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		<title>Ghislaine Maxwell asks SCOTUS to overturn conviction</title>
		<link>https://homesafetytechpros.com/ghislaine-maxwell-asks-scotus-to-overturn-conviction/</link>
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		<pubDate>Fri, 11 Apr 2025 18:37:54 +0000</pubDate>
				<category><![CDATA[Crime News]]></category>
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					<description><![CDATA[<p>Background: Background: FILE – The Supreme Court of the United States is seen in Washington, March 26, 2024 (AP Photo/Amanda Andrade-Rhoades, File). Inset: UNITED STATES – MARCH 4: President Donald Trump arrives to deliver his address to a joint session of Congress in the House Chamber of the U.S. Capitol on Tuesday, March 4, 2025 [&#8230;]</p>
<p>The post <a href="https://homesafetytechpros.com/ghislaine-maxwell-asks-scotus-to-overturn-conviction/">Ghislaine Maxwell asks SCOTUS to overturn conviction</a> appeared first on <a href="https://homesafetytechpros.com">Home Safety Tech Pros</a>.</p>
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<div id="post-body">
<div id="attachment_518922" style="width: 1210px" class="wp-caption alignnone"><img fetchpriority="high" decoding="async" aria-describedby="caption-attachment-518922" class="size-full wp-image-518922" src="https://am22.mediaite.com/lc/cnt/uploads/2025/04/Ghislaine-Maxwell-Jeffrey-Epstein-SCOTUS.jpg" alt="Background: Background: FILE - The Supreme Court of the United States is seen in Washington, March 26, 2024 (AP Photo/Amanda Andrade-Rhoades, File). Inset: UNITED STATES - MARCH 4: President Donald Trump arrives to deliver his address to a joint session of Congress in the House Chamber of the U.S. Capitol on Tuesday, March 4, 2025 (Tom Williams/CQ Roll Call via AP Images). Inset top: Ghislaine Maxwell (DOJ). Inset bottom: FILE - This photo provided by the New York State Sex Offender Registry shows Jeffrey Epstein, March 28, 2017 (New York State Sex Offender Registry via AP, File)." width="1200" height="627"/></p>
<p id="caption-attachment-518922" class="wp-caption-text">Background: Background: FILE – The Supreme Court of the United States is seen in Washington, March 26, 2024 (AP Photo/Amanda Andrade-Rhoades, File). Inset: UNITED STATES – MARCH 4: President Donald Trump arrives to deliver his address to a joint session of Congress in the House Chamber of the U.S. Capitol on Tuesday, March 4, 2025 (Tom Williams/CQ Roll Call via AP Images). Inset top: Ghislaine Maxwell (DOJ). Inset bottom: FILE – This photo provided by the New York State Sex Offender Registry shows Jeffrey Epstein, March 28, 2017 (New York State Sex Offender Registry via AP, File).</p>
</div>
<p>On the last day permitted by the justices, Ghislaine Maxwell filed a <a href="https://www.documentcloud.org/documents/25895382-maxwell-petition/">159-page petition</a> Friday asking the U.S. Supreme Court to overturn her sex-trafficking conviction, arguing that per the terms of a non-prosecution agreement the government made with her former boyfriend, Jeffrey Epstein, she should never have been prosecuted.</p>
<p>The 63-year old Maxwell was <a href="https://lawandcrime.com/live-trials/ghislaine-maxwell/ghislaine-maxwell-sentenced-to-20-years-in-prison-after-judge-and-prosecutors-denounce-her-heinous-crimes-with-jeffrey-epstein/">convicted in 2021</a> of five counts of sex trafficking and <a href="https://lawandcrime.com/high-profile/theyve-given-me-four-days-to-live-jeffrey-epstein-and-prince-andrew-accuser-says-bus-crash-will-leave-her-dead-by-weeks-end/" target="_blank" rel="noopener">grooming minors for Epstein’s abuse</a> — crimes for which she was sentenced 20 years imprisonment. Epstein himself died in jail before he could face trial.</p>
<p>Following Maxwell’s conviction, she unsuccessfully appealed, having argued that a <a href="https://lawandcrime.com/high-profile/ghislaine-maxwell-claims-its-clear-explicit-and-unambiguous-that-jeffrey-epsteins-2007-plea-deal-protects-her-to-this-day/" target="_blank" rel="noopener noreferrer">2007 plea deal between Epstein and the federal government made </a>in the Southern District of Florida protected her — even though she was not a party to the deal and her prosecution was taking place in the Southern District of New York. The U.S. Court of Appeals for the 2nd Circuit ruled that it was “well established” law that a plea agreement “binds only the office of the United States Attorney for the district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction,” and that no such indication was present in Maxwell’s case.</p>
