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Speaker 1: What's up, everyone, and welcome to another episode of The

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Diddy Diaries. In this episode, we're going to get right

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back to the Sarah Rivers lawsuit filed against Ditty and

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we're picking up with the seventh cause of action sexual harassment,

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gender discrimination and hostile work environment under New York City

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Human Rights Law and why Executive Law Section eight Dash

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one oh one and y CHURL against defendant Ditty BB,

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Bad Boy Records. Plaintiff repeats and realleges each and every

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allegation in all of the preceding paragraphs as a fully

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set forth here in, Defendants Didty BB and Bad Boy

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Records discriminated against plaintiff on the basis of her gender

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and violation of the NYCCHRL by subjecting plaintiff to one

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wanted touching of her intimate parts, enforcing plaintiff to endure

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derogatory name calling, constituting a hostile work environment. Defendants engaged

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in a pattern of criminal conduct in the workplace that

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created an offensive, intimidating, and hostile atmosphere for plaintiff based

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on her gender. As a direct and approximate result of

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defendants unlawful discriminatory conduct and violation of the nyc HRL,

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Plaintiff has sustained and will continue to sustain monetary damages,

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end or economic harm, physical injury, pain and suffering, and

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serious psychological and emotional distress. Defendants unlawful and discriminatory actions

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were intentional, done with malice, and or showed a deliberate, wilful, wanton,

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and reckless indifference to the plaintiff's rights under the nyc HRL,

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for which plaintiff is entitled to an award of punitive damages.

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Defendants continuous threats, coercion, and interference with Plaintiff's career prevented

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plaintiff from asserting her rights within the statutorily prescribed period.

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Defendants should be stopped from asserting the Statute of limitations

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as a defense due to the duress exerted upon plaintiff.

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Eighth cause of action retaliation and violation of New York

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State Human Rights Law n ysh ROL Section two ninety

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six against defendant Ditty BB and bad Boy Records. Plaintiff

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repeats and realleges each and every allegation in all of

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the preceding paragraphs, as if fully set. Fourth here in

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Plaintiff engaged in protected activity by rejecting defendant sexual advances,

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which constitutes opposition to unlawful sexual harassment under New York

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State Human Rights Law Section two ninety six. This rejection

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is protected activity under the nys HRL as it opposes

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discriminatory conduct in the workplace. Defendant Didty Bb and bad

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Boy records. Persistent denial of prominent or continuing singing, writing

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performing roles as to plaintiff constitutes adverse employment actions. Plaintiff's

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rejection of defendant Ditty sexual advances subjected her to an

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increasingly hostile work environment based on her gender. These actions

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materially and trimentally affected Plaintiff's terms and conditions of employment

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and were in direct response to plaintiff's protected activity of

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rejecting defendants sexual advances. Further, defendants failure to pay plaintiffs

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earned wages, royalties, and concert and promotional appearance fees according

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to contracts and other promises constitutes adverse employment actions based

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on gender and were done in retaliation by defendants. There

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is a direct casual connection between plaintiffs protected activity and

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defendants adverse employment actions. The timing and circumstances indicate defendants

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retaliatory motives As a direct and proximate result of defendants retaliation.

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Plaintiff is sustained and will continue to sustain monetary damages

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and or economic harm, physical injury, pain and suffering, and

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serious psychological and emotional distress. Defendants unlawful and retaliatory actions

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were intentional, done with malice, and are showed a deliberate, wilful, wanton,

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and reckless indifference to Plaintiff's rights under the NYSHRL, for

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which plaintiff is entitled to an award of punitive damages.

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Defendant's continuous threats, coercion, and interference with Plaintiff's career prevented

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plaintiff from asserting her rights. Defendants should be e stop

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from asserting the Statute of limitations as a defense due

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to the duress exerted upon plaintiff. Ninth cause of action

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violation of right of publicity under New York Rights Civil

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Law Section fifty and fifty one and on Justin Richmond

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against defendant bb Didty, Bad Boy Records, UMG, bm MTV, VIACOM,

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Paramount Janis, JCP, JCPH, and King Plaintiff repeats and realleges

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each in every allegation in all of the preceding paragraphs.

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As a fully set fourth year in defendant didty required

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Plaintiff to perform at and attend numerous promotional events and

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interviews as part of mtb V twos group the band,

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including later overnight parties, which runder contract between defendant Ditty

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and defendant's MTV, BM VIACOM and or UMG. Defendant knowingly

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used Plaintiff's voice, likeness, image, and persona without Plaintiff's consent

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for advertising and promotion purposes and for the purpose of trade.

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Defendants have been unjustly enriched at plaintiff's expense by using

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plaintiff's voice, image, likeness, and persona without compensating plaintiff. It

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would be inequitable for defendant to retain the benefit conferred

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by unauthorized use of Plaintiff's voice, image, likeness, and persona.

