Case 1:24-cr-00542-AS Document 31 Filed 10/09/24 Page 1 of 17

UNITED STATES DISTRICT COURT

United States of America

24 Cr. 542 (AS)

Sean Combs,

Defendant.

MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR AN

Dated: October 9, 2024

AGNIFILO INTRATER LLP

Marc Agnifilo
Teny Geragos
445 Park Avenue, 7th Floor
New York, NY 10022
T: 646-205-4350
marc@agilawgroup.com
teny@agilawgroup.com

Counsel to Defendant Sean Combs

Table of Contents

A. Introduction ............................................................................................................................. 1
B. Background ............................................................................................................................. 3
1. The Searches ....................................................................................................................... 3
2. Statements By DHS Agents To The Press .......................................................................... 5
3. The Leaked Hotel Videotape .............................................................................................. 8
C. This Court’s Authority .......................................................................................................... 11
D. Requested Relief ................................................................................................................... 14

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A. Introduction

Defendant Sean Combs moves for four forms of relief related to what the defense believes

was a series of unlawful government leaks, which have led to damaging, highly prejudicial pre-

trial publicity that can only taint the jury pool and deprive Mr. Combs of his right to a fair trial.

Mr. Combs requests: (1) an evidentiary hearing to examine government misconduct in connection

with the leaks; (2) discovery of emails, documents and records in the possession of the government

(including DHS) related to these leaks; (3) a gag order prohibiting government personnel from

disclosing any evidence or investigative material related to this case to any member of the media;

and (4) suppression of any evidence leaked by government employees in violation of Federal Rule

of Criminal Procedure 6(e) or any other law, rule, or regulation.

The available evidence makes a prima facie showing that the government, primarily

through DHS, has engaged in a seven-month campaign with three objects: (i) preventing Mr.

Combs from getting fair consideration by the grand jury; (ii) preventing him from getting a fair

trial; and (iii) strategically leaking confidential grand jury material and information, including the

2016 Intercontinental videotape, in order to prejudice the public and potential jurors against Mr.

Combs.

The government’s scheme to undermine Mr. Combs’ rights to a fair proceeding has several

methods and means. First, there has been a steady stream of false and prejudicial statements made

by DHS agents to various press outlets over the last seven months. Second, the agents engaged in

a particularly brutal and public search of Mr. Combs’ homes, during which they handcuffed Mr.

Combs’ innocent sons and then marched them before a news helicopter and the press. This was

an apparent effort to convey that they had overwhelming evidence against Mr. Combs, justifying

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the public and brutal treatment of even his children, who were handcuffed and manhandled by

federal agents armed with assault rifles. Third, government employees have repeatedly leaked

grand jury information and materials to the press to raise public hostility against Mr. Combs in

advance of trial.

The most egregious example of this is the leak to CNN of the 2016 videotape from the

Intercontinental Hotel in Los Angeles. As detailed below, the CNN leak was but one of a long and

documented history of leaks and false statements made with one purpose: to savage Mr. Combs’

reputation prior to trial. While the government’s misconduct in this case is particularly egregious,

it is unfortunately part of a trend in this District—the government has learned that it can

strategically leak information with impunity. This Court should exercise its authority to prohibit

these underhanded tactics, which severely undermine a criminal defendant’s right to a fair trial.

At the outset, the defense wants to be clear with the Court as to what our theory is and is

not. We do not contend that the leaks were orchestrated by the U.S. Attorney’s Office. Rather, we

contend that the false media statements and the grand jury leaks complained of below were planned

and executed by DHS. As the parties develop more information in this regard, the Court will see

that the defense repeatedly contacted the prosecutors and stated, in substance, that their agents

were leaking information to the press. Yet regardless of what, if any, action the U.S. Attorney’s

Office took, the leaks continued, even until after the arrest. The reason a hearing is needed is to

determine exactly what the DHS did, and did not do regarding these leaks, and what the U.S.

Attorney’s Office did and did not do to stop them.

The evidence of government misconduct is clear enough already that this Court is justified

in using its authority to craft appropriate remedies. Mr. Combs requests that this Court order

discovery and an evidentiary hearing to investigate the government’s misconduct. The abuse here

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is clear, but “without a hearing,” it would remain “unknown how far or where the abuse reached.”

