Jones v. Combs et al

1:24-cv-01457 | New York Southern District Court

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Division Foley Square
Judge Judge J. Paul Oetken
Filed Feb. 26, 2024
Case Flags ECF
Nature of Suit 470 Racketeer/Corrupt Organization
Cause 18:1962 Racketeering (RICO) Act
Jury Demand Plaintiff
Last Updated: 13 hours ago Show Interactive Timeline
Filing Date # Docket Text
3/24/2025
  • Motion for Joinder
OPINION AND ORDER re: 71 MOTION for Joinder in co-defendants' motion to dismiss. filed by Kristina Khorram, 66 MOTION to Dismiss the Second Amended Complaint. filed by Love Records, Sean Combs, Combs Global Ente rprises, 40 MOTION to Dismiss Plaintiff's Second Amended Complaint. filed by Motown Records, Lucian Charles Grainge, Universal Music Group. For the foregoing reasons, the Combs Defendants' motion to dismiss is GRANTED IN PART and DENIED IN PART. The motion is granted as to Jones's RICO claims, negligent and intentional infliction of emotional distress claims, and contract claims. The motion is also granted as to Jones's TVPA claims against Com bs Global. The motion is otherwise denied. Jones shall file a letter within two weeks of the entry of this opinion explaining the status of service as to Justin Combs and Cuba Gooding, Jr. Jones's claims are dismissed as to John and Jane Do es 1-10 and ABC Corporations 1-10. Defendants who have been served shall file an answer to the surviving claims with 14 days after the date of this opinion. The Clerk of Court is directed to close the motions at Docket Numbers 40, 66, and 71. SO ORDERED. ABC Corporations. 1-10 and John and Jane Does 1-10 terminated. (Signed by Judge J. Paul Oetken on 3/24/2025) (vfr)
12/13/2024
  • Motion to Dismiss (Demurrer)Granted
MEMORANDUM AND ORDER granting 49 Motion to Dismiss; denying 52 Motion for Sanctions. For the foregoing reasons, the UMG Defendants' motion for sanctions (ECF No. 52) is DENIED. Plaintiff's motion to voluntarily dismiss all claims in the second amended complaint against Grainge, Motown Records, and UMG (ECF No. 49) is GRANTED, and those claims are dismissed with prejudice. The Clerk of Court is directed to close the motions at Docket Numbers 49 and 52. SO ORDERED. (Signed by Judge J. Paul Oetken on 12/13/2024) (vfr) (Entered: 12/13/2024)
10/18/2024NOTICE of request for permission to join in the Reply Memorandum of Law filed on 10/18/24 on behalf of Mr. Combs. Document filed by Kristina Khorram..(Moskowitz, Avraham) (Entered: 10/18/2024)
10/18/2024
  • Motion to Dismiss (Demurrer)by Δ
REPLY MEMORANDUM OF LAW in Support re: 66 MOTION to Dismiss the Second Amended Complaint. . Document filed by Sean Combs, Combs Global Enterprises, Love Records..(Wolff, Erica) (Entered: 10/18/2024)
10/16/2024Minute Entry for proceedings held before Judge J. Paul Oetken: Oral Argument held on 10/16/2024 re: 52 MOTION for Sanctions . Decision Reserved. See transcript. (bh) (Entered: 10/16/2024)
10/8/2024 LETTER addressed to Judge J. Paul Oetken from Donald S. Zakarin dated October 8, 2024 Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group..(Saady, Nicholas) (Entered: 10/08/2024)
10/2/202481
  • Motion to Extend TimeGranted
ORDER granting 80 Motion for Extension of Time: Granted. The Combs Defendants shall file any reply brief in support of their motion to dismiss on or before October 18, 2024. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (djh) (Entered: 10/02/2024)
10/1/2024
  • Motion to Extend Time to File Replyby Δ
LETTER MOTION for Extension of Time to file reply brief addressed to Judge J. Paul Oetken from Erica A. Wolff dated October 1, 2024. Document filed by Sean Combs, Combs Global Enterprises, Love Records..(Wolff, Erica) (Entered: 10/01/2024)
10/1/2024DECLARATION of Tyrone A. Blackburn Esq. in Opposition re: 66 MOTION to Dismiss the Second Amended Complaint.. Document filed by Rodney Jones. (Attachments: # 1 Exhibit 1-Criminal Indictment, # 2 Exhibit 2-SDNY Civil Cases).(Blackburn, Tyrone) (Entered: 10/01/2024)
9/30/2024
  • Motion to Dismiss (Demurrer)by Π
FIRST MEMORANDUM OF LAW in Opposition re: 66 MOTION to Dismiss the Second Amended Complaint. . Document filed by Rodney Jones..(Blackburn, Tyrone) (Entered: 09/30/2024)
9/19/202477
  • Motion to Extend Time to File ResponseGranted
ORDER granting 75 Letter Motion for Extension of Time to File Response/Reply: Granted. Plaintiff shall file any opposition to the Combs Defendants' Motion to Dismiss the Second Amended Complaint on or before September 30, 2024. Counsel for Plaintiff is reminded to review and heed all applicable deadlines moving forward. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (djh) (Entered: 09/19/2024)
9/19/202476
  • Motion to Extend TimeGranted
ORDER granting 74 Letter Motion for Extension of Time: Granted. Plaintiff shall serve Defendants Justin Dior Combs and Cuba Gooding, Jr. on or before November 8, 2024. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (djh) (Entered: 09/19/2024)
