Match found in file: ./text/2024-02-28_Diddy-v-Jones-sexual-assault-complaint(73p)_ocr.txt

Line 34:           SEXUAL NATURE, INCLUDING SEXUAL ASSAULT. ADDITIONALLY,
Line 35:         THERE ARE GRAPHIC IMAGES OF THE AFTERMATH OF A SHOOTING,
Line 36:        REDACTED IMAGES OF SEXUAL INTERCOURSE, REDACTED IMAGES OF
Line 37:             MINORS, SEX WORKERS, AND PROSTITUTES, DETAILS OF SEX
Line 38:        TRAFFICKING, AND THE ILLEGAL DISTRIBUTION OF GUNS, AND DRUGS
Line 39: 
Line 40: 

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Line 240: 
Line 241: 
Line 242: 
Line 243:            c. Mr. Combs providing laced alcoholic beverages to minors and sex workers at his
Line 244:                homes in California, New York, the U. S. Virgin Islands1, and Florida,
Line 245:            d. Mr. Combs Chief of Staff, Kristina Khorram (“KK”) instructing her staff to retrieve
Line 246:                drugs so she can provide it to Mr. Combs for his consumption,

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Line 578: 
Line 579: 
Line 580:      MR. COMBS AND J. COMBS SOLICITS, DRUGS AND ENGAGES IN ILLICIT SEX
Line 581:                           ACTS WITH MINORS AND SEX WORKERS
Line 582:     98. On or about July 2, 2023, in California, Mr. Combs had a "listening party" at his home.
Line 583:     99. Present at this party was a R&B artist9 (REDACTED), J. Combs, sex workers, and some
Line 584:        underaged girls.

Match found in file: ./text/2024-02-28_Diddy-v-Jones-sexual-assault-complaint(73p)_ocr.txt

Line 967:         Shyne.
Line 968:  165. Defendants executed their RICO Enterprise with threats of isolation from the music and
Line 969:         entertainment industry: parading powerful music industry executives such as Defendants
Line 970:         Lucian Charles Grainge, Ethiopia Habtemariam at his parties filled with sex workers, minors,
Line 971:         and illegal drugs, such as ecstasy, cocaine, GHB, ketamine, marijuana, and mushrooms.
Line 972:  166. Defendants executed their RICO Enterprise with threats of nonpayment for work
Line 973:         completed, fake promises of cash payments ($250,000), producer of the year Grammy awards,

Match found in file: ./text/2024-02-28_Diddy-v-Jones-sexual-assault-complaint(73p)_ocr.txt

Line 1070:    “enterprise” as defined in 18 U.S.C. § 1961(4).
Line 1071: 180. Defendants have unlawfully increased their profits by luring, and deceiving producers,
Line 1072:    musicians, writers, creators, and artists such as Plaintiff to transport drugs (ecstasy, cocaine,
Line 1073:    GHB, ketamine, marijuana, and mushrooms), transport firearms, solicit minors, exotic
Line 1074:    dancers, sex workers, and to utilize their talents and labor to produce music, and other tangible
Line 1075:    goods and services without compensation.
Line 1076: 181. The RICO enterprise, which all Defendants have engaged in, and the activities of which

Match found in file: ./text/2024-02-28_Diddy-v-Jones-sexual-assault-complaint(73p)_ocr.txt

Line 1078:    including each Defendant and other unnamed co-conspirators. That association, in fact, was
Line 1079:    structured by various contracts and non-contractual relationships between the Defendants, by
Line 1080:    which Defendants assumed different roles in agreeing to carry out a mail and wire fraud
Line 1081:    scheme to acquire drugs, firearms, prostitutes, minors, sex workers and the labor of producers,
Line 1082:    musicians, writers, creators, and artists such as Plaintiff to utilize their talents and labor to
Line 1083:    produce music, and other tangible goods and services without compensation.
Line 1084: 182. The members of the RICO enterprise all share a common purpose: to enrich themselves

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Line 1090:    about murdering people, and bragging about bribing witnesses, and jurors in the criminal case
Line 1091:    concerning the 1999 NYC nightclub shooting with Shyne), threats of isolation from the music
Line 1092:    and entertainment industry (parading powerful music industry executives such as Defendants
Line 1093:    Lucian Charles Grainge, Ethiopia Habtemariam at his parties filled with sex workers, minors,
Line 1094:    and illegal drugs, such as ecstasy, cocaine, GHB, ketamine, marijuana, and mushrooms),
Line 1095:    threats of nonpayment for work completed, fake promises of cash payments ($250,000),
Line 1096:    producer of the year Grammy awards, and guaranteed access to future projects, a $20 million

