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The Epstein Chronicles

The Downfall Of Diddy: The Declaration Of Martha Brathwaite In Support Of Diddy/UMG (10/15/24)

In the lawsuit filed by Rodney "Lil Rod" Jones against Diddy and associated entities, Universal Music Group (UMG) and its representatives, including Martha Brathwaite, have made significant moves to distance the label from the allegations. Jones accuses Diddy of various forms of misconduct, including an alleged shooting incident at a 2022 writing camp. In response, UMG’s legal team, supported by Brathwaite’s declaration, asserts that UMG and Motown Records were not responsible for organizing or providing security for the camp where the alleged shooting took place.

Brathwaite’s declaration clarifies that Diddy’s Love Records, not UMG or Motown, oversaw and financed the camp, arguing that UMG should not be held accountable for any security failures or incidents that occurred. The label’s legal filings aim to have UMG dismissed from the case, contending that Jones is inappropriately attempting to involve the label despite its lack of operational control or direct involvement in the events under dispute.

Additionally, the legal strategy seeks to prevent the lawsuit from being amended further, with UMG lawyers arguing that any additional claims would be futile. The case exemplifies how UMG and other corporate entities named in the lawsuit are seeking to limit their exposure and sever any implied connections to Diddy’s alleged misconduct during these events. This legal push reflects the complexities of liability when artists manage multiple companies across overlapping spheres.

