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What's up everyone and welcome back to the program. In this episode we're going to pick up
1:05
where we left off with that Rodney Jones paperwork and his second amended complaint
1:12
filed against Diddy. To 25, upon information and belief, the true nature of defendant scheme
1:18
was left undisclosed, was omitted, and or was affirmatively misrepresented,
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all defraudulently increased defendant's profits, at least some of which were used to expand
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the enterprise, causing further injury to plaintiff Jones, and other unwitting artists, creatives,
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musicians, and producers. To 26, upon information and belief, defendant profited
1:41
from the enterprise and plaintiff Jones suffered because the enterprise
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diminished plaintiff Jones finances due to the 13 months of non-payment, and diminished
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plaintiff Jones' health through consistent drugging, and four sexual encounters with prostitutes,
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and sex workers. Defendant used the proceeds from their scheme to advance the scheme by funding
2:02
and operating their marketing machine, including through the use of the mail, social media,
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word of mouth, and interstate wires to sell the illusion that Mr. Combs was serious about the
2:13
talents and skills of the artists, creatives, musicians, and producers, and wanted to use those
2:18
skills to make music when nothing could be further from the truth. Defendants provided their
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artists, creatives, musicians, and producers, with this misrepresentative information,
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including via email, all over interstate wireline communication systems, and obtaining free labor,
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the distribution of drugs and firearms, as well as prostitutes, sex workers, and minors.
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Defendants obtained revenue via wire transfers, documents, and banking transactions that were
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exchanged via electronic means, over interstate wires, thereby growing the enterprise,
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and causing further injury to plaintiff Jones as described throughout.
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227. Upon information and belief, the defendant's scheme was reasonably calculated to deceive
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plaintiff Jones' artists, creatives, musicians, and producers of ordinary prudence and comprehension
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through the execution of their complex and illegal scheme, to misrepresent the effectiveness of
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soliciting prostitutes, sex workers, and minors, and distributing drugs and guns that did not
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would not and could not lead to securing Grammy Awards, purchasing $20 million homes,
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participating on future projects, $250,000 cash payments, and meeting influential music industry
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executives. Plaintiff Jones would not have lived with Mr. Combs for 13 months, missing birthdays,
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holidays, and family events, but for the illegal racketeering scheme operated by defendants.
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228. Upon information and belief, defendants each had a specific intent to participate in the
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overall rico enterprise and the scheme to defraud plaintiff Jones, and each participated in the
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enterprise's follows. 229. Upon information and belief, defendant Lucian Charles Grange,
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Combs Global, Motown Records, Love Records, and Universal Music Group,
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Control and Participate in the activities of the enterprise in a variety of ways as set forth
4:12
herein, including but not limited to developing and marketing scores of writing camps and
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listening party services that are marketed to innocent, unassuming artists, creatives, musicians,
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and producers. 238. Throughout the relevant period, defendant Lucian
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Charles Grange and his capacity as CEO of UMG, authorize Motown Records and Universal Music Group
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to enter into a general partnership agreement with Sean Combs and Love Records.
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As general business partners, each member is responsible for their partner's actions in the
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partnership. Defendant Lucian Charles Grange, Motown Records and Universal Music Group,
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have an ethical obligation to ensure their business partner Sean Combs and Love Records
4:56
were not using the partnership assets to engage in illegal activity. 231. Defendant Lucian Charles
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Grange and his capacity as CEO of UMG, authorize Motown Records and Universal Music Group
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to provide financial resources to their general business partners, defendant Sean Combs and Love
5:16
Records. Defendant Sean Combs and Love Records use the financial resources provided by their
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general business partner to solicit through the mail, email, social media, and the telephone,
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artist, creatives, musicians, and producers whom they would promise Grammy Awards,
5:32
expensive property, participation on future projects, cash payments, and meetings with powerful
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music industry executives. Defendant Sean Combs and Love Records,
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instructed defendant Justin Combs, Christina Korum and her staff to solicit these artist,
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creatives, musicians, and producers who resided in New York, Illinois, California, Georgia,
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and Florida. Defendant Justin Combs, Christina Korum and their staff relied on the mail, email,
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social media messenger, and telephone to disseminate the misleading information described herein.
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Defendant Sean Combs, Love Records, Justin Combs, and Christina Korum did not disclose to the
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individuals they solicited the fact that they would be drugged, required to sleep with sex workers,
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and forced the work for days at a time without compensation. As it relates to plaintive Jones,
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Defendant Sean Combs, Love Records, and Christina Korum controlled his ability to travel.
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They did not provide him with full compensation for the work he provided. As a result, Mr. Jones
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did not have the finances to return home without Defendant Sean Combs, Love Records,
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and Christina Korum paying for it. On several occasions in Miami, Florida, he asked Defendant Sean
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Combs and Christina Korum for permission to visit his family for their birthdays and holidays.
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Defendant Sean Combs and Christina Korum refused. They went so far as threatening Mr. Jones by telling
6:56
him that if he left, he would not be paid for the work he had done. Would not be allowed to return
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and would not receive the promised Grammy Awards, expensive property, participation in future projects,
7:07
cash payments, and meetings with influential music industry executives.
7:12
232. In connection with Defendants acting from New York, these defendants use the mail and
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interstate wires to solicit plaintive Jones and artists, creatives, musicians, and producers,
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and to use plaintive Jones and the artist's creatives, musicians, and producers to utilize
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their talents and labor to produce music and other tangible goods and services without full
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compensation, as well as the solicitation of sexual encounters with prostitutes, sex workers,
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and the purchasing and distribution of illegal firearms and drugs. Each of these acts was undertaken
7:46
with the knowledge and approval of all other defendants to further the goals of their conspiracy.
