In this filing, Sean Combs’s legal team reaffirms their argument to exclude evidence under Federal Rules of Evidence 413 and 404(b), which allow the introduction of prior sexual misconduct or other bad acts to show a defendant’s propensity or motive in certain cases. Combs’ attorneys argue that the plaintiff's attempt to introduce decades-old allegations and unrelated accusations from other individuals is highly prejudicial, lacks probative value, and would only serve to inflame the jury. They assert that these allegations are unsubstantiated, temporally remote, and bear no direct connection to the claims at issue in this specific case. They argue that the plaintiff is improperly attempting to create a pattern by stacking unrelated claims that would unfairly bias a jury.

The reply also takes aim at the plaintiff’s justification for using Rule 404(b) evidence, stating that it’s being used to improperly suggest character conformity — the very use the rule is designed to prevent. Combs’ team emphasizes that allowing this evidence would undermine his right to a fair trial by distracting from the core facts of the case and creating a “trial within a trial” over the truthfulness of other claims. They argue the evidence should be excluded under Rule 403 as well, due to the overwhelming danger of unfair prejudice substantially outweighing any alleged probative value. In conclusion, they urge the court to grant their motion and prevent the introduction of prior bad acts or sexual misconduct allegations under both Rule 413 and Rule 404(b).






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source:

gov.uscourts.nysd.628425.216.0.pdf