The Second Amended Complaint filed by Clayton Howard in the U.S. District Court for the Central District of California lays out a sweeping civil case against Sean Combs, Cassandra Ventura, Bad Boy Records, Combs Enterprises, and the Beverly Hills Hotel Corporation. Howard alleges a pattern of abuse, coercion, intimidation, and exploitation tied to Combs’ business empire, asserting that the defendants either directly participated in or knowingly enabled unlawful conduct. The complaint expands on earlier filings by adding detail, refining claims, and asserting that the alleged misconduct was not isolated but systemic, facilitated through corporate structures, private residences, hotels, and entertainment-industry power dynamics. Howard demands a jury trial and seeks damages, framing the case as one rooted in abuse of power, retaliation, and institutional complicity.


The amended filing also emphasizes the role of corporate defendants and venues, particularly the Beverly Hills Hotel, arguing that they failed in their duty to protect individuals from foreseeable harm and instead allowed their premises to be used in furtherance of alleged misconduct. By naming both individuals and corporate entities, the complaint aims to pierce the separation between Combs’ personal actions and his business operations, asserting joint liability across the enterprise. The Second Amended Complaint positions the case not merely as a dispute between private parties, but as a broader reckoning with how celebrity, money, and corporate shielding can be used to suppress accountability, with Howard seeking both financial relief and public adjudication of the claims before a jury.



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source:

Second Amended Complaint Howard v Combs Ventura.pdf