1 00:00:00,120 --> 00:00:02,799 Speaker 1: What's up, everyone, and welcome to another episode of The 2 00:00:02,960 --> 00:00:05,879 Diddy Diaries. In this episode, we're picking up where we 3 00:00:06,000 --> 00:00:09,919 left off with the Sarah Rivers lawsuit filed against Ditty 4 00:00:10,880 --> 00:00:14,640 upon information and belief defendant profited from the enterprise and 5 00:00:14,720 --> 00:00:18,000 use the proceeds from the enterprise to advance the enterprise 6 00:00:18,079 --> 00:00:21,920 by funding and operating their marketing machine, including through the 7 00:00:22,039 --> 00:00:25,239 use of the mail, television coverage, word of mouth, and 8 00:00:25,280 --> 00:00:28,839 interstate wires to sell the illusion that Defendant Ditty was 9 00:00:28,879 --> 00:00:32,439 a serious and legitimate businessman who made regular people into 10 00:00:32,560 --> 00:00:38,359 music stars. Defendant Ditty, bb E, Harve Tracy, Allison, Chris Devine, 11 00:00:38,960 --> 00:00:44,200 Norma Farnsworth, Defat Mickey D Dot, Jason Phil Sean, Daddy's House, 12 00:00:44,280 --> 00:00:51,679 UMG UMG Distribution, Janics, JCP, jcph SJC, Paramount, VIACOM, MTV, 13 00:00:51,920 --> 00:00:56,320 Jackie Lou, BM King and those were a direct participant 14 00:00:56,560 --> 00:00:58,719 in the marketing aspect of the scheme, as it was 15 00:00:58,840 --> 00:01:03,399 defendants BM and MTV who created the show idea, marketed 16 00:01:03,399 --> 00:01:07,480 the idea to potential contestants, and paid for contestants to 17 00:01:07,560 --> 00:01:12,200 travel to participate on the show. Defendants Harve, Tracy, Allison, 18 00:01:12,319 --> 00:01:17,680 Chris Divine, Norma, Fonnsworth, Do fatmickeyd Dot, Jason, Phil Sewan, Jackie, 19 00:01:17,760 --> 00:01:20,920 and Lou all appeared on the television show to further 20 00:01:21,040 --> 00:01:26,519 the enterprise and conceal their intentions from their participants. Defendants Janets, JCP, 21 00:01:26,959 --> 00:01:31,799 and JCP ensured that the enterprise owned any intellectual property 22 00:01:31,840 --> 00:01:36,439 produced by plaintiff. Defendants BM and MTV provided the general 23 00:01:36,519 --> 00:01:41,879 public at large misrepresentative information, including over interstate television wire 24 00:01:41,959 --> 00:01:47,519 line communication systems, via their television show MTB two. Upon 25 00:01:47,599 --> 00:01:52,040 information and belief, defendants obtained revenue via wire transfers, documents, 26 00:01:52,040 --> 00:01:56,719 and banking transactions that were exchanged via electronic means over 27 00:01:56,879 --> 00:02:00,480 interstate wires, thereby growing the enterprise and call using further 28 00:02:00,560 --> 00:02:05,599 injury to plaintiff. As described throughout, defendant scheme was reasonably 29 00:02:05,640 --> 00:02:10,360 calculated to deceive plaintiff of ordinary prudence and comprehension through 30 00:02:10,400 --> 00:02:14,199 the execution of their complex and illegal scheme to misrepresent 31 00:02:14,240 --> 00:02:17,919 the true purpose of defending Ditty's television show MTB two 32 00:02:18,400 --> 00:02:21,800 that would lead to assault, battery, or overall danger to plaintiff, 33 00:02:22,840 --> 00:02:26,039 Plaintiff would have never engaged in any regard with defendant 34 00:02:26,080 --> 00:02:29,199 Ditty if not but for the complex and illegal racketeering 35 00:02:29,240 --> 00:02:34,199 scheme operated by defendants. Upon information and belief, defendants each 36 00:02:34,240 --> 00:02:37,639 had the specific intent to participate in the overall reco 37 00:02:37,840 --> 00:02:41,719 enterprise scheme, and each participated in the enterprise as follows. 