9/17/2024
  • Motion to Extend Time to File Responseby Π
FIRST LETTER MOTION for Extension of Time to File Response/Reply as to 66 MOTION to Dismiss the Second Amended Complaint., 67 Memorandum of Law in Support of Motion addressed to Judge J. Paul Oetken from Tyrone Blackburn, Esq. dated 9/16/2024. Document filed by Rodney Jones..(Blackburn, Tyrone) (Entered: 09/17/2024)
9/9/2024
  • Motion to Extend Timeby Π
FIRST LETTER MOTION for Extension of Time to perfect the service of process on Justin Dior Combs and Cuba Gooding, Jr. addressed to Judge J. Paul Oetken from Tyrone Blackburn, Esq. dated September 9, 2024. Document filed by Rodney Jones. (Attachments: # 1 Exhibit Attachment A, # 2 Exhibit Attachment B, # 3 Exhibit Attachment C).(Blackburn, Tyrone) (Entered: 09/09/2024)
8/26/2024 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Corporate Parent 1169 Group Holdings LLC, Other Affiliate 1169 Corp. for Combs Global Enterprises. Document filed by Combs Global Enterprises..(Wolff, Erica) (Entered: 08/26/2024)
8/26/2024 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Love Records..(Wolff, Erica) (Entered: 08/26/2024)
8/26/2024
  • Motion for Joinder
MOTION for Joinder in co-defendants' motion to dismiss. Document filed by Kristina Khorram..(Moskowitz, Avraham) (Entered: 08/26/2024)
8/26/2024NOTICE OF APPEARANCE by Katie Elizabeth Renzler on behalf of Sean Combs, Combs Global Enterprises, Love Records..(Renzler, Katie) (Entered: 08/26/2024)
8/26/2024NOTICE OF APPEARANCE by Mark Elliot Cuccaro on behalf of Sean Combs, Combs Global Enterprises, Love Records..(Cuccaro, Mark) (Entered: 08/26/2024)
8/26/2024NOTICE OF APPEARANCE by Michael Tremonte on behalf of Sean Combs, Combs Global Enterprises, Love Records..(Tremonte, Michael) (Entered: 08/26/2024)
8/26/2024
  • Motion to Dismiss (Demurrer)by Δ
MEMORANDUM OF LAW in Support re: 66 MOTION to Dismiss the Second Amended Complaint. . Document filed by Sean Combs, Combs Global Enterprises, Love Records..(Wolff, Erica) (Entered: 08/26/2024)
8/26/2024
  • Motion to Dismiss (Demurrer)by Δ
MOTION to Dismiss the Second Amended Complaint. Document filed by Sean Combs, Combs Global Enterprises, Love Records. Responses due by 9/9/2024.(Wolff, Erica) (Entered: 08/26/2024)
8/26/2024NOTICE OF APPEARANCE by Erica Ashley Wolff on behalf of Sean Combs, Combs Global Enterprises, Love Records..(Wolff, Erica) (Entered: 08/26/2024)
8/26/2024NOTICE OF APPEARANCE by Deborah Austern Colson on behalf of Kristina Khorram..(Colson, Deborah) (Entered: 08/26/2024)
8/26/2024NOTICE OF APPEARANCE by Avraham Chaim Moskowitz on behalf of Kristina Khorram..(Moskowitz, Avraham) (Entered: 08/26/2024)
7/15/2024
  • Order
ORDER: The parties are directed to appear for a hearing on the UMG Defendants Motion for Sanctions (ECF No. 52) on October 16, 2024, at 10:00 a.m. in Courtroom 706 of the Thurgood Marshall United States Courthouse, 40 Foley Square, New York, NY 10007.SO ORDERED. Set Deadlines/Hearing as to ( Motion Hearing set for 10/16/2024 at 10:00 AM in Courtroom 706, 40 Centre Street, New York, NY 10007 before Judge J. Paul Oetken.) (Signed by Judge J. Paul Oetken on 7/15/2024) (sgz) (Entered: 07/15/2024)
6/7/2024DECLARATION of Donald S. Zakarin in Support re: 52 MOTION for Sanctions .. Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G).(Saady, Nicholas) (Entered: 06/07/2024)
6/7/2024
  • Motion for Sanctionsby Δ
REPLY MEMORANDUM OF LAW in Support re: 52 MOTION for Sanctions . . Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group..(Saady, Nicholas) (Entered: 06/07/2024)
6/3/2024FIRST LETTER addressed to Judge J. Paul Oetken from Tyrone A. Blackburn, Esq. dated 6/3/2024 re: Opposition to Sanctions Motion Delayed Filing. Document filed by Rodney Jones..(Blackburn, Tyrone) (Entered: 06/03/2024)
6/3/2024
  • Motion for Sanctionsby Π
FIRST REPLY MEMORANDUM OF LAW in Opposition re: 52 MOTION for Sanctions . . Document filed by Rodney Jones. (Attachments: # 1 Affidavit Rodney Jones Dec., # 2 Affidavit Declaration-Tyrone Blackburn, # 3 Exhibit 1, # 4 Exhibit 2, # 5 Exhibit 3, # 6 Exhibit 4, # 7 Exhibit 5.1, # 8 Exhibit 5.2, # 9 Exhibit 5.3, # 10 Exhibit 6, # 11 Exhibit 7, # 12 Exhibit 8, # 13 Exhibit 9, # 14 Exhibit 10, # 15 Exhibit 11, # 16 Exhibit 12).(Blackburn, Tyrone) (Entered: 06/03/2024)
5/24/202457
  • Order
