Case 1:23-cv-03335-CJN Document 1 Filed 11/09/23 Page 1 of 98
`Case 1:23-cv-03335-CJN Document1 Filed 11/09/23 Page 1 of 98
`Case: 1:23-cv—03335
`Assigned To : Nichols, Carl J.
`Assign. Date : 11/9/2023
`Description: Pro se. Gen. Civ. (F-Deck)
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`COMPLAINT
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`Plaintiff Rose Y. Celestin hereby pleads the following complaint against Defendants Onika Maraj-Petty
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`a/k/a Nicki Minaj, Aubrey Graham a/k/a Drake, Cash Money Records, and David Brewster a/k/a Dave
`
`East:
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`SUMMARY OF ACTION
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`1. Rose Celestin was a likable and impressionable young woman whooften stood out in the crowd
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`and left long-lasting, great impressions with everyone she had encountered. Often praised for her
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`professionalism, strong work ethic, and virtues, Rose Celestin always captured the hearts of many
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`with her captivating personality and admirable achievements, propelling her to new heights in her
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`professional career and personallife. While Rose Celestin had a certain mystique to her, she still
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`left many who hadcrossed her path wanting to learn more, compelling them to take her under
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`their wings while exposing herto stellar opportunities. Not only was Rose Celestin a charming
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`young woman,she wasalso considered trustworthy and inspirational by her peers and
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`commanded respect for many years. ‘hen, slowly but surely, Rose Celestin’s world began
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`tumbling down and ultimately fell apart right before her very eyes for reasons she could not
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`understand. What Rose did not fully realize until it was too late was that she wasthe target of an
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`unsuspecting group of celebrities, led by rapper Nicki Minaj, who were workingtirelessly over
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`the span of more than a decade to successfully sabotage Rose Celestin’s life.
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`2. Asaresult, Rose Celestin has sadly found herself an innocent victim of criminal espionage where
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`she has been placed against her will under perpetual unlawful surveillance. She is unable to
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`sustain a livelihood or economic advantage because her reputation has been utterly decimated,
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`thereby losing the respect of all her peers, employers, and business associates. She is constantly
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`mocked, humiliated, and ridiculed. The Defendants have exposed Rose Celestin to public scorn,
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`hatred, and contempt, discouraging others from having a good opinion of and associating with
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`her. Consequently, Rose Celestin haslost all her friends, and due to the Defendant’s constant
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`unlawful surveillance, she is unable to make new friends. The sheer damage and massive havoc
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`wrcakcd on Rosc Cclestin’s life is irrevocable.
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`And if it wasn’t enough for the Defendants to cause Rose Celestin inescapable shame, she is not
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`even safe within the four walls of her own homewhere sheis subjected to around-the-clock
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`bullying through means of espionage. Moving does no goodasit creates even more financial
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`burdenfor her. Neither does purchasing new devices and even acquiring the most highly-rated
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`VPNsubscriptions from reputable companies, promising to provide the one thing Rose Celestin
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`desperately craves—privacy. Every morning, Rose Celestin steps into her shower with a gut-
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`wrenching feeling of disgust, knowing that she is being watched by an audience who take
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`pleasure in her vulnerability. Every day, she checks her email, surfs the web, and engages on
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`social media with the nerve-wracking feeling of being smothered, knowing that everything she
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`does on her devices is tracked and under watchful, scrutinous eyes. Even the simple act of
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`checking her bank accounts or scheduling a doctor’s appointment causes Rose Celestin crippling
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`anxiety, knowing that the most private details of her personal life could potentially subject her to
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`unprovoked shame and ridicule.
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`The Defendants’ ability to impart such debilitating damage upon Rose Celestin hinges on this key
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`By knowingly perpetuating this falsehood with malice and intent, the Defendants have leveraged
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`their power and influence to inflict indefensible atrocities against Rose Celestin with no fear of
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`repercussions, rendering emotional, compensatory, and exemplary damages beyond enumeration.
