22. From September 2022 to November 2023, Mr. Jones produced nine songs on Mr. Combs' Love album.
23. Mr. Jones lived with Mr. Combs for months at a time, spending holidays, birthdays, and missing major family events.
24. Mr. Jones resided at Mr. Combs residence located in Los Angeles, California, New York City, and Miami, Florida. Mr. Jones also spent several weeks on a yacht rented by Mr. Combs in the US Virgin Islands.
25. Throughout his time with Mr. Combs, Mr. Jones witnessed, experienced, and endured many things that went far beyond his role as a Producer on the Love album.
26. The claims raised in this complaint have been corroborated through witness statements, video/audio recordings, and images that Mr. Jones has in his possession.
27. Mr. Combs required Mr. Jones to record him constantly. On several occasions, Mr. Combs took Mr. Jones cellphone and began recording himself. As a result, Mr. Jones has secured HUNDREDS of hours of footage and audio recordings of Mr. Combs, his staff, and his guests engaging in serious illegal activity.
28. Mr. Jones has secured irrefutable evidence of: a. The acquisition, use, and distribution of ecstasy, cocaine, GHB, ketamine, marijuana, and mushrooms,

b. The displaying and distribution of unregistered illegal firearms, Case 1:24-cv-01457 Document 1 Filed 02/26/24 Page 7 of 73 8

c. Mr. Combs providing laced alcoholic beverages to minors and sex workers at his homes in California, New York, the U. S. Virgin Islands1, and Florida,

d. Mr. Combs Chief of Staff, Kristina Khorram (“KK”) instructing her staff to retrieve drugs so she can provide it to Mr. Combs for his consumption,

e. Christian Combs drugging and sexually assaulting a woman2 ,

f. Mr. Combs detailing how he planned to leverage his relationship with Bishop T.D. Jakes to soften the impact on his public image of Cassie Ventura’s lawsuit,

g. Yung Miami’s cousin, and or assistant sexually assaulting Mr. Jones,

h. Actor Cuba Gooding Jr. sexually harassing and assaulting Mr. Jones,

i. Rapper3 (REDACTED) on Mr. Combs yacht consorting with underaged girls, sex workers, and

j. R&B Singer4 (REDACTED) in Mr. Combs Los Angeles home consorting with underaged girls and sex workers