DIRECT EXAMINATION BY MS. STEINER:
MS. STEINER: Good morning, Ms. Richard.
DAWN RICHARD: Good morning.
MS. STEINER: Before the weekend, you testified regarding an incident involving an egg skillet in 2009 at Mr. Combs' residence. Do you recall that?
DAWN RICHARD: Yes.
MS. STEINER: If you can just...
THE COURT: Yes. Please speak up.
DAWN RICHARD: Sorry.
MS. STEINER: You also testified that, the following day, Mr. Combs called you back to his residence and made certain statements to you. Do you recall that?
DAWN RICHARD: Yes.
MS. STEINER: Can you please remind the jury the statements that Mr. Combs made to you at that time?
DAWN RICHARD: That he -- the relationship that he had, that the incident was of passion and that Cassie was OK. And that if we say anything, that we could go missing.
MS. STEINER: When Mr. Combs told you, and I believe it was Ms. Harper --
DAWN RICHARD: Kaleena Harper.
MS. STEINER: -- that you could go missing, what did you understand him to mean?
MS. WESTMORELAND: Objection, your Honor.
THE COURT: It's overruled.
DAWN RICHARD: That we could die.
MS. STEINER: Ms. Richard, how did you react when Mr. Combs threatened you in this manner?
DAWN RICHARD: I didn't react at all. Was shocked, but also scared because it was our first time really getting started to record, and that was my first time really being in a group with everybody. And I couldn't believe that this would be the beginning of the journey for us.
MS. STEINER: The group you're referring to, Ms. Richard, is Diddy Dirty Money?
DAWN RICHARD: Dirty Money.
MS. STEINER: Following the incident in Mr. Combs' residence in 2009, did you continue to see Ms. Ventura while you were a member of Diddy Dirty Money?
DAWN RICHARD: I did.
MS. STEINER: Generally, where would you see her?
DAWN RICHARD: In the studio, in hotels, events that we would have, performances we would have, and in the house as well.
MS. STEINER: Generally, how frequently would you see Ms. Ventura?
DAWN RICHARD: Frequently.
MS. STEINER: After the incident in Mr. Combs' Los Angeles residence, were there other occasions when you observed acts of violence between Mr. Combs and Ms. Ventura?
DAWN RICHARD: Yes.
MS. STEINER: How frequently did you observe Mr. Combs being violent with Ms. Ventura?
DAWN RICHARD: Frequently.
MS. STEINER: Can you please describe for the jury what you observed generally?
DAWN RICHARD: Um, he would punch her, choke her, drag her, slap her in the mouth. Um, I saw him kick her. Um, punch her in the stomach.
MS. STEINER: Prior to witnessing those incidents, were you able to observe the interactions between Mr. Combs and Ms. Ventura?
DAWN RICHARD: Yes.
MS. STEINER: And, generally, based on your observations, what would prompt these acts of violence?
MS. WESTMORELAND: Objection.
THE COURT: It's overruled.
DAWN RICHARD: It varied. It could be Cass speaking up for herself. It could be, um, random -- like, we wouldn't even know where it came from. It could be if she wanted to perform or she had an opinion about something. It just varied.
MS. STEINER: And when you state that it happens sometimes when Ms. Ventura would speak up for herself, can you describe what you mean by that?
DAWN RICHARD: Cass is, like, quiet. She would be quiet. She had a quiet demeanor. She was soft. And when she would have these moments of, like, trying to be stick up for herself, trying to be more for herself and he wasn't having that, he would hurt her for it.
MS. STEINER: And when you refer to him, are you referring to Mr. Combs?
DAWN RICHARD: Yes.
MS. STEINER: Who, if anyone, from Mr. Combs' staff was present for these incidents of violence?
DAWN RICHARD: That varied, too. It could be anyone from Harve Pierre to Capricorn Clark to Mia, to D-Roc, to Bonds. It depends.
MS. STEINER: Generally, at a high level, can you describe the roles that Capricorn Clark and Mia served for the defendant?
DAWN RICHARD: They were, um, assistants and also a head of marketing, like, brand work.
MS. STEINER: You also testified that members from his security staff would observe these incidents, is that correct?
DAWN RICHARD: Yes.
MS. STEINER: And?
MS. WESTMORELAND: Objection. Your Honor, may we have a time context to any of this testimony?
THE COURT: Hold on.
MS. WESTMORELAND: Objection.
THE COURT: Thank you. Is that an objection?
MS. WESTMORELAND: Yes.
THE COURT: Ms. Steiner, can you rephrase the question?
MS. STEINER: Yes, your Honor.
BY MS. STEINER:
MS. STEINER: Ms. Richard, you testified that the first incident of violence that you observed between Mr. Combs and Ms. Ventura was in 2009, is that correct?
DAWN RICHARD: Right.
MS. STEINER: And approximately when was the last incident?
DAWN RICHARD: You said the last incident?
MS. STEINER: Of violence?
DAWN RICHARD: Which one?
MS. STEINER: Let me rephrase my question. You said you also observed violence frequently thereafter, is that right?
DAWN RICHARD: Yes, yes.
MS. STEINER: And that continued throughout the period of time in which you were a member of Diddy Dirty Money?
DAWN RICHARD: Yes.
MS. STEINER: And were you a member of Diddy Dirty Money from 2009 through 2011?
DAWN RICHARD: Correct.
MS. STEINER: And did that those incidents of violence continue throughout that period of time?
DAWN RICHARD: Yes.
MS. STEINER: Can you specify, Ms. Richard, who from Mr. Combs' security staff witnessed incidents of violence?
DAWN RICHARD: Um, D-Roc and Bonds.
MS. STEINER: Ms. Becker, can we please bring up what has been marked for identification and may be in evidence, I apologize, as Government Exhibit 2A-2-202. Thank you. I believe this is in evidence.
MS. STEINER: Ms. Richard, do you recognize this image?
DAWN RICHARD: I do.
MS. STEINER: Who is this?
DAWN RICHARD: It's D-Roc.
MS. STEINER: And can you please describe what D-Roc's role was for Mr. Combs?
DAWN RICHARD: He was a bodyguard. He was also really close to Puff. Like, they were close, like brothers.
MS. STEINER: Ms. Becker, can you please bring up what is in evidence as Government Exhibit 2A-201.
MS. STEINER: Ms. Richard, do you recognize this image?
DAWN RICHARD: Yes.
MS. STEINER: Who is depicted in it?
DAWN RICHARD: That's Bonds.
MS. STEINER: What was Bonds' role for Mr. Combs?
DAWN RICHARD: Security.
MS. STEINER: You can take that down.
MS. STEINER: The D-Roc and Bonds work for Mr. Combs the entire time you were a member of Diddy Dirty Money?
DAWN RICHARD: Yes.
MS. STEINER: How would D-Roc and Bonds react to incidents of violence that they observed?
DAWN RICHARD: They wouldn't react. They wouldn't do anything.
MS. STEINER: Did you ever observe Ms. Ventura with injuries after these instances of abuse?
DAWN RICHARD: Yes.
MS. STEINER: Where on her body?
DAWN RICHARD: Her face. When I say face, her eyes, her lip, her arms, her knees.
MS. STEINER: How, if at all, would Ms. Ventura attempt to cover up or hide these injuries?
DAWN RICHARD: Um, with makeup, clothing, and sometimes sunglasses.
MS. STEINER: Did there come a time later in 2009 when you were in New York for a festival performance?
DAWN RICHARD: Um, yeah. We were in Central Park.
MS. STEINER: Which festival was this?
DAWN RICHARD: I don't know the name of it, but we were announcing our group. It was in Central Park.
MS. STEINER: Again, the group is Diddy Dirty Money?
DAWN RICHARD: Diddy Dirty Money.
MS. STEINER: And in connection with that festival, was there a time that you and Ms. Ventura and Mr. Combs were in Mr. Combs' New York residence?
DAWN RICHARD: Correct.
MS. STEINER: Where is that residence located?
DAWN RICHARD: In New York City.
MS. STEINER: Who else, if anyone, was present?
DAWN RICHARD: Kaleena Harper, Cassie, and myself.
MS. STEINER: What happened while you were in the residence?
DAWN RICHARD: Kaleena and I were in the bathroom getting ready, doing our makeup, and Puffy and Cassie were in the hallway arguing.
MS. STEINER: What did you observe happen next?
DAWN RICHARD: He punched her in the face.
MS. STEINER: When you say he, are you referring to Mr. Combs?
DAWN RICHARD: Sean Combs punched her in the face.
MS. STEINER: Did he punch her with an open or closed fist?
DAWN RICHARD: It was a closed fist.
MS. STEINER: After Mr. Combs punched Ms. Ventura in the face with a closed fist, how did she respond?
DAWN RICHARD: She came into the bathroom crying. He walked off angry and she came in the bathroom. And we were with her and it was really quiet. You could see her -- you could see her upset. Like, she just -- she was hurt. She was embarrassed.
MS. WESTMORELAND: Objection.
THE COURT: That's sustained. The jury should disregard the last sentence of the witness's answer.
MS. STEINER: What, if any, injuries did you observe on Ms. Ventura at that time?
DAWN RICHARD: Her eye was swelling.
MS. STEINER: What, if anything, did you observe Ms. Ventura do to try and cover up that injury?
DAWN RICHARD: She started doing her makeup to try to hide it.
MS. STEINER: Did she do anything else to cover up the injury?
DAWN RICHARD: She wore sunglasses that day.
MS. STEINER: Why did she wear sunglasses?
DAWN RICHARD: She wanted to hide the swelling --
MS. WESTMORELAND: Objection.
THE COURT: Sustained.
MS. STEINER: Ms. Richard, did you remain with Ms. Ventura after this incident?
DAWN RICHARD: Yes.
MS. STEINER: Why did you remain with her?
DAWN RICHARD: I wanted her to feel supported. She wanted to be with us. We wanted to have her back.
MS. STEINER: Ms. Becker, can you please bring up for the parties, witness, and court what has been marked for identification as Government Exhibit 9R-101. Actually, can we please do 9P-102. Thank you.
MS. STEINER: Ms. Richard, do you recognize this image?
DAWN RICHARD: I do.
MS. STEINER: Generally, what does it depict?
DAWN RICHARD: It's us at the Central Park festival together in New York.
MS. STEINER: Is it a fair and accurate depiction of that?
DAWN RICHARD: Yes.
