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1:00
What's up, everyone?
1:01
And welcome back to the program.
1:04
In this episode, we're going to finish off
1:06
the second amended complaint filed by Rodney Jones,
1:11
16th Cause of Action,
1:13
obstruction of the enforcement of the trafficking,
1:17
Victim Protection Act,
1:18
U.S. Code 18, Section 1591-D,
1:21
against defendant Lucian Charles Grange
1:24
and his capacity as CEO of UMG Motown Records
1:27
and Universal Music Group, 377.
1:31
Mr. Jones and corporates by reference all proceeding paragraphs
1:34
and re-electism as if set forth fully herein, 378.
1:38
Defendant Lucian Charles Grange and his capacity
1:41
as CEO of UMG Motown Records and Universal Music Group
1:45
and its officers and employees,
1:47
knowingly and intentionally obstructed,
1:49
attempted to obstruct, interfered with,
1:52
and prevented the enforcement of U.S. Code 18,
1:55
Section 1591-A-N1, and A-N2.
1:59
All in violation of U.S. Code 18, Section 1591-D.
2:03
This activity is here and after referred to collectively,
2:07
simply as obstruction, 379.
2:11
Upon information and belief, defendant Lucian Charles Grange
2:14
and his capacity as CEO of UMG Motown Records
2:18
and Universal Music Group's obstruction
2:20
of the enforcement of U.S. Code 18,
2:24
Section 1591-A-N1, and A-N2,
2:27
was forbidden by U.S. Code 18, Section 1591-D,
2:31
and defendant Lucian Charles Grange and his capacity
2:34
as CEO of UMG Motown Records and Universal Music Group,
2:38
thereby violated chapter 77, title 18.
2:42
Defendant Lucian Charles Grange and his capacity
2:44
as CEO of UMG Motown Records and Universal Music Group's
2:49
obstruction described here and in the preceding paragraph,
2:52
directly, approximately, and foreseeably harmed Mr. Jones
2:57
by directly resulting in him,
2:59
coercively being caused to engage in commercial sex acts
3:02
and in other ways, 380.
3:05
Upon information and belief, defendant Sean Combs
3:07
has a well-documented history of criminal investigations,
3:11
defendant Lucian Charles Grange and his capacity
3:14
as CEO of UMG Motown Records and Universal Music Group
3:18
were on notice of Mr. Combs' proclivity to criminal activity.
3:22
They knew or should have known
3:24
that Mr. Combs' trafficking operation
3:26
would or could result in criminal investigation
3:29
by state and federal prosecutors
3:32
for violating, among other laws, the TVPA.
3:35
Defendant Lucian Charles Grange and his capacity
3:38
as CEO of UMG Motown Records and Universal Music Group
3:42
should have taken a cue from the federal prosecutors,
3:45
arrest and prosecution of Jeffrey Epstein,
3:48
honor about July 8, 2019, honor about that date,
3:53
the U.S. Attorney's Office for the Southern District of New York
3:56
and Dited Epstein and unnamed associates
3:59
for violating the TVPA.
4:01
Later on, about June 29, 2020,
4:04
the same office and Dited Epstein's co-conspirator,
4:07
Golan Maxwell, poor conspiracy to entice minor victims
4:11
to travel to be abused by Epstein.
4:13
Mr. Combs' defendant, J. Combs,
4:16
Coram and her direct reports,
4:18
Brendan Paul, Frankie Santella and Moibon,
4:21
all engaged in the same activities as Mr. Epstein
4:25
In fact, Mr. Combs' defendant, J. Combs, Coram
4:29
and her direct reports, Brendan Paul, Frankie Santella
4:32
and Moibon may have done worse.
4:34
Take it easy with that nonsense, okay?
4:36
May have done worse?
4:37
I highly doubt that.
