August 20, 2025 • 18 mins
Clayton Howard, a former male escort and frequent participant in Diddy’s private sex parties known as “freak-offs,” has filed a lawsuit accusing both Sean “Diddy” Combs and Cassie Ventura of sex trafficking, coercion, and abuse. According to his claims, he was recruited to perform sex acts under the guise of high-end parties, only to find himself drugged, manipulated, and transported across state lines for increasingly degrading and violent encounters. He alleges that Diddy exercised complete control over the events, orchestrating who did what and with whom, often while recording the acts without consent. Howard describes a world of intimidation, where refusal meant exile, and participation meant surrendering autonomy and dignity.
What makes his allegations even more explosive is his assertion that Cassie wasn’t just a victim of Diddy’s abuse—but an active participant in his exploitation. He accuses her of knowingly infecting him with an STD, coercing him into sexual acts, demanding he masturbate for hours while she filmed him, and ultimately pressuring him into an abortion. Howard paints a picture of Cassie as someone who embraced the power dynamic created by Diddy, allegedly using it to dominate and humiliate others in turn. His lawsuit portrays the entire environment as a sadistic, hierarchical structure of abuse where both Diddy and Cassie held power and used it to break down and control those beneath them.
to contact me:
bobbycapucci@protonmail.com
source:
Microsoft Word - Howard v Combs Ventura
What makes his allegations even more explosive is his assertion that Cassie wasn’t just a victim of Diddy’s abuse—but an active participant in his exploitation. He accuses her of knowingly infecting him with an STD, coercing him into sexual acts, demanding he masturbate for hours while she filmed him, and ultimately pressuring him into an abortion. Howard paints a picture of Cassie as someone who embraced the power dynamic created by Diddy, allegedly using it to dominate and humiliate others in turn. His lawsuit portrays the entire environment as a sadistic, hierarchical structure of abuse where both Diddy and Cassie held power and used it to break down and control those beneath them.
to contact me:
bobbycapucci@protonmail.com
source:
Microsoft Word - Howard v Combs Ventura
Mark as Played
Transcript
Episode Transcript
Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Speaker 1 (00:00):
What's up, everyone, and welcome to another episode of The
Diddy Diaries. In this episode, we're diving right back in
to that Clayton Howard lawsuit that was filed against Ditty
and Cassandra Ventura. Third cause of action Civil Remedy for
human trafficking California Code Section fifty two dot five Human
trafficking against all defendants. Plaintiff repeats and realleges each and
(00:24):
every allegation in all preceding paragraphs, as if fully set
forth here in at all times material here too. Plaintiff
was a victim of human trafficking as defined by California
Civil Code Section fifty two dot five A, having been
subjected to acts that constitute human trafficking under California Penal
Code section two thirty six dot one or two thirty
(00:45):
six dot two. Defendant engaged in human trafficking by depriving
or violating Plaintiff's personal liberty with the intent to obtain force, labor,
or services, depriving or violating Plaintiff's personal liberty with the
intent to effect or maintain a felony violation or specified
sexual offenses using force, fear, fraud, deceit, coercion, violence, duress,
(01:10):
menace or threat of unlawful injury to obtain labor or services,
and or causing, encouraging, or facilitating the commercial sexual exploitation
of plaintiff. Defendants trafficking conduct included, but was not limited to,
a transporting plaintiff across state lines for commercial sexual exploitation.
(01:30):
B Using promises of financial compensation and gifts to compel
compliance see making false promises of legitimate employment. D confiscating
identification documents in the wallet when items were withheld, Compelling
plaintiff to provide bodily fluids in separate containers for the
defendant's unknown enjoyment. Defendants used one or more of the
(01:54):
following means to accomplish the trafficking A force including physical
restraint or physical harm. B Fraud including false or deceptive
offers of employment, marriage, or other relationships. See coercion, including
threats of harm to a plaintiff for others, debt, bondage
or other means of control. D Violence or threats of violence. E.