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`Rose Celestin bringsthis civil complaint before the Court to clear her nameofthe deliberate
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`defamatory allegations made by the Defendants and instigated by Nicki Minaj. Rose Celestin
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`seeks to prove with factual evidence that (1) the allegations made against Rose Celestin are
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`knowingly false, (2) the Defendants acted with actual malice and intent in making false
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`allegations against Rose Celestin, (3) the Defendants intended to obstruct Rose Celestin from
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`seeking iegal recourse for their defamatory and illegal conduct, (4) the Defendants abused their
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`powerandinfluenceto intentionally interfere with Rose Celestin’s ability to gain and maintain
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`economic advantage, and (5) the Defendants leveraged means of criminal espionageto inflict
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`damage upon RoseCelestin.
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`Bythis civil lawsuit, Rose Celestin seeks to restore her reputation and establish the Defendants’
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`liability for the damages compoundedin perpetuity against her, seek equitable relief and punitive
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`damages for the reputational harm Rose Celestin has suffered, restrain the Defendants from
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`continuing their malicious and criminal actions against Rose Celestin, and most importantly,
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`uphold the virtue that no one, regardless of fame, power, and influence, is above reprimand.
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`JURISDICTION AND VENUE
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`Plaintiff Rose Y. Celestin is invoking diversity jurisdiction of this Court pursuant to 28 U.S.C.
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`Section 1332 (a)(3), where the statute provides that (a) the district courts shall have original
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`jurisdiction ofall civil actions where the matter in controversy exceeds the sum or value of
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`$75,000, exclusive of interests and costs, and is between(3) citizens of different States and in
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`whichcitizens or subjects of a foreign state are additionalparties.
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`The Venueis properin this district pursuant to 28 U.S.C. Section 1332(a)(3) because Plaintiff
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`resides in the district where the Court has diversity jurisdiction.
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`PARTIES
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`10.
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`Plaintiff Rose Y. Celestin is a citizen of Washington, DC with a principalplace of residence in
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`the District of Columbia.
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`11.
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`Defendant Nicki Minaj is a citizen of Los Angeles, CA with a principal place of residence in the
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`State of California.
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`12.
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`Defendant Drakeis a citizen of Toronto, Ontario with a principal place of residence in Toronto,
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`Ontario, Canada.
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`13.
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`Defendant Dave Eastis a citizen of New York, NY with a principal place of residence in the State
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`of New York.
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`14.
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`Defendant Cash Money Recordsis a private company with a principal place of business in the
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`State of Louisiana.
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`STATEMENT OF FACTS
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`15.
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`Plaintiff Rose Y. Celestin, born in Brooklyn, New York, was raised in Pine Bluff, Arkansas and
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`lived in Pine Bluff for mostofherlife.
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`16,
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`Rose wasraised in a loving, two-parent, middle class home with a good moral, conservative
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`upbringing. She was well provided for by her parents. Both her father and mother are college-
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`educated with degrees in Computer Science and Psychology, respectively. Growing up, Rose’s
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`parents were gainfully employed. Her parents provided a goodlife for Rose and her older brother,
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`regularly emphasizing andinstilling the high importance of education, hard work, and integrity in
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`order to succeed. As a result, Rose developed a very driven and ambitious mindsetat an early
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`age.
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`17.
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`Because of Rose’s good upbringing and charismatic personality, she took the initiative to seize a
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`rare opportunity to begin gainful employmentat the tender age of 14 at the University of
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`Arkansas at Pine Bluff (““UAPB”) as a Purchasing Technician, a feat not commonly accomplished
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`by other kids her age. Her tenacity and networking ability allowed herto land the role, despite her
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`young age. In addition to Rose’s driven and ambitious mindset, she wasalso a highly creative
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`kid.
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`18.
