Plaintiff Andrea Constand filed a civil lawsuit against Bill Cosby alleging battery, assault, and intentional/negligent infliction of emotional distress. She claims that in January 2004, Cosby invited her to his home and gave her pills that impaired her abilities. She alleges that Cosby then sexually assaulted her while she was incapacitated, causing her emotional and physical injuries. The complaint accuses Cosby and his representatives of making defamatory statements against the plaintiff to media outlets.

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IN tHE UNITED STATE9 DIS.TRICT COUF,T
FOR THf EASTERN DISTRICT OI' PENNSYLVANIA
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B' MEEi€g
3.. Plaintiff Andrea Constand is an adult lndivldual
currently residing at a confid.entiaL addtess in Pickering,
ontario,
4, Def€ndant William H. cosby' ,fr. iE an adult individual
with a residence at 8210 New seQor{d Street, Cheltenham,
!D ^h!rhr6rr,p,1 .,--l - yr v arrf a.
c.I:E@
5, Plaintiff incorporates by reference the prior
paragraphs of this Complaint, as though fulJ-y set forth at
Iength.
6, on or about December 2001r Plaintiff was empLoyed at
Temple university as Director of operations' for the Women's
Bask€tbaI.l- program. 1n her capacity as such, PlalnLiff met
Defendant Cosby in November 2002.
'1. Defendant foste.red a friendship with Plaintiffr so
that over tirtre she considered hlm to be both her friend, albeit
o1der. and a mentor,
8. For over dne {1) year, Plaintiff socialized wi.th
Defendant Cosby, including, inter alial discussing Temple
women'F hasketball with him, talking with him by telephone,
being his guest at dinner parties and other events hosted by
at his Ch€ltenham home and other locatiols,
ANDREA CONS,TANDI
Plaintlff
Y.
WIII,TAM H. COSBY, ,]R.
Defendant
CtrVII. ACTION
NO.05-cv-
JURY TRIAT, D.Ei:{4NDED
coffir.pr{E
Plaintiff And.rea Constand, by her attorneys,
Troianl/KiviLzr L.L.P., claims of DefendanL a sum 1n excess
$150/000.00, and irr support the.reof states the following:
A.
1, The united stales Distrj.ct Court fbr the Eastern
DistrlcL of Pennsylvania has jurisdiction orer lhis action
pursuant to diversity of citizenship and amount 1n
conLroversyt 2B U.s.C, S 1332,
2, Venue 1j.es in the Eastern Dlstrict of PenhBylvania
pursuant to 28 u.s.c.,s 1391 in that the events giving -rise
the clain occurred in the Eastern Distriet of Pennsylvania. and
him

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9, fn,fanuary 2OQ4f Defendairt invited Pla-lntiff to hi.s 11, when Plaintiff advised Defendant she did not feeL
8210 Nev, Second street, Cheltenham, Montgotne.ry Countyr !.lefl/ Defendant Ied Plaintiff to a sofa, becauEe she aou.ld nat
Pennsylv-ania./ home, telIlnq her that he wanted lo offer her walk on her own, where he laid her down, under lhe giuise of
assistalrce ih her pursuit of a different car.eer. 'he1ping" her.
1^ Dr.jhrirF -^reed to meet him, and airi/ed aL 18. Subsequentlyr Def,endant positioned hihself hehlnd
D€fendant's home at approximately 9:00 p.m, Plaintlff on the sofa, touched her: breasts and va.qlnal area,
11, Plaintlff and Defendant conversed, and durinq their rubbed his penis agains! he-r hand, and digitally penelIated her.
conversation' Plaintiff exFressed that she was feellng atressed 19. Plaintiff remained in a semi-oonscieus state
about making her caxeer dec.isio.n. th.roughout the time of this ordeal..
1,2. Defendant then offered Plaintiff three bLue pil1s, 2A. At no time !.naE Plaintiff c.apabLe of corsent after the
which ho told her were herk,al meitication, Which would help her piIIs affected her, and at no Lime did she consent to
relax, Defendant'd acts,
13. PlainLiff queslioned. if she needed to 1:ake all three 2L. plaintiff losl consciousness afle,r the events
pills/ and Defgndant assured her that aII three pills lvere descrihed above, and did not fully awaken untiL sometime after
4:00 a.m.
1,4, Plalntiff ingest.ed the piIIs with bottled wate-r, 22, Ptaintiff awoke feel-ing raw in aid afound her vaginal
bellevj-ng that the pil1s w€re what Eefendant rep-feselnted then to area,
be. 23, When Plaintlff awoke, her clottles and undergarments
15. I{ithin a shorl period of time, Plaintiffrs knees began were in disarray.
to shake. her limbs felt irnn6hj-Le, she felt diz.zy and weak, and 24, After PLaintlff awoke, Lrefendant qreeled her in hie
she began to feel only barely consoious. bathrobe..
L6. Upon informat.ion and bellef, Defendant prorided 25. Ptaintiff left Defendant's residence lry hexs€]f,.
Plalnliff with some sort of narcotic or other type of drugr and 26. On,lanuary ]-3i 2005, Plaintiff ieport.ed Ddfendant/s
not an "hei:bal" remecLy. actiins to the Durham, ontario police.