(02:18):
Duress through unlawful pressure and or f Menace by the
way a threat, declaration or act showing an intention to
inflict an evil or injury as a direct and approximate
result of defendants human trafficking. Plaintiffs suffered actual damages, including
general damages for physical and mental pain and suffering, medical
(02:41):
and psychological treatment expenses, loss wages and diminished earning capacity,
cost of reasonable relocation expenses, reasonable attorney fees, and other
losses approximately caused by the trafficking. Defendant. Beverly Hills Hotel,
through its employees, had actual knowledge or acted with reckless
disregard towards sex trafficking activity occurring within the hotel premises.
(03:05):
The employee's conduct directly contributed to or enabled the trafficking
harm suffered by plaintiff. Defendant's conduct was despicable and subject
to contempt, warranting punitive damages to deter similar conduct. Plaintiff
seeks restitution for the value of labor or services provided
while being trafficked. Plaintiff is entitled to reasonable attorney fees
(03:29):
as a prevailing party pursuant to California Civil Code Section
fifty two dot five. Plaintiff seeks injunctive relief to prevent
defendants from engaging and further trafficking conduct. Fourth cause of
action Federal civil remedy for human trafficking US Code eighteen,
Section fifteen ninety five, Trafficking Victims Protection Act against all Defendants.
(03:52):
Plaintiff repeats and realleges every allegation in all of the
preceding paragraphs, as if fully set forth here in all
all times material here too. Defendant violated one or more
provisions of Chapter seventy seven of Title eighteen of the
United States Code P and H slavery and trafficking in persons, specifically,
(04:13):
including but not limited to, US Code eighteen, Section fifteen
eighty three, enticement into slavery, US Code eighteen, Section fifteen
eighty nine, force labor US Code eighteen, Section fifteen ninety
trafficking with respect to P and H slavery, involuntary servitude
or force labour. Defendants engaged in sex trafficking and violation
(04:35):
of US Code eighteen, Section fifteen ninety one by knowingly recruiting, enticing, harboring, transporting, providing,
obtaining advertising, maintaining, patronizing, or soliciting plaintiff for the purpose
of a commercial sex act, using means of force, threats
of force, fraud, or coercion to cause plaintiff to engage
(04:57):
in commercial sex acts, and or causing plaintiff to engage
in commercial sex acts when plaintiff was under the age
of eighteen. Defendant's conduct constituted a commercial sex act as
defined by US Code eighteen, section fifteen ninety one e one,
meaning any sex act on account of which anything of
value was given or received by any person. Defendants use
(05:21):
one or more of the following means prohibited by US
Code eighteen, section fifteen ninety one. Fraud scheme plan pattern
intended to cause plaintiff to believe that failure to perform
certain acts would result in serious harm or a physical restraint, coercion,
threats of serious harm to or physical restraint against plaintiff
(05:42):
or another person, or any scheme, plan or pattern intended
to cause plaintiff to believe that failure to perform an
act would result in serious harm due to physical restraint
against plaintiff or another person, end or alternatively or In addition,
defendants engaged forced labor in violation of US Code eighteen,
(06:03):
section fifteen eighty nine by knowingly providing or obtaining the
labor or services of plaintiff through one or more of
the prohibited means set forth above. Defendant's conduct involved interstate
or foreign commerce, including but not limited to, transportation of
plaintiff across date lines, use of interstate communication system, other
(06:24):
activities affecting interstate commerce. As a direct and proximate result
of defendants violations of federal trafficking laws, plaintiff is suffered damages,
including medical expenses and costs of physical and occupational therapy
or rehabilitation, mental health counseling and treatment expenses, lost income
(06:44):
and diminished earning capacity, pain and suffering, emotional distress and
mental anguish, loss of enjoyment of life, costs of relocation
and temporary housing, legal fees, and other litigation costs. This
is proximately caused by the sex trafficking defendant's conduct was wilful, wanton, malicious,
(07:06):
and oppressive, warranting an award of punitive damages. Plaintiff is
entitled to reasonable attorney fees pursuant to US Code eighteen
section fifteen ninety five A. This action is timely filed
within the ten year statute of limitation provided by eighteen