7:53
233. Defendant Lucian Charles Grange, in his capacity as CEO of UMG, authorized Motown Records
8:00
and Universal Music Group to provide financial resources to their general business partners,
8:05
Defendant Sean Combs, and Love Records. As the financial supplier of Defendant Sean Combs
8:12
and Love Records, Defendant Lucian Charles Grange, in his capacity as CEO of UMG, Motown Records,
8:19
and Universal Music Group, had a duty to direct and control the manner in which Defendant
8:24
Sean Combs and Love Records use the money they supplied. In furtherance of the goals of the
8:29
conspiracy, Defendant Lucian Charles Grange, in his capacity as CEO of UMG Motown Records
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and Universal Music Group, used the Love album as a ruse to provide Defendant Sean Combs
8:41
and Love Records with the financial resources to be used to execute his Rico Enterprise.
8:47
Throughout the relevant period, Defendant Sean Combs and Love Records use the financial resources
8:53
their general business partners provided to solicit potential artists, creatives, musicians,
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and producers. As detailed throughout, they relied on the mail, email, social media, text messages,
9:05
and WhatsApp messages to disseminate the misleading information described herein,
9:10
and profit from the free labor of these artists, creatives, musicians, and producers.
9:16
In addition to the force-free labor, they used their power and influence to force these creatives
9:21
to solicit sex workers and to engage in unwanted sexual encounters with these sex workers.
9:27
They also use their power and influence to force these creatives to purchase transport
9:32
and distribute illegal firearms and drugs. As a general business partner of Defendant Sean Combs
9:39
and Love Records, Defendant Lucian Charles Grange in his capacity as CEO of UMG Motown Records
9:46
and Universal Music Group are equally liable for the commission of these acts.
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234. Upon information and belief, defendant Lucian Charles Grange and his capacity as CEO of
11:43
UMG, authorized Motown Records and Universal Music Group to provide financial resources to
11:49
defendant Sean Combs and Love Records through wire transfers to defendant Sean Combs and Love
11:55
Records accountant Robin Greenhill. Upon information and belief, Ms. Greenhill,
11:59
ensured the wiring, funds, transfer, or cash payments the sex workers were completed.
12:05
Defendant Christina Koram through her direct reports, Frankie Santella,
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Moibon, and Brendan Paul would negotiate the fees the sex workers received and would ensure
12:15
that the workers are paid in one of the matters detailed above. According to plaintiff Jones,
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defendant Sean Combs bragged about having several women on a monthly stipend.
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According to plaintiff Jones, the women who received these payments are Carisha,
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Romeka Brownlee, aka Young Miami, Jade Raimi, aka Jade, and Daphne Joy Servantes,
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Narvaez, aka Daphne Joy, who were paid a monthly fee to work as Mr. Combs sex workers.
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Based on information and belief, they received these payments the wire transfer from Robin
12:48
Greenhill. It is unclear if they were provided the appropriate United States federal tax documents
12:55
for these payments or if they independently declared these payments on their taxes.
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It is unclear if defendant Lucian Charles Grange, in his capacity as CEO of UMG Motown Records
13:06
and Universal Music Group, requested an audit of defendant Sean Combs and Love Records financial
13:13
records to ensure the financial support they provided to defendant Sean Combs and Love Records,
13:19
as part of their general business partnership was not being used to pay Carisha,
13:23
Romeka Brownlee, Jade Raimi, and Daphne Joy for their work.
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235. During the 10 years preceding the filing of this action and to the present,
13:34
all defendants did cooperate jointly and severally in the commission of three or more of the
13:39
predicate acts that are itemized at U.S. Code 18, section 1961, 1A and B in violation of U.S.
13:48
Code 18, 1962D, as described in this complaint. 236. Beginning at an exact date unknown to plaintiff,
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but within 10 years preceding this filing of action, defendant have knowingly, willfully and
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unlawfully participated in a pattern of racketeering activity that continues to this day. 237.
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The acts set below racketeering acts follow the same pattern and purpose to defraud the plaintiff
14:15
for the defendant's benefit. Each racketeering act involved the same or similar methods of
14:20
commission and participants. 238. The defendant's business would not have succeeded without the repeated
14:27
predicate acts and the ability to conduct their fraud using mail, telecommunication wires,
14:32
interstate travel, international travel, and money laundering. 239. The separate racketeering acts
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all relate to each other in that they were a part of a concerted action by defendants to use
14:44
the endorsement and channels of the enterprise to operate their business to solicit potential
14:50
artists, creatives, musicians, and producers. As detailed throughout, they relied on the mail,
14:55
email, social media, text messages, and WhatsApp messages to disseminate the misleading
15:01
information described herein and profit from the free labor of these artists, creatives,
15:06
musicians, and producers. As detailed throughout, they relied on the mail, email, social media,
15:11
text messages, and WhatsApp messages to disseminate the misleading information described herein
15:17
and profit from the free labor of these artists, creatives, musicians, and producers. In addition to
15:23
the force-free labor, they use their power and influence to force these creatives to solicit
15:28
sex workers and to engage in unwanted sexual encounters with these sex workers. They also use
15:34
their power and influence to force these creatives to purchase, transport, and distribute illegal
15:39
firearms and drugs. All right folks, we're going to wrap up right here and in the next episode
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