Case 1:24-cv-01457 Document 1 Filed 02/26/24 Page 1 of 73
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`UNITED STATES FEDERAL COURT
`SOUTHERN DISTRICT OF NEW YORK
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`Case Number: 24-1457
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`Civil Action
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`Jury Demand
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` Plaintiff,
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`RODNEY JONES,
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`v.
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`SEAN COMBS,
`JUSTIN DIOR COMBS,
`ETHIOPIA HABTEMARIAM,
`LUCIAN CHARLES GRAINGE,
`KRISTINA KHORRAM,
`CHALICE RECORDING STUDIOS,
`LOVE RECORDS,
`MOTOWN RECORDS,
`UNIVERSAL MUSIC GROUP,
`COMBS GLOBAL ENTERPRISES,
`JOHN and JANE DOES 1-10 and
`ABC CORPORATIONS. 1-10
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`Defendants.
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`TRIGGER WARNING:
`THIS DOCUMENT CONTAINS HIGHLY GRAPHIC INFORMATION OF A
`SEXUAL NATURE, INCLUDING SEXUAL ASSAULT. ADDITIONALLY,
`THERE ARE GRAPHIC IMAGES OF THE AFTERMATH OF A SHOOTING,
`REDACTED IMAGES OF SEXUAL INTERCOURSE, REDACTED IMAGES OF
`MINORS, SEX WORKERS, AND PROSTITUTES, DETAILS OF SEX
`TRAFFICKING, AND THE ILLEGAL DISTRIBUTION OF GUNS, AND DRUGS
`
`Plaintiff Rodney “Lil Rod” Jones (“Mr. Jones”) hereby alleges, as and for his Complaint
`against Defendant Sean Combs (“Mr. Combs”), Defendant Justin Dior Combs (“J. Combs”),
`Defendant Lucian Charles Grainge (“Mr. Grainge”), Defendant Ethiopia Habtemariam (“Ms.
`Habtemariam”), Defendant Kristina Khorram (“Ms. Khorram”), Defendant Chalice Recording
`Studios (“CRS”), Defendant Love Records (“LR”), Defendant Motown Records (“MR”),
`Defendant Universal Music Group (“UMG”), Defendant Combs Global Enterprises (“CGE”),
`John and Jane Does 1-10, ABC Corporations 1-10, as follows:
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`Case 1:24-cv-01457 Document 1 Filed 02/26/24 Page 2 of 73
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`JURISDICTION AND VENUE
`1. This Court has personal jurisdiction over the Defendants under and consistent with the
`Constitutional requirements of Due Process in that the Defendants, acting directly or through
`his agents or apparent agents, committed one or more of the following:
`a. The transaction of any business within the state;
`b. The making of any contract within the state;
`c. The commission of a tortious act within this district and
`d. The ownership, use, or possession of any real estate in this state.
`2. From September 2022 to the date of this filing, Defendants have consistently and purposefully
`availed themselves of the privilege of conducting activities within New York, thus invoking
`the benefits and protections of New York law. In return for these benefits and protections,
`Defendants must submit to the burdens of litigation in New York.
`3. This litigation arises from or relates to the tortious activities defendants visited upon
`defendants in the states of New York, California, Florida, and the United States Virgin Island.
`This tortious conduct violated United States Federal Rico Laws.
`4. Requiring Defendants to litigate these claims in this District does not offend traditional
`notions of fair play and substantial justice. Plaintiffs’ claims arise from some conduct
`occurring by Defendants in New York.
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`PARTIES
`5. Plaintiff Rodney Jones is an American artist and music producer. Mr. Jones resides in the
`states of New York, and California.
`6. Defendant Sean Combs is a rapper and record executive popularly known by his stage names
`Puff Daddy, Puffy, P. Diddy, Diddy, Brother Love or Love. Mr. Combs came to fame in the
`early 1990s with his record label Bad Boy Records. He rose to prominence in the music and
`entertainment industry over the decades and is regularly referred to as a hip-hop mogul. Mr.
`Combs resides at 200 South Mapleton Dr., Beverly Hills, California 90024.
