Case 1:24-cv-01457-JPO Document 16 Filed 03/25/24 Page 1 of 98
`Case 1:24-cv-01457-JPO Document 16 Filed 03/25/24 Page 1 of 98
`
`OUNITED STATES FEDERAL COURT
`SOUTHERN DISTRICT OF NEW YORK
`
`Case Number: 24-1457
`
`Second Amended Complaint
`Civil Action
`
`Jury Demand
`
`RODNEY JONES,
`
`Plaintiff,
`
`Vv.
`
`SEAN COMBS,
`JUSTIN DIOR COMBS
`CUBA GOODINGJR.,
`LUCIAN CHARLES GRAINGE,
`KRISTINA KHORRAM,
`LOVE RECORDS,
`MOTOWN RECORDS,
`UNIVERSAL MUSIC GROUP,
`COMBS GLOBAL ENTERPRISES,
`JOHN and JANE DOES1-10 and
`ABC CORPORATIONS. 1-10
`
`Defendants.
`
`
`
`TRAFFICKING, AND THE ILLEGAL DISTRIBUTION OF GUNS, AND DRUGS
`
`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 IMAGESOF SEXUAL INTERCOURSE, REDACTED IMAGES OF
`MINORS, SEX WORKERS, AND PROSTITUTES, DETAILS OF SEX
`
`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 Cuba Gooding Jr. (“Mr. Gooding
`
`Jr.”), Defendant Kristina Khorram (“Ms. Khorram”), 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:
`
`

`

`Case 1:24-cv-01457-JPO Document 16 Filed 03/25/24 Page 2 of 98
`
`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 the defendants visited upon
`Plaintiff Jones in New York, California, Florida, Saint Barthelemy, and the United States
`Virgin Islands. This tortious conduct violated United States Federal Rico Laws and the United
`States Victims (“USVI”) of the Trafficking and Violence Protection Act of 2000 (“TVPA”).
`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. Specifically, the trafficking of Plaintiff across State
`lines between California, Florida, New York, and the USVI, and the trafficking of Plaintiff
`internationally to Saint-Barthélemy.
`
`PARTIES
`5. Plaintiff Rodney Jones is an American artist and music producer. Mr. Jones is domiciled in
`the state of New York.
`
`
`
`2
`
`

`

`Case 1:24-cv-01457-JPO Document 16 Filed 03/25/24 Page 3 of 98
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`
`
`Defendant Sean Combs
`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 became famous 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 is domiciled at 200 South Mapleton Dr., Beverly Hills, California 90024.
`
`
`
`Defendant Justin Dior 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 is
`domiciled at 1550 N El Centro Ave, Los Angeles, CA 90028.
`
`
`
`3
`
`

`

`Case 1:24-cv-01457-JPO Document 16 Filed 03/25/24 Page 4 of 98
`
`
`Lucian Charles Grainge
`8. Defendant Lucian Charles Grainge is the CEO of Defendant Universal Music Group. Upon
`information and belief, Defendant Lucian Charles Grainge is domiciled at 53551 Ross Ave
`Unit 34A, La Quinta, CA 92253, and 668 Chautauqua Blvd, Pacific Palisades, CA 90272.
`Defendant Lucian Charles Grainge, in his capacity as CEO of UMG, authorized Motown
`Records and Universal Music Group to enter into a general business partnership agreement
`and to provide financial resources to their general business partners, Defendants Sean Combs
`and Love Records, Inc.
`
`
`
`Cuba Gooding, Jr.
`9. Defendant Cuba Gooding, Jr. was a relevant actor who has fallen from grace due to several
`sexual assault lawsuits and a recent guilty plea for sexual assault. Upon information and
`belief, Defendant Gooding, Jr. is domiciled at 60 Collister Street, Apt. #2B, New York, NY
`10013.
`
`
`
`
`
`4
`
`

