1 00:00:00,040 --> 00:00:02,839 Speaker 1: What's up, everyone, and welcome back to another episode of 2 00:00:02,919 --> 00:00:06,200 the Ditty Diaries. In this episode, we're getting back to 3 00:00:06,280 --> 00:00:10,759 the Sarrow Rivers lawsuit filed against Ditty. Second cause of 4 00:00:10,800 --> 00:00:16,079 action Assault and Battery against Defendant Ditty. Plaintiff incorporates by 5 00:00:16,120 --> 00:00:19,920 reference all preceding paragraphs and realegism as if set forth 6 00:00:20,160 --> 00:00:24,760 fully Herein, as set forth above, Defendant Ditty did initiate 7 00:00:24,839 --> 00:00:29,800 non consensual contact with plaintiff, did forcibly touch plaintiff, did 8 00:00:29,800 --> 00:00:33,640 intimidate and cause plaintiff safety and security to feel threatened, 9 00:00:33,880 --> 00:00:37,960 and did assault and sexually battery plaintiff in engaging in 10 00:00:38,000 --> 00:00:41,840 the conduct described herein. Defendant Ditty committed an assault against 11 00:00:41,840 --> 00:00:45,640 plaintiff because he intentionally plays plaintiff in a reasonable apprehension 12 00:00:45,880 --> 00:00:50,200 of imminent harmful or offensive contact, and Plaintiff reasonably feared 13 00:00:50,439 --> 00:00:55,039 immediate bodily harm as a result of Defendant's conduct. Defendant's 14 00:00:55,039 --> 00:00:58,520 actions amount of violations under en why Penal Laws Section 15 00:00:58,840 --> 00:01:04,400 one ten and one and one fifteen. Defendant made offensive 16 00:01:04,439 --> 00:01:08,560 bodily contact with plaintiff, constituting harmful and offensive contact a 17 00:01:08,599 --> 00:01:13,280 plaintiff's person. Said contact was done intentionally by defendant and 18 00:01:13,319 --> 00:01:17,879 without Plaintiff's consent or legal justification, as alleged here in, 19 00:01:18,000 --> 00:01:22,359 defendant acts against plaintiff created a reasonable apprehension in plaintiffs 20 00:01:22,560 --> 00:01:26,519 of immediate harmful or offensive contact a plaintiff's person. Set 21 00:01:26,560 --> 00:01:29,959 acts were done intentionally by the defendant and without plaintiff's 22 00:01:29,959 --> 00:01:33,959 consent or legal justification. As alleged here in, the defendant's 23 00:01:34,000 --> 00:01:38,400 acts against plaintiff constituted harmful and offensive contact a plaintiff's person, 24 00:01:38,719 --> 00:01:42,359 which were done intentionally by defendant without plaintiff's consent or 25 00:01:42,480 --> 00:01:47,599 legal justification. As alleged here in, defendant acts against plaintiff 26 00:01:47,640 --> 00:01:51,640 created or reasonable apprehension in plaintiff of immediate harmful or 27 00:01:51,680 --> 00:01:55,439 offensive contact a plaintiff's person. Set acts were done intentionally 28 00:01:55,519 --> 00:02:01,000 by defendant without Plaintiff's consent or legal justification. Inasmuch as 29 00:02:01,000 --> 00:02:04,359 each defendant was acting for upon and or in furtherance 30 00:02:04,439 --> 00:02:10,719 of the enterprise, defendants BMMTV, Paramount Viacombbe, and SJAC are 31 00:02:10,800 --> 00:02:14,719 liable under the doctrine of respondent superior for the tordious 32 00:02:14,879 --> 00:02:18,919 actions of its defendant actors. As a result of the foregoing, 33 00:02:18,919 --> 00:02:23,639 plaintiff was caused to sustain physical psychological and emotional injuries, 34 00:02:23,719 --> 00:02:28,199 pain and suffering, shame and embarrassment, humiliation, damaged to reputation, 35 00:02:28,759 --> 00:02:33,719 has been caused to incur losses, and otherwise damaged. The 36 00:02:33,719 --> 00:02:38,240 conduct of Defendant Ditty described herein was wilful, wanton, and malicious. 