ORDER: Counsel for Plaintiff and counsel for the UMG Defendants have submitted a number of letters to the Court by email, without a proper request for filing under seal. It is unclear what purpose these letters are intended to serve, other than to accuse the other side of improper conduct in various forms, and the letters do not ask for any relief or action by the Court. The Court will consider the UMG Defendant's motion for sanctions through proper briefing and not through these improperly submitted letters. With respect to the request that the Court "set a schedule for that [sanctions] motion," the Court notes that under SDNY Local Rule 6.1(b), Plaintiff's brief in opposition to the UMG Defendants' motion for sanctions is automatically due in 14 days from the filing of the motion, i.e., on May 31, 2024, and the UMG Defendants' reply brief is due 7 days from the filing of the opposition (absent any order setting a different schedule, which no one has requested). The Court will consider scheduling a hearing or oral argument on the motion after further briefing. (HEREBY ORDERED by Judge J. Paul Oetken) (Text Only Order) (Oetken, J.) (Entered: 05/24/2024)
5/23/2024Set/Reset Deadlines: Kristina Khorram answer due 8/26/2024. (tro) (Entered: 05/23/2024)
5/23/2024 STIPULATION: The deadline for Ms. Khorram to answer or otherwise respond to the Second Amended Complaint shall be August 26, 2024. (Signed by Judge J. Paul Oetken on 5/23/2024) (tro) (Entered: 05/23/2024)
5/20/2024FIRST LETTER addressed to Judge J. Paul Oetken from Tyrone A. Blackburn, Esq. dated 5/20/2024 re: Khorram Stip to Answer. Document filed by Rodney Jones. (Attachments: # 1 Supplement Khorram Stip to Answer).(Blackburn, Tyrone) (Entered: 05/20/2024)
5/17/2024DECLARATION of Donald S. Zakarin in Support re: 52 MOTION for Sanctions .. Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group. (Attachments: # 1 Exhibit A (Part 1 of 3) - Zakarin Rule 11 Declaration and Exhibits, # 2 Exhibit A (Part 2 of 3) - Zakarin Rule 11 Declaration and Exhibits, # 3 Exhibit A (Part 3 of 3) - Zakarin Rule 11 Declaration and Exhibits, # 4 Exhibit B - March 4, 2024 Zakarin Letter to Blackburn, # 5 Exhibit C - Blackburn Twitter / X Post).(Saady, Nicholas) (Entered: 05/17/2024)
5/17/2024
  • Motion for Sanctionsby Δ
MEMORANDUM OF LAW in Support re: 52 MOTION for Sanctions . . Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group..(Saady, Nicholas) (Entered: 05/17/2024)
5/17/2024
  • Motion for Sanctionsby Δ
MOTION for Sanctions . Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group..(Saady, Nicholas) (Entered: 05/17/2024)
5/14/2024 NOTICE OF MOTION FOR DISMISSAL OF ALL CLAIMS AND ALLEGATIONS AGAINST LUCIAN CHARLES GRAINGE, MOTOWN RECORDS AND UMG RECORDINGS, INC. (INCORRECTLY NAMED AS UNIVERSAL MUSIC GROUP): PLEASE TAKE NOTICE that, upon the supporting Declaration of Tyrone A. Blackburn dated May 13, 2024, and all prior proceedings heretofore had and all papers filed herein, Plaintiff Rodney Jones will move this Court, at a date and time to be determined by the Court, for an Order, pursuant to Rules 15, 21 and 41 of the Federal Rules of Civil Procedure, dismissing all claims and striking all allegations made against Lucian Charles Grainge, Motown Records, UMG Recordings, Inc. (incorrectly named as Universal Music Group) in the Second Amended Complaint with prejudice and removing Lucian Charles Grainge, Motown Records, UMG Recordings, Inc. (incorrectly named as Universal Music Group) from the caption of this action. Granted and so ordered. The Clerk of Court is directed to terminate the below-named defendants from this case. The motion at ECF No. 40 is denied as moot. The Clerk is directed to close ECF Nos. 40 and 49. Universal Music Group, Lucian Charles Grainge and Motown Records terminated. (Signed by Judge J. Paul Oetken on 5/14/2024) (ate) (Entered: 05/14/2024)
5/14/2024DECLARATION of Donald S. Zakarin in Support re: 49 FIRST MOTION to Dismiss with prejudice of all claims made in the Second Amended Complaint against Lucian Charles Grainge, Motown Records and Universal Music Group.. Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group..(Saady, Nicholas) (Entered: 05/14/2024)
5/14/2024
  • Motion to Dismiss (Demurrer)by Π
FIRST MOTION to Dismiss with prejudice of all claims made in the Second Amended Complaint against Lucian Charles Grainge, Motown Records and Universal Music Group. Document filed by Rodney Jones. (Attachments: # 1 Affidavit Declaration Tyrone Blackburn).(Blackburn, Tyrone) (Entered: 05/14/2024)
5/14/2024***NOTICE TO ATTORNEY REGARDING DEFICIENT VOLUNTARY DISMISSAL. Notice to Attorney Tyrone Blackburn. RE-FILE Document No. 47 Stipulation of Voluntary Dismissal. The filing is deficient for the following reason(s): (1) the wrong event type was used to file the voluntary dismissal; (2) the documents were not filed separately. Re-file the document using the event type Motion found under the event list Motions - select to Dismiss - select the correct filer/filers - select the correct party/parties the voluntary dismissal is against - and attach the correct signed PDF. (tp) (Entered: 05/14/2024)
5/13/2024FIRST LETTER addressed to Judge J. Paul Oetken from Tyrone Blackburn, Esq. dated 5/13/24 re: Update the Court on the status of service of the Summons and Complaint. Document filed by Rodney Jones..(Blackburn, Tyrone) (Entered: 05/13/2024)