`

`Case 1:24-cv-01457-JPO Document 16 Filed 03/25/24 Page 5 of 98
`
`
`Kristina Khorram, Chief of Staff to Sean "Diddy" Combs
`10. Defendant Kristina Khorram is the Chief of Staff to Sean “Diddy” Combs, Combs Global
`Enterprises. Upon information and belief, she is domiciled at 10445 Wilshire Blvd Apt 501,
`Los Angeles, CA 90024. Defendant Khorram manages the day-to-day operation of the
`Combs RICO and TVPA Enterprises.
`
`
`
`
`11. Defendant Motown Records is a record label with a principal place of business located at 1750
`Vine St, Los Angeles, CA. According to a Declaration by former Motown Chairwoman and
`CEO Ethiopia Habtemariam, Motown Records, with the consent of Defendant UMG, and
`presumably, Ms. Habtemariams direct supervisor, Defendant Lucian Grainge, entered a
`general partnership, as that term is defined by the laws of the State of New York, with
`Defendants Love Records, Inc. and Sean Combs.
`
`
`
`
`
`5
`
`

`

`Case 1:24-cv-01457-JPO Document 16 Filed 03/25/24 Page 6 of 98
`
`
`12. 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 of Universal Music Group. Defendant Lucian Charles Grainge, as CEO of UMG,
`authorized Universal Music Group to enter a general business partnership with Love Records,
`Inc. and Sean Combs. Additionally, according to former Motown Records Chairwoman, Ms.
`Habtemariam, they provided funding and/or reimbursements for expenses associated with the
`recording cost of the Love Album. The Love Album was released on September 23, 2023.
`
`
`13. 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 Combs
`founded Defendant Love Records. According to their website, Defendant Motown Records
`helped Sean Combs establish Love Records and had a distribution deal for the Love Album.
`
`
`
`
`
`Combs Global
`
`
`
`6
`
`

`

`Case 1:24-cv-01457-JPO Document 16 Filed 03/25/24 Page 7 of 98
`Case 1:24-cv-01457-JPO Document 16 Filed 03/25/24 Page 7 of 98
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`14. Defendant Combs Enterprisesis a diverse portfolio of businesses and investments, including
`
`music, fashion, fragrance, beverage, marketing, film, television, and media properties. They
`
`havea principal place of business located in New York, New York.
`
`RODNEY LIL ROD JONES
`
`15. Rodney “Lil Rod” JonesJr. is from the Windy City [Chi-town]. He was born andraised in
`
`Chicago,Illinois. Mr. Jonesis the second oldest son and fourth child out ofnine siblings. Mr.
`
`Jones comes from a long line of Gospel Music influencers.
`
`16. Mr. Jones started playing instruments at the age of five. He began playing drums in church,
`
`and at thirteen, he picked up playing the guitar. From thirteen to the present day, Mr. Jones
`
`has taught himself to play over thirteen instruments.
`
`Mr. Jones, the Child Prodigy
`
`17. 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 acclaimedartists in music history.
`
`18. Throughout his career, Mr. Jones has worked the south side of the Chicago Music scene,
`
`playing with the following legendary acts: Georgia Mass Choir, Donald Lawrence, The Clark
`
`Sisters, and The Smokie Norful.
`
`19. On or about August 2022, Mr. Jones received a call from Mr. Combs's representative
`
`requesting that he produced several songs on a rhythm and blues album titled "The Love
`
`Album: Off the Grid," ("Love Album").
`
`

`

`Case 1:24-cv-01457-JPO Document 16 Filed 03/25/24 Page 8 of 98
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`20. Mr. Jones agreed, and his life has been detrimentally impacted ever since.
`21. During the relevant period, Defendants John and Jane Does 1-10 are currently unknown
`individuals and/or employees who aided and/or abetted in the commission of conduct
`complained of herein and/or who either acted within the scope of their employment,
`Defendants ratified, embraced, and added to this conduct. As parties engage in discovery,
`Plaintiff retains the right to amend the Complaint to add these individual employees by name.
`22. During the relevant period, Defendants ABC Corps. 1-10 are currently unknown entities who
`employed Plaintiff or aided and/or abetted in the commission of conduct complained of
`herein. As the parties engage in discovery, Plaintiff retains the right to amend the Complaint
`to add these entities or individuals by name.
`
`
`SUMMARY OF EVENTS
`23. From September 2022 to September 2023, Mr. Jones produced nine songs on Mr. Combs'
`Love album.
`24. From September 2022 to September 2023, Mr. Jones lived with Mr. Combs for months,
`spending holidays, birthdays and missing major family events.
`25. Mr. Jones resided at Mr. Combs's residences in Los Angeles, California, and Miami, Florida.
`He also spent several weeks on a yacht rented by Mr. Combs in the US Virgin Islands and
`Saint-Barthélemy. As detailed below, Mr. Jones made several trips with Mr. Combs to New
`York City throughout his time living with him.
`26. 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.
`27. The claims raised in this complaint have been corroborated through witness statements,
`video/audio recordings, personal experiences, and images Mr. Jones possesses.
`28. Mr. Combs required Mr. Jones to record him constantly. On several occasions, Mr. Combs
`took Mr. Jones's cell phone 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.
`29. Mr. Jones has personally witnessed and secured irrefutable evidence of:
`a. The acquisition, use, and distribution of ecstasy, cocaine, GHB, ketamine, marijuana,
`and mushrooms,
`
`
`
`8
`
`

