Bill Cosby Appeal Petition For Review - 007363

Received 10/23/2018 1:16:54 PM Superior Court Eastern District
Filed 10/23/2018 1:16:00 PM Superior Court Eastern District

121 EDM 2018
IN THE SUPERIOR COURT OF PENNSYLVANIA
WILLIAM H. COSBY, JR., :
Petitioner :
: DOCKET NO.:
V.:
COMMONWEALTH OF PENNSYLVANIA, :
Respondent :
PETITION FOR REVIEW PURSUANT TO Pa.R.A.P. 1762(bX2)
The Petitioner, William H. Cosby, Jr. (the "Petitioner" or "Mr. Cosby"),
by and through his attorneys, Brian W. Perry and Kristen L. Weisenberger,
of Perry Shore Weisenberger & Zemlock, files this Petition for Review
Pursuant to Pennsylvania Rule of Appellate Procedure 1762(b), from the
determination and order of the trial court entered on September 27, 2018,
denying Mr. Cosby's request for bail post-sentencing and, in support
hereof, states as follows:
J URISDICTIONAL STATEMENT
1. This Court has authority to hear this Petition pursuant to
Pa.R.A.P 1762(b).
2. Procedurally, after a one-and-a-half day hearing, on
September 25,2018, Mr. Cosby was sentenced to a term of incarceration
of not less than three (3) years nor more than ten (10) years. See Notes of
SVP/Sentencing Hearing dated September 25,2018, p. 120. Relevant
portions of the Notes of Sentencing Hearing are attached hereto at
Exhibit "1." An oral motion for bail was made to the lower court
immediately following sentencing. ld., p. 120. The lower court denied the
motion and Mr. Cosby was immediately incarcerated. ld., pp. 124-127;
131-133. The Order denying bail was entered on September 27,2018. A
true and correct copy of the Order denying bail is attached as Appendix "A."
On October 2,2018, pursuant to Pa. R. Crim. P.720(8) and 720(C), a
timely Post-Sentence Motion to Reconsider and Modify Sentence and for a
New Trial in the lnterest of Justice (the "Post-Sentence Motion") was filed
with the lower court. Insofar as the Post-Sentence Motion is pending and
an appeal has not yet been filed, as it is not ripe, this Court has authority to
hear this Petition pursuant to Pa.R.A.P. 1762(b).
PARTIES
3. The Petitioner is William H. Cosby, Jr., who is currently
incarcerated at the State Correctional Institution at Phoenix.

4. The Respondent is the Commonwealth of Pennsylvania acting
by and through the District Attorney of Montgomery County.
DETERMINATION SOUGHT TO BE REVIEWED
5. Mr. Cosby seeks review of the determination and Order of
Judge Steven T. O'Neill of the Court of Common Pleas of Montgomery
County denying the motion for bail that Mr. Cosby's counsel presented to
the lower court immediately subsequent to sentencing. The lower court
placed his reasons for denying bail on the record during the sentencing
hearing on September 25,2018. The Order denying bail, which was
entered and docketed on September 27 ,2018, reflects that bail was denied
"for the reasons set forth on the record on September 25,2018." See
Appx. "A."
6. In addressing Mr. Cosby's request for bail, the lower court
stated that his reasons for denying bail were the same as those that he
relied upon in imposing sentence. See Ex. 1, p. 132. In short, the lower
court stated that Mr. Cosby was convicted of a serious crime and that "[t]he
nature of the crime and what this Court has before me indicates that he
could quite possibly be a danger to the community." ld.

7. As set forth more fully below, the lower court failed to disclose
his contentious relationship with a material witness on the critical issue of
whether the prosecution against Mr. Cosby could even proceed, the
circumstances of which should have compelled Judge O'Neill's recusal
from the case. Accordingly, the lower court's denial of bail on the purported
basis that Mr. Cosby was convicted of a crime for which he never should
have been prosecuted was a clear abuse of discretion.
8. Additionally, there are other significant appellate issues that
should result in a reversal of the conviction. Specifically, the lower court
wrongly admitted deposition testimony Mr. Cosby gave pursuant to District
Attorney Castor's promise not to prosecute, allowed the prosecution to
proceed despite a prejudicial twelve-year delay in filing charges, and
allowed five women offered by the prosecution to testify regarding
uncharged conduct. These errors denied Mr. Cosby his constitutional
rights and warrant reversal of the conviction.
L Moreover, there is absolutely nothing in the record that would
support any conclusion that Mr. Cosby, who is 81 years old and legally
blind, is a danger to the community.

GENERAL STATEMENT OF THE OBJECTIONS TO THE ORDER OR
OTHER DETERMINATION UNDER REVIEW
I. PROCEDURAL BACKGROUND
10. On December 30,2015, Montgomery County District Attorney
Kevin Steele charged Mr. Cosby with three counts of aggravated indecent
assault. As set forth in the criminal complaint, each count was based upon
purported conduct alleged to have occurred "on or about mid-January to
mid-February 2004" at a residence Mr. Cosby owns in Cheltenham,
Pennsylvania. The complainant had lodged the allegations against
Mr. Cosby more than a decade earlier, in January 2005. At the time that
the allegations were lodged, the Montgomery County District Attorney was
Bruce Castor, who, as more fully set forth below, thoroughly investigated
the allegations and thereafter determined and promised, on behalf of the
Commonwealth, that Mr. Cosby would never be prosecuted for them.
District Attorney Castor's promise not to prosecute was made for the
purpose of compelling Mr. Cosby to testify in an anticipated deposition in
civil litigation against the complaint ant without invoking his Fifth
Amendment privilege against self-incrimination.
11. On December 30, 2015, bail was set in the amount of
$1,000,000.00, ten percent (10%) acceptable. Mr. Cosby posted bail and
5
was released. On January 11,2016, Mr. Cosby filed a Petition forWrit of
Habeas Corpus through which Mr. Cosby sought dismissal of the charges
based on the binding promise not to prosecute made by District Attorney
Castor.
12. According to a sworn and notarized affidavit of Mr. Castor,
Judge O'Neill chose to assign this particular criminal case to himself.
Attached hereto as Exhibil"4'is the Affidavit of Bruce Castor. dated
October 20,2018. The lower court should have known that by assigning
the matter to himself he would preside over a hearing in which Mr. Castor
would be called as the primary witness on the key issue of whether this
prosecution could proceed. As set forth more fully below, during the
subsequent hearing at which Mr. Castor testified, the lower court took
questioned Mr. Castor and, in Mr. Castor's words, proceeded to treat
Mr. Castor with "tremendous animosity" before determining that Mr. Castor
lacked credibility. See Ex. 41117. At no time, either before or after the
hearing, did the lower court disclose his contentious relationship with
Mr. Castor.
13. Subsequently, on May 24, 2016, a preliminary hearing was held
before Magisterial District Judge Elizabeth McHugh and all charges were
held for court.
14. On July 13,2016, a three-count Criminal lnformation was filed

charging Mr. Cosby with aggravated indecent assault pursuant to 18
Pa.C.S. $3125(a)(1)(Count 1); aggravated indecent assault pursuant to 18
Pa.C.S. $3125(a)(4)(Count 2); and aggravated indecent assault pursuant to
1 8 Pa.C.S.531 2s(aXsXCount 3).
15. Shortly before trial, the prosecution filed a motion to admit the
testimony of more than a dozen accusers about misconduct they claim
occurred decades ago. On February 24,2017, the lower court entered an
order allowing the testimony of only one "404(b) witness," whose
accusations were most recent in time, yet still more than two decades old.
On May 22, 2017 , a jury was selected, and trial commenced on June 5,
2017 . On June 17,2017, however, the lower court declared a mistrial as
the jury could not reach a verdict after six days of deliberations.
16. Shortly before start of the second trial, the prosecution again
filed a motion seeking to admit the testimony of more than a dozen "404(b)
witnesses." This time, the lower court, without explanation and in stark
contrast to his ruling in the first trial, entered an order allowing five such
witnesses to testify. A jury was subsequently selected, and trial
commenced on April 9, 2018. Following testimony from not only the five
"404(b) witnesses," but also additional witnesses called by the prosecution
to bolster their credibility, the jury returned a verdict of guilty on the charges
on April 26,2018.
17. Subsequent to the return of the verdict, Mr. Cosby's bail was
continued, but modified to provide that he be confined to his Pennsylvania
home pending sentencing.
18. As noted above, the lower court, on September 25, 2018,
sentenced Mr. Cosby on Count One of the Criminal Information to, inter
alia, a term of incarceration of not less than three (3) nor more than ten (10)
years imprisonment. See Ex. "1," p. 120. The lower court determined that
the verdicts on Counts Two and Three merged with Count One. ld.,
pp 106-107, 120. The lower court also declared, immediately prior to
imposing sentence, that Mr. Cosby was a "sexually violent predator" within
the meaning of 42Pa.C.S. 59799.58(eX3).
19. As reflected above, the oral motion for bail was denied, and the
Order concerning the same was entered on September 27 ,2018.

OBJECTIONS TO THE DETERMINATION AND THE REASONS WHY
POST.SENTENCING BAIL SHOULD BE GRANTED
20. The Pennsylvania Rules of Criminal Procedure address the
provision of bail after a finding of gui[. In relevant part,
Pa. R.Crim. P. 521 (B)(2) provides:
...when the sentence imposed

includes imprisonment of 2 years or
more, the defendant shall not have
the same right to bail as before
verdict, but bail may be allowed in
the discretion of the judge.
21. lt is beyond dispute that Pa.R.Crim.P. 521(8)(2) provides the
lower court with the discretion to impose bail post-sentencing. Moreover,
this Court has recognized that an abuse of discretion will occur where the
record discloses that "'...the trial court exercised manifestly unreasonable
judgment or based its decision on ill will, bias or prejudice...."' Commw. v.
Heckman, 66 A.3d 765, 768 (Pa. Super.2013), quoting Commw. v. Ruby,
838 A.2d 786, 788 (Pa. Super. 2003).
22. The record in this case reflects that the lower court's decision to
deny Mr. Cosby bail post-sentencing was a clear abuse of discretion.
23. Prior to sentencing, Mr. Cosby's counsel filed a motion for
recusal based on the lower court's undisclosed contentious relationship

with Mr. Castor, and sought a hearing regarding the same in which the
testimony of percipient witnesses, including Mr. Castor, would be
introduced. The lower court denied the motion without a hearing in a
Memorandum Opinion and Order dated September 19, 2018.
24. ln support of the request for bail, Mr. Cosby's counsel advised
the lower court that an appeal was imminent and that there were
substantial legal issues, including recusal, to be raised on appeal. See
Ex. 1, pp. 120-121, 124, 127-128. The lower court summarily dismissed
this fact.
25. Moreover, the record reflects that, at age 81 and legally blind,
Mr. Cosby is a threat to no one. He was out on bail prior to sentencing,
complied with his conditions of bail, and appeared for all required court
proceedings.
26. The record demonstrates both that bail pending the
determination of Mr. Cosby's Post-Sentence Motion and, if necessary,
pending appeal is warranted, and that the judge abused his discretion by
not granting the same. The above issues will be addressed below,
seriatim.
10
II. NUMEROUS ERRORS BY THE LOWER COURT VIOLATED
MR. COSBY'S CONSTITUTIONAL RIGHTS AND COMPEL THE
CONCLUSION THAT THE CONVICTION SHOULD BE
REVERSED AND THE CASE DISMISSED OR, AT A MINIMUM,
THAT A NEW TRIAL IS WARRANTED. THE LOWER COURT
SUMMARILY DISMISSED THIS ARGUMENT, EFFECTIVELY
EXERCISING NO DISCRETION ON BAIL.
27. The issues that are anticipated to be raised on appeal are so
strong as to warrant the provision of post-sentencing bail. These issues
include, but are not limited to, the following:
a. The lower court failed to disclose his contentious relationship

with a material witness on a critical issue concerning
whether the prosecution aqainst Mr. Cosby could even
proceed, the circumstances of which compelled his recusal
from this case.
i. A legitimate and significant issue exists concerning
the failure of the lower court to disclose a contentious
relationship that he had with a material witness in this case.
That personal history created a bias, or at the very least, a
perception of bias, so significant as to call into question the
impartiality of the lower court and its ability to fairly decide
dispositive issues in this case. That bias, whether real or
perceived, also mandated the lower court's recusal from, at a
minimum, deciding any motions predicated, even in part, upon
11
the testimony of this critical witness. Specifically, and as
referenced above, a Petition for Writ of Habeas Corpus was
filed seeking the dismissal of the charges based on District
Attorney Castor's 2005 promise that he would not prosecute
Mr. Cosby. At a hearing on the Petition, Mr. Castor testified
that it was his intent to bind the Commonwealth to never
prosecute Mr. Cosby. See Notes of Testimony, dated
February 2,2016, at p. 63, lines 20-25; p. 63, attached hereto
as Exhibit"2." Mr. Castor made the promise not to prosecute in
orderto place Mr. Cosby in the position of being precluded from
invoking his Fifth Amendment rights in a deposition in the
complainant's civil suit. ld., pp. 63-65. Indeed, Mr. Castor
testified that "... I made the decision as the sovereign that
Mr. Cosby would not be prosecuted no matter what. As a
matter of law, that then made it so that he could not take the
Fifth Amendment ever as a matter of law." ld., p. 64, lines 17-
20.
ii. Then District Attorney Castor advised Mr. Cosby's
counsel, Walter Phillips, of his promise not to prosecute
L2
Mr. Cosby. ld. at pp. 64-67.1 In reliance on that promise,
Mr. Cosby's counsel allowed Mr. Cosby to be deposed in the
civil suit. See Notes of Testimony dated February 3,2016,
pp 10-1 1', 13-14 (Testimony of John Patrick Schmitt, counsel to
Mr. Cosby). Relevant portions of Attorney Schmitt's testimony
are attached hereto as Exhibit "3." Indeed, Attorney Schmitt, an
experienced 36-year practitioner, testified, "Mr. Cosby sat for a
deposition. We did that knowing that the criminal litigation-
that the criminal matter had been concluded and could not be
reopened.' ld., p. 13, lines 18-21. Becauseof DistrictAttorney
Castor's binding promise not to prosecute, Mr. Cosby could not,
and did not, invoke his rights under the Fifth Amendment to the
United States Constitution. Consistent with District Attorney
Castor's promise, and all parties' understanding of that
promise, Mr. Cosby was not prosecuted over the next decade,
including the two terms Risa Ferman served as District Attorney
from 2008 through 2016.
1 Mr. Phillips died in February 2015.

