Speaker 1: What's up everyone, and welcome to another episode of The
Diddy Diaries. In this episode, we're going to take a
look at the lawsuit filed by Cowboys for Angels John
Doe again Sean Diddy Combs case number one twenty five
dash CV DASH zero one six five two dash Lap
John Doe plaintiff for Shawn Combs, Garon James and Cowboys
for Angels. Plaintiff John Doe, buying through his attorneys eisenbergen Baum,
LLP hereby states his complaint against defending Shawn Combs, Garon James,
and Cowboys for Angels alleged as follows based upon personal
knowledge and information and belief. Preliminary statement in coordination with
Garon James and his Cowboys for Angels Sewn Colmes ler
John Doe to be sexually assaulted and then threaten them
to stay quiet. You'd better not say a word to
anybody about this. Do you hear me? I'm not fucking
playing with you. If I can get a pock hit,
what the fuck do you think can happen to you?
Fearing for his life, John Doe affirmed that he would
not say anything about the assault. Doll understood pac to
refer to Tupac Shakur, a well known recording artist who
was murdered. Given Colm's statement, Dough reasonably believed that Colms
was capable of orchestrating similar harm to him. Sean Diddy
Combs is one of the most powerful and influential figures
in music. Media reports and public knowledge at the time
suggested a potential connection between Seawan Colms and the murder
of Tupac Shakur, contributing to the credibility of Colmb's threat
in Dooe's mind. Dwayne Keith D Davis, charged with the
nineteen ninety six shooting death of Tupac, has claimed that
defendant offered him a million dollars to orchestrate the hit
blast fall. Tupac's family hired a lawyer to investigate any
connection between defendant and Tupac's murder, and another lawsuit alleges
that defendant raped a woman with a remote control after
she suggested he was involved with Tupac's murder. Due to
colmb's credible threats and Doe's fear for his life, Doe
is unable to immediately report the assault or pursue legal action.
This fear constituted an extreme form of intimidation that prevented
Doe from timely commencing in action. Colm's influence and power
as a celebrity further amplified Doe's fear of retaliation even
during the pendency of his criminal trial. This is not
a vague or a speculative fear of harm. It is
a direct, specific, and credible threat of lethal retaliation from
a man with a documented history of violence and the
resources parties. Plaintiff John Doe is an individual defending. Shawn
Colmes is an individual. Defendant. Garon James is an individual
defending Cowboys for Angels was at all relevant times a
male companion service owned, operated, and are managed by defending
Garon James. Jurisdiction and venue. This Court has some matter
jurisdiction for the federal law claim under US Code twenty eight,
section thirteen thirty one and thirteen forty three, because this
action arises under the laws of the United States. This
Court also has supplemental jurisdiction for state and common law
claims under US Code twenty eight, section thirteen sixty seven,
because the claims are substantially related to the federal law claim.
Venue is proper in this district under US Code twenty eight,
Section thirteen ninety one, because, among other things, the acts
and omissions giving rise to this complaint occurred in this district.
The statement of facts in twenty twelve, John Doe was
an aspiring actor and model as well as the contractor
for the male companion service Cowboys for Angels, based out
of Florida. Prior to meeting Colmbs. Defendant Garran James instructed
Doe to do everything that Combs asked without question, to
never talk to anyone about his experience with Combs, that
Colmbs was the service best client, and that Colms would
either make or break Doe's career in the entertainment industry,
in addition to lucrative financial compensation. After initially meeting Colmbs
through his Male Companion service, Doe would travel from Florida,
where he resides, to New York City at Colm's request.
When Doe arrived at the Intercontinental Hotel in New York City,
he was brought into a suite where Combs soon ordered
Doe to perform sexual acts upon a female companion of Colms.
During this time, Colmbs had Dough drink from a water
bottle and then Colms rubbed baby oil all over Doe's body,
one or both of which made Doe feel as if
he had been drugged and not incomplete control of his body.
Doe was directed by Colms to perform oral and penetrative
sex on his female companion for multiple hours, degrading her
and directing Doe to degrade and performed degrading acts upon her.