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`Rose wasgifted in writing, with great command of English grammar, due to her father’s
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`relentless emphasis on being highly educated to becomea respectable memberofsociety. Rose
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`began writing poetry, where her love for poetry eventually evolved into writing music. This gift
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`led to Rose forming a singing group, 3 Pretty Misses (“3PM”), which comprised of Rose and two
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`of her classmates. Rose continued her employment with UAPRBon a part-time basis while also
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`being an active member of 3PM during her time as a junior high and high school student. In June
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`2007, Rose graduated from Pine Bluff High School in Pine Bluff, Arkansas.
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`19,
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`Aroundthe time of Rose’s sophomoreyear of high school, 3PM began gaininglocalattention, as
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`well as the attention of music executives andlabels, piquing the interest of Xavier Lewis, an
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`A&R at So So Def Recordings, as well as other independentlabels. Ultimately, Rose’s singing
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`group, 3PM,began a businessrelationship with Xavier Lewis. The term of that business
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`relationship was for 3PM to release a debut single through Xavier’s company, Stoopid Fly
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`Entertainment, which was an imprint of So So Def Records. 3PM traveled to Austin, Texas for
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`about three days around May/June 2007, where the group becamefurther acquainted with Xavier
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`and his music company. Therelationship between Xavier, Stoopid Fly Entertainment, and 3PM
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`wasstrictly business. Xavier had the utmost respect for members of 3PM,and to Rose’s
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`knowledgeandrecollection, Xavier always had good and professional intentions for the group.
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`20.
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`Around July 2007, 3PM (absent one member) traveled to Atlanta, Georgia for about two months
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`to begin working on a single. During 3PM’s short time in Atlanta, the group wasresponsibly
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`supervised by Xavier in a professional manner.
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`Rose Celestin’s Journey Through the East Coast Music Scene
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`21.
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`3PM’s recording career wasoffto a great start, having already established solid music industry
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`connectionsearly on,priorto arriving to New York City. However, 3PM did not have an official
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`manager to managethe group. Rose, being well-connected in the music industry, was acting as
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`the head ofall business-related affairs for the group, which was not optimal given her gender and
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`young age. In summer 2007, DJ Cutmaster C, creator of True Stories DVD, met Rose on
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`Myspaceand offered to manage the group.
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`22.
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`Absent one member, 3PM traveled to Hackensack, NJ around September 2007, where they met
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`DJ Cutmaster C in person forthefirst time. Initially, the new business relationship established
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`between DJ Cutmaster C and the group waspositive, professional, and seemed very promising
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`due to DJ Cutmaster C also being well-connected within the east coast music industry. During the
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`first couple of weeks of managing the group, DJ Cutmaster C responsibly and professionally
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`managed the group while also leveraging his relationships to make introductions on behalf of
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`3PM,bragging about the group every chance he could get. The girls often accompanied DJ
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`Cutmaster C on professional errand runs and encounters with major players in the musicindustry.
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`They often frequented the Def Jam Recordings office in NYC many times, where DJ Cutmaster C
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`conducted interviews with major artists for True Stories. For the mostpart, the girls were excited
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`about being managed by DJ Cutmaster C andfelt that he was the perfectfit to managethe group.
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`23.
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`Ilowever, as time passcd, DJ Cutmaster C’s relationship with 3PM beganto take an unexpected
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`turn for the worst. DJ Cutmaster C began to grow increasingly distant withthe girls for reasons
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`beyond their comprehensionat the time.
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`24,
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`One day, DJ Cutmaster C had asked Rose’s groupmate to accompany him on an errand. Thinking
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`nothing ofthis, as it was commonforthe girls to tag along with DJ Cutmaster C on professional
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`business, Rose’s groupmate went with him on the errand, while Rose stayed behind. After a few
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`hours, DJ Cutmaster C dropped Rose’s groupmate offat the apartment wherethe girls wereliving
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`in Hackensack, while DJ CutmasterC left for the rest of the day. Immediately after arriving back
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`at the apartment, Rose noticed that her groupmate’s demeanor wasdifferent comparedto all the
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`other times she tagged along on an errand run. That time she was sad and despondent. When Rose
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`asked her groupmate what had happened, her groupmate did not wantto talk about it. About two
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`days later, DJ Cutmaster C had also asked Rose to accompany him on an errand, while her
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`groupmate stayed behind that time around.
