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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 take a

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look at the lawsuit filed by Cowboys for Angels John

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Doe again Sean Diddy Combs case number one twenty five

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dash CV DASH zero one six five two dash Lap

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John Doe plaintiff for Shawn Combs, Garon James and Cowboys

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for Angels. Plaintiff John Doe, buying through his attorneys eisenbergen Baum,

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LLP hereby states his complaint against defending Shawn Combs, Garon James,

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and Cowboys for Angels alleged as follows based upon personal

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knowledge and information and belief. Preliminary statement in coordination with

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Garon James and his Cowboys for Angels Sewn Colmes ler

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John Doe to be sexually assaulted and then threaten them

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to stay quiet. You'd better not say a word to

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anybody about this. Do you hear me? I'm not fucking

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playing with you. If I can get a pock hit,

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what the fuck do you think can happen to you?

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Fearing for his life, John Doe affirmed that he would

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not say anything about the assault. Doll understood pac to

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refer to Tupac Shakur, a well known recording artist who

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was murdered. Given Colm's statement, Dough reasonably believed that Colms

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was capable of orchestrating similar harm to him. Sean Diddy

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Combs is one of the most powerful and influential figures

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in music. Media reports and public knowledge at the time

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suggested a potential connection between Seawan Colms and the murder

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of Tupac Shakur, contributing to the credibility of Colmb's threat

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in Dooe's mind. Dwayne Keith D Davis, charged with the

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nineteen ninety six shooting death of Tupac, has claimed that

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defendant offered him a million dollars to orchestrate the hit

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blast fall. Tupac's family hired a lawyer to investigate any

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connection between defendant and Tupac's murder, and another lawsuit alleges

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that defendant raped a woman with a remote control after

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she suggested he was involved with Tupac's murder. Due to

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colmb's credible threats and Doe's fear for his life, Doe

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is unable to immediately report the assault or pursue legal action.

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This fear constituted an extreme form of intimidation that prevented

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Doe from timely commencing in action. Colm's influence and power

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as a celebrity further amplified Doe's fear of retaliation even

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during the pendency of his criminal trial. This is not

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a vague or a speculative fear of harm. It is

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a direct, specific, and credible threat of lethal retaliation from

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a man with a documented history of violence and the

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resources parties. Plaintiff John Doe is an individual defending. Shawn

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Colmes is an individual. Defendant. Garon James is an individual

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defending Cowboys for Angels was at all relevant times a

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male companion service owned, operated, and are managed by defending

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Garon James. Jurisdiction and venue. This Court has some matter

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jurisdiction for the federal law claim under US Code twenty eight,

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section thirteen thirty one and thirteen forty three, because this

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action arises under the laws of the United States. This

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Court also has supplemental jurisdiction for state and common law

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claims under US Code twenty eight, section thirteen sixty seven,

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because the claims are substantially related to the federal law claim.

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Venue is proper in this district under US Code twenty eight,

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Section thirteen ninety one, because, among other things, the acts

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and omissions giving rise to this complaint occurred in this district.

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The statement of facts in twenty twelve, John Doe was

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an aspiring actor and model as well as the contractor

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for the male companion service Cowboys for Angels, based out

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of Florida. Prior to meeting Colmbs. Defendant Garran James instructed

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Doe to do everything that Combs asked without question, to

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never talk to anyone about his experience with Combs, that

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Colmbs was the service best client, and that Colms would

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either make or break Doe's career in the entertainment industry,

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in addition to lucrative financial compensation. After initially meeting Colmbs

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through his Male Companion service, Doe would travel from Florida,

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where he resides, to New York City at Colm's request.

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When Doe arrived at the Intercontinental Hotel in New York City,

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he was brought into a suite where Combs soon ordered

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Doe to perform sexual acts upon a female companion of Colms.

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During this time, Colmbs had Dough drink from a water

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bottle and then Colms rubbed baby oil all over Doe's body,

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one or both of which made Doe feel as if

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he had been drugged and not incomplete control of his body.

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Doe was directed by Colms to perform oral and penetrative

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sex on his female companion for multiple hours, degrading her

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and directing Doe to degrade and performed degrading acts upon her.

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After these acts concluded, Doe went to the bathroom. While

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in the bathroom, Colms entered and said, I really want

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you to stay. Let's turn up. Let's turn up. Dough

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reiterated that he was not feeling well and needed to leave.

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Colmbs replied, saying no, We're gonna have some fun and

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grab those penis while he began to simultaneously touch himself.