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Broadcast on:
15 Oct 2024
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Open your free iHeart app and search Amazing Wildlife, and start listening. What's up everyone, and welcome to another episode of the Diddy Diaries. In this episode, we're getting right back to those core documents, and this time, we're going to take a look at the Declaration of Support by Martha Brathwaite, in support of the motion to dismiss the second amended complaint by defendants, Universal Music Group, Motown Records, and Sir Lucy and Grange. Case number 24-1457. Rodney Jones, Plaintiff, Varyshawn Combs, Justin Dior Combs, Lucy and Charles Grange, Christina Quorum, Chalice Recording Studios, Love Records, Motown Records, Universal Music Group, Combs Global Enterprises, John and Jane Doze 1-10, and ABC Corporations 1-10. I, Martha Brathwaite, declare as follows. One, during the time period applicable to the claims in this action, I was the Executive Vice President, Business Affairs for the Capital Music Group, which is affiliated with UMG Recordings Incorporated. As set forth in the accompanying Declaration of Sir Lucy and Grange, UMG Recordings, Chairman and Chief Executive Officer, UMG Recordings is incorporated in the state of Delaware, with its principal operating offices in Santa Monica, California. UMG Recordings is the principal legal entity for all recorded music operations in the United States for the Global Music and Entertainment Company, known as Universal Music Group. I have personal knowledge of the facts set forth in this declaration, and have called and sworn as a witness, I could and would competently testify there too. I am advised that in the first amended complaint, that the plaintiff in this action claimed that Motown Records was the parent company of Love Records Incorporated. This assertion was baseless, and I understand it has now been abandoned by the plaintiff, and his counsel in the second amended complaint. Three, instead I understand that plaintiff and his counsel, Mr. Blackburn, have substituted an equally false allegation in the SAC. That Motown Records and/or UMG Recordings is or was in a general business partnership with Love Records Incorporated and/or Mr. Combs. During the relevant time frame, I was the Executive responsible for handling all of the business and legal affairs for Motown Records. Motown Records is not a separate legal entity, but a record label that is unincorporated division of UMG Recordings. Neither Motown Records nor any of the UMG Recordings subsidiaries or affiliates are, nor were they ever, in a general business partnership, or any other kind of partnership with Love Records Incorporated, Mr. Combs, or any of his business entities. Four, to my knowledge Love Records Incorporated is a company associated with Sean Combs, and I believe owned by him directly or indirectly. I know this because the period starting in or around February 2022 through the beginning of May 2022, I negotiated and executed an arm's length license agreement for a limited term. On behalf of Motown Records with Love Records Incorporated, which was dated May 4th, 2022. Love Records Incorporated was represented by Kenny Mycelis, who I am aware has been Sean Combs' longtime transactional counsel. Five, I'm aware that in the SAC, it's admitted in various paragraphs including Paragraphs 13, 163, and 164 that Motown Records entered into a license agreement to distribute a Love Records album. A redacted copy of that license agreement, which I am informed, was provided to Mr. Blackburn by Our Council, is attached here too as Exhibit A. Six, Paragraph 16, 11 of the license agreement specifically provides as follows. You, Love Records, and Artist Combs are entering into this agreement and are performing your obligations here under as independent contractors. Nothing herein contemplates or constitutes you, or artists as Motown's partners, joint ventures, agents, or employees. Seven, as I said before, Mr. Blackburn was provided a copy of the license agreement. I do not understand how in the face of the plain language of this agreement, he can continue to allege that Motown Records and/or UMG recordings had a general business partnership with Love Records Incorporated and/or Mr. Combs. Eight, because I negotiated the license agreement, I can also address what I understand is the assertion of plaintiff and his counsel that no recordings were created by Love Records Incorporated until at least September of 2022. This assertion is completely false. Nine, to begin with, my negotiations with Mr. Mycelis only began after Ethiopia Haptomerium, who was then the Chairman and Chief Executive Officer of Motown Records, attended a listening session at Mr. Combs' studio to hear the recordings he had already recorded and intended to include on the album that became the subject of the license agreement. Ultimately, I am aware that Mr. Combs decided to record additional tracks beyond the ones he had already recorded. Ten, during my negotiations with Mr. Mycelis, he advised me that Mr. Combs and Love Records Incorporated had already spent several million dollars in recording and other costs on the album. As such, one part of my negotiations with Mr. Mycelis addressed his request for the reimbursement of the costs that Mr. Mycelis advised had already been incurred by Love Records Incorporated in recording tracks prior to our negotiations. Motown Records was not prepared to reimburse all the costs that Mr. Mycelis advised had been incurred by Love Records Incorporated, particularly for a distribution deal of a limited duration and no copyright ownership of the recordings. And we ultimately agreed that Motown Records would reimburse the sum of 1.3 million. This reimbursement amount is specifically identified in Paragraph 7.02A of the license agreement. 11. I am advised that Mr. Blackburn, without the slightest basis, alleges that Mr. Combs supposedly used the 1.3 million for sex workers. It appears this is premised on his completely incorrect assertion that until plaintiff showed up, in September 2022, there had been no recordings made by Mr. Combs and no expenses were incurred. Based upon a lack of knowledge and baseless conclusions, Mr. Blackburn and the SAC label, the license agreement as a ruse. 12. As I have said, Mr. Blackburn is completely incorrect. Not only did misshap to Mariam, listen to the tracks that already been recorded by Mr. Combs before we entered into the license agreement, Motown Records also spent a great deal of money marketing and promoting one of the tracks already recorded by Mr. Combs got a move on which featured Bryson Tiller. Motown released a single recording in or about June 2022 prior to the termination of our license agreement. And I understand it was thereafter also included on the expanded version of the album that Mr. Combs ultimately completed and released after the termination of the license agreement. I'm attaching here too as Exhibit B some invoices for expenses incurred and paid by Motown Records in connection with this recording before September of 2022. I do so in order to show that contrary to what is asserted in the SAC and by Mr. Blackburn, there were tracks already recorded by Mr. Combs long before September 22nd and it was for these already extent tracks that the 1.3 million was reimbursing love records incorporated for some of its recording costs. 