13
iii. lndeed, Mr. Cosby was not prosecuted until First
Assistant District Attorney Kevin Steele decided to make the
matter an issue in his 2015 campaign for election against
Mr. Castor, who had decided to again run for District Attorney.
Campaigning on a promise to prosecute Mr. Cosby, Mr. Steele
ultimately won the election and charged Mr. Cosby for the very
conduct for which he had been promised he would never be
prosecuted, a promise on which Mr. Cosby had expressly
relied, to his detriment.
iv. Although the lower court was well aware that
Mr. Castor was a critical and material witness to the existence
of this promise not to prosecute, the lower court did not disclose
the contentious relationship that he had with Mr. Castor. With
respect to that relationship, see Ex. "4" , which chronicles the
strained relationship between him and the lower court. In short,
Mr. Castor and Judge O'Neill were political rivals in 1999, over
the Office of the District Attorney. ld., fl1. During the campaign
for the party endorsement, Judge O'Neill accused Mr. Castor of
engaging in conduct during a political debate that sought to
L4
exploit a personal and private family issue. ld., t[112-8.
Specifically, Mr. Castor and Judge O'Neill debated each other
at an event where a female Assistant District Attorney with
whom Judge O'Neill had an extramarital affair was present in
the front row. ld., 1[[2-3. According to Mr. Castor's sworn
affidavit, Judge O'Neill seemed "distracted, unfocused, and
neryous" during that event. ld., 1[2. The next morning, Judge
O'Neill's campaign manager called Montgomery County's
Republican Party Chairman to complain that placing the female
prosecutor in the front of the debate to distract Judge O'Neill
was "playing dirty politics." ld., 1[3. Later, while leaving a
subsequent political event, Mr. Castor encountered Judge
O'Neill and his wife. ld., 115. Judge O'Neill, in front of several
witnesses, angrily accused Mr. Castor and his supporters of
"running a smear campaign and trying to ruin his marriage and
life." ld., fl115, 8. Mr. Castor won the Republican Party
endorsement for DA, causing Judge O'Neill to withdraw his
name from consideration for the election. ld., 116. Mr. Castor
believes that Judge O'Neill has never forgiven him or his
15
political supporters for using Judge O'Neill's marital infidelity as
a "smear campaign," and that Judge O'Neill's subsequent
conduct confirms that belief. ld., 1Jfl8-9. Mr. Castor describes
his relationship with Judge O'Neill over the next sixteen years
as "strained and tense." ld., flg. Judge O'Neill was appointed

to the bench in2002. ld., fl10. From 2002 until 2008, while
Mr. Castor served as DA, he does not recall ever personally
appearing before Judge O'Neill, and would have assigned
another prosecutor to appear before Judge O'Neill "so as to
avoid being put in a position where Judge O'Neill could
embarrass or humiliate me and potentially damage the
prosecution." ld., fl11. lt was after Mr. Castor secured the
endorsement of the party and was thereafter elected as the
District Attorney in 1999 that he investigated the allegations
lodged by the complainant. Had then Attorney O'Neill won the
endorsement and been elected, he would have been the
District Attorney that would have investigated these allegations.
v. Additionally, while serving as District Attorney and,
thereafter, Montgomery County Commissioner from 2008 to
t6
2016, Mr. Castor was placed in the position where he initially
opposed certain court-related programs supported and
proffered by Judge O'Neill. ld., ![fl13-14. As the attached
Affidavit reflects, Mr. Castor felt and believed that Judge O'Neill
harbored ill will toward him. See Cg. ld., 11fl8-9, 17.
vi. Despite this adverse relationship, which was so
strained as to warrant recusal from the case, the lower court
never disclosed the same to Mr. Cosby or his counsel.
lronically, according to Mr. Castor's sworn affidavit, the lower
court chose to assign the case to himself, thereby putting
himself in a position to make a decision regarding Mr. Castor's
credibility. ld., fl15.
vii. A review of the transcript of the hearing on the
Petition for Writ of Habeas Corpus reflects that despite
thorough cross-examination from a seasoned prosecutor, the
lower court, sua sponfe, repeatedly questioned Mr. Castor on
his promise not to prosecute Mr. Cosby. See eg., Ex. 2 at
pp.223-238. Mr. Castor felt "tremendous animosity" from
Judge O'Neill just from the tone of his questions. See Ex. 4
17
1117. A review of the transcript of that hearing demonstrates
that the lower court was never going to find Mr. Castor credible,
specifically stating, in response to arguments on the Petition by
Mr. Cosby's counsel:
THE COURT: Agreed, but, again,

your whole argument is premised
that this Court believes everything
that Mr. Castor said because he's
the only one testifying as to a promise.
He's the only one. It's not - - Mr. Phillips
isn't here. Mr. Cosby wasn't in the
room. You weren't in the room.
Mr. McMonagle. There's no other
witness to the promise.
So what' l'm trying to say is you've kind

of - - you know, the rabbit is in the hat.
And you want me at this stage to assume
that, hey, the promise was made, Judge.
Just accept that. And now everything
else doesn't really - - and I just wanted
to make sure that if there's cases in which
there's - - like this where one person
said they made the promise or a
potential defendant claims a prosecutor
made the promise, that might help,
too, you know. But I just wanted to make
sure that by the fact you're arguing it
doesn't make the promise enforceable.
See Ex., 3, Notes of Testimony dated February 3,2016,
p.269-270.
viii. On February 4,2016, immediately after two days of
testimony, the lower court issued an Order denying the Petition.
See Ex. "5." The lower court's Order states that "... based upon
review of all the pleadings and filings, the exhibits admitted at
the hearing, and all testimony of witnesses, with a credibilitv
determination being an inherent part of this Court's rulinq, the
Court find that there is no basis to grant the relief requested... "
and that the Petition is denied. ld. (emphasis added). In other
words, the lower court did not believe the testimony of former
District Attorney Castor. According to Mr. Castor, Judge O'Neill
intentionally publicly embarrassed him because he believed
Mr. Castor had flaunted an affair in order to win the party's
endorsement years earlier.
ix. With respect to this disclosure and recusal issue, on
September 11 ,2018, Mr. Cosby filed a "Motion for Disclosure,
Recusal and for Reconsideration of Recusal" and a
Memorandum of Law in support thereof. A copy of that Motion
is attached as Exhibit "6." Through that Motion, Mr. Cosby
asked the Court to make a disclosure related to Mr. Castor:
19
vacate the February 4,2016 Order denying his Petition for Writ
of Habeas Corpus; recuse itself from further proceedings; and
reconsider the denial of a prior motion for recusal, the basis for
which was independent of the instant issue. The lower court
denied the Motion without a hearing.
x. On September 19,2018, the lower court issued a
Memorandum Opinion and Order Sur Recusal. A copy of the
lower court's Memorandum Opinion and Order Sur Recusal is
attached hereto as Exhibtt"T.' In that Opinion, the lower court,
in addition to asserting that the Motion was untimely, goes on to
characterize the claim as "unsubstantiated" and "facially
meritless." According to the lower court, a hearing was "neither
required nor necessary." ld., p. 5. lronically, the lower court, in
its Opinion, recounts and relies on facts not of record
concerning his personal history on the bench and his
interactions with Mr. Castor-precisely the type of facts that
should have been disclosed and explored at a hearing, and,
where applicable, rebutted. See eg. , Ex. 7, pp. 5-6 (the lower
court discussing his tenure on the bench, and his interaction
20
with Mr. Castor over that period of time). Had a hearing been
granted, Mr. Castor would have testified inconsistently with the
trial judge's conclusions. See, Ex. 4.
xi. Given. (a) the adverse nature of the relationship
between Mr. Castor and the lower court; (b) that Mr. Castor was
the key witness concerning the promise that Mr. Cosby would
not be prosecuted; (c) that the lower court did not disclose that
adverse relationship; (d) that the lower court ostensibly made a
finding that Mr. Castor was not credible; and (e) that Mr. Cosby,
upon learning of the relationship, filed a motion questioning the
foregoing, the lower court should have, at a minimum, held a
hearing on this motion.
xii. The integrity of Mr. Cosby's criminal conviction is
marred by the lower court's failure to disclose, at any time
before or after denying the Petition for Writ of Habeas Corpus,
the nature of his contentious relationship with Mr. Castor.
Mr. Cosby had a right to have his Petition reviewed and
decided by a judge who could make a decision free of bias, or
even the perception of bias, where the ability to prosecute
2I
Mr. Cosby hinged on the testimony of the 2005 District
Attorney. This is a fundamental issue in the case implicating
Mr. Cosby's right to Due Process of Law under the Constitution
of the United States. as well as the Constitution of the
Commonwealth of Pennsylvania. Further, this issue is
meritorious such that Mr. Cosby should have been granted
post-sentencing bail.
b. The lower court's decision to denv Mr. Cosby's "Motion to

Suppress the Contents of his Deposition Testimonv and anv
Evidence Derived Therefrom on the Basis that the District
Attornev's Promise Not to Prosecute him lnduced him to
Waive his Fifth Amendment Riqht Aqainst Self-lncrimination"
(the "Motion to Suppress Deposition Testimonv") was not
onlv leqallv flawed. but also suffered from the same biases
as set forth above.
i. Related to the above issue, the lower court also
denied Mr. Cosby's Motion to Suppress Deposition Testimony.
Through this Motion, Mr. Cosby sought to suppress his civil
deposition testimony because it was provided in reliance on the
promise by the Commonwealth, through District Attorney
Castor, that Mr. Cosby would never be prosecuted for
complainant's allegations. Mr. Cosby's reliance on DA Castor's
22
promise is evidenced by the following exchange with
Mr. Cosby's civil counsel, Attorney Schmitt:
Q: lf you had known that the criminal

investigation in Montgomery County could be
reopened, how would it have affected your
representation if at all?
A: We certainly wouldn't have let him sit for a

deposition.
Ex. 3, p. 14,lines 6-10. Accordingly, and as set forth in
Mr. Cosby's motion, the Commonwealth was estopped from
using the deposition and any evidence obtained therefrom at
trial. The lower court's ruling, in allowing the Commonwealth to
use that deposition, violated Mr. Cosby's right to Due Process
of Law and his right against self-incrlmination as guaranteed by
the Constitution of the United States and the Constitution of the
Commonwealth of Pennsylvania.
ii. The two-day hearing that was held on the Petition
for Writ of Habeas Corpus was offered in support of the Motion
to Suppress Deposition Testimony. No further evidence was
provided by either party. As noted, the lower court ultimately
denied that Motion. A copy of the lower court's Findings of

Fact, Conclusions of Law and Order are attached hereto as
Exhibit "8." The Findings of Fact reflect that the lower court
challenged Mr. Castor's testimony and found, among other
things, that "...there were numerous inconsistencies in the
testimony and writings of Mr. Castor and [that the lower court]
has previously ruled that credibility determinations were an
inherent part of this Court's denial of the Defendants' initial
'Petition for Writ of Habeas Corpus."' Ex. 8, Finding 40. The
lower court concluded that "...there was neither an agreement
nor a promise not to prosecute...." ld., Conclusion 1.
Noteworthy, however, is the fact that Mr. Castor was not the
only witness to testify as to the existence of the promise not to
prosecute Mr. Cosby; as referenced above, Mr. Cosby's
counsel, John Schmitt, also testified as to the same. See e.q.,
Ex. 3, pp. 10-11 (ln response to a question concerning whether
he had an understanding "as to whether the criminal
investigation could be continued, could be re-opened," Attorney
Schmitt responded, "l had an understanding that it could not be.
I spoke to Mr. Phillips who indicated that, although the District
24
Attorney had determined there wasn't sufficient evidence to
charge Mr. Cosby, that he did anticipate that there would be
civil litigation. And he wanted to ensure that Mr. Cosby could
be compelled to testify in a civil litigation. And, therefore, his
decision was-it was an irrevocable commitment to us that he
was not going to prosecute."). See also ld. at p.40,lines 12-16
(Mr. Schmitt testifying, "l don't need to worry about the Fifth
Amendment because there is no risk of jeopardy to Mr. Cosby
because the District Attorney has agreed irrevocably that there
would be no criminal prosecution."). Although the lower court
acknowledged that Mr. Phillips had told Mr. Schmitt of
Mr. Castor's promise not to prosecute (See Ex. 8, Finding 21),
the lower court failed to reconcile this support with his
conclusion that this promise did not exist. The import of
Mr. Schmitt's testimony is simply ignored by the lower court.
iii. This issue has significant merit. Not only did the
lower court err in denying the Motion, he compounded his error
by considering, ruling on, and ultimately denying the Motion
without disclosing the strained and tense relationship he had
25
with Mr. Castor. The nature of that relationship mandated that
the lower court disclose his bias, or perceived bias, against
Mr. Castor and recuse himself from the case. The lower court's
failure to do so, and his more recent refusal to conduct a
hearing, warrants bail pending appeal in and of itself.
c. lf the Commonwealth had the abilitv to prosecute Mr. Cosbv,

which it did not. then the inexplicable twelve-vear delay in
filins charqes preiudiced Mr. Cosby and violated his riqht to
Due Process of Law.
In addition to the issues set forth above.
Mr. Cosby's Motion to Dismiss Charges Based on Deprivation
of Defendant's Due Process Rights should have been granted.
This is yet another meritorious issue. The complainant lodged
her allegations against Mr. Cosby in January 2005. As set forth
above, the Commonwealth promised not to prosecute
Mr. Cosby. lf no non-prosecution agreement existed, as the
current District Attorney argues, then the failure to file criminal
charges against Mr. Cosby over the past twelve (12) years has
been inexcusable and without valid reason. Over that twelve-
year period, Mr. Cosby has been substantially prejudiced
insofar as: (a) a critical witness to the non-prosecution

agreement has died; (b) memories have faded; and
(c) Mr. Cosby's health has deteriorated in that he is now legally
blind. For example, during an argument on the Motion to
Suppress Deposition Testimony held on September 6, 2016,
the lower court repeatedly pushed Mr. Cosby's counsel to
identify evidence besides Mr. Castor's testimony to support the
existence of the promise to not prosecute Mr. Cosby. See eg.
Notes of Testimony dated September 6, 2016, at pp. 34-40. A
true and correct copy of the relevant portions of these Notes of
Testimony is attached hereto as Exhibit.9." Although
Mr. Cosby's counsel reminded the lower court that Walter
Phillips, the cdminal defense attorney who represented
Mr. Cosby in 2005 when the promise was made, had died in
February 2015 (prior to the criminal charges filed later that year
and the new DA's position that there was no agreement to
prosecute), the lower court expressed skepticism that the
promise existed expressly because Mr. Castor was the only
percipient witness who testified and "Mr. Phillips isn't here."
27
Ex. 3, p. 269. Mr. Phillips's unavailability clearly had a negative
impact on the lower court.
d. The lower court infringed on Mr. Cosby's Due Process riqhts,

violated law. and abused his discretion by allowinq five
women to testify that Mr. Cosby sexually assaulted them at
various times durinq the 1980's. conduct with which
Mr. Cosbv was not charqed, that was remote in time, and
that served no purpose other than to smear Mr. Cosbv.
i. Mr. Cosby also intends to challenge on appeal the
lower court's decision, without any explanation, to permit five
women to testify at Mr. Cosby's second trial that he engaged in
inappropriate sexual contact with them. The lower court's
admission of this extremely prejudicial testimony was wholly
inappropriate under both the Pennsylvania Rules of Evidence
and the Constitutions of the United States and the
Commonwealth of Pennsylvania. That Mr. Cosby suffered
severe prejudice as a result of this decision by the lower court
is evidenced by the fact that, at Mr. Cosby's first trial, where
only one "404(b) witness" was permitted to testify, the jury could
not reach a verdict and a mistrial was declared. Subsequent
thereto, and prior to the second trial, the Commonwealth filed a
Motion to Introduce Evidence of 19 Prior Bad Acts from 19

28
different women. Other than the fact that the prosecution could
not prove its case during the first trial, the prosecution offered
no legitimate reason as to why the judge should increase the
number of accusers permitted to testify. On March 15, 2018,
the lower court issued an Order permitting five accusers beside
the complainant to testify. A copy of the lower court's Order is
attached hereto as Exhibit

.10." That Order improperly tipped
the scales in favor of conviction, and the lower court's failure to
provide any justification for the change in his ruling is telling.
This additional meritorious appellate issue constitutes further
reason to grant bail pending appeal.
28. The issues set forth above are but some of the issues that will
be raised on appeal. By identifying the above in this Petition, Mr. Cosby is
not in any way waiving any other issue that is properly preserved and that
he may raise on appeal. Instead, the above are illustrative of the significant
and meritorious issues that exist in this case. lf successful on appeal,
Mr. Cosby's conviction will be reversed and vacated.
29. Given the meritorious nature of the issues to be raised on
appeal, and their significance, bail is warranted. The lower court abused its
discretion by concluding otherwise. Moreover, the lower court abused its
discretion by refusing to even assess whether Mr. Cosby had meritorious
issues on appeal as a basis for his decision on bail.
III. GIVEN MR. COSBY'S AGE AND THE FACT THAT HE IS

LEGALLY BLIND, THE LOWER COURT'S ASSERTION THAT
MR. COSBY IS A RISK TO REOFFEND AND THAT IMMEDIATE
INCARCERATION IN LIEU OF BAIL IS NEEDED TO PROTECT
THE PUBLIC IS WITHOUT SUPPORT IN FACT.
30. As set forth above. the lower court advised that his "... reasons
for the sentence is [sic] the reasons that I am relying on in denying this
defendant bail." Ex. "1," p. 132, lines 14-16. The lower court noted that the
crime is a sexual assault crime, and that "...what this Court has before me
indicates that he could quite possibly be a danger to the community." ld. at
p. 132,lines 19-23. That assertion is meritless and there was nothing
before the lower court to support its claim.
31. Mr. Cosby, who is 81 and legally blind, is clearly not a danger to
the community. Mr. Cosby was out on bail prior to trial without incident.
After the verdict, Mr. Cosby was confined to his home as a condition to
continuing bail, again, without incident, and complied with all bail
conditions.
30
32. Dr. Timothy Foley, PH.D., a licensed psychologist, evaluated
Mr. Cosby in relation to his risk for recidivism. Citing Mr. Cosby's age and
poor health, Dr. Foley testified in his expert opinion that Mr. Cosby's risk of
recidivism is "extraordinarily low." See Notes of Testimony from SVP
Hearing/Sentencing Hearing dated September 25, 2018 p. 25, at Ex. 1 .
33. Moreover, prior to the instant conviction, Mr. Cosby had no prior
criminal record.
34. The lower court's denial of bail on the purported basis that
Mr. Cosby is a danger to the community was a clear abuse of discretion,
particularly in light of the meritorious issues on appeal.
A SHORT STATEMENT OF RELIEF SOUGHT
35. As referenced above, Mr. Cosby was initially released on bail

on December 30,2015, the date of his arrest. Mr. Cosby did not violate
any conditions of bail and appeared for all required Court proceedings.
36. Subsequent to the jury returning its verdict, as a condition of
bail, Mr. Cosby was confined to in-house arrest. Again, Mr. Cosby
appeared for all court proceedings.
37. Mr. Cosby seeks the reinstatement of bail as it existed prior to
sentencing.
31
WHEREFORE, the Petitioner respectfully requests that this
Honorable Court reverse the Order of the lower court denying Mr. Cosby
bail; grant to Mr. Cosby bail in the amount previously set, which was
$1,000,000.00, ten percent acceptable; and enter such other relief as this
Courl deems just and reasonable. Alternatively, to the extent that this
Honorable Court believes that it cannot grant this Petition on its face, or
has questions concerning the same, it is requested that this Honorable
Court grant a hearing on this Petition.
Respectfu ly su bm itted,
I
PERRY SHORE WEISENBERGER &