5/13/2024 FILING ERROR - WRONG EVENT TYPE SELECTED FROM MENU - STIPULATION OF VOLUNTARY DISMISSAL It is hereby stipulated and agreed by and between the parties and/or their respective counsel(s) that the above-captioned action is voluntarily dismissed, with prejudice against the defendant(s) Lucian Charles Grainge, Motown Records, Universal Music Group and without costs pursuant to Rule 41(a)(1)(A)(ii) of the Federal Rules of Civil Procedure. Document filed by Rodney Jones. Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers).. (Attachments: # 1 Affidavit Declaration of Tyrone Blackburn).(Blackburn, Tyrone) Modified on 5/14/2024 (tp). (Entered: 05/13/2024)
5/13/2024SUMMONS RETURNED EXECUTED Summons and Amended Complaint,, served. Kristina Khorram served on 4/29/2024, answer due 5/20/2024. Service was accepted by John Doe, Receptionist. Service was made by Mail. Document filed by Rodney Jones..(Blackburn, Tyrone) (Entered: 05/13/2024)
4/26/2024ELECTRONIC SUMMONS ISSUED as to Justin Dior Combs, Sean Combs, Combs Global Enterprises, Cuba Gooding, Jr., Lucian Charles Grainge, Kristina Khorram, Love Records, Motown Records, Universal Music Group..(jgo) (Entered: 04/26/2024)
4/25/2024REQUEST FOR ISSUANCE OF SUMMONS as to Sean Combs, Justin Dior Combs, Cuba Gooding, Jr., Lucian Charles Grainge, Kristina Khorram, Love Records, Motown Records, Universal Music Group, Combs Global Enterprises, re: 38 Amended Complaint,,. Document filed by Rodney Jones. (Attachments: # 1 Supplement Defendants List Rider-Summons).(Blackburn, Tyrone) (Entered: 04/25/2024)
4/25/2024***NOTICE TO ATTORNEY REGARDING DEFICIENT REQUEST FOR ISSUANCE OF SUMMONS. Notice to Attorney Tyrone Anthony Blackburn to RE-FILE Document No. 43 Request for Issuance of Summons,. The filing is deficient for the following reason(s): the PDF attached to the docket entry for the issuance of summons is not correct; party name on the docket text and the attached rider does not match exactly as it appears on the pleading caption (Justin Combs). Re-file the document using the event type Request for Issuance of Summons found under the event list Service of Process - select the correct filer/filers - and attach the correct summons form PDF. (jgo) (Entered: 04/25/2024)
4/24/2024 FILING ERROR - SUMMONS REQUEST PDF ERROR - REQUEST FOR ISSUANCE OF SUMMONS as to Sean Combs, Justin Combs, Cuba Gooding, Jr., Lucian Charles Grainge, Kristina Khorram, Love Records, Motown Records, Universal Music Group, and Combs Global Enterprises, re: 38 Amended Complaint,,. Document filed by Rodney Jones. (Attachments: # 1 Supplement Defendants List Rider-Summons).(Blackburn, Tyrone) Modified on 4/25/2024 (jgo). (Entered: 04/24/2024)
4/24/2024DECLARATION of Donald S. Zakarin in Support re: 40 MOTION to Dismiss Plaintiff's Second Amended Complaint.. Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group. (Attachments: # 1 Exhibit 1 - Declaration of Sir Lucian Grainge, # 2 Exhibit 2 - Declaration of Martha Braithwaite, # 3 Exhibit 3 - Declaration of Ethiopia Habtemariam, # 4 Exhibit 4 - Second Amended Complaint, # 5 Exhibit 5 - Ventura v. Combs et al, # 6 Exhibit 6 - Transcript of April 9, 2024 Court Telephone Conference, # 7 Exhibit 7 - Blackburn 3/25 Email to Davis, # 8 Exhibit 8 - Zakarin 3/4 Letter to Blackburn).(Saady, Nicholas) (Entered: 04/24/2024)
4/24/2024
  • Motion to Dismiss (Demurrer)by Δ
MEMORANDUM OF LAW in Support re: 40 MOTION to Dismiss Plaintiff's Second Amended Complaint. . Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group..(Saady, Nicholas) (Entered: 04/24/2024)
4/24/2024
  • Motion to Dismiss (Demurrer)by Δ
MOTION to Dismiss Plaintiff's Second Amended Complaint. Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group..(Saady, Nicholas) (Entered: 04/24/2024)
4/18/2024***NOTICE TO ATTORNEY REGARDING DEFICIENT REQUEST FOR ISSUANCE OF SUMMONS. Notice to Attorney Tyrone Anthony Blackburn to RE-FILE Document No. 39 Request for Issuance of Summons. The filing is deficient for the following reason(s): Defendant party name errors. Defendant party names listed on Summons PDF and ECF docket entry do not correspond exactly to pleading caption. Re-file the document using the event type Request for Issuance of Summons found under the event list Service of Process - select the correct filer/filers - and attach the correct summons form PDF. (vf) (Entered: 04/18/2024)
4/17/2024 FILING ERROR - DEFICIENT - SUMMONS REQUEST PDF ERROR - REQUEST FOR ISSUANCE OF SUMMONS as to Sean Combs, Justin Combs, Cuba Gooding, Jr., Kristina Khorram, Love Records, Combs Global, re: 38 Amended Complaint,,. Document filed by Rodney Jones. (Attachments: # 1 Supplement Defendant List).(Blackburn, Tyrone) Modified on 4/18/2024 (vf). (Entered: 04/17/2024)
4/12/2024
  • Complaintby Π