38 00:02:42,719 --> 00:02:46,199 Upon information and belief, Defendants control and participate in the 39 00:02:46,240 --> 00:02:49,000 activities of the enterprise in a variety of ways is 40 00:02:49,039 --> 00:02:52,680 set forth here in, including but not limited to, developing 41 00:02:52,919 --> 00:02:56,719 marketing campaign to rebrand defendan Ditty after his two thousand 42 00:02:56,759 --> 00:02:59,759 and one nightclub shooting trial to the general public. Upon 43 00:02:59,759 --> 00:03:05,840 an information and belief throughout the relevant period, Defendants Harves, Tracy, Alison, Chris, Divine, 44 00:03:05,919 --> 00:03:11,120 Norma Fonsworth, DOFAT, Mickey d Dot, Jason, Phil Sean, Daddy's House, 45 00:03:11,560 --> 00:03:19,000 UMG UMG Distribution, Janice JCP, JCPH Paramount, VIACOM, MTV, Jackie 46 00:03:19,039 --> 00:03:22,960 B M King and Does entered into a partnership agreement 47 00:03:23,000 --> 00:03:27,240 with defendant Diddy, s JC, and BB as general business partners. 48 00:03:27,680 --> 00:03:31,400 Each member is responsible for the partner's actions in the partnership. 49 00:03:32,879 --> 00:03:36,280 Defendants have an ethical obligation to ensure their business partners 50 00:03:36,439 --> 00:03:39,840 were not using the partnership to engage in a legal activity. 51 00:03:40,919 --> 00:03:45,520 Defendants Harve Tracy, Alison, Chris, Divine, Norma, Fonnsworth, Dofat, Mickey 52 00:03:45,759 --> 00:03:53,319 d Dot, Jason, Phil Sean, Daddy's House, umg UMG Distribution, Janice, JCP, Jcph, 53 00:03:53,599 --> 00:03:58,719 s JC, Paramount, Viacom, MTV, Jackie Lou, BM King, and 54 00:03:58,960 --> 00:04:04,080 those provided resources to their general business partners Defendants Diddy, SJC, 55 00:04:04,240 --> 00:04:09,400 and BBE. Defendant Diddy, SJC and BBE use the resources 56 00:04:09,400 --> 00:04:12,719 provided by their general business partners to entice the public 57 00:04:12,960 --> 00:04:16,399 to want to audition for Defendant Diddy and watch the 58 00:04:16,439 --> 00:04:20,920 television show MTB two. Defendant Diddy and his co conspirators 59 00:04:20,959 --> 00:04:24,639 relied on the mail, worldwide Web, and telephone to disseminate 60 00:04:24,680 --> 00:04:29,720 the misleading information described here in. Defendants did not disclose 61 00:04:29,759 --> 00:04:32,920 to the individual they solicited the fact that they would 62 00:04:32,920 --> 00:04:37,439 be exploited, harassed, abused, assaulted, or battered while participating in 63 00:04:37,519 --> 00:04:40,519 the making of the band sponsored by and starring defendants 64 00:04:40,800 --> 00:04:46,959 and their businesses. Defendants Harve, Tracy, Allison, Chris Devine, Norma, Fonsworth, 65 00:04:47,000 --> 00:04:50,319 do Fat, Mickey d Dot, Jason, Phil, Sean, Daddy's House, 66 00:04:50,680 --> 00:04:57,959 umg UNGG Distribution, Janics, JCP, JCPH, Paramount, Viacom, MTV, Jackie Lou, 67 00:04:58,319 --> 00:05:01,519 b M King, and DOZ authorize the resources to their 68 00:05:01,560 --> 00:05:05,360 general business partner, defendant Ditty in furtherance of the goals 69 00:05:05,360 --> 00:05:09,720 of the conspiracy. Defendant used this television show MTB two 70 00:05:09,839 --> 00:05:13,279 as a ruse to provide Defendan Ditty, SJC, and BB 71 00:05:13,959 --> 00:05:18,759 covered to disguise their covert reco enterprise. Throughout the relevant period, 72 00:05:18,800 --> 00:05:22,800 defendants use their collective resources, relying on the mail, email, radio, 73 00:05:23,120 --> 00:05:27,079 and worldwide Web, to disseminate the misleading information described herein. 