ZEMLOCK
bq'/
Supreme Court lD 75647
2411 North Front Street
Harrisburg, PA 1711Q
(717) 232-9900
t/
l/ t '4r--
L/'
Kristen L. Weisenberger, Esquire
Supreme Court lD 84757
2411 North Front Street
Harrisburg, PA 17110
(717) 232-ee0o
Date: October 23,2018

32
CERTIFICATE OF COMPLIANCE
Pursuant to Rule 127(a) of the Pennsylvania Rules of Appellate
Procedure, I hereby certified that this filing complies with the provisions of
the Case Records Public Access Policy of the Unified Judicial System of
Pe n n sylva n i a that req u i re fi Ii n g confidentia I i nformation a nd docu ments
differently than non-confidential information and documents.
Date: lO - a3 - l3
rian W. Perry, Esquire
33
VERIFICATION
I do hereby swear and affirm that the facts and matters set forth in the
within Petition for Review are true and correct to the best of my knowledge,
information and belief. The undersigned understands that the statements
made therein are made subject to the penalties of 18 Pa. C.S. 54904
relating to unsworn falsification to authorities.
Date. lo - d3- t(
Brian W. Perry, Eilquire
t-t'{------.
34
APPENDIX A
IN THE COURT OF COMMON PLEAS OF MONTGOMERY COUNTY, PENNSYLVAIiIIA
CRIMINAL DTVISION
COMMONWEALTH OF PENNSYLVANIA No. 3932-16
v.
WILLIAM H. COSBY, JR.
ORDER
AI{D NOW, this 27:*' day of September,2018, the Defendant's request for bail
pending appeal pursuant to Pa. R. Crim. P. 521 (B)(2), is hereby DENIED, for the
reasons set forth on tfre record on September 25, 2018.
BY THE COURT:
STEVEII T. O'NEILL, J.
lt
Copies of this Ord.er mailed o"?PJL&to the following:
Joseph P. Green, Esq.
Kevin R. Steele, Esq.
M. Stewart Ryan, Esq.
Kristen Gibbons Feden, Esq.
Administrator) Q
h
eJ :L
tn
rh !:
3
r d$:'
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EXHIBIT 1
IN THE COURT OF COMMON PLEAS
IN AND FOR THE COUNTY OF MONTGOMERY, PENNSYLVANIA
CRIMINAL DIVI S ION
COMMONWEALTH OF PENNSYLVANIA
\/ q NO. 3932-16
wrLLrAM H. COSBY, JR.
SVP HEARING/SENTENCING HEARING
Courtroom A
Tuesduy, Sept.ember 25, 2078
Cnmmcncinrr
rr v ! ar Y at 9:21 a.m.
Virginia M. Womelsdorf, RPR

Official- Court Reporter
Mnn]- .r.rmAr\/ Cnrrnf rz (lorrrf hOUSe
Nnrli stown - Pennqrrl rrania
f uuvvrrl, v_Irwsrl
BEFORE: THE HONORABLE STEVEN T. OINEILL, JUDGE

COUNSEL APPEARED AS FOLLOWS:
KEVIN R. STEELE, ESQUIRE

Dist.rict Attorney
M. STEWART RYAN, ESQUIRE
KRISTEN GIBBONS_FEDEN, ESQUIRE
TRACY S. PIATKOWSKI, ESQU]RE
Assistant District Attornevs
for the Commonwealth
JOSEPH P. GREEN, JR., ESQU]RE

EL]ZABETH A. REDMOND, ESQUIRE
PETER GOLDBERGER, ESQUIRE
for the Defendant
]NDEX
COMMONWEALTH I S EVIDENCE
Witness VDire Direct Cros s Redir Recr

KRISTEN F. DUDLEY, Psy. D. 11 5
12
DEFENDANT I S EVIDENCE
Wi-t.ne s s VDire Dire ct Cro s s Redir Recr

TTMOTHY P. FOLEY/ 6 21 26 53 54
Ph. D.
EXHIBITS
DEFENDANT I S
Number De s cr ipt ion Marked Recrd

D-SVP-1 Report of Timothy P. Fo1ey, 24
Ph.D. dated 9-11-18
D-SVP-2 Special Section DSM-5 and 7 22
paraphilic Disorders
D-SVP-3 Curricufum Vitae of Timothv P. 18 19
FoIey, Ph. D.
Dana
Sentence of the Court 1'1 0

1 COMMONWEALTH vs . WILLIAM H. COSBY, JR . 4
Z (The following proceedings were

3 commenced with the Court, Mr. SteeIe,
4 Mr. Ryan, Ms. Feden, Ms. Piatkowski, Mr.
q
Green, Ms. Redmond, Mr. Goldberger, and
b the defendant being present: )
B THE COURT: AI1 right. Mr. Green, you
9 m^\/ ra I I \/nrrr
I "" witneSS.
10 MR. GREEN: Your Honor, I'm going to
11 start by recalling Dr. Dudley for a moment.
L2 THE COURT: Recal-l-ing?
13 MR. GREEN: Dr. Dudley.
I4 THE COURT: For the record, at this
15 stage we are returning to the Sexually Viol-ent. Predator
16 Hearing. And then you woul-d be calling Mr. Green,
I1 you'11 be calling a witness f or the Sexually Viol-ent
1B Predator Hearing. If you are calling your witness for
79 nfher nrrrncrsFR- nlpaqc let
! _vu me knOw that that is
20 occurrr-ng.
27 MR. GREEN: Yes, I will.
22 THE COURT: Thank you.
23
24 KRTSTEN F. DUDLEY, PSY. D., having been
z3 r.lrrlrr
vurf arrrAFr]- waS examined
urrv!1rt and testified
1 KRTSTEN F. DUDLEY, PSY. D. RECROSS
2 as follows:
3 FURTHER RECROS S-EXAMINATION
4 BY MR. GREEN:
5 O Doctor, you testified yesterday and were asked

srlmF crlrFsf i ons about the def inition of Daraoh iI ic
7 disorder that vou identified.
B Do you remember those questions,
9 def ini t i onal que s t ion s ?
10 A I do.
11 a Do you reca]] testifying that you didn't. remember
L2 what the definition was of paraphilic disorder you were
13 daqnri hi nn?
L4 A I do, yes.
15 MR. GREEN: May I approach the witness,
I6 Your Honor ?
I1 THE COURT: Yes .
1B MR. RYAN: Just so the record is clear,

L9 Your Honor, I believe counsel is approaching with a
20 document he's iust provided to me for the first time.

ZL rTl-
L A11 11 F^rq o
qyyEqr fu(J^ 1-^
UC 1^
I U h^.-as
.i
all n lcncrfh.Lrr
rslrV I haVentt Seen
POVCD
22 it. f don't know if the witness has seen it, so Ird

23 ask
24 THE COURT: We11, then the wiLness wil-I
25 be permitted time t.o review the document. If she needs
I
KRISTEN F. DUDLEY, psy.D. - RECROSS 6
Z it, she'll let us know.

3 THE WITNESS: I would like a minute to
4 revlew this.
q THE COURT: Thank you.
o MR . GREEN : And I wi l- I give the Court
1 and counsel and the witness a heads-up that f intend to
B focus on the definitionaf portion on Page on the
9 I h i rd -HgY"
ner-rF nf D-SVP-3 .
10
11 ( Discuss j-on of f the record. )
I2
13 MR. GREEN: Judge, I have a bench copy.
I4 Wnrr'l d \/nlr
r vq like it?
15 THE COURT: If you have one' it. would
I6 help.
17 MR. GREEN: Judge, after consult.ation
1B uril-h nanrr'lo who knOw the exhibits better than I, I'd
L9 ask permission to add the articl-e marked as D-SVP-2.
20 THE COURT: Okay. So we're removing D-3
21 and it's D-SVP-2.
22 MR. GREEN: D-SVP-1 is the Foley fetter
23 previously marked.
24 THE COURT: Foley letter or FoleY
25 rcnnrt Ti-fS a fetter. I See it.
1 KRISTEN F. DUDLEY, PSY. D. RECROSS I
2 ( Special Section DSM-5 and paraphilic

3 Disorders marked Defendantrs Exhibit
4 D-SVP-2 for identification. )
q
MR. GREEN: If the witness is ready,
0 Vnrrr fJnnnr maVy
rrtq T OfOf:eed?
t/'
'
THE COURT: Yes, please.

B BY MR. GREEN:
q
O Doctor, do you recognize the table and the
10 information contained in the table on Page 193 of the
11 renri nt fhat I s marked as Defendantrs SVP-2 ?
12 A Yes.
13 O You recognize that as the DSM-5 diagnostic
I4 crit.eria for paraphilic disorder regarding
15 non-consenting victims?
t_o A I do.
I1 O You recogni ze that in Subparagraph A of t.hat
1B diagnostic criteria, there has to be a finding for one
I9 of the underlying predicate disorders; is that correct?
20 A Yes.
2I A And we talked about the underlying predicate
22 d'isnrdcrs
u!Dv!us!o \/esferdarz
Jsoue!uqJ
anrl
qrru \/nrr
Jvu
didntt idonfifrz
vrret!J an\/
*.._I of them
23 here: ,
is Ihat
Lv correct.?
24 A I bel ieve that. I did .
25 O What. underlying predicate disorder is identified

1 KRI STEN F. DUDLEY, PSY. D. - RECROSS B
2 i n vorr r renort.
J v qr ?
3 A The diagnosis that I came up with is the

4 paraphilic disorder. And in order to meet criteria,
5 the rrover a period of at l-east six months, recurrent
C) and intense sexual arousaltr, that is assumed based on
7 behavior.
B O Okay. ThaL ' s your opinion. f 'm not trying to
u fight with you about what your opinion is.
10 A Okay.
11 O I'm trying to ask you whether you agree what the
L2 diagnostic criteri-a are in the tab-le.
13 A This is the diagnostic criteria, yes.
14 O And you haven't identified any of those four
15 nredir-afes Aq ho'inr^r
Y annl.icable
gYY- here at aIl?
76 A Again
T7 a A simple yes or no would be helpful.
1B A Yes, I have.
T9 O Which one have you identified as being applicable?
20 A Okay, I see what you're asking. If you're asking
21 whether Mr. Cosby meets the criteri-a for voyeuristic
22 di sorder
23 O For any one of those four underlying predicate
24 disorders.
25 A No.
1 KRISTEN F. DUDLEY, PSY. D. RECROSS 9
2 O And the next is f'd like to invite your

3 attention down to the remission criteria. Do you see
4 that ? I f you go down about two-t.hirds of the wdy, it
q
says in full remission. Do you see that?
A f do.
1 O And the diagnostic criteria for what. is call-ed
B full remission is not acting on any urges with a
non-consenting person for at least five years in an

10 uncontrolled environment; is that correct?
11 A That is correct.
I2 O And that clearly applies here; correct.?
13 A It appears to.
I4 O WelI, Doctor, it doesn't appear to. In the l-ast
15 five years, have there been has there been any
I6 credible report of acting out?
L't A There has not been.
1B O In the Iast I4 years, has there been, to your
T9 lrnnr^rlodao
!uuYvrsrrJ ,an\/ r'rarlih'la rannrl- nf er-t'inrr crrrl-?
20 A There has not been.

2I O Okay. So do you think that that would qualify as
ZZ full- remission under the diagnostic criteria identified

23 l-rrr 1-ho nqM-q?
24 A Pot.entialIy.
z3 O Potentially?
1 KRISTEN F. DUDLEY, PSY. D. RECROSS 1O
2 A PotentialIy.
3 0 Okay.
4 A We know that vict j-ms don't always come f orward.
E
O Excuse me?
Ct A We know that victims don't always come forward.

7 O Yeahr dflything is possible; right?
B A So, y€s, anything is possible.
v O And that's reaIIy the basis of your opinion, isn't
10 it, that anything is possible? It's possible that
11 something might happen in the future; is that fair?
I2 A That is fair.
13 0 Doctor, is it still your testimony that the
I4 defendant is properly c-Iassified as suffering from
15 paraphilic disorder involving non-consenting victim
T6 given your admission that he doesn't meet any of the
r'7 diacrnnsfir- r-riteria for anv of the rrnclerlrzino four
1B nrarli cal_ oq?
19 MR. RYAN: Objection. Leading.

20 MR. GREEN: It' s cross-examination.
21, THE COURT: Overruled. She' s as of
22 cross.
23 THE WITNESS : T 'm sorry. CouId you
24 ranall-
lvt/vuuYqvg \/n rrr arrraqf i nn?
25
1 KRISTEN F. DUDLEY, PSY. D. REDIRECT 11
BY MR. GREEN:
O Do you conLinue to express the opinion that the

4 defendant meets the criteria for paraphilic disorder
5 involving non-consenting victims given your admission
o that he doesnrt meet the diagnostic criteria for any of
1 t.he four underlying disorders?
B A There's another chapter or another section of
9 paraphilic disorder. Not aIl the in DSM-4-TR
10 langud9e, it was rrnoL otherwise specified". In DSM-5
11 I anrrrrar-re
gqYv-"-tr it 'i s rrni.hcr sneCifiedtt.
T2 MR. GREEN : Thank you . That I s aI f I

13 have. Thank you.
14 THE COURT: Re-redirect now.
15 FURTHER REDIRECT EXAMINATION
.l_ o BY MR. RYAN:
I1 O Doctor, Iooking at the DSM criteria, you woul-d

1B agree with me that in the overal-1 context of your
I9 rannrt- therg waS a demonstration of behavior over at
20 Ieast a six-month period where there was touching and
2T rubbing against non-consensual persons?

ZZ THE COURT: What page are you on?
23 MR. RYAN: Same pase that werve been
24 on
ZJ THE COURT: Remi-nd me.

t KRTSTEN F. DUDLEY, psy. D. RECROSS 1'2
2 MR. RYAN: -- in this document that I

3 just got.
4 MS . FEDEN: Page 1 93 .
5 THE WITNESS: Okay.
BY MR. RYAN:
7 O You'd agree that in the overal-l- context of your

B renort-
luyvlLr narf of \/r-rrrr .t.,iniOn WaS fOrmed baSed On that
f vu! vy-
9 over a period of six months involving Andrea Constand

10 and others that testified at trial that defendant
11 engaged in a behavior of touching or rubbing against
I2 non-consenting persons ?
13 A Yes.
I4 O Okay. And that would be one of the diagnostic
15 criteria that we see on Page 193 here?
I6 A Thatrs correct.
I1 MR. RYAN: Those are alI the suestions I
1B have.
1q FURTHER RECROSS*EXAMINATION
20 BY MR. GREEN:
a1
LL O Which part of that event qualifies as recurrent?
22 A Wn].cn
23 O Which part of what you just described qualifies as
24 recurrent recruired in the first sentence of

25 Subparagraph A, the diagnostic criteria that counsel
1 KRISTEN F. DUDLEY, PSY.D RECROS S 13
2 i rr st se I er-t ed and read f rOm?

? MR. RYAN: I woufd ob-ject to that. I
4 got a document he literally just handed me. I didn't
5 sel-ectively quote from anything. The document speaks
o f or itsel-f . So if we can Ieave that to the side
1 THE COURT: So you're objecting to what
B he said
v MR. RYAN: To the form of the question.
10 THE COURT: -- which is a question which
11 is not any evidence in the case. You don't l-ike what
T2 he said. So maybe you can rephrase it so that we can
13 aIl- underst.and it.
I4 MR. GREEN: AtI right.
15 THE COURT: Do l-"volr neecl more ti-me to
IO review the document?

