act involved the same or similar

methods of commission and participants.

139. Defendants9 business would not have succeeded without the repeated predicate

acts and the ability to conduct their fraud using mail, telecommunications wires, interstate

travel, and possibly money laundering.

140. The Racketeering Acts all relate to each other in that they were part of concerted

actions by Defendants to use the endorsement and channels of the Enterprise to operate

their businesses to solicit potential victims as detailed herein.

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141. The separate Racketeering Acts all relate to each other in that they were part of

concerted actions by Defendants to use the endorsement and channels of the Enterprise to

operate their businesses to fraudulently induce Plaintiff.

142. Defendants9 wrongful conduct has injured Plaintiff and continues to threaten

Plaintiff and the public.

143. Defendants9 association with the Enterprise enabled Defendants to conduct,

direct, and control a pattern of fraudulent, illegal activities over a substantial number of

years, which continues to this day.

144. To further their collective goals, Defendants worked in concert to engage in

various forms of criminal activity at the direction and demand of Defendant Combs9.

145. Defendant9s ongoing racketeering activity has injured and continues to injure

Plaintiff.

Defendants Committed Multiple Acts of Mail Fraud in Violation of 18 U.S.C. § 1341 in

Furtherance of the Enterprise

146. Defendants voluntarily and intentionally devised and participated in a scheme

with the intent to defraud Plaintiff.

147. Defendants used the mail to execute the fraudulent scheme herein.

148. Specifically, the Defendants agreed to each of the acts of mail fraud described

throughout this Complaint. In addition, they agreed to rely on the mail to distribute their

marketing materials, contest instructions, secure wires and cash payments from other

participants in the scheme.

149. In furtherance of and for purposes of executing the above-described fraudulent

and illegal course of conduct and scheme to defraud, Defendants, either individually or in

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combination with themselves, used and caused to be used the U.S. mail by both placing

and causing to be placed, marketing materials, advertisements, agreements and other

matters in depositories and by removing, or causing to be removed, letters and other

mailable matters from depositories, in violation of the mail fraud statute, 18 U.S.C. §

1341.

150. Defendants could not have furthered their fraudulent scheme without the use of

the mail. For example, without the mail, Defendants would be unable to conduct any

business relevant to its purposed creation. Defendants also required the mail to distribute

misleading advertisements to various states, including Oklahoma. For these reasons, the

use of mail to conduct fraudulent activity was necessary and inevitable.

Defendants Committed Multiple Acts of Wire Fraud in Violation of 18 U.S.C. § 1343 in

Furtherance of the Enterprise

151. Defendants voluntarily and intentionally devised and participated in a scheme

with the intent to defraud Plaintiff.

152. Defendants agreed to each of the acts of wire fraud described herein.

Additionally, Defendants agreed to rely on interstate wires to disseminate funds to others

in the Enterprise. Defendants illegally acquired and utilized wire transfers to further their

collective goal of furthering their RICO Enterprise.

153. Defendants agreed that Defendants should facilitate these fraudulent purchases

over interstate wires in furtherance of the scheme.

154. In furtherance of and for purposes of executing the above-described fraudulent

and illegal course of conduct and scheme or artifice to defraud, Defendants, either

individually or in combination with themselves, used, or caused to be used, interstate

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wire communications to transmit or disseminate false, fraudulent, and misleading

communications and information, in violation of the wire fraud statute, 18 U.S.C. § 1343.

155. Defendants could not have furthered their fraudulent scheme without the ability

to use telecommunications to share information with clients and retailers nationwide.

Defendants needed to communicate with clients and retailers around the country, utilizing

interstate telecommunications wires to conduct the fraudulent activity. Which was

necessary and inevitable to use.

156. Plaintiff has been damaged in her business or property because Defendants

violated 18 U.S.C. § 1962(a), (c)-(d)), and, therefore, Plaintiff is entitled to recover the

damages and other remedies enumerated therein.

157. Defendants9 acts or omissions were actuated by actual malice and a willful and

wanton disregard for the consequences suffered by Plaintiff, were directed towards her

because of her gender, and with knowledge of a high degree of probability of harm to

Plaintiff and reckless indifference to the consequences of their acts or omissions.

158. Compensatory damages alone will be insufficient to deter such conduct in the

future. There needs to be a criminal referral to the United States Justice Department, as

well as to the States Attorney General9s Office.