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`25.
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`That was when Rosefirst realized why her groupmate wassad about two daysearlier.
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`Unbeknownst to 3PM, DJ Cutmaster C (and Nicki Minaj, on information and belief) were using
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`official 3PM photos from previous professional photoshoots without the group’s knowledge or
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`permission to post sex ads on Craigslist. Rose became aware of that when DJ Cutmaster C drove
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`Roseto a house andinstructed her to go inside where a man was ready to meet her. Upon entering
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`the stranger’s house, the stranger led Rose to his bedroom and began to undress. Scared and
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`confused, Rose asked the stranger why he wasgetting undressed. Confused, the stranger showed
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`Rose a Craigslist ad with her picture and content soliciting sex and asked her to confirm if it was
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`her in the ad. Completely caught off guard by that, Rose explained to the man that she did not
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`cometo his house to have sex with him and that she was unaware ofthe Craigslist ad. The man
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`began to read between the lines and asked Rose if DJ Cutmaster C, whowasstill parked outside,
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`was her pimp. Rose quickly corrected the stranger, telling him that DJ Cutmaster C wasnot her
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`pimp, but her manager because she wasin a singing group signed to So So Def. Putting two and
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`two together, the man then began to show compassion and explained that he had a daughter. Out
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`of sympathy, the man gave Rose a wadof cash, in case DJ Cutmaster C askedforit, and let Rose
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`leave without forcing her to have sex with him as originally planned.
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`Relieved and grateful to God that she was able to get herself out of suchasticky situation that
`26.
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`could have ended otherwise, the two chatted for a few minutes where the man warned Rosethat
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`she wasn’t “down south” anymore andto “be careful who youtrust”. During the quiet ride home,
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`DJ Cutmaster C asked Roseif she had any money. Rose then gave DJ Cutmaster C a wad of cash
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`givento herby the stranger. DJ Cutmaster C then counted the money, gave Rose about $200, and
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`kept the rest for himself.
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`27.
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`Traumatized and completely blindsided by that experience, Rose confronted DJ Cutmaster C
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`aboutit, because it was seemingly out of character for DJ Cutmaster C to do such a thing. Up
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`until that point, DJ Cutmaster C had alwaystreated the girls with the utmost respect. DJ
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`Cutmaster C then told the girls that studio time costs money and for him to invest in 3PM, 3PM
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`wouldfirst need to invest in themselves. That wasthe first time since working with DJ Cutmaster
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`C that he had expressedthat intent for the group and completely changedhis disposition with the
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`girls.
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`28.
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`Understanding what DJ Cutmaster C meant, Rose threatened to leave. However, DJ Cutmaster C
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`wasnot expecting that response and did not want the group to leave, because he too benefitted
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`from Rose’s connections in the music industry. Therefore, DJ Cutmaster C agreed to stop
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`pressuring the girls lu becoming sex workers al such ripe, leuder aves of (heir impressionable
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`teenage years. To give DJ Cutmaster C the benefit of a doubt and put that incident behind them,
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`3PM continued working with DJ Cutmaster C under his management.
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`Nicki Minaj: The Inconspicuous Villain
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`29. Unbeknownst to Rose, Nicki Minaj, on information and belief, had been engaged in criminal
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`espionage against Roseasearly as her high school years (and possibly even earlier), secretly
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`preying, spying, and stalking Rose, who Nicki Minaj had never met. Rose has no idea how Nicki
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`Minaj’s creepy obsession over her cameto be, because the two had never crossed paths, even to
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`this very day.