US Code section fifteen ninety five C, which runs from
(07:28):
the date on which the cause of action arose or
the date on which plaintiff reasonably discovered the cause of
action whichever is later. Fifth cause of action sexual assault
pursuant to the California Sexual Abuse and Cover Up Accountability
Act California Civil Procedure Section three forty dot sixteen. All
defendants plaintiff repeats and realleges each in every allegation in
(07:53):
all of the preceding paragraphs, as if fully set. Fourth
year in Defendant miss Ventura subjected plaintiff to sexual abuse,
sexual battery, and rape, forcing a sexual act upon him
during her menstrual cycle, as defined by California Penal Code
Section two thirty four, four two sixty one, and two
eighty nine. In knowingly committing this act, miss Ventura did
(08:16):
cause harmful and sexually offensive contact with her person and
placed mister Howard in apprehension of such contact. Defendant Colms
witnessed this encounter and attempted to cover up the matter,
offering the plaintiff additional monetary compensation for the actions of
miss Ventura. During the conversation, mister Combs confessed that miss
(08:37):
Ventura was aware of her monthly cycle, but was intoxicated
in horny. She had hoped that once she began I
would not mind. Miss Ventura acknowledged this eventually, but did
not apologize until the following morning, citing intoxication as an
excuse for her actions the night before. Defending corporations were
(08:58):
entities engaged in a cover up as defined in California
Civil Code Section three forty dot one sixty four A,
because defendant corporations financed the accommodations of the plaintiff and
took no efforts to protect the plaintiff from harm by
Miss Ventura, who was employed by the corporations. As a
direct result of the actions of the defendants on lawful,
(09:19):
drug fueled and sexual depraved conduct, as alleged here and above,
Plaintiff has suffered physical injury, severe emotional distress and anxiety, humiliation, embarrassment,
post traumatic stress disorder, economic harm, and other consequential damages.
Six cause of action civil liability for violations in New
(09:40):
York Penal Laws Section two thirty three four sex trafficking.
All defendants. Plaintiff repeats and realleges each and every allegation
in all of the preceding paragraphs as a fully set
fourth year in plaintiff brings a civil action for damages
pursuing to the civil remedies available under New York law
(10:00):
for victims of criminal conduct seeking compensation for injuries suffered
as a direct result of defendants violations at all times
relevant here too. Plaintiff was an adult resident of New
York City, New York, beginning around June twenty twelve and
lasting until twenty nineteen, with the last occurrence being December
twenty nineteen. Defendants engaged in sex trafficking and violation of
(10:25):
New York Penal Laws Section two thirty three four by
intentionally advancing or profiting from prostitution by a managing, supervising
and controlling acts of prostitution for an enterprise involving the
prostitution activity of plaintiff, and or b compelling a person
by force or intimidation to engage in prostitution, and or
(10:46):
knowingly advancing or profiting from prostitution. Defendant sex trafficking activities included,
but were not limited to, managing, supervising, controlling prostitution, organizing
and directing plaintiff's commercial sexual activities, maintaining operational control over
the prostitution enterprise, transportation and movement transporting plaintiff from New
(11:10):
York City, New York to Miami, Florida for the purpose
of commercial sexual exploitation, arranging housing and logistics to facilitate
continued prostitution activity, maintaining control over Plaintiff's movements and location.
Force and intimidation employed by defendant included a psychological coercion.
(11:30):
Mister Howard would be isolated inside located hotel suites where
his clothing and communication devices were withheld by defendants. He
was constantly on alert due to the violent outburst and
drug fuel moots. Wings of defendants. Economic control. Money was
used as a tool to course mister Howard to the
will of the defendants. Once under their control, mister Howard
(11:52):
was pressured and or coerced into compliance. Substance abuse facilitation
designer drugs were used by the defender and to lower
the natural resistance of mister Howard. The drugs were further
used to keep mister Howard awake and in the service
of the defendants. Through these acts of force and intimidation,
defending compelled plaintiff to engage in prostitution against Plaintiff's will.