4:39
381, upon information and belief
4:42
by providing finances for Mr. Combs,
4:45
sex trafficking organization
4:46
and concealing its actions thereafter,
4:48
defendant Lucien Charles Grange and his capacity as CEO
4:52
of UMG Motown Records and Universal Music Group
4:55
obstructed, interfered with and prevented the state
4:58
and federal government enforcement of the TVPA
5:03
Defendants, J. Combs, Coram and her direct reports,
5:06
Brendan Paul, Frankie Santella and Moibon
5:09
to the extent that the federal government was able
5:12
to ultimately charge Mr. Combs' defendant, J. Combs, Coram
5:16
and her direct reports.
5:17
Brendan Paul, Frankie Santella and Moibon
5:20
with TVPA violations.
5:23
The filing of those charges was delayed
5:25
by defendant Lucien Charles Grange
5:27
and his capacity as CEO of UMG Motown Records
5:31
and Universal Music Group's actions
5:33
because of that delay, Mr. Jones
5:35
was coercively caused to engage in commercial sex acts.
5:40
382, as one example of how defendant Lucien Charles Grange
5:44
and his capacity as CEO of UMG Motown Records
5:48
and Universal Music Group obstructed, attempted
5:51
to obstruct, interfered with and prevented state
5:54
and federal government enforcement of the TVPA,
5:57
defendant, defendant Lucien Charles Grange
6:00
and his capacity as CEO of UMG Motown Records
6:04
and Universal Music Group provided financial resources
6:09
And so that the coercive commercial sex acts
6:11
would escape the detection of state
6:14
and federal law enforcement and prosecuting agencies,
6:17
defendant Lucien Charles Grange and his capacity
6:21
as CEO of UMG Motown Records and Universal Music Group
6:25
provided financial resources to further the Mr. Combs,
6:28
defendant J. Combs, Coram and her direct reports,
6:31
Brandon Paul, Frankie Santella and Moybaughan Sex Trafficking Venture
6:35
and with the purpose of helping Mr. Combs defendants,
6:38
J. Combs, Coram and her direct reports,
6:41
Brandon Paul, Frankie Santella and Moybaughan
6:44
evade criminal liability for violating the TVPA, 383.
6:48
As an example of how defendant Lucien Charles Grange
6:51
and his capacity as CEO of UMG Motown Records
6:55
and Universal Music Group obstructed,
6:57
attempted to obstruct, interfered with
6:59
and prevented state and federal government's enforcement
7:02
of the TVPA, defendant Lucien Charles Grange
7:05
and his capacity as CEO of UMG Motown Records
7:09
and Universal Music Group fell to ensure
7:11
that there are general business partners,
7:13
Sean Combs and love records, timely and accurately reported
7:17
to the federal government, the required tax forms
7:20
that detail the partnership payments provided
7:22
by defendant Lucien Charles Grange
7:25
and his capacity as CEO of UMG Motown Records
7:30
and Universal Music Group to Mr. Combs,
7:33
timely filing of these reports is required
7:36
by the United States tax code
7:37
and related laws and regulations.
7:40
These reports are tools that the federal government uses
7:43
to detect and prosecute among other illegal activities,
7:46
sex trafficking and violation of the TVPA
7:50
by failing to ensure that there are general business partner,
7:53
timely and accurately filed the tax reporting,
7:56
documents regarding Mr. Combs' partnership,
7:58
financial transactions, defendant Lucien Charles Grange
8:02
and his capacity as CEO of UMG Motown Records
8:06
and Universal Music Group obstructed,
8:08
attempted to obstruct, interfered with
8:10
and prevented the government enforcement of the TVPA
8:14
by concealing from the government's attention
8:16
Mr. Combs financing and aid of sex trafficking, 384
8:21
by providing unchecked financial support to Mr. Combs,
8:24
defendant Lucien Charles Grange
8:26
and his capacity as CEO of UMG Motown Records
8:30
and Universal Music Group intended and knew
8:32
that Mr. Combs coercive commercial sex acts
8:35
would escape the detection of law enforcement
8:38
and prosecuting agencies for some period of time.