WHEREFORE, Plaintiff requests that the Court issue an Order and grant Judgment to

the Plaintiffs as follows:

¥ Grant Plaintiff statutory, common law, and punitive damages, and applicable pre-

and post-judgment interest, in full recompense for damages;

¥ Enter judgment according to the declaratory relief sought;

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¥ Grant Plaintiff such other and further relief, including, without limitation,

injunctive and equitable relief, as the Court deems just in all the circumstances;

and

¥ Grant Plaintiff an Incentive or Service Award reflective of the work done in

prosecuting this action, the time spent, the effort and hard costs invested, and

results obtained, in light of the Court9s judgment informed by awards in other

similar cases of comparable difficulty and complexity.

SECOND CAUSE OF ACTION

ASSAULT AND BATTERY
(Against Defendants Combs and Does)

159. Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as

if set forth fully herein.

160. As set forth above, the Defendants Combs and Does did initiate nonconsensual

contact with Plaintiff; did forcibly touch Plaintiff; did drug Plaintiff without her

knowledge or consent; did intimidate and cause Plaintiff9s safety and security to feel

threatened; and did assault and sexually battery Plaintiff.

161. Defendants made offensive bodily contact with Plaintiff, constituting harmful and

offensive contact to Plaintiff9s person. Said contact was done intentionally by Defendants

and without Plaintiff9s consent or legal justification.

162. As alleged herein, Defendants acts against Plaintiff created a reasonable

apprehension in Plaintiff of immediate harmful or offensive contact to Plaintiff9s person.

Said acts were done intentionally by the Defendants and without Plaintiff9s consent or

legal justification.

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163. As alleged herein, the Defendants9 acts against Plaintiff constituted harmful and

offensive contact to Plaintiff9s person, which were done intentionally by the Defendants

without Plaintiff9s consent or legal justification.

164. As alleged herein, Defendants9 acts against Plaintiff created a reasonable

apprehension in Plaintiff of immediate harmful or offensive contact to Plaintiff9s person.

Said acts were done intentionally by Defendants without Plaintiff9s consent or legal

justification.

165. Inasmuch as each Defendant was acting for, upon, and/or in furtherance of the

enterprise, Defendants BBE and Atlantic are liable under the doctrine of respondeat

superior for the tortious actions of its Defendant actors.

166. As a result of the foregoing, Plaintiff was caused to sustain physical,

psychological and emotional injuries, pain and suffering, shame, embarrassment,

humiliation, damage to reputation, has been caused to incur pecuniary losses, and was

otherwise damaged.

THIRD CAUSE OF ACTION

NEGLIGENT HIRING, TRAINING, SUPERVISION AND RETENTION
(Defendants BBE, Atlantic, and KJAMZ)

167. Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as

if set forth fully herein.

168. The offenses alleged herein resulted, in whole or in part, due to the failure of

Defendants BBE, Atlantic and KJAMZ to employ qualified persons for positions of

authority, and/or to train and supervise the conduct of such persons during their

employment, and/or to promulgate appropriate policies and procedures either formally or

by custom properly or conscientiously.

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169. Defendants were negligent in their hiring, training, retention, supervision,

direction, control, appointment and/or promotion of their employees, agents and/or

servants, including but not limited to each of the defendants named herein.

170. Defendants knew or should have known in the exercise of reasonable care the

propensities of their employees and partners to engage in the wrongful conduct heretofore

alleged herein.

171. Defendants were negligent, careless and reckless in its screening, hiring, training,

retention, supervision, direction, control, appointment and promotion of their agents,

servants and employees in that said employees lacked the experience and ability to be

hired by said Defendant(s); in failing to exercise due care and caution in their screening,

hiring, appointment and promotion practices, and in particular, hiring individuals who

lacked the mental capacity and ability to function on behalf of said Defendants; in that

these individuals lacked the maturity, sensibility and intelligence to function on behalf of

said Defendants; in that said Defendants knew of the lack of ability, experience and

maturity of these individuals when they hired them; knew of the propensities of said

individuals to act in the belligerent, aggressive, violent and illegal manner in which they

did; in that said Defendants, their agents, servants and/or employees, failed to supervise,

train, suspend and/or terminate these individuals when such action was either proper or

required; and in being otherwise careless, negligent and reckless in the instance.

