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Sean Combs made a plea for “fairness” ahead of his Oct. 3 sentencing, arguing in a new brief that he deserves no more than 14 months in prison for his two felony convictions for transportation to engage in prostitution.

In the 182-page sentencing memo submitted Monday shortly before the midnight deadline, Combs’ lawyers laid out his life story in an apparent bid for mercy, saying Combs struggled as a child after his father was murdered when he was only three years old. They argued the loss caused a “profound form of trauma” that set the stage for the substance abuse issues Combs wrestled with during his admittedly violent relationships with the two ex-girlfriends involved in his convictions.

“For decades, Mr. Combs struggled with serious substance abuse issues, anger and anxiety, and other flaws that he did not properly or professionally address until his incarceration last year,” the filing obtained by Rolling Stone stated. “Like every addict, his behavior while on painkillers was erratic and unpredictable, and often the reason behind any assaults discussed at the trial.”

His lawyers also attached more than 75 letters of support from family and friends, including Combs’ mother Janice; his sister Keisha; his three teen daughters, Chance, Jessie and D’Lila; and Dana Tran, the mother of Comb’s two-year-old daughter, Love.

Combs, 55, was convicted of the two felony counts on July 2 after a nine-week trial. Jurors rejected a trio of more serious charges, finding that prosecutors failed to prove Combs ran a racketeering conspiracy or sex trafficked two former girlfriends. The acquittals meant Combs was no longer facing the possibility of life in prison. At the time, the mogul pumped his fist and dropped to his knees as he celebrated in the courtroom.

The two prostitution charges, violations of a century-old law known as the Mann Act, each carry a maximum sentence of 10 years in federal prison. For their part, prosecutors previously estimated Combs’ sentencing guidelines range was around four to five years behind bars. Their formal recommendation could be much higher when they file their separate sentencing brief due Sept. 29.

Combs, who has served a year in custody, argued in his filing that a review of more than 60 other Mann Act cases determined that the average sentence was 14.9 months of incarceration. Combs and his lawyers claimed it would be “unlawful and a perversion of justice” if the court increases the sentence beyond 14 months based on “the court’s own findings about force or coercion or racketeering.”

Federal judges aren’t required to follow guidelines. In the Southern District of New York, judges stuck to guideline ranges 34.5 percent of the time in the last fiscal year, according to the U.S. Sentencing Commission.

U.S. District Judge Arun Subramanian will have wide latitude at the Oct. 3 sentencing, and it’s not clear how he’ll rule. But on the day of the verdict, when many speculated that Combs’ acquittal on the top charges would lead to his immediate release on bail pending sentencing, Judge Subramanian took a hard line. He denied the release on the basis that Combs’ defense admitted during trial that Combs was violent with his ex-partner Casandra “Cassie” Ventura, and a more recent ex-girlfriend who testified under the pseudonym Jane. In his closing argument, lead defense lawyer Mark Agnifilo explicitly told jurors that the defense wasn’t challenging the women’s claims of domestic violence.

“In terms of owning, just as a matter of personal responsibility … owning the domestic violence, we own it. It happened,” Agnifilo told the panel in his final address on June 27. “If he was charged with domestic violence, we wouldn’t all be here having a trial, because he would have pled guilty – because he did that.”

Rejecting the defense bid for immediate bail on July 2, Subramanian pointed to the disturbing video of Combs’ 2016 assault of Ventura inside L.A.’s now-shuttered InterContinental Hotel before sending a seemingly stunned Combs back into custody. Taking a serious tone, Subramanian also noted the video wasn’t the only violence acknowledged by the defense. He pointed to the days Ventura spent at the London Hotel in Los Angeles to recover after Combs allegedly stomped on her face in a vehicle. (“Obviously, there was some physical event, and she had injuries, okay? So she goes to the hotel as much for her own good as anyone else’s,” Agnifilo told jurors about the fight that landed Ventura at the London Hotel.)

“This type of violence, which happens behind closed doors in personal relationships, sparked by unpredictable bouts of anger, is impossible to police with conditions,” the judge said July 2. Turning to the June 2024 incident at Jane’s house, where, according to Agnifilo, Combs admittedly kicked Jane and restrained her “around the neck” during a blowout fight, the judge called out the timing. He noted the incident came after Combs’ homes were raided by federal authorities in March 2024. “At a time when [Combs] should have known that he needed to stay clean,” the mogul instead showed “a disregard for the rule of law and the propensity for violence,” the judge said.

Combs has been held at Brooklyn’s Metropolitan Detention Center (MDC) since his arrest last September. In a separate motion set for a hearing later this week, Combs is asking that his conviction be set aside as a matter of law or that he be retried on the prostitution charges alone. 

In its written opposition, filed Aug. 20, federal prosecutors alleged Combs’ motion should fail because there was “ample evidence to support the jury’s conviction.” They said Combs transported Ventura, Jane, and multiple male commercial sex workers to engage in threesomes, variously dubbed “freak offs” and “hotel nights,” that he stage-directed and often recorded.

“The defendant masterminded every aspect of freak offs. He transported escorts across state lines to engage in freak offs for pay. He directed the sexual activity of escorts and victims throughout freak offs for his own sexual gratification. And he personally engaged in sexual activity during freak offs,” they wrote. “While the defendant may wish to cabin his participation to mere voyeurism, he was, in reality, an active participant in the sexual activity.”

Prosecutors blasted Combs’ claims that he was an amateur porn producer who should be protected by the First Amendment. “Far from acting like an adult film producer or director, the defendant did not provide advance notice that he may film the sexual encounter and did not seek consent from the participants to be filmed,” they wrote in their Aug. 20 filing. “In fact, multiple participants specifically did not want to be filmed.”