I7 MR. RYAN: No. As of right now, he's
1B referring to one section on1y.
19 MR. GREEN: That ' s all Irve been
20 raf orri nn l- n
2L BY MR. GREEN:
22 O Do you see the beginning paragraph or the

23 beginning Iine of the diagnostic criteria A in the
24 DSM-5 for paraphilic disorder involving non-consenting?
ZJ A T see that.
f COMMONWEALTH vs . WfLLIAM H. COSBY, JR . L4
Z O Does it require in Paragraph A over a period of at

3 least six months, recurrent behavior that falls into
4 one of the four predicate disorders? Does the word
q
"recurrent* appear in the first
o A The word rf recurrenttr does appear, and Mr. Cosby Is
1 behavior was recurrent over time, over the course of

B many years.
I MR. GREEN: Thank you.
10 THE COURT: Let me just ask one other
11 question. Again, when you do these reports and you
I2 utilize the statutory definition of mental
13 rl.rnnrm:l ifrr
I4 THE WITNESS: Yes.

15 THE COURT: -- is there anything in the
l-o actual statutory definition of a mental abnormality
I1 thaf tclls \/ou to consult a DSM?
1B THE WITNESS: NO.

19 THE COURT: Okav. And as to the
20 sexually viol-ent predator definition, there it states
21 "due to a mental abnormality or personality disorder".
22 And again, you referenced yesterday to the personality
23 disorder ?
24 THE WITNESS: I di-d.

25 THE COURT: Okay. So you are going
1 COMMONWEALTH vs. WILLIAM H. COSBY, JR. 15
2 from the mental abnormality has a definition, but

3 you're utilizing the sexually violent predator due
4 to a mental abnormality, you're utilizing the
5 rler.sonal ifv disorder section?
THE WITNESS: No, not in this case. So
1 a mentaf abnormality j-t's a mental abnormality such

B as the paraphilia or a personality disorder such as
^^^.i ^r Pv!uvrrqrru_),
^*+.i DUUIAf
allLf êrsona'l itv clisorder.
L
10 THE COURT: Okay. So that's important.

11 So, agai-n, you're util-izing a mentaf abnormality
1"2 paraphilia
13 THE WITNESS: I am, yes.
I4 THE COURT: -- in a definition of mental
15 abnormality that does not require a consultation or
I6 usage of the DSM. I mean, I don't know what
L1 professionally and I'm going to allow them both to
1B ask you questions. I'm just asking in this statute
T9 does it say in order to do so
20 THE WITNESS: The statute does not sav
21, that the DSM needs to be util-i zed.
22 THE COURT: And that woul-d be the onf v
23 reference in t.he definition sections as to definitions

24 of mental abnormafity? Do you know of anything efse in
25 Section 9799 that saVS look somewhere else for a
-L TTMOTHY P. FOLEY, PH. D. - VOrR DrRE L6
2 definition of mental abnormality?

3 THE WITNESS: I could have also used the
4 ICD-10, the International Cl-assif ication diagnosi-s .
5 THE COURT: Did you?

o THE WITNESS: I did not.
1 THE COURT: Okay. So you used DSM-5?
6 THE WITNESS: I used DSM.
THE COURT: A11 riqht. Now, that may
10 A11an lrr.r fnr arrrael- i nnq
11 MR. RYAN: No.

\2 MR. GREEN: No, thank you.
13 THE COURT: Thank you very muchr frd'am.
I4 Ynrr m: \r c f on dOWn .
15 THE WITNESS: Thank you.

IO (Witness excused. )
r'7
1B MR. GREEN: I'd calf Dr. Timothy Foley.

L9
20 TIMOTHY P. FOLEY, PH. D. , having been

2I drr I
sqff rr swnrn - waS examined and test.if ied
22 as follows:
23 EXAMINATION ON VOIR DIRE
24 BY MR. GREEN:
ZJ O PIease state your name and speII your fast name.

1 TTMOTHY p. FOLEY, pH. D. - VOrR DIRE 11
) A Timothy P. Foley, F-O-L-E-Y.

3 O What is your vocation?
4 A I'm a licensed psychologist.
5 O What is your highest educational attainment?
o A I have a Ph. D. in psychology.
1 O How long have you been a Ph.D. in psychology?
B A For approximately 30 years.
9 0 Do you have any state or governmental ficensure in
10 connection with your vocation?
11 A Yes. I'm licensed in Pennsylvania and New Jersey.
L2 O Do you have any experience in the practice of
13 psychology and forensic psychology in the courts?
I4 A Yes, I do.
15 O How Iong have you been practicing forensic
16 psychology in the courts in Pennsylvania and New
I1 Jersey?
1B A In Pennsylvania, since 1990 approximately. And in
L9 Jersey, since 2000 , 200I.
20 O Do you hold any positions with the federal courts
21 in New Jersey and Pennsylvania regarding the
ZZ assessments and treatment of sex offenders?
23 A Yes. I have a purchasing agreement with Federal-
24 Parole and Probation that Irve had for many years.
25 O What do you do in brief for the federal- courts and
1 T]MOTHY P. FOLEY, PH.D. - VOIR DIRE 18
a probation department.s in New Jersey and Pennsylvania?

3 A I primarily do risk assessments, psychologrical
A
= evafuations primarily for child pornography offenses.
5 O Do you have any history of practice j-n the
6 assessment and treatment of sex offenders?
7 A YeS.
B O And where did that begin? What has t.hat. entaifed?

A Over approxi-mately t.he Iast 25 years I've done
10 evaluations in federal and state courts in New Jersey,
11 Pennsylvania, Virginia, DeIaware.
T2 O Do you have any experience with the legislation
13 and litigation of sexually viol-ent predator cases?
14 A Yes. Irve done many cases in Pennsylvania and New
15 Jer sey .
16 O Have you had occasion to participate in the

I7 Iegisl-ative side on the development of SVP legislation
1B by presentations to
I9 A Yes. frve testified in Harrisburq to the
20 legislature in the l-ate '90s i '97, '98.
2L O Have you participated in international forums
)t rA.rard i nrr
Y
fe'r hese issueS ?
23 A Yes.
24 O For instance, when most recently?
ZJ A I believe the Iast time was in Stockhol-m probably
1 TTMOTHY p. FOLEY, pH. D. - VOrR DIRE 19
2 about 13, L4 years ago.

J (Curriculum Vitae of Timothy P. FoIey,
4 Ph. D. marked Defendantts Exhibit D-SVP-3
5 for identification. )
o MR. GREEN: May I approach the witness,

1 Your Honor?
B THE COURT: Yes.
q
BY MR. GREEN:
10 O Sir, Irm going to show you whatrs been marked

11 D-SVP-3. Is that a copy of your most recent Curriculum
t2 Vitae ?
13 A I believe sor yes.

I4 MR. GREEN: Move the admission of D-3.
15 THE COURT: Any objection?
I6 MR. RYAN: No.
I7 THE COURT: It is admitted.
1B ( Def endant' s Exhibit D-SVP-3 rece j-ved in
I9 evidence. )
20 MR. GREEN: Your Honor, the defendant

2L offers Dr. Timothy FoIey as an expert in forensic
22 psychology and specifically in the assessment of
23 persons charged with sex offenses.
24 MR. RYAN: I would object. to that based
ZJ on the report. It's my understanding it is a risk
1 TIMOTHY P. FOLEY, PH. D. - VOIR DIRE 20
assessment. So certainly if he's going to testify as
3 to risk assessment.s, even specifically with regard to

4 sex offenders --
5 THE COURT What type of risk assessment
6 did he do?
1 MR. GREEN What type of risk assessment
B did he do in this case?
9 THE COURT Yes.
10 MR. GREEN I think the best answer to
11 LIIO.L fD f II tck
qON hrm
IlIttt, r t
r! you'd Iike.
L2 THE COURT Well, they're raising an
13 objection to his qualifications as an expert. And what

14 you're saying and I was just asking you said it's
15 based on his report. Now you're calling him as a
t_0 defense witness regarding an SVP' you know, oPinion

1,1 held by a member of the board; correct?
1B MR. GREEN: I am not. I'm limiting what
T9 Trm calling him for. ffm going to ask him the only
20 SVP questions I'fI ask him have to do with the
2L authenticity of the exhibit I just used, and it's
ZZ Iimited to the definitions. I'm not asking him to
23 express SVP opinions.
24 THE COURT: AfI riqht .
25 MR. GREEN: Separatel-v he ' l-l- addres s t.he

1 TIMOTHY P. FOLEY, PH. D. _ DIRECT 27
2 sentencinq issues. And what Irlf do is when I'm

3 f inished t.he questions on the f irst issue, I ' f I tell
4 votl
lvu when Trm mnrli nrr nn t-O the SeCOnd iSSUe.
5 THE COURT: Do you have any objection to

o him being called as a forensic psychologist and break
1 it down?
x MR. RYAN: So that he can say what. the
definitlon on Page 193 is?
10 THE COURT: I don't care what he's going
11 to say. Based on his qualifications, do you have any
I2 objection to calling him as a forensj-c psycho-Iogist
13 based on his experience and his testimony in previous
t4 cases?
15 MR. RYAN: No.
t_0 THE COURT: All right. So, so far we
I1 have one down. What is the further the finding of

1B that that you want to ut.ilize it f or? So he' s a I 'm
79 going to admit him as an expert. in forensic psychology

20 which is broad. Anything else?
2L MR. GREEN: I think that covers it.
')) THE COURT: AII right.
23 DIRECT EXAMINATION
24 BY MR. GREEN:
25 O Doctor, have you had occasion to review what's

1 rrMoTHY P. FOLEY, PH.D. - DTRECT 22
a
L been marked as D-SVP-2, an article reprint written by
J Michael B. First, M. D. , titled DSM-5 and Paraphific
4 Disorders published in the Journaf of the American
5 Academy of Psychiatry and Law, VoIume 42, Pages 192 Lo
20I I in 20I4?
1 A Yes.
B O Based on your experience, your review of that
article and other information in the fie1d, do you have
t_0 An nninion as to whether that's an authoritative work?
11 A Yes.
L2 O And what is your opinion in that regard?
13 A It is. It's been incorporated into the DSM-5.
L4 MR. GREEN: Move the admission of
15 D_SVP_2.
1a
.l_ o THE COURT: Admitted.
t1 t
\
rtof endant I s Exhibit.
ve! D-SVP-2 received in
1B evidence. )
T9 BY MR. GREEN:
20 O Doctor, at my request did you conduct an
27 assessment designed to study and express opini-ons on

zz the l-ikelihood of recidivism expressed or presented by
23 Mr. Cosby?
24 A Yes.
25 O How did you go about conducting that assessment?
1 TIMOTHY P. FOLEY, PH. D. _ DTRECT 23
2 A T reviewed the records Iisted on Pase 1 and 2 of

3 my report, and I met with Mr. Cosby on July lBth for
4 approximately three hours.
5 MR. GREEN: Your Honor, I bel-ieve that
o the report's been marked as D*SVP-1, and I'd move its
1 admission.
B MR. RYAN: I don't have an ob-iect.ion
I with it. I iust want to make sure I under.stand in
10 terms of expert testimony, because there are questions
11 about opinions, if he's being offered for something in
I2 addition to just. general forensic psychology and the
13 definition of
L4 THE COURT: Forensic psychology is a
15 broad, broad category. I'Il hear his testimony. He
I6 examined the defendant about to be sentenced in a
I7 criminal case. ThaL's a very broad category, so I I 11
1B hear him in recrards to his evaf uation.

L9 MR. GREEN I think T moved the
20 admission of D-SVP-1.
21, THE COURT You did.
ZZ MR. GREEN Is it admitted?
23 THE COURT Yes.
24 MR. GREEN I have a bench copy if you'd
25 like one.
1 TIMOTHY P. FOLEY, PH.D. - DIRECT 24
2 ( Defendant's Exhibit D-SVP-1 received in

evidence. )
4 BY MR. GREEN:
5 O Dr. Fo1ey, are you familiar with the Iiterature in

the field on the likel-ihood of re-offending or
1 recidivism?
B A Yes.
9 O And did you express your views in that regard on
10 D:no A aF \/n rrr rannrJ- ?
11 A r did.
TZ O Did notice any disabilities that Mr. Cosby
13 nraeon1-q?
L4 A The records I have indicate blindness, and he

15 demonstrated blindness during my meeting with him.
I6 O Did you notice anything about his age and his
I1 nhrzqin:l r.nn6lition ot.her than his blindness?
1B A He ambul-ates with a caner il€eded assistance.
T9 O Did he seem t.o you in the interactions you had
20 with him to be self-sufficient?
2T A No.
zz O Did you draw any conclusions regarding the risk
23 for sexual offense recidivism in the future? Yes or
24 no?
25 A Yes.
I TIMOTHY P. FOLEY, PH. D. DIRECT 25
2 MR. GREEN: Your Honor, this portion is

3 offered for sentencing. May I proceed?
4 THE COURT: Yes .
5 BY MR. GREEN:
o O What. opinions did you reach regarding his risk for

7 recidivism in the future?
B A Extraordinarily fow.
O Can you explain to the judge why?
10 A Because he's Bl vears old. He's been convicted of
11 a sex offense. Sex offense recidivism declines as a
T2 f unction of aging. Af ter 70, it becomes vj-rtually

13 nccrl i oi hl e - He has no known sexual- misconduct f or the
I4 l-ast 15 years. For all of those reasons, I f ound him
15 to be at extraordinarilv 1ow risk for sex offense
L6 recidivism.
T1 O Did you identify in your report any particular
1B pieces of Iiterature that you think are particularly
19 refevant in that recrard?
20 A Yes, I quoted Barbaree and Bl-anchard.
2L O What is Barbaree and Bl-anchard?
22 A Barbaree and Bl-anchard is a studv that was done on
23 an analysis looking at aging and recidivism, and they
24 found extremely Iow rates. And f'm basically
25 paraphrasing Barbaree and Blanchard saying that over
1 TIMOTHY P. FOLEY, PH.D. - CROSS 26
2 f0, sex offense recidivism becomes negtigibte.

3 O I s Barbaree and Bl-anchard the work that ' s
4 identified in Footnote 1 of your report at Page 4?
( A Yes.
o O And is that published in 2009 in a text?
1 A Yes.
B O Is that text generally accepted in the field?
9 A Yes.
10 O And is the Barbaree and Blanchard article
11 generally accept.ed as authoritative, in fact the gold
I2 standard on acre-related recidivism?
13 A Yes.
I4 MR. GREEN: That ' s al I I have, Your
15 Honor.
I6 THE COURT: Cross-examination.
L7 CROS S_EXAMINAT ION
1B BY MR. RYAN:
1,9 0 Good mornirg, Doctor.
20 A Good mornirg, sir.
2L O So I have a few questions just so that I make sure
22 I understand what it is that you did with regard to
23 1-hic
urrrr ronnrJ_ u
le}/vr rnrl \/^rrr l- oql- imnnrlie
J
rrninrv Y ]. n ho
'u '"
24 Before we get there, have you ever

ZJ testified as an expert for the government in any
1 T]MOTHY P. FOLEY, PH.D. - CROSS 21
2 r\Ar1^niIrr?
3 A Not in Pennsylvania. Not that f can recal-1, no.

4 O Okay. And when I say "governmeht", f mean someone
5 prosecut.ing a criminal of f ense.
o A Correct -
1 a Have you ever done an SVP assessment before?

B A Yes.
v O Have you ever found that a person that you're
10 evaluating meets the statutory definition of an SVP?
11 A Yes.
I2 O And how many t.imes have you done that?
13 A Approximately in Pennsylvania, approximately
I4 and New Jersey, approximately 50 percent of the
15 ref erral- s that I get .
L6 O So 50 percent of the time you find someone to be

I7 an SVP?
1B A So when a defense attorney retains fre, I del-iver a
T9 contrary opinion. And I don't testify.

20 O In terms of the records that you reviewed in order
21, f n nnmni I a \/
_r our report, 'd agree with me that you
you
aa Iist five different records that you reviewed?
ZJ A YeS.
24 O And one of them was Dr. Dudley's SVP assessment?

25 A Correct.
1 TTMOTHY P. FOLEY, PH.D. - CROSS 2B
2 O And you'd agree with me that Dr. Dudley 11sted, I

3 think, over 340 different sources of information?
4 A It was an extremely long discovery Iist.
5 O And prior to coming here to court and as you sit
o here today, you've never read a single page of the
1 trial transcript in this case; is that correct?
B A Correct.
Y 0 And yourve never read a single page of the
10 defendant's deposition in this case?
11 A Correct.
I2 O You've never read a sinqle page of Andrea
13 Constand's deposition in this case?
T4 A Correct.
15 O Were you aware before you met with the defendant
1,6 that he admitted in his deposltion to obtaining seven
r'7 prescriptions f or Quaal-udes ?
1B A I believe sor yes.

