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Speaker 1: What's up everyone, and welcome back to the program. This episode,

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we're getting back to the Cassie Ventura paperwork where she

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accuses puff Daddy of all sorts of abuse. Section number six.

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Miss Ventura tries to escape mister Colmb's abuse one oh four.

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Anytime she tried to create distance between her and mister Combs,

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he used his networks to find her and convince her

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to return to his abuse. One oh five. On multiple occasions,

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mister Combs sent his employees to learn Miss Ventura back

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one O six. In twenty eleven, during a rough patch

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in mister Colmbs and Miss Ventura's relationship, Miss Ventura had

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a brief relationship with musician Kid Cuddy one oh seven.

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When mister Combs returned from a trip, he demanded another

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FO of Miss Ventura and she acquiesced one o eight.

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During the FO, mister Combs found Miss Ventura's phone and

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found emails between her and Kid Cuddy. Mister Combs became

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enraged and proceeded to place annual corkscrew between his fingers

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and lunge at Miss Ventura. One oh nine. Miss Ventura

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ran away to stay at Kid Cutty's home to escape

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mister Combs's wrath. Soon thereafter, one of mister combs staff

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members told Miss Ventura that he needed to just talk

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to mister Combs, even though mister Combs was enraged. One ten,

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feeling like she could not escape mister Combs and his

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network of enforcers, miss Ventura returned to mister Colmbs. He

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hit her several times and then kicked her in the

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back as she tried to run out the door. One eleven,

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she went to her parents' home in Connecticut, where her

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mother took pictures of the bruises mister Combs had left

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on Miss Ventura's body. One twelve. In February twenty twelve,

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during Paris Fashion Week, mister Combs told Miss Ventura that

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he was going to blow up Kid Cutty's car and

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that he wanted to ensure that Kid Cutty was home

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with his friends When it happened. Around that time, Kid

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Cutty's car exploded in his driveway. One thirteen, Miss Ventura

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was terrified, and she again to fully comprehend what mister

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Combs was both willing and able to do to those

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he believed it slighted him. One fourteen. In two thousand

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and five, miss Ventura spoke to a popular music manager

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at an after party in a hotel sweet in Las Vegas.

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Mister Colmbs saw her speaking to this manager and sternly

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told her to step into the bedroom adjoining the suite.

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In the bedroom, mister Colmbs beat Miss Ventura severely. He

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ran from corner to corner of the room trying to

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avoid mister Colmbs beating and kicking. When she tried to

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lock herself in the bathroom, he pushed through and punched

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and kicked her while she crawled up under the toilet.

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Her screams were drowned out by the loud music playing

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in the outside area of the hotel suite one fifteen.

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When mister Colmbs had of security and assistant saw Miss

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Ventura after the assault, they began to cry. Miss Ventura

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had two black eyes, a burst and bruised lip, and

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a huge welt on her forehead. One sixteen. Upon seeing

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the result of his vicious attack, mister Combs immediately took

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steps to conceal his wrongdoing. One seventeen, he forced Miss

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Ventura to stay at his home in Holmby Hills along

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with one of his sons. While there, mister Combs facetimed

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Miss Ventura and stated, you gotta go up and put

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more makeup on. My son can't see you like that.

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One eighteen, she did put makeup on per mister colmbs demands.

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Miss Ventura felt that she had no choice but to

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obey her abuser. Even though security guards, assistants, and friends

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saw the situation she was in, no one dared to

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help her or speak up on her behalf. She therefore

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had no choice but to remain subservient. One nineteen later,

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in twenty fifteen, while shooting a movie in Cape Town,

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South Africa, Miss Ventura began a flirtatious relationship with an actor.

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She spent New Year's Eve with this actor, but mister

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Combs soon found out. Mister Combs called the actor and

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threatened them. The actor proceeded to call Miss Ventura and

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tell her, you really need to call mister Combs. Twenty

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In or around March twenty sixteen, during an fo at

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the Intercontinental Hotel in Century City, Los Angeles, mister Colmbs

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began extremely intoxicated and punched Miss Ventura in the face,

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giving her a black eye. One twenty one, after she

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fell asleep, Miss Ventura tried to leave the hotel room

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but as she exited, mister Combs awoke and began screaming

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at Miss Ventura. He followed her into the hallway of

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the hotel while yelling at her. He grabbed at her,

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then took a glass boss in the hallway and threw

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him at her, causing glass to crash around them. As

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she ran to the elevator to escape one twenty two,

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she managed to get into the elevator and when she

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got to the lobby, quickly took a cab to her apartment.