172. The failure of the Defendants to adequately train its agents, servants an employees

in the reasonable exercise of their job duties and the laws of the United States of

America, is evidence of the Defendants9 reckless lack of cautious regard for the rights of

the public in general and Plaintiff in particular, and exhibited a lack of that degree of due

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care which reasonable and prudent individuals would show under the same or similar

circumstances.

173. Defendants knew or should have known in the exercise of reasonable care, the

propensities of its agents, servants and employees to engage in the wrongful conduct

heretofore alleged in this Complaint.

174. Defendants knew or should have known that its policies, customs and practices, as

well as its negligent hiring, retention, supervision, training, appointment and promotion

of its agents, servants and employees, created an atmosphere where the most prominent

offenders felt assured that their most brazen acts of abuse, misconduct, and neglect would

not be swiftly and effectively investigated nor adverse employment action, or

prosecution, taken.

175. The mistreatment, abuses, and violations of Plaintiff9s rights, as set forth above,

were the reasonably foreseeable consequence of Defendants negligent conduct.

176. The aforesaid acts and omissions of Defendants its agents, servants and

employees, resulted in the Plaintiff9s rights being violated and her being injured.

177. As a result of the conduct complained of herein, Plaintiff suffered the damages

alleged.

178. As a result of the foregoing, Plaintiff is entitled to an award of compensatory

damages, punitive damages, and reasonable attorney9s fees, together with costs, expert

fees, and disbursements.

FOURTH CAUSE OF ACTION

NEGLIGENCE
(Against ALL Defendants)

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179. Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as

if set forth fully herein.

180. Each Defendant, inclusive of their agents, servants and employees, owed Plaintiff

a duty of care, including the duty to prevent her from being assaulted, battered, drugged

and injured.

181. Each Defendant, inclusive of their agents, servants and employees, breached their

duty of care to Plaintiff.

182. Each Defendant, inclusive of their agents, servants and employees, was negligent

in the instance in that no reasonable person under the same or similar circumstances

would have lured Plaintiff under false pretenses to be assaulted, battered, drugged and

injured.

183. Each Defendant, inclusive of their agents, servants and employees, was negligent

in the instance in that no reasonable person under the same or similar circumstances

would have caused and/or allowed Plaintiff to be drugged, assaulted and left

unconsciousness at a hospital.

184. The negligence of each Defendant, inclusive of their agents, servants and

employees, in the instance was the proximate cause of the injuries and damages suffered

by Plaintiff.

185. Inasmuch the Defendants were acting for, upon, and/or in furtherance of the

RICO enterprise and/or within the scope of their employment, Defendants BBE, Atlantic

and KJAMZ are liable under the doctrine of respondeat superior for the tortious actions

of same.

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186. As a result of the conduct complained of herein, Plaintiff suffered the damages

alleged.

187. As a result of the foregoing, Plaintiff is entitled to an award of compensatory

damages, punitive damages, and reasonable attorney9s fees, together with costs, expert

fees, and disbursements.

FIFTH CAUSE OF ACTION

THE NYC VICTIMS OF GENDER-MOTIVATED VIOLENCE PROTECTION ACT
(Against ALL Defendants)

188. Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as

if set forth fully herein.

189. The NYC Gender Motivated Violence Act revives any claims against <a party

who commits, directs, enables, participates in, or conspires in the commission of a crime

of violence motivated by gender has a cause of action against such party in any court of

competent jurisdiction.= N.Y.C. Admin. Code § 10-1104.

190. The herein described conduct of Defendants included forcibly drugging and

assaulting Plaintiff at a party thrown for radio contest winners, constitutes a <crime of

violence= against Plaintiff and is a <crime of violence motivated by gender= as defined in

N.Y. C. Admin Code § 10-1103. (<The term 8crime of violence9 means an act or series of

acts that would constitute a misdemeanor or felony against the person as defined in state

or federal law or that would constitute a misdemeanor or felony against property as

defined in state or federal law if the conduct presents a serious risk of physical injury to

another, whether or not those acts have actually resulted in criminal charges, prosecution,

or conviction,= and <The term 8crime of violence motivated by gender9 means a crime of

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violence committed because of gender or on the basis of gender, and due, at least in part,

to an animus based on the victim9s gender.=).