Match found in file: ./text/2024-02-28_Diddy-v-Jones-sexual-assault-complaint(73p)_ocr.txt

Line 1152:    participated, managed and executed the RICO Enterprise by purchasing and distributing
Line 1153:    ecstasy, cocaine, GHB, ketamine, marijuana, and mushrooms, by purchase and distributing
Line 1154:    firearms, by requiring the solicitation of sexual encounters with prostitutes, sex workers, and
Line 1155:    minors, and by forcing artists, creatives, musicians, and producers to utilize their talents and
Line 1156:    labor to produce music, and other tangible goods and services without compensation. The
Line 1157:    RICO enterprise has functioned as a continuing unit and maintains an ascertainable structure
Line 1158:    separate and distinct from the pattern of racketeering activity.

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Line 1162:    creatives, musicians, and producers. These false representations and omissions were designed
Line 1163:    to induce Defendants' artists, creatives, musicians, and producers to utilize their talents and
Line 1164:    labor to produce music and other tangible goods and services without compensation, as well
Line 1165:    as the solicitation of sexual encounters with prostitutes, sex workers, and minors, and the
Line 1166:    purchasing and distribution of illegal firearms and drugs.
Line 1167: 188.   As part of this scheme, Defendants required their artists, creatives, musicians, and
Line 1168:    producers to visit strip clubs wearing exclusive authentic Bad Boy merchandise and to use the

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Line 1199:    provided their artists, creatives, musicians, and producers with this misrepresentative
Line 1200:    information, including via email all over interstate wireline communications systems and
Line 1201:    obtaining free labor, the distribution of drugs and firearms, as well as prostitutes, sex workers,
Line 1202:    and minors.    Defendants obtained revenue via wire transfers, documents, and banking
Line 1203:    transactions that were exchanged via electronic means over interstate wires, thereby growing
Line 1204:    the enterprise and causing further injury to Plaintiff Jones as described throughout.
Line 1205: 191. The Defendants’ scheme was reasonably calculated to deceive Plaintiff Jones, artists,

Match found in file: ./text/2024-02-28_Diddy-v-Jones-sexual-assault-complaint(73p)_ocr.txt

Line 1205: 191. The Defendants’ scheme was reasonably calculated to deceive Plaintiff Jones, artists,
Line 1206:    creatives, musicians, and producers of ordinary prudence and comprehension through the
Line 1207:    execution of their complex and illegal scheme to misrepresent the effectiveness of soliciting
Line 1208:    prostitutes, sex workers, and minors and distributing drugs and guns that did not, would not,
Line 1209:    and could not lead to securing Grammy Awards, purchasing $20 million homes, participating
Line 1210:    on future projects, $250,000 cash payments, and meeting influential music industry
Line 1211:    executives such as Defendants Lucian Charles Grainge, and Ethiopia Habtemariam. Plaintiff

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Line 1252:    interstate wires to solicit Plaintiff Jones and artists, creatives, musicians, and producers, and
Line 1253:    to use Plaintiff Jones and the artists, creatives, musicians, and producers to utilize their talents
Line 1254:    and labor to produce music, and other tangible goods and services without compensation, as
Line 1255:    well as the solicitation of sexual encounters with prostitutes, sex workers, and minors, and the
Line 1256:    purchasing and distribution of illegal firearms and drugs. Each of these acts was undertaken
Line 1257: 
Line 1258: 

Match found in file: ./text/2024-02-28_Diddy-v-Jones-sexual-assault-complaint(73p)_ocr.txt

Line 1279:    messages, and WhatsApp messages to distribute, interstate wires to disseminate the
Line 1280:    misleading information described herein as well as to receive profits from the artists,
Line 1281:    creatives, musicians, and producers from their forced solicitation of sex workers, and the
Line 1282:    solicitation of sexual encounters with prostitutes, sex workers, and minors, and the purchasing
Line 1283:    and distribution of illegal firearms and drugs. Each of these acts was undertaken with the
Line 1284:    knowledge and approval of all other Defendants in furtherance of the goals of their conspiracy.
Line 1285: 197. Robin Greenhill, the accountant, would ensure the wiring, funds transfer, or cash payments

Match found in file: ./text/2024-02-28_Diddy-v-Jones-sexual-assault-complaint(73p)_ocr.txt