After these acts concluded, Doe went to the bathroom. While
in the bathroom, Colms entered and said, I really want
you to stay. Let's turn up. Let's turn up. Dough
reiterated that he was not feeling well and needed to leave.
Colmbs replied, saying no, We're gonna have some fun and
grab those penis while he began to simultaneously touch himself.
Combs then let go a doze penis and began inserting
his finger into Doez aenis. Without those consent, He continued
the assault, pinning Dough of the wall and forcing his
penis into those rectum. Dough continually told Colmbs to stop
screaming no because he was in pain. Colmbs continued the
assault for four to five minutes and forcibly anally raped Dough.
When Colmbs removed his penis from those rectum. He began
to threaten them, saying things like you better not say
a word to anybody about this. Did you hear me?
Though affirm that he had heard him. Colmbs then threatened
to have him murdered. I'm not fucking playing with you.
If I can get a pock hit, what the fuck
do you think will happen to you? Doe, fearing for
his life, again, affirmed that he would not say anything
about the assault, though already reasonably feared for his life
because his sexual assaulter was threatening to kill him immediately
after raping him, and this was furthered because Doe was
familiar with the allegations that Colms coordinated Tupac's murder. Indeed,
Doe discussed the threat with other contractors within garyon James
Companion Service, who agreed that Colms had a reputation of
involvement in organized crime within the entertainment industry, a sexual deviant,
and a person with a demonstrated ability to eliminate his opponents.
Colmbs threatened Doe again by calling GARYN James. Colmb stated
that he wanted to kill Doe. This threat and the
threat alluding to Tupac Shakur caused Doe to refrain from
timely raising civil suit against one of the most powerful
figures in music. Don't feel safe coming forward, not only
because Colmes is under the spotlight of law enforcement, but
because Colms is in custody. In other words, Colmes is
not the threat he was years ago. As soon as
the indictment was released with the criminal trial scheduled, Doe
felt that the threats ceased to be operational, especially with
the spotlight on Colms and all of his criminal and
civil cases. In addition to suffering severe emotional and psychological
distress from defendant's assault, those ability to continue his business
and earned income was adversely affected. Colm's actions by conspiring
with Garon James to use a companion service as affront
for sexual assault and threatening Dough into silence, directly interfered
with and harmed those business and property interests as a contractor,
an actor, and the model. Upon information and belief, defendant
Garon James and his cowboy for Angel Service were fully
knowledgeable about Comb's propensity for sexual violence, his intent to
lure and subsequently assault plaintiff, and were implicit in cam
sex trafficking a Doe and other vulnerable individuals. Doe did
not learn of the criminal enterprise until the criminal trial
began and witnesses testified, though otherwise had no knowledge or
means to know the inner workings of the criminal enterprise,
not at least until it became public at trial. Even
the indictment was only an accusation given the traumatic events
he experienced, though could not attend modeling or acting auditions
and abstain from working for Garn James Companion Service for
several weeks, losing unvaluable career opportunities, business reputation, and income.
First cause of action violation of US Code section fifteen
ninety one against all defendants, plain different repeats, reiterates, and
realleges each in every allegation in detail above, as if
set forth more fully and at length here in The
Trafficking Victims Protection Act TVPA creates a civil remedy by
victims against perpetrators and others who benefited financially from participation
in a sex trafficking venture. See US Code eighteen, section
fifteen ninety five. A TVPA claim must plead that the
defendant knowingly benefits financially or by receiving anything about value
from participation in a sex trafficking venture while knowing that
means a force, threats of force, fraud, or coercion will
be used to cause a person to engage in a
commercial sex act. US Code eighteen, Section fifteen ninety one
A two. In addition to traditional sex trafficking ventures such
as forced prostitution, the TVPA equally applies a simpler and
less sensational situation to defendants who have lured individuals under
false pretenses and with lucrative promises for sexual purpose Noble
versus Weinstein, three thirty five f. Dot supp three d
five oh four five sixteen, and five SDNY twenty eighteen.
