Sean Combs formally responds to the indictment against him, asserting that the evidence presented lacks context and credibility, and claims he has been unfairly targeted due to his fame. The defense will challenge the prosecution's evidence, the credibility of witnesses, and the legality of evidence collection, and highlight mitigating circumstances along with Combs' philanthropy. Although Combs intends to fight the charges, he is open to negotiating a plea deal to settle the matter if beneficial terms can be reached.

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA.,
Plaintiff,
vs.
SEAN COMBS, a/k/a "Puff Daddy," a/k/a "P. Diddy,"
a/k/a "Diddy," a/k/a "PD," a/k/a "Love”,
Defendant
Case No.: DEFENDANT’S RESPONSE TO THE
INDICTMENT
DEFENDANT’S RESPONSE TO THE INDICTMENT
I. Introduction
Sean Combs, through his legal counsel, respectfully submits this formal response to the indictment filed against him.
While the government may claim to possess evidence supporting the charges, the defense intends to demonstrate
that the evidence presented lacks context, credibility, and proper legal grounding. The defendant maintains that he
has been unfairly targeted due to his high-profile status, and the evidence used against him is either misleading or
insufficient to support the most serious allegations.
II. Argument
1. Challenging the Context and Presentation of Evidence
The government may have evidence, but that evidence must be interpreted with careful scrutiny. For instance, video
footage or witness statements about alleged abusive events must be examined in their entirety. The defense will
demonstrate that any actions depicted in such evidence are either mischaracterized, taken out of context, or do not
rise to the level of criminal conduct. In several cases, physical altercations or forceful actions were taken in self-
defense or as responses to threats against Mr. Combs’ safety and well-being.

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Additionally, recordings or communications cited as evidence of coercion, bribery, or intimidation will be shown
as part of broader discussions, often involving mutual agreements, negotiations, or legal business practices that the
prosecution has misinterpreted.
2. Credibility of Witnesses
Much of the prosecution’s case relies on witness testimony. The defense will question the credibility of these
witnesses. Many are individuals who had prior relationships with Mr. Combs and stand to benefit financially from
portraying themselves as victims. Several of these individuals have a history of personal conflicts or lawsuits
involving Mr. Combs, casting doubt on the objectivity and truthfulness of their allegations.
Witnesses who claim coercion or abuse must be cross-examined to explore possible inconsistencies in their stories,
prior motivations to lie, and whether they have been influenced by external factors, including media attention or
promises of financial settlements.
3. Challenge the Legality of Evidence (Chain of Custody, Admissibility Issues)
The defense will examine whether the government followed all legal procedures in obtaining and handling the
evidence. If the prosecution’s case involves digital communications, video, or audio recordings, the defense will
challenge the chain of custody, arguing that any tampering or misinterpretation could have occurred. In some cases,
these recordings may have been obtained in violation of privacy laws or without the proper legal warrants, rendering
them inadmissible.
4. Mitigating Circumstances (Context for the "Freak Offs" and Other Alleged Events)
With regard to the sexual activity allegations, the defense will argue that all involved individuals were consenting
adults and that the nature of the interactions was mutually agreed upon. The "Freak Offs" described in the
indictment, while sensationalized, were private, consensual events among adults who willingly participated.

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The defense will also show that the government has exaggerated the control and influence Mr. Combs had over
participants, especially regarding drug use and threats of violence. Any drug use or gifts provided were social in
nature and were not used to coerce or manipulate.
5. Rehabilitation and Philanthropic History of Sean Combs
As part of a defense strategy to mitigate sentencing or reduce the severity of charges, the defense will highlight
Mr. Combs’ long history of philanthropy, community work, and positive influence in the music and entertainment
industry. These efforts are evidence of Mr. Combs’ strong moral character and should be considered as mitigating
factors in the context of the accusations.
6. Legal Defenses Specific to the Charges
- Racketeering Conspiracy: While the government may argue that Mr. Combs led a "criminal enterprise," the
defense will argue that his businesses are legitimate, law-abiding companies that have been mischaracterized due to
the actions of a few rogue employees. Any criminal activity was incidental and not part of any organized scheme.
- Sex Trafficking and Forced Labor: The defense will emphasize that none of the participants were coerced into
sexual activity through force, fraud, or coercion, which is required to meet the legal definition of sex trafficking
under Title 18 U.S.C. § 1591. Consent, even under unusual circumstances, does not amount to trafficking.
- Bribery and Intimidation: Any payments made to individuals or witnesses were part of legitimate business
settlements or personal gifts and do not rise to the level of bribery or intimidation to silence witnesses or obstruct
justice.
7. Negotiation of Charges (Plea Deal Considerations)

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While Mr. Combs intends to fight these charges in court, he is open to resolving this matter through appropriate
legal channels if a mutually beneficial agreement can be reached. Should the prosecution agree to reduce certain
charges, Mr. Combs is willing to negotiate a plea deal that would avoid a protracted trial and minimize the negative
impact on all parties involved.
This agreement would involve an acknowledgment of lesser offenses, such as potential financial mismanagement
or failure to adhere to certain business regulations, but deny any allegations of violence, coercion, or trafficking.
III. Conclusion
The government’s case, while perhaps supported by some evidence, remains speculative and built upon
sensationalized and mischaracterized incidents. The defense intends to demonstrate that any actions taken by Mr.
Combs were lawful or, at most, part of consensual adult interactions.
We urge the Court to carefully scrutinize the government's evidence, to consider the context in which this evidence
was gathered, and to recognize the lack of a true criminal enterprise or intent behind Mr. Combs' actions.
The defense respectfully requests that this case proceed with caution, ensuring that the rights of Mr. Combs are
upheld, and that justice, rather than public spectacle, remains the central concern of these proceedings.
Respectfully Submitted,
/s/ Attorney for Defendant Sean Combs