Line 1315:    businesses to fraudulently induce Plaintiff Jones and the artists, creatives, musicians, and
Line 1316:    producers to utilize their talents and labor to produce music, and other tangible goods and
Line 1317:    services without compensation, as well as the solicitation of and sexual encounters with
Line 1318:    prostitutes, sex workers, and minors, and the purchasing and distribution of illegal firearms
Line 1319:    and drugs.
Line 1320: 203. The separate Racketeering Acts all relate to each other in that they were part of concerted
Line 1321:    actions by Defendants to use the endorsement and channels of the enterprise to operate their

Match found in file: ./text/2024-02-28_Diddy-v-Jones-sexual-assault-complaint(73p)_ocr.txt

Line 1322:    businesses to fraudulently induce Plaintiff Jones and the artists, creatives, musicians, and
Line 1323:    producers to utilize their talents and labor to produce music, and other tangible goods and
Line 1324:    services without compensation, as well as the solicitation of and sexual encounters with
Line 1325:    prostitutes, sex workers, and minors, and the purchasing and distribution of illegal firearms
Line 1326:    and drugs.
Line 1327: 204. The Defendants’ wrongful conduct has caused injury to Plaintiff Jones, remains a part of
Line 1328:    their ongoing business practices, and remains a continuing threat to Plaintiff Jones and the

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Line 1332:    continues to this day.
Line 1333: 206. To further their goals, Defendants, working in concert, engaged in various forms of
Line 1334:    criminal activity, including the solicitation of and sexual encounters with prostitutes, sex
Line 1335:    workers, and minors, and the purchasing and distribution of illegal firearms and drugs.
Line 1336: 207. Defendants’ ongoing pattern of racketeering activity has injured and continues to injure
Line 1337:    Plaintiff Jones. The Defendants’ pattern of forcing Plaintiff Jones and the artists, creatives,
Line 1338: 

Match found in file: ./text/2024-02-28_Diddy-v-Jones-sexual-assault-complaint(73p)_ocr.txt

Line 1345: 
Line 1346: 
Line 1347:     musicians, and producers to solicit sexual encounters with prostitutes, sex workers, and
Line 1348:     minors, and to purchase and distribute illegal firearms and drugs was the proximate cause of
Line 1349:     the injuries suffered by Plaintiff.
Line 1350: Defendants Committed Multiple Acts of Mail Fraud in Violation of 18 U.S.C. § 1341 in
Line 1351: Furtherance of the Enterprise

Match found in file: ./text/2024-02-28_Diddy-v-Jones-sexual-assault-complaint(73p)_ocr.txt

Line 2055:    to coerce Plaintiff Jones to engage in commercial sex acts. The cash directly formed part of
Line 2056:    the commercial nature of the sex acts. The cash was also a necessary and required part of Mr.
Line 2057:    Combs’ recruitment of Plaintiff Jones, as well as other sex workers, prostitutes and underage
Line 2058:    minors. By providing cash that Defendants Lucian Charles Grainge, Ethiopia Habtemariam,
Line 2059:    Motown Records, Love Records, and Universal Music Group knew would be used to fund
Line 2060:    the sex trafficking venture, Defendants Lucian Charles Grainge, Ethiopia Habtemariam,
Line 2061:    Motown Records, Love Records, and Universal Music Group actively participated in the

Match found in file: ./text/2024-02-28_Diddy-v-Jones-sexual-assault-complaint(73p)_ocr.txt

Line 2243:    knowledge that it was participating in Combs’ sex trafficking venture. Defendants
Line 2244:    Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Love Records, and
Line 2245:    Universal Music Group also had constructive knowledge that Plaintiff James, and
Line 2246:    other underaged minors were being coercively sex trafficked by Combs. Its
Line 2247:    constructive knowledge extended to the names of Combs’ victims, because Combs
Line 2248:    and his associates knew the names of the victims. Mr. Combs had hundreds of cameras
Line 2249:    in his homes in LA, NYC, and Miami. Mr. Combs required the sex workers, and

Match found in file: ./text/2024-02-28_Diddy-v-Jones-sexual-assault-complaint(73p)_ocr.txt

Line 2463: 
Line 2464: 
Line 2465:    (and unnamed “associates”) for violating the TVPA. Later, on about June 29, 2020, the same
Line 2466:    Office indicted Epstein’s co-conspirator, Ghislaine Maxwell, for conspiracy to entice minor
Line 2467:    victims to travel to be abused by Epstein. Mr. Combs, Defendants J. Combs, Khorram and
Line 2468:    her direct reports: Brendan Paul, Frankie Santella, and Moy Baun all engaged in the same
Line 2469:    activities as Mr. Epstein and Ms. Maxwell. In fact, Mr. Combs, Defendants J. Combs,