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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 getting right back to

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that Sarah Rivers lawsuit filed against Ditty. The eleventh cause

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of action breach of implied covenant of good faith and

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fair dealing against all defendants. Plaintiff repeats and realleges each

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and every allegation in all of the preceding paragraphs as

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if fully set forth you're in. Plaintiff entered several contracts

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with defendants, at least four. Plaintiff did all or substantially

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all of the significant things the contracts required her to do.

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The allegations set forth in this complaint detail the malevolent

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and intentional behavior by defendants, all of which constitute breaches

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of the implied covenant of good faith and fair dealing

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and demonstrate the bad faith of defendants at all relevant times.

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Defendants did not pay plaintiff as agreed. Defendants did not

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pay plaintiff royalties nor extraneous promotions in any instance. Defendant

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did not pay plaintiff her proper amount from touring. The

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defendant did not pay plaintiff or a proper amount from

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her television appearance for the three seasons of MTB two

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television show. Defendant did not pay plaintiff her share of

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income for her contributions to the musical compositions her publishing,

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despite the assignments to various companies. Not only have defendants

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failed to pay plaintiff, but they also have prevented plaintiff

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from working in any capacity in the music industry and

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infringed on her copyrights. Defendant's unfair interference with plaintiff's right

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to receive the benefits of each contract was foreseeable in

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causing plaintiff to suffer general, consequential and incidental damages, including

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economic damages. According to proof at trial, defendants knew or

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should reasonably have foreseen that the harm and or special

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circumstances were likely to occur in the ordinary course of events.

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As a result of the breaches of defendants obligations to

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act in good faith, make plaintiff property productive, and account

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for and pay plaintiff as agreed accordingly, Defendant's conduct was

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a breach of implied covenant of good faith and fair dealing.

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As an actual and proximate result of the aforementioned violations,

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Plaintiff has been harmed in an amount according to proof,

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and has lost wages, benefits, and other out of pocket expenses.

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As an actual approximate result of defendants aforementioned acts, Plaintiff

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has suffered physical injury and became mentally upset, stressed, and aggravated.

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Plaintiff has experienced post traumatic stress disorder, mental anguish, aggravation, anxiety, humiliation, embarrassment, sleeplessness,

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loss of appetite, low self esteem, depression, upset stomach, and

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other forms of extreme emotional distress. Plaintiff claims damages for

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physical injuries and mental distress in an amount according to

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proof at trial, The above described actions were perpetrated and

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or ratified by a managing agent, employee, or officer of defendants,

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and each of them. These acts were done with malice, fraud, oppression,

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and a reckless disregard for Plaintiff's rights. Further, said actions

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were despicable in character and warrant the imposition of punitive

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damages in a sum sufficient to punish and deterred defendant's

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future conduct. Defendant's continuous threats, coercion interference with plaintiff's music

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career prevented plaintiff from asserting her rights within the statutorily

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prescribed period. Defendants should be e stopped from asserting the

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statute of limitations as a defense due to the duress

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exerted upon plaintiff. Twelfth cause of action Fraud, intentional misrepresentation,

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false promise against all defendants. Plaintiff repeats and realleges each

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in every allegation in all of the preceding paragraphs. As

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a fully set forth year in, Plaintiff asserts this cause

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of action against all defendants. Defendants represented to plaintiff that

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certain facts relative to payments two plaintiff were true in

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each of the contracts listed above. Further, Defendant made multiple

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promises and verbally too Plaintiff, which were captured and aired

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on the television show MTB. Two defendants representations were false.

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Defendant did not intend to perform these promises when they

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were made or at any time. Defendants knew that their

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representations were false and that they were made, and they

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had made such representations recklessly and without regard for the

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truth and such representations. Defendant intended that Plaintiff rely on

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their representations and promises. Plaintiff reasonably relied on defendants representations

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and promises. Defendants did not perform the promised acts. Plaintiff

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was harmed. Plaintiff's reliance on defendant's representations and promises was

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a substantial factor in causing plaintiff to suffer general, consequential

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and incidental damages, including economic damage. According to proof at trial,

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defendants knew or could reasonably have foreseen that the harm

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and special circumstances were likely to occur in the ordinary

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course of events as a result of the defendant's breaches

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a contract. Accordingly, defendant's conduct was intentional misrepresentation. As an

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actual approximate result of defendants intentional and unlawful misrepresentation and

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false promises, Plaintiff has lost wages, profits, benefits, royalties, and

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has incurred other out of pocket expenses As an actual