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Upon realizing that her running away would cause mister Colmbs

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to be even more angry or with her and completely

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stuck in his vicious cycle of abuse, miss Ventura returned

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to the hotel with the intention of apologizing for running

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away from her abuser. When she returned, hotel security staff

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urged her to go back into a cab and back

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to her apartment, suggesting that they had seen the security

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footage showing mister Combs beating Miss Ventura and throwing a

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glass at her in the hotel hallway one twenty three.

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Upon information and belief, mister Combs paid the Intercontinental Century

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City fifty g's for the hallway security footage from that

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evening one twenty four. After this, Miss Ventura left her

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home in Comstock and went to hide away at a

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friend's home in Florida. James Cruz, president of bad Boy Management,

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tracked Miss Ventura down and told her that her single

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would not be released if she did not answer mister

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Combs's phone calls. One twenty five. A woman who worked

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at Sony Music reached out to her with a similar

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ultimatum concerning her record one twenty six. Incredibly, mister Combs

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even convinced one of his attorneys to call Miss Ventura

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at this time. This lawyer told Miss Ventura that it's

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in your best interest to call mister Combs back one

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twenty seven. Each time Ventura tried to run away, mister

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Combs and his powerful network would force her back to him.

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One twenty eight. Mister colmbs tight hold over her life

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had irreparably damaged her friendships. Around twenty eighteen, when Miss

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Ventura was with her friend Carrie Morgan in her house,

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mister Combs used his key to Miss Ventura's home and

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came in unannounced. He and Miss Morgan had an altercation,

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during which mister Combs threw a hangar at miss Morgan

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upon information and belief. The incident resulted in a settlement

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between mister Combs and Miss Morgan, and Miss Ventura ended

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up paying Miss Morgan additional funds in an attempt to

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resolve the dispute between her close friend and her abusive

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and controlling boyfriend. The relationship between Miss Ventura and Miss

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Morgan was strained since this time one twenty nine. Seeing

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the extreme measures mister Colmbs took to keep a tight

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hold on Miss Ventura, an isolator from her support network,

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and having experienced the repercussions of rejecting his demands, miss

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Ventura filled that's saying no to mister Colmbs would cost

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her something, her family, her friends, her career, even her life.

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Section seven Mister Combs rapes Miss Ventura one thirty by

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twenty seventeen. In twenty eighteen, Miss Ventura became desperate to

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leave mister Colmbs and his abuse of her. She recognized

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that if she stayed with him, she would never be

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able to have a successful career or ever be physically

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and mentally safe. She therefore became determined to completely break

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away from mister Combs and discycle of abuse and made

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concerted efforts to avoid them. One thirty one. In September

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twenty eighteen, she joined mister Combs for a dinner at

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an Italian restaurant in Malibu, California, for what she believed

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would be a discussion about concluding their relationship for good.

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One thirty two. After dinner, mister Combs and Miss Ventura

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returned to miss Ventura's home, which was paid for by

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mister Combs. One thirty three, Mister Colmbs forced himself into

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her apart carment and tried to kiss Miss Ventura. She

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told him to stop and attempted to push him away.

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One thirty four. Mister Combs thenforcibly pulled off Miss Ventura's

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clothing and unbuckled his belt. He proceeded to rate Miss

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Ventura while she repeatedly said no and tried to push

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him away. One thirty five. Soon thereafter, Miss Ventura took

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steps to completely separate herself from her longtime abuser, including

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by leaving the home that he paid for and returning

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the car he purchased four one thirty six. Despite moving away,

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miss Ventura's address was posted online in early twenty nineteen,

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leading to fears for safety. One thirty seven Miss Ventura,

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who was under immense duress during the months after mister

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Combs raped her, took all steps possible to entirely remove

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herself from her abuser's orbit, including by entering into contracts

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to end her record deal with Bad Boy Entertainment. Section eight.

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Mister Combe's sexual and physical abuse of Miss Ventura has

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caused her lifelong life one thirty eight. As a result

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of the immense trauma miss Ventura endured over a decade

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with mister Colmbs, she has suffered and continues to suffer

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from immense and emotional distress one thirty nine. Following her

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escape from the cycle of abuse and sex trafficking she endured,

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she struggled with the physical and mental manifestations of her

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trauma one forty The birth of her two children, however,

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allowed her a new lease on life and gave her purpose.

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She credits her children with saving her from the trauma

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that had consumed her over a decade of her life

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one forty one, except for the months when she was

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pregnant with her children, miss Ventura struggled with her addictions

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of drugs and alcohol, addictions that were established and fueled

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by mister Colmbs. She turned to substances to drown out

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the memories of her abuse without being intoxicated. She suffered

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from horrific nightmares of the four sexual acts that mister

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Combs demanded she participate in during the regularly scheduled defoes,

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and the physith beatings that she endured throughout the relationship.

