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What's up everyone and welcome back to the program.
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In this episode we're getting right back to April Lampros' complaint made against Diddy.
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First cause of action, battery.
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Miss Lampros incorporates, by reference, all preceding paragraphs and re-elections them, as
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if said fourth fully, herein, 84.
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The defendant committed battery against Miss Lampros, when he penetrated Miss Lampros
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orally and vaginally against her will, as detailed in the four encounters above, 85.
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In addition, Mr. Combs physically assaulted Miss Lampros when he pulled her hair and
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forced her to perform oral sex on him in an open parking garage with a parking attendant
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Defendant Combs intentionally and without her consent.
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Attack Miss Lampros to satisfy his sexual desires.
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After all circumstances, the defendant's physical contact with Miss Lampros was offensive
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Defendant Combs continued to attack Miss Lampros despite her attempts to thwart his actions.
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The defendant's conduct was, the direct and proximate cause of Miss Lampros passed in
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future substantial damages, including significant pain in suffering, lasting psychological and
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financial harm, loss of dignity, and invasion of privacy.
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The defendant's actions constitute sexual offenses as defined in Article 130 of the New York
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Penal Law, including but not limited to sexual misconduct and forcible touching.
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The plaintiff's claim for battery is thus timely under the Gender Motivated Violence Act
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NYC Admin Code, Section 10-1101.
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The Second Cause of Action.
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Assault, Sexual Assault, 90.
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Miss Lampros incorporates, by reference, all preceding paragraphs and real edges them
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as if set forth fully herein.
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As described above, Defendant Combs frightened and plays plaintiff in apprehension of harm
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when he physically assaulted her within the city of New York.
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Defendant forcibly touched and attempted and or threatened to touch, plaintiff's intimate
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areas, and or touch her with his intimate body parts.
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As a result of Defendant Combs Conduct, plaintiff has suffered and continues to suffer harm,
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including physical injury, severe emotional distress, humiliation, anxiety, and other consequential
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damages for which he is entitled to an award of monetary damages and other relief.
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The Conduct of Defendant Combs described above was willful, wanton, and malicious.
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At all relevant times, Defendant acted with conscious disregard for plaintiff's rights
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and feelings, acted with the knowledge of or with reckless disregard for the fact that
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his conduct was certain to cause injury and or humiliation to plaintiff, and intention
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to cause fear, physical injury, and or pain and suffering to plaintiff.
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By virtue of the foregoing, plaintiff is entitled to recover punitive damages.
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The Cause of Action is timely under the Gender Motivated Violence Act and Y.C.
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Madman Code, Section 10-1101, Third Cause of Action, Negligine Infliction of Emotional
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Miss Lampros, Incorporates by Reference, All Proceeding Paragraphs and Realleges them, as
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if set forth fully herein.
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The Defendant's Conduct created an unreasonable risk of causing emotional distress to plaintiff,
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and the defendant's new or should have known that such conduct was likely to result in
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an emotional distress that might and or likely would cause illness or bodily harm, 98.
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The plaintiff's emotional distress was foreseeable to the defendant's, 99.
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As a direct and proximate result of the Negligine Conduct of the defendant's plaintiff suffered
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and will continue to suffer severe emotional distress, 100.
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Defendant's Conduct was Wanton, Militius, Willful, and or Cruel, entitling plaintiff to punitive
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This cause of action is timely under the Adult Survivors Act, NYCPLR, Section 214,
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J. McKinney, 2022, because it arises out of conduct perpetrated against plaintiff, who
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was the statutory age or older at the time of the conduct, which constitutes multiple sexual
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offenses, as defined in Article 130 of the New York Penal Law.
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The Fourth Cause of Action, Violation of the Victims of Gender Motivated Violence Protection
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Law, NYC, Admin Code, Section 10-1101, VGM, VPL, 102.
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Miss Lampros, Incorporates by Reference, All Proceeding Paragraphs, and Re-Elegism, as
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have said Fourth, Fully, Herein, 103.
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The above described conduct of defendant comms, including, but not limited to, comb sexual
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assault of plaintiff in New York City, constitutes a crime of violence against plaintiff, and
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is a crime of violence motivated by gender.