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and approximate result of defendants fraudulent acts, Plaintiff has suffered

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physical injury and became mentally upset, stressed, and aggravated. Plaintiff

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has experienced post traumatic stress disorder, mental anguish, aggravation, anxiety, humiliation, embarrassment, sleeplessness,

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loss of appetite, low self esteem, depression, upset stomach, and

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other forms of extreme emotional distress. Plaintiff claims damages for

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physical injuries and mental distress in an amount according to

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proof at trial. The above described actions were perpetrated and

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or ratified by a managing agent, employee, or officer of defendant,

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and each of them These acts were done with me

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naly fraud, oppression, and reckless disregard of Plaintiff's rights. Further

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set actions were despicable in character and warrant the imposition

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of punitive damages in a sum sufficient to punish and

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deterred defendant's future conduct. Defendant's continuous threats, coercion, and interference

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with plaintiff's music career prevented plaintiff from asserting or rights

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within the statutorially prescribed period. Defendants should be EA 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. Thirteenth cause of action

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negligent hiring, training, supervision, and retention against Defendant BBE, Bad

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Boy Records, Colm's Enterprise, UMG UMG Distribution, SJCBMMTV, VIACOM, Paramount, JCP,

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and JCPH. Plaintiff incorporates by reference all preceding paragraphs and

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reallegis them as if fully set forth here in. The

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offense alleged here in resulted in whole or in part

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due to the failure of the defendants to employ qualified

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persons for positions of authority and order, to train or

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supervise the conduct of such persons during their employment, and

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or to promulgate appropriate policies and procedures, either formally or

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by custom, properly or conscientiously. Defendants were negligent in hiring, training, retention, supervision, direction, control, appointment,

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and or promotion of their employees, agents, and or servants,

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including but not limited to, each of the defendants named

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here in. Defendants knew or should have known, in the

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exercise of reasonable care, the propensity of their employees and

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partners to engage in the wrongful conduct heretofore alleged here in.

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Defendants were negligent, careless, and reckless in its screening, hiring, training, retention, supervision, direction, control, appointment,

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and promotion of their agents, servants, and employees in that

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said employees lacked the experience and ability to be hired.

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I said defendants in failing to exercise doe care and

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caution in their screening, hiring, appointment, and promotion practices, and

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in particular, hiring individuals who lacked the mental capacity and

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ability to function on behalf of said defendants, in that

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these individuals lack the maturity, sensibility, and intelligence to function

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on behalf of said defendants. In that said defendants knew

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of the lack of ability, experience, and maturity of these

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individuals when they hired them, knew of the propensity of

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said individuals to act in the belligerent, aggressive, violent, and

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a legal manner in which they did. In that said defendance,

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their agents, servants, and or employees failed to supervise, train, suspend,

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and or terminate these individuals when such action was either

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proper or required, and in being otherwise careless, negligent, and reckless.

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In this instance, the failure of the defendants to adequately

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train its agents, servants, and employees in the reasonable exercise

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of their job duties and the laws of the United

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States of America is evidence of the defendant's reckless lack

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of cautious regard for the rights of the public in

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general and plaintiff in particular, and exhibited a lack of

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that degree for due care which reasonable and prudent individuals

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would show under the same similar circumstances. Defendants new or

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should have known in the exercise of reasonable care the

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propensity of its agents, servants, and employees to engage in

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the wrongful conduct heretofore alleged in this complaint. Defendants new

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Or should have known that its policies, customs and practices,

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as well as its negligent hiring, retention, supervision, training, appointment,

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and promotion of its agents, servants, and employees, created an

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atmosphere where the most prominent offenders felt assured that their

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brazen acts of abuse, misconduct, and neglect would not be

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swiftly and effectively investigated nor adverse employment action or prosecution taken.

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The mistreatment, abuses, and violations of plaintiff rights as set

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forth above were the reasonably for seeable consequence of defendants

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negligent conduct. The aforesaid acts and omissions of Defendant and

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its agents, servants, and employees resulted in the plaintiff's rights

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being violated and her being injured as a result of

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the conduct can plained of Herein plaintiffs suffered the damages

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alleged as a result of the foregoing Plaintiff is entitled

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to an award of compensatory damages, punitive damages, and reasonable

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attorney fees together with costs expert fees and disbursements. All right,

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we're going to wrap up this one right here, and

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in the next episode dealing with the topic, we're going

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to pick up with the fourteenth cause of action negligence.

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All of the information that goes with this episode, including

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