In the reply memorandum of law filed in Case No. 24-CV-08852, the Combs Defendants argue for the dismissal of Dexter Withers' First Amended Complaint, asserting that it fails to state a valid legal claim and relies heavily on conclusory and unsupported allegations. They contend that Withers does not provide concrete facts linking Sean Combs or any affiliated entities to the specific harm alleged. The reply reaffirms the defense's position that the complaint lacks the legal sufficiency required under Rule 12(b)(6) of the Federal Rules of Civil Procedure and fails to meet the standards for pleading direct involvement, intent, or causation.

The Combs Defendants also address Withers’ attempt to bring Macy’s into the suit, arguing that the inclusion of a third-party retailer further weakens the complaint’s coherence and legal foundation. They maintain that the plaintiff’s assertions are speculative, disjointed, and fail to show any actionable misconduct by the named entities. In requesting dismissal, the Combs legal team insists that the amended complaint is merely a rehash of previously inadequate claims and does not correct the deficiencies identified in the original filing. As such, they urge the court to dismiss the complaint in full and with prejudice.


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source:

gov.uscourts.nysd.632109.55.0.pdf