Attorney in Diddy Case Risks Contempt for AI Citation Blunder

A Brooklyn attorney litigating a sexual assault case against Sean “Diddy” Combs and Universal Music Group is at risk of being held in contempt over his failure to pay a $6,000 sanction for relying on a fake AI-generated citation.

Tyrone Anthony Blackburn, who represents plaintiff Liza Gardner in her case alleging she was raped by Combs and R&B singer Aaron Hall in 1990 when she was 16 years old, failed to meet the first two $500 installment payments that were due in March and April and didn’t notify the court of his inability to meet the deadlines.

The court only found out about the nonpayment “through its own inquiry” at an April 13 status conference, said Judge Leo M. Gordon of the US Court of International Trade, sitting by designation in the US District Court for the District of New Jersey.

In a May 11 hearing, Blackburn will have to argue why he shouldn’t be held in contempt. He’ll also need to produce his financial records to show whether he can pay the sanctions.

Gordon issued the sanctions in December after Blackburn relied on the non-existent case United States v. Masha to argue against dismissing UMG from the case. Blackburn specifically argued the music company knew about Combs’ and Hall’s prior sexual misconduct and failed to prevent known risks, making them complicit in the abuse under the Mann Act that prohibits transporting anyone across state lines for the purpose of prostitution or sexual activity.

The judge dismissed UMG from the case in January.

Blackburn told the judge in an April conference call and in a May email that he can’t afford to pay the $500 monthly payments. Gordon on Thursday said he “remains concerned about Mr. Blackburn’s inability to comply with court directives, meet deadlines, and communicate effectively in circumstances where compliance may not be possible.”

Sher Tremonte LLP represents Combs.

The case is Gardner v. Combs, D.N.J., No. 2:24-cv-07729, 5/7/26.