I9 O And where did you learn that information?
20 A I'm not sure. It might have been from the press.
21, T don't know.
22 0 Okay. Is there information that you Iearned from
Z5 the press that you used in preparing your report?
24 A No.
25 O I s t.here inf ormation that you learned f rom the

1 TIMOTHY P. FOLEY, PH. D. - CROS S 29
2 rlre.ss thaf vou

_1'" usecl in Vour interview
-i of the def endant?
3 A No. Not that. I can t.hink of , no.
4 O Okay. So fair to say you didn't use the
5 information that the defendant obtalned seven
o prescriptions for Quaaludes in any way in your
1 interview with him or in your report?
a A I don't believe so, no.
9 O Were you aware that the defendant admitted j-n that
10 same deposition with regard to Quaaludes that he
11 obtained those prescriptions in order to give them to

I2 young women he wanted to have sex with?
13 A Could you repeat that? I'm sorry.
I4 O Sure. Are you aware that the defendant in his
15 deposition admitted that he obtained seven
T6 prescript ions for Quaaludes in order to give t.hem to
I1 young women he wanted to have sex with?
1B A I didn't read the deposition.
1q Can you answer my question?
20 MR. GREEN: He just did.
2L THE WITNESS: NO.
22 MR. GREEN : Obj ect ion, Your Honor . He
z5 just did.
24 THE COURT: Wel1, he said he didnrt read
25 the deposition. That's an answer, probably the one
1 TIMOTHY P. FOLEY, PH. D. - CROSS 30
2 you ' re looking for.

3 BY MR. RYAN:
4 O If I can refer to your report starting on Page 2
5 rrnder h:r-koround informat.ion.

o A Correct.
'7
O Are you with me?
B A Yes.
v O You indi cate in your report t.hat the records you
10 reviewed indicated that he, being the defendant,

11 sexually assaulted an adult female acquaintance on
I2 separate occasions in 2004; is that right?

13 A Correct.
L4 O And you al-so indicated in your report that on each
15 of 1_hese senarate
""r occasions when the defendant,
.i_ o according to the records you reviewedr s€xuaIIy
I7 assaulted Andrea Constand, that the defendant provided
1B medications to f acil-1tat.e the sexual assaults ?
L9 A That was in the Affidavit of Probable Cause.

20 O Okay. So it's your testimony that the informaLion
2I f haf is renresent.ed here came f rom the Af f idavj-t
! vr! of
ZZ Probable Cause?
23 A Yes.
24 O And sor going through your report and preparing
25 your report, it was your understanding that there were
1 TTMOTHY P. FOLEY, PH.D. - CROSS 31
a
L multiple occasions of sexual assaul-t in this case?
3 A Yes.
4 O In meeti-ng with the def endant, you'd agree with me
5 that he was oriented to time and place?

o A Yes.
7 O That his speech was cl-ear and comprehensible?
B A Correct.
w
O That there were no indications of deficits in his
10 atri I i f rz to attend verbal- stimuli?
11 A Correct.
I2 O That his short- and long-term memory were intact?
13 A Yes.
I4 O That his verbal- intelligence was above average?
15 A Correct -
I6 O That he had no problems sl-eeping or maintaining

I7 sleep?
1B A That was his report.
I9 O Okay. And you reported that there was no sign of
20 A n'Frrrn'l ooir-al di snrder: correct?
2L A No gross symptoms . I'm not a neurologist.
22 O Okay. And you did indicate t.hat you reviewed
23 records and it was your perception that the defendant
.A
LA was legally blind?
25 A Yes.
I TTMOTHY P. FOLEY, PH. D. - CROS S 32
2 O You did not do any sort of independent medical

3 examination in order to confirm that, did you?
+A A I 'm not a phvs ician .
5 O Right. And so I just wanted to make sure I

k understand some of the opinions that you appear to
1 offer with regard to likel-ihood of re-offending.
6 You've cited blindness. You have no
9 independent you did no independent medical
10 examination to confirm that fact.?
11 A No. I relied on the records that I had.
12 O And where did you get the records?
13 A Mr. Green.
I4 O The fact that the defendant needs to ambulate with
15 a cane, ds you said, you did no independent medical-
t_o examination in order to confirm whether that was true
L1 or not ?
1B A No.
19 O And you testified earlier that the defendant was

20 'rnot self-sufficj-enL't. That's not an opinion that you
27 can hold to any reasonable degree of scientific

22 nerJ-ain.l-rr: 'i-S that tfue?
23 A I asked him his adjustments for daily living. He
24 said he needed assistance. And I knew and I had

z3 corroboration t.hat he was bIind.
1 T]MOTHY P. FOLEY, PH.D. _ CROSS JJ
2 O Is it your testimony that you're offering an
3 expert. opinion based on your expertise in forensic

4 psychology that the defendant is not self-suffici-ent?
5 A Yes, because of his blindness that I had
corroboration on. I didn't determine his blindness.
7 But he had difficulties finding his way outside of the
B room. He had difficulties getting from the house that
Y we where I saw him which was Iike a house ad-i acent
10 to but not connected to his house. And I had to assist
11 him t.o get back to the door to get in.
I2 O And I understand those are the observations that
13 you're telling us here today.
t4 A Yes.
15 0 My question is: In terms of your expertise as a
1a
.t- o f orensic psychol-ogist, is it your opinion that you're
I1 able to offer, expert opinion, about. whether or not the
1B defendant is self-sufficient ?
1_9 A You're correct, I have no expertise in that.

ZU O And you'd agree with me that separate and apart
2I from your expertise as a forensj-c psychologist, you do
22 have familiaritv with various institutions where a
23 criminal defendant mav be incarcerat.ed?

24 A Yes.
25 O And you're aware that there is specifically in
2 Penn.svlrrania a State Correctional Institution desicrnerl

Yrivv
3 to deal wit.h older i-nmates ?

4 A I ' l- I take your word f or it .
5 O Okay. So you're not independently

o A I I ve never been to one.
1 O Okay. And f'm not asking whether you've been to
B one or not, but are you independently aware that
9 THE COURT: Can you hold one second?
10 MR. RYAN: Sure .
11 ( Pause . )
T2 THE COURT: I apologize. Thank you very
13 much.
T4 BY MR. RYAN:
15 0 My question was whether or not you're

L6 'i ndenendenl- lv aware fhat therers a nlar:e r:a'l 'l ecl SCI
T7 LaureI Highlands that ' s specif ically des igned f or o-Lder
1B inmates?
L9 A ftm not.
20 a Okay. I want to speak to you again about the risk
2L ^^h^h+
d,>>cDDllturrL *haf
LrrqL \/nlr
yvu r:ondrrr-fed
uvlluuuLEu and
qrlu iust also risk
-l
22 assessments in generaf.
23 A Okay.
24 O You'd agree with me that case Iaw such as Dengler
25 and the statute itself indicaLe that the factors
1 TTMOTHY P. FOLEY, PH. D. - CROSS 35
2 contained in the SVP statute are not to be used as a
3 risk assessment tool?

4 MR. GREEN: Objection to the Iegal
5 concl-usions. I don't have any ob jection to it being
o questioned about whet.her the defendant meets t.he SVP
1 criteria if he was of f erinq t.hat. He was not.

B THE COURT: We11, he was offered to
q
defeat a component of Ms. DudIey's evaluation. So I'm
10 ncr he I s nof
AcrreeiUlllYUv.yLlLLllY|-Yvu nni n i n^ l.rrr+ Cid caII him
11 specifically to be the one that brought in what you're

12 saying you're using. You probably could have sought. to
13 bring the actual DSM in.
T4 MR. GREEN: f have the actual DSM, but

15 my point is that I made an effort to be precise and
16 di-rect in this. And what counsel is now doinq is

L1 onen i nrr f he cnrest i on i no that's the entire SVP
1B assessment.
I9 THE COURT: Why donrt you define for me
20 what I should be hearing from his limited testimony

21_ rA.rAr.{r n.r f he SVP?
)J e rr
22 MR. GREEN: The proper diagnostic

23 criteria as set forth in the authoritative report.
24 THE COURT: Riqht. So he's saying the
25 r')rrrr1 Ar d'i acrnost i e reoort. wasn I t used. Then he t s now
2 saying, Wefl and he's going

? MR. GREEN: No, he did not.
4 THE COURT: He did not?
q
MR. GREEN: He didn't sav that the
o proper criteria wasnft used. If we want to get off
1 lnto that. tangent of whether Dr. Dudley properly
B supported an opinion, we can go there.
9 THE COURT: You said that. You brouqht
10 him on to say here are the factors and, you know,
11 obrli orrs'l vJ'YvY'"
vorrrrA r^rninr^r to ar.r'nF thaf f hev were not
L2 used. Your cross-examination he's now seekinq to

13 cross-examine this doctor who brought in a scholarly
T4 articfe. He didn't. bring in just the DSM. He brought
15 in a scholarl-v article that was admitted into evidence,
I6 and he stands for that scholarlv article.
I1 MR. GREEN: And that's fine so long as
1B counsel recognizes that if he wants to go down this
L9 rnad - l-hen f he redirect is an entire SVP assessment
20 based on the evidence that's in front of me. I haven't
21, tried to do t.hat.
22 THE COURT: All riqht. Let me hear it
23 fhaf rrTA\7
24 MR. GREEN: Okay.

25 THE COURT: If you're Iimiting simply
2 that he was a vehicle to bring in something that talked

3 about the actual underlying criteria, DSM-5, the
4 paraphi I ia
5 MR. GREEN: Correct.
6 THE COURT: -- and that vou felt the
1 need to use an expert for that, and he did it by also
a bringing in a scholarly article I could have just
looked at the DSM, seen the same things that you're
10 pointing out, and I ignore the rest of the scholarly
11 article because the scholarly articfe is what brings
I2 him into this sphere. The scholarly article is DSM-5
13 and Paraphilic Disorders. As long as you're saying
I4 you're not utilizing him for SVP, then limit your
15 cross-examination.
1,6 MR. GREEN: I didn 't sav for SVP. I
I1 said for an SVP assessment. His likelv fo reoffend
1B evidence 1s relevant to that and t.hat's different than

T9 that one.
20 THE COURT: As a piece of contrary, in
2I your opinion, to Dr. Dudley.
)) MR. GREEN: Yes, sir.
23 THE COURT: I think I understand. Limit
24 your cross-examination. You don't need to go into the
25 rest of the SVP.
1 TTMOTHY P. FOLEY, PH.D. - CROSS 3B
2 MR. RYAN: And f 'm not .
3 THE COURT: Good. Then you have nothing

4 t o worrv a hout .
q MR. RYAN: What I am trying to make sure

o that we understand is risk assessmenL versus SVP.
1 THE COURT: That's important, if he
B knows.
MR. RYAN: P 1 dni
10 BY MR. RYAN:
11 O So, as I understand it, you did not conduct an SVP
L2 assessment in this case?

13 A Correct.
74 O Your what I understand your Ietter to be is a
15 risk assessment.
L6 A Correct.
17 O Okay. Now, you'd agree with me that with regard
1B f n l)onn'l or and t.he SVP statute, that does, in fact'
T9 rlic|inarliqlr risk assessments and it savs that those
20 factors are not to be used as a risk assessment?
2T A The 1,4 factors are not to be used as a ri-sk
t) assessment.
23 O Right. And Iike we just said, you didn't do an
24 SVP assessment?
25 A Correct.
2 O Was the risk assessment you conducted specific to

3 the defendantrs history of sex offending?
4 A Yes. That. was the that was the lndexed
5 offense. That was the reason that prompted the
^ ^*\^-+
7 O Okay. And what risk assessment tool- did you use

B in compllinq thls letter?
A There was none available that was appropriate.
10 Static-99 or other actuarial tools really donrt fit
11 with an individual- who's B1 Vears old. And t.he reason
I2 for that is that the pool of individuals who recidivate
13 af ter the age of 70 is so l-ow that you can I t match it.
I4 And that's the iob of an actuarial tool-.
15 So what I looked at. basical-1v was his
16 o9E.
n^r
nllu
*LAf
LIIuL was
wqD the
Lrls nr"imerrz
l/! rr[ar)/ far-f63.
!quL( And I know the
I1 recidivism rate for individuals over the age of 70,

1B which is extraordinarily 1ow, and T referenced that
I9 through the Barbaree and Blanchard report.
20 O And the information that you've just offered is
21, based on that report, that Barbaree
ZZ A Barbaree and Blanchard, yes.
23 O Okay. So you, as you indicated, did not use a
24 Static-99 or anv other sort of actuarial --

25 A All of t.hem would have been inappropriate.
2 O You did not use a structured clinical interv j-ew in

3 this case?
4 A No.
5 O You'd agree with me that dating aII the way back
o to L95 4 and Meal-, that it ' s general ly accept.ed that
1 r-l i n'i r:al iuclomenf
J "*Y s on their own without some sort of
B tool are insufficient to calcul-ate risk?
u A ft's no better than chance, but what I'm doing is
10 mafr-hino Mr- Cnslrrr with e .rrr-'rn of individuals with a
11 known behav j-or; in other words, sex of f enders over t.he

I2 age of 10, by gauging their recidivism, not time of the
13 f irst of f ense.
L4 O Would you agree with me that the principle I just
15 sfafed
o uuLuu is crenArallrz ar-r'cnl_ed
_Y *" in \/orrr
-I "*. field?
IO A The ' 5 4 Meaf, yes .
L1 O You, in your report, caLaloged the defendant.rs

1B sexuaf history?
I9 A Yes.
20 O And I bel-ieve it's on Page 3?
27 A Yes.
22 O You indicated that t.here was " no report of il
)? paraphilic disorders such as voyeurism, bestiality'

24 frotteurism or fetishism; is that correct?
25 A Correcl.
2 O And that was based on the defendant's self-report?

3 A Correct -
4 O And you didn't revi-ew any materials with regard to

5 either of the two trials that occurred in this case?
,^! A Correct.
1 O Or any investigative materials other t.han the
B Affidavit of Probable Cause?
v A Correct.
10 O The defendant, in your conversation with him,
11 dcnicd an\/ lnrAnnrfcd
uurrleu qrrJ I/v! Lvs hisforv of r:ont.act Sex offenses?
L2 A Correct.
13 O What. question did you ask him to elicit t.hat
I4 information?
15 A Are there any unreported victims of sexual
l_o misconduct that you want to share with me?
I7 O Did you take that to mean that all of his vict.ims

1B harze rFnnrf ed?
I9 A I didnft assume that there were prior victims.

20 Those are al-Iegations. f assume and what I know is
2I that he's been convicted of three counts of aggravated
22 indecent assault involving AC.
23 O And did you know that there were six other

24 individuals that testified under oath that the
25 defendant sexually assaulted them?
z A I didn't have that information.

3 O As you sit here today, do you have that
4 informat ion ?
5 A Wefl, you just told me.
o O Right. Take aside what I said. Do you know that

'7 i ndcncndeni- I v of me tel I i ncr \/crrr ri oht
Jvq now?
B A No.
9
O Did you ask him any questions about the facts of
10 the offense for which he was convicted?
11 A He decided on the advice of his attorney not to
1"2 discuss that..
13 O AII- right. And did you include that in your
I4 report?
15 A I don't think sor no.
I6 O Who asked you to do the report?
I1 A Mr. Green.
1B O Did you ask him any questions surrounding other
L9 women that might. have accused him of sexual assault,
20 abuse or harassment?
2I A I didn't go into thatr Do.
zz O Why?
23 A I asked him unreported victims and I left it at

24 that..
25 n
Y la1hrr
Yrrrj rli.l \z^rr dn l_h:l-?
-Yvu
'l
TTMOTHY P. FOLEY, PH. D. - CROSS 43
Z A Because it's a standard question that f ask when I

J do an evaluation, Is there something I don't know about
4 that you want to tell- me?
5 O And you base it st.rictly off of the signal answer

o that that. individual gives and explore no further?
1 A I didn't go f art.her than his self -report when I
B don't have any other information to counter it.
q
O You had the Affidavit of Probable Cause; right?
10 A I had the Af f idavit of Probab.l-e Cause.
11 O You know that t.hat talks about other victims?
12 A f don't reca11, to tel- I you the truth.
13 O You had Dr. Dudley's report and assessmentl right?
I4 A Yes.
15 O Do you remember mention of other victims in t.hat ?
t_o A I didn't go into it with him during my evaluation
I7 of him.
1B O And I understand that you didn't go into it. My
79 question is not that. ftrs based on your earlier

20 response which said that you didn't have the
21 informat ion .
zz So is your answer now that you didn't

23 have the information or that you made a conscious
24 decision not to go into it?
25 A I made a conscious decision not to so into it
2 hon:rrca
sev I
nn the adViCe Of hiS dttOfno.r
I rru_y /
ha
lru erurlidnrt
ri Want
3 to discuss it. Itrs under appeal-, any other number of

4 leoal reasr-lnS.
5 O So I understand thj-s correctly, his attorney

o engaged you on his behalf to do a risk assessment;
1 correct ?
B A Correct.
O And this risk assessment is intended to be used
10 for sentencing; correct?
11 A Correct.
72 O And you were speci f ical Iy instructed and rnade the
13 decision not to ask any questions about t.he underlying
74 nffensF:lr 9 9 ,
r-nrrect?
15 A Correct.
T6 O And you made the conscious decision under the
I1 advice of Mr. Green not to ask any questions about any
1B other accusations ?
79 A Correct -
20 O And is it also true that with regard to this no
2L report of paraphific disorder such as voyeurism,

)) bestiality, frotteurism, or fetishism, you took the
23 defendant's word at that; correct?
24 A I did. I had nothing else to counter it, no.
25 O Because you didn't ask?
Aq
1 TTMOTHY P. FOLEY, PH. D. - CROSS
2 A I didnrt ask what?