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She had difficulty eating or sleeping, and her relationships with

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her family they suffered During this time. She frequently had

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thoughts of ending her life. One forty two. To rebuild

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her life and her career, Miss Ventura needed to completely

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reinvent herself. She checked herself into inpatient treatment at a

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rehabilitation center, where she first confronted the extent of the

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trauma she lives with. She has required intensive therapy and

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other medical care to recover from mister Colmb's abuse, and

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she will forever live with the physical and psychological repercussions

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of the over a decade of violence, fear, and exploitation

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that she endured. One forty three. Although Miss Ventura was

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unable to speak up against the years of abuse she

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endured at the hands of mister Colmes, she has since

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been able to rebuild her life and confront her trauma.

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Thanks to the passage of the New York Adult Survivors

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Act and California Sexual Abuse Accountability and of her UP Act,

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she is now ready and able to also confront her

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abuser and to hold him and those who enabled his

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abuse accountable for their actions. First cause action sex trafficking

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under US Code eighteen, section fifteen ninety one against all

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defendants one forty four. Plaintiff repeats and re alleges each

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and every allegation in all of the preceding paragraphs as

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if fully set forth here In one forty five. Plaintiff

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is a victim of sex trafficking within the meaning of

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US Code eighteen, section fifteen ninety one A and B,

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and is therefore entitled to bring a civil action under

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US Code eighteen, section fifteen ninety five one forty six.

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The defendants acts and omissions, taken separately and or together

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as outlined above, constitute a violation of US Code eighteen,

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fifteen ninety five. Specifically, Defendant Shawn Combs perpetrated sex trafficking

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of Miss Ventura by requiring her to engage in force

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sexual acts in multiple jurisdictions, and all defendants benefited from

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mister Comb's venture By holding Miss Ventura, an artist signed

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with defendant bad Boy Records and otherwise employed by defendant

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Dough Corporations, captive to mister combs demands and desires at

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all relevant times, defendants participated in and facilitated the harbouring

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and transportation of plaintiff four purposes of sex induced by force, fraud,

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or coercion. Seven. The defendant corporations have financially and otherwise

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benefited as a result of these acts and omissions. By

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keeping mister Combs, the volatile and explosive owner of the

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defendant corporation, satisfied, they benefited from facilitating his behavior to

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the extent it kept the mercurial music mogul happy and

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kept Miss Venturo obedient to mister Combs and the corporation's interests.

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One forty eight. Defending Combs and defendants bad Boy Records,

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bad Boy Entertainment, and DO Corp. One through ten formed

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a venture as defined in US Code eighteen, Section fifteen

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ninety one, given that they constituted a group of two

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or more individuals associated in fact, whether or not a

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legal entity. One nine as a direct and proximate result

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of defendants unlawful conduct, as alleged here and above, Plaintiff

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has suffered physical injury, severe emotional distress and anxiety, humiliation, embarrassment,

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post traumatic stress disorder, economic harm, and other consequential damages.

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One fifty Plaintiff also seeks reasonable attorney's fees as provided

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under US Code eighteen, Section fifteen ninety five A. The

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second cause of action violation of the New York Services

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for Victims of Human Trafficking Section four eighty three BBC

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against all defendants one fifty one. Plaintiff repeats and re

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alleges each in every allegation in all of the preceding paragraphs.

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As a fully set forth herein one fifty two. Plaintiff

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is a victim of sex tracks within the meaning of

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New York Penal Law section two thirty dashed thirty four,

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and is therefore entitled to bring civil action under New

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York Social Services Section forty three b B one fifty three.

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The defendants acts and omissions, taken separately and or together

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00:14:16,519 --> 00:14:20,039
as outlined above, constitute a violation of New York Social

237
00:14:20,120 --> 00:14:24,960
Services Section forty three b B. Specifically, Defendant Shawn Combs

238
00:14:25,200 --> 00:14:28,720
perpetrated sex trafficking of Miss Ventura by requiring her to

239
00:14:28,840 --> 00:14:31,879
engage in four sexual acts in the state of New York,

240
00:14:32,159 --> 00:14:35,919
and all defendants benefited from mister Combs venture by holding

241
00:14:35,960 --> 00:14:39,399
Miss Ventura, an art assigned with defendant bad Boy records

242
00:14:39,639 --> 00:14:43,679
and otherwise employed by other defendant dough corporations, captive to

243
00:14:43,840 --> 00:14:48,559
mister colmbs demands and desires at all relevant times, defendants

244
00:14:48,759 --> 00:14:53,320
participated in and facilitated the harboring and transportation of plaintiff

245
00:14:53,519 --> 00:14:57,679
for purposes of sex induced by force, fraud, or coercion.

