In the Reply Memorandum of Law supporting Sean Combs’ motion to dismiss the amended complaint in Thalia Graves v. Sean Combs and Joseph Sherman, Combs’ legal team reiterates that the plaintiff’s claims are both legally and factually insufficient. They argue that the amended complaint relies on conclusory allegations without concrete evidence of Combs’ direct involvement in the alleged misconduct. The reply further contends that the complaint improperly attempts to attribute liability to Combs through speculative inferences about his association with co-defendant Joseph Sherman, rather than demonstrating specific acts or intent required under the applicable legal standards.


Additionally, Combs’ attorneys assert that many of the claims are time-barred and fall outside the statute of limitations. The reply memorandum emphasizes that the plaintiff’s attempt to revive these claims through generalized references to a purported ongoing pattern of misconduct is legally untenable. They also argue that the complaint fails to meet the heightened pleading standards required for claims of intentional infliction of emotional distress and other tort-based allegations. On these grounds, the defense urges the court to dismiss the amended complaint in its entirety, with prejudice.


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source:

gov.uscourts.nysd.630450.87.0.pdf

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