<p>Maxwell initially had until Feb. 23 to file an appeal with the nation’s highest court, but a few weeks before the filing was due, the deadline was <a href="https://www.supremecourt.gov/search.aspx?filename=/docket/docketfiles/html/public/24a709.html">extended</a> by Justice Sonia Sotomayor until April 10, after Maxwell <a href="https://www.supremecourt.gov/DocketPDF/24/24A709/337362/20250117162420418_AMENDED%20Application%20to%20Extend%20Time%20to%20File%20Petition%20for%20Writ.pdf">said</a> she had hired a new lawyer just one day earlier.</p>
<p>In Maxwell’s petition, her attorney called the case “the perfect vehicle” to resolve a split among the circuits over whether, in disputes like Maxwell’s, “United States” refers to the federal government broadly, or prosecutors in a specific jurisdiction more narrowly. It goes on to argue that a promise made in a plea agreement by one set of federal prosecutors should be binding on prosecutors from a different jurisdiction.</p>
<p>“A defendant should be able to rely on a promise that the United States will not prosecute again, without being subject to a gotcha in some other jurisdiction that chooses to interpret that plain language promise in some other way,” it said in the brief.</p>
<p>Maxwell is a British former socialite who is the daughter of British media proprietor and <a href="https://www.theguardian.com/us-news/2019/aug/22/the-murky-life-and-death-of-robert-maxwell-and-how-it-shaped-his-daughter-ghislaine">fraudster</a> Robert Maxwell.</p>
<p>Throughout Maxwell’s prosecution, information surfaced relating to <a href="https://lawandcrime.com/live-trials/ghislaine-maxwell/ghislaine-maxwells-accuser-jane-testifies-that-jeffrey-epstein-introduced-her-to-trump-at-mar-a-lago-when-she-was-14/">connections between Maxwell, Epstein, and President Donald Trump,</a> including testimony from one of Maxwell’s victims that Epstein introduced her to Trump at Mar-a-Lago when she was just 14 years old. The conservative-leaning Court — which includes three justices appointed by Trump — will now have the chance to decide whether Maxwell’s case is one in which they wish to become involved.</p>
<p>“This is an important issue and we are hopeful that the Supreme Court takes the case,” said Maxwell’s attorney, David Oscar Markus, in an email to Law&amp;Crime Friday. “Ghislaine never should have been charged as the federal government gave her immunity. To say that it only applies in one jurisdiction and not another makes no sense as a matter of law or common sense.”</p>
<p>You can read the full filing <a href="https://www.documentcloud.org/documents/25895382-maxwell-petition/">here</a>.</p>
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<br /><a href="https://lawandcrime.com/high-profile/never-should-have-been-charged-ghislaine-maxwell-tells-scotus-that-jeffrey-epstein-deal-applied-to-her-too/">Source link </a></p>
<p>The post <a href="https://homesafetytechpros.com/ghislaine-maxwell-asks-scotus-to-overturn-conviction/">Ghislaine Maxwell asks SCOTUS to overturn conviction</a> appeared first on <a href="https://homesafetytechpros.com">Home Safety Tech Pros</a>.</p>
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		<title>Diddy&#8217;s gag order proposal to crack down on &#8216;leaks&#8217; revealed</title>
		<link>https://homesafetytechpros.com/diddys-gag-order-proposal-to-crack-down-on-leaks-revealed/</link>
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		<dc:creator><![CDATA[homesafetytechpros]]></dc:creator>
		<pubDate>Fri, 25 Oct 2024 13:51:16 +0000</pubDate>
				<category><![CDATA[Crime News]]></category>
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		<category><![CDATA[proposal]]></category>
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		<category><![CDATA[sean &#039;diddy&#039; combs]]></category>
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					<description><![CDATA[<p>Sean P. Diddy Combs at the 2017 Costume Institute Benefit Gala celebrating the opening of the exhibition Rei Kawakubo/Comme des Garcons: Art Of The In-Between held on May 1, 2017 at The Metropolitan Museum of Art in New York City (zz/ESBP/STAR MAX/IPx). Now that Sean “Diddy” Combs has persuaded a federal judge that “a gag [&#8230;]</p>
<p>The post <a href="https://homesafetytechpros.com/diddys-gag-order-proposal-to-crack-down-on-leaks-revealed/">Diddy&#8217;s gag order proposal to crack down on &#8216;leaks&#8217; revealed</a> appeared first on <a href="https://homesafetytechpros.com">Home Safety Tech Pros</a>.</p>