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`Defendant Sean Combs
`7. Defendant Justin Dior Combs is the son of Mr. Combs and Misa Hylton. J. Combs was born
`on December 30, 1993. J. Combs is a producer and actor. He has appeared on TV series like
`Catfish: The TV Show, Wild' N Out and Hip-Hop Squares. Defendant Justin Dior Combs
`resides at 1550 N El Centro Ave, Los Angeles, CA 90028.
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`
`Defendant Justin Dior Combs
`8. Defendant Lucian Charles Grainge is the CEO of Defendant Universal Music Group.
`Defendant Lucian Charles Grainge resides at 53551 Ross Ave Unit 34A, La Quinta, CA
`92253; and 668 Chautauqua Blvd, Pacific Palisades, CA 90272.
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`Lucian Charles Grainge
`9. Defendant Ethiopia Habtemariam is the Former CEO of Defendant Motown Records the
`parent company of Defendant Love Records. Defendant Habtemariam resides at 13701
`Riverside Dr Apt 8Flr, Sherman Oaks, CA 91423-2430.
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`Ethiopia Habtemariam
`10. Defendant Kristina Khorram is the Chief of Staff to Sean “Diddy” Combs, Combs Global
`Enterprises. She resides at 10445 Wilshire Blvd Apt 501, Los Angeles, CA 90024.
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`Kristina Khorram, Chief of Staff to Sean "Diddy" Combs
`11. Defendant Chalice Recording Studios is a popular recording studio located at 845 Highland
`Ave, Los Angeles, CA 90038, United States.
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`12. Defendant Motown Records is a record label with a principal place of business located at 1750
`Vine St, Los Angeles, CA. Ethiopia Habtemariam was the chairman and CEO of Universal
`Music Group’s Motown Records.
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`13. Defendant Universal Music Group is a record label with a principal place of business located
`at 2220 Colorado Avenue in Santa Monica, California. Lucian Grainge is the Chairman &
`CEO, Universal Music Group.
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`14. Defendant Love Records is a record label with a principal place of business located at 6255
`Sunset Boulevard Suite 713. Los Angeles, CA, United States 90028. Defendant Love Records
`was founded by Mr. Combs and Defendant Motown Records.
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`15. Defendant Combs Enterprises is a diverse portfolio of businesses and investments
`that includes music, fashion, fragrance, beverage, marketing, film, television, and media
`properties. They have a principal place of business located in New York, New York.
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`Combs Global
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`RODNEY LIL ROD JONES
`16. Rodney “Lil Rod” Jones Jr. is from the Windy City [Chi-town]. He was born and raised in
`Chicago, Illinois. Mr. Jones is the second oldest son and fourth child out of nine siblings. Mr.
`Jones comes from a long line of Gospel Music influencers.
`17. Mr. Jones started playing instruments at the age of five. He began playing drums in church,
`and at the age of thirteen he picked up playing the guitar. From thirteen to present day, Mr.
`Jones has taught himself to play over thirteen instruments.
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`Mr. Jones, the Child Prodigy
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`18. Mr. Jones is considered a musical prodigy. His talents have led him to produce and create a
`commercial marketplace for music that has been recorded by some of the most prestigious
`and highly acclaimed artists in music history.
`19. Throughout the duration of his career, Mr. Jones has worked the south side of Chicago Music
`scene, playing with the following legendary greats: Georgia Mass Choir, Donald Lawrence,
`The Clark Sisters and The Smokie Norful.
`20. On or about, August 2022 Mr. Jones received a call from Mr. Combs requesting that he
`produce several songs on a rhythm and blues album titled, “The Love Album: Off the Grid,”
`(“Love Album”).
`21. Mr. Jones agreed, and his life has been detrimentally impacted ever since.
`
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`SUMMARY OF EVENTS
`22. From September 2022 to November 2023, Mr. Jones produced nine songs on Mr. Combs'
`Love album.
`23. Mr. Jones lived with Mr. Combs for months at a time, spending holidays, birthdays, and
`missing major family events.