`

`Case 1:24-cv-01457-JPO Document 16 Filed 03/25/24 Page 9 of 98
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`b. The displaying and distribution of unregistered illegal firearms,
`c. Mr. Combs providing laced alcoholic beverages to minors (LA home July 2023) and
`sex workers at his homes in California, the U. S. Virgin Islands1, Florida, and Saint-
`Barthélemy,
`d. Mr. Combs Chief of Staff, Kristina Khorram (“KK”) instructs her staff to retrieve
`drugs so she can provide them 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.
`
`
`CHALICE RECORDING STUDIOS SHOOTING
`30. 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.
`31. Mr. Combs, his son Justin Combs, and Justin's friend G were present at this camp.
`32. Based on information and belief, Mr. G is a 30-year-old tall African American male.
`33. Based on information and belief, in addition to these individuals, other musicians were present
`at the camp. This writer has spoken to several musicians who attended the camp.
`34. One evening during this camp, Mr. Combs, J. Combs, and G were in a heated conversation.
`35. That conversation was moved out of the studio and into a restroom adjacent to where Mr.
`Jones was sitting.
`
`
`1 This writer spoke with several employees of the yacht rented by Mr. Combs in the U.S. Virgin Islands and Saint-
`Barthélemy who personally witnessed Defendant Khorram instruct her staff, Brendan Paul, Frankie Santella, and Moy
`Baun spike bottles of champagne with ecstasy. Upon information and belief, this occurred the day of the December
`31, 2022 New Year’s Eve party.
`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.
`
`
`
`9
`
`

`

`Case 1:24-cv-01457-JPO Document 16 Filed 03/25/24 Page 10 of 98
`
`36. Mr. Jones was approximately 2 feet away from the bathroom when gunshots rang out. Mr.
`Jones recalls hearing multiple gunshots.
`37. 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.
`38. After the shooting ended, a crowd gathered around the restroom.
`39. Upon information and belief, when the door finally opened, Mr. Combs and J. Combs exited.
`40. G was lying on the restroom floor in a fetal position, holding his stomach and bleeding out of
`his torso and leg/hip area.
`41. 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
`torso.
`42. As he was applying pressure to his torso, Mr. Jones realized that G was gushing blood from
`another area near his leg/hip.
`43. He decided to lift G and placed him to sit on the toilet. Mr. Jones asked the crowd to call the
`ambulance.
`44. Mr. Jones lifted G and brought him to the ambulance at the front of the studio. At this time,
`Mr. Combs and Justin disappeared to another part of the studio.
`45. 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.
`
`
`
`10
`
`

`

`Case 1:24-cv-01457-JPO Document 16 Filed 03/25/24 Page 11 of 98
`Case 1:24-cv-0145/7-JPO Document16 Filed 03/25/24 Page 11 of 98
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`Case 1:24-cv-01457-JPO Document 16 Filed 03/25/24 Page 12 of 98
`
`46. Mr. Jones has several corroborating witnesses who spoke with this writer anonymously
`because they feared retaliation from Mr. Combs. They have agreed to speak publicly when
`subpoenaed.
`47. Mr. Jones has the clothing he wore that day and believes it may still have G's blood stains and
`DNA.
`48. The following are screenshots of the aftermath of the restroom where G was shot by either
`Mr. Combs or J. Combs:
`
`
`
`Aftermath of the Shooting of G
`49. Upon information and belief, it is clear that G was NOT shot outside of the studio, as Mr.
`Combs instructed his team to report to law enforcement.
`50. Upon information and belief, Mr. Combs and Defendant’s LR, MR, UMG, and CRS provided
`private security for the writers’ camp at Chalice.
`51. The Security was porous and lackluster at best.
`
`
`
`12
`
`