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2.'1, .EoIIoting Ptaintiff's 'lanuary :13t 2AA5' police report'
Defendant and his aulhorized representatives andlor aqents have
mad.e publicized statgments Lo Lhe media' includinq' Celebrity
Justicd ("C,1"), which have included:
sources connecl-ed with BiLl Cosby te11 "cJ" that before his
accuser went to ot;i;t'";;; mo-tnet-as-k€d the comedian to
make thinqs rignt"wilh'*otuy"wu''" told she asked cosby to
help pav for her a"t$itt;t-i'a*-'-:]^t::lo to qenerallv help
her out fin-"1-ffy' and this-Qonver+tion occurred before
the acauser t'*t
"ii'ti"i"J'-pori""'-'r':"Y:':";r:::tinue
to
investlgate, a Cosbv rep caII lsrcl LIrr
sha ke down '
These particular statements were broadcast rratlonwide' and
posted on Celebrity Justice's internet website' also available
nationwlde, on EebruarY '1' 2Aa5'
28. Celebrity 'lustice' The Toronto Sun' and EoxNews' amonq
other medla sources/ had previously pfinted and/or aired
plainliff,s nama anc address and'/or picture in connection with
thisinvestigation'andothermediaSourceshadpub}ishedher
name and/or a picturq of Plaintiff as well' therefore making her
identltyasCosby,saccuse.rrecoqflizabletOthepubliC.
29. on or aboul February lft 2aQ5t Defendaht gave an
.."*s1usive" interview to The Enqui]|ert a national tabloid wi"th a
clrculation of about 1'5 millionr conceininq Plainlifffs
alleqations' In that intervj-ewt in an effort to conLinue Lo
make the public believe that plaintiff was guilty of exLortionr
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Defendantsai(].,'.lamnotqoingtoqiveintop]eoplewhotryto
explait me because of my celebrity status"'
30. At the time that Defendant and/or hi.r authorized
representati ves and'/or agents' servan!s' or employees made their
stat6mentE to Celebrity 'lustice and The Enquirer' ea'h of them
kneli or should have known that the statements were false'
hecause followlnE Plaintiff/s reporl of the incident to the
Durham police, and beginning on ol abcut 'lanuary 16' 2005'1 and
continuing in the days thereafter' Defendant and/or hls
representatives and aqents Blaced at Least four t'elephone ca1ls
to plaintiff and her mother in whlch' among other things'
Defendant apologized and offered financial compellsation to
Plaiutiff,whichofferwasnotacceptedbyPlaintiffand/orher
mothe r '
31, Plaintiff hereby in-corporates by reference the prior
paragraphs of this Complaint as thouqh fu11y sel forth at
length.
32. Defendant's offensive or harmlul coltaat with
Plaintiff as set fofth herein at Jenqlh constituted a battery
upon her.