SECOND AMENDED COMPLAINT amending 27 Amended Complaint,, 16 Amended Complaint,, against ABC Corporations. 1-10, Justin Dior Combs, Sean Combs, Combs Global Enterprises, Cuba Gooding, Jr., Lucian Charles Grainge, John and Jane Does 1-10, Kristina Khorram, Love Records, Motown Records, Universal Music Group with JURY DEMAND.Document filed by Rodney Jones. Related document: 27 Amended Complaint,, 16 Amended Complaint,,. (Attachments: # 1 Exhibit B, # 2 Exhibit A).(Blackburn, Tyrone) (Entered: 04/12/2024)
4/9/2024Minute Entry for proceedings held before Judge J. Paul Oetken: Telephonic Pretrial Conference held on 4/9/2024. See Order. See transcript. (bh) (Entered: 04/09/2024)
4/9/202437
  • OrderDenied
ORDER denying without prejudice 24 Motion to Dismiss. The UMG Defendants' motion to dismiss the First Amended Complaint is denied as moot and without prejudice to re-filing in light of the filing of a Second Amended Complaint. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (Oetken, J.) (Entered: 04/09/2024)
4/9/202436
  • Motion to File DocumentGranted
ORDER granting 30 Letter Motion for Leave to File Document: As discussed during the telephone conference held on April 9, 2024, Plaintiff's motion for leave to file a second amended complaint is granted. Plaintiff shall file the proposed second amended complaint on ECF as a separate docket entry. The UMG Defendants shall file their motion to dismiss by April 30, 2024. Plaintiff's opposition shall be filed within three weeks of the filing of Defendants' motion and any reply shall be filed within two weeks of the filing of Plaintiff's opposition. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (Oetken, J.) (Entered: 04/09/2024)
4/9/2024FIRST LETTER addressed to Judge J. Paul Oetken from Tyrone A. Blackburn, Esq. dated 04/09/24 re: Response to Defendants letter dated 4/4/24. Document filed by Rodney Jones..(Blackburn, Tyrone) (Entered: 04/09/2024)
4/9/2024
  • Motion to File Amended Complaintby Π
FIRST REPLY MEMORANDUM OF LAW in Support re: 30 FIRST LETTER MOTION for Leave to File Second Amended Complaint addressed to Judge J. Paul Oetken from Tyrone A. Blackburn, Esq. dated 3/28/24. . Document filed by Rodney Jones. (Attachments: # 1 Exhibit A, # 2 Exhibit B).(Blackburn, Tyrone) (Entered: 04/09/2024)
4/4/2024 LETTER addressed to Judge J. Paul Oetken from Donald S. Zakarin, Esq. dated April 4, 2024 Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group. (Attachments: # 1 Exhibit 1 - Judge Cote Order).(Saady, Nicholas) (Entered: 04/04/2024)
4/2/202432
  • Order
ORDER: Counsel for the parties shall appear for a telephone conference on April 9, 2024, at 3:30 p.m. At the scheduled time, counsel should call (888) 557-8511 and enter passcode 9300838. So ordered. (HEREBY ORDERED by Judge J. Paul Oetken) (Text Only Order) (nhb) (Entered: 04/02/2024)
4/1/2024LETTER RESPONSE in Opposition to Motion addressed to Judge J. Paul Oetken from Donald S. Zakarin dated April 1, 2024 re: 30 FIRST LETTER MOTION for Leave to File Second Amended Complaint addressed to Judge J. Paul Oetken from Tyrone A. Blackburn, Esq. dated 3/28/24. . Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group. (Attachments: # 1 Exhibit 1 - Declaration of Ethiopia Habtemariam, # 2 Exhibit 2 - Lin Letter to Blackburn, # 3 Exhibit 3 - Declaration of Martha Braithwaite, # 4 Exhibit 4 - Blackburn X Statement).(Saady, Nicholas) (Entered: 04/01/2024)
3/28/2024
  • Motion to File Amended Complaintby Π
FIRST LETTER MOTION for Leave to File Second Amended Complaint addressed to Judge J. Paul Oetken from Tyrone A. Blackburn, Esq. dated 3/28/24. Document filed by Rodney Jones. (Attachments: # 1 Supplement Proposed Second Amended Complaint, # 2 Exhibit A, # 3 Exhibit B).(Blackburn, Tyrone) (Entered: 03/28/2024)
3/28/2024 LETTER addressed to Judge J. Paul Oetken from Donald S. Zakarin, Esq. dated March 28, 2024 Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group. (Attachments: # 1 Exhibit A - March 4, 2024 Letter from D. Zakarin to T. Blackburn).(Saady, Nicholas) (Entered: 03/28/2024)
3/28/2024***NOTICE TO ATTORNEY REGARDING DEFICIENT PLEADING. Notice to Attorney Tyrone Anthony Blackburn to RE-FILE re: Document No. 27 Second Amended Complaint. The filing is deficient for the following reason(s): Court's leave has not been granted; the order granting permission to file the pleading was not attached; The pleading is not linked to a First Amended Complaint. Re-file the pleading using the event type Amended Complaint found under the event list Complaints and Other Initiating Documents - attach the correct signed PDF - select the individually named filer/filers - select the individually named party/parties the pleading is against. File the Exhibit to Pleading event found under the event list Other Documents and attach either opposing party's written consent or Court's leave. (vf) (Entered: 03/28/2024)
3/28/2024FIRST LETTER addressed to Judge J. Paul Oetken from Tyrone A. Blackburn, Esq. dated 3/27/24 re: Defendants Bad Faith Motion To Dismiss. Document filed by Rodney Jones..(Blackburn, Tyrone) (Entered: 03/28/2024)
