Cosby Lawsuit

Case 2:15-cv-07817-SVW-AGR Document 1 Filed 10/06/15 Page 1 of 22 Page ID #:1
1 Tiffany T. Chung (SBN 275981)

Tiffany@chunglegal.com
2 Law Offices of Tiffany Chung
9701 Wilshire Blvd., # 1000
3 Beverly Hills, CA 90212
Tel: 310-363-0327
4 Fax: 888-402-2078
5
Attorneys for Plaintiff

6 CHLOE GOINS
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8
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
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11 CHLOE GOINS,
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Plaintiff(s),
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Case No.: 2:15-CV-7817

COMPLAINT FOR DAMAGES
1. Sexual Assault
vs.
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16 WILLIAM HENRY BILL COSBY,
JR. (BILL COSBY),
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DEMAND FOR JURY TRIAL
Defendant(s).
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Plaintiff, CHLOE GOINS (Hereinafter GOINS), by and through her
undersigned attorneys, hereby sues the Defendant, WILLIAM HENRY BILL
COSBY, JR., (Hereinafter BILL COSBY), and allege as follows:
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1
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PARTIES
1.
This is an action for damages in excess of the sum of Seventy-five
3 Thousand ($75,000.00) Dollars, exclusive of costs, interest and attorney's fees.

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2.
At all times material hereto, the Plaintiff, GOINS, was a resident of San
5 Diego, in San Diego County, California, and her date of birth is May 17, 1990.
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3.
At all times material hereto, the Defendant, BILL COSBY, was a
7 resident of Shelburne, in Franklin County, Massachusetts.

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JURISDICTION AND VENUE

4.
Jurisdiction in this court is proper based on 42 U.S.C. 1332 because
10 Plaintiff GOINS, is a citizen of California and Defendant, BILL COSBY was a

11 citizen of Massachusetts and the damages are in excess of $75,000.
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5.
Venue is proper in this Court under 28 U.S.C. 1391(b) because all
13 incidents, events, and occurrences giving rise to this action occurred in the County
14 of Los Angeles, California.
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FACTS COMMON TO ALL CLAIMS FOR RELIEF

6.
Plaintiff repeats and realleges each and every allegation in paragraphs 1
17 through 5 of this Complaint with the same force and effect as if fully set forth
18 herein.
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7.
BILL COSBY is a professional comedian and world known public
20 figure who started his professional entertainment career in or about 1962.