MS. STEINER: Government offers Government Exhibit 9P-102.
THE COURT: Any objection?
THE COURT: 9P-102 will be admitted.
(Government's Exhibit 9P-102 received in evidence)
BY MS. STEINER:
MS. STEINER: Ms. Richard, was this image taken later in the day following that incident?
DAWN RICHARD: Yes.
MS. STEINER: Can you please describe --
MS. STEINER: Or can you please publish that for the jury.
MS. STEINER: Can you please describe who is depicted in this photograph?
DAWN RICHARD: On the left is Kaleena Harper, and in the middle is myself, and to the right is Cassie.
MS. STEINER: And it appears in this photo that the three of you are wearing sunglasses. Why are you all wearing sunglasses?
MS. WESTMORELAND: Objection.
MS. STEINER: I can rephrase, your Honor.
THE COURT: OK.
MS. STEINER: Ms. Richard, what are you wearing in this photograph?
DAWN RICHARD: I'm wearing sunglasses.
MS. STEINER: And what is Ms. Harper wearing?
DAWN RICHARD: She's wearing sunglass.
MS. STEINER: What is Ms. Ventura wearing?
DAWN RICHARD: She is wearing sunglasses.
MS. STEINER: Are those the sunglasses you observed her put on in the bathroom?
DAWN RICHARD: Yes.
MS. STEINER: Why are the three of you, why did you --
MS. WESTMORELAND: Objection.
MS. STEINER: Why did you decide to wear sunglasses that day?
DAWN RICHARD: To have solidarity, to be a friend, to be a support system for someone who needed it.
MS. STEINER: You can take this down.
MS. STEINER: Ms. Richard, directing your attention now to the following year in 2010, did there come a time that you were in a restaurant in West Hollywood, California, with Mr. Combs and Ms. Ventura?
DAWN RICHARD: Yes.
MS. STEINER: What happened at that restaurant?
DAWN RICHARD: Mr. Combs punched Cassie in the stomach.
MS. STEINER: Can you please describe what you observed leading up to that incident?
DAWN RICHARD: We were having a private conversation and we were all sitting, eating at the tables together. When I say we, I mean some Bad Boy -- some of our other label, and even some celebrities were in the room. And they were secretly arguing, and he punched her in the stomach. Sean Combs punched her in the stomach.
MS. STEINER: How, if at all, did Ms. Ventura respond when she was punched in the stomach?
DAWN RICHARD: She immediately bent over and then was -- he was -- he told her to leave because I could see him point out, and she went out and left the room.
MS. STEINER: Who, if any, of Mr. Combs' employees were present?
DAWN RICHARD: Harve Pierre, Capricorn Clark, Mia, D-Roc, Bonds, myself, and Kaleena Harper.
MS. STEINER: Ms. Becker, can you please bring up for the parties and the court and the witness what has been marked as Government Exhibit 2A-319.
MS. STEINER: Ms. Richard, do you recognize this image?
DAWN RICHARD: I do.
MS. STEINER: What is it?
DAWN RICHARD: This is Harve Pierre.
MS. STEINER: Is it that a fair and accurate depiction of Mr. Pierre?
DAWN RICHARD: Yes.
MS. STEINER: Government offers Government Exhibit 2A-319.
MS. WESTMORELAND: No objection.
THE COURT: All right. 2A-319 will be admitted.
(Government's Exhibit 2A-319 received in evidence)
MS. STEINER: Ms. Becker, can we please publish that for the jury.
BY MS. STEINER:
MS. STEINER: Ms. Richard, generally, who was Mr. Pierre?
DAWN RICHARD: He was the president of Bad Boy Records.
MS. STEINER: Who, if anyone, did he report to at Bad Boy?
MS. WESTMORELAND: Objection.
THE COURT: Can you rephrase the question?
MS. STEINER: Of course.
MS. STEINER: Ms. Richard, you said that Mr. Pierre was the president of Bad Boy, is that correct?
DAWN RICHARD: Correct.
MS. STEINER: Does that mean he was your boss?
DAWN RICHARD: He wasn't my boss. He just was the boss of Bad Boy. My boss was Puff, Sean Combs.
MS. STEINER: Mr. Combs?
DAWN RICHARD: Yeah.
MS. STEINER: And did you observe Mr. Combs and Mr. Pierre while at Bad Boy together?
DAWN RICHARD: Yes.
MS. STEINER: Did you have an understanding of what Mr. Pierre's role was at Bad Boy?
DAWN RICHARD: Yes. He answered to Puff or Sean Combs.
MS. STEINER: What, if anything, did Mr. Pierre or the other employees present do to intervene after that incident?
DAWN RICHARD: They didn't. No one intervened. We didn't.
MS. STEINER: When did you next see Ms. Ventura?
DAWN RICHARD: We got in the car together to head back to the LA house.
MS. STEINER: Who was present in the car?
DAWN RICHARD: Kaleena, myself, Cassie, Puff, and D-Roc.
MS. STEINER: Can you please describe where everyone was positioned in the car?
DAWN RICHARD: Yes. Kaleena and I was -- it was, like, a Sprinter, so, like, a BMW Sprinter, so we were sitting facing them, if that makes sense. So it was Kaleena and I and then Puff and Cass and then D-Roc was in the front.
MS. STEINER: Was D-Roc driving?
DAWN RICHARD: He was driving, yeah.
MS. STEINER: Was anyone speaking in the car?
DAWN RICHARD: Cass and Puff were arguing.
MS. STEINER: And what generally were they discussing?
DAWN RICHARD: Cass was embarrassed and she was telling him, like, he shouldn't have done that in public and she felt embarrassed.
MS. WESTMORELAND: Objection.
THE COURT: Sustained.
MS. STEINER: How did Mr. Combs respond?
DAWN RICHARD: He grabbed her by the neck and popped her in -- he slapped her in the mouth, told her to shut the fuck up.
MS. STEINER: You say that he popped her in the mouth. What do you mean by that?
DAWN RICHARD: Like, an open-hand slap to the mouth.
MS. STEINER: How did Ms. Ventura respond after she was hit in the mouth?
DAWN RICHARD: She looked outside the, um, the window and everyone was quiet for the rest of the ride.
MS. STEINER: How, if at all, did D-Roc respond?
DAWN RICHARD: He didn't.
MS. STEINER: Ms. Richard, what, if anything, would you discuss with Ms. Ventura about her music career?
DAWN RICHARD: Cass had big dreams. She really loved --
MS. WESTMORELAND: Objection.
THE COURT: The basis?
MS. STEINER: It's for the effect on the listener, your Honor, not for its truth.
THE COURT: All right. It's overruled. A. She wanted to put out her album, and I told her I would write for her. She wanted to do more modeling. She wanted to do well with her career. And I, myself and Kaleena, we encouraged her to do that. We wanted to support her in any way that we could.
MS. STEINER: Did you observe any discussions between Ms. Ventura and Mr. Combs about those career goals?
DAWN RICHARD: Yes.
MS. STEINER: And how, if at all, would Mr. Combs respond in those discussions?
MS. WESTMORELAND: Objection.
THE COURT: It's overruled.
DAWN RICHARD: Um, Mr. Combs didn't like that we knew or we talked to Cassie, and oftentimes, we would pay for it.
MS. STEINER: I just want to stop you for a moment. Ms. Richard, can you describe what, if anything, you recall Mr. Combs saying to Ms. Ventura in those discussions?
DAWN RICHARD: Oh, that it would be, um, on his time. Like, it was coming. But when he say it would come, he would also tell her, like, he owned her. Like, this was -- I do -- I do this. It was a very much, like, when I'm ready for you, you'll do it. And it was always wait, wait, wait for her. Like, she had to wait her time.
MS. STEINER: Would Mr. Combs ever be upset in these discussions?
MS. WESTMORELAND: Objection.
THE COURT: You can rephrase.
MS. STEINER: Thank you, your Honor.
MS. STEINER: What was Mr. Combs' demeanor in these discussions?
DAWN RICHARD: That varied. Sometimes it was just a moment of, like, wait your turn and it was regular. And then other times, it was violent, violent and volatile, and we would have to see that.
MS. STEINER: What, if anything, would Mr. Combs say when he became violent or volatile?
DAWN RICHARD: It varied to, I mean, whether that was him hitting her or calling her out her name or telling her, like, you know, it was -- he owned her in that moment, or her decisions, that would be what it would be.
MS. STEINER: Ms. Richard, what, if anything, would you tell Ms. Ventura after witnessing acts of physical abuse?
DAWN RICHARD: We told her she should leave.
MS. WESTMORELAND: Objection.
THE COURT: Grounds?
MS. WESTMORELAND: Hearsay. We.
THE COURT: I think, Ms. Steiner, you can probably rephrase the question to avoid the objection.
MS. STEINER: Thank you, your Honor.
BY MS. STEINER:
MS. STEINER: Ms. Richard, can you please answer just limit it to you specifically?
DAWN RICHARD: Yeah.
MS. STEINER: Thank you.
DAWN RICHARD: I told her she should leave.
MS. STEINER: How would Ms. Ventura react when you told her to leave?
DAWN RICHARD: Cass looked torn. Like, she -- she would listen, but you could see -- I could see the fear --
MS. WESTMORELAND: Objection.
THE COURT: Sustained.
MS. STEINER: If you know, Ms. Richard, was Mr. Combs later made aware of these discussions?
DAWN RICHARD: Yes.
MS. STEINER: And what, if anything, did Mr. Combs tell you after those discussions?
DAWN RICHARD: He didn't like it when Kaleena and I would talk to Cass because she would -- she would tell him, and then he would come and we would pay for it.
MS. STEINER: And, I guess --
DAWN RICHARD: I paid for it.
MS. STEINER: Specifically, what, if anything, do you recall Mr. Combs telling you?
DAWN RICHARD: Oh, man. Stay the fuck out of my relationship. You bitches are here to work, not be a part of my relationship. Um, you motherfuckers don't know real work. Man...
MS. STEINER: What, if any, threats would Mr. Combs make to you?
DAWN RICHARD: That we would -- it would be, or else, we would pay for it. That was always -- y'all are going to pay for it or keep doing it, a-ight, that kind of thing. It's always you do this or else something bad will happen to you. It was always that, like, a threat, that if you didn't stay in line, there was consequences.
MS. STEINER: What was Mr. Combs' demeanor when he made these threats?