3/27/2024 FILING ERROR - DEFICIENT PLEADING - FRCP RULE 15 NON-COMPLIANCE -SECOND AMENDED COMPLAINT amending 16 Amended Complaint,, against ABC Corporations. 1-10, Justin Dior Combs, Sean Combs, Combs Global Enterprises, Cuba Gooding, Jr., Lucian Charles Grainge, John and Jane Does 1-10, Kristina Khorram, Love Records, Motown Records, Universal Music Group with JURY DEMAND.Document filed by Rodney Jones. Related document: 16 Amended Complaint,,. (Attachments: # 1 Affidavit Attachment B, # 2 Exhibit Attachment A).(Blackburn, Tyrone) Modified on 3/28/2024 (vf). (Entered: 03/27/2024)
3/27/2024DECLARATION of Donald S. Zakarin in Support re: 24 MOTION to Dismiss the First Amended Complaint.. Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group. (Attachments: # 1 Exhibit 1 - Declaration of Sir Lucian Grainge, # 2 Exhibit 2 - Declaration of Martha Braithwaite, # 3 Exhibit 3 - Declaration of Ethiopia Habtemariam, # 4 Exhibit 4 - First Amended Complaint, # 5 Exhibit 5 - Love Records Incorporation, # 6 Exhibit 6 - Discover Music Article, # 7 Exhibit 7 - List of UMG Labels, # 8 Exhibit 8 - Billboard & Revolt Articles, # 9 Exhibit 9 - Ventura v. Combs et al, # 10 Exhibit 10 - March 4, 2024 Letter from D. Zakarin to T. Blackburn).(Saady, Nicholas) (Entered: 03/27/2024)
3/27/2024
  • Motion to Dismiss (Demurrer)by Δ
MEMORANDUM OF LAW in Support re: 24 MOTION to Dismiss the First Amended Complaint. . Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group..(Saady, Nicholas) (Entered: 03/27/2024)
3/27/2024
  • Motion to Dismiss (Demurrer)by Δ
MOTION to Dismiss the First Amended Complaint. Document filed by Lucian Charles Grainge, Motown Records, Universal Music Group. Responses due by 4/10/2024 Return Date set for 4/17/2024 at 11:59 PM..(Saady, Nicholas) (Entered: 03/27/2024)
3/27/2024WAIVER OF SERVICE RETURNED EXECUTED. Document filed by Lucian Charles Grainge..(Saady, Nicholas) (Entered: 03/27/2024)
3/27/2024WAIVER OF SERVICE RETURNED EXECUTED. Document filed by Motown Records..(Saady, Nicholas) (Entered: 03/27/2024)
3/27/2024WAIVER OF SERVICE RETURNED EXECUTED. Document filed by Universal Music Group..(Saady, Nicholas) (Entered: 03/27/2024)
3/27/2024 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Corporate Parent Universal Music Group N.V., Other Affiliate Compagnie de Cornouaille SAS, Other Affiliate PS VII Master, L.P. for Motown Records, Universal Music Group. Document filed by Motown Records, Universal Music Group..(Saady, Nicholas) (Entered: 03/27/2024)
3/26/2024 NOTICE OF VOLUNTARY DISMISSAL PURSUANT TO F.R.C.P. 41(a)(1)(A)(ii). Pursuant to F.R.C.P. 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff Rodney Jones hereby gives notice that the above-captioned action is voluntarily dismissed, with prejudice, against Defendant Ethiopia Habtemariam only. So ordered. The Clerk of Court is directed to terminate the below-named defendant from this case., (Ethiopia Habtemariam terminated.) (Signed by Judge J. Paul Oetken on 3/26/24) (yv) (Entered: 03/26/2024)
3/26/2024 NOTICE OF VOLUNTARY DISMISSAL PURSUANT TO F.R.C.P. 41(a)(1)(A)(i). Pursuant to F.R.C.P. 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff Rodney Jones hereby gives notice that the above-captioned action is voluntarily dismissed, WITHOUT prejudice, against Defendant Chalice Recording Studios only. Plaintiff will refile against Defendant Chalice Recording Studios in Los Angeles, California. So ordered. The Clerk of Court is directed to terminate the below-named defendant from this case., (Chalice Recording Studios terminated.) (Signed by Judge J. Paul Oetken on 3/26/24) (yv) (Entered: 03/26/2024)
3/26/2024***NOTICE TO ATTORNEY REGARDING DEFICIENT PLEADING. Notice to Attorney Tyrone Anthony Blackburn to RE-FILE Document No. 16 Second Amended Complaint. The filing is deficient for the following reason(s): the PDF attached to the docket entry for the pleading is not correct; the Court name contains a typographical error; the PDF must be titled to correspond with the proper event type; the wrong event type was used to file the pleading. Re-file the pleading using the event type Amended Complaint found under the event list Complaints and Other Initiating Documents - attach the correct signed PDF - select the individually named filer/filers - select the individually named party/parties the pleading is against. (jgo) (Entered: 03/26/2024)
3/26/202417 ORDER granting 8 Motion to Amend/Correct: Granted. So ordered. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (nhb) (Entered: 03/26/2024)
3/25/2024 FILING ERROR - WRONG EVENT TYPE SELECTED FROM MENU - SECOND AMENDED COMPLAINT amending 2 Complaint, against ABC Corporations. 1-10, Justin Dior Combs, Sean Combs, Combs Global Enterprises, Lucian Charles Grainge, John and Jane Does 1-10, Kristina Khorram, Love Records, Motown Records, Universal Music Group, Cuba Gooding, Jr. with JURY DEMAND.Document filed by Rodney Jones. Related document: 2 Complaint,. (Attachments: # 1 Affidavit B, # 2 Affidavit A).(Blackburn, Tyrone) Modified on 3/26/2024 (jgo). (Entered: 03/25/2024)