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8.
In addition to his comedy career, BILL COSBY has also acted in
22 numerous motion picture films and co-wrote and starred in various television shows
23 over the last 50 years.
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9.
Since approximately 2000 BILL COSBY has been the subject of
25 various different sexual assault allegations which date back to the beginning of his
26 professional career in the 1960s.
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10.
To date, more than 40 women have come forward and accused BILL
2 COSBY of various different types of sexual assaults, including drug assisted sexual
3 assaults.
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11.
In or about 2005, Andrea Constand filed a civil suit for sexual assault
5 against BILL COSBY and subsequently the Court has unsealed documents from that
6 civil proceeding which show that BILL COSBY has admitted in sworn testimony to
7 a history of infidelity, casual sex and the use of drugs with a series of women.
8 During this civil litigation, 13 various Jane Doe witnesses were prepared to testify
9 against BILL COSBY to establish his pattern, habit, practice, or modus operendi for
10 drugging and sexually assaulting women.
11
12.
The list of other alleged victims of BILL COSBY include, but are not
12 limited to:
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1.
Kristina Ruehli
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Year of Alleged Incident: 1965
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Ruehli, now 71, has stated that Cosby sexually assaulted her when she
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was a 22-year-old secretary at a talent agency. Ruehli states that Cosby
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invited her to a party at his home, but when she got there she was the
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only guest. Ruehli went on to claim that she had a cocktail with Cosby
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and suddenly passed out. Ruehli further alleges that when she came to,
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she was in Cosby's bed and he allegedly tried to force her to perform
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oral sex on him. Ruehli has spoken with media, and stated that she was
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one of the 13 Jane Doe witnesses that was prepared to testify against
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Cosby during Andrea Constand's civil suit.
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2.
Carla Ferrigno
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According to actress, Carla Ferrigno She has stated that after being
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invited to Cosbys home they ended up alone together, and that he
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allegedly pulled her close and kissed her roughly as she tried to fight
him off.
3.
Joan Tarshis
Tarshis has stated publically that Bill Cosby had raped her when she
was a 19-year-old comedy writer. She said Cosby invited her to help
create material for his short-lived sitcom The Bill Cosby Show. During
the writing sessions she claims that Cosby forced himself on her and
raped her on two occasions.
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4.
Cindra Ladd
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In an op-ed written for The Huffington Post and published on, January
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26, 2015, Ladd wrote that she met Cosby when she was 21, living in
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New York City, and working for the late movie producer, Ray Stark.
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Ladd alleges that one night, she meet Cosby at an apartment that he
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said belonged to his friend. Ladd, who says she was suffering from a
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headache that night, alleges that Cosby offered her a capsule that would
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ease the pain. Ladd claims that she was drugged and that she awoke
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naked in bed with Cosby in a white robe in the room with her.
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5.
Victoria Valentino
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Valentino, a former Playboy playmate, claims that she was introduced
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to Cosby by a Playboy bunny in 1970, just months after the tragic death
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of her 6-year-old son. Valentino alleges that she and her roommate
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went out for dinner and drinks with Cosby, who allegedly offered her a
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pill that would cheer her up. Valentino claimed, in an interview with
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The Washington Post, that Cosby drove her and her roommate up to an
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apartment in the Hollywood Hills. She alleges Cosby forced her to
perform oral sex and then, Valentino claims, he raped her.
6.
Autumn Burns
Burns claims that she met Cosby while working as a waitress at the
gaming tables in a casino in Las Vegas. Burns claims that, after
attending one of the comedian's shows, he gave her a drink that caused
her to feel woozy. Burns further alleges that Cosby raped her in his
hotel suite.
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7.
Louisa Mortiz
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Actress Louisa Mortiz, claims that Bill Cosby forced her to perform
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oral sex on him in the dressing room of Johnny Carson's Tonight Show
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in 1971.
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8.
Donna Motsinger
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Motsinger spoke with the New York Post's, where she claimed that she
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was Jane Doe witness No. 8 in the 2005 Constand suit filed against
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Cosby. Motsinger claims that Cosby drugged and raped her while she
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was working as a jazz club waitress in Sausalito, California.
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9.
Katherine McKee
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Year of Alleged Incident: Early 1970s
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McKee, an actress and former show girl, claims that Cosby raped her in
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a Michigan hotel room in the early 1970s while she was on tour with
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Sammy Davis Jr. According to McKee in an interview with the New
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York Daily News, McKee alleges that she came to have dinner with
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Cosby at his hotel, and that when she arrived Cosby attacked her.
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According to McKee, Cosby spun her around, pulled her panties down,
and just took her sexually.
10.
Helen Hayes
Year Of Alleged Incident: 1973
Hayes claims to have encountered Cosby in 1973 when he allegedly
stalked her and her friends during a weekend-long celebrity golf
tournament in Pebble Beach, California. She has stated in the media
that Cosbys "behavior was like that of a predator." She claims that, on
the last night of the tournament, Cosby approached her from behind,
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reached over her shoulder and grabbed her breast.