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`30. In her song, “Wuchoo Know”released on July 5, 2007, Nicki Minaj madethe statements, “Cause
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`
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`ifabirdtrytogetoutofthecage, one bitch down. New York Times front page” and “Nowclass
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`is finished. pou’be home ‘bout 3”. Nicki Minaj made those unprovoked, hostile statements
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`referring to Rose and her singing group, 3PM, whoat the time had just graduated high school, a
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`monthearlier in June 2007.
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`31. In “Sticks In My Bun”, released by Nicki Minaj on July 5, 2007, Nicki Minaj made an
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`unprovoked defamatory statement about Rosestating, “Wigga said he di
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`hoe”, falsely accusing Rose, a high schoolstudent, of beingastripper.
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`32. In “Playtime Is Over’ released on July 5, 2007, Nicki Minaj stated, “Bitches talk shit, but what is
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`
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`you saying?” and “Fuck a dry pussy bitch, causeIknow she thirsty”, falsely accusing Rose of
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`showing animosity and spreading gossip towards Nicki Minaj, although the two had never met.
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`Nicki Minaj also falsely alleged that she had inside information concerning Rose’s alleged
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`promiscuity.
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`33. In “Dilly Dally” released on July 5, 2007, Nicki Minaj stated, “they think I’m makingfunof
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`them, when [helike: “Na-Na-Na-Na!” That's the track, little mama. Look: ““Na-Na-Na-Na!” Do
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`
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`write your lyrics. little mama. I can dig it”, ridiculing 3PM and accusing Roseofnot writing her
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`ownlyrics for songs she’s written, although they had not heard of Nicki Minaj or were aware of
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`her secret animosity towards them.
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`34.
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`straightin,Lil Dolce & Gabbana,got this broad hatin”. “Mami stop fakin’. talking bout what you
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`got, you ain’t got Nathen, and you’re not caking, you're not my taste, stay in a child’s place.
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`check the timin”, ridiculing Rose, warning herto stay in a child’s place. She also stated “check
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`the timing” in a subliminal reference to Rose’s singing group, 3PM.
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`35.
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`In “I’m Cumin”released on July 5, 2007, Nicki Mingj stated, “I_don’tplayaround, J’m_@ have to
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`shut her down”, “Bitches pop shit, but they soft like play dough”, “Gotta lotta banks, so she
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`wanna be me, I gotta full tank, little mama on E”, threatening to intentionally interfere with
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`Rose’s prospective economic advantage in the music industry and falsely accusing Rose of
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`harboring animosity towards Nicki Minaj.
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`36.
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`“Encore ‘07”, “Dirty Money (Freestyle)”, and “Jump Off ‘07” also contained targeted subliminal
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`messages towards Rose and her group.
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`37.
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`Those songs were released before 3PM had even met DJ Cutmaster C.
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`38.
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`Those statements clearly show actual malice and intent on causing damage to Rose through
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`premeditated attacks and motive to sabotage Rose’s public image.
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`39,
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`Rose was completely unaware andoblivious to Nicki Minaj’s targeted attacks.
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`40.
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`Sources familiar with the matter confirmed that Nicki Minaj has indeed admitted and often brags
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`to them about how all the lyrics and statements presented in this complaint are about Rose.
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`41.
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`Rosefirst discovered in June 2022 Nicki Minaj’s long, extensive history of espionage, secret
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`animosity, verbal attacks, false allegations, aggressive, hostile, and fighting words directed
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`towards Rose, countless efforts at intentionally interfering with Rose’s prospective economic
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`advantage in the music industry and professional circles, and defaming Rose’s character.
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`Rose’s Faux Pas: The Come Up DVD
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`42.
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`Around late October 2007, Fendi, creator of the Come Up DVD and Nicki Minaj’s managerat the
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`time, wanted to meet 3PM.