37 00:02:38,599 --> 00:02:42,039 At all relevant times. Defendant Ditty acted with conscious disregard 38 00:02:42,319 --> 00:02:45,439 for a plaintiff's rights and feelings, acted with the knowledge 39 00:02:45,520 --> 00:02:48,400 of or with reckless disregard for the fact that his 40 00:02:48,520 --> 00:02:51,479 conduct was certain to cause injury and or humiliation to 41 00:02:51,560 --> 00:02:55,360 plaintiff and intended to cause fear physical injury and or 42 00:02:55,479 --> 00:03:00,560 pain and suffering the plaintiff. By virtue of the foregoing 43 00:03:00,599 --> 00:03:04,599 plaintiff is entitled to recover punitive and exemplary damages from 44 00:03:04,599 --> 00:03:08,360 defendant Calms according to proof at trial. The third cause 45 00:03:08,400 --> 00:03:11,479 of action forced labour and violation of US Code eighteen, 46 00:03:11,560 --> 00:03:15,960 Section fifteen eighty nine and fifteen ninety five against Defendant Ditty, 47 00:03:16,080 --> 00:03:21,560 BB Bad Boy Records, UMG, BM MTV, VIACOM, and paramount 48 00:03:22,319 --> 00:03:26,039 Plaintiff repeats and realleges each and every allegation in all 49 00:03:26,080 --> 00:03:28,879 of the preceding paragraphs as a fully set fourth year 50 00:03:28,919 --> 00:03:33,120 in defendants knowingly obtain labor from plaintiff through threats of 51 00:03:33,280 --> 00:03:37,240 serious harm, physical restraint, and other means of coercion in 52 00:03:37,319 --> 00:03:41,759 violation of US Code eighteen, section fifteen eighty nine. Defendant Ditty, BB, 53 00:03:42,120 --> 00:03:47,039 bad Boy Records, bm MTV, VIACOM, UMG, and Paramount knowingly 54 00:03:47,120 --> 00:03:50,879 benefited from the force labor and the trafficking activities conducted 55 00:03:50,960 --> 00:03:55,520 by Defendant Ditty. Under US Code eighteen, section fifteen ninety five, 56 00:03:55,879 --> 00:03:58,759 Plaintiff is entitled to bring a civil action against all 57 00:03:58,800 --> 00:04:03,039 defendants for their violation of US Code eighteen, section fifteen 58 00:04:03,080 --> 00:04:06,960 eighty nine. As a direct and approximate result of defendant's actions, 59 00:04:07,159 --> 00:04:10,599 Plaintiff is sustained and will continue to sustain monetary damages 60 00:04:10,879 --> 00:04:14,680 and lore economic harm, physical injury, pain and suffering, and 61 00:04:14,800 --> 00:04:20,720 serious psychological and emotional distress. Plaintiff seeks compensatory damages for 62 00:04:20,759 --> 00:04:24,279 the harm suffered as a result of defendants forced labor practices. 63 00:04:25,680 --> 00:04:29,800 Plaintiff also seeks punitive damages to deter such conduct by 64 00:04:29,839 --> 00:04:33,439 defendants in the future, along with reasonable attorney fees and costs. 