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33. The aforegaid conduct by Defendant was committed
h/i11fully, knoryingly, maticiously, inlextionelly, wantonly,
recklessly, and/or n.eq1igent1y,
34, As the direct and proximate result of Defendant's acts
4s 6isscribed in the foregoing paragraphs of this Complaint,
plaintiff has suffered serious and debllitating injuries, mental
anguish, humiliation, embarrassmeflt' phys.lcal and emotional
upset, includinq, but not llmited to, post*traudiatic stress
disorder, depression, sleeplessnegg, isolatian, flashbacksr
arixiety, the full extent of which injuries are rlot. yet known'
and some or al1 of which may b.e permanent in natur'e.
35, As the direct and preximate resul-t of the Defendant's
acts as described iri the foregolng paragraphs of thls Camplaint.
plaintiff suffer:ed and wiIl in the future continue to suffer
serious pain, menlal anguish, emolional upset, and the loss of
enj oyment of 1 ifEJ s pleasures .
36. As the dlrect and proximate result of the Defendant's
acts as described it the foregoing paragraphs of this Complaint,
plaintiff suEtained a setback and loss of continuity in her
education, the ful1 extent of whlch is not yet known.
3'7, As the direct and proximate .result of the Defendantr8
acts as described ih the foregoinq paragraphs of this Complaint,
plaintiff has Sustalned a foss of earnings and ezlrning capacity.
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38. As the direct and proximate regulL of Lhe Defendanl's
acts as desdribed in the foregoing paraqraphs of this Complaint,
PLaint.iff has in the past and will in the future conlinue to lle
compel-1ed to expend larqe suris of money for psychological
treatment and therapY'
WHEREfoRE, PlainLlff respectfuLLy requests that this
Honorable Court enter iudgment in her iavor ancL against
DefendanL William Cosby, in an amount in excess of one Hund-red
Fifty Thousand Dollars ($150r000.00) plus reasonable attorneys'r
fees, lnt.erest, costs, punitlve damages, and such othe.r relief
a6 the Court deems juFl and p.ropel:.
COUNT TI
.Andrea Constand v. Willian Cosbv
Assaul,t
39. Plaint.iff hereby incorporates by reference the prior
paraqraph€ of this Complaint as though fu1ly set forth at
40. Defendant's haimful or offensive contact with
plaintiff as Eet forth herein at length, placed her in ilhminent
app]rehension of such contaet, and constituted an assault upon
her.
4L, The aforesald conduct by Defendant ilas committed
wil1ful1y, knowingly, maliciously' intentionally' wantonlY,
-reckJesslv, and/or negligentl-y'

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42. As the dliect and proximate result af Defendant's acts c'ompelled to expend large sums of money for psychological
described in the foregoing paragraphs of this Complaitt, treatment and thelapy.
plaintiff h.as suffered serlous and debllitatinq Injuries, mental WHEREEoRE, PlaintifI respectfully requests that this
anguish, humiliatiOn, gnlcarrassment, physiaal and emotional Honorable Court enter iudgment in her faYor and against
upset, including, but not limited to, post-traumatlc stless Defendant william Cosby, in an amount in excess of one Hundred
dlsorder, d.epressioh, sleepfessness, isolation, flashbacksf Eifty thsa53nd Dollars ($150,000.00) plus attorneys' fees,
anxiety, the full extent oi which lnjuries are not yet knowE and interest/ costs, punitive damages, and such other add.itional
s.ome or aII of which may be permanent in nature. relief as this, Co.urt deems just artd proper.
43. As the direct and proximate .result of Defendant's acts
CoUNT III
desdribed ln the foregoing paragraphs of this Complaint, 4a+eq PonsFt-ilil-F$lffeJo=g9qbf
Intentio,nal +na Negligen! Infllotion of Enotioqal piEtr:F1
PlainLiff suffered and will- in the future continu,e to suffer
4'l . Plainliff hereby incorpotates by -refe.ren.a the prior
serlous painr mental anguishr emotional- upset. and the loss of
paragraphs of this Complaint as though fu11y set forth at
enjoymenL of life/s pleasurg.s,
lenglh.
44" As Lhe direct and proximate result of Defendant's acts
48. Defendant's conduct, as set forth ln the foragoinq
descrii:ed in the foreqoin'g paraqraphs of thls complaint'
paragraphs of lhis Coinplaint, was so outrageous in character and
Plaiatiff sustalned a setback and loss of conLinuity in her
30 extreme in degree as to faII orrtside the bounds of dec.ency,
educationi the fu1l extent of which is not yet known.
and is to be reqarded as intolerable in the commurlity.
45, As the direct and proximate result of Defendant.'s actg
49, At all tines relevant hereto, Defendant knew with
described in the fo.regoing paragraphs of this Complaint,
substantial certainty/ or should Ltave known that severq'
plaintiff has sustained a loss of earnings and earning capacity.
emotj-onal distress would be produced by his conduct.
46. As the dlrect. and proximate result of Defendant/s. acLs
50, By engaqinq in the acts set forth in tlre foreg.oing
described in the foreqoinq paiagraphs of this Complalnt,
paraqraphs of this Complaint, Defendant engaged in extreme and
Plaintiff has in the pasl and will in the future continue to be
1.0