3 O You didn't explore further whether there were any
4 rennrt s nf fhesc" narenh
r" ilic disorders?
5 A I described t.hem and asked him if he had ever
o engaged in them. Some of them might be 1egal. Some of
'l them might be ilfegal. And he responded no.
B O And agaJ-n, unreported history of contact sex
offenses, did you make a decision not. to push him
10 further on that and accept his word?
11 A I made a decision not to press him further on it.
I2 O So he did not admit to you that. he had given
13 ysss
Orr::lrrrloq - 'l--Je young women j-n order to have sex with
14 them?
15 A No.
t_o O You indicate, again in sexual history on Page 3,

1,1 that the defendant denied viewing internet pornography?
1B A Correct.
IY O Did you ask him questions about other forms of
20 po r no gr aphy ?
2I A No, just internet pornography which is the most

22 common. If he had answered positively, then I woul-d
23 have gone back and gotten the history of pornography,
24 but he told me that he had no affinj-ty for pornography
25 af anv noint in his l-ife.
2 O And you took him at his word for that?

J A Yes.
4 O Okay. So, just so I understand, your statement in
5 here about internet pornography, j-t's your testimony
b that the defendant told you he had no affinity
1 what.soever for any form of pornography?
B A I believe so, yes. But what's in my report is
v anaî
uyvv f i n l- n 'i nf arnpl- n.\rnncrranhrr
10 O With regard to drugs and alcohol, the defendant

11 denied any sort of compulsive use of alcohol- or drugs?
I2 A Correct.
13 O Does he indicate to you that he does not use drugs
T4 or alcohol in any form?
15 A He told me that he had never abused them.
I6 O Okay. And did you explore that any further?
I7 A I left it at that.
1B O Are you aware that the defendant has in the past
I9 claimed that he does not drink or use drugs?
20 A I don'L think frm aware of that, flo.
2I O I believe it's under the summary section on
22 Page 4, that. top paragraph. The Iast sentence, You
23 said: "There is no known record of community

z+ srrrlerrrision difficulties since his conviction in April
25 of 2018" ?
2 A Correct.
3 0 Was t.hat se-l-f-reported?
4 A Yes. I asked him if he had any problems, and I
5 was unaware of any.
,1
O So you're not aware that the police were called to
7 his house whil-e he was confined to his home on house
a arrest ?
v MR . GREEN : Obj ect ion .
10 THE COURT: Sustained.

11 BY MR. RYAN:
L2 O Did he teII you that informati-on?

13 A No.
I4 O I believe you indicated that. there was no known

15 offending in the last 15 years?
1,6 A CorrecL.
1,1 0 And that was what he reported to you?
1B A Yes, and from the records that I know that
L9 thereis no new charges. And since 2004 therers no new
20 r-harcres nr r-onvictionS.
2L O And you know that from the records you reviewed or
ZZ from other information?
23 A Probably other information.
24 O So that you chose to explore further?
25 A No, I didn't go into it with him.
1 TTMOTHY P. FOLEYf PH. D. - CROSS 4B
2 O But you knew that personally?

3 A Yes.
4 O Before the interview or after?
5 A f'm not sure. I'm not sure. I can't tell you one
b w^\/ or thc other.
1 O So the conclusion with regard to that informalion
B l- h:l- j-*
\/Arr r--
nrrJ- in your report, you're willing to rely on
q his words and other information?
10 A I guess sor yes.
11 O inf ormat ion t.hat you didn 't
Including detail and
L2 the sources of j-nformation in your report?
13 A Correct.
I4 O Did Mr. Green tell- you to do that ?
15 A No.
IO O That was a consci-ous decision on your part?
L1 A Yes.
1B O Did you make the conscious decj-sion to rely on
I9 information outside of what you list as sources for any

20 other conclusions you reached in your report?
21, A Not that I know of . I mean, I was there to answer
22 the nri marrr rcf crra I .ruestion
-1". which was his risk. So a
23 lot of those things, given that he was B1 years o1d and

24 without sight, didn't become that j-mportant to me.
25 O His risk without regard to any other prior

2 r'l I aart- i nn c eVen thOSe nf €arad l.rrz

vt WOmen Othef t.han
3 A Given t.he f act that he ' s BL , bl ind, and has been

4 convicted and will be supervised, no.
5 O And in the summary section, you quote from the
o Barbaree and Blanchard text?
1 A Right.
B O Now, yourd agree with me that that study was based
Y on offenders when refeased from custody?
10 A Correct.
11 O And offenders who have been rel-eased from cust.ody
I2 have undergone treatment; correct?
13 A Some have, some haven I t .
T4 O You'd agree with me that most offenders refeased

15 frnm r:rtsf or-lv trndprr^rn trcatment?
I6 A f don't know. I can't say most .
17 O Okay. Are you aware of what percentage of

1B offenders released from custody undergo treatment?
79 A Trm not.
20 O In t.his study, did the population that. was studied
ZI of individual-s released from custody incl-ude anyone
22 fhr.l- r.7ae 'larrrl'lrr hlinrl?
23 A Not that I know of.

24 O Did it include anyone who had been alleged by
ZJ approximately 60 women that he sexually assaulted them?

2 MR. GREEN: Obj ect ion.

J THE COURT: Sustained.
4 THE WITNESS: Not that I know of.
5 BY MR. RYAN:
a Did the popul-aLion of the study incl-ude anyone who
1 had a criminal- t.riaf where seven women testified under

oath that they were sexually assaulted by the
Y defendant ?
10 MR. GREEN: Same obj ection, Your Honor .
11
t,L THE COURT: Letrs move oflr Mr. Ryan.
I2 You I re asking leading questions whi-ch you're permit.ted
13 t-n dn en rv, hrrl Itm nOt SUre fhevrre
elrvl adrranr:ino Y
fhe
erl
L4 sexually vj-ofent predator

15 MR. RYAN: That I s not what he' s
I6 foql-ifrz'ina
I1 THE COURT: Excuse frer advancing

1B te.sti monv t.hat 'i s l^rei no of f ered.
I9 BY MR. RYAN:
20 O Did the popul-ation include anyone who was
2I convicted of a drug-facititated sexual assault?

ZZ A I assume that it. did, but I don't know. I canrt
23 give you a percentage, no.
24 O Did it or did it not?
25 A I assume it did.
Z O Why do you make that assumption?

3 A Because out of a large group of sex offenders,
4 some of them are going to have drug-facilitated
5 offenses.
6 O And your eval-uations focus primarily on chifd
1 n^rnnrrra nh rr offen s es ?
X A No.
Y O I thought I heard you say that during voir dire as
10 l-n avnarti qa
11 A Primarily for cases that are in federal court.

L2 O Okay. But you base the assumption based on your
13 understanding of statistics with regard to
T4 rlrrrcr-f ar-, i I 'i t ated sexual- assault
15 A And
t_o O Let me finish my question.

T1 A I 'm sorry.
1B O You made t.hat assumption based on statistics that
L9 volr
JVU rrndersf
UrlUUrJLqrrU ancl w'i f
WrUrr recra-d fUVn
h rUYU!U r"^-f acilitat.ed
U!UY sexual
20 assault offenders that are o1d?
21, A And my experience of doing SVP evaluations for
22 more than 20 years.
23 O D j-d the study cons ider the use of medications such
24 AQ \II AdT: /
25 A I doubt it, no.

,L TTMOTHY P. FOLEY, PH.D. - CROSS 52
2 O Now, the study itself discuses the d9€, function,

3 and analogizes it to, as f see, three different. things,
4 'i nr. lrrdinrrY vrhlOOd leveIS of testOsLerOne?
5 A Irm sorry. Say again?
o O It anafogizes age function to three different
1 things, one of them being blood l-evel-s of testosterone?
B a k 1 dhi
O Okay. Did you test the defendant for that?

10 A No.
11 O Di-d you test the defendant for what woul-d be the
I2 sexual arousal of him personally?
13 A No.
T4 O What about with regard to him as a sex offender?
15 A No.
I6 O You'd agree with me that your report does not

T1 you were not tasked with giving any sort of an opinion
1B with regard to a diagnosis of other specified
T9 paraphilic disorderr flon-consenting women?
20 A Correct.
21 O You'd agree wit.h me that with regard to the
22 DSM-IV-TR compared to the DSM-5, that the DSM-IV-TR had
23 a diagnosis of paraphilia not otherwise specified?
24 A Yes.
25 O And that that category was essentially broken
1 TIMOTHY P. FOLEY, PH.D. - REDIRECT 53
2 apart in the DSM-5 to paraphilia, other specified

3 dj-sorder versus paraphilic I'm sorry, unspecified
4 naranhi I i r: rlisorder?
5 A And other specified. Those are the two.
o O You'd agree with me that I s what occurred in the
1 DSM_5?
B A Yes.
9 MR. RYAN: Those are all the questions I
10 harre- Yorrr Honor.
11 MR. GREEN: May I please foll-ow uP?
I2 THE COURT: Redirect.

13 REDIRECT EXAMINATION
74 BY MR. GREEN:
15 O Doctor, I ' ll- tel-l- you that in the Presentence

t6 Investigation Report at Page 11 there is reference to a
L1 Ietter dated November 24Lh, 20L5, from Robert Ritch,

1B M.D., dh ophthalmologist that summarized the
I9 defendant I s bfindness.
2n fs that a source of factual- information
2L .rn
vrr urhir-h
vyrrrerr \/.'\lr
-Y
vu r^rr-rrrld relrr in 1_he nrar-fir:e of vollr
22 nrnf oqqi nn?
z5 A Yes.
24 O I'1I tetl you aIso, Doctor, that in the
z3 Presentence Tnvestigation Report at Page 12, t.he
trA
1 TTMOTHY P. FOLEY, PH. D. RECROSS
2 Probation Department which has been mnn i I nr i nn his

3 house arrest since conviction writes +1--+
LITA L
]-^
IIC
fl r--^
II A D
l-^^^
U E C II
4 r:r^lmn'l i ant wi th his bail conditions " I h rnrr nh nrr I !L^!

L 1I Ct L
5 no ri nrl
fs that a fact on which you woufd rely

1 i n J_ho nrA^l- i no nf \7^rrr nrnfeqqi nn?
a A Yes.
MR. GREEN: That' s all- I have Thank
10 you
11 RECROSS_EXAMINATION
LZ BY MR. RYAN:
13 O Have you seen the PSI?

T4 A No, I haven't.
15 THE COURT: FinaI recross examinati-on.
_LO MR. RYAN: That ' s al- l- I have .
I1 THE COURT: Let me get it out before you

1B ^^r-
q.>A a qUEDL! ^^+.ion. I missed \znrrr
J vqr
arrrAqtinn.
Yevs u!v
I9 MR. RYAN: I asked him if he ever saw

20 t.he PS I .
2L BY MR. RYAN:
22 0 Doctor?
23 A No.
24 THE COURT: tnznF \/n tl

J-- \zAr\/ mrrr-h - sir
25 You may step down.

1 COMMONWEALTH vs. WILLIAM H. COSBY, JR. rf,
za (Witness excused. )
4 MR. GREEN: That's t.he conclusion of the

5 defendant's evidence for sentencing subject to
6 discussion about allocution. I understood from the
1 Court yesterday
B THE COURT: I need to hear your argument
q
on SVP and then we' .Ll get. to what's next .
10 MR. GREEN: I understand.

11 THE COURT: I've got to make the SVP
I2 decision bef ore we move on to anything el-se.

13 MR. GREEN: So that was going to be my
74 question. Is that how you want to proceed?

15 THE COURT: Yes. I'm going to hear your
I6 Ar.rl'rmcnf q - rprzi ar^r m\/ nnl- es - ancl make
r! v e I an SVP deciS j-on.
I7 And then we'11 move to other stages of the sentencing.

1B MR. GREEN: The only part of that was to
T9 offer the Commonwealth an opportunity for rebuttal. I
20 r-l osed m\; r:ase. Are we done? ShaII we stand and
21, arque ?
)) THE COURT: Do you have any rebuttal?

23 MR. RYAN: No.
)A MR. GREEN: Judge, the section requires
25 cI.ear and convincing evidence that there is a
1 COMMONWEALTH vs. WTLLIAM H. COSBY, JR. 56
2 qual-ifying condition that makes the defendant likely to

3 re-offend. And the J-ikely to re-offend is a matter of
4 fact and of scrence.
q
And the fact set forth in the
o Present.ence Report and not contested by the
1 Commonweal-th other than through cross-examination is
B that. the def endant i-s blind.
g The fact set forth in the Presentence
10 Report. and not contested by the Commonweafth is that
11 the defendant is B1 years oId.
T2 The fact set forth by Dr. Foley and not
13 seriorrslv J r:onl-es,|-er^l
vv hrr
vI an\/r-lnF is fha1- eficr'lO-
L ' v f the
I4 risk of recidivism is practically zero. As you get to

15 81, if 1t could be less than zero.
I6 When you combine those facts, no
I7 reasonable fact finder could concl-ude bv cfear and

1B convincing evidence that any identifiable condition
1"9 makes him l-ikelv to re-of f end.
20 He is, according to the DSM-5, in f uIl-
2I remission. If you accept the diagnosis of paraphilic
22 disorders involving non-consenting victims, he's in
23 full remission. Not just five years of remission as
24 required by the diagnostic criteria, but approaching

25 1q
1 COMMONWEALTH VS wrLLrAM H. COSBY, JR. 51
2 What I suggest is that you should not

3 accept the suggestion that Mr. Cosby suffers from or is
4 properly cl-assif ied and that's, I think, the better
5 verb. He's not cl-assif ied as exhibiting paraphilic
o disorder involving a non-consenting victim because the
7 def ini-tion means something. In a court of 1aw, the
B rules matter. And the ru.l-es are set f orth. And t.he
g Commonwealt.hrs wi-tness, the Commonweal-th's expert
10 concedes that he doesn't meeL those criteria.
11 Now, T suppose that there could be a
L2 case in which a rrprsr-rn di cl nIt have a di ecrnr-rsFal'rl c
13 condition that would meet the condition prong of the

I4 definition. I canrt imagine what it is, but I don't
15 imacrine tha1- I have an inf inite ana.l-ogy. So I quess
T6 if rs" nossihle.
v"
T1 But even in the cases where non-forensic

1B psychologists do SVP assessments, SOAB assessments in
1,9 the middle of the state where thev donft have the
20 roster of experts that we have in this part of the
27 qrara a\ran J- haro nnl'rnr.lr;
---r'purports to identify an SVP
22 without findinq a diaqnostic cfassification that fits.
23 fs it required by the sLatute? No,
24 there's no express reouirement of the statute that it

ZJ be DSM-5 or DSM-IV-TR or some other criteria. But. what.
1 COMMONWEALTH vs. WILLIAM H. COSBY, JR. 5B
2 I ask you to notice is that Dr. Dudley tried to put it

3 in this box, and she did that because she knows she's
4 crof fo f ind a box.
Y""gr9qlrf And iI r:learlv doesn't fit. And if
5 the rule of l-aw is what matters, that ' s the rule of l-aw
6 we have to apply.
1 I'd be happy to address any questions
B fhaf anrrlrodrz micrht harrc- bUt fOr thoSe reaSons ittS the
v defense cont,ention that the evidence is insufficient
10 for any reasonabl-e fact finder to find by clear and
11
aa convincing evidence the factors required.
L2 THE COURT: Mr. Rvan.
13 MR. RYAN: Thank you, Your Honor.
I4 I think iL's i-m'portant to and I'11-
15 frrz
"- J
fo l^re hrief in "'J
mv remarks outline the
I6 requirements under SVP which is, first and foremost,
11 that as it relates to I4 factors, it is not a balance.
1B It is the finding of factors by the Court that is
1,9 necessary. And the absence of factors is not a
20 conclusion that a defendant is not an SVP.
2L Because the defense/ I would suggest, is