11.
Charlotte Fox
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Year of Alleged Incident: Mid-1970s
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Fox claims to have met Cosby while she was working as an extra on
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the set of the comedian's 1974 film, Uptown Saturday Night, where she
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was allegedly invited to the Playboy Mansion for a dinner Cosby was
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hosting. Fox has stated publically that she "vaguely remembers coming
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back from the bathroom." According to her accounts, "The next thing I
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remember was that I was sort of awake, in a bed, with no clothes on
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and there was Mr. Cosby, in a robe, crawling from the bottom of the
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bed." Fox alleges that Cosby engaged in non-consensual sexual
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activity with Fox, who claims to have been "incapacitated."
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12.
Judy Huth
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Huth filed a lawsuit against Cosby on December 2, 2014, in which she
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claims that she first met Cosby back in 1974, when she was 15 and she
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- along with an unnamed 16-year-old female friend - wandered onto a
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movie set where Cosby was working. According to the lawsuit, Cosby
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allegedly befriended Huth and her friend, and invited them over to his
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home where he served them alcohol. Huth's lawsuit goes on to claim
that Cosby knew how old she was, and that he took her to a party at the
Playboy Mansion where he allegedly told her to tell anyone who asked
that she was 19. While at the party, Huth alleges in court documents
that, when she emerged from using the restroom in one of the
mansion's many rooms, Cosby was sitting on a bed waiting for her, and
then allegedly sexually assaulted her by taking her hand and making
her perform a sex act on him.
13.
Tamara Green
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Green first publicly shared her story on the Today show in 2005 in the
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wake of the civil lawsuit filed by Andrea Constand. According to
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Green, Cosby gave her pills that would help with her flu symptoms,
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and before long she was nearly unconscious. Green went on to claim
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that Cosby took her back to her home, undressed her and began groping
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her.
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14.
Marcella Tate
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According to Tate, she attended a party at the Playboy mansion as
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Cosby's guest. Tate claims that Cosby gave her a drink that caused her
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head to get "cloudy." Tate claims that she woke up in an unfamiliar
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bed the next day, allegedly with a naked Cosby in bed with her. Tate
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made her allegations during a press conference held by attorney Gloria
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Allred on April 23, 2015.
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15.
Therese Serignese
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Year(s) Of Alleged Incident: Mid-1970s
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Speaking with People Magazine on November 20, 2014, Seringese
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alleged that she met with Cosby in Las Vegas, after one of his stand-up
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shows, when she was 19 years old. She claims that Cosby pressured
her into taking Quaaludes a powerful sedative-hypnotic drug and
then pressured her into agreeing to engage in sexual activity. Serignese
stated, "My next memory is I felt high; I don't remember what
happened in the meantime. Then my next memory is being in that
vanity room, by that big mirror, and he didn't have any clothes on, and
obviously I didn't either by that point. I don't know how they got off. I
don't have that memory I was just like bent over, and he was saying
all kinds of dirty stuff," she says. "I felt powerless, I didn't know what
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to do." Serignese also claims to be one of the 13 Jane Doe witnesses
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that were prepared to testify against Cosby during Andrea Constand's
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2005 civil suit, before it was settled out of court in 2006.
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16.
Shawn Brown
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Brown claimed in an interview with The Daily Mail that Cosby
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drugged and raped her, despite her previous willingness to sleep with
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him. She claims that Cosby convinced her to drink alcohol, got her
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high on marijuana, and then had sex with her after she had blacked out.
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"I had never really been into him and the other times I had really just
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been going through the motions," Brown said. "I don't think I was
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freaky enough for him, and that's why he drugged me." Brown claims
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she became pregnant from the affair and gave birth to a daughter,
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Autumn Jackson, who Cosby secretly helped support.
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17.
"Elizabeth"
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"Elizabeth" -- who wished to only be identified by that moniker at a
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press conference held by attorney Gloria Allred in New York on
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August 20, 2015, claims that she met Cosby on an airplane when she
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was 20 years old while working as a flight attendant. "Elizabeth"
alleges that, during a dinner with Cosby at a Japanese restaurant, the
comic gave her a glass of sake, after which she claims that she fell into
a "trance-like state" and ended up in Cosby's hotel room, where she was
allegedly forced to perform an unspecified sex act.
18.
Joyce Emmons
Year of Alleged Incident: Late 1970s
In the 1970s, Joyce Emmons ran a number of comedy clubs and claims
that she and Cosby would often hang out. According to allegations by
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Emmons, Cosby had "a drawer full of drugs," including Quaaludes.
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Emmons spoke with TMZ on November 22, 2014, and claimed that
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Cosby gave her a pill that was supposed to cure her strong headache,
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but instead caused her to pass out.
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19.
P.J. Masten
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In an interview with the New York Daily News, Masten claims that
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Cosby attacked her when she was working as a Playboy Bunny at the
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Playboy Club in Chicago. According to Masten, Cosby allegedly lured
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her to his room where he served her a glass of alcohol, after which she
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claims to have blacked out. Masten alleges that she woke up, hours
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later, in bed next to Cosby who was naked. Masten further claims that
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Cosby has done this to several Playboy Bunnies, saying, "There are a
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dozen former bunnies that I know of with similar stories, but theyre
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afraid to come forward."
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20.
Linda Kirkpatrick
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Kirkpatrick claims that Cosby invited her to see him perform at the Las
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Vegas Hilton when she was 25. According to Kirkpatrick, Cosby asked
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her to see him in his dressing room where she claims he served her
spiked champagne and then sexually assaulted her. Kirkpatrick was
one of three women to level new accusations against Cosby at a press
conference held by Gloria Allred on January 7, 2015.
21.
Lynn Neal
Neal claims that Cosby sexually assaulted her when she was in her
mid-20s after the comedian invited her to one of his stand-up
performances at the Las Vegas Hilton. According to Neal, Cosby took
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her out for a bite to eat after the show and bought her a drink. "By the
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time we walked back to his dressing room, I was having problems
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walking," Neal claimed at a press conference held by Gloria Allred on
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January 7, 2015. "When we entered the dressing room I sat on the
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couch and he started taking my pants down I felt helpless and I
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couldn't stop him."
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22.
Janice Baker-Kinney
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Baker-Kinney alleges that she met the comedian in the early '80s
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during a pizza party thrown by a casino, where she worked at the time.
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Baker-Kinney claims that Cosby gave her two pills that caused her to
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pass out, only to allegedly wake up the next day in bed with Cosby.
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Baker-Kinney made her allegations during a press conference held by
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attorney Gloria Allred on April 23, 2015.
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23.
Janice Dickinson
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The 59-year-old supermodel has stated with Entertainment Television
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on November 18, 2014, that Cosby contacted her after she got out of
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rehab and convinced her to travel to Lake Tahoe to have dinner and
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discuss a possible job opportunity. After this dinner she alleges that he
gave her a pill to help with menstrual cramps. "The next morning I
woke up, and I wasn't wearing my pajamas, and I remember before I
passed out that I had been sexually assaulted by this man," she has
claimed. "Before I woke up in the morning, the last thing I remember
was Bill Cosby in a patchwork robe, dropping his robe and getting on
top of me. And I remember a lot of pain."
24.
Renita Chaney Hill