United States v. Walters, 910 F.3d 11, 32 (2d Cir. 2018) (Jacobs, J., concurring). An evidentiary

hearing is thus necessary. In addition, if the hearing demonstrates that the violation of grand jury

secrecy was intentional, as we expect it will, the Court should order the suppression of the

videotape and/or any other illegally disclosed evidence, as well as other potential sanctions.

B. Background

The full extent of the government’s misconduct cannot yet be known. But what is known

is already enough. The government’s tactic in the searches, its constant stream of statements to

the press, and the leak of the hotel video demonstrate its intent to violate grand jury secrecy rules

and prejudice Mr. Combs prior to trial.

1. The Searches

The government’s campaign to prejudice Mr. Combs in the press commenced with the

searches on March 25, 2024. Notably, the searches could have been avoided altogether at no cost

to the government—prior to the searches, counsel for Mr. Combs had contacted the government

twice to offer cooperation. Prosecutors thus knew that they could serve a subpoena on counsel for

the phones, devices and other items they sought. Indeed, after the searches had been conducted,

the prosecutors did exactly this, serving two subpoenas on the undersigned seeking the identical

items it sought in the search warrants. However, the prosecutors ignored defense counsel’s

invitation to discuss the case so that they could engage in one of the more brutal and public searches

in recent memory.

At about 12:40 PM (PST) on March 25, 2024, over one-hundred armed federal agents

massed in three locations. Over 50 agents were at a residence at Two Star Island in Miami, Florida;

over 50 more were at Mr. Combs’ property in Los Angeles, California, and over 30 more were

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prepared to stop and search an airplane that Mr. Combs and his family were taking to a spring

break vacation. These searches were specifically designed to be public spectacles of brutality and

were not primarily focused merely on acquiring potential evidence.

First, the searches were carried out in the middle of the day to optimize media exposure.

Typically, searches are conducted quietly in the early morning. In this case, however, they were

conducted in the middle of the day—both in Los Angeles and Florida—so that the media could

cover them before a larger audience.

Second, the media was present at the inception of the Los Angeles search. In fact, one

media outlet, Fox 11, boasted on air that it was on site and filming even before the crime scene

tape was put up. It is thus clear that the DHS alerted the media prior to the search in order to

maximize exposure.

Third, the agents arrived in military-style armored vehicles, with scores of heavily armed

agents in full combat gear. One would think they were attempting to retake Donbas rather than

seize some phones and computers. The show of force had no legitimate purpose—it was merely

an attempt to garner further press attention, sensationalize the case, and portray Mr. Combs as

dangerous. The show of force was also particularly egregious given that authorities knew Mr.

Combs’ children—who are innocent, and who have never been a target of this investigation—were

likely to be present.

Fourth, the agents used excessive force against Mr. Combs’ children—who were in his

home, doing nothing wrong. One agent held a semi-automatic rifle to the head of Christian Combs,

even though he was visibly complying with the agents’ demands. Another agent had a semi-

automatic rifle with a laser site trained, and the orange dot visible, on the middle of the chest of

Justin Combs. Like his brother, Justin was also complying with agents’ demands. The agents then

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handcuffed Christian and Justin inside their house and then marched them to the front yard of the

house where news cameras and the Fox 11 helicopter—all invited by authorities—were waiting to

get salacious footage. 1 After perp-walking these two completely innocent young men and

displaying them in handcuffs and under restraint to the media, the agents walked them back into

the house, still in handcuffs, and released them.

These egregious tactics had no possible purpose other than to garner sensational media

coverage. It worked. The images of armed agents in full tactical gear, of the military style vehicles

and of Mr. Combs’ sons handcuffed and under restraint, having been removed at the point of an

assault weapon from their homes, made instant international news.

2. Statements By DHS Agents To The Press

With the searches concluded, the public relations campaign by the agents moved into high

gear. There were scores of public statements made by the agents, only a small sampling of which

will be included here. On March 25, 2024, agents and a spokesperson from Homeland Security

Investigations (HSI) confirmed that the government was conducting an ongoing sex trafficking

investigation. Agnifilo Decl. Exs. 1, 2. That day, “a source” further disclosed to the press that

“four Jane Does and one John Doe already sat for interviews with Southern District of New York

investigators for a probe related to alleged sex trafficking and racketeering” and that “[m]ore

interviews are scheduled.” Agnifilo Decl. Exs. 1, 2.