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`43,
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`DJ Cutmaster C madethe introduction.
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`4A.
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`At the time of 3PM’s first introduction to Fendi, the group had never heard of the Come Up DVD
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`or Fendi. Nor were the girls aware of Nicki Minaj’s existence and that Fendi was her manager.
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`The girls had never mether. In fact, neither Fendi nor DJ Cutmaster C ever even mentioned the
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`names Nicki Minaj or Oniku Muraj. Rose and her groupmate were entirely clueless of Nicki
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`Minaj’s existence or who she was.
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`45.
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`DJ Cutmaster C andthe girls met Fendi at a restaurant in a nearby town where Fendi wanted to
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`learn more about the group and asked them to sing for him. After paying for dinner, Fendi also
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`discussed with DJ Cutmaster C options for studio time and expressed interest in working with the
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`group. Fendi had even pitched the idea to DJ Cutmaster C of creating a DVD seriestailored just
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`for 3PM. A couple of weekslater, Fendi approached DJ Cutmaster C andthe girls with an
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`opportunity for “massive exposure”. That opportunity was for 3PM to begin making appearances
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`on the Come Up DVD,which would then segue into 3PM’s own DVD series. Fendi cameto the
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`apartment where the girls were living in Hackensack io begin filming “‘a day in the life” type of
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`footage of the group. Rose volunteered to go first. Fendi, who acted as director, wanted totest
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`ideas for b-roll footage in different areas of the apartment.
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`46.
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`Rose, who customarily wore conservative clothing since her youth, wastold that her original
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`outfit was not a fit for the footage and that to be a successfulartist, she needed to learn to be more
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`comfortable showing “alittle skin”. Fendi suggested for Rose to change into something with
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`more sex appeal because it would producebetter results. After deliberation, Rose decidedto let
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`her guard downand agreed to be more “marketable”. Therefore, Rose burrowed her yroupmute’s
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`pink lingerie top that fully covered her torso and changedinto black boy short lingerie bottoms.
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`Since her early preteen years, Rose had alwayshad a “curvy”figure and a robustderriere that she
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`would hide beneath her skirts and dresses as a conservative teen. Fendi would then throw out
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`ideas for Roseto “look into the bathroom mirror while combing yourhair”, or “pretend to reach
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`over the showerfor a bar of soap” or “reach overthe stove fora skillet in the cabinet as if you’re
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`getting ready to cook”, as he collected b-roll footage. Although Rose was wearing boy shorts
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`lingerie, in certain angles, her butt would become exposed due to its size. But Fendi assured the
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`girls that they were in good hands,that the project would positively promote the group, and that
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`the girls would be pleased with the outcome.
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`47.
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`Trusting Fendi’s judgementas a professional videographer, Rose followedhis instructions.
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`Throughout filming, Rose wasfully dressed in the lingerie set that she was encouraged to change
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`into and did not do anything sexually explicit while being filmed. She talked a lot about the group
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`and their journey, and highlighted details about the group that she felt would resonate with an
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`audience learning about 3PM forthe first time. After filming Rose, Fendi wanted more time to
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`edit the existing footage before filming the other groupmatelater.
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`48.
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`However, 3PM nevergot the chanceto finish the project with Fendi because the girls discovered
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`that DJ Cutmaster C (and Nicki Minaj, on information and belief) werestill using their photos to
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`post sex ads on Craigslist without their knowledge or consent, to humiliate and defame the group
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`by giving the impression that the girls were sex workers instead of recording artists. As a result,
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`the girls abruptly ended their businessrelationship with DJ CutmasterC, cutting offall ties with
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`him around Novemberbecause Roseabsolutely refused to allow the group to engage in
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`prostitution with unwavering conviction.
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`49.
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`Rose never saw Fendi or DJ Cutmaster C in person ever again.
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`50.
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`Rose was neversexually involved with Fendi or DJ Cutmaster C.
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`S31.