65 00:04:34,800 --> 00:04:39,839 Defendants continuous threats, erratic behavior, coercion, and interference with Plaintiff's 66 00:04:39,879 --> 00:04:43,360 music career prevented plaintiff from asserting her rights within the 67 00:04:43,399 --> 00:04:47,519 statutorially prescribed period. Defendant should be e stopped from asserting 68 00:04:47,519 --> 00:04:50,600 the statute of limitations as the defense due to the 69 00:04:50,680 --> 00:04:55,720 duress exerted upon plaintiff for the cause of action Battery 70 00:04:56,000 --> 00:05:00,839 sexual battery against defendants Ditty, BB, Bad Boy Records, BM, 71 00:05:00,920 --> 00:05:08,519 VIACOM Paramount, MTVSJC, and JCP. Plaintiff repeats and realleges each 72 00:05:08,519 --> 00:05:11,879 in every allegation in all of the preceding paragraphs as 73 00:05:11,879 --> 00:05:15,439 a fully set fourth year in in engaging in the 74 00:05:15,480 --> 00:05:19,639 conduct described here in Defending Ditty committed a battery against 75 00:05:19,680 --> 00:05:24,240 plaintiff because he intentionally engaged in unlawful, intentional, and offensive 76 00:05:24,240 --> 00:05:28,319 touching or application of force to Plaintiff's person. Defending Ditty 77 00:05:28,360 --> 00:05:32,759 without consent touch Plaintiff's body, including her chest area. Defendant's 78 00:05:32,800 --> 00:05:36,439 actions amount of violations under NY Penal Laws Section one 79 00:05:36,519 --> 00:05:39,879 fifty dot fifty one thirty dot fifty two, one thirty 80 00:05:39,920 --> 00:05:44,439 dot fifty five, and one thirty dot sixty five. Defending 81 00:05:44,519 --> 00:05:48,279 Bad Boy Records as financially and otherwise benefited from these 82 00:05:48,319 --> 00:05:52,120 acts of omissions by keeping defendant Ditty, the volatile and 83 00:05:52,240 --> 00:05:56,319 explosive owner of Bad Boy Records satisfied and benefited from 84 00:05:56,360 --> 00:06:02,920 facilitating its behavior. BM has financially and otherwise benefited from 85 00:06:02,920 --> 00:06:06,000 these acts and omissions by keeping defending Ditty, and the 86 00:06:06,120 --> 00:06:10,000 volatile explosive owner of Bad Boy Records satisfied and benefited 87 00:06:10,000 --> 00:06:15,120 from facilitating his behavior. Defendant VIACOM has financially and otherwise 88 00:06:15,160 --> 00:06:18,920 benefited from these acts and omissions by keeping defending Ditty, 89 00:06:19,000 --> 00:06:22,319 the volatile and explosive owner of Bad Boy Records satisfied 90 00:06:22,759 --> 00:06:28,600 and benefited from facilitating his behavior. Defendant Paramount has financially 91 00:06:28,680 --> 00:06:32,079 and otherwise benefited from these acts and omissions by keeping 92 00:06:32,079 --> 00:06:35,319 defending Ditty, The volatile and explosive owner of Bad Boy 93 00:06:35,360 --> 00:06:41,240 Records satisfied and benefited from facilitating his behavior. Defending MTV 94 00:06:41,360 --> 00:06:45,319 is financially and otherwise benefited from these acts and omissions 95 00:06:45,560 --> 00:06:48,920 by keeping defending Ditty, the volatile and explosive owner of 96 00:06:48,959 --> 00:06:53,040 Bad Boy Records satisfied and benefited from facilitating his behavior. 97 00:06:54,079 --> 00:06:58,000 Defending SJC is financially and otherwise benefited from these acts 98 00:06:58,160 --> 00:07:01,680 and omissions by keeping defended and Didty, the volatile and 99 00:07:01,720 --> 00:07:05,519 explosive owner of Bad Boy Records satisfied and benefited from 100 00:07:05,800 --> 00:07:11,000 facilitating his behavior. Defending JCP is financially and otherwise benefited 101 00:07:11,160 --> 00:07:14,519 from these acts and omissions by keeping Defending Ditty, the 102 00:07:14,680 --> 00:07:18,920 volatile and explosive owner of bad Boy Records, satisfied and 103 00:07:19,000 --> 00:07:23,240 benefited from facilitating his behavior. As a direct and approximate 104 00:07:23,319 --> 00:07:27,319 result of Defendant's actions, Plaintiff has sustained and will continue 105 00:07:27,319 --> 00:07:31,839 to sustain monetary damages and lore, economic harm, physical injury, 106 00:07:32,160 --> 00:07:37,720 pain and suffering, and serious psychological and emotional distress. The 107 00:07:37,800 --> 00:07:41,519 described conduct by Defending Ditty was wilful, wanton, and malicious. 