`24. Mr. Jones resided at Mr. Combs residence located in Los Angeles, California, New York City,
`and Miami, Florida. Mr. Jones also spent several weeks on a yacht rented by Mr. Combs in
`the US Virgin Islands.
`25. Throughout his time with Mr. Combs, Mr. Jones witnessed, experienced, and endured many
`things that went far beyond his role as a Producer on the Love album.
`26. The claims raised in this complaint have been corroborated through witness statements,
`video/audio recordings, and images that Mr. Jones has in his possession.
`27. Mr. Combs required Mr. Jones to record him constantly. On several occasions, Mr. Combs
`took Mr. Jones cellphone and began recording himself. As a result, Mr. Jones has secured
`HUNDREDS of hours of footage and audio recordings of Mr. Combs, his staff, and his guests
`engaging in serious illegal activity.
`28. Mr. Jones has secured irrefutable evidence of:
`a. The acquisition, use, and distribution of ecstasy, cocaine, GHB, ketamine, marijuana,
`and mushrooms,
`b. The displaying and distribution of unregistered illegal firearms,
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`c. Mr. Combs providing laced alcoholic beverages to minors and sex workers at his
`homes in California, New York, the U. S. Virgin Islands1, and Florida,
`d. Mr. Combs Chief of Staff, Kristina Khorram (“KK”) instructing her staff to retrieve
`drugs so she can provide it to Mr. Combs for his consumption,
`e. Christian Combs drugging and sexually assaulting a woman2,
`f. Mr. Combs detailing how he planned to leverage his relationship with Bishop T.D.
`Jakes to soften the impact on his public image of Cassie Ventura’s lawsuit,
`g. Yung Miami’s cousin, and or assistant sexually assaulting Mr. Jones,
`h. Actor Cuba Gooding Jr. sexually harassing and assaulting Mr. Jones,
`i. Rapper3 (REDACTED) on Mr. Combs yacht consorting with underaged girls, sex
`workers, and
`j. R&B Singer4 (REDACTED) in Mr. Combs Los Angeles home consorting with
`underaged girls and sex workers.
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`CHALICE RECORDING STUDIOS SHOOTING
`29. On or about September 12, 2022, Mr. Combs held a writers and producers camp at Chalice
`Recording Studio at 845 Highland Ave, Los Angeles, CA 90038.
`30. Present at this camp were Mr. Combs, his son Justin Combs, and Justin's friend named G.
`31. Mr. G is a 30-year-old tall African American male.
`32. In addition to these individuals, other musicians were present at the camp. This writer has
`spoken to several musicians who attended the camp.
`33. One evening during this camp, Mr. Combs, J. Combs, and G were in a heated conversation.
`34. That conversation was moved out of the studio and into a restroom adjacent to where Mr.
`Jones was sitting.
`35. Mr. Jones was approximately 2 feet away from the bathroom when gunshots rang out. Mr.
`Jones recalls hearing multiple gunshots.
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`1 This writer spoke with several employees of the yacht rented my Mr. Combs in the U.S. Virgin Islands who
`personally witnessed Defendant Khorram instruct her staff, Brendan Paul, Frankie Santella, and Moy Baun spike
`bottles of champagne with ecstasy.
`2 A complaint is forthcoming.
`3 He is a Philadelphia Rapper who dated Nicki Minaj.
`4 He is a Grammy Award winning R&B singer who had trouble with law enforcement after assaulting a Bajan
`Billionaire.
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`36. Mr. Jones immediately went into a state of shock and feared that he would be shot next. Mr.
`Jones genuinely believed that he would be shot through the door due to how close he was.
`37. After the shooting ended, a crowd gathered around the restroom.
`38. When the door finally opened, Mr. Combs and J. Combs exited.
`39. G was lying on the restroom floor in a fetal position, holding his stomach and bleeding out of
`his leg/hip area.
`40. Everyone stood around looking upon G. Frustrated by the lack of aid to G, Mr. Jones dropped
`everything, ran to G, and immediately began placing pressure on G’s gunshot wound to his
`stomach.
`41. As he was applying pressure on his stomach, Mr. Jones realized that G was gushing blood
`from another area near his leg/hip.