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<div id="attachment_484098" style="width: 1210px" class="wp-caption alignnone"><img fetchpriority="high" decoding="async" aria-describedby="caption-attachment-484098" class="size-full wp-image-484098" src="https://am21.mediaite.com/lc/cnt/uploads/2024/10/Sean-Combs.jpg" alt="File Photo by: zz/ESBP/STAR MAX/IPx 2017 5/1/17 Sean P. Diddy Combs at the 2017 Costume Institute Benefit Gala celebrating the opening of the exhibition &quot;Rei Kawakubo/Comme des Garcons: Art Of The In-Between&quot; held on May 1, 2017 at The Metropolitan Museum of Art in New York City. (NYC)" width="1200" height="627"/></p>
<p id="caption-attachment-484098" class="wp-caption-text">Sean P. Diddy Combs at the 2017 Costume Institute Benefit Gala celebrating the opening of the exhibition Rei Kawakubo/Comme des Garcons: Art Of The In-Between held on May 1, 2017 at The Metropolitan Museum of Art in New York City (zz/ESBP/STAR MAX/IPx).</p>
</div>
<p>Now that <a href="https://lawandcrime.com/?s=Sean+%27Diddy%27+Combs" target="_blank" rel="noopener">Sean “Diddy” Combs</a> has persuaded a federal judge that “a gag order is appropriate,” in the <a href="https://storage.courtlistener.com/recap/gov.uscourts.nysd.628425/gov.uscourts.nysd.628425.48.0.pdf" target="_blank" rel="noopener">words of the defense</a>, the high-profile <a href="https://lawandcrime.com/?s=RICO+" target="_blank" rel="noopener">RICO</a> and <a href="https://lawandcrime.com/?s=sex+trafficking">sex trafficking</a> defendant’s lawyers and federal prosecutors are fighting over just how far an order should go and to whom it can and should apply.</p>
<p>In recent days, Combs asked U.S. District Judge Arun Subramanian to <a href="https://lawandcrime.com/high-profile/diddys-lawyers-mock-outlandish-baby-oil-conspiracy-theories-while-urging-judge-to-gag-witnesses-and-lawyers-identify-victims/" target="_blank" rel="noopener">put a stop to</a> “extrajudicial statements from prospective witnesses and their lawyers” and to protect the defendant’s right to a fair trial amid an <a href="https://lawandcrime.com/high-profile/serious-threats-to-his-rights-diddy-demands-to-know-accusers-identities-claims-many-pretend-victims-are-trying-to-cash-in-on-false-to-outright-absurd-allegations/" target="_blank" rel="noopener">avalanche of civil lawsuits that Combs</a> claims are “opportunistic.” At the same time, the defense has claimed that “unauthorized and prejudicial leaks of grand jury information” have taken place.</p>
<p><iframe title="P. Diddy&#039;s Lawyers Seek to Muzzle Everyone in Sex Trafficking Case" width="760" height="428" src="https://www.youtube.com/embed/UJ2Fvr453xQ?feature=oembed" frameborder="0" allow="accelerometer; autoplay; clipboard-write; encrypted-media; gyroscope; picture-in-picture; web-share" referrerpolicy="strict-origin-when-cross-origin" allowfullscreen></iframe></p>
<p>For instance, defense attorney Marc Agnifilo <a href="https://lawandcrime.com/high-profile/prosecutors-fire-back-after-diddy-raises-claims-of-grand-jury-leaks/" target="_blank" rel="noopener">asserted two weeks ago</a> that the Department of Homeland Security (DHS), was “most likely” the “source” that handed CNN a 2016 video of him abusing his ex-girlfriend Cassie Ventura at the Intercontinental Hotel in Los Angeles.</p>
<p>While <a href="https://lawandcrime.com/uncategorized/several-terabytes-diddy-prosecutors-shed-light-on-voluminous-discovery-including-icloud-accounts-and-dozens-of-seized-devices-as-defense-slams-leaks-of-grand-jury-info/" target="_blank" rel="noopener">prosecutors swiftly disputed the claim</a>, the defense went so far as to speculate that the “leak” to CNN was timed for May 17 former President <a href="https://lawandcrime.com/?s=donald+trump" target="_blank" rel="noopener">Donald Trump’s</a> <a href="https://lawandcrime.com/?s=hush-money+" target="_blank" rel="noopener">hush-money trial in Manhattan</a> was on pause for that day as he attended son Barron Trump’s high school graduation — making it “a slow news day” and a “perfect time” for the abuse video to come out and “mortally wound the reputation and the prospect of Sean Combs successfully defending himself against these allegations.”</p>
<aside class="o-callout__recirculate o-callout"/>
<p>Over the last couple of days, the defense and prosecution have submitted their own proposals about a gag order-to-be and separately offered explanations for the proposed language therein.</p>
<p><strong>Combs’ proposed gag order</strong></p>
<p><img decoding="async" class="alignnone size-full wp-image-488064" src="https://am24.mediaite.com/lc/cnt/uploads/2024/10/Screenshot-2024-10-25-at-7.43.08-AM.png" alt="" width="802" height="1458"/></p>