108 00:07:42,519 --> 00:07:46,319 At all times. Didty acted with conscious disregard of Plaintiff's 109 00:07:46,399 --> 00:07:49,319 rights and feelings, acted with the knowledge of, or with 110 00:07:49,519 --> 00:07:52,639 reckless disregard for the fact that his conduct was certain 111 00:07:52,920 --> 00:07:57,279 to cause injury and or humiliation the plaintiff, and intended 112 00:07:57,279 --> 00:08:01,240 to cause fear, physical injury, and or pain suffering the plaintiff. 113 00:08:02,000 --> 00:08:04,839 By virtue of the foregoing, plaintiff is entitled to recover 114 00:08:04,959 --> 00:08:09,240 punitive and exemplary damages from Defendant Ditty. According to proof 115 00:08:09,240 --> 00:08:15,000 at trial, Defendant's continuous threats, coercion, and interference with her 116 00:08:15,040 --> 00:08:18,680 career prevented plaintiff from asserting her rights within the statutorily 117 00:08:18,800 --> 00:08:22,000 prescribed period. Defendant should be EA stop from asserting the 118 00:08:22,000 --> 00:08:25,480 statute of limitations as the defense due to the duress 119 00:08:25,480 --> 00:08:31,040 exerted upon Plaintiff. Fifth cause of action false imprisonment against 120 00:08:31,040 --> 00:08:35,519 Defendants Ditty BB Bad Boy Records in Daddy's House. Plaintiff 121 00:08:35,519 --> 00:08:38,720 repeats and realleges each in every allegation in all of 122 00:08:38,759 --> 00:08:41,559 the preceding paragraphs, as I fully set fourth year in 123 00:08:42,279 --> 00:08:45,879 Defendant Ditty falsely imprisoned Plaintiff in New York, as alleged 124 00:08:45,879 --> 00:08:50,039 in this complaint by suddenly, and without provocation, willfully and 125 00:08:50,039 --> 00:08:53,960 maliciously falsely imprisoned Plaintiff against her will in the defendant's 126 00:08:53,960 --> 00:08:58,240 corporate recording studio, Daddy's house for a prolonged period. Defendant 127 00:08:58,320 --> 00:09:01,960 BVE has financially and otherwise benefited from these acts and 128 00:09:02,080 --> 00:09:06,720 omissions by keeping Defendant Ditty, the volatile and explosive owner 129 00:09:06,720 --> 00:09:10,799 of Bad Boy Records, satisfied and benefited from facilitating his behavior. 130 00:09:11,639 --> 00:09:15,559 Defending Bad Boy Records is financially and otherwise benefited from 131 00:09:15,600 --> 00:09:20,200 these acts and omissions by keeping Defendant Ditty, the volatile 132 00:09:20,399 --> 00:09:23,879 and explosive owner of Bad Boy Records, satisfied and benefited 133 00:09:24,080 --> 00:09:28,960 from facilitating his behavior. Defendant Daddy's House has financially and 134 00:09:29,080 --> 00:09:33,120 otherwise benefited from these acts and omissions by keeping Defendant Ditty, 135 00:09:33,360 --> 00:09:36,879 the volatile and explosive owner of Bad Boy Records, satisfied 136 00:09:37,120 --> 00:09:41,559 and benefited from facilitating this behavior. As a direct and 137 00:09:41,679 --> 00:09:45,960 proximate result of Defendant's actions, Plaintiff has sustained and will 138 00:09:46,000 --> 00:09:51,159 continue