74 00:05:28,079 --> 00:05:31,600 As the general business partner of Defendan Didty, SJC, and BBE, 75 00:05:32,040 --> 00:05:34,839 defendants are equally liable for the commission of these acts. 76 00:05:35,800 --> 00:05:40,720 Defendants bm MTV, and BB insured cash payments to plaintiff 77 00:05:40,759 --> 00:05:45,040 were executed. Plaintiff does not recall receiving appropriate United States 78 00:05:45,279 --> 00:05:48,839 Federal tax documents for payments or the value of the trip, 79 00:05:48,879 --> 00:05:52,240 as if they independently declared these payments on their taxes. 80 00:05:53,439 --> 00:05:57,000 It's unclear if defendant requested an audit of defending Ditty's 81 00:05:57,040 --> 00:06:00,439 business financial records to ensure the resources pro invited to 82 00:06:00,519 --> 00:06:03,839 Defendant Diddy was not being used to fund the legal activity. 83 00:06:04,839 --> 00:06:07,920 During the ten years preceding the filing, of this action 84 00:06:08,240 --> 00:06:11,600 and to the present, all defendants did cooperate jointly and 85 00:06:11,759 --> 00:06:15,439 severally in the commission of predicate acts itemized in US 86 00:06:15,480 --> 00:06:19,360 Code eighteen, section nineteen sixty one one, in violation of 87 00:06:19,480 --> 00:06:23,680 US Code eighteen, Section nineteen sixty two D as described 88 00:06:23,680 --> 00:06:28,040 in this complaint, beginning at an exact date unknown to plaintiff, 89 00:06:28,079 --> 00:06:30,639 but within ten years preceding the filing of this action, 90 00:06:31,000 --> 00:06:35,319 defendants have knowingly, willfully, and unlawfully participated in a pattern 91 00:06:35,360 --> 00:06:39,920 of racketeering activity that continues, possibly to this day. The 92 00:06:40,000 --> 00:06:43,480 racketeering acts followed the same pattern and purpose to defraud 93 00:06:43,560 --> 00:06:47,639 the plaintiff for the defendant's benefit. Each racketeering act involved 94 00:06:47,639 --> 00:06:52,920 the same or similar methods of commission and participants. Defendant's 95 00:06:52,959 --> 00:06:56,319 business would not have succeeded without the repeated predicate acts 96 00:06:56,639 --> 00:07:01,079 and the ability to conduct their fraud using mail, telecommunity cations, wires, 97 00:07:01,319 --> 00:07:06,839 interstate travel, and possibly money laundering. The racketeering acts all 98 00:07:06,839 --> 00:07:08,759 relate to each other in that they were a part 99 00:07:08,800 --> 00:07:11,920 of a concerted action by defendants to use the endorsement 100 00:07:12,040 --> 00:07:15,079 and channels of the enterprise to operate their business to 101 00:07:15,160 --> 00:07:19,879 solicit potential victims. As detailed here in, the separate racketeering 102 00:07:19,920 --> 00:07:22,199 acts all relate to each other in that they were 103 00:07:22,199 --> 00:07:25,240 a part of the concerted actions by defendants to use 104 00:07:25,279 --> 00:07:28,439 the endorsement and channels of the enterprise to operate their 105 00:07:28,480 --> 00:07:33,240 businesses to fraudully induce plaintiff. Defendant's wrongful conduct is injured 106 00:07:33,240 --> 00:07:37,240 plaintiff and continues to threaten plaintiff to the public. Defendants 107 00:07:37,279 --> 00:07:40,680 association with the enterprise enabled defendant to conduct direct and 108 00:07:40,720 --> 00:07:45,120 control a pattern of fraudulent, illegal activities over a substantial 109 00:07:45,199 --> 00:07:48,920 number of years, which continues to this day. To further 110 00:07:49,000 --> 00:07:52,279 their collective goals, defendants worked in concert to engage in 111 00:07:52,360 --> 00:07:55,480 various forms of criminal activity at the direction and demand 112 00:07:55,560 --> 00:08:01,120 of defendant. Calms defendants ongoing racketeering activity as injured and 113 00:08:01,240 --> 00:08:06,439 continues to injure plaintiff. Defendants committed multiple acts of mail 114 00:08:06,519 --> 00:08:10,279 fraud and violation of US Code eighteen, Section thirteen forty one. 115 00:08:10,600 --> 00:08:15,920 In furtherance of the enterprise, Defendants voluntarily and intentionally devised 116 00:08:15,959 --> 00:08:19,199 and participated in a scheme with the intent to defraud plaintiff. 