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As a result of defendants on authorized use of Plaintiff's likeness, image,

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and persona, Plaintiffs suffered damages and is entitled to restitution

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in an amount to be determined at trial. Defendants continue

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as threats, coercion, and interference with plaintiff's career prevented plaintiff

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from asserting her rights defendants should be easy stop from

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asserting the statute of limitations as a defense due to

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the duress exerted upon Plaintiff. The tenth cause of action

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copyright infringement US Code seventeen, Section one oh six against

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defendant Diddy, BB, Bad Boy Records, UMG, BM MTV, VIACOM, Paramount, Janis, JCP,

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and JCPH. Plaintiff repeats and realleges each and every allegation

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in all of the preceding paragraphs as if fully set.

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Fourth here In, Plaintiff wrote, created and performed the music

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composition in sound recordings on the album to Offer TV,

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the song why on the Bad Boy two soundtrack, and

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two theme songs for the television show MTB two seasons

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two and three. The compositions and recordings of the above

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were published by defendants absent agreement on terms. Thus, defendants

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have no signed or enforceable agreement with plaintiff. Plaintiff believes

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that Defendant Diddy, BBE, Janis, JCP and or JCP register

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the musical composition and sound recording pertinent thereto with a

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register of copyrights and receive the certificate of registration. Therefore,

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Plaintiff is the rightful owner of the copyrights in the

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musical composition, rights of performance therein, and the exclusive rights

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to reproduce and distribute to the public by sale or

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other transfer of ownership or by lease lending her license

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reproductions of the copyrighted works under Copyright Acts seventeen US Code,

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Section one oh six, Plaintiff, upon information and belief, believes

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defendants and each of them knowingly and willfully and without

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securing Plaintiff's permission or license embodied, adapted, used, reproduced, marketed, distributed,

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and sold plaintiff stolen copyrighted material on the Bad Boy

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two soundtrack. Accordingly, Plaintiff alleges her acclaim for copyright infringement

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based on each defendant publication of Plaintiff's copyrighted musical composition

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without license, permission, or approval, and if such work was

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with a license, that license was obtained fraudulently. Each defendant

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unquestionably had access to Plaintiff's work through defendants previous companies,

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bad Boy Records, etc. Or other of defendants holders of

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recorded compositions, and each defendant knowingly and willfully irratified and

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confirms that access thereafter in undertaking the conduct complained of

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in this action, defendants knowingly and intentionally violated Plaintiff's rights.

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At no time did Plaintiff authorize defendants to use, license, own, reproduce, adapt,

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or distribute Plaintiff's copyrighted material. At the times of the

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acts of infringement complained of, Plaintiff was and is the

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rightful owner of the copyright in the music composition identified

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and named above. After the respective dates of the first

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publication and continuing to the present, the defendants in each

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of them have infringed and continue to infringe inge Plaintiff's

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copyrights in the music composition by reproducing or causing, contributing to,

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and participating in the unauthorized reproduction of the copyrighted material composition,

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and by causing, contributing to, and participating in the distribution

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of the unauthorized reproductions of the music composition as recorded

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to the public. Despite their actual or constructive knowledge through

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their individual and collective recording industry experience and knowledge of

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copyright laws, enforcement of intellectual property rights in other instances,

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and their duties to view and examine licenses for uses

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of copyrighted works, defendants have used and promoted, and continue

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to use and promote reproduce and to enable others to

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reproduce Plaintiff's copyrighted music composition and its complete or substantial

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entirety as and for the commercial profit of defendants without

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any ongoing payment to or authorization by Plaintiff. Ie no

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accountings have been re received. As a direct and proximate

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result of defendants knowing and wilful infringing use of the copyrights,

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Plaintiff has sustained, and will continue to sustain, substantial injury, loss,

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and damage to our ownership, publishing, and performing rights in

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our own composition, which is copyrighted material as a result

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of all defendants joint several wilful and deliberate acts of

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copyright infringement. Plaintiff is further entitled to recover from defendants

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all of the damages sustained by plaintiff permitted by federal

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copyright law, including but not limited to, competentory damages, and

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the profits derived by defendants as a result other infringing acts,

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in an amount to be determined according to proof of trial.

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Plaintiff is further entitled to recover from defendants the gains, profits,

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and advantages defendants and each of them have obtained as

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a result of their acts of copyright infringement. Plaintiff is

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entitled to the maximum statutory damages which copyright registration confer

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upon a copyright owner pursuing the US Code seventeen, section

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five O four C, in the amount of one hundred

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and fifty thousand dollars with respect to each defendant for

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each work infringed, or for such other amounts as may

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be proper under US Code seventeen, section five O four C.

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All Right, folks, we're going to wrap up right here,

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and in the next episode, we're going to pick up

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where we left off, and that's with the eleventh cause

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of action. All of the information that goes with this episode,

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including my contact information, can be found in the description box.