<p><strong>Prosecutors’ proposed gag order</strong></p>
<p><img loading="lazy" decoding="async" class="alignnone wp-image-488063" src="https://am21.mediaite.com/lc/cnt/uploads/2024/10/Screenshot-2024-10-25-at-7.43.18-AM.png" alt="" width="764" height="933"/></p>
<p><strong>The differences between the two stances</strong></p>
<p>Combs’ lawyers <a href="https://storage.courtlistener.com/recap/gov.uscourts.nysd.628425/gov.uscourts.nysd.628425.46.0_2.pdf" target="_blank" rel="noopener">told the judge</a> that “unfortunately” the defense and prosecution could not agree on proposed language despite an “extensive back and forth since” Oct. 10, but added that the two sides are not as far apart as they could be. The defense urged Subramanian to act quickly because government “agents” allegedly haven’t stopped leaking (a recent <a href="https://deadline.com/2024/10/sean-combs-victims-names-motion-1236117051/" target="_blank" rel="noopener">Deadline article</a> that quoted a “law enforcement source with knowledge of the case” was cited as one example, and a <a href="https://www.cnn.com/2024/05/29/entertainment/sean-diddy-combs-federal-investigation/index.html" target="_blank" rel="noopener">CNN story from May</a> — predating the indictment by months — was another).</p>
<p>“At this juncture, the Court’s intervention is critical because agents involved in the investigation have continued their leaks, and their damaging and false information to the press in the wake of the October 10 status conference, only heightening the need for the gag order to be issued as soon as possible,” the defense said, noting that the “principal disagreement between the parties stems from the fact that the government continues to resist language that will ensure that the order covers all the agents who may be exposed to grand jury materials and other confidential information related to the investigation and prosecution of this case.”</p>
<p>“The government wanted the order only to cover agents ‘assigned to’ the investigation, rather than any agents who acquire confidential information about the investigation and objected to the specific reference to the Department of Homeland Security,” Combs’ lawyers continued. “These objections would defeat the purpose of the order. Whether an agent is officially ‘assigned’ to the investigation or not should not matter.”</p>
<p>In response, <a href="https://storage.courtlistener.com/recap/gov.uscourts.nysd.628425/gov.uscourts.nysd.628425.47.0.pdf" target="_blank" rel="noopener">prosecutors clarified</a> that the primary lingering disagreement boils down to “the definition of the government” and who in law enforcement can be restrained from leaking.</p>
<p>“Accordingly, the only remaining disagreement between the parties is the language concerning who would be bound by the order. The Government’s proposed order reflects the reality that the Government has two separate obligations—maintaining the secrecy of grand jury material in accordance with Rule 6(e) of the Federal Rules of Criminal Procedure, and complying with the directives set forth in Local Criminal Rule 23.1,” prosecutors with the U.S. Attorney’s Office for the Southern District of New York said. “The parties agree that the Government attorneys assigned to the matter and staff members working under their supervision or at their direction are bound by both obligations. However, the parties disagree about the extent to which law enforcement agents and/or officers may be bound by those obligations.”</p>
<p>Slamming Combs’ proposal as “plainly overbroad,” prosecutors said there’s “simply” no way to enforce it and noted that the “purported leaks […] have not been of grand jury material and—as the defendant concedes—are not alleged to be from the agents and officers assigned to this case”:</p>
<blockquote>
<p>By contrast, the defendants—citing no authority—have insisted that such an order bind any “local and federal law enforcement agents assisting any aspect of the investigation or prosecution of the above-referenced case, and any related grand jury proceedings, including but not limited to the Department of Homeland Security.” Defendant’s proposal is plainly overbroad as it would require the Government to be held accountable for potentially thousands of agents in an independent law enforcement agency over whom the Government has no authority or oversight. Indeed, the United States Department of Homeland Security (“DHS”) employs over 200,000 individuals and includes the investigating agency here, Homeland Security Investigations (“HSI”), in addition to multiple other law enforcement agencies (such as U.S. Immigration and Customs Enforcement, U.S. Secret Service, and others) with no role in this case whatsoever. Such an order would simply be unenforceable.</p>
