The Reply Memorandum of Law in Further Support of the Motion to Dismiss the Complaint against the Combs Defendants argues that the plaintiff’s amended complaint fails to state a viable claim under applicable legal standards. The defendants contend that the complaint is legally insufficient because it relies on conclusory allegations without concrete factual support, particularly regarding claims of sex trafficking and racketeering. They emphasize that the plaintiff has not demonstrated the necessary elements to establish a criminal enterprise or direct involvement by Sean “Diddy” Combs or his affiliated entities, and thus the case should be dismissed at this early stage.

Furthermore, the defendants assert that the complaint improperly conflates business operations with alleged illegal conduct, failing to show that the defendants knowingly participated in or benefited from any criminal activity. They argue that the plaintiff’s attempt to hold the defendants liable for the actions of third parties lacks the required causation and direct connection. The memorandum stresses that courts must reject attempts to extend liability beyond what the law permits, especially in complex cases involving serious accusations, and urges the court to grant dismissal in favor of the Combs Defendants to prevent unwarranted litigation.


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source:

gov.uscourts.nysd.632026.47.0.pdf