(12:15):
Interstate nature in continuing course of conduct. Defendants trafficking scheme
involved interstate transportation of plaintiff from New York to Florida,
demonstrating the scope and sophistication of the trafficking operation. The
trafficking constituted a continuing course a criminal conduct that began
in New York and continued in Florida, with defendant maintaining
(12:36):
control and profiting throughout proximate cause in damages. As a
direct and approximate result of defendant's violation in New York
penal law, plaintiff suffered severe and continuing damages, including physical injury,
physical trauma, medical expenses for treatment of injuries, ongoing medical care,
psychological harm, severe emotional distress in psychological trauma, post traumatic
(13:01):
stress disorder, depression, anxiety, and other mental health conditions, cost
of psychological treatment and therapy, economic damages, diminished earning capacity,
loss of educational and career opportunity, other consequential damage, pain
and suffering, loss of enjoyment of life. The plaintiff's damages
are ongoing and continue to accrue as a result of
(13:24):
the lasting after effects of defendant Shahn Colm's criminal trial.
After being exposed through the allegations of his Ventura and
an investigation by US Attorney Mister Howard, name has been
connected to the criminality of the defendants prayer for relief.
Seventh cause of action violation in New York State Human
Rights Law the Executive Law section two ninety against all defendants.
(13:49):
Plaintiff repeats and re alleges each and every allegation contained
in preceding paragraphs, as if fully set forth here in,
At all times relevant here too, Defendant was an employer
with the means of New York Executive Law Section two
ninety two five, employing four or more persons. At all
times relevant here too, Plaintiff was an employee within the
(14:10):
meaning of New York Executive law. The New York State
Human Rights Law prohibits employers from discriminating against employees on
the basis of race and domestic violence victim status. Defendant's
discriminatory conduct was intentional, willful, wanton, and malicious. As a
direct and proximate result of defendants on lawful discrimination, Plaintiff
(14:31):
is suffered and continues to suffer damages, including but not
limited to, emotional distress, humiliation, and mental anguish, other economic
and non economic damages. Defendant's conduct was egregious and undertaken
with malice, reckless indifference, or a callous disregard for Plaintiff's rights.
Warranting an award of punitive damages. Eighth cause of action
(14:54):
New York Services for Victims of Human Trafficking against all
defendants TNI differ repeats and realleges each and every allegation
contained in the preceding paragraphs as a fully set fourth
year in at all times relevant here too, New York
Services Law Section four eighty three BB was in full
force and effect. New York Services Law for eighty three
(15:16):
BB creates a private right of action for victims of
human trafficking and provides that any person who is a
victim of conduct that would constitute a violation of the
Human Trafficking Laws may bring a civil action in any
court of competent jurisdiction. The statute defines human trafficking to
include labour trafficking, which encompasses the recruitment, harboring, transportation, provision,
(15:39):
or obtaining of a person for laborer services throughout the
use of force, fraud, or coercion for the purpose of
subjection to involuntary servitude, p andage, debt, bondage, or slavery. Defendant,
through his agents, servants and employees engaged in conduct constituting
human trafficking by coercing and orchestrating the transportation of plaintiff
(16:00):
across state line for the purpose of commercial sex act,
using force, fraud, or coercion to compel plaintiff to provide
labor or services, harboring and or maintaining plaintiff in a
condition of forced labor, obtaining labor or services from plaintiff
through threats, physical restraint, or abuse of legal process. Defendant's
conduct was undertaken knowingly and with the intent to subject
(16:22):
plaintiff to involuntary servitude, force labor, or other forms of
human trafficking. As a direct and approximate result of defendants
trafficking conduct, Plaintiff has suffered and continues to suffer years
of damages, including but not limited to, physical and psychological injury,
lost wages and benefits, medical expenses, pain and suffering, emotional
distress and mental anguish, loss of enjoyment of life, other
(16:46):
economic and non economic damages. Defendant's conduct was egregious, intentional,
and undertaken with malice or reckless disregard for Plaintiff's rights
and well being. Plaintiff is entitled to recover damages, including
punitive damages, reasonable attorney fees and cost pursuant NYS Service
Law Section forty three b B. Plaintiff's claims under this
(17:08):
statute are not subject to any statute of limitation that
would otherwise apply prayer for relief. Wherefore, Plaintiff respectfully demands
judgment against defendant as follows, a compensatory damage and an
amount to be proven at trial, including but not limited to,
past in future medical expenses, past and future lost earnings
in diminished earning capacity, pain and suffering, emotional distress, punitive
(17:33):
damages to punish defendants egregious criminal conduct and deter similar
future conduct, pre impost judgment interest as provided by law,
costs and reasonable attorney fees, punitive damages pursuant to Florida
Statute section seven sixty eight seventy two, seven sixty eight
seven twenty five, and seven sixty eight seventy three, such
(17:55):
other and further relief as this Court deems just and proper.
