Clayton Howard’s declaration lays out a first-person account meant to establish a pattern of coercion, violence, and control surrounding Sean “Diddy” Combs, while reinforcing the broader allegations raised in related civil litigation involving Cassie. Howard describes his proximity to Combs during key periods and frames himself as a direct witness to abusive behavior, not a distant observer relying on rumor. The declaration emphasizes power imbalance, alleging that Combs used wealth, influence, and intimidation to control environments and people around him. Howard asserts that the conduct he witnessed was not isolated or misunderstood, but repetitive and normalized within Combs’ inner circle. He details how fear and career consequences discouraged people from speaking out at the time. The document is written to counter any narrative that these allegations are exaggerated or opportunistic. Its core purpose is to show continuity, credibility, and corroboration. Howard positions his testimony as evidence that the alleged abuse was an open secret to those close enough to see it.
In support of his lawsuit, Howard’s declaration also focuses on the emotional and psychological toll of witnessing and navigating that environment. He describes feeling trapped between personal safety, professional survival, and moral responsibility, underscoring why silence persisted for so long. The filing frames Cassie’s allegations not as an anomaly, but as consistent with behavior Howard claims to have observed firsthand. Howard asserts that retaliation, intimidation, and control were standard tools used to maintain silence. The declaration is structured to meet the evidentiary burden of civil litigation by grounding claims in specific interactions and timeframes rather than broad accusations. It aims to bolster credibility by acknowledging the risks and delays involved in coming forward. Ultimately, the declaration functions as both corroboration and escalation, signaling that Cassie’s lawsuit is not standing alone. It presents itself as another piece of a growing evidentiary record challenging Combs’ public persona.
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source:
gov.uscourts.nysd.628425.552.1.pdf