The next day, March 26, 2024, law enforcement sources told the New York Post that the

agents “wanted to seize the 54-year-old’s phones and computers, and that his properties in New

1
The agents could have brought the sons to a large fenced-in backyard where the media could
not see them in handcuffs. However, they purposefully marched them in handcuffs to the front
of the house where the media and the news helicopter were positioned.
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York and Chicago will be next.” Agnifilo Decl. Ex. 3. Sources further reported that the searches

were “based on a search warrant issued by the Southern District of New York.” Id.

On March 27, 2024, two days after the searches of Mr. Combs’ residences, an agent

specifically identified as working for DHS made public statements to, among other media, the

New York Post that “[w]e believe that there is a disturbing history of sex trafficking…We are

responding to concrete, detailed, explicit allegations. This is not random. We didn’t choose his

name out of a hat. We had allegations that we’re following up on.” The source—identified by the

Post as “[a]n officer with the Department of Homeland Security”—went on to tell the press, “[y]ou

have to understand that we didn’t just decide on a whim to search his homes. A federal judge had

to sign off. This isn’t a witch hunt.” The “DHS operative” further shared: “That’s a funny thing

about victims. They may be reluctant to speak at first, but once they start talking, they talk. They

talk a lot. We are getting a lot of cooperation from a lot of people who want to see him brought to

justice.” The New York Post further described the source of these quotes as a “Miami-based

officer” who spoke under condition of anonymity and confirmed Mr. Combs “is under

investigation.” Agnifilo Decl. Ex. 4.

Two days later, on March 29, 2024, “law enforcement sources” told ABC News that

“[p]rosecutors have interviewed a number of Diddy’s accusers, including those who have filed

civil lawsuits…”. Agnifilo Decl. Ex. 5. The next day, on March 30, 2024, a reporter at the New

York Post stated to News Nation that according to “Homeland Security sources” that the

investigation into Combs was “the tip of the iceberg” and that “nothing was off the table.” 2

Agnifilo Decl. Ex. 7.

2
This same phrase: “nothing off the table” was also used by the United States Attorney during
the press conference announcing the indictment in this case.
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On April 2, 2024, a media outlet called The Source reported that “sources close to the case”

shared that authorities had requested “telecommunications records related to Combs.” It further

reported that “the source, who requested anonymity due to the sensitivity of the matter, disclosed

that Homeland Security investigators are also keen on obtaining flight records associated with

Combs. These flight records, including passenger lists, could provide valuable insights into

Combs’ movements and activities.” Agnifilo Decl. Ex. 6.

Within the first week of the searches, the agents, all of whom were involved in an ongoing

grand jury investigation, informed the press that purported victims had been interviewed, that they

had obtained and executed search warrants, that they were obtaining telecommunications and flight

records (presumably with grand jury subpoenas), that their grand jury investigation was “getting a

lot of cooperation from a lot of people who want to see him brought to justice,” and that the grand

jury investigation into Combs was “the tip of the iceberg.” In addition, the agents’ public

statements were solely designed to prejudice the grand jury and the public, such as, “we believe

that there is a disturbing history of sex trafficking…We are responding to concrete, detailed,

explicit allegations. This is not random. We didn’t choose his name out of a hat. We had

allegations that we’re following up on.” Agnifilo Decl. Ex. 4.

Between the grand jury leaks and the incendiary public statements, the agents all but

ensured that the grand jury would be tainted as well as the general public from which we will soon

select a jury.

The inflammatory and false public statements continue up to the present. On September

18, 2024, a “Department of Homeland Security agent” told the New York Post that “the music

mogul had rooms that were clearly ‘dedicated to sex’ with cameras all around.” The source was

identified as “one of the [DHS] agents who helped raid [Mr. Combs’] Florida abode,” and further

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described “video evidence” obtained during the investigation. This agent went on to tell the press,

“[s]o if you were in those sex parties, you were being recorded from every possible angle, including

angles you wouldn’t have known about.” The Homeland Security agent then told the New York

Post, “in my opinion, he’s as bad as Jeffrey Epstein…These women are young. Either barely legal

or barely illegal.” Agnifilo Decl. Ex. 8; see also Agnifilo Decl. Ex. 9.