`

`Case 1:24-cv-01457-JPO Document 16 Filed 03/25/24 Page 13 of 98
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`52. 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.
`53. As a result of this shooting, Mr. Jones is severely traumatized. Mr. Jones now suffers from
`PTSD, severe anxiety, depression, and insomnia.
`54. The following is an image of Mr. Combs a couple of hours before G is shot in the restroom of
`Chalice:
`
`
`This photo of Mr. Combs was taken at Chalice Recording Studios outside of Studio G
`hours before G was shot.
`
`CHALICE RECORDING STUDIOS, AND DEFENDANTS SEAN COMBS AND JUSTIN
`COMBS REPRESENTATIVE SHAWN HOLLEY
`PROVIDE CONFLICTING AND INTELLECTUALLY DISHONEST ACCOUNTS
`CONCERNING THE SHOOTING
`55. On or about, February 28, 2024, Chalice sent an Instagram message which alleges that G was
`shot a “half a block away from Chalice.”
`
`
`
`13
`
`

`

`Case 1:24-cv-01457-JPO Document 16 Filed 03/25/24 Page 14 of 98
`Case 1:24-cv-01457-JPO Document16 Filed 03/25/24 Page 14 of 98
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`2:19
`
`at 5G¢ 8
`
`<
`
`Busines
`‘hat
`chalicerecording
`
`
`
`chalicerecording
`Instagram
`2.1K followers - 34 posts
`Youdon't follow each other on Instagram
`You both follow ehudsonmusic and 5 others
`
`View profile
`
`You started a chat with chalice’ecording. Weuse information
`from this chat to improve y
`experience. Learn about
`business chats and your privacy.
`
`2:58PM
`
`The shooting occurred a half a
`block away from Chalice andit
`wasa result of ¢ robbery. There
`are police repor’s corroborating
`this. Please wait for the facts to
`comeout before you start
`contributing to the defamation
`e of our organization.
`
`Accept messace request from
`chalicerecording?
`If you accept,
`they will also be ableto call you and
`$ and when you've
`see info such as your acti
`
`
`Block
`
`Delete
`
`Accept
`
`Instagram Message From Chalice Recording Studios
`
`56. Upon information and belief, Shawn Holley’ claimed that she had “evidence” the shooting
`
`took place several blocks away and that G returned to the studio after being shot.
`
`57. Upon information and belief, TMZ°reports that their “law enforcement sources” claim that
`
`“the story that was told to cops that night -- namely, that the victim was robbed at gunpoint
`
`and shot by unknown assailants outside. The gunshotvictim [G] stepped outside of the studio
`
`around 3:30 AM and was accosted by twoindividuals... at which point they tried to rob him.
`
`... the man suffered a gunshot wound.”
`
`58. Below is an imageofthe front of Chalice Recording Studios:
`
`> Shawn Holley previously represented Tory Lanez and Danny Masterson.
`° https://www.tmz.com/2024/02/28/diddy-lawyer-women-come-forward-deny-underage-claim-lawsuit/
`
`14
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`

`

`Case 1:24-cv-01457-JPO Document 16 Filed 03/25/24 Page 15 of 98
`Case 1:24-cv-01457-JPO Document16 Filed 03/25/24 Page 15 of 98
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`
`
`59. In the photo above, the white van is blocking a security gate.
`
`Photo of Chalice Recording Studios
`
`60. Upon information andbelief, to enter the building, you must buzz the gate and announce
`
`whichsession youare there to attend.
`
`61. Upon information andbelief, once the correct session is confirmed, you then must go past
`
`another layer of security before you can enter the reception area.
`
`62. Upon information andbelief, once inside the reception area, you must identify yourself, and
`
`the receptionist will check to ensure that you are on thelist of visitors for that session. Once
`
`you are confirmed, you are then allowedin.
`
`63. Upon information and belief, to get to the restroom where G was bleeding out, you have to
`
`follow a maze. Once you’ve passed the receptionist, you walk down a long hallway, walk
`
`past three recording studios, turn left, and go past a lounge area before you arrive at the
`
`restroom where G wasbleedingout.
`
`64. Upon information and belief, TMZ also reported that Mr. Combs and J. Combs were not in
`
`the studio whenthe police arrived. Thatis also factually inaccurate.
`
`15
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`