246
00:14:58,399 --> 00:15:02,879
One four. The defendant incorporations have financially and otherwise benefited

247
00:15:03,080 --> 00:15:05,759
as a result of these acts and omissions by keeping

248
00:15:05,799 --> 00:15:10,799
mister Colmbs, a volatile and explosive owner of the defendant corporation, satisfied.

249
00:15:11,200 --> 00:15:14,720
They benefited from facilitating his behavior to the extent it

250
00:15:14,840 --> 00:15:18,039
kept the mercurial music mogul happy and kept Miss Ventura

251
00:15:18,120 --> 00:15:22,519
obedient to mister Combs and the corporation's interests. One fifty five.

252
00:15:23,039 --> 00:15:25,600
As a direct and proximate result of the defendants on

253
00:15:25,679 --> 00:15:29,360
lawful conduct as alleged Heer and above, Plaintiff has suffered

254
00:15:29,559 --> 00:15:35,120
physical injury, severe emotional distress, end, anxiety, humiliation, embarrassment, post

255
00:15:35,120 --> 00:15:39,919
traumatic stress, disorder, economic harm, and other consequential damages. One

256
00:15:40,000 --> 00:15:44,720
fifty six. Plaintiff also seeks reasonable attorney fees as provided

257
00:15:44,799 --> 00:15:48,240
under New York Social Services Section four eighty three b B.

258
00:15:50,360 --> 00:15:54,039
The third cause of action violation of the California Trafficking

259
00:15:54,120 --> 00:15:57,919
Victims Protection Act California Civil Code fifty two dot five

260
00:15:58,440 --> 00:16:02,840
against all defendants one fifty seven. Plaintiff repeats and re

261
00:16:02,919 --> 00:16:06,519
alleges each in every allegation in all the preceding paragraphs.

262
00:16:06,639 --> 00:16:09,320
As a fully set forth here in one fifty eight.

263
00:16:09,679 --> 00:16:12,399
Plaintiff is a victim of sex trafficking within the meaning

264
00:16:12,440 --> 00:16:15,559
of California Penal Code section two thirty six dot one,

265
00:16:15,879 --> 00:16:19,320
and is therefore entitled to bring civil action under California

266
00:16:19,360 --> 00:16:23,320
Civil Code Section fifty two five one fifty nine. The

267
00:16:23,360 --> 00:16:27,120
defendant's acts and omissions, taken separately and or together as

268
00:16:27,120 --> 00:16:31,279
outlined above, constitute a violation of California Civil Code fifty

269
00:16:31,320 --> 00:16:36,039
two dot five. Specifically, Defendant Shawn Combs perpetrated sex trafficking

270
00:16:36,080 --> 00:16:39,399
in Miss Ventura by requiring her to engage in four

271
00:16:39,559 --> 00:16:42,600
sexual acts in the state of California, and all defendants

272
00:16:42,639 --> 00:16:46,480
benefited from mister combs venture by holding Miss Ventura, an

273
00:16:46,600 --> 00:16:50,440
artist signed with defendant bad Boy Records and otherwise employed

274
00:16:50,480 --> 00:16:55,039
by other defendant Dough corporations, captive to mister combs demands

275
00:16:55,080 --> 00:16:59,879
and his desires at all relevant times, Defendants participated in

276
00:17:00,519 --> 00:17:05,400
and facilitated the harboring and transportation of plaintiff for purposes

277
00:17:05,400 --> 00:17:10,119
of sex induced by force, fraud, or coercion one sixty

278
00:17:10,480 --> 00:17:14,839
The defendant corporations have financially and otherwise benefited as a

279
00:17:14,880 --> 00:17:18,400
result of these acts and omissions by keeping mister Colmbs,

280
00:17:18,400 --> 00:17:24,039
the volatile and explosive owner of defendant corporations, satisfied. They

281
00:17:24,079 --> 00:17:28,200
benefited from facilitating his behavior to the extent it kept

282
00:17:28,200 --> 00:17:32,000
the mercurial music mogul happy and kept Miss Ventura obedient.

283
00:17:32,240 --> 00:17:36,400
Two Mister Combs and the corporation's interests one sixty one.