For a government employee to make statements to a New York Post reporter are false,

damaging and prejudicial. The indictment alleges a single victim as part of the sex trafficking

charge, an adult woman with whom Mr. Combs had a romantic relationship for ten years. For the

agent to make public statements that the conduct involves “barely illegal” women and that Combs

is as bad as Jeffrey Epstein is destructive to Mr. Combs’ right to a fair trial, particularly in light of

the fact that the only victim in the indictment was an adult throughout the charged conduct.

Taken together, the false, prejudicial statements and leaks served to feed further

sensationalistic media coverage—and prejudice potential jurors in advance of trial.

3. The Leaked Hotel Videotape

In the midst of this seven-month campaign to impugn Mr. Combs’s reputation before trial,

on Friday, May 17, 2024, a 2016 videotape from the Intercontinental Hotel in Los Angeles was

leaked to CNN. By far the most likely source of the leak is the government. That is true for several

reasons.

First, as set forth above, by May 17, 2024, federal agents had already engaged in a months-

long campaign of leaking information to the press. They had a demonstrated propensity of

embracing contacts at numerous press outlets and leaking information in order to produce media

coverage.

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Second, Victim 1 is not a likely source of the leak. There is no evidence that either she or

her lawyers had possession of the tape. To the contrary, had either Victim 1 or her lawyer had the

tape, the allegations in the civil complaint would have been entirely different and far more specific

than they were. Moreover, Victim 1 had no motive to approach law enforcement, much less leak

a videotape. She had sued Mr. Combs and received a substantial eight-figure settlement. The

government’s investigation only began after her lawsuit was settled.

Third, an unrelated third party is not a likely source. If a person not in law enforcement

were to leak the videotape to a news source, that person likely would have sold the tape rather than

simply give it to CNN. Outlets such as TMZ are known to pay tens of thousands of dollars for

such footage. That it was leaked instead to CNN shows a motive other than financial profit. It

shows a motive to damage Mr. Combs’ reputation without remuneration—a motive held by federal

agents.

Fourth, the timing of the leak suggests government involvement. The tape was leaked on

one of the few days the Trump trial was not being held as Barron Trump, Donald Trump’s youngest

son, graduated that day from High School in Florida with his father in attendance. One of the more

contentious issues in the Trump trial was whether trial would be stayed so Trump could attend his

son’s graduation. Eventually, the court announced that May 17 would not be a trial day. This was

a fact that would have been known to federal agents—and they also would have known that May

17 was thus a perfect time, as it was a slow news day given the break in the Trump trial.

Early in the morning of May 17, a CNN reporter informed a member of Mr. Combs’ public

relations team that CNN has “come across a video” from the Intercontinental Hotel. The reporter

went on to say, “through our reporting, we have confirmed this video is authentic.” The reporter

sought comment and also stated that CNN was reaching out to Victim 1’s representatives for

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comment. At 10:22 AM that morning, defense counsel emailed the prosecution team to say that

CNN was in possession of this videotape, and that counsel was concerned about the circumstances

by which it was provided to CNN. The government acknowledged defense counsel’s email hours

after the tape was made public, but, as far as defense counsel is aware, took no further action.

Regardless, a few hours after defense counsel made the prosecutors aware that CNN had the tape,

CNN released it to overwhelming international attention.

The videotape was leaked to CNN for one reason alone: to mortally wound the reputation

and the prospect of Sean Combs successfully defending himself against these allegations. Rather

than using the videotape as trial evidence, alongside other evidence that gives it context and

meaning, the agents misused it in the most prejudicial and damaging way possible. The

government knew what it had: a frankly deplorable video recording of Sean Combs in a towel

hitting, kicking and dragging a woman in full view of a camera in the hallway of the hotel.

The potential problem for the government is that if an agent provided this videotape to

CNN, this would be a violation of grand jury secrecy. This is, among other things, what the hearing

will determine. Because it is reasonable to believe that this was obtained in connection with a

grand jury investigation, that it was intentionally given to CNN to be released to the world, and

that there is a strong possibility that the person providing it to CNN was a federal agent involved

in this grand jury investigation, the remedy for this conduct should be full suppression of the

videotape that the government leaked. 3

3
After the undersigned notified the government that we would be filing this motion, prosecutors
responded that the video broadcast by CNN was not obtained through grand jury process and that
DHS did not have possession of the videotape prior to CNN’s publication of it. However,
government attorneys have not given any indication that they have investigated any of the leaks
related to this case. And, as discussed, we are not suggesting that the U.S. Attorney’s Office itself
leaked the videotape, but given all the evidence cited above, and the sheer number of agents

