Tony Buzbee is asking a New York federal judge to remove Jane Doe’s latest sworn declaration from the record in the continuing litigation brought by Shawn “Jay-Z” Carter. The immediate disagreement is over a September 24 declaration in which Doe says her prior accusation against Carter was false and that she had never met or spoken with him.

Buzbee’s side characterizes the filing as a “bought-and-paid-for” declaration. The argument is not that Doe was paid money for the statement: Doe says Carter and his representatives gave her no money and promised none. Rather, Buzbee’s lawyer argues that Carter’s decision to dismiss his claims against Doe supplied the exchange for her declaration. Carter’s lawyers have said dismissing Doe narrowed the issues in the case that remains against Buzbee and attorney David Fortney.

At this point, those are competing litigation positions, not findings by the court. Judge Dale Ho has not resolved whether the declaration should remain part of the court record, how much weight it should receive if it remains, or the underlying factual disputes that led to the current case.

What is being argued now

Carter sued Doe, Buzbee and Fortney after Doe withdrew her earlier civil lawsuit against Carter and Sean “Diddy” Combs. Carter alleged that the defendants pursued claims they knew were false, causing reputational and business harm that he said included more than $20 million in lost deals. Buzbee has rejected those allegations and has accused Carter’s side of pressuring Doe.

On September 24, Carter dismissed his claims against Doe without prejudice and submitted her new declaration along with the dismissal notice. A dismissal without prejudice generally means a claim is ended for the moment but is not necessarily barred forever. That differs from Doe’s February 2025 dismissal of her own suit against Carter and Combs, which was with prejudice. A dismissal with prejudice prevents the same claim from being filed again.

Buzbee’s September 25 letter asks Judge Ho to strike Doe’s new declaration. In court practice, to strike a filing means to request that the judge remove it from the record or decline to consider it. Buzbee’s side maintains Carter did not need Doe’s statement in order to voluntarily dismiss her from his suit, and says the procedural sequence is material to whether the declaration should be considered.

The request is also alternative in nature: if the court does consider Doe’s September declaration, Buzbee wants it to weigh earlier sworn declarations in which Doe continued to support her accusation. The core point is that one recent version of events does not erase the existence of earlier sworn accounts. Whether the competing statements can be reconciled, and what they establish, remains for the litigation process rather than public assumption.

Doe’s new account and the earlier allegations

The dispute traces back to a lawsuit Doe filed in October 2024 against Combs concerning an alleged assault in 2000. She said she had been 13, went to a party following the MTV Video Music Awards, accepted a drink that made her feel ill, and was sexually assaulted. The complaint initially called an alleged second attacker “Celebrity A.”

Buzbee sent a demand letter to Carter’s lawyers in November 2024. On December 8, Doe’s complaint was amended to identify Carter as “Celebrity A” and accused Carter and Combs of rape while another celebrity watched. Carter and Combs both denied the allegation.

Carter had already filed a California case against Buzbee, alleging the lawyer was attempting to force a private settlement by threatening a public sexual-assault claim. Buzbee denied attempting extortion and, at the time, said Doe stood by her account.

Public questions later arose about aspects of Doe’s story. In an interview, she acknowledged errors in portions of the account while continuing to say an assault occurred. Her father said he did not recall driving to New York to retrieve her after the alleged incident. Carter’s lawyers relied on such discrepancies while seeking dismissal of the case.

Doe withdrew her lawsuit against Carter and Combs on February 14, 2025, with prejudice. The short dismissal filing did not publicly explain why. Carter called the outcome a victory and later brought his case against Doe, Buzbee and Fortney.

In sworn statements after the February dismissal, Doe still backed her allegation and said fear of retaliation contributed to her choice to end the case. Buzbee’s new letter points to those statements as well as declarations Doe signed in November and December 2024.

Her September 24 declaration presents a substantially different account. Doe says she began questioning her allegations against Carter in January 2025 and came to doubt whether she attended a celebrity party or whether Combs was involved in an assault on her. She states that Carter never raped her and that she never met or spoke to him. Her current lawyer says Doe continues to maintain she was sexually assaulted, but was mistaken in identifying Carter.

Doe also says she responded to a Facebook advertisement seeking people with claims against Combs, that the original lawsuit was filed without her knowledge, and that she questions the investigation conducted by her former lawyers. She describes a late-January call she believes occurred with Fortney, during which she said she did not want to proceed, followed by a February 13 visit at her Alabama home. Doe says she signed a dismissal document while seated in Fortney’s vehicle and was not given a copy or an explanation of why the case was ending.

Those assertions are themselves part of the current legal conflict. They should not be read as judicially determined facts about the conduct of any lawyer or party.

Why the wording around a “paid-for” declaration matters

The phrase used by Buzbee’s side is rhetorically forceful, but the letter’s theory is more specific than a claim of cash payment. Doe expressly says she received no money and was promised none in return for the September declaration. Buzbee’s position is that dismissal from Carter’s lawsuit was the thing of value allegedly exchanged for the recantation.

That distinction matters because the court will be dealing with procedure, credibility and relevance rather than simply an allegation of a financial transaction. A party can choose to dismiss a defendant for many litigation reasons, including a desire to streamline a case. Carter’s lawyers have offered precisely that explanation, saying Doe’s removal focused the litigation on the remaining defendants. Buzbee contends the timing and accompanying declaration tell a different story.

Neither framing decides the issue alone. A judge may consider the filings, their procedural posture and the contradictory declarations before determining what should stay in the record. The presently available material establishes that the parties sharply disagree; it does not establish that the court has accepted either side’s interpretation.

This wider dispute has produced litigation in more than one court, and it is important not to blend their rulings together. On September 9, a California appeals court upheld dismissal of Carter’s claims against Buzbee in that state. That decision concerned whether Buzbee’s demand letters and statements could support Carter’s extortion claims. It did not determine whether Doe’s original allegation was true.

The New York case before Judge Ho is separate and remains pending against Buzbee and Fortney. That procedural split is especially relevant in a high-profile dispute, because an outcome on one claim can sound broader than it is. Dismissal of a particular legal theory does not necessarily validate every factual assertion made by a party, just as a filing from one side does not settle credibility disputes by itself.

The current New York argument therefore has a limited but consequential focus: whether Doe’s newest declaration belongs in the record and, if so, how the court should treat it alongside her prior sworn statements. The merits of Carter’s remaining claims against Buzbee and Fortney have not been resolved in the supplied court posture.

What to watch next

The next meaningful development would be Judge Ho’s response to Buzbee’s request. The judge could strike the declaration, leave it in place, or address the competing materials in another way. Any ruling on the filing itself would be a procedural decision; it would not automatically resolve every allegation in the larger dispute.

For readers following celebrity legal cases, the useful checkpoint is to separate three things: what a declarant now says, what opposing lawyers allege about the circumstances surrounding that statement, and what the court has actually decided. Those categories have diverged here. Doe’s latest declaration recants the accusation against Carter. Buzbee contests the circumstances and asks for the filing to be excluded. Carter’s side says its dismissal of Doe was intended to narrow the case. Judge Ho has yet to decide the issue.

The matter also sits alongside other ongoing pop-culture court coverage, including the separate report on NBA Ben10’s emergency-release request and pending decision. In both situations, allegations in filings and arguments by counsel are not substitutes for a final judicial ruling.