117 00:08:19,959 --> 00:08:24,639 Defendants use the mail to execute the fraudulent scheme. Herein specifically, 118 00:08:24,759 --> 00:08:27,360 the defendants agreed to each of the acts of mail 119 00:08:27,439 --> 00:08:30,839 fraud described throughout this complaint. In addition, they agreed to 120 00:08:30,920 --> 00:08:35,960 rely on the mail to distribute their marketing material, contest instructions, 121 00:08:36,080 --> 00:08:39,480 secure wires, and cash payments from other participants in the 122 00:08:39,480 --> 00:08:43,919 scheme in furtherance of and four purposes of executing of 123 00:08:44,000 --> 00:08:47,159 the above describe fraudulent and a legal course of conduct 124 00:08:47,200 --> 00:08:51,559 in scheme to defraud, Defendants, either individually or in combination 125 00:08:51,679 --> 00:08:54,559 with themselves, used in cause to be used the US 126 00:08:54,679 --> 00:09:00,279 Mail by both placing and causing to be placed marketing materials, advertisements, agreements, 127 00:09:00,480 --> 00:09:04,000 and other matters in depositories, and by removing or causing 128 00:09:04,000 --> 00:09:07,679 to be removed letters and other mailable matters from depositories 129 00:09:08,000 --> 00:09:11,279 in violation of the Mail Fraud Statute US Code eighteen, 130 00:09:11,600 --> 00:09:15,600 Section thirteen forty one. Defendants could not have furthered their 131 00:09:15,639 --> 00:09:18,440 fraudulent scheme without the use of the mail. For example, 132 00:09:18,480 --> 00:09:21,840 without the male, defendants would be unable to conduct any 133 00:09:21,879 --> 00:09:26,480 business relevant to its purpose creation. Defendants also required the 134 00:09:26,519 --> 00:09:31,519 mail to distribute misleading advertisements to various states. For those reasons, 135 00:09:31,720 --> 00:09:35,039 the use of mail to conduct fraudulent activity was necessary 136 00:09:35,399 --> 00:09:39,960 and inevitable. Defendants committed multiple acts of wire fraud and 137 00:09:40,039 --> 00:09:43,879 violation of US Code eighteen, section thirteen forty three. In 138 00:09:43,960 --> 00:09:49,080 furtherance of the enterprise, Defendants voluntarily and intentionally devised and 139 00:09:49,120 --> 00:09:52,240 participated in a scheme with the intent of the fraud plaintiff. 140 00:09:52,679 --> 00:09:55,360 Defendants agreed to each of the acts of wire fraud 141 00:09:55,360 --> 00:10:00,120 described Herein Additionally, defendants agreed to rely on interstate wires 142 00:10:00,320 --> 00:10:04,320 to disseminate funds to others in the enterprise. Defendants illegally 143 00:10:04,360 --> 00:10:08,039 acquired and utilized wire transfers to further their collective goal 144 00:10:08,320 --> 00:10:13,360 of furthering their reco enterprise. Defendants agreed that defendants should 145 00:10:13,399 --> 00:10:17,639 facilitate these fraudulent purchases over interstate wires and furtherance of 146 00:10:17,679 --> 00:10:20,759 their scheme. In furtherance of and for the purpose of 147 00:10:20,799 --> 00:10:24,240 executing the above describe fraudulent and a legal course of 148 00:10:24,320 --> 00:10:28,919 conduct in scheme or artifice