This was signed by Clayton Howard pro Sae, and it
was dated June twenty ninth, twenty twenty five. All of
the information that goes with this episode can be found
in the description box
What's up, everyone, and welcome to another episode of The
Diddy Diaries. In this episode, we're diving right back in
to that Clayton Howard lawsuit that was filed against Ditty
and Cassandra Ventura. Third cause of action Civil Remedy for
human trafficking California Code Section fifty two dot five Human
trafficking against all defendants. Plaintiff repeats and realleges each and
(00:24):
every allegation in all preceding paragraphs, as if fully set
forth here in at all times material here too. Plaintiff
was a victim of human trafficking as defined by California
Civil Code Section fifty two dot five A, having been
subjected to acts that constitute human trafficking under California Penal
Code section two thirty six dot one or two thirty
(00:45):
six dot two. Defendant engaged in human trafficking by depriving
or violating Plaintiff's personal liberty with the intent to obtain force, labor,
or services, depriving or violating Plaintiff's personal liberty with the
intent to effect or maintain a felony violation or specified
sexual offenses using force, fear, fraud, deceit, coercion, violence, duress,
(01:10):
menace or threat of unlawful injury to obtain labor or services,
and or causing, encouraging, or facilitating the commercial sexual exploitation
of plaintiff. Defendants trafficking conduct included, but was not limited to,
a transporting plaintiff across state lines for commercial sexual exploitation.
(01:30):
B Using promises of financial compensation and gifts to compel
compliance see making false promises of legitimate employment. D confiscating
identification documents in the wallet when items were withheld, Compelling
plaintiff to provide bodily fluids in separate containers for the
defendant's unknown enjoyment. Defendants used one or more of the
(01:54):
following means to accomplish the trafficking A force including physical
restraint or physical harm. B Fraud including false or deceptive
offers of employment, marriage, or other relationships. See coercion, including
threats of harm to a plaintiff for others, debt, bondage
or other means of control. D Violence or threats of violence. E.
(02:18):
Duress through unlawful pressure and or f Menace by the
way a threat, declaration or act showing an intention to
inflict an evil or injury as a direct and approximate
result of defendants human trafficking. Plaintiffs suffered actual damages, including
general damages for physical and mental pain and suffering, medical
(02:41):
and psychological treatment expenses, loss wages and diminished earning capacity,
cost of reasonable relocation expenses, reasonable attorney fees, and other
losses approximately caused by the trafficking. Defendant. Beverly Hills Hotel,
through its employees, had actual knowledge or acted with reckless
disregard towards sex trafficking activity occurring within the hotel premises.
(03:05):
The employee's conduct directly contributed to or enabled the trafficking
harm suffered by plaintiff. Defendant's conduct was despicable and subject
to contempt, warranting punitive damages to deter similar conduct. Plaintiff
seeks restitution for the value of labor or services provided
while being trafficked. Plaintiff is entitled to reasonable attorney fees
(03:29):
as a prevailing party pursuant to California Civil Code Section
fifty two dot five. Plaintiff seeks injunctive relief to prevent
defendants from engaging and further trafficking conduct. Fourth cause of
action Federal civil remedy for human trafficking US Code eighteen,
Section fifteen ninety five, Trafficking Victims Protection Act against all Defendants.