DAWN RICHARD: That varied. Again, sometimes it was a -- a stern, like, moment to say it, and other times it was loud, angry, violent and, like, it's mean. It was mean. It was mean.
MS. STEINER: Did anyone else speak to you specifically about your discussions with Ms. Ventura?
DAWN RICHARD: Yes.
MS. STEINER: Who was that?
DAWN RICHARD: Harve, Harve Pierre.
MS. STEINER: And what, if anything, would Mr. Pierre tell you?
DAWN RICHARD: Harve said it gets dark and lonely. And Mr. Combs used to say this, too. It gets dark and lonely if you don't listen. It was very much, like, y'all need to listen to him. Y'all don't want to deal with what happens if you don't. And that was stated by Harve and Mr. Combs.
MS. STEINER: What did you understand that when Mr. Pierre and Mr. Combs said it gets dark and lonely?
MS. WESTMORELAND: Objection.
THE COURT: It's overruled.
DAWN RICHARD: I had seen and witnessed brutality in a way that I had to believe that if the person that was supposedly in love with, did what he did to her, what would he do to an employee? I imagine it would be worse than that.
MS. STEINER: How did you respond to these threats?
DAWN RICHARD: My thought was to be as kind and possible. Like, I tried to please -- I saw what if you spoke out looked like. So I would oftentimes approach Mr. Combs, like, with softness and, like, Hey, how are you. It was always very much, like, if I do it this way, I maybe will have a better chance than what the other way looked like.
MS. STEINER: Did you continue to try to intervene in Mr. Combs' relationship?
DAWN RICHARD: No. I made a decision that it would be best for the safety of myself to not -- not interfere -- interfere, because I don't think she was ready to really do anything.
MS. WESTMORELAND: Objection.
MS. STEINER: I'm prepared to turn to a new topic, your Honor.
THE COURT: I didn't even hear the objection, so must be a problem with the microphone. What was the objection? What were the grounds?
MS. WESTMORELAND: Speculation.
THE COURT: That's overruled. Ms. Steiner, you may proceed.
MS. STEINER: Thank you, your Honor.
BY MS. STEINER:
MS. STEINER: While you were employed by Mr. Combs, did you ever observe him using drugs?
DAWN RICHARD: Yes.
MS. STEINER: What kinds of drugs?
DAWN RICHARD: Um, weed, ketamine, cocaine, um, molly, E.
MS. STEINER: Approximately how often did you observe him taking those drugs?
DAWN RICHARD: Often.
MS. STEINER: Generally, where would he take these substances?
DAWN RICHARD: The studio or the house.
MS. STEINER: How often, if at all, did you observe him taking opiates?
DAWN RICHARD: I never really saw him take opiates.
MS. STEINER: Who, if anyone, would deliver the drugs to the studio?
DAWN RICHARD: There was this guy named One Stop that used to come in the studio.
MS. STEINER: Ms. Becker, can you please put up for the witness the parties and the court what has been marked as Government Exhibit 2A-507.
BY MS. STEINER:
MS. STEINER: Ms. Richard, do you recognize this image?
DAWN RICHARD: Yes.
MS. STEINER: What does it depict?
DAWN RICHARD: That's One Stop.
MS. STEINER: Is that a fair and accurate depiction of One Stop?
DAWN RICHARD: It is.
MS. STEINER: Government offers Government Exhibit 2A-507.
MS. WESTMORELAND: No objection.
THE COURT: 2A-507 will be admitted.
(Government's Exhibit 2A-507 received in evidence)
MS. STEINER: Ms. Becker, can we please publish that.
MS. STEINER: What types of drugs did One Stop sell?
DAWN RICHARD: That varied, too. The reason why they called him that --
MS. WESTMORELAND: Objection.
DAWN RICHARD: OK.
THE COURT: That's sustained. Hold on.
DAWN RICHARD: I'm sorry.
BY MS. STEINER:
MS. STEINER: What types of drugs did you observe One Stop selling?
DAWN RICHARD: Cocaine, plan B, birth control, weed, E, molly, like, everything.
(Continued on next page)
BY MS. STEINER:
MS. STEINER: Did he deliver drugs to Mr. Combs?
DAWN RICHARD: He did.
MS. STEINER: Where would he deliver the drugs?
DAWN RICHARD: In the studio.
MS. STEINER: We can take that down.
MS. STEINER: Where did Mr. Combs generally store the drugs he received?
DAWN RICHARD: He had --
MS. WESTMORELAND: Objection.
THE COURT: Ms. Steiner, you can rephrase.
MS. STEINER: Thank you, your Honor.
MS. STEINER: Ms. Richard, did you observe Mr. Combs take possession of the drugs that were delivered?
DAWN RICHARD: Yes.
MS. STEINER: Did you observe where he stored the drugs?
DAWN RICHARD: Yeah, he had this Louis Vuitton pouch, travel toiletry bag that he would put the drugs in.
MS. STEINER: When, if at all, would you observe Mr. Combs traveling with that Louis Vuitton pouch?
DAWN RICHARD: That Louis Vuitton pouch went everywhere from domestic to overseas.
MS. STEINER: Who would you observe carrying the Louis Vuitton pouch?
DAWN RICHARD: It could be his assistants or himself.
MS. STEINER: Did Mr. Combs ever offer you drugs?
DAWN RICHARD: Yes.
MS. STEINER: Did you take them?
DAWN RICHARD: I only smoked weed.
MS. STEINER: Did you observe Mr. Combs offer anyone else drugs?
DAWN RICHARD: Yes.
MS. STEINER: Who did you observe him offer drugs to?
DAWN RICHARD: Kaleena Harper and Cassie.
MS. STEINER: You've been testifying about observing Mr. Combs receiving drugs in the studio. Did you observe him consume those drugs in the studio?
DAWN RICHARD: Yes.
MS. STEINER: While he was taking drugs in the studio, was he also working?
DAWN RICHARD: Yes.
MS. STEINER: What type of work was he doing?
DAWN RICHARD: It could be anything from our album stuff to his business corporations and things he had going on.
MS. STEINER: While you were working for Mr. Combs, when, if ever, did you see him with a weapon on his person?
DAWN RICHARD: A few times.
MS. STEINER: What kind of weapon did you observe on his person?
DAWN RICHARD: It looked like a handgun.
MS. STEINER: Approximately when did you first see Mr. Combs with a handgun?
DAWN RICHARD: In the studio.
MS. STEINER: When you say in the studio, was that when you working for Diddy Dirty Money?
DAWN RICHARD: Correct.
MS. STEINER: Where in time during your employment for Diddy Dirty Money did you first observe the handgun?
DAWN RICHARD: In 2009 going into 2010.
MS. STEINER: Generally, where would you observe Mr. Combs carrying the handgun?
DAWN RICHARD: In the lower waist, in the back.
MS. STEINER: You said that you observed Mr. Combs with a handgun in the studio; is that correct?
DAWN RICHARD: Correct.
MS. STEINER: Did you observe him carrying the handgun in any other locations?
DAWN RICHARD: If we went to a club after studio.
MS. STEINER: Who, if anyone else, working for Mr. Combs carried handguns or guns?
DAWN RICHARD: His body guards.
MS. STEINER: And specifically, which body guards?
DAWN RICHARD: D-Roc and Bonds.
MS. STEINER: And generally, where would D-Roc and Bonds carry those firearms?
DAWN RICHARD: In the same place, the lower back.
MS. STEINER: How, if at all, did your observations of Mr. Combs and his security with handguns affect you?
MS. WESTMORELAND: Objection.
THE COURT: That's overruled.
DAWN RICHARD: I mean, fear. You have to know your environment, and it was fearful every day to be in to understand, like, what that meant. I mean, it was just -- that was the kind of environment I was in.
MS. STEINER: Ms. Richard, did there come a time when you left your employment for Mr. Combs?
DAWN RICHARD: Yes.
MS. STEINER: Approximately when was that?
DAWN RICHARD: 2011.
MS. STEINER: Generally, what did you do after leaving Bad Boy?
DAWN RICHARD: What do you mean?
MS. STEINER: Did you work after leaving Bad Boy?
DAWN RICHARD: Yeah.
MS. STEINER: Generally, what kind of work did you do?
DAWN RICHARD: It was the same.
MS. STEINER: Did Mr. Combs remain in contact after you left Bad Boy?
DAWN RICHARD: Yes.
MS. STEINER: Can you describe generally when he would be in touch?
DAWN RICHARD: Every time I was kind of, like, getting a little momentum in my career, there would be a FaceTime call, and if you didn't answer that, then someone else would call, and if you didn't answer that, someone else would call, and finally you would get on the call and make contact. And so it would be every so often. Another time he contacted me for the possibility of using an old song --
MS. STEINER: I'm going to stop you right there, Ms. Richard. When you said someone else would contact you when you didn't pick up immediately, who would those individuals be?
DAWN RICHARD: His assistant or management.
MS. STEINER: And when you had these discussions with Mr. Combs, how would you interact with him?
DAWN RICHARD: Again, the smartest way to talk, because it was the way I felt was the safest, was to always be pleasant, very pleasant, very kind, almost calling him bro all the time. Hi bro, very much like that.
MS. STEINER: When you initially left your employment for Mr. Combs, did you disclose the abuse that you had observed?
DAWN RICHARD: No.
MS. STEINER: Why not?
DAWN RICHARD: Before I left, I was told to come in, and that the only way I could --
MS. STEINER: I'm going to stop you right there, Ms. Richard. Without getting into that conversation, can you just describe, more generally, why you did not disclose what you had?
DAWN RICHARD: I was told not to.
MS. STEINER: Who told you not to?
DAWN RICHARD: Mr. Combs and Harve Pierre.
MS. STEINER: Did there later come a time when you did decide to speak publicly about what you had witnessed?
DAWN RICHARD: Yes.
MS. STEINER: Approximately, when was that?
DAWN RICHARD: 2024.
MS. STEINER: What, if anything, changed your willingness to be public with what you had experienced?
DAWN RICHARD: I saw Cassie finally take the stand and tell the truth.
MS. WESTMORELAND: Objection. Move to strike.
THE COURT: The objection is sustained. The jury should disregard the witness's answer. Ms. Steiner, you can ask a question phrased differently to avoid the objection.
MS. STEINER: Ms. Richard, did you observe Ms. Ventura file a civil lawsuit around that time?
DAWN RICHARD: I did.