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C. This Court’s Authority

This Court has authority to investigate the government’s actions and to order appropriate

remedies. Its authority begins with Federal Rule of Criminal Procedure 6(e), which mandates

secrecy of grand jury proceedings and materials. A violation of Rule 6(e) occurs when a covered

person discloses “anything that will reveal what transpired during the grand jury proceedings.” In

re Grand Jury Subpoena, 103 F.3d 234, 238 (2d Cir. 1996). Covered persons include attorneys for

the government and other government personnel assisting government attorneys. Fed. R. Crim. P.

6(e)(2)(B)(vi)-(vii). “Both the direct and indirect disclosure of information are proscribed.” In re

Grand Jury Matter, 682 F.2d 61, 63 (3d Cir. 1982). Secrecy extends not just to grand jury

transcripts but also to all materials “relating to or affecting the grand jury.” In re Grand Jury

Subpoena, 103 F.3d at 238 (citing Fed. R. Crim. P. 6(e)(5)-(6)); accord Lawyers’ Comm. for 9/11

Inquiry, Inc. v. Garland, 43 F.4th 276, 286-87 (2d Cir. 2022) (“Congress intended for [Rule 6(e)’s]

confidentiality provisions to cover matters beyond those actually occurring before the grand jury”).

Federal courts are obligated to enforce the rule by imposing sanctions on those who violate

its secrecy provisions. Rule 6 itself states that a violation of that secrecy “may be punished as a

contempt of court.” Fed. R. Crim. P. 6(e)(7). That is not the sole possible remedy. “Other possible

remedies are suppression of grand-jury material or, in extraordinary cases, dismissal of an

indictment.” See 1 Wright & Miller, Fed. Prac. & Proc. Crim. § 107 Grand Jury Secrecy (5th ed.

& 2024 update). Indeed, Rule 6 “indicates no limits on the relief available to address violations.”

Barry v. United States, 865 F.2d 1317, 1321 (D.C. Cir. 1989).

involved in the investigation and the history of leaks, it seems entirely reasonable that the video
was leaked by one or more DHS agents.
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More generally, this Court has inherent authority under its supervisory powers to address

this sort of misconduct. Federal courts may exercise their supervisory powers “to prevent parties

from reaping benefit or incurring harm from violations of substantive or procedural rules (imposed

by the Constitution or laws).” United States v. Williams, 504 U.S. 36, 46 (1992). Government

misconduct includes actions whereby the government seeks to “obtain[] an unfair advantage long

before the trial even has begun.” United States v. Stein, 435 F. Supp. 2d 330, 382 (S.D.N.Y. 2006).

To deter and punish such misconduct, this Court has authority to “formulate procedural rules” that

apply to officers of the Court, including all “members of the bar” and “United States attorneys.”

United States v. He, 94 F.3d 782, 792 (2d Cir. 1996).

Pretrial statements to the press that have the tendency to prejudice a criminal defendant’s

right to a fair trial are prohibited by Rule 3.6 of the New York Rules of Professional Conduct and

SDNY Local Criminal Rule 23.1. Additionally, federal regulations bar all Department of Justice

employees—not just attorneys—from making prejudicial information prior to trial. “[T]he release

of information for the purpose of influencing a trial is, of course, always improper ….” 28 C.F.R.

§ 50.2(a)(2); see also id. § 50.2(b)(2) (“At no time shall personnel of the Department of Justice

furnish any statement or information for the purpose of influencing the outcome of a defendant's

trial, nor shall personnel of the Department furnish any statement or information, which could

reasonably be expected to be disseminated by means of public communication, if such a statement

or information may reasonably be expected to influence the outcome of a pending or future trial.”).

These provisions specifically note that “observations about a defendant’s character,” “statements

concerning the … credibility of prospective witnesses,” and “opinion[s] as to the accused’s guilt”

are never permissible—especially in the period leading up to trial. Id. § 50.2(b)(6); see also 5

U.S.C. § 552a (Privacy Act); 18 U.S.C. § 1503 (obstruction of “due administration of justice”

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through corrupt attempt to influence grand or petit jurors). This Court has authority to craft rules

and remedies to enforce those provisions—which have been violated by federal agents in this case.