(03:52):
Plaintiff repeats and realleges every allegation in all of the
preceding paragraphs, as if fully set forth here in all
all times material here too. Defendant violated one or more
provisions of Chapter seventy seven of Title eighteen of the
United States Code P and H slavery and trafficking in persons, specifically,
(04:13):
including but not limited to, US Code eighteen, Section fifteen
eighty three, enticement into slavery, US Code eighteen, Section fifteen
eighty nine, force labor US Code eighteen, Section fifteen ninety
trafficking with respect to P and H slavery, involuntary servitude
or force labour. Defendants engaged in sex trafficking and violation
(04:35):
of US Code eighteen, Section fifteen ninety one by knowingly recruiting, enticing, harboring, transporting, providing,
obtaining advertising, maintaining, patronizing, or soliciting plaintiff for the purpose
of a commercial sex act, using means of force, threats
of force, fraud, or coercion to cause plaintiff to engage
(04:57):
in commercial sex acts, and or causing plaintiff to engage
in commercial sex acts when plaintiff was under the age
of eighteen. Defendant's conduct constituted a commercial sex act as
defined by US Code eighteen, section fifteen ninety one e one,
meaning any sex act on account of which anything of
value was given or received by any person. Defendants use
(05:21):
one or more of the following means prohibited by US
Code eighteen, section fifteen ninety one. Fraud scheme plan pattern
intended to cause plaintiff to believe that failure to perform
certain acts would result in serious harm or a physical restraint, coercion,
threats of serious harm to or physical restraint against plaintiff
(05:42):
or another person, or any scheme, plan or pattern intended
to cause plaintiff to believe that failure to perform an
act would result in serious harm due to physical restraint
against plaintiff or another person, end or alternatively or In addition,
defendants engaged forced labor in violation of US Code eighteen,
(06:03):
section fifteen eighty nine by knowingly providing or obtaining the
labor or services of plaintiff through one or more of
the prohibited means set forth above. Defendant's conduct involved interstate
or foreign commerce, including but not limited to, transportation of
plaintiff across date lines, use of interstate communication system, other
(06:24):
activities affecting interstate commerce. As a direct and proximate result
of defendants violations of federal trafficking laws, plaintiff is suffered damages,
including medical expenses and costs of physical and occupational therapy
or rehabilitation, mental health counseling and treatment expenses, lost income
(06:44):
and diminished earning capacity, pain and suffering, emotional distress and
mental anguish, loss of enjoyment of life, costs of relocation
and temporary housing, legal fees, and other litigation costs. This
is proximately caused by the sex trafficking defendant's conduct was wilful, wanton, malicious,
(07:06):
and oppressive, warranting an award of punitive damages. Plaintiff is
entitled to reasonable attorney fees pursuant to US Code eighteen
section fifteen ninety five A. This action is timely filed
within the ten year statute of limitation provided by eighteen
US Code section fifteen ninety five C, which runs from
(07:28):
the date on which the cause of action arose or
the date on which plaintiff reasonably discovered the cause of
action whichever is later. Fifth cause of action sexual assault
pursuant to the California Sexual Abuse and Cover Up Accountability
Act California Civil Procedure Section three forty dot sixteen. All
defendants plaintiff repeats and realleges each in every allegation in
(07:53):
all of the preceding paragraphs, as if fully set. Fourth
year in Defendant miss Ventura subjected plaintiff to sexual abuse,
sexual battery, and rape, forcing a sexual act upon him
during her menstrual cycle, as defined by California Penal Code
Section two thirty four, four two sixty one, and two
eighty nine. In knowingly committing this act, miss Ventura did
(08:16):
cause harmful and sexually offensive contact with her person and
placed mister Howard in apprehension of such contact. Defendant Colms
witnessed this encounter and attempted to cover up the matter,
offering the plaintiff additional monetary compensation for the actions of
miss Ventura. During the conversation, mister Combs confessed that miss
(08:37):
Ventura was aware of her monthly cycle, but was intoxicated
in horny. She had hoped that once she began I
would not mind. Miss Ventura acknowledged this eventually, but did
not apologize until the following morning, citing intoxication as an
excuse for her actions the night before. Defending corporations were
(08:58):
entities engaged in a cover up as defined in California
Civil Code Section three forty dot one sixty four A,
because defendant corporations financed the accommodations of the plaintiff and
took no efforts to protect the plaintiff from harm by
Miss Ventura, who was employed by the corporations. As a
direct result of the actions of the defendants on lawful,
(09:19):
drug fueled and sexual depraved conduct, as alleged here and above,
Plaintiff has suffered physical injury, severe emotional distress and anxiety, humiliation, embarrassment,
post traumatic stress disorder, economic harm, and other consequential damages.