MS. STEINER: Did you, yourself, file a civil lawsuit against Mr. Combs around that time?
DAWN RICHARD: I did.
MS. STEINER: Is that civil lawsuit that you filed primarily related to Mr. Combs's treatment of you?
DAWN RICHARD: Yes.
MS. STEINER: Are there claims in your civil lawsuit based on Mr. Combs's conduct towards you --
MS. WESTMORELAND: Objection, your Honor.
THE COURT: That's sustained. You can rephrase the question.
MS. STEINER: You testified just now, Ms. Richard, that your civil lawsuit is based on Mr. Combs's treatment of you specifically; is that correct?
DAWN RICHARD: Correct.
MS. STEINER: And in your testimony here today and on Friday before the weekend, have you talked about Mr. Combs's treatment of you during your testimony or have you focused on his treatment of others?
DAWN RICHARD: His treatment of others.
MS. WESTMORELAND: Objection.
THE COURT: That's overruled.
MS. STEINER: Ms. Richard, is your lawsuit against Mr. Combs still pending?
DAWN RICHARD: It is.
MS. STEINER: And are you aware of the details of any settlement negotiations with Mr. Combs?
DAWN RICHARD: No, I'm not.
MS. STEINER: Are you aware of how much money, if at all, has been requested to settle the suit?
DAWN RICHARD: No, I'm not.
MS. STEINER: As a result of your testimony here today, Ms. Richard, are you expecting any compensation?
DAWN RICHARD: I'm expecting justice.
MS. STEINER: Are you expecting any compensation, Ms. Richard?
DAWN RICHARD: From this?
MS. STEINER: From your testimony.
DAWN RICHARD: No.
MS. STEINER: No further questions, your Honor.
CROSS-EXAMINATION BY MS. WESTMORELAND:
MS. WESTMORELAND: Good morning, Ms. Richard. My name is Nicole Westmoreland. I represent Mr. Combs. Okay?
DAWN RICHARD: Good morning.
MS. WESTMORELAND: I need to ask you a few questions. Now, your lawsuit that's pending right now as we speak, correct, you have a lawsuit?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And there's a motion to dismiss pending for that lawsuit?
DAWN RICHARD: I'm not sure.
MS. STEINER: Objection.
THE COURT: Overruled.
MS. WESTMORELAND: You're aware that there's currently a motion to dismiss pending in your lawsuit, correct?
DAWN RICHARD: Not aware.
MS. WESTMORELAND: Okay. Now, before filing a lawsuit against Mr. Combs, you're aware that your attorneys sent a demand letter on your behalf, correct?
DAWN RICHARD: I'm not aware of what my attorneys sent. I'm sorry.
MS. WESTMORELAND: Without telling me any conversations between you and your lawyers, you hired civil lawyers, correct?
DAWN RICHARD: I have civil lawyers.
MS. WESTMORELAND: And you understand that the civil lawyers that you hired are litigating on your behalf, correct?
DAWN RICHARD: Can you give that in a term I can understand.
MS. WESTMORELAND: You hired lawyers to do a job on your behalf?
DAWN RICHARD: Yes.
MS. WESTMORELAND: Thank you. Ms. Richard, you formally filed suit January 11, 2024; does that sound accurate?
DAWN RICHARD: I'm not sure. I'd have to see. I thought it was September 2024.
MS. WESTMORELAND: So you formally filed suit September 2024; does that sound accurate?
DAWN RICHARD: It sounds -- yeah.
MS. WESTMORELAND: Now, after filing a formal lawsuit against Mr. Combs, you had an interview with the government; do you remember that?
DAWN RICHARD: What are you referring -- like, just a conversation with -- can you give me more? I'm sorry.
MS. WESTMORELAND: Yes. You've had the opportunity to sit down and speak with the federal prosecutors, the government, correct?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And you sat down and you spoke with them numerous times, right?
DAWN RICHARD: A few times.
MS. WESTMORELAND: You sat down with them eight times; does that sound right?
DAWN RICHARD: I don't recall the number. I'm sorry.
MS. WESTMORELAND: Would several be fair?
DAWN RICHARD: A few times.
MS. WESTMORELAND: Would you agree with me that over the few times that you sat down and spoke with the government that your allegations, the ones that you've testified to today have changed over time?
DAWN RICHARD: No, I think they've been as best as I can recall.
MS. WESTMORELAND: You think they've been consistent?
DAWN RICHARD: As best as I can recall.
MS. WESTMORELAND: First, I want to speak with you about your testimony on Friday, about the egg in the kitchen incident. Do you remember explaining a situation like that to the jury?
DAWN RICHARD: Yes, ma'am.
MS. WESTMORELAND: And you, on Friday, you stated that Ms. Ventura was in the kitchen and she was cooking eggs, right?
DAWN RICHARD: She was cooling eggs.
MS. WESTMORELAND: The eggs were done and she was cooling eggs, correct? And then you said Mr. Combs came downstairs, he was yelling, right?
DAWN RICHARD: He was.
MS. WESTMORELAND: And then he attempted to hit Ms. Ventura with the frying pan, with the -- okay. I couldn't hear you. I need you to say yes or no with the court reporter.
DAWN RICHARD: He went to swing at her, it didn't --
MS. WESTMORELAND: So he attempted to hit her in the head, and then you testified Ms. Ventura dropped down into a fetal position?
DAWN RICHARD: She covered herself, yeah.
MS. WESTMORELAND: And that's your testimony?
DAWN RICHARD: Yeah.
MS. WESTMORELAND: This isn't the first time, testifying on Friday and today, it's not the first time you spoke about this egg alleged incident, right?
DAWN RICHARD: Spoke in my civil case and right now.
MS. WESTMORELAND: I'm sorry. I couldn't hear the last part.
DAWN RICHARD: I'm not sure. Yes, I've spoken in my case and here now.
MS. WESTMORELAND: You've spoken about it in your civil case and you've spoken about it here?
DAWN RICHARD: Mhm.
MS. WESTMORELAND: And you've also spoken about it to the prosecutors, right?
DAWN RICHARD: We've spoken, yes.
MS. WESTMORELAND: Let's start with the civil part. You're aware that in the letters sent on your behalf to Mr. Combs, that you described this egg incident; are you aware of that?
DAWN RICHARD: Repeat the question. I'm sorry.
MS. WESTMORELAND: Are you aware in the letters sent on your behalf to Mr. Combs that the egg incident that you allegedly saw, that it's described, are you aware of that?
DAWN RICHARD: No, I'm not aware.
MS. WESTMORELAND: I'd like to show it to you to see if it would refresh your memory. Okay?
DAWN RICHARD: Okay.
MS. WESTMORELAND: Could you please pull up pre-marked defense exhibit 1500 just for the parties. Can you go to page 7, paragraph 2.
MS. WESTMORELAND: Ms. Richard, could you please read that to yourself and, once you're finished, please look up at me.
DAWN RICHARD: Okay.
MS. WESTMORELAND: Are you done?
DAWN RICHARD: Yes, ma'am.
MS. WESTMORELAND: Were you aware that your allegation here was described as you --
MS. STEINER: Objection.
THE COURT: Sustained.
MS. WESTMORELAND: Did you ever make the statement that you heard a pan hit the wall, you didn't see it?
DAWN RICHARD: I don't recall.
MS. WESTMORELAND: Does looking at that document refresh your memory?
DAWN RICHARD: I don't recall that, though, writing that.
MS. WESTMORELAND: Are you aware that that was said on your behalf?
MS. STEINER: Objection.
THE COURT: That's sustained.
MS. WESTMORELAND: Let's go back. You hired civil lawyers, correct?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And you hired civil lawyers to enter into a litigation on your behalf, correct?
DAWN RICHARD: Right.
MS. WESTMORELAND: And you are aware that civil lawyers reached out to lawyers in reference to Mr. Combs, you're aware of that, right?
DAWN RICHARD: I'm not aware of that. I'm sorry.
MS. WESTMORELAND: You're aware that they filed a lawsuit on your behalf?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And you are aware that, in the civil proceedings, they litigated on your behalf, correct?
DAWN RICHARD: Can you, again, give it to me where I understand it. I'm sorry.
MS. WESTMORELAND: Sure. You hire lawyers to represent you, right?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And you understand what a civil suit is, correct?
DAWN RICHARD: Correct.
MS. WESTMORELAND: That's when you're suing someone?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And you're asking for money?
DAWN RICHARD: Correct.
MS. WESTMORELAND: You understand that?
DAWN RICHARD: I'm asking for compensation for the work that I had.
MS. WESTMORELAND: Compensation, money, whatever term you'd like to use, that's what you're asking for, right?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And you hire a lawyer to do that for you, that's what you did?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And so you understand that lawyers make claims on your behalf?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And you understand that when you hire civil lawyers, they make claims on your behalf?
DAWN RICHARD: Correct.
MS. WESTMORELAND: To seek for your compensation?
DAWN RICHARD: Okay.
MS. WESTMORELAND: And are you aware that, on your behalf, the incident you described was that you heard --
MS. STEINER: Objection.
THE COURT: That's sustained.
MS. WESTMORELAND: Ms. Richard, let me ask you this: you sat down with the federal government on October 31st, 2024, didn't you?
DAWN RICHARD: I don't remember the date. I'm sorry.
MS. WESTMORELAND: May I show you something to help refresh your memory?
DAWN RICHARD: Please, yes. Thank you.
MS. WESTMORELAND: Could you please, for the parties only, pull doc 3574.006.
MS. WESTMORELAND: Do you see the highlighted date?
DAWN RICHARD: I see the highlighted date.
MS. WESTMORELAND: You can pull that down for now.
MS. WESTMORELAND: You understand that when you went in to interview with the government that there was someone there taking notes?
DAWN RICHARD: Yes.
MS. WESTMORELAND: And the government, during these interviews, the government would ask you questions, right?
DAWN RICHARD: Correct.
MS. WESTMORELAND: You would answer them?
DAWN RICHARD: Yes.
MS. WESTMORELAND: Now that you had the chance to look at that document, does that help refresh your memory that you met with the government on October 31st, 2024?
DAWN RICHARD: It doesn't help me because I don't know what that document -- like, I've never seen that document before.
MS. WESTMORELAND: Do you have any reason to disagree with me that you met with the government?
DAWN RICHARD: I was saying I didn't see that.
