Jane Doe declaration

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -1- SMRH:4933-6230-7616.1 DECLARATION OF JANE DOE SHEPPARD, MULLIN, RICHTER & HAMPTON LLP A Limited Liability Partnership Including Professional Corporations CAMILLE M. VASQUEZ, Cal Bar No. 273377 CVasquez@sheppardmullin.com SAMUEL A. MONIZ, Cal Bar No. 313274 SMoniz@sheppardmullin.com J. RANDALL BOYER, Cal Bar No. 290003 JBoyer@sheppardmullin.com MELISSA M. MIKAIL, Cal Bar No. 323212 MMikail@sheppardmullin.com 650 Town Center Drive, 10th Floor Costa Mesa, California 92626-1993 Telephone: 714.513.5100 Facsimile: 714.513.5130 Attorneys for Defendants, THE BUZBEE LAW FIRM and ANTHONY G. BUZBEE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES, SANTA MONICA COURTHOUSE SHAWN CARTER, Plaintiff, v. THE BUZBEE LAW FIRM, ANTHONY G. BUZBEE, Defendants. Case No. 24SMCV05637 Assigned for All Purposes to: Hon. Mark H. Epstein, Department I DECLARATION OF JANE DOE IN RESPONSE TO SHAWN CARTER’S PROFFER OF NEW EVIDENCE AT HEARING ON DEFENDANTS’ SPECIAL MOTION TO STRIKE PORTIONS OF PLAINTIFF’S FIRST AMENDED COMPLAINT 


         1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2- SMRH:4933-6230-7616.1 DECLARATION OF JANE DOE DECLARATION OF JANE DOE I, Jane Doe, declare as follows: 1. I am over the age of eighteen and I am the individual referred to as “Jane Doe” in the action Jane Doe v. Sean Combs, et al., Case No. 1:24-cv-07975-AT (S.D.N.Y.) (the “New York Action”). I am also the individual identified as “Jane Doe” in a letter (“Demand Letter”) sent by Defendant The Buzbee Law Firm to Shawn Carter (“Carter” or “Jay-Z”) in or about November of 2024. I was granted permission to proceed under a pseudonym in the New York Action, and make this Declaration under a pseudonym for the same reasons as in the New York Action. 2. I have personal knowledge of the facts set forth herein, which are known by me to be true and correct, and if called as a witness, I could and would competently testify thereto. 3. This declaration is submitted in support of the Defendants The Buzbee Law Firm and Anthony G. Buzbee’s (“Mr. Buzbee”) Motion To Strike Under Code of Civil Procedure Section 425.16 (“Motion”). 4. On Friday, February 21, 2025, I was approached at my home by two individuals, a woman and a large man. They cornered me on my front porch and told me that they are investigators working with an attorney on behalf of Jay-Z. They asked me if I would be willing to sign an affidavit stating that my claims in the New York Action were false. I refused. They also asked me if Mr. Buzbee sought me out as a client, and whether Mr. Buzbee offered to pay me to pursue a false claim against Jay-Z. I told them that neither of those things ever happened, and I asked them to leave me alone. I felt intimidated and terrified at being confronted by these two individuals on my doorstep, and that they knew my name and home address despite me being anonymous in the New York Action. 5. I also understand that investigators approached my father and my mother multiple times. Two investigators approached my father and mother as my father was picking my mother up from a medical appointment, asking them similar questions about whether Mr. Buzbee had paid me, and requesting that they sign affidavits stating that my claims were false. My father was separately approached later at a gas station, and my mother was separately approached at a store. 


         1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -3- SMRH:4933-6230-7616.1 DECLARATION OF JANE DOE In all instances my parents refused to sign any affidavits, denied the investigators’ claims about my case and Mr. Buzbee’s conduct, and asked to be left alone. 6. It is very alarming to me that Jay-Z’s agents are looking for me and now know my whereabouts. Fear of intimidation and retaliation from Jay-Z and/or his associates or fans is one of the reasons that I chose not to pursue the New York Action and instructed my attorneys to dismiss it. 7. Although I ultimately chose not to pursue them, I stand by my claims in the New York Action and believe that I had a meritorious claim against Jay-Z. In September of 2000, when I was approximately thirteen years old, I attended a party at a house in New York where both Sean Combs (“Diddy”) and Jay-Z were present. I saw and recognized both men at the party. At the party, I accepted a drink and began to feel lightheaded. I went into an empty bedroom to lie down by myself. Soon after that, Diddy, Jay-Z, and another individual entered the bedroom. Jay￾Z removed my clothes, and both Jay-Z and Diddy engaged in sexual intercourse with me. I did not consent to this, and, given that I was only thirteen at the time, I could not have given valid consent. 8. In 2024, I signed up as a client with AVA Law Group. AVA Law Group partnered with The Buzbee Law Firm to pursue claims against Diddy and others, and my case was referred to The Buzbee Law Firm as a result. Several attorneys from the Buzbee Law Firm interviewed me extensively, including Anthony Buzbee (“Mr. Buzbee”). I authorized Mr. Buzbee and The Buzbee Law Firm to send a demand letter to Jay-Z, and to initiate legal proceedings against him in the New York Action. 9. I ultimately decided to dismiss the New York Action, because I was frightened by the reaction of Jay-Z and his supporters, and the likelihood that I would have to be publicly named and subjected to public attacks. Jay-Z and his attorneys made numerous public statements attacking the veracity of my claims, and I am informed and believe that he sent investigators looking for me. I understand that even my attorneys have been sued by Jay-Z. I was not prepared to undergo years of attacks, intimidation, and harassment, and ultimately chose to dismiss my claims after certain negotiations among the attorneys involved in the New York Action. 


         1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -4- SMRH:4933-6230-7616.1 DECLARATION OF JANE DOE I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on this 27th day of February, 2025. JANE DOE 


         1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF ORANGE Shawn Carter v. The Buzbee Law Firm, et al. Case No. 24SMCV05637 At the time of service, I was over 18 years of age and not a party to this action. I am employed in the County of Orange, State of California. My business address is 650 Town Center Drive, 10th Floor, Costa Mesa, CA 92626-1993. On March 3, 2025, I served true copies of the following document(s) described as DECLARATION OF JANE DOE IN RESPONSE TO SHAWN CARTER’S PROFFER OF NEW EVIDENCE AT HEARING ON DEFENDANTS’ SPECIAL MOTION TO STRIKE PORTIONS OF PLAINTIFF’S FIRST AMENDED COMPLAINT on the interested parties in this action as follows: Michael T. Lifrak Mari Henderson Deshani Ellis QUINN EMANUEL URQUHART & SULLIVAN, LLP 865 S. Figueroa Street, 10th Floor Los Angeles, CA 90017 Telephone: (213) 443-3000 Facsimile: (213) 443-3100 michaellifrak@quinnemanuel.com marihenderson@quinnemanuel.com deshaniellis@quinnemanuel.com Attorneys for Plaintiff Shawn Carter BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the document(s) to be sent from e-mail address CSuda@sheppardmullin.com to the persons at the e-mail addresses listed in the Service List. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on March 3, 2025, at Costa Mesa, California. Casey Suda