</blockquote>
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<p>The post <a href="https://homesafetytechpros.com/diddys-gag-order-proposal-to-crack-down-on-leaks-revealed/">Diddy&#8217;s gag order proposal to crack down on &#8216;leaks&#8217; revealed</a> appeared first on <a href="https://homesafetytechpros.com">Home Safety Tech Pros</a>.</p>
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		<title>Diddy says sex civil trafficking lawsuit should be dismissed</title>
		<link>https://homesafetytechpros.com/diddy-says-sex-civil-trafficking-lawsuit-should-be-dismissed/</link>
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		<pubDate>Sun, 20 Oct 2024 13:45:04 +0000</pubDate>
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					<description><![CDATA[<p>FILE -Sean ‘Diddy’ Combs participates in “The Four” panel during the FOX Television Critics Association Winter Press Tour in Pasadena, Calif., Jan. 4, 2018 (Photo by Richard Shotwell/Invision/AP, File). Defense attorneys for Sean “Diddy” Combs on Friday moved to dismiss a civil racketeering (RICO) lawsuit filed against him and other high-profile defendants by one of [&#8230;]</p>
<p>The post <a href="https://homesafetytechpros.com/diddy-says-sex-civil-trafficking-lawsuit-should-be-dismissed/">Diddy says sex civil trafficking lawsuit should be dismissed</a> appeared first on <a href="https://homesafetytechpros.com">Home Safety Tech Pros</a>.</p>
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<div id="attachment_485204" style="width: 1210px" class="wp-caption alignnone"><img fetchpriority="high" decoding="async" aria-describedby="caption-attachment-485204" class="size-full wp-image-485204" src="https://am21.mediaite.com/lc/cnt/uploads/2024/10/AP24261467731863.jpg" alt="Sean &quot;Diddy&quot; Combs" width="1200" height="627"/></p>
<p id="caption-attachment-485204" class="wp-caption-text">FILE -Sean ‘Diddy’ Combs participates in “The Four” panel during the FOX Television Critics Association Winter Press Tour in Pasadena, Calif., Jan. 4, 2018 (Photo by Richard Shotwell/Invision/AP, File).</p>
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<p>Defense attorneys for Sean “Diddy” Combs on Friday moved to dismiss <a href="https://www.courtlistener.com/docket/68284775/jones-v-combs/" target="_blank" rel="noopener">a civil racketeering (RICO) lawsuit</a> filed against him and other high-profile defendants by one of his former sound engineers.</p>
<p>In February, Rodney “Lil Rod” Jones Jr. sued Combs for sex trafficking, drug distribution, sexual assault, and sexual harassment. Also named in the lawsuit is Combs’ son, Justin Dior Combs, actor Cuba Gooding Jr., an unnamed “Rapper,” and an unnamed “R&amp;B Singer.”</p>
<p>Since then, an amended complaint was filed <a href="https://lawandcrime.com/high-profile/homeland-security-raids-diddys-homes-as-music-mogul-is-accused-of-sex-trafficking-grooming-for-cuba-gooding-jr-and-forced-drug-use/" target="_blank" rel="noopener">in March</a> and a second amended complaint was filed in April — in order to correct various deficiencies and abide by mandatory pleading standards.</p>
<p>Now, Combs’ lawyers say Jones anticipates filing yet another iteration of his lawsuit — and are imploring the judge overseeing the case to shut things down by dismissing the complaint entirely.</p>
<aside class="o-callout__recirculate o-callout"/>
<p>“Apparently recognizing the [second amended complaint’s] insufficiency, Jones repeatedly asks for permission to replead after the Combs Defendants’ motion is inevitably granted,” <a href="https://storage.courtlistener.com/recap/gov.uscourts.nysd.616406/gov.uscourts.nysd.616406.83.0.pdf" target="_blank" rel="noopener">the latest Combs filing</a> reads. “Leave to replead — in what would be his fourth complaint — should be denied as futile. Despite his efforts to supplement his pleading with new allegations in his Opposition, nothing in the Opposition suggests that Jones has additional facts to allege that would remedy the essential deficiencies of his claims.”</p>
<p>The defendants’ <a href="https://www.courtlistener.com/docket/68284775/66/jones-v-combs/" target="_blank" rel="noopener">motion to dismiss</a> was filed in August. Weeks later, after a steady drip of bad news, Combs was indicted by a grand jury in the Southern District of New York on charges of racketeering conspiracy, sex trafficking and transportation to engage in prostitution.</p>