2? focused so much on the risk of re-offending, that's
23 what I'11- focus my argument oflr first bringing the
24 Court's attention to the fact that it is one of four
z3 factors under mental- abnormality which, as the Court
2 pointed out earlier, is not required by legaI construct

{ to fit within the DSM.
4 Ultimately I do disagree with Mr. Green

q in his suggestion that Dr. Dudley testified that it
0 didn't fit within the DSM. I would suggest. that
1 rrltimafelv t.hatrs exact-l v whaf she did do.
B And in addit.ion to that, there has been
9 no evidence proffered bv t.he defense whatsoever to
10 rebut that cIaim. I would suggest. the testimony with
11 reoarcl fo t-hat that Dr. Drrcllev rtro\/ided is more than
I2 sufficient to overcome the clear and convinci-ncr
TJ standard that we have.
I4 Because at the end of the dry, this risk
15 of re-offendi.g, I would suqqest, under the legal
IO construct that j-s the SVP is very specific and
I1 technical. And the defense has focused t.heir argument
1B primarily on whether or not the defendant in this
I9 particular case has a risk of re-offending.
20 I would suggest to you that a close
a1
ZL reading of the statute tells you that your inquiry is
)) just a l-ittle bit dif f erent. Of course it requires an
z5 anal-ysis of the individual defendant. Thatrs what the

24 assessment is about and that's how the conclusion in
overall context of SVP is reached.
2 But if the Court were to l-ook at the

3 definition of mental abnormality under the legal
4 construct that we have wlth SVP, what that definition
5 tal-ks about is a diaqnoseabf e l-if etime condit.ion. Of
r-nrrrRF - 'i I dnesn I l- recrrli re comnl i ance with the DSM or
Yqf!vvvrllr
7 any other diagnostic too1. It requires an expert to

B test.ify in the conLext of that statute there is a
v lifetime condition that would make a person Iikely to

10 re-offend.
11 And so I would suggest that's where the
I2 departure from the defense's focus on this individual
I
13 defendant reaIIy comes because you look at the overal-l-

I4 context, of course the 74 factors, mental abnormality
15 and predatory behavior.
T6 But when Vou tal-k about t.hat. l-ikelihood
r'7 of re-offending in t.he context of the statute, it is
1b not a specific inquiry as to this defendant, but rather
19 can he be diagnosed with a mental- abnormality under the
20 statute that is a lifetime condition that would lead a
2T person to re-offend. That's what the statute requires.

ZZ Clearly thatrs what the evidence has suggested.
23 I would also sdy, in the alternati-ve,
24 that there has been evidence bevond the clear and
25 convincing standard that would say and suggest this

1 COMMONWEALTH vs. WILLIAM H. COSBY, JR. 6I
2 individual who is not one that's been released from
3 custody, who is not one that has had any history of
4 treatment, is one who a defense expert has specifically
5 avoided talking about any sort of legitimate and true
o sex offending history, and no other individual expert
1 or otherwise has had the opportunity to eval-uate that
B exact aspect of the def endant's hist.ory.
9 And I'm not saying that it is
10 necessarily improper under the 1aw for him to assert
11 his right to sil-ence, but I think it is something
I2 that's important to considerr especially when you're
13 dealing with the technical 1ega1 definition in this
74 case of what exactly a mental abnormality is.
15 With regard to the specific factors that.
I6 Dr. Dudley relied upon, I t.hink t.hat there were
I7 ultimately four that were very significant to her: The
1B nature of the sexual contact with the victim, the

L9 re-l-ationship of the defendant to the victim, the mental
20 capacity in the moment of the sexual- assault of the
2T rri u u rim-
w ! r-f lr t and ul I imatel v t-he behavioral characteristics
)) that she utilized usinq the record in this case. Not
Z5 sel f -renor1_ i ncr- hrrf thc
L vLtLY I reCOrd in thiS CaSe Under the
24 statute as she's reguired to do.
25 Certainly she testified as to how the
1 COMMONWEALTH vs . WfLLIAM H. COSBY, JR . 62
Z defendant meets the classification as engaging 1n

3 predatory behavior. And uftimately, Iike I said, with
4 this mentaf abnormal-ity, she's characterized it as
other specified personality disorder, flon-consenting

o women. And again, thatrs where I know the Court
7 inquired as to what weight, if dDy, other individuals
B who testified at trial had. That's where those
q
individuals come in.
10 And I would suggest as a result of the
11 overall contexL of her report and her testimony, the
I2 fact that it has not been attacked in any meaningful
13 way by the defendant certainly meets our burden under
I4 the SVP statute.
15 MR. GREEN: May f respond?
l-0 THE COURT: Yes .
I1 MR. GREEN: f want to respond to two

1B '1-er-hn i r:a I crrrest j-onS.
I9 As f ar as f can tel-1 f rom my notes,
20 that's the fourth time in the SVP discussion that
2I counsel has referred back to things t.hat are not part
22 of this record; the prior history that Dr. Dudley
23 relied on and, more importantfy, the defendant's
24 decision not to t.alk about other uncharged crimj-na1
25 conduct.
2 Itrs one thing to say f'm not suggesting

3 that that's wrong. It's another thing to say you
4 shoul-d cons j-der it, which is what he' s now said three
5 different times. And that's just not right. In the
6 court of Iaw that are rules, and therers a rule that
7 savs vor
j"" clontt.
B That. ' s the one th i ng .
9 THE COURT: Thatrs Mr. Ryan's argument .
10 The Corrrt""r soeei fi cal 1v instructed her to, when she was
11
II on the stand, to not consider it and her testimony
12 should not consider it. So she either heard me or
13 didn't. And what Mr. Ryan says that she had to, I
T4 didn't hear it and T've got to take the testimony that
15 she did not incl-ude it.
_LO Again, f don't remember her testimony
L1 anywhere around about the defendant not offering
1B himself for an assessment by the board.
I9 Mr. Ryan is doing it in some oratorical
20 f'l are to sav ha clidnrf e q_Y oreSent it. I know the law
2L cannot take that int.o account. So I know the law here.
ZZ And the fact that Mr. Ryan has said it is just, dgain,
23 a statemenL of counsef.
24 MR. GREEN: Then I 'l-1 relv on vou to
25 annlrz
*-t/y'-I911 the law.
a
Z THE COURT: AIl riqht. The Court is
3 going to take a brief recess. I have to consider the
4 arguments and the evidence that was presented, and I
5 wiII issue my decision regarding the designation of SVP
1 Now, I do remind t.he parties before

U everybody runs out t.he door that, dgain, the conviction
g in this case and the Court's ruling yesterday to not
10 decl-are the current statute unconstitutional-
11 automatically designates him as a fifetime registranL
12 and alI other appficabilities under the sexual offender
13 registration scheme that is currently in this
14 Commonwealth -
15 So, in that regard, I'd ask the parties

T6 Lo, one way or the other, you know, have some kind of
I1 no'l lc'.rrr\./- some kind
"Yq]|99
of notice that would either be the
1B Iifetime registration without the SVP component or a
L9 lifetime registration with an SVP component.

20 If you have them, make sure you get them
21" toget.her so that we can move right directly, whatever
)t the Court decides, to colloquy him and provide him the
23 appropriate notice because the Court does intend to
24 issue the sentence today.
25 | | v a \l /
2 MR. RYAN: Yes.

4
5 (Recess. )
1 (Proceedings were reconvened wit.h the

B Court, Mr. Steele, Mr. Ryan, Ms. Feden,
Ms. Piatkowski, Mr. Green, Ms. Redmond,
10 Mr. Gol-dberger, and the def endant being
11 nrFqcnl- . \
t/lvuvlru./
I2 THE COURT: A1l right. The Court has

13 previously ruled on the constitutionality of the
T4 current f orm of Sectlon I. That was l-aw ef f ective
15 July 13th , 20IB . I apoJ-ogize, f 'm losing my voice.
L6 AccordingIv, this is a statutory Iaw. Therefore, I
T1 will- folIow the statutes in issuing my order.
1B The burden that the Commonwealth musL
79 meet is a clear and convincinq standard. A clear and

20 convincing standard is one that specifically, when
21" applied to assessments and designations under sexual-

22 offender Iaws, has been defined as evidence that's so
23 cIear, direct, weighty, and convincing as to enabl-e the

24 trier of fact to come to a clear conviction without
ZJ hesitancy of the truth of the precise facts aL issue.
2 Sj-nce it is a statutory vehicle, I will

1-11-1 fo thc sfafrrfe re1^fe1^6li nnY t_1-'a
urrv Aa€initiOnS that are to
4 l.ra rnnl
s-Y-v i ad
-
5 I find the definition of mental

o ahnormal'i tv
svrrv!rlrqrruJ a.s a conoen'ir-
vrrfLol
r v! AUYU. ired condition of a
'7 nersnn f haf af f ect.s an emotional or vol j-t.iona1 r:ar;ar: if v
B of the person in a manner that predisposes that person

9 to the commission of cri-minal- sexual acts to a deqree
10 that makes a person a menace to the health and safety
11 of other persons.
1,2 Predatory is defined as an act directed
13 at a stranger or at a person with whom a relationship
1-4 has been initiated, established, maintained, or
15 promoted, in whole or in part., in order to facilitate
1,6 or support victimization.
T7 A sexually viofent offense is again,
1B I remind a1l that this is an offense that occurred
L9 between ApriI 22nd, I996, but before December 30th/
20 201,2, wh j-ch are the Act cover s that per iod of t ime .
21 He was convicted of a sexuallv violent offense from

)) January 2004.
23 Sexually viol-ent predator is a person
24 who has been convicted of a sexually violent offense'
Z) which this defendant was for an offense in 2004, who is
a determined to be a sexually viol-ent predator pursuant

3 to the statute relatincI to assessments due to a mental
4 abnormality or personality disorder that makes the
5 h6ron n 1i12a117 tn Fn.ra1.rF 'i n l/!uu
nreclatorrr J sFx';al
ruûq!rJ lrr rriOf ent
o offenses or has ever been determined bv a Courl to have

1 such a mental- abnormality or personality disorder.
B So, based upon those statutory
v definitions, the testimony of Dr. Dudley, the
10 cross-examination of Dr. DudIey, and considerat.ion of
11 the arguments of counsel, I find the Commonwealth has
72 met a clear and convincing and, therefore, this
13 defendant is designated a sexually viol-ent predator
T4 under the Act based upon the date of the offense and
15 the Act in its current form.
16 All right. Now we're going to move on
I1 with the remainder of sentencing. We had had closing
1B arguments, and at that stage I did say that if there
I9 were any other comments regarding the closing arguments
20 or summation versus sentencj-ng, that it shoufd focus
2I itsel-f on Dr. Foley and his report f or that is why he
22 was nrFscnted hrz l-he dcf enSe.
23 Qn rln \7n rr
]""J"" harro anrzl-h-i nn frrrfhar \/n rr r,z-i qh
24 to say on that, Mr. Green?

25 MR. GREEN: f don't have anything that
2 is specif ic to Dr. Fo1ey, but there are t.hings t.hat

3 were said by the Commonwealth in their argument to
4 which I would Iike to respond. And I understood that
5 this woul-d be an opportunity to do that as welI.
THE COURT: Yeah, I do want to give
1 6\76rrrl-rnr{rz
svs!yvvuy an
qrr nnn^rirrni
v-y-yv! Lurr!uJ 1_rr J.n
uv roqnnnrl
!uoI/vrru. Porhanq
L u!rru}/u 1-hcrr rîi I I
B accept an invitation.
Why don't we do this? I have not yet
10 offered the option that I offer in every case, and that
11 revolves around a defendant's allocution. So before
L2 there are any final wrap-up summations, we need to get
13 t o that. .
I4 So does your client intend to allocute

15 and, j-f he so chooses to do Sor can he do it before
I6 \./r-'rrr r:losincr summation or does he want the final word
I1 before this Court imposes sentence?
1B MR. GREEN: I'fl ask.
79 THE COURT: Okay.
20 (Discussion off the record between
21, Mr. Green and the defendant. )
22 MR. GREEN: No.

23 THE COURT: All right. Now, Mr. CosbY,
24 I am requiredr ds I have throughout this case again,
25 I wilI treat you as under oath, dS I have throughout
COMMONWEALTH vs. WILLIAM H. COSBY, JR . 69
Z fho r^.AsF- nnlrz

I v LL L J
As fo deciSiOnS beino macle and announCed
3 by counsel in this case.

4 So that the record is cIear, vou have an
5 absolute right to allocute; that is, to have the final-
o word in this case. Any decision made in that regard,
1 of course, will be made with counsef as to your
B decision of whether to al-f ocuLe. If you do not
u allocute, it cannot be held against you by this Court,
10 nor may any inferences be made by your failure to
11 al-1ocute.
72 I assume vou have reviewed all of that
13 with Mr. Green; is that correct?
I4 THE DEFENDANT: YES.
15 THE COURT: And has anybody forced you,
I6 threaLened your or made any promises to you t.o get you
I1 not to af l-ocute ot r again, waive allocution in this
1B case?
I9 THE DEFENDANT: NO.
20 THE COURT: And todav are vou under the
zJ, influence of any drugs, alcohol- or emotional illness
22 that would prevent you from making such a decision?
23 THE DEFENDANT: NO.
24 THE COURT: Do you have anything efse
that you wish to review with Mr. Green in that to
) make that decision ? I s t.here anything you wish to

revj-ew? Is there any questions that he has not.
4 answered for you that you need to talk to him about
5 before I conclude this col-l-oquy?
b THE DEFENDANT: I woul-d l-ike Lo talk to
1 him for a moment..
B THE COURT: Okav This is abouL the
9 decision whether to a1locute.
LO THE DEFENDANT: I don't need any more
11 discussion on that.
L2 THE COURT: Okay. Thank you very much
t_3 THE DEFENDANT: Thank you.
T4 THE COURT: Now we are at the Place to
15 r^rhcrF_
WIICIET he
lIg harrincr
rraVIIrY heen
UssIr dcîanrfaA
UgJJVIIALgU L^th
Uv as lifetime
l_o rani qfrrnf 'rnder the CUrrenL SexUaf Offender

t'7 registration law in Pennsylvania and a concurrent
1B designation by this Court of a sexually violent
1"9 predator, Trm going to ask that the Commonwealth engage
ZU in the col-Ioquy as to the understanding of his rights.
27 Again, I am doing both because the Court
22 is cognizant that the status of Pennsylvania's sexuaf
23 offender registration acts in this Commonwealth are
24 tenuous in t.hat there are many' many cases before our
25 appellate courLs. Our legislature has labored over the
1 COMMONWEALTH vs. WILLIAM H. COSBY, JR. 1L
z l-ast year to pass statutes that will meet the purpose

3 nf recri qf eri no sex nf f enders and also l-rei no
Y abl
svL e to
4 know where those offenders are by the reporting
q rFcrlr i remcnt s of that ACt.
0 So, with that said, Mr. Ryan, you wi11,

1 as an agent for the Commonwealth, give him his rights.
B He can respond. He just has t.o be given his
Y r6dlr i raman1_ c
10
11 WILLIAM HENRY COSBY, JR., having been

12 previously duly sworn, was examined and
13 testified as follows:
I4 BY MR. RYAN:
15 O Mr. Cosbyr my name is Stewart Ryan. Can you hear
I6 the words that I'm saying to you right now?
I1 A f-nrrlrl \/nrr
t"" enaalr rrn?
1B O Sure. So my name is Stewart Ryan. I'm going to

I9 :qlr \/^rr
_1 ""
a^ma ffrraqi- -i nne Olcerr?
20 A Is it al-I right?
2L THE COURT: Mr. Cosby, just so you know,
22 ^nA rarr\/
" *l
rrr 1-he other I wish we had a written form,
23 but we don't.
24 MR. GREEN: The written form wouldn't
25 help him because he canrt read.
I COMMONWEALTH vs. WILLIAM H. COSBY, JR. 12
2 THE COURT: WeIl, vou would read to him

{ from the form and he would at that stage then say I
4 underst.and there and he could make his mark or siqn.
5 THE DEFENDANT: A11 I was --
6 THE COURT: Mr. Cosby, Ird ask you not
1 to speak. f've done it with people that have sight
B i qqrreq
- Just
T -i
say we don't have one. I've used them
9 before.
10 So, Mr. Cosby, this is the only way in
11 which we can give you the advice as to what your
L2 requirements are. So if you can't hear Mr. Ryan,
13 nl ease I et us know.
I4 THE DEFENDANT: I can hear him. He said
15 he had some suesti-ons.
IO THE COURT: Okay. Here he goes.
r'l BY MR. RYAN:
1B n
\l
Qir
JLL, if \z^rr
_Yvu
r.:nrJ-
uqrr u haer
rruq! anrzl- hincl Tlm sarli
es_I no
lrrY
T9 A I can hear you.