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outrageeus canduet and intentionally inflicLood severe emotional
distress upon Plaintiff .
51, By engagihg in the acts set forth in lhe fo.regoing
paragraphs of this Complaintr Defendant expLoited and abused his
friendship and his mentor relationship with Plaintiff, violated
her trust, and caused her great djslress.
52, AE a dlrect .and proximate result of the acts of
Defendant as 8et forth ln the foregoing paragraphs of this
complalnt/ PLaintiff has in the past b,een requiredl and may in
lhe future rdquired, medicine, medlcal, psycholoqical and olher
treatment in erder to cure herself of Lhe injuries she has
sustainedi has in the past been obliged, and may in the future
be obliged, to expend various sums of money for such medical
care and treaLnent,
53, As furLhet difect and proximate result of tho acts of
the Defe.ndant as seL forth in the foreqoing paragraphs of this
Complaint, Plaintiff has been caused to suffer ahd continues to
suffer severe emotj-onal distress, humlliation, gfiftarrassnent aRd
financial loss,
WHEREFoRE, Plalnliff respectfulLy requests that this
Honorabl-e Courl enter iudqment in her favor and against
Defendant William Codlty, in an amount in excess of one Hundred
Fifly Thousand Dollar6 ($150,000.00) plus attorneys' feesr
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interest, costs, punltive damages. and such other additional
rellef as this Court deems just and propei.
54. Plaintiff hereby incorporates hy reference the prior
paraEfaphs of this Complaint as ttrough fully s€t forth at
1enqth.,
55. At all tir0es relevant hereto, Plaintiff was a 1aw
abiding citizen of Lhe commonwealth of Pennsylvania andlor
Plokering, ontario, who enjoyed the respect, confidence and
esteem of her neigthl)ors, as well as others in the comnunity, and
has never been adjudqed quilty of any critoel offense or
violation of the 1aw which would tend to lessen the reEpect7
confidsnce and dsteem which she enjoyed, and to which she was
entitle.d,
56. At all tiiles mentioned herein, Defendaot acted on his
own or t.hrough his author:ized aqentE, representalives, sources,
seryanti! ot ernployees hto. acted for Defendant's henefit, under
Defend,ant's contro.l or directlon, and within the course and
scope of their authoiityf aqency, fepresenlatioh or employment.
5?, On or before February 1' 2aa5, the Defendant, through
hls representativesr agents, servantsr or €mployees intending to
injure Lhe Plaintiff and to deprive her of her qood namev credit
12

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and reputation, faIsely, maliciously, and wickedly p{ovided
information for at f,east crne publication which aired on
Celebrlty ,Iustice, a nationalLy syndicated televisloo show, and
was posted on the Celebrity Justice lrebsite conderning
Plaintiff.
58, on or abouL Feb.ruary 2I, 2005r Defendaht. gave an
"exclusive" lntetview to The Enquirer, a national tabloid with a
circulatlon o.f about 1.5 mi11ion, lntenclinq to or knowing it
would injure Plaintiffr and to deprive her of her good nane7
credit and reputation, in lrhich Defendant said, 'I am not going
to give in to people who try to explolt me because of my
celebrity status. "
59, The staLenents contained in the above pubLicatlolrs,
shows and websites intended to and did. convey to the viervers
and,/or readers thereof. either dixectly ar by iilplication, that
Plaintiff asked Defendan.t for moneyi she did so before she went
to the policei and, that her actlons constltuted a "shakedown",
or an attempt. to exto.rt monev front D.efendant, and to exploit
him.
50, The statanents and charges in the publications, shows,
and/or websites identlfied in the foregoing paragraphs of this
Complaint are fa1se, ahd Defendant knevn o.r shou.ld have known
that they were false a'L the tirne of the publications.
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61. Plaintiff has never' at any time, been qritty of the
crimes alleged by Defendant, nor lias she ever an accessory tol
nor an aider and abeilor of, such criminal actsr no.r has she
ever been guilty of any .other viol.ation of law, but she ha8 at
aII times been a peaceahle and lavr' abiding inhabitant of the
seve.ral conniunities in ivhich she has resided from the day of her
birth to the present time,
6.2, Defendant and,/or his representatives and agehts knew/
or should have hnown that the sLaLements and charges contained
in the pub.licat.ions, shows and vqebsites identified in the
foreqoinq paragraphs of this CompLaint. were false when made, and
Defendant uttered aFd published them either intentionally and
maliciously, or with reckless distegard fo-r their truth or
falsity.
63, The slatements and charqes contained in the
publicatiohs, shows and websiies j,d.entified in the foregoing
paraqraphs of this Complaint were. printed, published, circulated
and aired by Celeb-rlty Justice on February 1t 2AA5t and by The
Enqulrer on or about Mat:oh 4/ 2005f and wele widely heard aid
read by the Plaintiff's family, n€)ighbors/ a.nd friends and
div€rse other persoBs, who understood imediately that Plaintiff
was the adcuser to which Cosby ancl,/or his represenfalives,
agents, FervanLs or employees referred.