<p>In late September, in a hard-charging <a href="https://www.courtlistener.com/docket/68284775/78/jones-v-combs/" target="_blank" rel="noopener">motion in opposition</a>, Jones’ attorneys took note of the nearly-year-worth of bad press and the allegations contained in the federal indictment.</p>
<p>From the plaintiff’s motion [emphasis in original]:</p>
<blockquote>
<p>The [court] must deny the RICO Enterprise Defendants Hail Mary Motion to Dismiss. Sean Combs (“SC”), Love Records (“LR”), Kristina Khorram (“KK”), and Combs Global Enterprises (“CGE”) (collectively, “the Combs RICO Enterprise”), the Court needs only to Google, and it would be abundantly clear that SC has zero credibility, and to quote United State President Joe Biden, he “has the morals of an alley cat.” SC is a criminally indicted, racketeering sex trafficking, illegal prostitution facilitating, accused drugs and guns dealer, accused Mexican cartel drug runner, accused murderer, and <span style="text-decoration: underline;"><strong><em>confirmed</em></strong></span> woman beater.</p>
</blockquote>
<p>Attorneys for the fallen-from-grace hip-hop mogul did not appreciate the verbiage employed by his one-time record producer.</p>
<p>“Because Jones is unable to refute any of the Combs Defendants’ arguments for dismissal of the incoherent Second Amended Complaint, his Opposition focuses heavily on ad hominem attacks,” the defense reply memorandum reads. “For the most part, Jones does not even attempt to argue that he has pled the elements of his purported claims.”</p>
<p><a href="https://lawandcrime.com/high-profile/serious-threats-to-his-rights-diddy-demands-to-know-accusers-identities-claims-many-pretend-victims-are-trying-to-cash-in-on-false-to-outright-absurd-allegations/" target="_blank" rel="noopener"><strong>More Law&amp;Crime coverage: ‘Serious threats to his rights’: Diddy demands to know accusers’ identities, claims ‘many pretend victims’ are trying to cash in on ‘false to outright absurd’ allegations</strong></a></p>
<p>The Jones filing also sought formal judicial notice for the indictment — essentially asking the court to formally acknowledge the allegations leveled by law enforcement. Specifically, the judge was asked to “notice that the indictment closely mimics Plaintiff Jones’s Second Amended Complaint.”</p>
<p>Combs’ attorneys aim to rubbish this effort.</p>
<p>“Jones impermissibly attempts to piggy-back off the Indictment to make up for the [second amended complaint’s] failure to plead any of the elements of a RICO claim,” the memo reads.</p>
<p>To hear the defense tell it, in each instance, Jones’ claims in the lawsuit against Combs fail on a basic, procedural level.</p>
<p>From the memo, at length:</p>
<blockquote>
<p>His centerpiece RICO claim still fails off the bat for lack of standing because he has not pled any economic injury to himself; nor can he rely on the Indictment to make up for his failure to allege predicate acts or the numerous other requirements for this claim. His TVPA claim still fails because of his admitted inability to plead a causal link between any threat or promise and any commercial sex act. His vague assault claim against Mr. Combs fails because Jones has still not identified when, where, or how these purported acts occurred. His premises liability claims against Mr. Combs fail because he still has not alleged that any claimed assault by third parties was foreseeable or that he suffered any injury. His emotional distress claims fail because they are duplicative, because Jones does not allege the requisite negligence and “outrageous” conduct necessary to support them, and because he fails to plead any injury. And his breach of oral contract claim still fails as barred by the Statute of Frauds because it involves a royalty claim that cannot be performed within a year.</p>
</blockquote>
<p>Combs, by way of his attorneys, purports to have more or less put the kibosh on Jones’ claims in his prior filings. And, the reply memorandum argues, the plaintiff should not get another chance to shore up his serially-deficient legal arguments and factual allegations.</p>
<p>“Jones has already amended his complaint twice and the operative pleading is 98 pages long — if he had any facts to allege against the Combs Defendants that made out a valid claim, he would (and should) have alleged them by now,” the memo concludes. “His request to file another amended pleading should be denied as futile.”</p>
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