8:42
Defendant Lucien Charles Grange
8:44
and his capacity as CEO of UMG Motown Records
8:48
and Universal Music Group provided financial
8:51
support to further the Combs' sex trafficking venture
8:54
and with the purpose of helping Mr. Combs evade
8:57
criminal liability for violating the TVPA.
9:00
385 upon information and belief defendant Lucien Charles Grange
9:05
and his capacity as CEO of UMG Motown Records
9:08
and Universal Music Group's obstruction,
9:10
attempted obstruction, interference with
9:13
and prevention of the enforcement of the TVPA
9:16
were all done intentionally and knowingly.
9:19
For example, defendant Lucien Charles Grange
9:21
and his capacity as CEO of UMG Motown Records
9:25
and Universal Music Group knew that Mr. Combs
9:27
was high risk, specifically high risk
9:30
to violate the TVPA through continuing
9:33
criminal sex trafficking activities.
9:35
As evidenced by Cassie Vinchera's civil complaint,
9:38
she informed members of Mr. Combs' parent label
9:41
about the abuses he was visiting upon her
9:44
and instead of coming to arrest you,
9:46
they forced her to return his calls
9:48
and to return to his sex trafficking enterprise 386 upon
9:53
information and belief defendant Lucien Charles Grange
9:57
and his capacity as CEO of UMG Motown Records
10:00
and Universal Music Group was aware Mr. Combs
10:03
at a laundry list of criminal charges
10:05
and barely escaped serving prison time upon information
10:09
and belief Mr. Combs engaged in witness intimidation
10:13
and bribery to escape criminal liability
10:15
for shooting the Tanya Rubin in the face.
10:18
Defendant Lucien Charles Grange and his capacity
10:21
as CEO of UMG Motown Records
10:24
and Universal Music Group was aware
10:26
that there were public allegations at Mr. Combs
10:29
illegal conduct was facilitated
10:31
by several named co-conspirators.
10:34
They were made aware of this through complaints made
10:37
by Cassie Vinchera and the lawsuit
10:39
by former diddy sex worker Jonathan Odie.
10:42
Defendant Lucien Charles Grange and his capacity
10:45
as CEO of UMG Motown Records
10:48
and Universal Music Group can seal
10:50
from the federal government its numerous financial payments
10:53
to Mr. Combs and love records incorporated
10:56
defendant Lucien Charles Grange
10:57
and his capacity as CEO of UMG Motown Records
11:01
and Universal Music Group continued its affirmative conduct
11:04
of providing financing to Mr. Combs
11:07
so that he could make payments to his co-conspirators
11:10
with knowledge that such transactions
11:13
did not produce a clear paper trail.
11:15
Defendant Lucien Charles Grange
11:17
and his capacity as CEO of UMG Motown Records
11:20
and Universal Music Group
11:22
intentional conduct obstructed attempted to obstruct
11:25
in many ways interfered with
11:27
and prevented the enforcement of the TVPA
11:30
by investigators and prosecuting agencies
11:33
to enforce the TVPA 388.
11:37
Upon information and belief,
11:38
defendant Lucien Charles Grange
11:40
and his capacity as CEO of UMG Motown Records
11:43
and Universal Music Group's obstruction
11:46
of the government's TVPA
11:48
and other law enforcement efforts
11:50
was intentional and willful
11:51
and therefore defendant Lucien Charles Grange
11:54
and his capacity as CEO of UMG Motown Records
11:58
and Universal Music Group's intentionally
12:00
and willfully caused Mr. Combs Commission
12:03
of the forcible commercial sex acts
12:05
with Mr. Jones through its obstruction
12:08
supporting the concealment
12:09
of Mr. Combs' trafficking venture.
12:12
Defendant Lucien Charles Grange
12:14
and his capacity as CEO of UMG Motown Records
12:17
and Universal Music Group knew
12:19
that Mr. Combs and his other co-conspirators
12:22
would use means of force, threats of force, fraud, coercion
12:26
and the combination of such means
12:28
to cause Mr. Jones to engage in commercial sex acts.