3/25/2024NOTICE OF APPEARANCE by Alina Jamil Mian on behalf of Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Universal Music Group..(Mian, Alina) (Entered: 03/25/2024)
3/25/2024NOTICE OF APPEARANCE by Nicholas George Saady on behalf of Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Universal Music Group..(Saady, Nicholas) (Entered: 03/25/2024)
3/25/2024NOTICE OF APPEARANCE by William Laurence Charron on behalf of Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Universal Music Group..(Charron, William) (Entered: 03/25/2024)
3/25/2024NOTICE OF APPEARANCE by James A. Janowitz on behalf of Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Universal Music Group..(Janowitz, James) (Entered: 03/25/2024)
3/25/2024 LETTER addressed to Judge J. Paul Oetken from Donald S. Zakarin, Esq. dated March 25, 2024 Document filed by Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Universal Music Group..(Zakarin, Donald) (Entered: 03/25/2024)
3/25/2024NOTICE OF APPEARANCE by Donald S. Zakarin on behalf of Lucian Charles Grainge, Ethiopia Habtemariam, Motown Records, Universal Music Group..(Zakarin, Donald) (Entered: 03/25/2024)
3/25/2024***NOTICE TO COURT REGARDING NOTICE OF VOLUNTARY DISMISSAL Document No. 6 Notice of Voluntary Dismissal, 7 Notice of Voluntary Dismissal,, was reviewed and referred to Judge J. Paul Oetken for approval for the following reason(s): the plaintiff(s) filed their voluntary dismissal and it did not dismiss all of the parties or the action in its entirety;. (nd) (Entered: 03/25/2024)
3/23/2024FIRST LETTER addressed to Judge J. Paul Oetken from Tyrone A. Blackburn, Esq. dated 03/23/24 re: Voluntary Dismissal of Defendants Ethiopia Habtemariam, and Chalice Recording Studios pursuant to F.R.C.P. 41(a)(1)(A)(i). Document filed by Rodney Jones..(Blackburn, Tyrone) (Entered: 03/23/2024)
3/23/2024FIRST MOTION to Amend/Correct 6 Notice of Voluntary Dismissal, . Document filed by Rodney Jones..(Blackburn, Tyrone) (Entered: 03/23/2024)
3/23/2024NOTICE OF VOLUNTARY DISMISSAL pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff(s) and or their counsel(s), hereby give notice that the above-captioned action is voluntarily dismissed, without prejudice and without costs against the defendant(s) Chalice Recording Studios. Document filed by Rodney Jones. Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers)...(Blackburn, Tyrone) (Entered: 03/23/2024)
3/23/2024NOTICE OF VOLUNTARY DISMISSAL pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff(s) and or their counsel(s), hereby give notice that the above-captioned action is voluntarily dismissed, with prejudice and without costs against the defendant(s) Ethiopia Habtemariam. Document filed by Rodney Jones. Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers)...(Blackburn, Tyrone) (Entered: 03/23/2024)
3/20/2024>>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. 5 FIRST MOTION for Rodney Diggs, Esq. to Appear Pro Hac Vice For Plaintiff Rodney Jones. Filing fee $ 200.00, receipt number ANYSDC-29102400. Motion and supporting papers to be reviewed by Clerk's Office staff.</FO. The filing is deficient for the following reason(s): missing Certificate of Good Standing from Supreme Court of California; Must provide a Declaration or a signed and notarized affidavit; Re-file the motion as a Motion to Appear Pro Hac Vice - attach the correct signed PDF - select the correct named filer/filers - attach valid Certificates of Good Standing issued within the past 30 days - attach Proposed Order. (rju) (Entered: 03/20/2024)
3/19/2024 FILING ERROR - DEFICIENT DOCKET ENTRY - FIRST MOTION for Rodney Diggs, Esq. to Appear Pro Hac Vice For Plaintiff Rodney Jones. Filing fee $ 200.00, receipt number ANYSDC-29102400. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Rodney Jones. (Attachments: # 1 Proposed Order Proposed Order).(Blackburn, Tyrone) Modified on 3/20/2024 (rju). (Entered: 03/19/2024)
3/5/2024***NOTICE TO ATTORNEY REGARDING DEFICIENT REQUEST FOR ISSUANCE OF SUMMONS. Notice to Attorney Tyrone Anthony Blackburn to RE-FILE Document No. 4 Request for Issuance of Summons,. The filing is deficient for the following reason(s): the PDF attached to the docket entry for the issuance of summons is not correct; party name on the attached rider does not match exactly as it appears on the pleading caption (Combs Enterprises). Re-file the document using the event type Request for Issuance of Summons found under the event list Service of Process - select the correct filer/filers - and attach the correct summons form PDF. (jgo) (Entered: 03/05/2024)
3/5/2024Case Designated ECF. (jgo) (Entered: 03/05/2024)