`42. He decided to lift G and placed him to sit on the toilet. Mr. Jones asked the crowd to call the
`ambulance.
`43. Mr. Jones lifted G and brought him to the ambulance at the studio's front. At this time, Mr.
`Combs and Justin disappeared to another part of the studio.
`44. Mr. Combs gave strict instructions to inform the police that he had nothing to do with the
`shooting. He also forced Mr. Jones to lie to the police by telling them that G was shot standing
`outside the studio by a drive-by assailant.
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`45. Mr. Jones has several corroborating witnesses who spoke with this writer anonymously due
`to fear of retaliation from Mr. Combs. They have agreed to speak publicly when subpoenaed.
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`46. Mr. Jones has the clothing he wore that day and believes it may still have the stains and DNA
`of G’s blood.
`47. The following are screenshots of the aftermath of the restroom where G was shot by either
`Mr. Combs or J. Combs:
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`Aftermath of the Shooting of G
`48. Clearly, G was NOT shot outside of the studio as Mr. Combs instructed his team to report to
`law enforcement.
`49. Mr. Combs and Defendant’s LR, MR, UMG, and CRS provided private security for the writers
`camp at Defendant CRS.
`50. The Security was porous and lackluster at best.
`51. The fact that either Mr. Combs and J. Combs were allowed to enter CRS with guns, and those
`guns were not confiscated by security is a clear breach of duty by Mr. Combs, Defendant’s
`LR, MR, and UMG to protect Mr. Jones and the other attendees of this writers camp.
`52. As a result of this shooting, Mr. Jones is severely traumatized. Mr. Jones now suffers from
`PTSD, severe anxiety, depression, and insomnia.
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`MR. JONES WAS SEXUALLY HARASSED, AND ASSAULTED BY MR. COMBS
`53. Throughout his time living with Mr. Combs, Mr. Jones was the victim of constant unsolicited
`and unauthorized groping and touching of his anus by Mr. Combs.
`54. These events took place in LA, NY, FL, and the United States Virgin Islands.
`55. In addition to the unsolicited and unauthorized touching, Mr. Jones was forced by Mr. Combs
`to work in Mr. Combs' bathroom as Mr. Combs walked around naked and showered in a clear
`glass enclosure.
`56. As a heterosexual Christian man, Mr. Jones was uncomfortable with Mr. Combs’ advances
`and expressed his discomfort to Mr. Combs Chief of Staff, Kristina Khorram (“KK”).
`57. KK responded to Mr. Jones complaint with, “you know, Sean will be Sean.”
`58. KK also attempted to downplay Mr. Combs groping of Mr. Jones anus and genitals, as friendly
`horseplay, stating that those acts were Mr. Combs way of “showing that he likes you [Mr.
`Jones]”.
`59. Despite these assurances, on several occasions when Mr. Combs began to undress and walk
`around his house naked, KK would say, “okay, I am leaving now,” and she would disappear.
`60. KK’s hypocrisy is breathtaking at best or enabling at worst.
`61. Mr. Jones believes that KK aided and abetted Mr. Combs’ sexual assault of him and was
`working with Mr. Combs to groom him into accepting a homosexual relationship.
`62. Through these sexually deviant acts, one would say Mr. Combs has a pattern and practice of
`engaging in such nefarious activity. This ongoing conduct shows that Mr. Combs cannot be
`rehabilitated.
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`MR. COMBS ATTEMPTED TO GROOM MR. JONES INTO ENGAGING IN GAY SEX
`63. Mr. Combs was aware that Mr. Jones looked up to, and idolized music Producer Steven Aaron
`Jordan (“Stevie J”).
`64. Stevie J is an American DJ, record producer, and television personality.
`65. Stevie J was part of the Bad Boy Records production team the Hitmen.
`66. In 1997, Stevie J won a Grammy Award for his work on Puff Daddy's debut album.
`67. Throughout the late 1990s, Stevie J produced for several artists including Mariah Carey, Tevin
`Campbell, The Notorious B.I.G., 112, Jodeci, Faith Evans, Jay-Z, and Eve.
`68. Stevie J was one of the producers on the Love Album.