To be clear, the TVPA does not require that exploitation
be of a sexual nature, despite the fact that in
this case Doe was sexually exploited. The mere fact that
Doe was fraudulently hired by Calms under the pretext of
serving as a male companion for the purpose of Calms
James and Cowboys Angels benefit is enough to establish dough
with traffic by defendant. Indeed, Congress noted that trafficking in
persons is not limited to the sex industry, and that
traffickers lure people into their networks through false promises of
decent working conditions at relatively good pay as Nanni's maids, dancers,
factory workers, restaurant workers, sales clerks, or models. Noble three
thirty five dot supp three d at five fourteen, citing
Publication l number one oh six through three eighty six,
Section one O two one fourteen, Statute fourteen eighty eight. Here,
by working with Cowboys for Angels, Dough had no expectation
that he would be raped, drugged against his will, or
forbidden from leaving. Meanwhile, that is exactly what all defendants
expected and planned. Benefiting from this heinous enterprise. Do was
misled by James and Cowboys for Angels into believing that
he was being hired for a typical and consensual escorting encounter.
In reality, Doe was sex trafficked for the purpose of
being drugged and sexually assaulted. Based on the instructions Dough
received from Garon James, encouraging him to do whatever Colmbs said,
to never tell anybody about his encounter with Combs, and
that Combs was somehow the agency's best client. It's clear
that James and Cowboys for Angels had an ulterior agreement
with Combs involving sex with Doe and other male companions.
The circumstances of Doe's rape are even more dispositive of trafficking.
Dough was misled into believing that he was being hired
for a typical consensual escorting encounter. In truth, however, Dough
was sex traffic for a bizarre and very unusual encounter
where he was drugged against his will and ultimately raped.
In twenty eighteen, though William Wilberforce Trafficking Victims Protection Reauthorization
Act tv PR two thousand and eight amended the statue
to create a criminal enforcement mechanism against traffickers who recklessly
dis regard that a business venture has engaged in the
providing or obtaining of services through force, fraud, or coercion.
This expands aforementioned civil cause of action under US Code
eight section fifteen ninety five by victims against individuals who
benefit or attempt or conspire to benefit from trafficking by
overlooking red flags and concerning behaviors, but are not themselves.
The traffickers defending Cowboy for Angels, along with Intercontinental Hotel,
recklessly disregarded the telltale signs of trafficking and the intent
to obtain commercial sex through force, fraud or coercion, as
Doe was hired with the understanding that he was not
expected to perform sex acts or remove clothing, and was
only contracted to attend dates with women. However, Combs was
able to develop sexually violent criminal reputation among male companions
within Cowboys for Angels, showing that Combs and Cowboys for
Angels established a pattern of selling sex with male companions
through force, fraud or coercion. Colms frequently traveled to different
states and had plaintiff travel interstate under the guise of
a valid business transaction. On beknownsta plaintiff, Colms actually intended
to sexually assault plaintiff. Instead, Calms knew that he would
use the contractor's service for which plaintiff worked in order
to create a pretext for him to meet with plaintiff
for business related purposes, used fraud, physical force, or coercion
to force sexual encounters without Plaintiff's consent. Colms traveled in
interstate and foreign commerce, knowingly recruiting and enticing plaintiff offering
him something of value through the companion service, knowing that
he would use these offers as a means to coerce
plaintiff to have private business meetings with Colms and then
use fraud, intimidation, force, and or coercion into force sexual
encounters without Plaintiff's consent. Thus, Calms knowingly affected interstate commerce
by recruiting, enticing, transporting, and soliciting plaintiff, knowing that he
intended to and did perform a commercial sex act on
plaintiff without Plaintiff's consent. The other defendants knowingly participated in
Colmb's venture and violation of US Code eighteen, Section fifteen
ninety one by knowingly benefiting from, facilitating, and receiving value
for the adventure in which Colmes traveled, in or utilized
foreign and interstate commerce, with knowing or in reckless disregard
of the facts that Colmbs would defraud, force, and or
coerce sexual encounters from individuals seeking to do business with
defendant James and Cowboys for Angels. Defendants each coordinated to
form a venture that coerce, transported, and harbored plaintiff, either
with knowledge or in reckless disregard for the fact that
Colmes would use threats, means of force and coercion to
force plaintiff into a commercial sex act. The other defendants
knew or were in reckless disregard of the fact that
it was an established pattern and practice of Defendant Calm
to travel or have others travel in interstate and foreign
commerce to lure individuals such as plaintiff into fraudulent, forced,
or coerce pretectual business meetings that, unbeknownst a plaintiff, would
lead to forced sexual acts. Despite this knowledge, these defendants
continued to facilitate Calm sex trafficking venture while knowing or
recklessly disregarding the fact that he would seek to coerce
the fraud and or force sexual activity in the guise
of escort work. As a result, Plaintiff experienced injury in
the form of severe emotional pain and suffering emotional distress
and humiliation for the reasons alleged above. Plaintiff sees compensatory
and punitive damages at an amount to be determined at trial,
and an award of attorney fees, costs, and disbursements. Second
cause of action violation of New York's VGMVPL against Defendant
Calms only under New York City's Victims of Gender Motivated
Protection Law, VGMVPL survivors ASSAI actual abuse have a two
year window to file claims over gender motivated assaults that
occurred at any time in the past. The window opens
on March first, twenty twenty three, and closes on March first,
twenty twenty five. The VGMVPL provides a civil cause of
action to any person claiming to be injured by a
party who commits, directs, enables, participates in, or conspires in
the commission of a crime of violence motivated by gender.