191. Pursuant to § 10-1105(a), this cause of action is timely because it is commenced

within <two years and six months after September 1, 2022.=

192. Defendants9 crimes of violence were motivated by Plaintiff9s gender as defined in

in the New York City Administrative Code § 8-903, as either Defendant Combs or Does

committed forcible sex acts upon Plaintiff that would constitute felonies under state law

and as the conduct presents a serious risk of physical injury, whether or not those acts

have resulted in criminal charges, prosecution, or conviction.

193. The Appellate Division has held that sexual assault is an act of gender-motivated

violence under the law as <Coerced sexual activity is dehumanizing and fear-inducing.

Malice or ill will based on gender is apparent from the alleged commission of the act

itself. Animus inheres where consent is absent.= Breest v. Haggis, 180 A.D.3d 83, 94

(App. Div. 2019).

194. The described conduct herein of Defendants Combs and/or Does constitutes

sexual offenses as defined in Article 130 of the New York Penal Law.

195. Plaintiff is a woman, who is older than 18, who alleges misdemeanor and/or

felony penal law violations, including but not limited to sexual misconduct (N.Y. Penal

L. § 130.20), criminal sexual act in the first degree (N.Y. Penal L. § 130.50), criminal

sexual act in the third degree ( N.Y. Penal L. § 130.40), forcible touching (N.Y. Penal L.

§ 130.52), sexual abuse in the first degree (N.Y. Penal L. § 130.65), and sexual abuse in

the second degree ((N.Y. Penal L. § 130.60).

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196. Defendants Combs and/or Does drugged Plaintiff and engaged in sex acts with

her unconscious person, whereas Plaintiff could not refusal or be an unwilling participant.

197. Defendant Combs demanded Plaintiff drink laced alcohol while a guest at his

party as there was no other option for refreshments other than the ones provided by the

waitresses at the party. Thus, Defendant Combs knew or should have known that Plaintiff

was incapable of consenting to sexual contact and/or sexual conduct.

198. Defendants9 actions presented a serious risk of physical injury to Plaintiff9s

person, regardless of whether or not those acts resulted in criminal charges, prosecution

or conviction.

199. Furthermore, Defendants BBE, Atlantic, Savas, Delta, KJAMZ, Hotel and Does

enabled Defendant Combs9 commission of the crimes of violence motivated by gender,

and thus, are liable under the NYC Victims of Gender-Motivated Protection Act.

200. Defendants enabled or participated in the assault, battery and drugging of Plaintiff

because Defendants failed to, among other things, (1) protect Plaintiff from a known

danger; (2) have sufficient policies and procedures in place to prevent sexual assault; (3)

properly implement policies and procedures to prevent sexual assault; (4) take reasonable

measures to ensure that policies to prevent sexual assault were working; (5) train their

employees on identifying sexual assault and inappropriate workplace behaviors; (6)

protect their employees from sexual assault; and (7) adhere to the applicable standard of

care.

201. Defendants enabled or participated in the assault, battery and drugging of Plaintiff

because Defendants failed to timely and properly educate, train, supervise, and/or

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monitor their agents or employees regarding policies and procedures that should be

followed when assaults are suspected or observed.

202. Defendants knew, or should have known, that Defendant Combs was not fit to be

in a position of authority. Defendants, by and through their agents, servants and/or

employees, became aware, or should have become aware of Defendant Combs9

propensity to commit sexual assault and of the risk to Plaintiff9s safety. At the very least,

Defendants knew, or should have known, that they did not have sufficient information

about whether or not their leaders, managers, and people were safe to be in positions of

power.

203. Defendants knew, or should have known, that Defendant Combs posed a risk of

sexual violence, assault, harassment and battery.

204. Defendants failed to properly supervise Defendant Combs and protect Plaintiff

from a known danger, and thereby enabled Defendant Combs9 assault of Plaintiff.

205. Defendants negligently deemed that Defendant Combs was fit to be in a position

of authority; and/or that any previous suitability problems Defendant Combs had were

fixed and cured; and/or that Defendant Combs would not commit acts of sexual assault,

battery, harassment or trafficking; and/or that Defendant Combs would not injure others.