MS. WESTMORELAND: No worries. No worries. I want to get to the substance of it. When you met with the government, didn't you tell them that Mr. Combs actually hit Ms. Ventura with a frying pan?
DAWN RICHARD: I said he attempted to hit her with a frying pan.
MS. WESTMORELAND: I didn't ask you that. Did you actually tell the government not that he attempted to hit her, that he did hit her?
DAWN RICHARD: Yes.
MS. WESTMORELAND: You told the government that?
DAWN RICHARD: That he hit her, yes.
MS. WESTMORELAND: And you agree with me that there's a major difference between attempting to hit someone with a frying pan and actually hitting them, you agree with that?
DAWN RICHARD: Yes.
MS. WESTMORELAND: And you understood that when you were sitting down with the federal prosecutors, that it was very important for you to tell the truth?
DAWN RICHARD: Yes.
MS. WESTMORELAND: And you understood that it was important for you to be as accurate as possible?
DAWN RICHARD: To the best of my ability, yes.
MS. WESTMORELAND: And you understand, testifying today, that you're under oath?
DAWN RICHARD: Yes.
MS. WESTMORELAND: And you know that you need to tell the ladies and gentlemen of this jury the truth?
DAWN RICHARD: Absolutely.
MS. WESTMORELAND: And you would agree with me that there is a difference between hitting someone with a frying pan and throwing a frying pan, correct?
DAWN RICHARD: Correct.
MS. WESTMORELAND: But you gave two different stories, didn't you?
DAWN RICHARD: I did the best that I could to recall.
MS. WESTMORELAND: How about, you gave another interview. Would you have reason to disagree with me that your next interview was on March 18, 2025?
DAWN RICHARD: I wouldn't disagree with you. That sounds right.
MS. WESTMORELAND: And in that interview, isn't it true that you told the federal prosecutors that Mr. Combs actually threw eggs at Ms. Ventura?
DAWN RICHARD: No, I don't recall that.
MS. WESTMORELAND: You don't recall that? And that after throwing eggs at Ms. Ventura, that he actually set the pan back down. Do you remember saying that?
DAWN RICHARD: I don't recall that.
MS. WESTMORELAND: Let me show you something to help refresh your memory. Okay?
DAWN RICHARD: Thank you.
MS. WESTMORELAND: Can you please publish only for the parties 3574.007. Can you please go down to page 4, first open bullet point. Can you highlight that section right there. Thank you very much.
MS. WESTMORELAND: Please read that to yourself and then look up at me when you're done. Are you done?
DAWN RICHARD: I am.
MS. WESTMORELAND: Does it refresh your memory that you actually told the prosecutors that Mr. Combs didn't hit her with the pan at all?
DAWN RICHARD: I don't recall saying that. I'm sorry.
MS. WESTMORELAND: And isn't it true that you told the prosecutors, now with reading that, that he actually threw eggs at her?
DAWN RICHARD: I don't recall saying it.
MS. WESTMORELAND: You don't recall saying that?
DAWN RICHARD: Uh-uh.
MS. WESTMORELAND: And we discussed that when you had these interviews, that there was a note taker, right?
DAWN RICHARD: Yes.
MS. WESTMORELAND: You agree that throwing eggs and then setting the pan down is different than hitting someone with a pan, right?
DAWN RICHARD: I do.
MS. WESTMORELAND: And you agree that hitting someone with a pan is very different than attempting to hit someone with a pan, right?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And you agree that hearing a pan thrown against the wall is different than all three of the other ways, right?
DAWN RICHARD: Correct.
MS. WESTMORELAND: Ms. Richard, let me just ask you, would you agree with me that it's been hard for you to keep your story the same in reference to this egg incident?
MS. STEINER: Objection.
THE COURT: It's overruled.
DAWN RICHARD: No, I wouldn't agree with that.
MS. WESTMORELAND: You would agree that you told multiple different stories, though?
DAWN RICHARD: No, I would agree that I told it to the best of my recollection and it was as close as I could give it.
MS. WESTMORELAND: To the best of your recollection, you have about four different recollections on what may have happened that day?
DAWN RICHARD: No, I don't.
MS. WESTMORELAND: Let's talk about the day after.
DAWN RICHARD: Okay.
MS. WESTMORELAND: Now, you testified on Friday and you furthered that testimony today, and you explained to us that Mr. Combs called you to the studio the next day, right?
DAWN RICHARD: He did.
MS. WESTMORELAND: And that you went to the studio, Mr. Combs locked the door, and he told you this was a love and passion thing, right?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And then he told you, you better not say anything, and -- excuse me. He told you and Ms. Harper, right? Ms. Harper was there?
DAWN RICHARD: Yes.
MS. WESTMORELAND: And he told both of you, you better not say anything because where I'm from, people go missing?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And that's what you told the ladies and gentlemen of the jury in this court, that's what you said?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And that's the truth?
DAWN RICHARD: That's the truth.
MS. WESTMORELAND: Now, testifying Friday and today, that's not the first time that you've had the opportunity to explain that alleged incident, right?
DAWN RICHARD: Correct.
MS. WESTMORELAND: Because you sat down with the prosecutors on numerous occasions, right?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And you remember them asking you about this?
DAWN RICHARD: Correct.
MS. WESTMORELAND: October 31st, 2024, we're going back to what you don't argue with me is the first interview, okay?
DAWN RICHARD: Okay.
MS. STEINER: Objection.
THE COURT: It's overruled.
MS. WESTMORELAND: Now, isn't it true that at that interview, during that interview, you explained to the prosecutors that Mr. Combs told you that this was nothing but a love argument, right, no one was hurt?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And you did not tell the prosecutors that Mr. Combs told you, where I'm from, people go missing?
DAWN RICHARD: Can I see what you're saying, because --
MS. WESTMORELAND: Absolutely.
DAWN RICHARD: Thank you.
MS. WESTMORELAND: Could you please pull 3574.006, page 6, first paragraph. Can you highlight the first paragraph, please.
MS. WESTMORELAND: Please read to yourself and look up at me when you're done. That whole line, please. Thank you. You're done?
DAWN RICHARD: Mhm.
MS. WESTMORELAND: Does that refresh your memory that you did not tell the federal prosecutors that Mr. Combs told you, people go missing?
DAWN RICHARD: I always state what I've stated. So if not, it's not my recollection that wasn't stated, but that was what happened.
MS. WESTMORELAND: So you agree with that if you stated that, the prosecutors didn't write that down?
MS. STEINER: Objection.
DAWN RICHARD: No.
THE COURT: That's sustained.
MS. WESTMORELAND: You didn't see it there?
MS. STEINER: Objection.
THE COURT: That's sustained.
MS. WESTMORELAND: Let's go to your interview on 3/18/2025, that's your next interview.
DAWN RICHARD: Okay.
MS. WESTMORELAND: Okay?
DAWN RICHARD: Okay.
MS. WESTMORELAND: And isn't it true in that interview, you stated that Mr. Combs said this was a love thing, no one was hurt, right, and that you did not say anything about Mr. Combs told you, people go missing?
DAWN RICHARD: Is there -- what was the question?
MS. WESTMORELAND: You didn't tell prosecutors that on 3/18/2025; isn't that true?
DAWN RICHARD: No, that's not true. I don't recall not saying that.
MS. WESTMORELAND: I'm going to show you a document to refresh your memory.
DAWN RICHARD: Thank you.
MS. WESTMORELAND: Can you please pull 3574.007. This is for the parties. Page 5, second bullet point.
MS. WESTMORELAND: You done?
DAWN RICHARD: I'm done.
MS. WESTMORELAND: Isn't it true, Ms. Richard, that you told the prosecutors that you were in the studio --
MS. STEINER: Objection.
THE COURT: Ms. Westmoreland, can you start again and maybe rephrase the question.
MS. WESTMORELAND: Sure. No worries. Thank you.
MS. WESTMORELAND: I'll ask you one question: you didn't tell the prosecutors on 3/18/2025, your second interview, that Mr. Combs told you, people go missing?
DAWN RICHARD: I tell my story as I remember it.
MS. WESTMORELAND: So on that day, you just didn't remember that Mr. Combs told you that people go missing, a comment that you said meant that you could die?
MS. STEINER: Objection.
THE COURT: That's overruled.
DAWN RICHARD: I spoke as best as I could as I remember it. It was a long time ago. I'm doing my best to understand these questions as best I can.
MS. WESTMORELAND: Let me ask you this: when you were in that room with the federal prosecutors, Mr. Combs was not there, right?
DAWN RICHARD: No.
MS. WESTMORELAND: And none of his lawyers were there?
DAWN RICHARD: No.
MS. WESTMORELAND: And you felt safe in the room with federal prosecutors?
DAWN RICHARD: Yes, ma'am.
MS. WESTMORELAND: And you know it was important to tell the truth?
DAWN RICHARD: Yes.
MS. WESTMORELAND: You know it was important to try to be accurate?
DAWN RICHARD: Yes.
MS. WESTMORELAND: The prosecutors were asking you questions?
DAWN RICHARD: Yes.
MS. WESTMORELAND: You were answering them?
DAWN RICHARD: Yes, ma'am.
MS. WESTMORELAND: You spoke about this particular incident in detail, right?
DAWN RICHARD: Yes, ma'am.
MS. WESTMORELAND: I mean, they asked you questions and you answered them?
DAWN RICHARD: To the best of my ability.
MS. WESTMORELAND: Right. And you would agree that you alleging Mr. Combs threatened you was something that you would want to tell the United States federal government, right?
DAWN RICHARD: Yes, ma'am.
MS. WESTMORELAND: And although that's what you're saying here in trial, you would agree with me that even in your second interview, you didn't mention that?
MS. STEINER: Objection.
THE COURT: It's overruled.
MS. WESTMORELAND: Could you please answer the question.
DAWN RICHARD: What was the question?
MS. WESTMORELAND: You would agree with me you didn't mention that?
DAWN RICHARD: I, again, I mentioned it. Whether or not -- I don't know what the notes were taken. I don't know -- I can't know what the notes are going to be taken. Sorry.
MS. WESTMORELAND: You did another interview on April 17, 2025?
DAWN RICHARD: Okay.
MS. WESTMORELAND: Do you have a reason to disagree with that date?
DAWN RICHARD: No.
MS. WESTMORELAND: During that interview, you and the United States Government, you guys spoke about this incident that you're alleging, you spoke about it again, okay? Do you agree with that?