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Combs then let go a doze penis and began inserting

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his finger into Doez aenis. Without those consent, He continued

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the assault, pinning Dough of the wall and forcing his

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penis into those rectum. Dough continually told Colmbs to stop

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screaming no because he was in pain. Colmbs continued the

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assault for four to five minutes and forcibly anally raped Dough.

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When Colmbs removed his penis from those rectum. He began

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to threaten them, saying things like you better not say

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a word to anybody about this. Did you hear me?

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Though affirm that he had heard him. Colmbs then threatened

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to have him murdered. I'm not fucking playing with you.

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If I can get a pock hit, what the fuck

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do you think will happen to you? Doe, fearing for

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his life, again, affirmed that he would not say anything

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about the assault, though already reasonably feared for his life

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because his sexual assaulter was threatening to kill him immediately

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after raping him, and this was furthered because Doe was

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familiar with the allegations that Colms coordinated Tupac's murder. Indeed,

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Doe discussed the threat with other contractors within garyon James

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Companion Service, who agreed that Colms had a reputation of

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involvement in organized crime within the entertainment industry, a sexual deviant,

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and a person with a demonstrated ability to eliminate his opponents.

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Colmbs threatened Doe again by calling GARYN James. Colmb stated

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that he wanted to kill Doe. This threat and the

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threat alluding to Tupac Shakur caused Doe to refrain from

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timely raising civil suit against one of the most powerful

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figures in music. Don't feel safe coming forward, not only

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because Colmes is under the spotlight of law enforcement, but

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because Colms is in custody. In other words, Colmes is

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not the threat he was years ago. As soon as

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the indictment was released with the criminal trial scheduled, Doe

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felt that the threats ceased to be operational, especially with

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the spotlight on Colms and all of his criminal and

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civil cases. In addition to suffering severe emotional and psychological

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distress from defendant's assault, those ability to continue his business

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and earned income was adversely affected. Colm's actions by conspiring

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with Garon James to use a companion service as affront

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for sexual assault and threatening Dough into silence, directly interfered

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with and harmed those business and property interests as a contractor,

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an actor, and the model. Upon information and belief, defendant

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Garon James and his cowboy for Angel Service were fully

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knowledgeable about Comb's propensity for sexual violence, his intent to

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lure and subsequently assault plaintiff, and were implicit in cam

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sex trafficking a Doe and other vulnerable individuals. Doe did

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not learn of the criminal enterprise until the criminal trial

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began and witnesses testified, though otherwise had no knowledge or

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means to know the inner workings of the criminal enterprise,

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not at least until it became public at trial. Even

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the indictment was only an accusation given the traumatic events

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he experienced, though could not attend modeling or acting auditions

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and abstain from working for Garn James Companion Service for

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several weeks, losing unvaluable career opportunities, business reputation, and income.

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First cause of action violation of US Code section fifteen

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ninety one against all defendants, plain different repeats, reiterates, and

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realleges each in every allegation in detail above, as if

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set forth more fully and at length here in The

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Trafficking Victims Protection Act TVPA creates a civil remedy by

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victims against perpetrators and others who benefited financially from participation

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in a sex trafficking venture. See US Code eighteen, section

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fifteen ninety five. A TVPA claim must plead that the

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defendant knowingly benefits financially or by receiving anything about value

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from participation in a sex trafficking venture while knowing that

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means a force, threats of force, fraud, or coercion will

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be used to cause a person to engage in a

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commercial sex act. US Code eighteen, Section fifteen ninety one

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A two. In addition to traditional sex trafficking ventures such

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as forced prostitution, the TVPA equally applies a simpler and

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less sensational situation to defendants who have lured individuals under

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false pretenses and with lucrative promises for sexual purpose Noble

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versus Weinstein, three thirty five f. Dot supp three d

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five oh four five sixteen, and five SDNY twenty eighteen.

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To be clear, the TVPA does not require that exploitation

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be of a sexual nature, despite the fact that in

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this case Doe was sexually exploited. The mere fact that

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Doe was fraudulently hired by Calms under the pretext of

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serving as a male companion for the purpose of Calms

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James and Cowboys Angels benefit is enough to establish dough

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with traffic by defendant. Indeed, Congress noted that trafficking in

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persons is not limited to the sex industry, and that

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traffickers lure people into their networks through false promises of

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decent working conditions at relatively good pay as Nanni's maids, dancers,

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factory workers, restaurant workers, sales clerks, or models. Noble three

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thirty five dot supp three d at five fourteen, citing

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Publication l number one oh six through three eighty six,

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Section one O two one fourteen, Statute fourteen eighty eight. Here,

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by working with Cowboys for Angels, Dough had no expectation

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that he would be raped, drugged against his will, or

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forbidden from leaving. Meanwhile, that is exactly what all defendants

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expected and planned. Benefiting from this heinous enterprise. Do was

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misled by James and Cowboys for Angels into believing that

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he was being hired for a typical and consensual escorting encounter.

