Dear Judge Carter:
The Government respectfully submits this letter in advance of the bail appeal by defendant
Sean Combs, a/k/a “Puff Daddy,” a/k/a “P. Diddy,” a/k/a “Diddy,” a/k/a “PD,” a/k/a “Love.” For
the reasons set forth below, and in the Government’s September 17, 2024 detention letter (Dkt. 5
(the “September 17 Letter”)) and argument before the Magistrate Court (Dkt. 13-9 (“Tr.”) at 11-
23, 48-50), the defendant presents a danger—to victims and others, both through physical violence
and through obstructive conduct—and a risk of flight. He must be detained…
III. The Defendant Has Consistently Obstructed Justice
Equally, as outlined in the Government’s September 17 Letter, the defendant poses a
significant risk of obstruction. (September 17 Letter at 9-11). The defendant’s argument that his
recent contacts with witnesses to the charged conduct should not be considered “obstruction”
because he was unaware of the Government’s investigation simply cannot be credited.
2 The defendant has been aware of the Government’s investigation of this case since at least in or about
January 2024. And even earlier, directly following the filing of a civil lawsuit in November 2023,
the defendant was aware of the potential for criminal charges. Nevertheless, since that time, the
defendant has continued his long-standing pattern of engaging in obstructive conduct.
Defense counsel acknowledges that the defendant has contacted witnesses in this
investigation—apparently with “counsel’s blessing”—but claims that the defense has “studiously
avoided” interviewing grand jury witnesses. (Dkt. 13 at 10). The fact is, the defendant has
personally and repeatedly contacted multiple witnesses, including at least one he himself knew was
a grand jury witness. The defendant contacted these witnesses, including at least one whom he
had not been in contact with for years, after they were served and leading up to the date they were
required to appear before the grand jury. The defendant’s behavior illustrates Judge Tarnofsky’s
point that counsel cannot control their client. (Tr. 54).