In the Memorandum of Law in Opposition to the Combs Defendants’ Motion to Dismiss, the plaintiff—identified as Jane Doe—argues that her claims against Sean Combs and his affiliated companies should proceed, emphasizing the severity and credibility of her allegations. The filing challenges the defense's attempt to dismiss the case on procedural and substantive grounds, asserting that the complaint contains sufficient detail to establish plausible claims under federal sex trafficking laws, as well as state law causes of action. Jane Doe’s legal team maintains that her allegations, including forced sex acts, psychological manipulation, and threats of retaliation, clearly fall within the scope of actionable conduct under the Trafficking Victims Protection Reauthorization Act (TVPRA) and related statutes.

The memorandum also refutes the Combs defendants’ claims that the statute of limitations has expired or that the allegations are too vague to move forward. The plaintiff argues that the TVPRA allows for a longer limitations period due to the traumatic nature of sex trafficking crimes and the psychological barriers that often delay victim disclosure. Furthermore, the opposition brief asserts that the named entities were not passive corporate shells but active participants or enablers of the conduct in question, and therefore cannot be dismissed from the lawsuit. The filing seeks to hold Combs and his affiliated companies accountable for a pattern of organized abuse and exploitation, arguing that the case should advance to discovery rather than be prematurely dismissed.









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source:

gov.uscourts.nysd.630375.69.0.pdf