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In reality, Doe was sex trafficked for the purpose of

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being drugged and sexually assaulted. Based on the instructions Dough

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received from Garon James, encouraging him to do whatever Colmbs said,

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to never tell anybody about his encounter with Combs, and

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that Combs was somehow the agency's best client. It's clear

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that James and Cowboys for Angels had an ulterior agreement

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with Combs involving sex with Doe and other male companions.

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The circumstances of Doe's rape are even more dispositive of trafficking.

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Dough was misled into believing that he was being hired

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for a typical consensual escorting encounter. In truth, however, Dough

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was sex traffic for a bizarre and very unusual encounter

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where he was drugged against his will and ultimately raped.

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In twenty eighteen, though William Wilberforce Trafficking Victims Protection Reauthorization

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Act tv PR two thousand and eight amended the statue

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to create a criminal enforcement mechanism against traffickers who recklessly

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dis regard that a business venture has engaged in the

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providing or obtaining of services through force, fraud, or coercion.

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This expands aforementioned civil cause of action under US Code

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eight section fifteen ninety five by victims against individuals who

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benefit or attempt or conspire to benefit from trafficking by

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overlooking red flags and concerning behaviors, but are not themselves.

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The traffickers defending Cowboy for Angels, along with Intercontinental Hotel,

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recklessly disregarded the telltale signs of trafficking and the intent

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to obtain commercial sex through force, fraud or coercion, as

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Doe was hired with the understanding that he was not

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expected to perform sex acts or remove clothing, and was

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only contracted to attend dates with women. However, Combs was

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able to develop sexually violent criminal reputation among male companions

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within Cowboys for Angels, showing that Combs and Cowboys for

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Angels established a pattern of selling sex with male companions

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through force, fraud or coercion. Colms frequently traveled to different

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states and had plaintiff travel interstate under the guise of

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a valid business transaction. On beknownsta plaintiff, Colms actually intended

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to sexually assault plaintiff. Instead, Calms knew that he would

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use the contractor's service for which plaintiff worked in order

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to create a pretext for him to meet with plaintiff

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for business related purposes, used fraud, physical force, or coercion

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to force sexual encounters without Plaintiff's consent. Colms traveled in

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interstate and foreign commerce, knowingly recruiting and enticing plaintiff offering

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him something of value through the companion service, knowing that

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he would use these offers as a means to coerce

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plaintiff to have private business meetings with Colms and then

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use fraud, intimidation, force, and or coercion into force sexual

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encounters without Plaintiff's consent. Thus, Calms knowingly affected interstate commerce

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by recruiting, enticing, transporting, and soliciting plaintiff, knowing that he

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intended to and did perform a commercial sex act on

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plaintiff without Plaintiff's consent. The other defendants knowingly participated in

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Colmb's venture and violation of US Code eighteen, Section fifteen

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ninety one by knowingly benefiting from, facilitating, and receiving value

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for the adventure in which Colmes traveled, in or utilized

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foreign and interstate commerce, with knowing or in reckless disregard

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of the facts that Colmbs would defraud, force, and or

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coerce sexual encounters from individuals seeking to do business with

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defendant James and Cowboys for Angels. Defendants each coordinated to

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form a venture that coerce, transported, and harbored plaintiff, either

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with knowledge or in reckless disregard for the fact that

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Colmes would use threats, means of force and coercion to

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force plaintiff into a commercial sex act. The other defendants

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knew or were in reckless disregard of the fact that

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it was an established pattern and practice of Defendant Calm

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to travel or have others travel in interstate and foreign

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commerce to lure individuals such as plaintiff into fraudulent, forced,

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or coerce pretectual business meetings that, unbeknownst a plaintiff, would

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lead to forced sexual acts. Despite this knowledge, these defendants

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continued to facilitate Calm sex trafficking venture while knowing or

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recklessly disregarding the fact that he would seek to coerce

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the fraud and or force sexual activity in the guise

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of escort work. As a result, Plaintiff experienced injury in

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the form of severe emotional pain and suffering emotional distress

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and humiliation for the reasons alleged above. Plaintiff sees compensatory

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and punitive damages at an amount to be determined at trial,

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and an award of attorney fees, costs, and disbursements. Second

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cause of action violation of New York's VGMVPL against Defendant

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Calms only under New York City's Victims of Gender Motivated

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Protection Law, VGMVPL survivors ASSAI actual abuse have a two

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year window to file claims over gender motivated assaults that

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occurred at any time in the past. The window opens

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on March first, twenty twenty three, and closes on March first,

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twenty twenty five. The VGMVPL provides a civil cause of

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action to any person claiming to be injured by a

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party who commits, directs, enables, participates in, or conspires in

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the commission of a crime of violence motivated by gender.

