With six weeks to go until Sean “Diddy” Combs’ criminal trial for sex trafficking and more begins, the incarcerated Bad Boy Records founder now has one fewer lawsuit to deal with among the dozens he is fighting.
A federal judge today dismissed a rape case from a Jane Doe against Combs because the plaintiff did not file as required under her own name after a motion to proceed anonymously was denied earlier this month. Judge Lewis J. Liman — yes, the same judge who is overseeing the Blake Lively vs. Justin Baldoni case — gave Jane Doe until March 20 to make that filing or the matter of an alleged 1995 rape by Combs at a party for Biggie Smalls aka The Notorious B.I.G. would be closed.
On March 6, Judge Liman wrote “the very gravity of the charges, combined with the fact that Plaintiff has presented no evidence of specific and concrete harm from disclosure of her identity and the severe prejudice to Defendants from keeping that identity confidential, undermine her claim to proceed anonymously.”
March 20 came and went and there was no filing, so the judge made his move.
“As of today, March 31, 2025, Plaintiff has not filed a complaint in her own name, nor has she sought an extension of time to do so,” Judge Liman wrote Monday of the matter, first filed on October 14, 2024, and shut the whole thing down. It is extremely noteworthy that Liman’s decision had nothing to do with whether Jane Doe had a case or was telling the truth about what did or didn’t happen that June night 30 years ago at NYC’s Elks Plaza near the beginning of Combs’ big-time hip-hop career
Still, for the much-accused 55-year-old Combs, who is looking at life behind bars if found guilty in the racketeering, sex trafficking and transportation to engage in prostitution trial that starts May 12, the action was a welcomed reprieve.
“Today a federal judge dismissed a lawsuit filed against Mr. Combs by Texas attorney Anthony Buzbee and his local counsel Antigone Curis on behalf of an anonymized plaintiff,” a spokesperson for the performer told Deadline Monday. “This is now the second case brought by these attorneys against Mr. Combs that has been dismissed in its entirety. It will not be the last. For months, we have seen case after case filed by individuals hiding behind anonymity, pushed forward by attorneys more focused on media headlines than legal merit. The other claims, like the one dismissed today, also will not hold up in a court of law.”
For Tony Buzbee, who is representing literally dozens and dozens of plaintiffs against Combs, the events of today are more about the dangers of Diddy’s reach and influence than the merits of the case itself, he says.
“This was expected,” the often-brazen Houston-based attorney said after Liman’s ruling was made public. “In this particular case, Jane Doe opted not to proceed.
“There is a lot of fear amongst these plaintiffs,” he Buzbee added. “I thus can’t blame her. These are tough cases, and they are many times re-traumatizing for those who pursue them. Each case stands on its own merit. This woman chose not to proceed and subject herself to the media circus and the perceived danger she felt. We have to respect that.”
Denied admission on February 13 to cases in the District Court in the Eastern and Southern Districts of New York for apparently skirting the rules, Buzbee also has to respect that a number of the other Jane Doe and John Doe cases he is representing against Combs have judges that are requiring the plaintiff to reveal their true identifies. With deadlines for some of those matters coming up on April 4 and April 10, Buzbee has made moves to step away from many of the cases before the SDNY.
At the same time, with the February 14 self-dismissal by Jane Doe of her own case accusing Combs and Jay-Z of raping her after the 2000 MTV MVAs when she was 13 years old, Buzbee now finds himself battling the “99 Problems” superstar in California state court and federal court in Alabama. While Jay-Z (real name Shawn Carter) looks to have his extortion claim against Buzbee stripped from the L.A. Superior Court case, the defamation allegations can still go forward to trial, LASC Judge Mark H. Epstein decided on February 26.
From left: Sean “Diddy” Combs, Tony Buzbee and Jay-Z
Getty Images
Combs saw a flood of allegations and lawsuits hit him after long-term girlfriend Cassie Ventura in November accused the one-time mini-mogul of years of abuse and assault in a quickly ($30 million, I hear) settled suit. Some of those high-profile actions have now been trimmed down, like Diddy producer Lil Rod’s $30 million sexual assault and trafficking lawsuit against the Love Album performer. On March 24, Judge J. Paul Oetken stripped the RICO, breach of contract and infliction of emotional distress charges off the Lil Rod aka Rodney Jones Jr’s case against Combs. Still, for all the victory dances Combs’ team did over that decision, the fact is Oetken did permit Lil Rod’s sex-trafficking claims and some others to continue.
On parallel lines, Combs is facing claims of raping minors, among many others. In the most recent filing, he is accused of demanding fellatio from a John Doe photographer/production assistant about two years ago in exchange for a career jolt.
After raids by the feds on his Miami and LA homes last spring, Combs was arrested on September 16, 2024 on the criminal charges. Failing on multiple occasions to get out on a $50 million bail, the defendant has been sitting in the harsh Metropolitan Detention Center in NYC ever since.
Combs has denied all of the allegations against him.