DAWN RICHARD: I would have to see the document.
MS. WESTMORELAND: No worries.
DAWN RICHARD: Thank you.
MS. WESTMORELAND: Could you please pull 3574.012, page 2, first paragraph.
MS. WESTMORELAND: Please look up at me when you're done.
DAWN RICHARD: I'm done.
MS. WESTMORELAND: You would agree with me that you discussed this alleged incident with prosecutors on 4/17/2025?
DAWN RICHARD: Yes, ma'am.
MS. WESTMORELAND: We're on our third interview?
DAWN RICHARD: Uh-huh.
MS. WESTMORELAND: Mr. Combs wasn't there?
DAWN RICHARD: No, he was not.
MS. WESTMORELAND: I wasn't there?
DAWN RICHARD: No.
MS. WESTMORELAND: None of his lawyers were there?
DAWN RICHARD: No, ma'am.
MS. WESTMORELAND: You felt safe in this interview?
DAWN RICHARD: Yes, ma'am.
MS. WESTMORELAND: You didn't tell the federal government that Mr. Combs told you, people go missing?
DAWN RICHARD: I told them exactly what my recollection of that event was.
MS. WESTMORELAND: So your recollection that day was that Mr. Combs didn't threaten you by telling you that people go missing?
DAWN RICHARD: He threatened me and said, people go missing.
MS. WESTMORELAND: I understand that's what you're testifying here. I'm asking you, you didn't tell the government that, on 4/17/2025, your third interview, correct?
DAWN RICHARD: I'm telling you I told them what I remembered.
MS. WESTMORELAND: So you just didn't remember the threat?
MS. STEINER: Objection.
MS. WESTMORELAND: Is that fair?
DAWN RICHARD: No, I remembered everything I'm telling you now.
MS. WESTMORELAND: Ms. Richard, you don't have a reason to disagree with me that you met the government on 10/31/2024, we talked about that, right?
DAWN RICHARD: Yes, ma'am.
MS. WESTMORELAND: You met the government on 3/18/2025, no disagreement there?
DAWN RICHARD: No, ma'am.
MS. WESTMORELAND: You met the government on 4/8/2025, no disagreement there?
DAWN RICHARD: Yes, ma'am.
MS. WESTMORELAND: You met the government on 4/17/2025, no disagreement there?
DAWN RICHARD: No, ma'am.
MS. WESTMORELAND: You met with the government on 4/9/2025, no disagreement there?
DAWN RICHARD: No disagreement there.
MS. WESTMORELAND: You met with the government on 5/10/2025, no disagreement there?
DAWN RICHARD: Yes, ma'am.
MS. WESTMORELAND: Ms. Richard, isn't it true that the first time that you mention and allege that Mr. Combs told you, people go missing, was a week ago on May 10th, 2025?
DAWN RICHARD: No, ma'am.
MS. WESTMORELAND: Would you like me to show you the rest of your interviews to refresh your recollection?
DAWN RICHARD: I know what I said, ma'am.
MS. WESTMORELAND: Now, you said that when Mr. Combs told you, people go missing, you took that to be a death threat?
DAWN RICHARD: Yes, ma'am.
MS. WESTMORELAND: That's what you're telling us, right?
DAWN RICHARD: Yes, ma'am.
MS. WESTMORELAND: A death threat that you didn't recall on seven different occasions?
MS. STEINER: Objection.
THE COURT: That's sustained.
MS. WESTMORELAND: Let's move on. Ms. Richard, you testified to some other incidents that you allegedly witnessed, right?
DAWN RICHARD: Yes, ma'am.
MS. WESTMORELAND: Now, you told us about a restaurant, right?
DAWN RICHARD: Yes, ma'am.
MS. WESTMORELAND: And that Ms. Ventura and Mr. Combs were arguing and that he hit her?
DAWN RICHARD: Yes, ma'am.
MS. WESTMORELAND: Please tell me who all was at this restaurant.
DAWN RICHARD: Harve Pierre, Capricorn Clark, Mia and myself, Kaleena, our body guards, which was Bonds and D-Roc, Cassie.
MS. WESTMORELAND: Now, you've spoken about that incident before, right?
DAWN RICHARD: I have.
MS. WESTMORELAND: And you remember being asked who was all there, right?
DAWN RICHARD: Mhm.
MS. WESTMORELAND: Do you recall alleging several celebrities was actually there?
DAWN RICHARD: Yes.
MS. WESTMORELAND: So when the government asked you who was all there and I asked you who was all there right now, you didn't mention any of the celebrities, right?
DAWN RICHARD: Right.
MS. WESTMORELAND: Please recall those celebrities now.
DAWN RICHARD: Usher was there, Jimmy Iovine was there, Ne-Yo came through. There were a few others, too. I don't recall those people, but those are the ones I remember talking to.
MS. WESTMORELAND: Those are the ones you remember talking to. Any reason why you left those individuals out when I asked you the question?
DAWN RICHARD: I just -- I thought you were recalling what I mentioned here, asked me to give you the names of the people I mentioned here.
MS. WESTMORELAND: Any reason you left those individuals out when the government asked you the question?
MS. STEINER: Objection.
THE COURT: It's overruled.
DAWN RICHARD: She just asked me who was there.
MS. WESTMORELAND: And if those individuals were there, why didn't you say their name?
DAWN RICHARD: I'm not sure.
MS. WESTMORELAND: Okay. You told us about an incident in a car leaving the festival. Do you remember that?
DAWN RICHARD: Yeah. Wait, no, not -- in the car leaving the festival, no.
MS. WESTMORELAND: Today is not your first day discussing these other alleged situations that you saw, right?
DAWN RICHARD: Correct.
MS. WESTMORELAND: Spoke about that, too, with the prosecutors, correct?
DAWN RICHARD: Correct.
MS. WESTMORELAND: Was there a time that you stated that you saw Mr. Combs pull Ms. Ventura out of the car, drag her in the grass, and everybody around saw it?
DAWN RICHARD: I never stated that.
MS. WESTMORELAND: You never stated that?
DAWN RICHARD: Uh-uh.
MS. WESTMORELAND: I'm going to show you something to help refresh your memory, okay?
DAWN RICHARD: Mhm.
MS. WESTMORELAND: Can you pull 3574.002. Actually, I want you to take that down for a second. I want to pull something else first. Can you pull 3574.016. Can you go to the next page. Go to page 1, first paragraph, yes, first bullet point right there. Thank you very much.
MS. WESTMORELAND: Can you please read that to yourself and then look up at me when you're done. You done?
DAWN RICHARD: Uh-huh.
MS. WESTMORELAND: During that interview, you remember having an interview with the government, right?
DAWN RICHARD: Yes.
MS. WESTMORELAND: In May?
DAWN RICHARD: Yes.
MS. WESTMORELAND: Just a week or two ago. And the government asked you about an allegation that was made on your behalf in your civil complaint, right?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And the government asked you about an allegation made on your behalf that Mr. Combs dragged Ms. Ventura out of the car, onto the grass in front of everyone, correct?
DAWN RICHARD: Correct.
MS. WESTMORELAND: Because that was in your complaint, right?
DAWN RICHARD: That was a misquote from a lawyer in my complaint.
MS. WESTMORELAND: And so you explained to the government that that didn't happen?
DAWN RICHARD: Correct.
MS. WESTMORELAND: Now, you told us about an incident that you allege occurred at a festival, right?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And you agree with me that, at that festival, Ms. Harper was there, right?
DAWN RICHARD: Correct.
MS. WESTMORELAND: Isn't it true that at the festival, you were being filmed, you, Ms. Ventura, and Ms. Harper were being filmed the whole time?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And so there's video, to your knowledge, of this whole vent, right?
DAWN RICHARD: Yes.
MS. WESTMORELAND: You have video?
DAWN RICHARD: No.
MS. WESTMORELAND: But you're aware that there is video?
DAWN RICHARD: Yes.
MS. WESTMORELAND: Are you aware of whether that video has been turned over to the prosecution's office?
DAWN RICHARD: No.
MS. STEINER: Objection.
THE COURT: It's overruled.
MS. WESTMORELAND: I couldn't hear you. Yes or no?
DAWN RICHARD: No.
MS. WESTMORELAND: Because you're aware that there was video, and you made an allegation that Mr. Combs punched Ms. Ventura, right?
DAWN RICHARD: Yes, in the bathroom.
MS. WESTMORELAND: So that was surely beyond the video, right?
DAWN RICHARD: No.
MS. WESTMORELAND: Well, camera crew was filming.
DAWN RICHARD: Okay.
MS. WESTMORELAND: You're aware there's video?
DAWN RICHARD: Okay.
MS. WESTMORELAND: And if something like what you described occurred -- you're not following me?
DAWN RICHARD: No, because we were filmed in the bathroom.
MS. WESTMORELAND: Right. You had to go out of the bathroom, right?
DAWN RICHARD: Yeah.
MS. WESTMORELAND: So at some point you had to go out of the bathroom, you spent all day at this festival, right?
DAWN RICHARD: Correct.
MS. WESTMORELAND: With a camera crew filming all day?
DAWN RICHARD: Correct.
MS. WESTMORELAND: Now, for these alleged times that you said you saw different situations, you'd agree with me that you were never with Mr. Combs alone, right? There was someone else with you?
DAWN RICHARD: What do you mean by -- just the incidents I've named, yes.
MS. WESTMORELAND: Let's just stick to those. The incidents that you named, there was someone always with you, right?
DAWN RICHARD: Yes.
MS. WESTMORELAND: You've provided those individuals' names to the prosecution?
DAWN RICHARD: Yes.
MS. WESTMORELAND: And we can both agree that during all of the allegations of what you said that you saw happen with Cassie, that Ms. Harper, that she was with you, right?
DAWN RICHARD: Yes.
MS. WESTMORELAND: She was with you at the festival?
DAWN RICHARD: Yes.
MS. WESTMORELAND: You told the ladies and gentlemen of this jury she was with you in this car?
DAWN RICHARD: Yes.
MS. WESTMORELAND: She was with you at the restaurant?
DAWN RICHARD: Yes.
MS. WESTMORELAND: Ms. Richard, let's talk about guns. You testified about guns, right?
DAWN RICHARD: Yes.
MS. WESTMORELAND: Now, you would agree with me that Mr. Combs was a celebrity, right?
DAWN RICHARD: Yes.