Years of Alleged Incident: 1982-1986
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Renita Chaney Hill claims that she began a relationship with Cosby in
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1982 when she was only 15 years old. According to Hill, Cosby
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allegedly served her drinks and when she woke up she would find
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herself in bed. Hill says that she doesn't know if Cosby raped her
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because she was unconscious after drinking cocktails he allegedly
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served her. Allegedly, Hill continued to see Cosby until she was 19
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before breaking it off. Hill spoke to KDKA Pittsburgh, saying, "No
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one wants to be associated with something like this But the bottom
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line for me is that no one has the right to violate someone else, no
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matter who they are. I dont care how big they are or how the
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community sees them. It's not right."
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25.
Beth Ferrier
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Years of Alleged Incident: Early to mid-1980s
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Following the 2005 civil suit filed by Andrea Constand against Cosby,
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Ferrier came out as one of 13 women who had been preparing to serve
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as a Jane Doe witness against Cosby before the case was settled out of
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court. According to Ferrier, one night after she ended their months-
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long consensual affair, she was drinking a cup of coffee in Cosby's
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dressing room in Denver. "He said, 'Here's your favorite coffee,

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something I made, to relax you,'" she says. And then she blacked out.
When she came to, Ferrier claims that her clothes were disheveled and
her bra unhooked. Ferrier told People magazine in 2006 that when she
asked Cosby about the incident, he allegedly said, "We'll never speak
of this again."
26.
Heidi Thomas
Thomas alleged that Cosby sexually assaulted her when she was a 24-
year-old aspiring model. Thomas claimed that her agent sent her to
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meet Cosby at Harrahs Casino in Reno, Nevada, so that he could
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mentor her. Thomas alleged that when she arrived at the airport in
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Reno, she was picked up by a driver who took her to a house outside of
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the city where Cosby was waiting for her. Thomas claimed that Cosby
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asked her to perform a series of monologs, including one where she
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was supposed to act drunk. Cosby allegedly then gave her a glass of
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wine. Thomas claimed her memory became hazy after drinking the
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wine and that she lost consciousness. She alleged that, when she woke
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up, Cosby was forcing her to perform oral sex on him. Thomas made
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her claims in an interview with CNN, published on February 26, 2015.
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27.
Beverly Johnson
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Supermodel Beverly Johnson wrote an essay for Vanity Fair in
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December 2014, alleging that she was drugged and almost attacked by
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Cosby after she auditioned for a role on The Cosby Show. In the op-
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ed, Johnson wrote that after meeting with the sitcom star at a taping of
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the show, "He seemed genuinely interested in guiding me to the next
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level." She claims that she was invited to Cosby's home on multiple
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occasions, but during her last visit, he allegedly gave her coffee that she
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later realized was laced with drugs. Johnson claims that she knew
almost immediately that she had been drugged, and when Cosby began
trying to put his hands on her, she screamed at him. According to
Johnson, Cosby became enraged and kicked her out of his house and
shoved her into a cab, leaving her confused and disoriented.
28.
Sammie Mays
Year of Alleged Incident: Mid-'80s
Mays, a writer, claims to have met with Cosby for an interview in 1986
or 1987 while reporting on a convention the comedian appeared at in
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New Orleans. Mays alleges that, during the interview, Cosby fixed her
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a drink and she soon lost consciousness. Mays claims that, when she
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came to, she was half-undressed. She says she believes that she was
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raped by the comedian while unconscious. Mays made the claims
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during a press conference held by attorney Gloria Allred on May 1,
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2015.
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29.
Barbara Bowman
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Bowman was another of the 13 Jane Doe witnesses who had been
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prepping to testify against Cosby for Andrea Constand's 2005 civil suit.
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She made headlines again in November 2014, when she penned an
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article for the Washington Post titled, "Bill Cosby raped me. Why did it
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take 30 years for people to believe my story?" Bowman claims that
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Cosby worked toward gaining her trust and becoming her mentor
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before sexually assaulting her in a Reno hotel room in 1986. Bowman
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alleges that this was the first in a string of instances that took place that
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year, including an assault in Atlantic City when Cosby drugged her and
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forcibly attempted to rape her. "[Cosby] threw me on the bed and
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braced his arm under my neck so I couldn't move my head, and he