3/5/2024Magistrate Judge Valerie Figueredo is designated to handle matters that may be referred in this case. Pursuant to 28 U.S.C. Section 636(c) and Fed. R. Civ. P. 73(b)(1) parties are notified that they may consent to proceed before a United States Magistrate Judge. Parties who wish to consent may access the necessary form at the following link: https://nysd.uscourts.gov/sites/default/files/2018-06/AO-3.pdf. (jgo) (Entered: 03/05/2024)
3/5/2024CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge J. Paul Oetken. Please download and review the Individual Practices of the assigned District Judge, located at https://nysd.uscourts.gov/judges/district-judges. Attorneys are responsible for providing courtesy copies to judges where their Individual Practices require such. Please download and review the ECF Rules and Instructions, located at https://nysd.uscourts.gov/rules/ecf-related-instructions..(jgo) (Entered: 03/05/2024)
3/5/2024***NOTICE TO ATTORNEY REGARDING PARTY MODIFICATION. Notice to attorney Tyrone Anthony Blackburn. The party information for the following party/parties has been modified: RODNEY JONES; SEAN COMBS; JUSTIN DIOR COMBS; ETHIOPIA HABTEMARIAM; LUCIAN CHARLES GRAINGE; KRISTINA KHORRAM; CHALICE RECORDING STUDIOS; LOVE RECORDS; MOTOWN RECORDS; UNIVERSAL MUSIC GROUP; COMBS GLOBAL ENTERPRISES; JOHN and JANE DOES 1-10 ; ABC CORPORATIONS. 1-10. The information for the party/parties has been modified for the following reason/reasons: party name was entered in all caps;. (jgo) (Entered: 03/05/2024)
3/5/2024***NOTICE TO ATTORNEY REGARDING CIVIL CASE OPENING STATISTICAL ERROR CORRECTION: Notice to attorney Tyrone Anthony Blackburn. The following case opening statistical information was erroneously selected/entered: Dollar Demand $30,000,000,000;. The following correction(s) have been made to your case entry: the Dollar Demand has been modified to none;. (jgo) (Entered: 03/05/2024)
3/4/2024 FILING ERROR - SUMMONS REQUEST PDF ERROR - REQUEST FOR ISSUANCE OF SUMMONS as to SEAN COMBS, JUSTIN DIOR COMBS, ETHIOPIA HABTEMARIAM, LUCIAN CHARLES GRAINGE, KRISTINA KHORRAM, CHALICE RECORDING STUDIOS, LOVE RECORDS, MOTOWN RECORDS, UNIVERSAL MUSIC GROUP, COMBS GLOBAL ENTERPRISES, re: 2 Complaint,. Document filed by RODNEY JONES. (Attachments: # 1 Supplement Defendants List Rider-Summons).(Blackburn, Tyrone) Modified on 3/5/2024 (jgo). (Entered: 03/04/2024)
3/4/2024CIVIL COVER SHEET filed..(Blackburn, Tyrone) (Entered: 03/04/2024)
3/4/2024
  • Complaintby Π
COMPLAINT against ABC CORPORATIONS. 1-10, CHALICE RECORDING STUDIOS, JUSTIN DIOR COMBS, SEAN COMBS, COMBS GLOBAL ENTERPRISES, LUCIAN CHARLES GRAINGE, ETHIOPIA HABTEMARIAM, JOHN and JANE DOES 1-10, KRISTINA KHORRAM, LOVE RECORDS, MOTOWN RECORDS, UNIVERSAL MUSIC GROUP. (Filing Fee $ 405.00, Receipt Number ANYSDC-29026491)Document filed by RODNEY JONES..(Blackburn, Tyrone) (Entered: 03/04/2024)
2/27/2024***NOTICE TO ATTORNEY REGARDING DEFICIENT CIVIL COVER SHEET. Notice to attorney Tyrone Anthony Blackburn to RE-FILE Civil Cover Sheet. The filing is deficient for the following reason(s): the PDF attached to the docket entry for the civil cover sheet is not correct; all of the party names must be listed on the PDF case caption. If all of the party names do not fit, include 'et al'; the event wrong event type was used to file the civil cover sheet; the PDF must be filed separately. Re-file the document using the event type Civil Cover Sheet found under the event list Other Documents and attach the correct PDF. Use civil cover sheet issued by S.D.N.Y. dated October 1, 2020. The S.D.N.Y. Civil Cover Sheet dated October 1, 2020 is located at
http://nysd.uscourts.gov/file/forms/civil-cover-sheet.. (jgo) (Entered: 02/27/2024)
2/27/2024***NOTICE TO ATTORNEY REGARDING DEFICIENT PLEADING. Notice to Attorney Tyrone Anthony Blackburn to RE-FILE Document No. 1 Complaint. The filing is deficient for the following reason(s): the PDF attached to the docket entry for the pleading is not correct; the PDF must be titled to correspond with the event type used. Re-file the pleading using the event type Complaint found under the event list Complaints and Other Initiating Documents - attach the correct signed PDF - select the individually named filer/filers - select the individually named party/parties the pleading is against. If the deficiency/deficiencies are not corrected within five (5) days per Amended Standing Order 15-mc-00131 this case will be administratively closed. Initial Pleading due by 3/4/2024. (jgo) (Entered: 02/27/2024)
2/26/2024 FILING ERROR DEFICIENT PLEADING - PDF ERROR - COMPLAINT against ABC CORPORATIONS. 1-10, CHALICE RECORDING STUDIOS, JUSTIN DIOR COMBS, SEAN COMBS, COMBS GLOBAL ENTERPRISES, LUCIAN CHARLES GRAINGE, ETHIOPIA HABTEMARIAM, JOHN and JANE DOES 1-10, KRISTINA KHORRAM, LOVE RECORDS, MOTOWN RECORDS, UNIVERSAL MUSIC GROUP. (Filing Fee $ 405.00, Receipt Number ANYSDC-28998805)Document filed by RODNEY JONES. (Attachments: # 1 Civil Cover Sheet Civil Cover Sheet).(Blackburn, Tyrone) Modified on 2/27/2024 (jgo). (Entered: 02/26/2024)