MS. WESTMORELAND: And during the whole time that you had the opportunity to be around Mr. Combs and Bad Boys, he was a celebrity, right?
DAWN RICHARD: Yes.
MS. WESTMORELAND: And you once yourself had fame, right?
DAWN RICHARD: Yes.
MS. WESTMORELAND: And you would agree with me that it's common for celebrities to have body guards?
DAWN RICHARD: Yes.
MS. WESTMORELAND: And you would agree with me that part of the reason for celebrities to have body guards is to help protect them from danger?
DAWN RICHARD: Yes.
MS. WESTMORELAND: Now, you testified that you saw Mr. Combs with a gun?
DAWN RICHARD: Yes.
MS. WESTMORELAND: And I don't want to misquote you, you said a few times?
DAWN RICHARD: Yes.
MS. WESTMORELAND: You were around Mr. Combs from 2004 to 2011, pretty close proximity, you would say?
DAWN RICHARD: Yes.
MS. WESTMORELAND: So over several years, you saw a gun a few times?
DAWN RICHARD: Yes.
MS. WESTMORELAND: You told us once, studio, that's what you said?
DAWN RICHARD: The studio and sometimes the club.
MS. WESTMORELAND: Can you give us a little bit of detail, first time you saw a gun, tell us when, where, tell us about it.
DAWN RICHARD: Studio, New York, Daddy's house.
MS. WESTMORELAND: Second time.
DAWN RICHARD: Studio, New York, Daddy's house.
MS. WESTMORELAND: Third time.
DAWN RICHARD: In his house, New York.
MS. WESTMORELAND: Did you give those details to the government?
DAWN RICHARD: No.
DAWN RICHARD: No.
MS. WESTMORELAND: Eight interviews, right?
DAWN RICHARD: Mhm.
MS. WESTMORELAND: And during these interviews, the prosecutors asked you questions, right?
DAWN RICHARD: Mhm.
MS. WESTMORELAND: And you answered them?
DAWN RICHARD: Mhm.
MS. WESTMORELAND: And you spoke about guns?
DAWN RICHARD: Yes.
MS. WESTMORELAND: This question-answer session?
DAWN RICHARD: Yes.
MS. WESTMORELAND: And out of eight interviews, you didn't tell the prosecution, hey, I saw a gun, it was at the studio at daddy's house, you didn't tell them that?
DAWN RICHARD: I answered what was asked of me.
MS. WESTMORELAND: They didn't ask you any detail?
DAWN RICHARD: That wasn't asked at the time.
MS. WESTMORELAND: Well, when you say at the time, I'm talking about eight times.
DAWN RICHARD: It wasn't asked. I'm sorry.
MS. WESTMORELAND: Okay. Thank you for that. Let me ask a few questions.
DAWN RICHARD: Okay.
MS. WESTMORELAND: You never saw Mr. Combs pull a gun out and like wave it around, right?
DAWN RICHARD: No.
MS. WESTMORELAND: You never saw Mr. Combs like pull a gun out and like cock it back or anything?
DAWN RICHARD: No.
MS. WESTMORELAND: You never saw Mr. Combs like load bullets in a gun or anything like that?
DAWN RICHARD: No.
MS. WESTMORELAND: Matter of fact, you've never seen Mr. Combs pull a gun out, period?
DAWN RICHARD: Just had it on him.
MS. WESTMORELAND: Just had it on him?
DAWN RICHARD: Mhm.
MS. WESTMORELAND: In the back?
DAWN RICHARD: Mhm.
MS. WESTMORELAND: I want to ask you about your testimony regarding drugs. Okay?
DAWN RICHARD: Okay.
MS. WESTMORELAND: You saw Mr. Combs do drugs?
DAWN RICHARD: Yes.
MS. WESTMORELAND: You did drugs, too, right?
DAWN RICHARD: Weed, yes.
MS. WESTMORELAND: You ever pretend to do some other drugs?
DAWN RICHARD: Yes.
MS. WESTMORELAND: But you didn't actually do them?
DAWN RICHARD: No.
MS. WESTMORELAND: You were putting on a facade?
DAWN RICHARD: Yes.
MS. WESTMORELAND: Now, I want to make sure that this is your testimony. You stated today that you've never seen Mr. Combs do cocaine, right?
MS. STEINER: Objection.
THE COURT: Sustained.
MS. STEINER: Misstates the testimony.
MS. WESTMORELAND: You've never saw Mr. Combs do cocaine, right?
THE COURT: That's sustained.
MS. WESTMORELAND: I'm asking, have you ever seen Mr. Combs do cocaine?
DAWN RICHARD: Yes.
MS. WESTMORELAND: You have. Okay. Was there a time that you told the government in interviews that you've never seen Mr. Combs do cocaine?
DAWN RICHARD: I don't recall that.
MS. WESTMORELAND: Let me help refresh your memory.
DAWN RICHARD: Thank you.
MS. WESTMORELAND: Can you please pull doc 3574.006, please. Can you take us to page 7. This is just for the parties. First bullet point, can you highlight that.
MS. WESTMORELAND: Ms. Richard, can you please read that to yourself and when you're finished, please look up at me. You done?
DAWN RICHARD: Mhm.
MS. WESTMORELAND: Did that refresh your memory?
DAWN RICHARD: It did.
MS. WESTMORELAND: So, I'll ask you again, isn't it true that you told the government that you've never seen Mr. Combs do cocaine?
DAWN RICHARD: At the time I hadn't recalled that, no.
MS. WESTMORELAND: I'm sorry. At the time that you did the interview on 10/31, you hadn't recalled that?
DAWN RICHARD: No, I hadn't.
MS. WESTMORELAND: But the government asked you about Mr. Combs's drug usage, right?
DAWN RICHARD: They did.
MS. WESTMORELAND: And you didn't say to the government, hey, I don't know?
DAWN RICHARD: No, I didn't say that.
MS. WESTMORELAND: You actually said, Mr. Combs did not do --
MS. STEINER: Objection.
THE COURT: I think there was a withdrawn objection. Can you re-ask the question.
MS. WESTMORELAND: You didn't say, I don't know if Mr. Combs does cocaine, right?
DAWN RICHARD: I didn't say.
MS. WESTMORELAND: You told the government, Mr. Combs, I've never, never seen him do cocaine, that's what you said?
DAWN RICHARD: Yes.
MS. WESTMORELAND: And you would agree with me that your testimony has changed on that?
DAWN RICHARD: It has.
MS. WESTMORELAND: I mean, you would agree with me at this point that your testimony's changed on quite a few things?
DAWN RICHARD: I think I'm, as time progresses, I get better with knowing it because it was so long ago.
MS. WESTMORELAND: So you would agree with me that as time progresses, your story changes?
DAWN RICHARD: Yes.
MS. WESTMORELAND: Now, you testified to the ladies and gentlemen of the jury that you would see an individual by the name of One Stop?
DAWN RICHARD: Yes.
MS. WESTMORELAND: And that he would come to the studio?
DAWN RICHARD: Yes.
MS. WESTMORELAND: And that you witnessed him sell drugs?
DAWN RICHARD: Yes.
MS. WESTMORELAND: That's what you said?
DAWN RICHARD: Yes.
MS. WESTMORELAND: This is not the first time you had an opportunity to discuss this subject, right?
DAWN RICHARD: Mhm.
MS. WESTMORELAND: And isn't it true that you've never seen One Stop actually sell drugs?
DAWN RICHARD: No, I've seen One Stop sell drugs.
MS. WESTMORELAND: Who did you see give One Stop money?
DAWN RICHARD: That varied. It could be an assistant or it could be Puff giving the assistant money to pay for it.
MS. WESTMORELAND: You said could be, I'm not asking you to speculate, that's not allowed here. I'm asking you to answer the question, if you know.
DAWN RICHARD: Yeah, I've seen him give money, an assistant give money to One Stop and he would give drugs.
MS. WESTMORELAND: Can you please pull doc 3574.015, page 2. This is just for the parties. Take us down to the third bullet point. And please highlight the last open bullet point, just the last open bullet point, please. Thank you.
MS. WESTMORELAND: Ms. Richard, please read that to yourself and look up at me when you're done. Isn't it true that you had an interview with the government, right?
DAWN RICHARD: Mhm.
MS. WESTMORELAND: And you discussed One Stop?
DAWN RICHARD: Mhm.
MS. WESTMORELAND: They asked you questions? They, meaning the government.
DAWN RICHARD: Yes.
MS. WESTMORELAND: You answered questions?
DAWN RICHARD: Yes.
MS. WESTMORELAND: You knew to tell the truth?
DAWN RICHARD: Yes.
MS. WESTMORELAND: And whether you had witnessed One Stop selling drugs?
DAWN RICHARD: Mhm.
MS. WESTMORELAND: That subject was discussed?
DAWN RICHARD: It was.
MS. WESTMORELAND: And isn't it true that you told the government you never saw --
MS. STEINER: Objection.
THE COURT: Overruled.
MS. WESTMORELAND: Isn't it true that you told the government that you never saw anyone give payment to One Stop?
DAWN RICHARD: Yes.
MS. WESTMORELAND: You didn't know who paid for the drugs?
DAWN RICHARD: Correct.
MS. WESTMORELAND: Right. So when you testified today in front of the ladies and gentlemen of the jury that you saw One Stop sell drugs, that you saw Mr. Combs pay him for drugs, that was a lie?
MS. WESTMORELAND: So you agree with me that what you're testifying to today is different than what you told the government in that interview?
DAWN RICHARD: Correct.
MS. WESTMORELAND: Another story change?
DAWN RICHARD: Not a story change, but yes, different.
MS. WESTMORELAND: Ms. Richard, I don't know the exact count, but at this point, you would agree with me we have several story changes?
MS. STEINER: Objection.
THE COURT: That's sustained.
MS. WESTMORELAND: Let's talk about your testimony in reference to how threatened you felt by Mr. Combs. You were scared?
DAWN RICHARD: Yes.
MS. WESTMORELAND: Very?
DAWN RICHARD: Yes.
MS. WESTMORELAND: So, Ms. Richard, you separated in 2011, meaning you went on as a solo artist, right?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And so you were no longer with or around Mr. Combs like that, right?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And I mean, you being pretty scared and so fearful, in fear of your life, after 2011, you were away from him, right?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And I'm sure you being pretty fearful and scared of him, that once you were able to get away from him, you definitely wouldn't want to come back, right?
