Sean “Diddy” Combs saw another legal complaint against him tossed out on Monday (March 31) in federal court after a woman using the alias “Jane Doe” failed to meet a court-ordered deadline to reveal her real name in a civil lawsuit tied to an alleged decades-old incident.
U.S. District Judge Lewis J. Liman dismissed the case on March 31 after the plaintiff missed the March 20 deadline to refile her complaint under her legal name.
The court had previously denied her request to proceed anonymously and she did not ask for an extension. With no amended complaint submitted, the judge closed the case and terminated all pending motions.
“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 Combs said in a statement. “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.”
The dismissal adds to a growing list of legal setbacks for Buzbee and Curis, who have filed multiple lawsuits against Combs in the Southern District of New York.
On March 28, Judge Mary Kay Vyskocil issued an Order to Show Cause against Curis in a separate case, questioning why she should not face sanctions for submitting conflicting documents related to Buzbee’s denied pro hac vice admission.
Curis had filed an affidavit claiming Buzbee had never been denied admission to any court. However, she also submitted an order showing his application had been rejected by the Southern District of New York.
Meanwhile, Combs’ legal team has pushed back hard against Buzbee’s involvement in these cases.
In a February 26 filing, they accused him of “egregious misconduct,” including practicing law without authorization in 22 cases in the district, failing to disclose his lack of admission and making public comments suggesting Combs’ guilt in unrelated criminal matters.
“In our collective decades of practice, undersigned counsel have never opposed a pro hac vice application, and we do not do so lightly here,” the filing stated. “But Buzbee’s egregious misconduct warrants denial of the privilege of appearing in this District.”
Additional rulings in related cases have also raised questions about the credibility of filings submitted by Buzbee and Curis.
On March 27, Judge Jennifer L. Rochon rejected anonymity requests in two separate lawsuits involving alleged incidents from 1991 and 1998.
In her written opinion, she noted that Buzbee’s declarations were “substantively identical to declarations filed on the same day in other Doe v. Combs cases in this District involving different plaintiffs and facts.”
Judge John P. Cronan issued a similar directive in another case filed by Buzbee on behalf of a male plaintiff who alleged an incident occurred in 2022.
That plaintiff was also ordered to refile under his real name by April 4, 2025.
The next major development in these related cases is expected on April 14, when Judge Vyskocil will hold the sanctions hearing for Curis.
This is the second legal victory for Diddy in the past two weeks, coming on the heels of a federal judge’s grueling that significantly pared down Rodney “Lil Rod” Jones’ blockbuster lawsuit against Diddy.
The lawsuit originally stemmed from Jones’ work on Diddy’s The Love Album: Off the Grid.
In that ruling, the judge dismissed the civil RICO claim along with allegations of breach of contract and both intentional and negligent infliction of emotional distress.
Diddy’s legal team argued the case was simply a “garden variety breach of contract” dressed up as a federal racketeering suit, and the court agreed, tossing out some of the lawsuit’s most serious accusations.
While five major claims were dropped, 14 other causes of action still remain.