In the memorandum of law filed in Case No. 25-cv-00996, the Combs Defendants—consisting of Sean Combs and several affiliated Bad Boy entities—move to dismiss the complaint brought by a plaintiff identified as John Doe. The defense argues that the complaint fails to meet the basic legal standards required for litigation, lacking specific factual allegations that would establish a plausible claim for relief. They contend that the complaint is overly broad, relies on conclusory assertions, and does not clearly link the named defendants to any actionable conduct. The motion emphasizes that Doe’s claims are insufficient under Rule 12(b)(6) and should not survive judicial scrutiny.

Additionally, the Combs Defendants argue that the complaint improperly lumps together numerous corporate entities and unidentified “Doe” defendants without distinguishing their individual roles or responsibilities, making it impossible to determine who allegedly did what. They maintain that this generalized approach violates federal pleading standards and fails to provide the clarity needed for a meaningful legal defense. The memorandum ultimately requests that the court dismiss the complaint in its entirety and with prejudice, asserting that further amendments would be futile given the lack of concrete factual support.


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source:

gov.uscourts.nysd.636272.44.0.pdf