12:33
Upon information and belief, defendant Lucien Charles Grange
12:36
and his capacity as CEO of UMG Motown Records
12:40
and Universal Music Group knew
12:42
that Mr. Combs acted in reckless disregard
12:43
of the fact and should have known
12:45
that its obstruction and violation of US code 18,
12:48
section 1591D would directly and approximately lead
12:52
to unlawful, coercive, commercial sex acts
12:55
by Mr. Combs with men like plaintiff Jones, young men
13:02
Upon information and belief, defendant Lucien Charles Grange
13:06
and his capacity as CEO of UMG Motown Records
13:10
and Universal Music Group, obstruction is caused
13:13
Mr. Jones serious harm, including without limitation,
13:16
physical, psychological, financial and reputational harm.
13:20
That harm was direct and approximately caused
13:23
by the obstruction and the harm resulting
13:26
from the obstruction was foreseeable.
13:29
Upon information and belief, defendant Lucien Charles Grange
13:33
and his capacity as CEO of UMG Motown Records
13:37
and Universal Music Group's obstruction
13:39
has caused Mr. Jones harm that is sufficiently serious
13:43
under all the surrounding circumstances
13:45
to compel a reasonable person of the same background
13:48
and in the same circumstances to perform
13:50
or to continue performing commercial sex acts
13:53
to avoid incurring that harm.
13:56
Upon information and belief, this case does not involve
13:59
Mayor Fraud instead, defendant Lucien Charles Grange
14:02
and his capacity as CEO of UMG Motown Records
14:06
and Universal Music Group's criminal conduct
14:09
and obstructing enforcement of the TVPA
14:12
with so outrageous and intentional
14:14
because it was in deliberate furtherance of a widespread
14:17
and dangerous criminal sex trafficking organization.
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Defendant Lucian Charles Grange in his capacity
16:24
as CEO of UMG Motown Records
16:27
and Universal Music Group's obstruction
16:29
also invents the high degree of moral turpitude
16:32
and demonstrated such wanton dishonesty
16:34
as to imply a criminal indifference to civil obligations.
16:38
Defendant Lucian Charles Grange in his capacity
16:41
as CEO of UMG Motown Records
16:44
and Universal Music Group's obstruction
16:46
was directed specifically at Mr. Jones,
16:49
who was the victim of Mr. Combs,
16:51
sex trafficking organization, 393.
16:54
By virtue of these violations of US code 18,
16:57
Section 1591D, Defendant Lucian Charles Grange
17:01
in his capacity as CEO of UMG Motown Records
17:05
and Universal Music Group is liable to Mr. Jones
17:08
for the damages he sustained and reasonable attorney fees
17:11
by operation of US code 18, Section 1595.
17:15
Defendant Lucian Charles Grange
17:17
in his capacity as CEO of UMG Motown Records
17:21
and Universal Music Group perpetrated an obstruction
17:24
of the TVPA and therefore perpetrated a violation
17:28
of Chapter 77, Title 18.
17:31
The 17th cause of action, breach of oral contract
17:35
against love records in Sean Combs, 394.
17:38
Mr. Jones and corporates by reference
17:40
all preceding paragraphs and re-elegism
17:42
as if set forth fully herein, 395.
17:46
Plaintiff Jones and Defendant Mr. Jones and L.R.
17:49
had an oral contract for Mr. Jones
17:52
to receive $20,000 for every song
17:55
he produced on the love album.
17:57
Mr. Combs agreed to allow Mr. Jones
18:00
to keep his publishing as well as four royalty points
18:03
per song and to credit him as a producer
18:06
for every song that he touched
18:07
as well as credit him for each instrument he played.
18:12
Mr. Jones fully executed his obligations under the contract
18:16
when he produced, deliver me, stay part one,
18:19
reach in, what's love, stay a while,
18:22
moments need somebody, homecoming and tough love, 397.
18:26
Mr. Jones worked on the following songs,
18:29
brought my love and creepin' remix, 398.