Six cause of action civil liability for violations in New
(09:40):
York Penal Laws Section two thirty three four sex trafficking.
All defendants. Plaintiff repeats and realleges each and every allegation
in all of the preceding paragraphs as a fully set
fourth year in plaintiff brings a civil action for damages
pursuing to the civil remedies available under New York law
(10:00):
for victims of criminal conduct seeking compensation for injuries suffered
as a direct result of defendants violations at all times
relevant here too. Plaintiff was an adult resident of New
York City, New York, beginning around June twenty twelve and
lasting until twenty nineteen, with the last occurrence being December
twenty nineteen. Defendants engaged in sex trafficking and violation of
(10:25):
New York Penal Laws Section two thirty three four by
intentionally advancing or profiting from prostitution by a managing, supervising
and controlling acts of prostitution for an enterprise involving the
prostitution activity of plaintiff, and or b compelling a person
by force or intimidation to engage in prostitution, and or
(10:46):
knowingly advancing or profiting from prostitution. Defendant sex trafficking activities included,
but were not limited to, managing, supervising, controlling prostitution, organizing
and directing plaintiff's commercial sexual activities, maintaining operational control over
the prostitution enterprise, transportation and movement transporting plaintiff from New
(11:10):
York City, New York to Miami, Florida for the purpose
of commercial sexual exploitation, arranging housing and logistics to facilitate
continued prostitution activity, maintaining control over Plaintiff's movements and location.
Force and intimidation employed by defendant included a psychological coercion.
(11:30):
Mister Howard would be isolated inside located hotel suites where
his clothing and communication devices were withheld by defendants. He
was constantly on alert due to the violent outburst and
drug fuel moots. Wings of defendants. Economic control. Money was
used as a tool to course mister Howard to the
will of the defendants. Once under their control, mister Howard
(11:52):
was pressured and or coerced into compliance. Substance abuse facilitation
designer drugs were used by the defender and to lower
the natural resistance of mister Howard. The drugs were further
used to keep mister Howard awake and in the service
of the defendants. Through these acts of force and intimidation,
defending compelled plaintiff to engage in prostitution against Plaintiff's will.
(12:15):
Interstate nature in continuing course of conduct. Defendants trafficking scheme
involved interstate transportation of plaintiff from New York to Florida,
demonstrating the scope and sophistication of the trafficking operation. The
trafficking constituted a continuing course a criminal conduct that began
in New York and continued in Florida, with defendant maintaining
(12:36):
control and profiting throughout proximate cause in damages. As a
direct and approximate result of defendant's violation in New York
penal law, plaintiff suffered severe and continuing damages, including physical injury,
physical trauma, medical expenses for treatment of injuries, ongoing medical care,
psychological harm, severe emotional distress in psychological trauma, post traumatic
(13:01):
stress disorder, depression, anxiety, and other mental health conditions, cost
of psychological treatment and therapy, economic damages, diminished earning capacity,
loss of educational and career opportunity, other consequential damage, pain
and suffering, loss of enjoyment of life. The plaintiff's damages
are ongoing and continue to accrue as a result of
(13:24):
the lasting after effects of defendant Shahn Colm's criminal trial.