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`Rose, and to Rose’s knowledge, her groupmate, were never introduced to Nicki Minaj, nor were
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`they aware of her existence.
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`52. DJ Cutmaster C nor Fendi ever took Rose, or to Rose’s knowledge, her groupmate, to any strip
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`clubs,
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`53. And Rose never becameorhas ever beena stripper.
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`54. Rose Celestin’s immediate cousins, who wereandarestill established doctors,lived close by in
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`Jamaica Estates, NY. Rose’s groupmate also had a close relative nearby. Her father lived in
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`Brooklyn, NY. Additionally, 3PM, to Rose’s knowledge,still had a good professional
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`relationship with Xavier Lewis and So So Def. Therefore, there was absolutely no reason
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`whatsoever for Rose or her groupmate to engage in anyillicit sexual activities, stripping, or other
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`unrespectable means to support themselves.
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`55. Because the girls had abruptly endedall ties with DJ Cutmaster C in November 2007, Rose did
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`not have the opportunity to review Fendi’s final cut of the footage, nor did she give Fendi
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`permission to use the footage for public consumption.
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`Rose Celestin at Monza
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`56. 3PM left Hackensack, NJ abruptly in the middle of the night in November 2007. Rose drove to an
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`abandonedSears parking lot in a nearby townso that she and her groupmate could regaintheir
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`composure and strategize their next move. They had considered going back home to Arkansas or
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`reaching out to their nearby relatives, or Xavier, but were afraid of hearing “I told you so”,
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`because their families were not comfortable with them moving to NYC,especially since their
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`families had never heard of DJ Cutmaster C. The girls were just too embarrassedto tell their
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`parents and relatives what happened. So instead, Rose madea few calls to some of her contacts
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`before the girls went to sleep in Rose’s PT Cruiserthat night until early morning. At the crack of
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`dawn, Rapper Cassidy met up with the girls at a gas station near the abandonedSears parking lot.
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`Later that day, the girls followed Cassidy’s vehicle to Grindhouse Studios, located in Midtown
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`Manhattan, NY. At Grindhouse, 3PM metthe studio owner, “Panther”. Also at the studio was
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`Grady Spivey.
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`37.
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`The girls then stayed at Grindhouse for a couple of days. After, they walked to the next street to
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`37% Street and 6% Avenue to Monza, a studio owned by Kasseem Dean (“Swizz Beatz’). Rose
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`reasonably assumesthat Swizz Beatz heard aboutthe situation and sent Cassidy to go fetch the
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`girls from the abandonedSears parking lot to bring them somewheresafe.
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`58.
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`While at Monza, 3PM wasstill missing a third member because she had not yet graduated high
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`school. As a result, Swizz Beatz suggested forthe girls to focus on songwriting. Therefore, 3PM
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`disbanded in November 2007 and remained at Monzaas their place of domicile where Rose
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`Celestin was a songwriter and producer. There, Rose and her groupmate also met Swizz Beatz’s
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`production team, The Individualz, who wereall in the same age rangeasthegirls.
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`59.
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`The Individualz comprised of Avery Chambliss, Joseph Alexander, Jose Gonzalez, and Anderson
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`Hernandez (“Vinylz”). Vinylz eventually left The Individualz to join Drake’s OVOrecordlabel,
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`whereheisstill gainfully associated with Drake to this day.
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`60.
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`During the girls’ time at Monza, they had established good, healthy relationships with Swizz
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`Beatz, Grady Spivey, and The Individualz. Swizz Beatz, Grady Spivey, and The Individualz
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`treated them with respect. Rose was never sexually involved with Swizz Beatz, Grady Spivey, or
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`The Individualz.
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`The Aftermath of the Come Up DVD Footage
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`61.