18:32
Mr. Jones lived and traveled with Mr. Combs
18:35
from September, 2022 to October, 2023.
18:39
Through the duration of that time,
18:40
Mr. Combs did not compensate Mr. Jones
18:43
for his time or the work he did on the above mentioned songs.
18:47
Mr. Combs also failed to provide Mr. Jones
18:50
with producer credit or for royalty points for all songs.
18:56
As a result of Mr. Combs' actions,
18:57
Mr. Jones has suffered the following losses, $180,000,
19:02
royalty points, and producer credit for the following songs,
19:06
deliver me, stay part one, reach in, what's love,
19:09
stay a while, moments, need somebody, homecoming,
19:14
As a result of Mr. Combs' actions,
19:16
Mr. Jones has suffered the following losses,
19:19
$40,000 for royalty points,
19:22
and producer credit for the following songs.
19:25
Brought my love and creepin' remix, 401.
19:29
As a result of Mr. Combs' breach of contract,
19:31
Mr. Jones has suffered and continues to suffer harm,
19:34
including severe emotional distress, anxiety,
19:37
and other consequential damages
19:39
for which he is entitled to an award
19:41
of monetary damages and other relief, 402.
19:45
The conduct of Mr. Combs described above
19:48
was willful, wanton, and malicious.
19:50
At all relevant times, Mr. Combs acted
19:53
with conscious disregard for plaintiffs' rights
19:56
and feelings to cause injury to plaintiff Jones.
19:59
By virtue of the foregoing,
20:01
plaintiff is entitled to recover punitive damages.
20:05
The prayer for relief.
20:06
Wherefore, plaintiff prays the court enter judgment
20:09
in her favor and against defendants
20:11
containing the following relief.
20:14
A, a declaratory judgment that the actions, conduct,
20:17
and practices of defendants can plaint of herein
20:20
violate the laws of the state of New York B,
20:22
an award of damages against defendant,
20:24
and an amount to be determined that trial,
20:27
plus pre-judgment interest to compensate plaintiff
20:29
for all monetary and or economic damages,
20:33
including but not limited to loss of past and future income,
20:36
wages, compensations, seniority,
20:38
and other benefits of employment.
20:41
C, an award of damages against defendant,
20:43
and an amount to be determined that trial,
20:46
plus pre-judgment interest to compensate plaintiff
20:49
for all non-monetary and or compensatory damages,
20:53
including but not limited to compensation
20:55
for her mental anguish, humiliation,
20:57
embarrassment, stress and anxiety, emotional pain,
21:01
and suffering, and emotional distress.
21:03
D, an award for punitive damages
21:06
in an amount to be determined that trial,
21:08
E, pre-judgment interest on all amounts due,
21:11
F, and award cause for plaintiff,
21:13
has incurred in this action,
21:15
including but not limited to expert witness fees,
21:18
as well as plaintiff's reasonable attorney fees,
21:21
and cost of the fullest extent permitted by law,
21:23
and G, such other and further relief
21:26
as the court may deem just improper.
21:29
Plaintiff hereby demands trial by jury
21:31
on all issues of fact and damage stated herein.
21:34
This was dated March 25th, 2024,
21:38
and it was signed by Tyrone Blackburn.
21:41
All right, so that is the second amended complaint
21:44
that was that issue in dispute.
21:46
Now we know that the lawyers for UMG,
21:49
they gummed up the whole situation
21:51
with all of their filings,
21:53
and it was their opinion that this second amended complaint
21:56
shouldn't even be accepted by the court,
21:58
but the court has accepted it,
22:00
so this second amended complaint
22:02
is now part of the court filings.
22:05
So as the documents continue to come in,
22:07
we'll continue to hammer them out,
22:09
that way we all have an idea of what's going on,
22:11
because we all know the legacy media
22:13
is only going to give you a very surface level look.
22:17
The good news is we're diving deeper than a sub-mariner here,
22:20
and we plan on continuing to do that.
22:23
But until then, all of the information
22:25
that goes with this episode can be found in the description box.
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