In a letter to Judge Subramanian regarding United States v. Combs, S3 24 Cr. 542 (AS), the Government addresses expected defense objections to specific aspects of testimony from Capricorn Clark. The defense is seeking to exclude Clark’s statements related to a 2004 incident in which she was allegedly kidnapped and threatened, as well as testimony concerning statements made to her by Cassie Ventura about an alleged assault committed by Sean Combs.

The Government argues that both portions of Clark’s testimony should be admitted. They contend the threats made during the kidnapping are directly relevant to demonstrating the scope of the enterprise’s coercive tactics and pattern of intimidation, central to the RICO charges. Additionally, Ventura’s statements to Clark regarding abuse by Combs are presented as corroborative evidence of the defendant's conduct and the atmosphere of fear maintained within his inner circle. The Government maintains that these statements are admissible under established evidentiary rules, including hearsay exceptions, and are critical to establishing context and intent.


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gov.uscourts.nysd.628425.367.0.pdf