284
00:17:36,680 --> 00:17:39,480
As a direct and approximate result of defendants on lawful

285
00:17:39,519 --> 00:17:43,359
conduct as alleged hearian above, plaintiff has suffered physical injury,

286
00:17:43,519 --> 00:17:49,880
severe emotional distress and anxiety, humiliation, embarrassment, post traumatic stress disorder,

287
00:17:50,039 --> 00:17:55,599
economic harm, and other consequential damages one sixty two. Plaintiff

288
00:17:55,920 --> 00:18:00,000
also seeks reasonable attorney fees as provided under cal Silvie

289
00:18:00,200 --> 00:18:03,079
Code fifty two to five. The fourth cause of action

290
00:18:03,759 --> 00:18:07,960
battery sexual battery under New York law against defendant Sean

291
00:18:08,039 --> 00:18:13,039
Colmes one sixty three. Plaintiff repeats and re alleges each

292
00:18:13,039 --> 00:18:16,480
in every allegation and all the preceding paragraphs, as I

293
00:18:16,559 --> 00:18:20,079
fully set forth here in one sixty four. In performing

294
00:18:20,119 --> 00:18:24,160
the conduct described above, Defendant committed a battery against plaintiff

295
00:18:24,319 --> 00:18:28,720
because he intentionally engaged in unlawful, intentional, and offensive touching

296
00:18:28,880 --> 00:18:33,200
or application of force two Plaintiff's person. Defendant's actions amount

297
00:18:33,240 --> 00:18:36,400
of violations under New York Penal Code section one thirty

298
00:18:36,440 --> 00:18:39,759
dot fifty one thirty dot fifty two, one thirty dot

299
00:18:39,799 --> 00:18:43,079
fifty five, one thirty dot sixty five, as well as

300
00:18:43,119 --> 00:18:46,480
California law and the common law of New York and California.

301
00:18:46,720 --> 00:18:50,680
One sixty five. As a result of mister Colmb's alleged conduct,

302
00:18:50,680 --> 00:18:56,920
Plaintiff has suffered physical injury, severe emotional distress, humiliation, embarrassment, anxiety,

303
00:18:57,200 --> 00:19:02,559
economic harm, and other consequential damages. One sixty six. The

304
00:19:02,599 --> 00:19:06,440
conduct of mister Colmbs described above was wilful, wanton, and

305
00:19:06,559 --> 00:19:10,559
malicious at all times relevant. Mister Colmbs acted with conscious

306
00:19:10,599 --> 00:19:14,599
disregard of Plaintiff's rights and feelings, acted with the knowledge

307
00:19:14,720 --> 00:19:17,599
of or with the reckless disregard for the fact that

308
00:19:17,640 --> 00:19:20,920
his conduct was certain to cause injury and or humiliation

309
00:19:21,279 --> 00:19:24,799
to the plaintiff and intended to cause fear physical injury,

310
00:19:25,039 --> 00:19:28,279
and or pain and suffering to plaintiff. By virtue of

311
00:19:28,319 --> 00:19:31,640
the foregoing plaintiff is entitled to recover a punitive and

312
00:19:31,720 --> 00:19:35,680
exemplary damages from mister Colmbs. According to proof at trial

313
00:19:36,640 --> 00:19:40,039
one sixty seven. The action is timely because it falls

314
00:19:40,079 --> 00:19:44,240
within CPLR Section two fourteen J and is brought during

315
00:19:44,240 --> 00:19:47,000
the one year time period set fourth in that section.

316
00:19:48,000 --> 00:19:51,640
The claims brought herein allege intentional and negligent acts and

317
00:19:51,799 --> 00:19:56,200
or emissions for physical, psychological, and other injuries suffered as

318
00:19:56,200 --> 00:19:59,559
a result of conduct that would constitute sexual offenses as

319
00:19:59,599 --> 00:20:02,160
the fine an Article one thirty of the New York

320
00:20:02,200 --> 00:20:05,599
Penal Law, and such acts and or emissions were committed

321
00:20:05,599 --> 00:20:08,839
against Miss Ventura when she was over eighteen years of age.

322
00:20:09,119 --> 00:20:13,680
The action also falls within California's adult Sexual Abuse law

323
00:20:13,839 --> 00:20:16,400
and has brought during the three year time period set

324
00:20:16,440 --> 00:20:20,000
forth in that action. The fifth cause of action sexual

325
00:20:20,039 --> 00:20:23,240
assault pursuant to the California Sexual Abuse and Cover Up

326
00:20:23,240 --> 00:20:28,480
Accountability Act California Civil Procedure Section three forty dot sixteen

327
00:20:29,039 --> 00:20:32,640
one sixty eight. Plaintiff repeats and realleges each and every

328
00:20:32,680 --> 00:20:36,079
allegation in all of the preceding paragraphs as a fully

329
00:20:36,079 --> 00:20:39,880
set fourth year. In one sixty nine, defended mister Combe

330
00:20:39,880 --> 00:20:44,680
subjected plaintiff to sexual abuse, sexual battery, rape, and forcible

331
00:20:44,680 --> 00:20:48,440
act of sexual penetration as defined in California Penal Code

332
00:20:48,559 --> 00:20:51,759
section two thirty four dot four two sixty one, and

333
00:20:51,799 --> 00:20:55,200
two eighty nine. In doing so, he intended to and