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started trying to take his clothes off," Bowman told People magazine
back in 2006. "I remember all the clinking of his belt buckle. And he
was trying to take my pants down, and I was trying to keep them on."
30.
Lisa Jones
Jones claims that she first met Cosby in 1986, when she was 17 and
working as a model in Canada. She alleges that Cosby contacted her
modeling agency to invite her and her mother to meet him at a stand-up
performance in Vancouver. According to Jones, Cosby acted like a
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father figure to gain her trust. Jones claims that the comedian later
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invited her to fly out to New York to audition for a role on The Cosby
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Show, but when she landed she was driven to Cosby's home, where he
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allegedly gave her alcohol. Jones claims Cosby was "very derogatory
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about how women were going to be successful in the industry and how
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[the way] women had gotten successful was by the casting couch."
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Jones went public with her allegations to ET Canada on December 1,
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2014, where she further claimed that Cosby tried to sexually assault
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her. "He, out of nowhere, started to walk past me, and crouched in
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front of my knees, grabbed my legs, and tried to pull them apart I
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just remember I was so shocked All I wanted to do was get out of
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there because I was in an unsafe environment and that's what I did."
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31.
Chelan
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Chelan, whose last name has not been made public, claims that Cosby
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reached out to her in 1986 when she was 17 and working at the Las
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Vegas Hilton. Chelan, then an aspiring model, says Cosby
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corresponded with her under the pretense of introducing her to
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modeling agency reps. She claims that when she arrived at his hotel
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suite in Las Vegas, Cosby gave her a blue pill and said it was an
antihistamine, then told her to take it with alcohol. Chelan claims that
Cosby sexually assaulted her before she passed out, and that when she
awoke, Cosby gave her $1,500. According to Chelan, Cosby later
invited her to see his stand-up show at the Hilton, but when she
declined, she was fired. She went public with her allegations at a
December 3, 2014 press conference. Chelan was joined at the
conference by Beth Ferrier and Helen Hayes, two other women who
have made sexual assault allegations against Cosby.
10
32.
Jena T.
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12
In an interview with People, Jena T. she asked that her last name not
13
be used claims that, when she was 17, she met with a modeling
14
agency in New York, and was then sent to meet with Cosby.
15
According to Jena T., Cosby called her parents to encourage them to
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support Jena's move to New York, and assured her that he would help
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her become a successful model. However, Jena claims that she soon
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became uncomfortable with the amount of attention Cosby paid her,
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and felt it was more than paternal. Jena claims that she attempted to
20
confront Cosby, who responded to her concerns with an offer to send
21
her to college and buy her a car. Later, Jena claims Cosby pressured
22
her into an unwanted sexual position, and allegedly gave her $700
23
before she left. Jena T. claims that the incident with Cosby has had
24
long-lasting negative effects on her self-esteem and ability to trust
25
people.
26
27
33.
Lisa
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Identifying herself only by her first name, Lisa appeared on Dr. Phil
where she accused Cosby of drugging and sexually assaulting her when
she was 21. Lisa alleges that she met Cosby while trying to pursue a
modeling career. Lisa told Dr. Phil that Cosby invited her back to his
house where he poured her a shot of alcohol, which she drank and
began to immediately feel dizzy. She claims Cosby then asked her to
join him on his couch. "I was sitting down in between his legs with my
back to his crotch," Lisa said. "He started to stroke my hair back in a
petting motion. The last thing I remember is just feeling the strokes on
10
11
my head. After that I dont remember anything else."