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Title eight NYC Admin Code, Section ten Tosh eleven O four.

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The term crime of violence is expressly defined to mean

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an act or a series of acts that would constitute

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a misdemeanor or felony against the person as defined in

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state or federal law, or that would constitute a misdemeanor

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or felony against property is defined in state or federal law,

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if the conduct presents a serious risk of physical injury

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to another, whether or not those acts have actually resulted

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in criminal charges, prosecution, or conviction. As set forth, the above

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combs sexually assaulted plaintiff, and this would not have occurred

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had plaintiff been female. Colms got pleasure from hurting himself

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in the form of watching other men have raunchy sex

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with his girlfriend, but then would need to dominate and

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reclaim his girlfriend and then dominate and claim the man

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who had the raunchy sex with her. Put another way,

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Colmbs exhibited a cycle of self punishment followed by lashing

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out in the form of dominating claiming the ones that

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punished them. Specifically, here, Combs would masturbate while watching and

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directing his girlfriend and other men to have sex and

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do specific sex sex. After a session like that ended

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after many hours, Colmbs would have sex with his girlfriend

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in another room. In the last encounter, Colmbs also raped

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Doe in the bathroom after having sex with his girlfriend.

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In any event, sexual assault is presumed to be committed

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with animus for a purpose of the VGMVPL for the

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reasons alleged above, Plaintiff seized compets into and punitive damages

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in an amount to be decided at trial, and an

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award of attorney fees, costs, and disbursements. Third cause of

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action common law sexual assault, battery and or rape against

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defendant calms only plaintiff realleges and incorporates the preceding paragraphs

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00:18:17,599 --> 00:18:21,000
as a fully set fourth here in Colm's intentionally attempted

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without authority or consent to harm and or offensively contact plaintiff,

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and this attempt reasonably plays Plaintiff in fear and apprehension

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00:18:29,799 --> 00:18:33,599
of such harm and offensive contact, which conduct approximately caused

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00:18:33,599 --> 00:18:38,680
them injury and damage. A harmful, offensive, unprivileged, and unpermitted

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00:18:38,720 --> 00:18:42,240
contact with plaintiff actually occurred as a result of this conduct.

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As a result, Plaintiff has experienced and will continue to experience,

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emotional anguish, pain and suffering, and loss of dignity damages.

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00:18:52,039 --> 00:18:55,839
Colmb's conduct was malicious, wanton, and wilful for the reasons

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alleged above. Plaintiff seeks competantory and punitive damages in an

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amount of determined that trial and an award of attorney fees, costs,

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and disbursements. Fourth cause of action intentional infliction of emotional

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distress against all defendants. Plaintiff re alleges and incorporates the

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preceding paragraphs as a fully set fourth year in Comb's

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conduct and assault and battery of plaintiff described above, facilitated

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by defendant James and Cowboy for Angels, was intentional, shocking, unreasonable,

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and highly offensive which caused severe and debilitating emotional distress

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for plaintiff. Defendant's conduct was malicious, wanton, and willful. Accordingly,

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Plaintiffs seeks compensatory and punitive damages in an amount to

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be determined at trial, and an award of attorney fees, costs,

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00:19:43,079 --> 00:19:48,400
and disbursements. Fifth cause of action violations of Racketeer Influenced

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and Corrupt Organizations Act against all defendants. Plaintiff realleges and

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00:19:53,240 --> 00:19:56,559
incorporates the preceding paragraph as a fully set fourth year

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in the Racketeer Influenced and Corrupt Organizations Act. US Code eight,

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section nineteen sixty one prohibits any racketeering activity. At the

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time of colmb's assault, Plaintiff was engaged as a contractor

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for mail companion service based in Florida. Combs utilized this

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mail companion service to establish contact with plaintiff, initially presenting

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their interactions as legitimate business transactions. Colms arranged for plaintiff

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to travel interstate from Florida to New York City under

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the false pretense of these business related meetings. COLMS knowingly

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recruited and enticed plaintiff offering something of value through the

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companion service with the intent to correse Plaintiff in the

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non consensual sexual encounters. The continued use of the mail

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companion service and the interstate travel arrangements by COLMS constituted

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00:20:47,839 --> 00:20:51,200
a pattern of racketeering activity where the service was used

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as a means to commit sexual assault and sex trafficking

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in violation of US Code eighteen, section fifteen ninety one.