to defraud. Defendants, either individually 149 00:10:29,240 --> 00:10:32,000 or in combination with themselves, used or caused to be 150 00:10:32,159 --> 00:10:37,360 used interstate wire communications to transmit or disseminate false, fraudulent, 151 00:10:37,679 --> 00:10:41,399 and misleading communications and information in violation of the wire 152 00:10:41,440 --> 00:10:47,080 fraud statue. US Code eighteen, section thirteen forty three. Defendants 153 00:10:47,080 --> 00:10:49,840 could not have furthered their fraudulent scheme Without the ability 154 00:10:49,879 --> 00:10:54,879 to use telecommunications to share information with clients and retailers nationwide. 155 00:10:56,200 --> 00:10:59,320 Defendants needed to communicate with clients and retailers around the 156 00:10:59,320 --> 00:11:04,519 country utilizing interstate telecommunication wires to conduct the fraudulent activity, 157 00:11:05,320 --> 00:11:09,799 which was necessary and inevitable to use. Plaintiffs have been 158 00:11:09,879 --> 00:11:13,080 damaged in her business, to or property because defendants violated 159 00:11:13,200 --> 00:11:16,759 US Code eighteen, Section nineteen sixty two AC and D, 160 00:11:17,279 --> 00:11:20,799 and therefore plaintiff is entitled to recover the damages and 161 00:11:20,919 --> 00:11:26,519 other remedies enumerated therein. Defendants acts or omissions were actuated 162 00:11:26,559 --> 00:11:30,039 by actual malice and a wilful and wanton disregard for 163 00:11:30,080 --> 00:11:33,759 the consequences suffered by plaintiff, were directed towards her because 164 00:11:33,759 --> 00:11:36,279 of her gender, and with knowledge of a high degree 165 00:11:36,279 --> 00:11:39,919 of probability of harm to plaintiff and reckless indifference to 166 00:11:39,960 --> 00:11:45,159 the consequences of their actions or omissions. Compensatory damages alone 167 00:11:45,360 --> 00:11:48,360 will be insufficient to deter such conduct in the future. 168 00:11:48,879 --> 00:11:51,159 There needs to be a criminal referral to the United 169 00:11:51,159 --> 00:11:57,519 States Justice Department as well as the state's Attorney General's office. Wherefore, 170 00:11:57,600 --> 00:11:59,960 plaintiff requests that the Court issue in order in gret 171 00:12:00,240 --> 00:12:03,919 judgment to the plaintiff as follows, grant plaintiff statutory common 172 00:12:04,000 --> 00:12:07,600 law and punitive damages and applicable pre and post judgment 173 00:12:07,639 --> 00:12:12,799 interest in full recompense for damages enter judgment according to 174 00:12:12,840 --> 00:12:16,879 the declaratory relief saught, Grant plaintiffs such other and further relief, 175 00:12:16,919 --> 00:12:21,120 including without limitation, injunctive and equitable relief as the Court 176 00:12:21,159 --> 00:12:25,399 deems just in all these circumstances, and grant plaintiff an 177 00:12:25,440 --> 00:12:28,679 incentive or service award reflective of the work done in 178 00:12:28,840 --> 00:12:32,480 prosecuting this action, the time spent, the effort and hard 179 00:12:32,519 --> 00:12:35,559 costs invested, and results obtained in light of the Court's 180 00:12:35,600 --> 00:12:39,720 judgment informed by awards and other similar cases of comparable 181 00:12:39,759 --> 00:12:43,519 difficulty and complexity. All right, we're going to wrap this 182 00:12:43,559 --> 00:12:45,759 one up right here, and in the next episode we're 183 00:12:45,759 --> 00:12:47,840 going to pick up with the second cause of action. 184 00:12:48,600 --> 00:12:51,799 All of the information, including my contact information, can be 185 00:12:51,879 --> 00:12:53,759 found in the description box.