After being exposed through the allegations of his Ventura and
an investigation by US Attorney Mister Howard, name has been
connected to the criminality of the defendants prayer for relief.
Seventh cause of action violation in New York State Human
Rights Law the Executive Law section two ninety against all defendants.
(13:49):
Plaintiff repeats and re alleges each and every allegation contained
in preceding paragraphs, as if fully set forth here in,
At all times relevant here too, Defendant was an employer
with the means of New York Executive Law Section two
ninety two five, employing four or more persons. At all
times relevant here too, Plaintiff was an employee within the
(14:10):
meaning of New York Executive law. The New York State
Human Rights Law prohibits employers from discriminating against employees on
the basis of race and domestic violence victim status. Defendant's
discriminatory conduct was intentional, willful, wanton, and malicious. As a
direct and proximate result of defendants on lawful discrimination, Plaintiff
(14:31):
is suffered and continues to suffer damages, including but not
limited to, emotional distress, humiliation, and mental anguish, other economic
and non economic damages. Defendant's conduct was egregious and undertaken
with malice, reckless indifference, or a callous disregard for Plaintiff's rights.
Warranting an award of punitive damages. Eighth cause of action
(14:54):
New York Services for Victims of Human Trafficking against all
defendants TNI differ repeats and realleges each and every allegation
contained in the preceding paragraphs as a fully set fourth
year in at all times relevant here too, New York
Services Law Section four eighty three BB was in full
force and effect. New York Services Law for eighty three
(15:16):
BB creates a private right of action for victims of
human trafficking and provides that any person who is a
victim of conduct that would constitute a violation of the
Human Trafficking Laws may bring a civil action in any
court of competent jurisdiction. The statute defines human trafficking to
include labour trafficking, which encompasses the recruitment, harboring, transportation, provision,
(15:39):
or obtaining of a person for laborer services throughout the
use of force, fraud, or coercion for the purpose of
subjection to involuntary servitude, p andage, debt, bondage, or slavery. Defendant,
through his agents, servants and employees engaged in conduct constituting
human trafficking by coercing and orchestrating the transportation of plaintiff
(16:00):
across state line for the purpose of commercial sex act,
using force, fraud, or coercion to compel plaintiff to provide
labor or services, harboring and or maintaining plaintiff in a
condition of forced labor, obtaining labor or services from plaintiff
through threats, physical restraint, or abuse of legal process. Defendant's
conduct was undertaken knowingly and with the intent to subject
(16:22):
plaintiff to involuntary servitude, force labor, or other forms of
human trafficking. As a direct and approximate result of defendants
trafficking conduct, Plaintiff has suffered and continues to suffer years
of damages, including but not limited to, physical and psychological injury,
lost wages and benefits, medical expenses, pain and suffering, emotional
distress and mental anguish, loss of enjoyment of life, other
(16:46):
economic and non economic damages. Defendant's conduct was egregious, intentional,
and undertaken with malice or reckless disregard for Plaintiff's rights
and well being. Plaintiff is entitled to recover damages, including
punitive damages, reasonable attorney fees and cost pursuant NYS Service
Law Section forty three b B. Plaintiff's claims under this
(17:08):
statute are not subject to any statute of limitation that
would otherwise apply prayer for relief. Wherefore, Plaintiff respectfully demands
judgment against defendant as follows, a compensatory damage and an
amount to be proven at trial, including but not limited to,
past in future medical expenses, past and future lost earnings
in diminished earning capacity, pain and suffering, emotional distress, punitive
(17:33):
damages to punish defendants egregious criminal conduct and deter similar
future conduct, pre impost judgment interest as provided by law,
costs and reasonable attorney fees, punitive damages pursuant to Florida
Statute section seven sixty eight seventy two, seven sixty eight
seven twenty five, and seven sixty eight seventy three, such
(17:55):
other and further relief as this Court deems just and proper.
This was signed by Clayton Howard pro Sae, and it
was dated June twenty ninth, twenty twenty five. All of
the information that goes with this episode can be found
in the description box
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