`

`Case 1:24-cv-01457-JPO Document 16 Filed 03/25/24 Page 16 of 98
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`65. Mr. Combs and J. Combs were located in Studio G across the parking lot from the building
`where G was shot (near Studio A). Mr. Combs and J. Combs hid out in Recording Studio G
`while the police “investigated,” and were the first to depart after the officers left7.
`
`
`Mr. Combs Published the Love Records Chalice Recording Studios
`Assignment List. Mr. Combs Stayed in Studio G
`Throughout The Duration of the Writers Camp
`
`66. Upon information and belief, after being shot in the torso and hip/leg, G was physically
`incapable of walking; therefore, the notion that he was shot several blocks away (Shawn
`Holley), half a block away (CRS), or as he stepped outside of the studio is implausible.
`67. If G could do as much walking as Shawn Holley and CRS claim, then Mr. Jones would not
`have been required to physically pick him up off the restroom floor and walk him through the
`maze that is CRS for him to receive care from the ambulance.
`
`
`7 This FACT will be made crystal clear in discovery.
`
`
`
`16
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`Case 1:24-cv-01457-JPO Document 16 Filed 03/25/24 Page 17 of 98
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`68. As of the date of this filing, neither the Los Angeles Police Department nor the Los Angeles
`Fire Department has released any official reports surrounding this shooting. There has been
`no body camera footage or 911 call recording. What is even more disturbing is that there has
`been no citing of G.
`a. The LAPD has only released a vaguely written "News Release" dated September 12,
`2022.
`69. The unfortunate shooting of G, the unexplained disappearance of G, the lack of disclosures
`by the LAPD and LAFD, and the incoherent nature of Shawn Holley and Chalice Recording
`Studios' account of the shooting raises more questions than answers point to foul play, and an
`apparent massive coverup.
`
`THE DEAFENING SILENCE FROM THE ATTENDEES OF THE CRS SHOOTING
`STEMS FROM UNDERSTANDABLE FEAR THAT THE ATTENDEES WOULD BE
`SUED BY MR. COMBS FOR VIOLATING A
`NON-DISCLOSURE AGREEMENT
`70. Upon information and belief, a few days before the September 12, 2022, shooting inside of
`Chalice Recording Studio, Mr. Combs required all attendees of the CRS shooting to sign a
`Non-disclosure Agreement.
`71. Mr. Jones did not sign the agreement.
`72. A copy of the non-disclosure agreement8 that a witness who has asked to remain anonymous
`provided this writer is attached. (Attachment A).
`
`MR. JONES WAS SEXUALLY HARASSED, AND ASSAULTED BY MR. COMBS
`73. 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.
`74. These events occurred in LA, NY, FL, Saint-Barthélemy, and the United States Virgin Islands.
`75. 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.
`
`
`8 Unfortunately for the attendees of the writers’ camp, they are unaware that NDA’s are non-binding when it comes
`to reporting criminal activity such as a shooting, sex trafficking, and the distribution and use of illegal drugs and
`guns.
`
`
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`76. As a heterosexual Christian man, Mr. Jones was uncomfortable with Mr. Combs' advances
`and expressed his discomfort to Mr. Combs' Chief of Staff, Defendant Kristina Khorram.
`77. KK responded to Mr. Jones complaint with, "you know, Sean will be Sean.”
`78. KK also attempted to downplay Mr. Combs groping of Mr. Jones's anus and genitals as
`friendly horseplay, stating that those acts were Mr. Combs's way of "showing that he likes you
`[Mr. Jones].”
`79. 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.
`KK's hypocrisy is breathtaking at best or enabling at worst.
`80. Mr. Jones believes that KK aided and abetted Mr. Combs' sexual assault and was working
`with Mr. Combs to groom him into accepting a homosexual relationship.
`81. 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.
`
`
`MR. COMBS ATTEMPTED TO GROOM MR. JONES INTO ENGAGING IN GAY SEX
`82. Mr. Combs knew Mr. Jones looked up to and idolized music Producer Steven Aaron Jordan
`("Stevie J").
`83. Based on information and belief, Stevie J is an American DJ, record producer, and television
`personality.
`84. Based on information and belief, Stevie J was part of the Bad Boy Records production team,
`the Hitmen.
`85. Upon information and belief, in 1997, Stevie J won a Grammy Award for his work on Puff