DAWN RICHARD: Correct.
MS. WESTMORELAND: But you would agree with me that you actually asked Mr. Combs to come back, didn't you?
DAWN RICHARD: Not to come back, no.
MS. WESTMORELAND: Can you please pull up for the parties defense exhibit 1501.
MS. WESTMORELAND: Ms. Richard, I'm going to ask you to look at the top of this document. Do you know what this is?
DAWN RICHARD: Yes, I do.
MS. WESTMORELAND: Looks familiar to you?
DAWN RICHARD: Yes.
MS. WESTMORELAND: And you would agree that this is a text message exchange?
DAWN RICHARD: Yes, it is.
MS. WESTMORELAND: Accurate?
DAWN RICHARD: Yes.
MS. WESTMORELAND: At this time I move to admit defense exhibit 1501.
MS. STEINER: Objection. Hearsay.
MS. WESTMORELAND: Your Honor, this was ruled on.
THE COURT: Well, there was an issue that was ruled on, but let's have a very brief sidebar.
(Continued on next page)
(At the sidebar)
THE COURT: The issue that was previously raised had to go to the 803.3 issue of then state of mind. However, the way you've presented this is as an impeaching document. So that's a separate issue and I don't believe that the prerequisites have been satisfied yet that would permit you to put in the statement on those grounds.
MS. WESTMORELAND: Okay.
THE COURT: Ms. Steiner, do you have anything further?
MS. STEINER: No.
THE COURT: I understand that there was a different issue that was presented with this document and that's why I called the sidebar. So you can lay the foundation, go through the steps and try to introduce it as a prior inconsistent statement, but you have to ask the questions first.
(Continued on next page)
(In open court)
MS. WESTMORELAND: Ms. Richard, now, you gave testimony that after you left and you were separate from Mr. Combs, that he would reach out to you when you were -- he would reach out to you at certain moments is what you described. You testified that you would respond kindly, right?
DAWN RICHARD: Mhm.
MS. WESTMORELAND: And that you would only respond kindly because you figured out that was the best way to do so, right? Okay. But you also just testified that because were you in fear, right, I asked you about your fear?
DAWN RICHARD: Mhm.
MS. WESTMORELAND: And because you were finally able to -- or you were gone from Mr. Combs, that being in fear, that you wouldn't want to come back and work with him or be around him, right?
DAWN RICHARD: Correct.
MS. WESTMORELAND: That's what you said, right?
DAWN RICHARD: Correct.
MS. WESTMORELAND: Isn't it true that Mr. Combs didn't just reach out to you, you reached out to him?
DAWN RICHARD: Correct.
MS. WESTMORELAND: So you weren't just responding in kind, you were initiating conversation?
DAWN RICHARD: Once before, yeah.
MS. WESTMORELAND: Once?
DAWN RICHARD: When I say once before, I mean there was a time when I was asked by someone --
MS. WESTMORELAND: I'm going to stop you right there.
DAWN RICHARD: -- to contact Puffy --
MS. WESTMORELAND: I'm going to stop you right there. The government will get up and ask you questions and I'm asking you this question.
DAWN RICHARD: Yes, ma'am.
MS. WESTMORELAND: The question I'm asking you is: isn't it true that you initiated contact with Mr. Combs?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And I just want to make sure we are clear, because you said something about one time a second ago, so I want to make sure we're clear. You reached out to Mr. Combs on several different occasions, correct?
DAWN RICHARD: Yes.
MS. WESTMORELAND: And so you would agree with me that there is a difference between Mr. Combs reaching out to you and you responding to him, as opposed to you reaching out to him?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And you were so scared of him, right?
DAWN RICHARD: Yes.
MS. WESTMORELAND: So you would agree with me that you reached out to Mr. Combs and one of the reasons that you reached out to Mr. Combs was to work with him again?
DAWN RICHARD: Yes.
MS. WESTMORELAND: Ms. Richard, I want you to help us understand. Mr. Combs had threatened you?
DAWN RICHARD: Mhm.
MS. WESTMORELAND: You perceived the threats as death threats?
DAWN RICHARD: Yes.
MS. WESTMORELAND: Feared for your life?
DAWN RICHARD: Yes.
MS. WESTMORELAND: Scared?
DAWN RICHARD: Yes, ma'am.
MS. WESTMORELAND: You're away from him 2011, but then you ask him to come work with him again?
DAWN RICHARD: Mhm.
MS. WESTMORELAND: Now, Ms. Richard, you explained to us that your relationship with Mr. Combs started about 2004, right? And you testified Friday that you were in a group, Danity Kane, correct?
DAWN RICHARD: Yes, correct.
MS. WESTMORELAND: And you would agree with me that when you were a member of Danity Kane that you experienced fame by way of that, right?
DAWN RICHARD: Yes.
MS. WESTMORELAND: I mean, you would describe it as you couldn't walk the streets, you know, like a regular person?
DAWN RICHARD: I wouldn't describe it as that. I mean, we were young, so it was younger kids.
MS. WESTMORELAND: You've had this conversation with the government about Danity Kane, right?
DAWN RICHARD: Yup.
MS. WESTMORELAND: And in fame? You don't remember?
DAWN RICHARD: In fame, meaning like just us being famous?
DAWN RICHARD: Yeah, I mean, we were big.
MS. WESTMORELAND: You were big?
DAWN RICHARD: Yeah.
MS. WESTMORELAND: Right. And Danity Kane was dismantled in 2008, 2009?
DAWN RICHARD: Yes, in 2009, yeah.
MS. WESTMORELAND: And then after Danity Kane, Danity Kane was like a five-member group?
DAWN RICHARD: Yes.
MS. WESTMORELAND: And you named Danity Kane, right?
DAWN RICHARD: Yes.
MS. WESTMORELAND: And then Danity Kane was dismantled and then you were a member of the group Dirty Money, right?
DAWN RICHARD: Correct.
MS. WESTMORELAND: When you were a member of the group Dirty Money, that was you, Mr. Combs, and Ms. Harper?
DAWN RICHARD: Yeah.
MS. WESTMORELAND: So now Mr. Combs is actually a member in the group that you're in, right?
DAWN RICHARD: Yes.
MS. WESTMORELAND: And you would agree with me that Dirty Money did pretty good in the industry, right?
DAWN RICHARD: They did okay, yeah.
MS. WESTMORELAND: I mean, you would agree that Danity Kane and Dirty Money both went platinum?
DAWN RICHARD: Yeah, they went --
MS. WESTMORELAND: In case the ladies and gentlemen of the jury, explain platinum?
DAWN RICHARD: We sell a lot of records.
MS. WESTMORELAND: I mean, you would agree with me that Danity Kane sold 100,000 records in one day?
DAWN RICHARD: Yes.
MS. WESTMORELAND: 600,000 in a week?
DAWN RICHARD: Mhm.
MS. WESTMORELAND: Did pretty good.
DAWN RICHARD: Did pretty well.
MS. WESTMORELAND: Now, you testified Danity Kane stopped 2009, Dirty Money stopped in 2011?
DAWN RICHARD: Mhm.
MS. WESTMORELAND: And so that was the end of the music with Mr. Combs, correct?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And then I think the prosecutor asked you about what you had been doing since, right?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And you've released over 100 songs?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And you would agree with me that the songs that you've released haven't reached the levels of success as Dirty Money and Danity Kane, to mean no offense, but you agree with that, right?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And you agree with me that you actually asked Mr. Combs to sign you as a solo artist?
DAWN RICHARD: Before I left.
MS. WESTMORELAND: Before you left, right, about 2011?
DAWN RICHARD: Mhm.
MS. WESTMORELAND: And he told you no?
DAWN RICHARD: Yeah.
MS. WESTMORELAND: And you agree with me that you've reached out to Mr. Combs after you were gone and asked him to come back and do work with him, right?
DAWN RICHARD: Correct.
MS. WESTMORELAND: I mean as recently as the years 2020, 2021, right?
DAWN RICHARD: To work together as Dirty Money?
MS. WESTMORELAND: Just work together, period.
DAWN RICHARD: Yeah. Yes.
MS. WESTMORELAND: You have?
DAWN RICHARD: Yes.
MS. WESTMORELAND: And the endeavors that you were trying to do with Mr. Combs more recently, those didn't work out, you didn't end up working with him, right? So you would agree with me that you felt like Mr. Combs had no legitimate reason to dismantle the previous groups that you were in, you would agree with that, right?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And you would agree with me -- I mean, you've given plenty of interviews in reference to your feelings on Dirty Money and Danity Kane being dismantled, right?
DAWN RICHARD: Correct.
MS. WESTMORELAND: So you felt Mr. Combs had no legitimate reason to do that?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And you would agree with me or admit that you were angry about it?
DAWN RICHARD: Saddened by it.
MS. WESTMORELAND: Saddened by it. Because you would agree that you felt like Mr. Combs ruined your career, not once, but twice?
DAWN RICHARD: Yes.
MS. WESTMORELAND: And then Mr. Combs had the audacity to not sign you as a solo artist, you felt like that?
DAWN RICHARD: Yeah, I didn't care about that.
MS. WESTMORELAND: You didn't care?
DAWN RICHARD: Yeah, whether he signed me.
MS. WESTMORELAND: Music is your dream?
DAWN RICHARD: Yes.
MS. WESTMORELAND: And you've been trying to succeed at it for a long time?
DAWN RICHARD: I did succeed at it.
MS. WESTMORELAND: In the past?
DAWN RICHARD: Now.
MS. WESTMORELAND: Ms. Richard, November 2023, you saw Ms. Ventura had filed suit against Mr. Combs?
DAWN RICHARD: Correct.
MS. WESTMORELAND: You read her complaint?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And shortly after Ms. Ventura filed suit, you filed suit yourself, right?
DAWN RICHARD: Correct.
MS. WESTMORELAND: And it is your want to get a lot of money from Mr. Combs, correct?
MS. WESTMORELAND: So you're not filing a lawsuit to get money?
DAWN RICHARD: I'm filing a lawsuit to get compensated for the work that I've put forth.
MS. WESTMORELAND: And you would agree with me that your definition of compensation is money?
DAWN RICHARD: Yes, correct.
MS. WESTMORELAND: I have no further questions.
MS. STEINER: Your Honor, may we please have a sidebar?
THE COURT: You may.
(Continued on next page)