206. Moreover, Defendants Atlantic, Savas, Delta and KJAMZ facilitated the

trafficking and assault of Plaintiff by actively maintaining and employing Defendant

Combs in a position of power and authority through which Combs had control over

people, including Plaintiff.

207. As a direct and proximate result of the aforementioned crime of violence and

gender- motivated violence, Plaintiff has sustained and will continue to sustain, monetary

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damages, physical injury, pain and suffering, and serious psychological and emotional

distress, entitling her to an award of compensatory and punitive damages, injunctive and

declaratory relief, attorneys9 fees and costs, and other remedies as this Court may deem

appropriate damages, as set forth in § 10-1104.

WHEREFORE, Plaintiff respectfully requests a judgment against the Defendants that:

¥ Declares Defendant Combs engaged in unlawful practices prohibited by the New York

City Victims of Gender-Motivated Violence Protection Act, in that Combs drugged,

assaulted and battered Plaintiff;

¥ Declares that Defendants BBE, Atlantic, Savas, Delta, KJAMZ, Hotel and Does engaged

in unlawful practices prohibited by the New York City Victims of Gender-Motivated

Violence Protection Act, in that they enabled Defendant Combs9 commission of the

crimes of violence motivated by gender;

¥ Awards Plaintiff compensatory damages for mental, and emotional injury, distress, pain

and suffering and injury to her reputation, consequential damages, lost wages, earning,

and all other sums of money, together with interest on these amounts in an amount to be

proven;

¥ Awards Plaintiff damages against Defendants joint and severally;

¥ Awards Plaintiff punitive and exemplary damages according to proof;

¥ Awards Plaintiff attorneys9 fees, costs, and expenses incurred in the pursuance of this

action;

¥ Awards prejudgment and post-judgment interest; and

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¥ Awards Plaintiff such other and further relief as the Court may deem equitable and

proper.

SIXTH CAUSE OF ACTION

NEGLIGENT INFLICTION of EMOTIONAL DISTRESS
(Against ALL Defendants )

208. Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as

if set forth fully herein.

209. Defendants created an unreasonable risk of causing emotional distress to Plaintiff,

and Defendants knew or should have known that such conduct was likely to result in

emotional distress that might and/or likely would cause illness or bodily harm.

210. Plaintiff9s emotional distress was foreseeable to Defendants.

211. As a direct and proximate result of the negligent conduct of Defendants,

specifically Defendant Combs and/or Does, Plaintiff suffered and will continue to suffer

severe emotional distress.

212. Defendants conduct was wanton, malicious, willful, and/or cruel, entitling the

Plaintiff to punitive damages.

SEVENTH CAUSE OF ACTION

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
(Against ALL Defendants)

213. Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as

if set forth fully herein.

214. Defendants engaged in conduct toward Plaintiff that is extreme and outrageous to

exceed the bounds of decency in a civilized society, namely by, inter alia, subjecting her

to sexual assault, battery and misconduct.

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215. The sexual assault, battery and misconduct by Defendants were extreme and

outrageous conduct that shocks the conscience.

216. These actions were taken with the intent to cause or disregard for the substantial

probability of causing severe emotional distress.

217. As a direct and proximate result of Defendants9 extreme and outrageous conduct,

Plaintiff has suffered severe emotional distress.

218. Defendants conduct, specifically Defendant Combs, was wanton, malicious,

willful, and/or cruel, entitling the Plaintiff to punitive damages.

FINAL PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays for all of the relief enumerated and sought within this complaint.

JURY DEMAND

Plaintiff hereby demands a trial by jury on all issues of fact and damages stated herein, so

triable, pursuant to Fed. R. Civ. P. 38 and the 7th Amendment to the United States Constitution.

Respectfully Submitted,

Dated: December 20
17, 2024 By:/s/ Ariel E. Mitchell, Esq.
Ariel E. Mitchell, Esq.
The Law Office of Ariel E. Mitchell, P.A.
500 NW 2nd Ave. #12864
Miami, FL 33103
305-903-5835
ariel@arielesq.com
Attorney for Plaintiff
(pro hac vice motion pending)

By:/s/ Steven A. Metcalf, II, Esq.

Steven A. Metcalf, II, Esq.
METCALF & METCALF
99 Park Ave., Suite 110

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New York, NY 10004

646-253-0514
Attorney for Plaintiff
(Co-counsel/local counsel)

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