In this memorandum, the plaintiff in the federal case against Sean Combs and others seeks court approval to serve defendants Cuba Gooding Jr. and Justin Dior Combs via publication. The plaintiff argues that despite extensive efforts—including personal service attempts at multiple verified addresses, formal and informal waiver requests, professional skip-trace investigations, physical surveillance, and over $1,000 in service-related expenses—both defendants have deliberately evaded service. The plaintiff contends that traditional methods have been exhausted and that service by publication in widely circulated newspapers like the New York Times and Los Angeles Times is now necessary to proceed with the case.


The motion emphasizes that both defendants are aware of the lawsuit: Mr. Gooding has discussed it publicly, and Mr. Combs' father, Sean Combs, has been served and is actively litigating. The plaintiff asserts that the defendants' avoidance tactics are intentional strategies to frustrate the judicial process and avoid accountability in a serious federal lawsuit alleging sexual abuse, trafficking, and related claims. Citing precedents where courts have allowed alternate service methods for high-profile individuals residing in gated communities, the plaintiff urges the court to authorize service by publication to ensure the case can move forward without further delay.


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source:

gov.uscourts.nysd.616406.91.2.pdf

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