Rodney "LiL Rod" Jones And The Amended Diddy Complaint (Part 6)

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What's up everyone and welcome back to the program.

In this episode, we're going to get right back to

the second amended complaint filed against Ditty by Rodney Jones.

2-13.

The Rico Enterprise, which all defendants have engaged in

and the activities of which affected interstate and foreign commerce

is comprised of an association in fact of persons,

including each defendant and other unnamed co-conspirators.

That association was structured by various general partnership,

agreements, establishment deals, distribution deals, contracts,

and non-contractual relationships between the defendants

by which defendants assume different roles in either knowingly

or negligently funding directly or indirectly participating

in the acts necessary to carry out a scheme to acquire

and distribute drugs, firearms, prostitutes, and sex workers.

They also work collectively to deceptively obtain the labor

of producers, musicians, writers, creators, and artists

such as plaintiff to utilize their talents and labor

to produce music and other tangible goods and services

without full compensation.

As detailed herein, plaintiff Jones worked for Mr. Combs

for 13 months.

Combs Enterprise employee Frankie solicited him

to produce a love album.

Frankie and Mr. Combs agreed to provide Mr. Jones,

20 grand per song, four royalty points per song,

credit as producer, credit for each instrument Mr. Jones

played, and publishing rights for Mr. Jones' work

in exchange for Mr. Jones' services on the love album.

Over 13 months, Mr. Jones fulfilled his end of the agreement

and provided services for the love album.

Mr. Combs benefited from Mr. Jones' services

and refused to compensate him by their agreement.

Mr. Jones is not the only creative who

had his services stolen by Mr. Combs.

Many creatives worked for months on the love album

and were never compensated for their work.

To 14, according to the Habtomerium Declaration,

the collective reimbursed or paid for the production

of the love album.

Mr. Jones was not compensated, so if the Habtomerium Declaration

is correct, what was the collective financial support

used for?

And what mechanism did the collective have in place

to ensure the money provided to defend in Sean Combs?

Combs enterprises, love records, Justin Combs,

and Christina Corham were used for the purposes outlined

in the collective's partnership deal with defendant,

Sean Combs, Combs Enterprise, love records,

Justin Combs, and Christina Corham.

215, the collective and defendants, Sean Combs,

Combs enterprises, love records, Justin Combs,

and Christina Corham all share a common purpose

to use deception, coercion, force,

and the threat of violence to enrich themselves

at the expense of individuals like the plaintiff.

As set forth herein, although members of the collective

may not have directly threatened, coerced, forced,

or violently threatened plaintiff,

they financially benefited from defendant, Sean Combs,

Combs enterprises, love records, Justin Combs,

and Christina Corham's scheme of defrauding

and intimidating the plaintiff with threats of violence.

Threatening to eat plaintiffs' face,

displaying and distributing guns and plaintiffs' presence,

bragging about having law enforcement under control,

bragging about murdering people,

and bragging about bribing witnesses,

and jurors in the criminal case,

concerning the 1999 NYC nightclub shooting Wishine,

threats of isolation from the music and entertainment industry,

parading influential music industry executives

at Mr. Combs parties filled with sex workers, minors,

and illegal drugs such as ecstasy, cocaine,

GHB, ketamine, marijuana, and mushrooms,

threats of non-payment for work completed,

fake promises, a cash payments, 250 Gs,

producer of the year Grammy Awards,

guaranteed access to future projects,

and the $20 million home on Star Island and Miami.

It's reasonable to believe defendant, Sean Combs,

Combs enterprises, love records, Justin Combs,

and Christina Corham would not have engaged in these acts

or threats, but for the existence of the Rico scheme

and their understanding that the collective would provide

unfettered access to financial resources

without ever questioning defendants, Sean Combs,

Combs enterprises, love records, Justin Combs,

and Christina Corham's use of the money.

216, upon information and belief,

the collective and defendant, Sean Combs,

Combs enterprises, love records, Justin Combs,

and Christina Corham have had several partnerships

throughout the years.

As is the case here, defendant, UMG,

provided Mr. Combs with unfettered access

to financial dollars in exchange for Mr. Combs

and defendant, Sean Combs, Combs enterprises,

love records, Justin Combs, and Christina Corham,

providing defendant, UMG with the fruits of the labor

of producers, musicians, writers, creators,

and artists such as plaintiff to utilize our talents

and labor to produce music and other tangible goods

and services without full compensation.

217, as outlined in the chart above,

from 2003 to 2005, defendant Combs,

the then CEO and owner of Bad Boy Records

entered a joint venture deal with Universal Music,

a subsidiary of Defendant Universal Music Group.

Upon information and belief at the time,

Defendant Combs and UMG entered their three-year joint venture,

it was public knowledge that Mr. Combs

had a serious reputation for violence

and engaging in criminal activity.

Defendant UMG had first-hand knowledge

of the Combs' propensity for violence

because on April 16, 1999, Defendant Combs

assaulted Steve Stout, their executive vice president

of InnerScope Geffen ANR.

Combs was arrested and charged with two felonies,

second-degree assault and criminal mischief.

In a beating of Steve Stout, who says Combs

and two bodyguards beat him with their fists,

a telephone, a champagne bottle, and a chair.

Mr. Combs had a criminal trial surrounding

a 1999 nightclub shooting in NYC

when Mr. Combs required his then-girlfriend,

Jennifer Lopez, to transport his illegal firearm

into the New York City nightclub.

In 2001, a former television host, Roger Mills,

sued Mr. Combs for assault.

The case did not end until 2004, two years

into the joint venture deal.