Title eight NYC Admin Code, Section ten Tosh eleven O four.
The term crime of violence is expressly defined to mean
an act or a series of acts that would constitute
a misdemeanor or felony against the person as defined in
state or federal law, or that would constitute a misdemeanor
or felony against property is defined in state or federal law,
if the conduct presents a serious risk of physical injury
to another, whether or not those acts have actually resulted
in criminal charges, prosecution, or conviction. As set forth, the above
combs sexually assaulted plaintiff, and this would not have occurred
had plaintiff been female. Colms got pleasure from hurting himself
in the form of watching other men have raunchy sex
with his girlfriend, but then would need to dominate and
reclaim his girlfriend and then dominate and claim the man
who had the raunchy sex with her. Put another way,
Colmbs exhibited a cycle of self punishment followed by lashing
out in the form of dominating claiming the ones that
punished them. Specifically, here, Combs would masturbate while watching and
directing his girlfriend and other men to have sex and
do specific sex sex. After a session like that ended
after many hours, Colmbs would have sex with his girlfriend
in another room. In the last encounter, Colmbs also raped
Doe in the bathroom after having sex with his girlfriend.
In any event, sexual assault is presumed to be committed
with animus for a purpose of the VGMVPL for the
reasons alleged above, Plaintiff seized compets into and punitive damages
in an amount to be decided at trial, and an
award of attorney fees, costs, and disbursements. Third cause of
action common law sexual assault, battery and or rape against
defendant calms only plaintiff realleges and incorporates the preceding paragraphs
as a fully set fourth here in Colm's intentionally attempted
without authority or consent to harm and or offensively contact plaintiff,
and this attempt reasonably plays Plaintiff in fear and apprehension
of such harm and offensive contact, which conduct approximately caused
them injury and damage. A harmful, offensive, unprivileged, and unpermitted
contact with plaintiff actually occurred as a result of this conduct.
As a result, Plaintiff has experienced and will continue to experience,
emotional anguish, pain and suffering, and loss of dignity damages.
Colmb's conduct was malicious, wanton, and wilful for the reasons
alleged above. Plaintiff seeks competantory and punitive damages in an
amount of determined that trial and an award of attorney fees, costs,
and disbursements. Fourth cause of action intentional infliction of emotional
distress against all defendants. Plaintiff re alleges and incorporates the
preceding paragraphs as a fully set fourth year in Comb's
conduct and assault and battery of plaintiff described above, facilitated
by defendant James and Cowboy for Angels, was intentional, shocking, unreasonable,
and highly offensive which caused severe and debilitating emotional distress
for plaintiff. Defendant's conduct was malicious, wanton, and willful. Accordingly,
Plaintiffs seeks compensatory and punitive damages in an amount to
be determined at trial, and an award of attorney fees, costs,
and disbursements. Fifth cause of action violations of Racketeer Influenced
and Corrupt Organizations Act against all defendants. Plaintiff realleges and
incorporates the preceding paragraph as a fully set fourth year
in the Racketeer Influenced and Corrupt Organizations Act. US Code eight,
section nineteen sixty one prohibits any racketeering activity. At the
time of colmb's assault, Plaintiff was engaged as a contractor
for mail companion service based in Florida. Combs utilized this
mail companion service to establish contact with plaintiff, initially presenting
their interactions as legitimate business transactions. Colms arranged for plaintiff
to travel interstate from Florida to New York City under
the false pretense of these business related meetings. COLMS knowingly
recruited and enticed plaintiff offering something of value through the
companion service with the intent to correse Plaintiff in the
non consensual sexual encounters. The continued use of the mail
companion service and the interstate travel arrangements by COLMS constituted
a pattern of racketeering activity where the service was used
as a means to commit sexual assault and sex trafficking
in violation of US Code eighteen, section fifteen ninety one.