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As defined in Section 10-1101, the term of violence means an act, or series of acts that
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would constitute a misdemeanor, or felony against the person, as defined in state or federal
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law, or that would constitute misdemeanor, or felony against property, as defined in state
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If the conduct presents a serious risk of physical injury to another, whether or not those
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acts have actually resulted in criminal charges, prosecution, or conviction, the term crime
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of violence motivated by gender means a crime of violence committed because of gender,
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or on the basis of gender, and due, at least in part, to an animus based on the victim's
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Defendant SME, and their subsidiary A&R, enabled Mr. Combs to commit the crime of violence
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motivated by gender, and are therefore also liable under VGM VPL.
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As detailed above, Ms. Lamprost worked for Arista Records during Mr. Combs' assault.
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Bad Boy Records was a subsidiary of Arista Records at the time.
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Ms. Lamprost reported to her manager, Jeff, who was an agent of Arista Records.
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Defendants AR, and SME, enabled Mr. Combs' commission of the crimes of violence motivated
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by gender, and thus are liable under the NYC victims of Gender Motivated Protection
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Defendants A&R, and SME, enabled or participated in the sexual abuse of plaintiff because defendants
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fell to, among other things, protect plaintiff from a known danger, have sufficient policies
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and procedures in place to prevent sexual assault, properly implement policies and procedures
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to prevent sexual assault, take reasonable measures to ensure that policies to prevent sexual
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assault were working, train their employees on identifying sexual assault, and inappropriate
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workplace behaviors.
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Defendant Arista Records enabled or participated in the sexual abuse of plaintiff because defendants
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felt the timely and properly educate, train, supervise, and or monitor their agents or
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employees regarding policies and procedures that should be followed when sexual abuse
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is suspected or observed.
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Prior to Combs' actually assaulting plaintiff, Arista Records knew or should have known
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that Combs was not fit to be in a position of authority.
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Defendants buying through their agents, servants, and or employees became aware or should have
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became aware of Combs' propensity to commit sexual assault and to the risk to plaintiff
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At the very least, defendant knew or should have known that they did not have sufficient
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information about whether or not their leaders, managers, and people were safe to be in positions
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Defendant Arista Records knew or should have known that Combs posed a risk of sexual assault.
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Defendant Arista fell to properly supervise Combs and protect plaintiff from a known danger,
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thereby enabling Combs repeated sexual assaults of plaintiff.
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Defendant Arista Records negligently deemed Mr. Combs was fit to be in a position of authority
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and or that any previous suitability problems Mr. Combs had were fixed and cured and or
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that Mr. Combs would not commit acts of sexual assault and or that Mr. Combs would not
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Moreover, Defendant Arista Records enabled the sexual abuse of plaintiff by actively
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maintaining and employing Mr. Combs in a position of power and authority through which
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Mr. Combs had control over people, including plaintiff.
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As a direct and proximate result of the aforementioned crime of violence and gender-motivated violence,
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plaintiff has sustained and will continue to sustain monetary damages, physical injury,
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panic suffering, and serious psychological and emotional distress, entitling her to an
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award of Compensatory and Punitive Damages, Injunctive and Declaratory Relief, Attorney's
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Fees and Costs, and other remedies as this court may deem appropriate damages, as said
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4th in Section 10-1104.
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The above described conduct of Defendants constitutes a sexual offense, as defined an article 130
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of the New York Penal Law.
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Pursuant to Section 10-1105A.
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This cause of action is timely because it's commenced within two years and six months
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after September 1st, 2022.
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The Prayer for Relief.
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Wherefore, plaintiff prays that the court enter judgment, inner favor, against defendants,
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banning the following relief, A, for a money judgment, representing Compensatory Damages,
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including consequential damages, loss wages, earnings, and all other sums of money together
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with interest on these amounts according to proof, B, for a money judgment for mental
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pain and anguish and severe emotional distress according to proof, C, for a punitive and
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exemplary damages according to proof, D, for Attorney Fees and Costs, E, for the pre-judgment
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and post-judgment interest, and death, such other and further relief as the court may
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deem just improper.
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Plaintiff hereby demands a trial by Jerry on all issues of fact and damages stated herein.
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This was dated on May 23rd, 2024, and it was signed by Tyrone Blackburn.
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Alright, that's going to do it for the April Lamprose complaint.
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And I have a sneaking suspicion, folks, this is not the last one we're going to see.
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All of the information that goes with this episode can be found in the description box.