Despite all these public warning signs of a pattern

and practice of behavior, that evidence of propensity

to engage in violent crimes and other criminal activity,

Defendant UMG chose to enter into a general partnership

agreement with Mr. Combs.

Defendant UMG knew or should have known

that it had a duty to monitor how the financial resources they

provided to Mr. Combs were being spent upon information

and belief from 2009 to 2015, the collective and defendant

Sean Combs, Combs Enterprises, Love Records,

Justin Combs, and Christina Corum

continue their Rico Enterprise when Mr. Combs,

UMG and Mr. Grange entered a general business partnership

to internationally distribute music produced

by Mr. Combs and Bad Boy Records.

As part of the deal, UMG provided financial support

to Mr. Combs and paid for all expenses

related to the development and distribution

of the music Mr. Combs and Bad Boy Records produced.

Number 218, honor about 2022 to 2023,

the collective and defendant Sean Combs, Combs Enterprises,

Love Records, Justin Combs, and Christina Corum

establish the latest iteration of their Rico Enterprise

when they entered a general business partnership

to establish Love Records and distribute Love Records

first album, The Love Album Off the Grid.

According to the Declaration of Mishab to Mariam,

as the Chairwoman and CEO of Motown Records,

she reported directly to defendant Lucien Grange.

Mishab to Mariam also states that she was given approval

by defendant UMG to enter the partnership with Sean Combs

to help establish Love Records.

It is safe to assume that defendant Lucien Grange,

Mishab to Mariam's direct supervisor, was aware of

and signed off on the UMG and Sean Combs partnership,

which led to the establishment of Love Records.

According to Mishab to Mariam,

the defendant UMG and MR financial Combs

for approved invoices associated with the creation

of the Love Album.

If the treatment of Plaintiff Jones is any indication

of how defendant UMG and MR ensure that they're financing

of Love Records and the Love Album was applied in accordance

with the partnership agreement, then they would have realized

that artists like Plaintiff Jones had worked for several months

on the Love Album without full compensation.

Upon information and belief,

if the collective finance defendant Sean Combs,

Combs Enterprises, Love Records, Justin Combs,

and Christina Korum in the manner described by Mishab

to Mariam's declaration, then it's safe to assume

that they financed the recording cost

at Chalice Recording Studios,

defendant Combs House in Miami and Los Angeles,

as well as the yacht as evidence by post by Mr. Combs

that he made to Instagram from September 2022

to September 2023.

Honor about the time the Love Album was released.

As well as the videos and photos in Mr. Jones' possession,

defendant Sean Combs, Combs Enterprises, Love Records,

Justin Combs and Christina Korum did more than just record music.

On a daily basis, defendant Sean Combs, Combs Enterprises,

Love Records, Justin Combs, and Christina Korum had sex workers

and endless drugs flowing through the recording sessions

at CRS.

Mr. Combs Homes and on the yacht, which Mr. Combs rented.

Unless the collective had an overseer or present

at the recording sessions to account

for how the money they provided defendant Sean Combs,

Combs Enterprises, Love Records, Justin Combs,

and Christina Korum was being spent.

It's safe to say that they were complicit

in allowing their money to pay for illegal drugs

and sex workers.

220.

As evidence by the hundreds of hours of video

and audio recordings and plaintiffs' possession,

defendant Sean Combs, Justin Combs, Christina Korum,

his assistance, and staff all orchestrated,

participated, managed, and executed the Rico Enterprises

by purchasing and distributing ecstasy, cocaine,

GHB, ketamine, marijuana, and mushrooms.

They transported the drugs by flying on commercial airlines

from California to New York, Florida, the Virgin Islands,

and St. Bartholomew in the French Caribbean.

They placed these control substances

in their carry-on luggage through TSA.

They then carried these substances and black pouches

and distributed the drugs to Mr. Combs

as friends, houseguests, girlfriends, and sex workers.

221.

The Rico Enterprises functioned as a continuing unit

and maintains an ascertainable structure separate

and distinct from the pattern of racketeering activity.

222.

Upon information and belief,

the Enterprises was characterized by the collective

providing unlimited unchecked financing

to defendant Sean Combs and love records

for the establishment of love records

and the creation of the love album.

Defendant Sean Combs, love records, and Christina Korum

had a pattern of making false representations

and omissions to the artist's creatives, musicians,

and producers who use their talents

to provide services to the Rico Enterprises.

These false representations and omissions were designed

to induce artists, creatives, musicians, and producers

to utilize their talents and labor

to produce music and other tangible goods

and services without full compensation.

These artists, producers, creatives, and musicians

were also forced to solicit and participate

in sexual encounters with prostitutes and sex workers.

They were also required to transport illegal,

unregistered handguns and to purchase and distribute narcotics.

223.

As part of this scheme, defendants require their artists,

creatives, musicians, and producers

to visit strip clubs wearing exclusive, authentic,

bad boy merchandise and to use the name and reputation

of Mr. Combs to solicit sex workers and prostitutes.

224.

Additionally, Mr. Combs uses the prospects

of winning Grammy awards, purchasing $20 million homes,

participating in future projects,

making $250,000 cash payments,

and meeting influential music industry executives.

This pattern of false representations

was disseminated to artists, creatives, musicians,

and producers who reside in California, Florida, New York,

and around the country by defendants based in California,

Florida, and New York, under the direction

and on the behalf of defendants in New York.

The dissemination typically used interstate telephone wires,

social media messages, and electronic mail.

All right folks, we're gonna wrap up right here

with this episode, and the next episode discussing the topic

will pick up where we left off.

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