to sustain monetary damages and lore economic harm, physical injury, 139 00:09:51,200 --> 00:09:57,120 pain and suffering, and serious psychological and emotional distress. Defendants 140 00:09:57,120 --> 00:10:02,000 continuous threats, coercion, and interference with with Plaintiff's career prevented 141 00:10:02,000 --> 00:10:05,320 plaintiff from asserting her rights, and defendant should be stopped 142 00:10:05,320 --> 00:10:08,519 from asserting the statute of limitations as a defense due 143 00:10:08,559 --> 00:10:12,639 to the duress exerted upon plaintiff six cause of action 144 00:10:12,840 --> 00:10:17,360 sexual harassment, gender discrimination and hostile work environment under New 145 00:10:17,440 --> 00:10:20,600 York State Human Rights Law and y Executive Law Section 146 00:10:20,639 --> 00:10:24,799 two ninety n ys hr L against Defendant Didty BB 147 00:10:25,080 --> 00:10:28,519 and Bad Boy Records. Plaintiff repeats and realleges each and 148 00:10:28,639 --> 00:10:31,960 every allegation in all of the preceding paragraphs as a 149 00:10:32,039 --> 00:10:35,639 fully set forth year in defending Ditty BB and Bad 150 00:10:35,639 --> 00:10:38,960 boy records, discriminated against plaintiff on the basis of her 151 00:10:39,039 --> 00:10:44,120 gender and violation of the nys HRL by subjecting plaintiff 152 00:10:44,120 --> 00:10:48,840 to disparate treatment, verbal abuse, systematic exclusion, failure to address 153 00:10:48,840 --> 00:10:54,360 complaints of discrimination, end lore, harassment, retaliation, derogatory gender based 154 00:10:54,399 --> 00:10:59,320 slurs and comments, insults, an offensive gender based language, intimidation 155 00:10:59,399 --> 00:11:04,120 and bullying threats, unfair treatment, and denial of opportunities, promotions, 156 00:11:04,320 --> 00:11:07,879 or benefits based on gender. As a direct and proximate 157 00:11:07,960 --> 00:11:12,360 result of defendants unlawful discriminatory conduct and violation of the 158 00:11:12,519 --> 00:11:16,679 nys HRL, Plaintiff is sustained and will continue to sustain 159 00:11:16,799 --> 00:11:21,000 monetary and economic harm, physical injury, pain and suffering, and 160 00:11:21,159 --> 00:11:27,120 serious psychological and emotional distress. Defendants unlawful and discriminatory actions 161 00:11:27,159 --> 00:11:31,120 were intentional, done with malice, and showed a deliberate, wilful, wanton, 162 00:11:31,480 --> 00:11:36,399 and reckless indifference to Plaintiff's rights under the nys HRL, 163 00:11:36,720 --> 00:11:40,159 for which plaintiff is entitled to an award of punitive damages. 164 00:11:40,879 --> 00:11:45,840 Defendant's continuous threats, coercion, and interference with plaintiff's career prevented 165 00:11:45,879 --> 00:11:49,519 plaintiff from asserting her rights within the statutorily prescribed period. 166 00:11:50,279 --> 00:11:53,919 Defendants should be eastop from asserting the Statute of Limitations 167 00:11:53,960 --> 00:11:57,480 as a defense due to the duress exerted upon plaintiff. 168 00:11:58,279 --> 00:11:59,799 All Right, we're going to wrap up right here, and 169 00:12:00,039 --> 00:12:01,960 in the next episode we're gonna pick up with the 170 00:12:02,000 --> 00:12:04,960 seventh cause of action. All of the information that goes 171 00:12:05,000 --> 00:12:08,759 with this episode, including my contact information, can be found 172 00:12:08,960 --> 00:12:10,600 in the description box.