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`69. Mr. Combs used access to Stevie J, and his knowledge of Mr. Jones admiration of Stevie J to
`groom and entice Mr. Jones to engage in homosexuality.
`70. Mr. Combs went so far as to share a video of Stevie J anally penetrating a Caucasian male
`without a condom. This was done to ease Mr. Jones’ anxiety concerning homosexuality.
`According to Mr. Combs, “this is a normal practice in the music industry, look even Stevie J
`is doing it.”
`71. Mr. Combs informed Mr. Jones that he had engaged in sexual intercourse with rapper5
`(REDACTED), R&B singer6 (REDACTED), and Stevie J.
`72. Mr. Combs promised to make sure that Mr. Jones wins producer of the year at the Grammys
`if he engaged in homosexuality.
`73. The following are screenshots of the video7 of Stevie J anally penetrating a Caucasian male,
`that Mr. Combs provided to Mr. Jones:
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`5 He is a Philadelphia Rapper who dated Nicki Minaj.
`6 He performed at the Superbowl and had a successful Vegas residency.
`7 This writer is in possession of the video and will provide a copy to the court.
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`THANKSGIVING 2022, MR. JONES IS SEXUALLY ASSAULTED BY
`YUNG MIAMI’S COUSIN
`74. On Thanksgiving Day 2022, Mr. Jones was in Mr. Combs house located in Miami, Florida.
`Yung Miami and her female cousins were also present.
`75. Mr. Combs was intoxicated and offered cocaine to Mr. Jones. Mr. Jones rejected him and
`proceeded to walk to the restroom.
`76. While using the restroom Yung Miami’s cousin burst into the bathroom and began groping
`Mr. Jones. Mr. Jones believes that Mr. Combs sent her in there to sexually assault Mr. Jones.
`77. As she entered the bathroom she dropped to her knees and began performing oral sex on Mr.
`Jones exposed penis. Mr. Jones pushed her away and exited the bathroom.
`78. Yung Miami’s cousin did not accept Mr. Jones rejection, as she proceeded to follow Mr. Jones
`out of the bathroom.
`79. She started undressing and attempted to straddle him and have sex with him in the presence
`of Mr. Combs and his staff.
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`80. Once again Mr. Jones pushed her off. The following are images from a video8 of Yung Miami,
`her cousin, Mr. Jones, and Mr. Combs:
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`Mr. Jones and Mr. Combs on Thanksgiving Day right before Mr. Combs invites Mr. Jones
`into the restroom and attempted to force him to take cocaine.
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`Yung Miami, and her female cousin who sexually assaulted Mr. Jones on
`Thanksgiving Day 2022
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`TRAFFICKING AND VICTIMS’ PROTECTION ACT
`81. Throughout his time with Mr. Combs, Mr. Jones was transported from California to New
`York, Florida, and the United States Virgin Islands.
`82. During this time, Mr. Jones was forced to solicit sex workers and perform sex acts to the
`pleasure of Mr. Combs.
`83. On or about February 4, 2023, Mr. Combs forced Mr. Jones to bring prostitutes and sex
`workers back to his home in Miami, Florida.
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`8 This writer is in possession of the video and will provide a copy to the court.
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`The Sex Workers That Mr. Combs Forced Mr. Jones To Bring Back To His Home
`84. On or about, February 2, 2023, incident, Mr. Jones believes Mr. Combs drugged him. Mr.
`Jones recalls waking up naked, dizzy, and confused. He was in bed with two sex workers and
`Mr. Combs. He also recalls aimlessly wandering around the house with no clothes on.
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`Sex Workers In Mr. Jones Bed The Morning After Being Drugged
`85. On another occasion in Miami, Florida, on Thanksgiving night of 2022, Mr. Combs asked Mr.
`Jones and DeForrest Taylor to enter the studio bathroom.
`86. He asked them for a hundred-dollar bill because he wanted them to do cocaine with him.
`87. Mr. Jones was scared, but luckily, he didn’t have a hundred-dollar bill, so Mr. Combs waited
`a little later to do coke with Yung Miami.