See US Code eight section nineteen sixty one, including among
the definitions of racketeering activity any violation of US Code eighteen,
section fifteen eighty one through fifteen ninety two relating to
pe andage slavery and trafficking in persons. Defendant Garon James
and Cowboys for Angels were at all times aware and
complicit in this racketeering activity. Plaintiff only learned of this
racketeering activity, that is, the inner workings of Comb's criminal
enterprise that caused him to be trafficked and then raped,
after the filing of the criminal indictment against Colmb's honor
about September twenty twenty four. Plaintiff's ability to continue his
business and earn income was directly affected by Comb's racketeering activity.
Comb's actions by using the Companion Service as affront for
sexual assault, directly interfered with and harmed Plaintiff's business and
property interests as a contractor and also as a professional
model and actor. Given the traumatic events he experienced, though
could not attend modeling or acting auditions and abstain from
Companion Services for several weeks, losing unvaluable career opportunities, business reputation,
and income. Accordingly, plaintiff seeks all available remedies pursuant to
US Code eighteen, Section nineteen sixty four C six cause
of action violation of New York's Trafficking Victims Protection Act
against all defendants. Plaintiff repeats, reiterates, and realleges each and
every allegation set in detail above, as if set fourth
more fully and at length herein New York's Trafficking Victims
Protection and Justice Act, New York Social Service Law, Section
forty three BBC I creates a civil cause of action
for victims of both labor and sex trafficking, specifically providing
that an individual who is a victim of the conduct
prohibited by section two thirty dot three three two thirty
dot three four two thirty three four A one thirty
five dot three five or one three five dot three
seven of the Penal Law may bring civil action against
the purpse trader or whoever knowingly advances or profits from,
or whoever should have known he or she was advancing
or profiting from an act in violation as section two
thirty dot thirty three, two thirty dot thirty four, two
thirty dot thirty four a one thirty five dot thirty five,
or one thirty five dot thirty seven of the Penal
Law to recover actual, compensatory and punitive damages injunct of relief,
any combination of those, or any other appropriate relief, as
well as reasonable attorney fees. In turn, NY Penal Laws
Section one thirty five dot three five prohibits labor trafficking
and NY Penal Law two thirty dot thirty four prohibit
sex trafficking. Colmbs is the perpetrator, and his conduct towards
plaintiff described above constitutes labor and or sex trafficking and
violation of New York's tv PJA. Karen James and Cowboys
for Angels each knowingly advanced and or profited from the
trafficking venture while knowing or in recklessess regard of the
fact that Comb's conduct violated and why Penal Laws section
one thirty five dot three five and two thirty three four.
As a result, plaintiff experienced injury in the form of
severe emotional pain and suffering emotional distress and humiliation for
the reasons alleged above. Plaintiff cease competantory and punitive damages,
an amount to be determined by trial, and an award
of attorney fees, costs and disbursements prayer for relief. Wherefore,
Plaintiff respectfully praised at the Court grant the following relief
against defendants, a enter judgment against defendants, and an award
of damages, including but not limited to, competentory damages for
emotional distress, nominal, punitive and or exemplary damages, attorney fees,
pre impose judgment interest in an amount to be determined
at trial by a jury, and b any further relief.
This Court deems just and proper. This document was dated
June sixteenth, twenty twenty five, and it was signed by
Adriana al Kalbi. All of the information that goes with
this episode can be found in the description box