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`Oneday, around February 2008, Grady Spivey caught wind of the Come Up DVD footage,
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`approached Roseaboutit, and expressed his disapproval. Rose, who wasabsolutely blindsided by
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`the release of the unapproved footagefirst saw it on the internet. It was then she immediately
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`realized that Fendi had released the footage for public consumption on his Come Up DVD
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`platform without Rose’s knowledge.
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`62.
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`Rose wasinstantly mortified at the tasteless and unflattering representation of herself. She had no
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`idea that Fendi had zoomedin on her butt while filming, when she wasjust following Fendi’s
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`directions during the shoot. He had ensuredthegirls that they could trust his judgement while
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`

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`Case 1:23-cv-03335-CJN Document1 Filed 11/09/23 Page 14 of 98
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`directing the project and that they would not be disappointed with the outcome. However,that
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`wasthe furthest thing fromthe truth. Not only was the footage released without Rose’s
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`permission, but it was also out of context with the true intent of the overall project Fendi had
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`presented to 3PM.
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`63. Becausethe original intent of the project was to be a documentary-style series similar to “a day in
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`the life”, leading up to the release of their debut single, Fendi wanted to capture b-roll footage of
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`the girls that would help show their personalside so their target fanbase could resonate with them
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`on a more personallevel, while main footage ofthegirls in the studio working on their debut
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`single and navigating their single deal would bethe Icading angle.
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`64. The girls were scheduled to return to Atlanta to wrap up businessfor their debutsingle.
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`Therefore, in the footage, Rose hadslipped andsaid that she was “from Atlanta” rather than
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`saying she was “in Atlanta”, because the intention wasfor the girls to act as if they were in
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`Atlanta in the middle of recording their single, for cohesiveness since they were due back soon to
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`tic loose ends. ‘hat proves that the footage on the Come Up DVD wasrawfootage that was not
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`authorized to be released.
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`65. As a result, if one did not know Rosepersonally and had seen the footage, they would think that
`Lo
`Ln an
`as
`(Cane eten te etead 5
`Veerte
`7 ae _—
`SHe wads LOM AAlidiitd, WCOLBId WIstCdd O Pine Bluff, Arkansas, based on the unauthorized release
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`of the Come Up DVD footage.
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`66. That is a key detail of this complaint.
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`Nicki Minaj Plants the Seed to Defame Rose Celestin’s Character
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`67. Rose, who was 18 at the time the footage was recorded in Hackensack, and 19 at the time the
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`footage wasreleased without consent, explained to Grady Spivey what really happened and how
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`the footage cameto be.
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`68. Rose would then Google her nameto find the embarrassing footage and screenshots ofher butt
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`plastered throughout Google search results. Rose was extremely upset, disgusted, felt exploited
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`

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`Case 1:23-cv-03335-CJN Document 1 Filed 11/09/23 Page 15 of 98
`Case 1:23-cv-03335-CJN Document1 Filed 11/09/23 Page 15 of 98
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`by the situation, and firmly believed that it was an act of sabotage doneto ruin the public’s
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`perception of Rose and 3PM,causingher to lose the respect of someofher industry peers at the
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`time whohad seen the footage.
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`69.
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`Several weeks after Grady brought the footage to Rose’s attention, she Googled her name again
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`and found that the footage and screenshots of her butt no longer populated search results, and
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`they were completely scrubbed from the internet and search engines. Relieved, Rose reasonably
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`assumes that Swizz Beatz had the footage and unflattering screenshots scrubbed from the internet
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`and handledthesituation on her behalf. Moving on from the situation, the embarrassing footage
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`wasnever brought up again. Rose wasthen able to put that extremely unfortunate situation
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`behind heras a crucial lesson learned.
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`70.
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`Dealing with post-traumatic stress from the situation, Rose stayed isolated from music industry
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`events and social groups out of fear and embarrassment that some had seen the footage and
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`instead focused heavily on songwriting and producing. Eventually, knowing that the footage was
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`no longer accessible on the internet or through search engines, Rose wasable to put that incident
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`behind her and forget