`88. Later that evening, he required Mr. Jones to solicit sex workers from Booby Trap on the River
`located at 3615 NW S River Dr, Miami, FL 33142. Mr. Jones did so, and Mr. Combs forced
`him to engage in unsolicited sex acts with these workers.
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`Booby Trap on the River
`89. As part of Mr. Jones sex worker recruitment tools, Mr. Combs provided Mr. Jones with an
`exclusive Bad Boy baseball cap and required him to wear it to Booby Trap on the River as a
`signal to any sex worker he approached that Mr. Combs was in town and had sent Mr. Jones
`to recruit them.
`90. Mr. Jones had no desire to visit Booby Trap on the River. Mr. Jones had no desire to solicit
`sex workers from Booby Trap on the River. Mr. Combs used his power and influence, to
`intimidate and force Mr. Jones into soliciting sex workers from Booby Trap on the River. As
`detailed below, Mr. Combs used many tactics to maintain dominion and control of Mr. Jones.
`91. Apparently, these workers were accustomed to servicing Mr. Combs, and would know that he
`is in town by the sight of the Bad Boys baseball cap.
`92. The following are Instagram Profiles of two of the sex workers that Mr. Combs required Mr.
`Jones to solicit and have sex with at his home in Miami, Florida:
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`93. Mr. Jones had no desire to solicit and or have sex with the individuals in the previous
`paragraph. Mr. Combs used his power and influence, to intimidate and force Mr. Jones into
`soliciting and sleeping with these women.
`94. The following is the phone number of another sex worker that Mr. Combs required Mr. Jones
`to solicit and perform sex acts with at his home in Miami, Florida:
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`
`95. Mr. Jones had no desire to solicit and or have sex with the individual in the previous
`paragraphs. Mr. Combs used his power, and influence, to intimidate and force Mr. Jones into
`soliciting and sleeping with the individuals above.
`96. Mr. Combs used many tactics to maintain dominion and control of Mr. Jones. He promised
`him a Grammy for Producer of the Year for the Love Album. He offered him $250,000.00 to
`purchase all the instruments he wanted. He promised him ownership of his $20,000,000
`property, 1 Star Island, in Miami, Florida. He promised access to record label executives like
`Defendants Lucian Charles Grainge and Ethiopia Habtemariam.
`97. Mr. Combs would often switch up his approach. He would go from promising Mr. Jones the
`world to threatening Mr. Jones with physical harm. Mr. Combs threatened to eat Mr. Jones
`face and informed Mr. Jones that he is willing to kill his mother, Janice Combs, if he must in
`order to get what he wants, so he wouldn’t think twice to harm Mr. Jones.
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`MR. COMBS AND J. COMBS SOLICITS, DRUGS AND ENGAGES IN ILLICIT SEX
`ACTS WITH MINORS AND SEX WORKERS
`98. On or about July 2, 2023, in California, Mr. Combs had a "listening party" at his home.
`99. Present at this party was a R&B artist9 (REDACTED), J. Combs, sex workers, and some
`underaged girls.
`100. The event began at 7 pm. Mr. Combs requested female sex workers and required Mr. Jones
`to solicit them. An hour later, several sex workers appeared.
`101. In addition to sex workers, there were at least five women in the crowd that were under the
`age of sixteen.
`102. Mr. Combs forced all the women to drink laced DeLeon liquor. Upon information and
`belief, Mr. Combs laced the liquor with ecstasy.
`103. Mr. Combs did not check the identification of any of these underage girls.
`104. The presence of these underage women made Mr. Jones very uncomfortable.
`105. He attempted to leave, and Mr. Combs forced him to stay.
`106. Mr. Combs went so far as to take Mr. Jones' car keys to prevent him from leaving.
`107. After being forced to drink laced DeLeon shots Mr. Jones began feeling lightheaded and
`recalls passing out and waking up at 4 am the following morning naked with a sex worker
`sleeping next to him.
`108. Screenshots of a video10 from that night is imbedded below:
`
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`9 He is a Grammy Award winning R&B singer who had trouble with law enforcement after assaulting a Bajan
`Billionaire.
`10 This writer is in possession of the video and will provide a copy to the court.