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54. By reason of the printing, publicatlon. and
clrculation of the statements and charge€ cohtained in the
artioles, shows, publlcations, and websites identlfied in the
for€qoing pa.ragraphs of thi6 Complaint, Plaintiff has been
brought into scandal and reproach, and has been held up to scorn
and conternpt amonq her neiqhbors, business acquaintances, and
othet qood citizens, and ls suspected by them to have been
gu1lly of the crimes and fraudulent practices which Defendant's
a.rticles imputed to Plaintiff, as a result of which the
plaintiff has suffeted ih her business, her reputatlon, feelings
and peace of mind, to her g-reat financial loss and damage, and
to her great humiliation,
IfHEREEQRE, Plai-ntiff respe.ctfully iequests that this
llonorable Court enter judgment in her favor and against
Defendant WiIllam Cosby, in an amount in excess of one Hundred
Fifty fhousand Dollars ($150,000.00) plus attorneys' fees,
interest, costs, punitive damages, and such other additional
relief as this Court deems just and proper.
65, Plalntiff
paraqraphs of thl.s
1 ength ,
hereby incorporaLes by reference Lhe prior
Complainl as though fully set forth at
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66. The sLatements ident.lfied ln the foregoin.g pa.ragraphs
of this Complaint made by Defeldaht. or through his authorized
representatives, ag.ents/ s€rvants or employees ,{ere hiEhly
offensive statements made aqainst Plaintiffr which portrayed her
In a la se rdht.
6'7 . The statenents identified 1n the foregolng paragraphs
of this Complaint made against Plaintiff were publ.icized by
Defendantf or publicized through his authorized rep.resentatives/
agents, servanLs, employ€eg and sources.
68. Defendanl ald his authorized representativesf agents,
sel:vants, emp.Ioyees and sou.rces knew or should have known that
such statements hiere fa1se, or recklessly disregarded the
falsity of said statem€nts..
69, Defendant and/or his authorized .reprdsentatives,
aqents, servants or employees created a false. imBression by
knowingly or recklessly puhlicizing selective pieces of
information; rendering the publication susceptible to inferences
casting Plainriff in a false 1i ghL.
70. By reason of Defendant's aforesaid conduct, Plaintiff
has suffered in her busine€s, her reputptiqn, feelings and peace
of niindl to her great financlal Loss and damage, and to her
graat humiliation.
WHEREEoREf Plaintiff respectfufly requests that this
Honorable Court ehter judgment in her favor and aqainst
15

9. Case 2:05-cv-01099-ER Document 1 Filed 03/08/2005 Page 17 ol 17
Def e]1,lant I/ili l1iam Cosby, in al amount irr excess of One Hundrei]
ElflV Tfiousand Dollars ($150,000.00) plus aLr-orheysr fe-os/
inLe:rest, co;ts, punil-ive damages, and sLlcfi oLher addil:ional
relre:[ as this CourL deems jusL anti proper.
JURY DEI{AITD
Plairrtiif hereby clerrands a l-.ria1 by jLrry iI Lhis mati.er.
RespecLlully submi L.Led,
Troi.ani,/Kivit-.2 | L, L. P,
,/s/ 8,.b.-. H. Kivitz
Bebe H. Klvrtz/ Esqulre
1. D. No, 30253
Do.o-^ ,1 . Troi-n , q. .
I . D. No , 21283
38 trlorLh WaLerloc Road
Devon/ PA 1 9333
(510) 688-8400
(610) 6BB-8426 fax
Allorneys lor Pl ainLiffr
Andrea Cons Land
DaLeLl: March B, a-0q5