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See US Code eight section nineteen sixty one, including among

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the definitions of racketeering activity any violation of US Code eighteen,

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section fifteen eighty one through fifteen ninety two relating to

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pe andage slavery and trafficking in persons. Defendant Garon James

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00:21:16,759 --> 00:21:19,559
and Cowboys for Angels were at all times aware and

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complicit in this racketeering activity. Plaintiff only learned of this

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racketeering activity, that is, the inner workings of Comb's criminal

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enterprise that caused him to be trafficked and then raped,

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after the filing of the criminal indictment against Colmb's honor

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about September twenty twenty four. Plaintiff's ability to continue his

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00:21:37,279 --> 00:21:41,559
business and earn income was directly affected by Comb's racketeering activity.

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00:21:42,119 --> 00:21:45,799
Comb's actions by using the Companion Service as affront for

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00:21:45,920 --> 00:21:50,079
sexual assault, directly interfered with and harmed Plaintiff's business and

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00:21:50,200 --> 00:21:53,839
property interests as a contractor and also as a professional

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model and actor. Given the traumatic events he experienced, though

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00:21:57,799 --> 00:22:01,400
could not attend modeling or acting auditions and abstain from

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00:22:01,440 --> 00:22:07,279
Companion Services for several weeks, losing unvaluable career opportunities, business reputation,

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00:22:07,720 --> 00:22:12,720
and income. Accordingly, plaintiff seeks all available remedies pursuant to

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00:22:12,920 --> 00:22:17,039
US Code eighteen, Section nineteen sixty four C six cause

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00:22:17,039 --> 00:22:20,519
of action violation of New York's Trafficking Victims Protection Act

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against all defendants. Plaintiff repeats, reiterates, and realleges each and

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every allegation set in detail above, as if set fourth

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00:22:28,599 --> 00:22:32,519
more fully and at length herein New York's Trafficking Victims

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Protection and Justice Act, New York Social Service Law, Section

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forty three BBC I creates a civil cause of action

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for victims of both labor and sex trafficking, specifically providing

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that an individual who is a victim of the conduct

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prohibited by section two thirty dot three three two thirty

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dot three four two thirty three four A one thirty

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five dot three five or one three five dot three

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seven of the Penal Law may bring civil action against

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the purpse trader or whoever knowingly advances or profits from,

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or whoever should have known he or she was advancing

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00:23:07,799 --> 00:23:10,799
or profiting from an act in violation as section two

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00:23:10,799 --> 00:23:14,039
thirty dot thirty three, two thirty dot thirty four, two

359
00:23:14,039 --> 00:23:17,039
thirty dot thirty four a one thirty five dot thirty five,

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or one thirty five dot thirty seven of the Penal

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Law to recover actual, compensatory and punitive damages injunct of relief,

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any combination of those, or any other appropriate relief, as

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well as reasonable attorney fees. In turn, NY Penal Laws

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Section one thirty five dot three five prohibits labor trafficking

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and NY Penal Law two thirty dot thirty four prohibit

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sex trafficking. Colmbs is the perpetrator, and his conduct towards

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plaintiff described above constitutes labor and or sex trafficking and

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violation of New York's tv PJA. Karen James and Cowboys

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00:23:53,720 --> 00:23:57,200
for Angels each knowingly advanced and or profited from the

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trafficking venture while knowing or in recklessess regard of the

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00:24:00,599 --> 00:24:04,440
fact that Comb's conduct violated and why Penal Laws section

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00:24:04,480 --> 00:24:07,799
one thirty five dot three five and two thirty three four.

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As a result, plaintiff experienced injury in the form of

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00:24:11,599 --> 00:24:16,839
severe emotional pain and suffering emotional distress and humiliation for

375
00:24:16,880 --> 00:24:21,160
the reasons alleged above. Plaintiff cease competantory and punitive damages,

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00:24:21,680 --> 00:24:24,319
an amount to be determined by trial, and an award

377
00:24:24,319 --> 00:24:29,359
of attorney fees, costs and disbursements prayer for relief. Wherefore,

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Plaintiff respectfully praised at the Court grant the following relief

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against defendants, a enter judgment against defendants, and an award

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of damages, including but not limited to, competentory damages for

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emotional distress, nominal, punitive and or exemplary damages, attorney fees,

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pre impose judgment interest in an amount to be determined

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at trial by a jury, and b any further relief.

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This Court deems just and proper. This document was dated

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June sixteenth, twenty twenty five, and it was signed by

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Adriana al Kalbi. All of the information that goes with

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this episode can be found in the description box