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` Mr. Combs With an
` Underage Female
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`Underage Female
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`Sex Worker
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`Justin Combs With an
`Underage Female
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`MR. COMBS ATTEMPTS TO PASS OFF MR. JONES TO CUBA GOODING JR.
`109. Mr. Jones believes that Mr. Combs was grooming him to pass him off to his friends.
`110. This fear became reality when Mr. Combs introduced Mr. Jones to Cuba Gooding Jr. while
`they were on Mr. Combs’ yacht.
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`111. During the introduction, Mr. Combs suggested that Cuba “get to know” Mr. Jones better.
`He then left them alone in a makeshift studio on the yacht.
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`Mr. Combs and Cuba Gooding Jr. Moments Before Mr. Jones is Assaulted
`
`112. As evidenced by a video, of which screenshots are imbedded below, Cuba Gooding Jr.
`began touching, groping, and fondling Mr. Jones’ legs, his upper inner thighs near his groin,
`the small of his back near his buttocks and his shoulders.
`113. Mr. Jones was extremely uncomfortable, and proceeded to lean away from Mr. Gooding Jr.
`114. He rejected his advances and Mr. Gooding Jr. did not stop until Mr. Jones forcibly pushed
`him away. The following is a screenshot11 of the encounter with Cuba Gooding Jr.:
`
`
`11 This writer is in possession of the video and will provide a copy to the court.
`
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`Case 1:24-cv-01457 Document 1 Filed 02/26/24 Page 23 of 73
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`Cuba Gooding Jr12. Forcibly Touching Mr. Jones on Mr. Combs yacht
`
`THE LOVE ALBUM
`115. Throughout his time with Mr. Combs, Mr. Jones was under an implied work-for-hire
`agreement.
`116. He was not compensated for his time living with Mr. Combs or for the songs he produced.
`117. As evidence, he was listed as a producer for the following songs on the Love Albums final
`release: Deliver Me, Stay PT 1, Reaching, What’s Love, Stay Awhile, Moments, Need
`Somebody, Homecoming, and Tough Love.
`118. Mr. Combs and Defendants LR, MR, UMG all benefited from Mr. Jones’ work product.
`119. They failed to compensate Mr. Jones for his work.
`120. As a result, Mr. Combs, and Defendants LR, MR, UMG were all unjustly enriched at the
`expense of Mr. Jones.
`121. Mr. Jones attempted to work with Mr. Combs to secure his publishing and royalty rights
`for the work he completed on the Love album. Mr. Combs only offered Mr. Jones $29,000.00
`for 13 months, thousands of hours of work, and 9 songs that made it to the Love album.
`Ironically, Mr. Jones was willing to take $50,000.00, his publishing and royalties. Mr. Combs
`self-serving greed would not allow him to pay13 Mr. Jones an additional $21,000.
`
`
`12 Mr. Gooding Jr. has a storied history of sexually assaulting and forcibly touching individuals against their well.
`https://www.usatoday.com/story/entertainment/celebrities/2023/11/22/cuba-gooding-jr-lawsuits-sexual-assault-
`battery/71682417007/
`13 This writer has retained other creatives, artists, and writers who have experienced this same treatment from Mr.
`Combs and will file suit in the coming weeks.
`
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`Case 1:24-cv-01457 Document 1 Filed 02/26/24 Page 24 of 73
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`122. Mr. Combs deceptive business practices became so bad that Mr. Jones was left with no
`choice other than to make a public plea on social media for Mr. Combs to pay him for his
`work.
`123. After publicly requesting that Mr. Combs do the right thing, and pay him fairly, Mr. Jones
`received an onslaught of threating messages from Stevie J and Love Records A&R DeForrest
`Taylor14.
`
`
`
`DeForrest Taylor Threatening Mr. Jones
`
`MR. COMBS USED HIS POWER, AND INFLUENCE TO
`THREATEN AND INTIMIDATE MR. JONES
`124. According to Mr. Jones, Mr. Combs is very forceful and demanding.
`125. Mr. Combs does not take no for an answer and would often threaten to inflict bodily harm
`on Mr. Jones if Mr. Jones did not comply with his demands.