This Court also has the authority—and indeed the duty—to investigate government

misconduct. “Most often, conducting a hearing is the preferred course of action in cases where

disputed factual issues exist.” United States v. Cuervelo, 949 F.2d 559, 567 (2d Cir. 1991)

(remanding for hearing on outrageous government conduct); accord United States v. Ventura, 96

F.4th 496, 502 (2d Cir. 2024); see also United States v. Voigt, 89 F.3d 1050, 1067-68 (3d Cir. 1996).

Once a prima facie showing of misconduct has been made, courts should conduct an evidentiary

hearing. See United States v. Rioux, 97 F.3d 648, 662 (2d Cir. 1996); cf. United States v. Skelos,

988 F.3d 645, 662 (2d Cir. 2021).

Moreover, this Court has authority to impose a gag order—that is, an order prohibiting

“extrajudicial statements by any lawyer, party, witness, or court official which divulged prejudicial

matters.” Sheppard v. Maxwell, 384 U.S. 333, 361 (1966); accord Gentile v. State Bar of Nevada,

501 U.S. 1030, 1072-76 (1991). Court have an “ongoing obligation to ensure that speech about a

criminal case” does not prejudice the proceedings. United States v. Trump, 88 F.4th 990, 1004

(D.C. Cir. 2023). And while court have only limited authority to limit the speech of the press, they

have much broader authority to police attorneys and other trial participants. Id. at 1004-05.

Finally, once the Court has ascertained the full extent of the misconduct, it has wide latitude

to fashion an appropriate remedy. “Rule [6(e)] indicates no limits on the relief available to address

violations.” Barry, 865 F.2d. at 1321. For example, if “Rule 6(e) . . . has been violated,” the

“sanctions . . . that may be imposed,” include “imprisonment for criminal contempt” and

“dismissal of the case.” United States v. Flemmi, 233 F. Supp. 2d 75, 83, 86 (D. Mass. 2000);

accord Fed. R. Crim. P. 6(e)(7). “Other possible remedies” include “suppression of grand-jury

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material.” 1 Wright & Miller, Fed. Prac. & Proc. Crim. § 107 Grand Jury Secrecy (5th ed. & 2024

update). Defendants reserve the right to seek one or more of these remedies, including suppression

of the videotape, following the evidentiary hearing.

D. Requested Relief

Based on the foregoing, Mr. Combs requests the following relief:

First, this Court should order an evidentiary hearing to investigate the misconduct detailed

above, as well as other misconduct that may yet come to light. Here, the defense has made a prima

facie showing that a hearing should be held, because it is clear “agents involved in this

investigation spoke to the press” about matters relating to or affecting the grand jury, and leaked

evidence. Skelos, 988 F.3d at 662. The agents here were specifically identified in press accounts

as HSI officers and “DHS operative[s],” and specifically as “Miami-based officer[s]” “who helped

raid [Mr. Combs’] Florida abode.” These officers disclosed specific information about the

investigation, including its target, the types of search warrants obtained and materials sought, what

witnesses had reported to prosecutors, and actual evidence, “reveal[ing] the nature or direction of

the grand jury proceedings.” In re Grand Jury Subpoena, 103 F.3d at 238.

Second, in advance of that hearing, this Court should order relevant discovery from the

government. This should include any emails and text messages by any government attorneys or

law enforcement agents regarding these and any other leaks of information about the investigation

or prosecution of this case.

Third, this Court should immediately enter an order forbidding government attorneys and

agents involved in the case from leaking any further information to the media. The order should

cover all grand jury material, as well as other non-public information related to the investigation

and prosecution of this case.

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Fourth, after the evidentiary hearing, and the extent and nature of the misconduct has been

clarified, Mr. Combs will submit requests for any additional appropriate remedies, including

disqualification of witnesses, suppression of evidence including the 2016 video, or dismissal of all

charges in the indictment.

Dated: October 9, 2024 Respectfully submitted,

AGNIFILO INTRATER LLP

/s/

Marc Agnifilo
Teny Geragos
445 Park Avenue, 7th Floor
New York, NY 10022
T: 646-205-4350
marc@agilawgroup.com
teny@agilawgroup.com
Counsel to Defendant Sean Combs

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