In the case of John Doe v. Sean Combs et al., the Combs defendants filed a reply memorandum in further support of their partial motion to dismiss the complaint. They argue that several of the plaintiff’s claims—including those related to alleged events occurring outside the statute of limitations—should be dismissed as time-barred. The defense maintains that the plaintiff has failed to provide sufficient factual support to sustain certain causes of action, including claims under the Trafficking Victims Protection Act and various state law allegations. They also contend that the complaint improperly lumps together multiple corporate entities without specific allegations connecting each to the alleged conduct.

Additionally, the Combs defendants assert that the complaint is vague and fails to meet the pleading standards required under federal law. They emphasize that the plaintiff has not sufficiently linked Sean Combs or the named corporate entities to actionable misconduct that would justify moving forward on all counts. The reply brief reinforces the argument that certain claims—particularly those not tied to clearly identified actions or dates—lack the specificity needed to survive a motion to dismiss. As such, they request the court to dismiss the relevant portions of the complaint while allowing only properly pleaded claims to proceed.


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source:

gov.uscourts.nysd.629905.61.0.pdf