`126. As detailed above, Mr. Combs threatened to eat Mr. Jones' face.
`
`
`14 As the A&R of Love Records, DeForrest Taylor did not require Mr. Jones or any of the other creatives, musicians,
`or artists to sign an NDA.
`
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`Case 1:24-cv-01457 Document 1 Filed 02/26/24 Page 25 of 73
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`127. On another occasion, while standing in Mr. Combs' bedroom, Mr. Jones was forced to
`watch as Mr. Combs displayed his guns and bragged about getting away with shooting people.
`128. Mr. Combs shared that he was responsible for the shooting in the nightclub in New York
`City with rapper Shyne.
`
`
`129. He shared that artist, and Mr. Combs’ girlfriend at the time, Jennifer Lopez, aka, J-Lo
`carried the gun into the club for him and passed him the gun after he got into an altercation
`with another individual.
`
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`
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`130. The shooting in Chalice Recording Studios confirmed Mr. Combs' statements.
`131. These statements reinforced Mr. Jones’s fear of Mr. Combs and strengthened Mr. Combs
`dominion and control of Mr. Jones.
`132. Mr. Jones was terrified of Mr. Combs. He felt like he could not tell him no.
`133. Mr. Combs consistently made it clear that he has immense power in the music industry and
`with law enforcement.
`134. Mr. Combs made it clear that his head of security, Faheem Muhammad (“Mr. Muhammad”)
`had the power to make people and problems disappear.
`
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`
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`Faheem Muhammad
`135. Mr. Combs instructs his staff to always contact Mr. Muhammad if they are ever pulled over
`by the police in Miami or California.
`136. Upon information and belief, Mr. Muhammad spoke with the LAPD after G was shot at
`CRS. The LAPD was in CRS and witnessed the blood in the restroom, and they went with
`the bogus claim that the shooting of G occurred outside of the studio. This was all thanks to
`Mr. Muhammad’s connections within law enforcement.
`137. Mr. Jones had no reason to disbelieve Mr. Combs as he had seen firsthand through the
`shooting of G and the subsequent silence of the LAPD and the media that Mr. Combs indeed
`had the power to harm him.
`138. The LAPD spent HOURS in CRS after the shooting of G, yet there were no arrests. Mr.
`Jones witnessed the LAPD in the restroom pictured above, yet no arrests were made.
`139. The morning after the shooting, Mr. Jones and several others arrived at CRS and G’s blood
`was still on the floor of the restroom, and Mr. Combs hired a cleaning crew to clean it up.
`
`
`
`DEFENDANTS ETHIOPIA HABTEMARIAM, LUCIAN CHARLES GRAINGE,
`MOTOWN RECORDS, LOVE RECORDS, AND UNIVERSAL MUSIC GROUP
`AIDED, ABETTED, AND PROFITED OFF OF
`SEAN COMBS RICO ENTERPRISE
`140. Mr. Jones recalls seeing Defendant Grainge15 visiting Mr. Combs home in Miami, Florida,
`and Los Angeles, California.
`
`15 TikTok is one of the most important short video platforms in the world. It has a significant impact on the spread of
`global music. Today it is believed that artists are paying more and more attention to producing music suitable for
`dissemination on TikTok. Due to failed contractual renewal negotiations between Universal and TikTok, a lot of music
`
`
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`141. According to Mr. Jones, whenever Defendant Grainge visited Mr. Combs at his homes, it
`would be in the evening, and he and Mr. Combs would disappear for hours in Mr. Combs
`bedroom.
`142. Defendant Grainge sponsored and attended several Love Album listening parties at Mr.
`Combs’ home in Los Angeles, California. These parties were sponsored by Defendants MR,
`LR, and UMG. As evidence above, these parties had sex workers and underage girls present.
`143. During these parties, Defendant Grainge knew or should have known that Mr. Combs was
`drugging the attendees through laced bottles of DeLeon Tequila, and Ciroc Vodka.
`
`
`144. It is no secret that Mr. Combs had specific bottles of alcohol designated for females, and
`other bott