34.
Jewel Allison
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Year(s) of Alleged Incident: Late-1980s
13
Jewel Allison claims that Cosby began contacting her in the late 1980s,
14
supposedly to try and mentor her and develop her career as a model and
15
actress. Allison alleges that she accepted a dinner invitation to Cosby's
16
home, during which he allegedly poured her a glass of wine. Allison
17
claims that after she drank the wine, she quickly felt incapacitated and
18
collapsed. Allison further alleges that Cosby sexually assaulted her that
19
evening. In an interview with The New York Daily News, Allison said,
20
"There's no such thing as America's Dad There's just a man named
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Bill Cosby. He's a very sick sociopath.
22
35.
Kacey
23
24
Kacey one of three women to accuse Cosby of sexual assault at a
25
press conference on January 7, 2015 claims that she was attacked by
26
the comedian when she was working at the William Morris Agency as
27
an assistant to Cosby's personal appearance agent. Kacey says she was
28
invited to Cosby's house to read a script with him, whereupon she

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claims the comic pressured her into taking a "large white pill." "Next, I
remember waking up in a bed with Mr. Cosby naked beneath his open
robe," Kacey told reporters during the press conference. Kacey claims
that she soon left William Morris in order to avoid seeing Cosby again.
36.
Angela Leslie
At the time, Angela Leslie was an aspiring actress who allegedly met
with Cosby in Las Vegas. Leslie claims that the comedian tried to get
her to drink a cocktail he had made her, but she didn't drink from it.
10
According to Leslie's allegations, made in The New York Daily News,
11
Cosby coerced her into touching his genitals, but allegedly kicked her
12
out of his hotel when she refused to drink from the cocktail that he
13
poured her.
14
37.
Lili Bernard
15
16
Lili Bernard, a former actress who appeared in an episode of The
17
Cosby Show in 1992 and claims to have been mentored by Cosby,
18
alleged that the comedian raped her during an encounter in the show's
19
studio and then threatened her. Bernard has gone to the New Jersey
20
police with her allegations. Bernard made the claims during a press
21
conference held by attorney Gloria Allred on May 1, 2015.
22
38.
Michelle Hurd
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Actress Michelle Hurd, best known for her work in Law & Order:
25
SVU, claims that Cosby was very "inappropriate" with her when she
26
had a small role in an episode of The Cosby Mysteries. In a Facebook
27
post written November 21, 2014, Hurd claimed, "It started innocently,
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lunch in his dressing room, daily, then onto weird acting exercises
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where he would move his hands up and down my body, (cant believe I
fell for that). I was instructed to NEVER tell anyone what we did
together, (he said other actors would become jealous).
39.
Lachelle Covington
Lachelle Covington, an actress on the sitcom Cosby, filed a police
report against the comedian accusing him of making unwanted sexual
advances toward her. According to the 2000 story in The New York
Post, Covington allegedly came to Cosby looking for career advice.
10
The police report claimed that Cosby put his hand under her shirt and
11
then allegedly attempted to guide her hand down his pants.
12
40.
Andrea Constand
13
Year of Alleged Incident: January 2004
14
Constand, the director of operations for the Temple University women's
15
basketball team, says that in November 2002, she met with Cosby a
16
Temple University alum when he approached her and offered to be
17
her mentor in an attempt to gain her trust. In January 2004, she says
18
she met with Cosby at his home in Pennsylvania and alleges that he
19
gave her pills that he said would ease her anxiety. Constand claims that
20
after drugging her, Cosby groped and sexually assaulted her. In March
21
2005, Constand filed civil charges against Cosby. The case was settled
22
out of court for an unspecified amount in November 2006.
23
13.
This list of 40 other alleged victims of BILL COSBYs shows that he
24 has a habit, pattern, practice and/or modus operendi of drugging and sexually
25 assaulting women without their consent.
26
14.
In fact, the nature of these activities establishes a history of a serial
27 rapist that has been conducting these horrendous activities against women for over
28 the last 40 years.
-18-
15.
In 2008, GOINS attended an event at the Playboy Mansion in Los
2 Angeles, California.
3
16.
While attending this event, shortly after she arrived, she was introduced
4 to BILL COSBY and Mr. Hugh Hefner.