13. I understand in the SAC and at a telephone conference with the court on April 9, 2022, Mr. Blackburn also claimed that Motown Records did not administer any recording budget as provided for in paragraph four of the license agreement. Suggesting instead that Motown Records simply gave the money to Mr. Combs, which he then supposedly used to pay for sex workers instead of making recordings. Apparently Mr. Blackburn bases this incorrect conclusion solely on Plato's claim that Mr. Combs allegedly did not pay him. 14. Beyond the fact that money is fungible and there is no way that Mr. Blackburn can possibly know how Mr. Combs used any of the money, his assertion is also again incorrect. 15. First of all, paragraph 4.02(b) provided that Motown Records would administer the budget for the recordings and pay recording costs. In fact, that is what Motown Records did. Attached here too as Exhibit C are some illustrative invoices for recording costs that were submitted directly to Motown Records and paid by Motown Records. Motown paid for studio time, engineers and producers. It did not pay cash and it did not pay sex workers. As a United Explorer card member, you can earn 50,000 bonus miles. Plus, look forward to extraordinary travel rewards, including a free-checked bag, two times the miles on United purchases and two times the miles on dining and at hotels. Become an explorer and seek out unforgettable places while enjoying rewards everywhere you travel. 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Listen to amazing wildlife on America's number one podcast network iHeart. Open your free iHeart app and search amazing wildlife and start listening. 16. I would also note that paragraph 4.04A of the license agreement imposed on love records incorporated, not on Motown records, the obligation to negotiate, draft and execute all producer agreements and the corresponding obligations to pay producers unless love records incorporated requested that Motown records undertake the obligation of paying certain producers as reflected in exhibit as part of the recording cost payable under the license agreement Motown did directly pay some of the producers. 17. In short, contrary to every uninformed assertion that is made in the SAC by Mr. Blackburn, at the hearing on April 9, 2024, Motown records reimbursed love records incorporated for recording costs that love records incorporated actually incurred before the license agreement was executed and paid marketing and promotion costs associated with the release of love recordings and a directly paid recording costs love records incorporated incurred after the license agreement was executed and also contrary to what the SAC and Mr. Blackburn have alleged Motown records did not pay directly indirectly, intentionally or unintentionally any money to sex workers on behalf of Mr. Combs. The direct payments made by Motown records third party vendors such as producers, engineers, recording studios, videographers and insurance companies were not paid to sex workers nor were they paid to love records incorporated and they're thus not available to be used by Mr. Combs for the supposedly improper purposes alleged in the SAC. 18. I also understand that the SAC claims that Motown records, UMG recordings and/or Lucian Grange somehow profited by virtue of the license agreement. In fact, as I stated in my original declaration in support of the motion to dismiss the FAC, subsequent to executing the license agreement, Motown records and Mr. Combs decided that Motown records would not release and distribute the album that Mr. Combs had created. Accordingly, I negotiated and executed a separate document that terminated the license agreement, effective as of February 1, 2023, on behalf of Motown records. Under the termination agreement, Motown assigned back to love records incorporated on a quit-claim basis, all of Motown records rights as a licensee in the recordings. The termination agreement ended any relationship between love records incorporated and Mr. Combs, and on the one hand, UMG recordings on the other hand and Mr. Combs company love records released the album independently. 19. Because Motown records did not distribute the album, it had no opportunity to recoup the recording costs and marketing promotional costs. It paid to or on behalf of love records incorporated, nor did it recoup the reimbursement of recording costs it paid to love records incorporated under the license agreement. Thus far from profiting from the album, the license agreement was not profitable for Motown records or UMG recordings. 20. I understand that the claim in the FAC that Motown records and/or UMG recordings were responsible for the security at Chalice Recording Studio, at which there was allegedly a shooting, and that the security provided was allegedly inadequate, has been abandoned, but that there remained some allegations about Motown records, UMG recordings, and/or Sir Lucy and Grange nevertheless somehow being responsible for security. Whether it is asserted as a claim or an allegation, it is false. 21. I can confirm that neither Motown records nor UMG recordings were involved for and did not pay for security at Chalice Recording Studio, love records not Motown records, or UMG recordings was responsible for security at any love recordings writer camp, or recording session at Chalice Recording Studio, or anywhere else for that matter. Motown records did pay for studio time at Chalice Recording Studio, as well as engineers and producers that worked there, but it had no responsibility, nor did it pay for any security. I declare under the penalty of perjury, under the laws of the United States of America, that the foregoing is true and correct. This was signed by Martha Brathwaite, and it was dated April 18, 2024. All of the information that goes with this episode can be found in the description box. Step into the world of power, loyalty, and luck. I'm going to make him an offer he can't refuse. With family, cannolis, and spins mean everything. Now, you want to get mixed up in the family business. Introducing the Godfather at ChampaCasino.com. Test your luck in the shadowy world of the Godfather slots. Someday, I will call upon you to do a service for me. Play the Godfather, now at ChampaCasino.com. Welcome to the family. No purchase necessary, VDW Group. We were prohibited by law, 18 plus terms and conditions apply. 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