334
00:20:55,279 --> 00:20:59,240
did cause harmful and sexually offensive contact with their person

335
00:20:59,480 --> 00:21:03,440
and placed them an imminent apprehension of such contact. One

336
00:21:03,599 --> 00:21:08,119
seventy Defending corporations where entities engaged in a cover up

337
00:21:08,359 --> 00:21:11,720
as defined in California Civil Code Section three forty dot

338
00:21:11,839 --> 00:21:16,519
sixteen foreign a because defending corporations took concerted efforts to

339
00:21:16,599 --> 00:21:20,160
hide evidence relating to the above described sexual assaults that

340
00:21:20,240 --> 00:21:25,440
incentivized individuals to remain silent or prevented information relating to

341
00:21:25,559 --> 00:21:29,960
the above described sexual assaults that incentivized individuals to remain

342
00:21:30,039 --> 00:21:34,680
silent or prevented information relating to the sexual assaults from

343
00:21:34,720 --> 00:21:38,839
becoming public one seventy one. As a direct and proximate

344
00:21:38,920 --> 00:21:42,599
result of Defendant's unlawful conduct as alleged here and above,

345
00:21:42,799 --> 00:21:48,839
Plaintiff has suffered physical injury, severe emotional distress and anxiety, humiliation, embarrassment,

346
00:21:49,119 --> 00:21:53,880
post traumatic stress disorder, economic harm, and other consequential damages.

347
00:21:54,200 --> 00:21:57,279
The six cause of action violation of the Victims Gender

348
00:21:57,359 --> 00:22:02,480
Motivated Violence Act, NYC Administration Code, Section ten Dash eleven

349
00:22:02,720 --> 00:22:07,920
zero one against all defendants one seventy two. Plaintiff repeats

350
00:22:07,920 --> 00:22:10,839
and realleges each in every allegation in all of the

351
00:22:10,880 --> 00:22:14,240
preceding paragraphs. As a fully set fourth here in one

352
00:22:14,400 --> 00:22:18,400
seventy three, The above described conduct of defendant mister Combs,

353
00:22:18,400 --> 00:22:22,079
including but not limited to mister Combs repeated physical and

354
00:22:22,119 --> 00:22:25,440
sexual assaults of plaintiff in New York City, constitutes a

355
00:22:25,480 --> 00:22:28,200
crime of violence and a crime of violence motivated by

356
00:22:28,279 --> 00:22:31,960
gender against plaintiff as defined by the New York City

357
00:22:32,119 --> 00:22:36,880
VGM VPL one seventy four. The above described conduct of

358
00:22:36,880 --> 00:22:40,839
defendant mister Combs, including but not limited to mister Combs

359
00:22:40,920 --> 00:22:44,160
repeated physical and sexual assaults of plaintiff in New York

360
00:22:44,160 --> 00:22:47,640
City constitutes a crime of violence against plaintiff and is

361
00:22:47,640 --> 00:22:51,359
a crime of violence motivated by gender, as defined in

362
00:22:51,400 --> 00:22:55,079
Section ten eleven oh three. The term crime of violence

363
00:22:55,359 --> 00:22:58,359
means an act or series of acts that would constitute

364
00:22:58,400 --> 00:23:02,119
a misdemeanor or a felony against the person as defined

365
00:23:02,160 --> 00:23:04,799
in state or federal law, or that would constitute a

366
00:23:04,799 --> 00:23:08,400
misdemeanor or felony against property as defined in state or

367
00:23:08,440 --> 00:23:11,640
federal law, if the conduct presents a serious risk of

368
00:23:11,680 --> 00:23:14,920
physical injury to another, whether or not those acts have

369
00:23:15,000 --> 00:23:19,880
actually resulted in criminal charges, prosecution, or conviction. And the

370
00:23:19,960 --> 00:23:23,079
term crime of violence motivated by gender means a crime

371
00:23:23,119 --> 00:23:26,559
of violence committed because of gender or on the basis

372
00:23:26,599 --> 00:23:29,400
of gender, and do at least in part to an

373
00:23:29,440 --> 00:23:33,759
animis based on the victim's gender one seventy five. Defending

374
00:23:33,839 --> 00:23:37,519
corporations enabled mister Comb's commissions of the crime of violence

375
00:23:37,559 --> 00:23:41,200
motivated by gender, and are therefore also liable under the

376
00:23:41,279 --> 00:23:46,119
VGMVPL one seventy six. As direct and proximate result of

377
00:23:46,160 --> 00:23:50,160
the aforementioned crimes of violence and gender motivated violence, Plaintiff

378
00:23:50,359 --> 00:23:55,000
has sustained and will continue to sustain monetary damages, physical injury,

379
00:23:55,079 --> 00:23:59,799
pain and suffering and serious psychological and emotional distress entitling

380
00:23:59,799 --> 00:24:04,519
her to an award of compensatory and punitive damages, injunctive

381
00:24:04,759 --> 00:24:08,680
and declaratory relief, attorney fees and costs, and other remedies

382
00:24:08,720 --> 00:24:12,039
as this Court may deem appropriate damages as set forth

383
00:24:12,319 --> 00:24:16,880
in section ten dash eleven oh four one seventy seven.