`Daddy's debut album.
`86. Upon information and belief, 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.
`87. Based on information and belief, Stevie J was one of the producers of the Love Album.
`88. According to Mr. Jones, 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 homosexual acts.
`
`
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`89. Mr. Combs went so far as to share a video of who he claims was Stevie J9 anally penetrating
`a Caucasian male without a condom. Mr. Jones believes that Mr. Combs showed him this and
`attributed it to his idol Stevie J. to ease Mr. Jones’ anxiety concerning homosexuality.
`According to Mr. Jones, Mr. Combs said, “this is a normal practice in the music industry, look
`even Stevie J10 is doing it.”
`90. According to Mr. Jones, Mr. Combs informed Mr. Jones that he had engaged in sexual
`intercourse with rapper11 (REDACTED), R&B singer12 (REDACTED), and Stevie J.
`91. According to Mr. Jones, Mr. Combs promised to make sure that Mr. Jones wins producer of
`the year at the Grammys if he engaged in homosexual acts.
`
`
`THANKSGIVING 2022, MR. JONES IS SEXUALLY ASSAULTED BY
`YUNG MIAMI’S COUSIN
`92. On Thanksgiving Day, 2022, Mr. Jones was in Mr. Combs' house in Miami, Florida. Yung
`Miami and her female cousin (Jane Doe 1) were also present.
`93. According to Mr. Jones, Mr. Combs was intoxicated and offered cocaine to Mr. Jones. Mr.
`Jones rejected him and proceeded to walk to the restroom.
`94. 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.
`95. According to Mr. Jones, 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.
`96. According to Mr. Jones, Yung Miami's cousin did not accept Mr. Jones rejection, as she
`proceeded to follow Mr. Jones out of the bathroom.
`97. She started undressing and attempted to straddle him and have sex with him in the presence
`of Mr. Combs and his staff.
`98. Despite the lack of assistance from Mr. Combs and his staff, Mr. Jones pushed her off. The
`following are images from a video13 of Yung Miami, her cousin, Mr. Jones, and Mr. Combs:
`
`
`9 This writer is in possession of the video and will provide a copy to the court.
`10 Upon information and belief, Stevie J denies that he is the person in the video. A male porn star claimed that he
`was the black male in the video. Mr. Jones stands by his position that Mr. Combs provided him with the video and
`identified the individual in the video as Stevie J.
`11 He is a Philadelphia Rapper who dated Nicki Minaj.
`12 He performed at the Superbowl and had a successful Vegas residency.
`13 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-JPO Document 16 Filed 03/25/24 Page 20 of 98
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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.
`
`
`
`Yung Miami, and Jane Doe 1 who sexually assaulted Mr. Jones on
`Thanksgiving Day 2022
`
`TRAFFICKING AND VICTIMS’ PROTECTION ACT
`99. According to Mr. Jones, he was transported from California to New York, Florida, Saint-
`Barthélemy, and the United States Virgin Islands throughout his time with Mr. Combs.
`100. According to Mr. Jones, during this time, Mr. Jones was forced to solicit sex workers and
`perform sex acts to the pleasure of Mr. Combs.
`101. 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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`Case 1:24-cv-01457-JPO Document16 Filed 03/25/24 Page 21 of 98
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`
`
`The Sex Workers That Mr. Combs Forced Mr. Jones To Bring Back To His Home
`
`102. On or about February 2, 2023, 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. Healso recalls aimlessly wandering around the house with no clothes on.
`
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`Case 1:24-cv-01457-JPO Document 16 Filed 03/25/24 Page 22 of 98
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`
`Sex Workers In Mr. Jones Bed The Morning After Being Drugged
`103. According to Mr. Jones, on another occasion in Miami, Florida, on Thanksgiving night of
`2022, Mr. Combs asked Mr. Jones and DeForrest Taylor to enter the studio bathroom.
`104. According to Mr. Jones, he asked them for a hundred-dollar bill because he wanted them
`to do cocaine with him.
`105. 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.
`106. According to Mr. Jones, later that evening, Mr. Combs 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
`107.