5
17.
When BILL COSBY walked up, he was introduced to MS. GOINS and
6 a conversation began between MS. GOINS, BILL COSBY, Mr. Hefner and a third
7 female.
8
18.
At one point during this conversation, BILL COSBY stepped away and
9 then came back shortly thereafter with two drinks, one of which he gave to MS.
10 GOINS.
11
19.
MS. GOINS began drinking the drink given to her by BILL COSBY
12 and immediately began feeling sick to her stomach and dizzy. It is MS. GOINS
13 belief that BILL COSBY had put some type of drug or narcotic in her drink without
14 her knowledge.
15
20.
At this point, Mr. Hefner asked MS. GOINS if she wanted to go to a
16 room and lie down. BILL COSBY responded that he would help by showing MS.
17 GOINS to one of the rooms at the Mansion.
18
21.
MS. GOINS left with BILL COSBY with the understanding that he
19 was merely going to escort her to a room where she could lie down and recover
20 from her dizziness and illness. Shortly after leaving the group of people, MS.
21 GOINS blacked out.
22
22.
MS. GOINS awoke sometime later. When she awoke, she was laying
23 on her back on a bed and she was naked. Her clothes had been removed, without
24 her consent.
25
23.
MS. GOINS awoke to find that her breasts were wet and sticky, as if
26 someone had been licking them, and BILL COSBY was biting on one of her toes as
27 he crouched at the end of the bed.
28
-19-
24.
Immediately upon waking up, MS. GOINS was startled and asked
2 BILL COSBY what he was doing. BILL COSBY then got up and immediately left
3 the room.
4
25.
MS. GOINS was scared, afraid, embarrassed and repulsed at what had
5 just occurred. She then collected her clothes from the floor, dressed herself, and
6 immediately left the Mansion.
7
26.
MS. GOINS at no time gave BILL COSBY consent to touch her body
8 in any way, let alone in a sexual manner.

9
27.
BILL COSBY clearly intended to cause offensive contact with MS.
10 GOINS breasts and otherwise naked body, and did in fact cause contact with these
11 parts of her body.
12
28.
BILL COSBY also caused MS. GOINS to have imminent fear of
13 additional offensive contact with her groin and breasts.

14
29.
MS. GOINS was offended by this contact made by BILL COSBY and
15 this offensive contact would be offensive to any reasonable sense of personal

16 dignity.
17
COUNT I
18
SEXUAL ASSAULT
19
AGAINST DEFENDANT BILL COSBY
20
30.
The Plaintiff repeats and realleges paragraphs 1 through 29 above.
21
31.
This is an action for childhood sexual abuse pursuant to California
22 Code of Civil Procedure Section 340.1(a). It is less than eight years since CHLOE
23 GOINS has attained the age of majority.
24
32.
BILL COSBY touched an intimate part of CHLOE GOINS body while
25 she was seriously disabled and/or unconscious.

26
33.
This touching was against the will of CHLOE GOINS and was made
27 for the purpose of sexual arousal, sexual gratification and/or sexual abuse by BILL
28 COSBY.
-20-
34.
As a direct and proximate result of the offenses committed by
2 Defendant BILL COSBY against the then minor Plaintiff, GOINS, she has in the
3 past suffered and will in the future suffer injury, pain and suffering, emotional
4 distress, psychological and psychiatric trauma, mental anguish, humiliation,
5 confusion, embarrassment, loss of self-esteem, loss of dignity, loss of enjoyment of
6 life, invasion of her privacy and other damages associated with Defendants
7 manipulation and leading her into a perverse and unhealthy way of life. Plaintiff
8 will incur medical and psychological expenses. Plaintiff has suffered a loss of
9 income, a loss of the capacity to earn income in the future, loss of proper and
10 complete education. These injuries are permanent in nature and Plaintiff GOINS
11 will continue to suffer these losses in the future.
12 //
13 //
14 //
15 //
16 //
17 //
18 //
19 //
20 //
21 //
22 //
23 //
24 //
25 //
26 //
27 //
28 //
-21-
1
2
PRAYER FOR RELIEF

WHEREFORE, Plaintiff GOINS requests entry of judgment in her favor and
3 against Defendant BILL COSBY as follows:

4
A.
5
6
For compensatory damages under federal and state law, in the

amount to be proven at trial;
B.
For punitive damages against the individual defendants in an

amount to be proven at trial;
C.
For interest;
D.
For reasonable costs of this suit and attorneys fees; and
10
E.
For such further other relief as the Court may deem just, proper,
11
and appropriate.
12
13 Dated: October 6, 2015
14
15
Respectfully Submitted,
LAW OFFICES OF TIFFANY CHUNG
By: ____/s/__________________________
TIFFANY T. CHUNG
Attorney for Plaintiff
Primary Email: tiffany@chunglegal.com
16
17
18
19
DEMAND FOR JURY TRIAL
20
21
Plaintiff hereby demands a trial by jury.
22
23
24
Dated: October 6, 2015
Respectfully Submitted,
LAW OFFICES OF TIFFANY CHUNG
25
26
27
By: ____/s/__________________________
TIFFANY T. CHUNG
Attorney for Plaintiff
Primary Email: tiffany@chunglegal.com
28
-22-

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Cosby Lawsuit

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Case 2:15-cv-07817-SVW-AGR Document 1 Filed 10/06/15 Page 1 of 22 Page ID #:1

1 Tiffany T. Chung (SBN 275981)

Attorneys for Plaintiff

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

Case No.: 2:15-CV-7817

DEMAND FOR JURY TRIAL

COMPLAINT FOR DAMAGES

COMPLAINT FOR DAMAGES

Case 2:15-cv-07817-SVW-AGR Document 1 Filed 10/06/15 Page 2 of 22 Page ID #:2

This is an action for damages in excess of the sum of Seventy-five

3 Thousand ($75,000.00) Dollars, exclusive of costs, interest and attorney's fees.

At all times material hereto, the Defendant, BILL COSBY, was a

7 resident of Shelburne, in Franklin County, Massachusetts.

JURISDICTION AND VENUE

Jurisdiction in this court is proper based on 42 U.S.C. 1332 because

10 Plaintiff GOINS, is a citizen of California and Defendant, BILL COSBY was a

Venue is proper in this Court under 28 U.S.C. 1391(b) because all

FACTS COMMON TO ALL CLAIMS FOR RELIEF

Plaintiff repeats and realleges each and every allegation in paragraphs 1

BILL COSBY is a professional comedian and world known public

20 figure who started his professional entertainment career in or about 1962.

In addition to his comedy career, BILL COSBY has also acted in

Since approximately 2000 BILL COSBY has been the subject of

COMPLAINT FOR DAMAGES

Case 2:15-cv-07817-SVW-AGR Document 1 Filed 10/06/15 Page 3 of 22 Page ID #:3

Year of Alleged Incident: 1965

was a 22-year-old secretary at a talent agency. Ruehli states that Cosby

Cosby during Andrea Constand's civil suit.

Year of Alleged Incident: 1967

invited to Cosbys home they ended up alone together, and that he

COMPLAINT FOR DAMAGES

Case 2:15-cv-07817-SVW-AGR Document 1 Filed 10/06/15 Page 4 of 22 Page ID #:4

Year of Alleged Incident: 1969

raped her on two occasions.

Year of Alleged Incident: 1969

Year of Alleged Incident: 1970

Valentino, a former Playboy playmate, claims that she was introduced

COMPLAINT FOR DAMAGES

Case 2:15-cv-07817-SVW-AGR Document 1 Filed 10/06/15 Page 5 of 22 Page ID #:5

apartment in the Hollywood Hills. She alleges Cosby forced her to

perform oral sex and then, Valentino claims, he raped her.

Year of Alleged Incident: 1970

gaming tables in a casino in Las Vegas. Burns claims that, after

Year of Alleged Incident: 1971

Year of Alleged Incident: 1971

was working as a jazz club waitress in Sausalito, California.

Year of Alleged Incident: Early 1970s

Sammy Davis Jr. According to McKee in an interview with the New

COMPLAINT FOR DAMAGES

Case 2:15-cv-07817-SVW-AGR Document 1 Filed 10/06/15 Page 6 of 22 Page ID #:6

and just took her sexually.

Year Of Alleged Incident: 1973

Hayes claims to have encountered Cosby in 1973 when he allegedly

stalked her and her friends during a weekend-long celebrity golf

tournament in Pebble Beach, California. She has stated in the media

reached over her shoulder and grabbed her breast.

Year of Alleged Incident: Mid-1970s

remember was that I was sort of awake, in a bed, with no clothes on

bed." Fox alleges that Cosby engaged in non-consensual sexual

activity with Fox, who claims to have been "incapacitated."

Year of Alleged Incident: 1974

Huth filed a lawsuit against Cosby on December 2, 2014, in which she

- along with an unnamed 16-year-old female friend - wandered onto a