384
00:24:17,079 --> 00:24:20,759
The above described conduct of defendant mister Combs constitutes a

385
00:24:20,839 --> 00:24:24,319
sexual offense as defined an Article one thirty of the

386
00:24:24,359 --> 00:24:27,960
New York Penal Law one seventy eight pursuant to Section

387
00:24:28,000 --> 00:24:30,759
ten eleven oh five A. This cause of action is

388
00:24:30,799 --> 00:24:34,160
timely because it is commenced within two years and six

389
00:24:34,200 --> 00:24:38,599
months after September one, twenty twenty two. The seventh cause

390
00:24:38,640 --> 00:24:42,839
of action sexual harassment, gender discrimination and a hostile work

391
00:24:42,920 --> 00:24:47,480
environment under New York State Human Rights Law one seventy nine.

392
00:24:47,720 --> 00:24:51,680
Plaintiff repeats and realleges and every allegation in all of

393
00:24:51,720 --> 00:24:54,440
the precedings paragraphs, as if fully set forth here In

394
00:24:54,920 --> 00:24:58,920
one E Defendant discriminated against plaintiff on the basis of

395
00:24:58,960 --> 00:25:02,920
her gender and vice violation of nys hr L in

396
00:25:02,960 --> 00:25:07,359
subjecting plaintiff to disparate treatment based upon her gender, including

397
00:25:07,359 --> 00:25:11,839
but not limited to subjecting her to sexual assault and harassment, rape,

398
00:25:11,880 --> 00:25:15,240
and a hostile work environment. One one As a direct

399
00:25:15,279 --> 00:25:19,920
and proximate result of defendants unlawful discriminatory conduct and violation

400
00:25:20,680 --> 00:25:24,680
of the nys hr L, Plaintiffs suffered and continues to

401
00:25:24,680 --> 00:25:28,000
suffer monetary and or economic harm, for which he is

402
00:25:28,160 --> 00:25:31,279
entitled to an award of monetary damages and other relief.

403
00:25:31,720 --> 00:25:34,799
One eight two. As a direct and proximate result of

404
00:25:34,880 --> 00:25:39,880
defendants unlawful discriminatory conduct in violation of nys hr L,

405
00:25:40,519 --> 00:25:44,119
Plaintiffs suffered and continues to suffer severe mental anguish and

406
00:25:44,240 --> 00:25:47,319
emotional distress, for which he is entitled to an award

407
00:25:47,559 --> 00:25:52,680
of monetary damages and other relief. Three. Defendants unlawful and

408
00:25:52,720 --> 00:25:56,839
discriminatory actions were intentional, done with malice, and or showed

409
00:25:56,839 --> 00:26:00,680
a deliberate, wilful, wanton, and reckless indifference to plaintiff rights

410
00:26:00,799 --> 00:26:04,599
under the nys hr L, for which plaintiff is entitled

411
00:26:04,640 --> 00:26:08,680
to an award of punitive damages. One eighty four. This

412
00:26:08,799 --> 00:26:12,519
action is timely because of falls within cpl R Section

413
00:26:12,559 --> 00:26:15,160
two fourteen J, and has brought during the one year

414
00:26:15,240 --> 00:26:18,960
time period set forth in that section. The claims brought

415
00:26:18,960 --> 00:26:22,920
here in alleged intentional and negligent acts and or emissions

416
00:26:22,920 --> 00:26:26,920
of for physical, psychological, and any other injury suffered as

417
00:26:26,960 --> 00:26:30,640
a result of conduct that would constitute sexual offenses as

418
00:26:30,640 --> 00:26:33,200
defined an Article one point thirty of the New York

419
00:26:33,240 --> 00:26:36,839
Penal Law, and such acts and or emissions were committed

420
00:26:36,880 --> 00:26:40,079
against Miss Ventura when she was over the age of eighteen.

