In the memorandum supporting their consolidated motion to dismiss, the defendants in the case of Dawn Angelique Richard v. Sean Combs et al. argue that the plaintiff's claims are largely time-barred under New York's statutes of limitations. They contend that the state’s shorter limitation periods should apply, rendering many of the plaintiff's causes of action untimely. Specifically, they assert that claims related to assault, battery, false imprisonment, intentional infliction of emotional distress, trafficking, forced labor, and various employment-related allegations fall outside the permissible time frames. The defendants also challenge the applicability of revival statutes, arguing that the Gender-Motivated Violence Law (GMVL) revival provision conflicts with existing laws like the Child Victims Act (CVA) and Adult Survivors Act (ASA), and thus cannot retroactively apply to the defendants.

Additionally, the defendants argue that the plaintiff's claims against various entities associated with Sean Combs, such as the "Bad Boy" and "Combs" entities, rely on improper group pleadings without specific allegations against each entity. They assert that the GMVL claim fails because the law did not apply to certain defendants at the relevant times and that the plaintiff does not sufficiently allege a gender-motivated crime of violence. Furthermore, the defendants contend that the plaintiff fails to state valid claims for forced labor, sex trafficking, discrimination under the New York State Human Rights Law, right of publicity, and unjust enrichment. They argue that these claims are either inadequately pled or legally baseless, and in some cases, barred by applicable statutes of limitations.



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source:

gov.uscourts.nysd.628103.154.0.pdf