421
00:26:41,039 --> 00:26:45,400
Eighth Cause of action sexual harassment, gender discrimination and hostile

422
00:26:45,440 --> 00:26:48,960
work environment under New York City's Human Rights Law one

423
00:26:49,039 --> 00:26:52,599
eighty five. Plaintiff repeats and re alleges each in every

424
00:26:52,640 --> 00:26:56,079
allegation in all the preceding paragraphs. As a fully set

425
00:26:56,079 --> 00:27:00,440
forth here in one eighty six, Defendant has discriminated against

426
00:27:00,440 --> 00:27:03,519
plaintiff on the basis of her gender in violation of

427
00:27:03,759 --> 00:27:08,880
nyc HRL by subjecting Plaintiff to disparate treatment based upon

428
00:27:08,880 --> 00:27:12,400
her gender, including but not limited to, subjecting her to

429
00:27:12,440 --> 00:27:16,160
sexual assault and or harassment, rape, and or a hostile

430
00:27:16,160 --> 00:27:20,079
work environment one seven. As a direct and proximate result

431
00:27:20,119 --> 00:27:24,559
of defendants on lawful discriminatory conduct and violation of the

432
00:27:24,680 --> 00:27:29,480
ny CHRL, Plaintiff is suffered and continues to suffer monetary

433
00:27:29,839 --> 00:27:32,680
and or economic harm, for which he is entitled to

434
00:27:32,720 --> 00:27:37,920
an award of monetary damages and other relief. Eight As

435
00:27:37,960 --> 00:27:42,599
a direct and proximate result of defendants unlawful discriminatory conduct

436
00:27:42,839 --> 00:27:47,119
in violation of NYCHRL, Plaintiff has suffered and continues to

437
00:27:47,119 --> 00:27:50,960
suffer severe mental anguish and emotional distress, for which he

438
00:27:51,000 --> 00:27:54,640
is entitled to an award of monetary damages and other relief.

439
00:27:56,039 --> 00:28:00,960
Nine defendants unlawful and discriminatory actions were intentional, unwith malice.

440
00:28:01,160 --> 00:28:04,759
Endors showed a deliberate, wilful, wanton, and reckless indifference. Two

441
00:28:04,799 --> 00:28:09,559
Plaintiff's rights under the NYCCHURL, for which plaintiff is entitled

442
00:28:09,599 --> 00:28:13,640
to an award of punitive damages one ninety. This action

443
00:28:13,759 --> 00:28:17,799
is timely because it falls within CPLR Section two fourteen

444
00:28:17,920 --> 00:28:20,519
J and is brought during the one year time period

445
00:28:20,799 --> 00:28:24,440
set forth in that section. The claims brought herein a

446
00:28:24,519 --> 00:28:28,880
leegendentional and negligent acts end or omissions for physical, psychological,

447
00:28:29,200 --> 00:28:32,319
or other injuries suffered as a result of conduct that

448
00:28:32,359 --> 00:28:36,599
would constitute sexual offenses as defined an Article one thirty

449
00:28:36,839 --> 00:28:39,319
of the New York Penal Law, and such acts and

450
00:28:39,519 --> 00:28:42,640
or omissions were committed against Miss Ventura when she was

451
00:28:42,680 --> 00:28:47,079
over the age of eighteen. Prayer for relief, wherefore a

452
00:28:47,119 --> 00:28:50,720
plaintiff praise judgment be entered in her favor against defendants

453
00:28:50,920 --> 00:28:53,799
and each of them as follows. One for a money

454
00:28:53,880 --> 00:28:59,720
judgment representing compensatory damages, including consequential damages, loss, wages, earning,

455
00:29:00,079 --> 00:29:03,279
and all other sums of money, together with interest on

456
00:29:03,400 --> 00:29:06,799
these amounts according to proof. Two for a money judgment

457
00:29:07,000 --> 00:29:10,440
for mental pain and anguish and severe emotional distress according

458
00:29:10,440 --> 00:29:14,759
to proof. Three for punitive and exemplary damages, according to

459
00:29:14,799 --> 00:29:18,880
proof four for attorney fees and costs, five for pre

460
00:29:19,079 --> 00:29:23,559
judgment and post judgment interests, and six for such other

461
00:29:24,119 --> 00:29:27,440
and further relief as the Court may deem just and proper.

462
00:29:28,319 --> 00:29:31,559
This was signed by Douglas H. Wigdor and it was

463
00:29:31,640 --> 00:29:36,319
dated November sixteenth, twenty twenty three. All right, folks, So

464
00:29:36,440 --> 00:29:41,000
that wraps up the Cassie Ventura allegations against Poff Daddy.

465
00:29:41,559 --> 00:29:43,880
And now the next document we're going to dive into

466
00:29:44,359 --> 00:29:47,160
is a Jane Doe who says she was under age

467
00:29:47,400 --> 00:29:50,319
when Diddy did older. But that's going to do it

468
00:29:50,359 --> 00:29:52,839
for this one and all of the information that goes

469
00:29:52,880 --> 00:29:56,000
with this episode can be found in the description box.