20 O I understand that. If you can't at any point
drrrina fho r.nrrrqa nf m\/ .rlrAetinnq tn \/nrr- nleas^ r^r
2T -..J - -J IVJI YfEqoE fCL ILLE
22 know because it's important that you hear and

z5 understand what frm saying. Okay?
24 A YeS.
25 n
v
(ir
rLL t
rln \/nrr rrndersfancl that
,Yvq vou have been
2 convicted of a sexually violent offense listed under

3 Pennsylvania Iaw at TitIe 42, Chapter 9199.55?
4 A Yes.
5 O Do you also understand that after today's
O proceedings, t.he judge has determined that. you qualify
1 as a sexuaf violent predator under Pennsylvanj-a law?
B A Yes.
(.,
O Do you understand that because you have been
10 convicted of a sexually viol-ent offense, in this case
11 aggravated indecent assault, as well as a result of t.he
irrdna f nrng you are vrr:1117
a sexuarl.l vsq vvL
T2 r *-)r rlal- orm' rlin-lant nrarlaf
r! nr ,
13 thaf \/c:lr
Yvu wi I I l^re rp.trt'i red l- n rccri sf er with the
I4 Pennsylvania State Police for the remainder of your

15 lifetime?
L6 A Yes.
L1 O Do you understand that upon your release from
1B incarceration, upon parole from a state or county
19 correctional- institution, or upon the beginning of a
20 sent.ence of intermediate punishment or probation, you
21, mrrst nrorride the Pennsvl-vania State PoIice with the

22 f nl I nr^r'i nrr i nf Of matiOn:
!v!!
23 Your current or intended residences.

24 All information concerning your current or intended
25 empl-oyment. All information concerning your current or
intended enrollment. as a student or anv other

3 information required by the statute?
4 Do you understand that?
q
A Ona drrael- inn
O Qrrra
1 n
6 If I went from a r:itv to anot.her ni
Uf 1-
Ly,rr rln
UU T
A l-'--'^
llaVc
B
+^
L(J UVCtr if
I! itrs
ru g irrsf
JUDU rl\/Frniohf
vvs!rraytrL, - T harrc f o Yvu
cret in
I touch with the Stat.e PoIice ?
10 O I would advise, first and foremost., t.hat you

11 discuss that. with your counsel. I can tell- you it's my
T2 understanding that with regard to empl-oyment, if you

13 maintain a different employment for more than I4 days,
I4 you must register that change with the Pennsylvania
15 St.ate Police.
I6 InT'ifh
vtfLIMVa!g roa:rd l-n
LV \/nrrr
JVUr
raqidanno
!9O!VgIrU9t !!if \z^rl
JVU
I1 maintain a residence for 30 days or more, you must

1B register that new residence with the State PoIice.
L9 However, like I said at the beginning, I would suggest
20 t.hat that specific question be posed to your counsel.
27 Okay?
22 A Thank you.
23 O You're welcome. Do you understand that, uDless
nflrorr^r'i wroeco nrn\r'irlarl hrz -lr-' :c cail l.LUn nnmn-1
24 uurrs! yrvvruEu py Lclw, -LI yU|'.l Idf I UUrilI/ry " "if
W-LLII1^
25 fhe recrisf ratinn rp.rll'i rpmcnf Lt v

q
e t
\t.rlr r^/i]-l
,Y v
q nOt be fe]-eaSed
'75
1 COMMONWEALTH vs. WILLIAM H. COSBY, JR.
2 should you be incarcerated from a state or county
3 correctional facilit.v or released from a sentence of
4 probation or intermediate punishment?
Ct A Yes.
1 0 Do you understand that if you change your
residence, establ-ish an additional residence, or change
other information listed above that f described before,
10 that you must do the foflowing:
11 Nof ifv ihe Pennsvlrrania State PoIice of
L2 fhe r:hanoe of \,/rrrrr resirlence or other information
13 required by l-aw within three business days of the date
I4 \/crlr r-hancre \/our residence
I Vq .I or other information and
15 register with a new law enforcement agency no l-ater
16 than three business days after establishing your
T7 residence in whatever jurisdiction that may be.
1B Do you understand that?
19 A Yes.
20 O Do you understand that if you fail to establish a
21, residence, you must inform the Pennsylvania State

22 PoIice of t.he f ollowins inf ormation:
23 The Iocation of all temporary habitats
24 or other temporary dwellings, the places where you eat,
25 frequent or engage in l-eisure activities, and any
2 *1 ^^^^r
PIAIIIIgU
r^^r i naf i nn - JtlU!uurrrY
UEDLIIIqLLV!1, i nr:l rrcli no those
Lrrvu\ located outside of
3 Pennsylvania, and the place where you receive maif,
4 'i nr'l rrdi ncr a nnsf of f i r-c box.

o A No.
1 O Okay. Again, I 'l-l ref er you to counsel-, but f or
a my purposes, what this is tellinq you is that if you
I become Lransient or homel-ess, vou must register that
10 i-nf ormation with the Pennsvf vania State PoIice.
T2 A YeS.
13 n
\/
rrL:rr
vây. Dn yvu
uv \/nrr rrndersf
url9g!Juqrru and votl
_l,vu mttst
rrluoL recri sf er
!uYruuv! with
I4 the appropriate authorities in any state that requires

15 srrr-h
Duull reo.i str-f
!9YroL!AL!UIl
..i
^^ :$
!! Jvu are
q!g emnlOved_
srtty!vJEul .,arr\/
vsLLl nn
vrr a
I6 vocat. loor or are a student in that. state?

I1 Do you understand that?
1B A YeS.
I9 O Do you understand the period of registration shal-I
20 l^re l-ol'l
evr!vs,ed- m '.1 - if
...eanrng pause*, voil
_r,* are recommi-tted for a
ZL
^1 parole or probation violation, or sentenced to any
22 addifional nrison
I- term?
23 A Would you read that again?
.A
LA O Sure. Do you understand the period of
25 registration shafl be tolled, or paused, if you are
2 recommitted for a parole or probation violation or

3 sentenced to an addit.ional prison term?
4 MR. GREEN: That doesn't really apply to
5 him.
o MR. RYAN: I woufd agree with your but
1 'i f rs recrlrired hrr fhe statute.
B BY MR. RYAN:
9 O Do you understand that, even though it may not
10 apply technically in this case, Mr. Cosby?
11 A Yes.
T2 O Do you understand that periodically an address
13 verification form will- be sent to your registered
1,4 address and that you must report to any Pennsylvania
15 State Police station to complete the verification form
t-o and to be photographed within 10 days of the
I7 verification date given to you by the Pennsylvania
1B State Police?
I9 Do vou understand that?
20 A Yes.
2I O Do you understand that, ds you are required to
)) recr'i sf cr r^r'i f h the Pennsvf vania State PoIice f or the
23 remainder of your fifetime, that if you fail to comply
24 with the lifetime registration requirement, you wiII be
z3 committing a felony of the second degree or a felony of

) the first deqree?

4 A Yes.
q
O Do you understand that your name, address, the
o offense to which you have pled guilty, and other
1 iclenfi frzincr factors and information wi I I be r-."
rlrovi-ded to
B Iaw enforcement agencies and made available to the
q nrrl'r'l i
l/svrrv
r- nn en internet website?
11 A Coul-d you read that again, please?
t2 O Sure. Do you understand that your name, address,
13 the offense to which you have been convicted, and other
I4 identifying factors and information will- be provided to
15 1aw enforcement agencies and made avail-able to the
I6 nrrh'l i r: on an internet website?
1,7 A YeS.
1B O And I realize I may have said pled guilty earlier.

79 A You did.
20 O So I appreciate you catching that.
zJ, A And I appreciate you correcting i-t.
zz O No problem.
23 Do you understand that t.he victim shall-
24 be notified in accordance with the Crime Victims Act
25 found at Chapter 18, Section II.20I which is also
2 call-ed the Crime Vict.ims Bill of Riohts?

4 A No, sir.
5 O What. t.hat means --
o A Ird just like to hear it again.
1 O Sure. Do you understand that the victi-m shaf 1 be
B noti-fied in accordance with the Crime Victims Act which
is found in Title 18, Section ]-t.20I, also known as the
10 Crime Victims Bill of Rights?
11 A When you say "crime vj-ctim"
I2 n
Y
Voq
13 A or rrvictims", what victims?

T4 o
)l Sfat-rrl-orilrr-
'-] | the rrictim in this caSe will be
15 notified of your registration under this 1aw.
T6 Do you understand that?

T7 A I have to notify?
1B O No. She will be notified by the individuals that
I9 conduct the registration.
20 A Good.
ZT O Okay . I s that al- I set ?
22 A YeS.
23 O Good.
24 MR. RYAN: Your Honor, t.hose are the
25 questions that I'm required to colloquy him on by
1 COMMONWEALTH vs. WILLTAM H. COSBY, JR. B0
a ^ ! ^ | '. |
JLdLULC. ^
3 At this stage, it's my understanding

4 based on a conversat.ion with Mr. Green yesterday that
5 pursuant to the same statute because, as we've
o el-aborated, this individual- physically may not be abfe
1 to complete a form that. I would ask the Court. t.o
B cert.ify that. this defendant has been advised of his
Y rights pursuant. to the statute.
t_0 THE COURT: All riqht.. The Court will
11 e^ nar1_'i f rr
L2 MR. GREEN: I would not oppose.

13 THE COURT: He's been advised of his
T4 r i nhJ- c
15 A11 right. We've now given him the SVP
I6 designation registration and reporting requirements.

I7 He has waived hi s right t.o aIl-ocution af ter colf oquy.
1B So, again, I would like to limit any closing arguments
I9 to brief rebuttaf or sur rebuttaf or including in that
20 Dr. FoIey and any of his testimony regarding rights
ZI to Iikelihood to re-offend. But I did hear a long
ZZ closing argument from counsel yesterday.
23 Following that, then the Court would
24 retire to prepare its reasons for sentencing. And at
25 that time I woul-d ask t.hat there be a writt.en col-IoQuY,
2 if you can do it this wdy, understanding meaning you

3 would take the colfoquy which is in written form,
4 awnl: i n o:nh .rrraqf i nn
) If he has an ability to make a mark or

o s'i crn his
urYrr name where annrnnriatc- suvt
s-t/-Y' \/rlrt
J". can aSSiSt him in
'7
that. Or I wiII just do it oraIIy as we1I. And if you
B feel- that you do not want to do j-t that. wdY, I fu11y

understand and I will just give him his oral.
10 MR. GREEN: I have completed it. and
11 initialed it for him in each of the places where his
L2 'i nitials miohf he re.rlrired.
13 THE COURT: Thank you very much.

T4 Afl right. Is there anything else that
15 anvboclv believes that. we have missed here in terms of
L6 his sentencing or t.he checklist?
t1 (No response. )
1B THE COURT: A11 right. I wil-l hear You,

19 Mr. Green, and/or Mr. Steefe if therers any sur
20 rebuttal.
2t MR. GREEN: Judge, I'd like first to
22 rcsnnnd t o ,4 1 an:1 nnni- entiOn and then brief Iy tO
23 factual contentions.
24 The Commonwealth yesterday at some point
ZJ drrrilrrYncr t-heir
uu! ufrer r:losinoY *-arcrrmcnf nrodrrCed a memorandum
1 COMMONWEALTH vs. WILLIAM H. COSBY, JR . 82
2 rd^f -rli na f l-'e ann'l

s_v_v f i r:at i on of the int_ermediate
3 punishment statute . I rve had an opportunit y to l-ook at

4 that last nlqht.. I'd fike to address that first.
5 The guidelines prepared by the Probation
o Denartmenf i nnnrnn rrforl intO the PSI indiCate that thiS
7 offense is eligible for intermediate punishment.
B There's been no ob-iecti-on to that f rom the
u Commonwealth. And there's a good reason why the PSI
10 indicates that. The current statute does not exclude
11 from the definition of etigible offenses any pre-20L2
L2 convi-ction.
13 THE COURT: Let me ask vou in this
I4 rcc:rd hcfnrp \/nlr crel- starfed
J""Y-" so vou can address it..
15 The different iterations of the
1"6 Sentencing Guidelines which sets these forward clearly
I1 indicaLe t.hat the Level 5 offense for which he was
1B Ân\''i
v v rr v ! nt-
v u arl
v v t
that between 7996 and 2004 theSe were
I9 amended in June of 2005 there's just no county
20 nrrn'i shmenf there.
21, The Probation DepartmenL did the correct
22 nrrmorir.
llulttclfu orrirl^'l .ih^^ 1^^^^rtqe
ucuau- theV haVenrf
--ts" Jrl u r.hencrcd.
vllqlrYsu The
YurueIlllcJ
23 guidelines in regards to LeveI 5 have changed. They
24 simply don't include a county intermediate punishment.

25 Sn
Jv tzntt
JUU
t !s
re q,q"i
oqJrrrY na rrnrr I I I
Jvu f OIIOW the
1 COMMONWEALTH vs . WI LL IAM H . COSBY, JR . 83
2 orrirlclincs fhat were in nlar:e

F!qe
in 2OO4: hn\^re\/Fr- T
3 shoul-d util-ize the guidelines in place today because

4 I'm senLencing him todav.
5 So there is a dichotomy as to am I using
o the guidelines in place in 2004 or am I using the ones
't in place today because the code clearly says for crimes
tJ committ.ed back beLween 1996 and 2005.
I So as f put that ouL there, please
10 address it because I have gone over I went to the
11 Sentencinq Commission website. I l-ooked at every
I2 iteration of the Sentencing Guidefines since therr
13 implementation since 1,992 and tracked the historY, and
I4 .:! JL.lDL
J-L -i .,^r ^.r*^l\/
>rrlt}JrJ wasnIt
wqJfr u there.
Lr I intend tO note thiS in
15 my sentencing remarks, but it may help you.
L6 A11 right.
ft MR. GREEN: The general principle that
1B should be applied when construing sentencing statutes
19 and secondary guidelines is that changes that
20 disadvantage the defendant may not be applied because
2I that would constitute ex post facto application of a
ZZ punitive degree. But the provisions that expand

23 opportunitiesr dvailabilities, benefits to a defendant,
24 if int.ended to be prospectively applied, are available
ZJ for the benefit of the defendant
1 COMMONWtrALTH vs. WILLIAM H. COSBY, JR. B4
2 And the best example of that is that

'l eoi sl at i rre determinatiOn g6rtrnt.rli n1-armediate
3 tO make
4 punishment available. It was effective 50 days after

q
signing. And it was the legisl-ative j-ntention to make
lntermediate punishment available to people who are
'1
sentenced beginning 60 days after the statute was
a effective.
q
THE COURT: And I don't have a problem
10 with it. I just bring that to your attention so
11 whatever arqument that both sides may have in this

I2 regard would be regarding any current statutory
13 exclusions for county intermediate punishment. as
I4 onnosed f o si mnl rli n 2OO4 it
v}Jtlv999 did not exist and it was
15 not included.
I6 So why don't we move on and the
I7 Commonwealth remark. They have filed' I believe, a
1B memo on this.
t9 MR. GREEN: So, with regard to the

20 exclusion, what we're really focused on is the
2I definition of eliqible offender. And the definition of
22 eligible offender exc-l-udes any conviction subject to
23 Srrlrnhanf er H of Chaof.er 91 . It ' s the sexuaf of f ense
24 sentencinq provisions.
ZJ And l^rrr
vt rlcfinif ion fhen- fhe on'l v
1 COMMONWEALTH vs. WILLIAM H. COSBY, JR. B5
2 eligible offender exclusions are offenses committed on

3 or after December 20I2 because that's the onlv offenses
4 that are sub j ect to Subchapter B by their t.erms .
5 Subchapters H and I are time-defined pursuant to the

o amendments of this.
1 So Subchapter H counsel points to and
B says this is an excl-usion. Subchapter H doesn't appf y
because t.his is an offense that doesn't meet the state
10 tri rroers f or Srrlrr-hanter H.
ur tY So itts not excluded f rom
11 the def i-nition.
r2 The other issue that counsel raises in
13 the memorandum is this history of violence suggestion.
I4 And this is a crystalfized view of the application of
15 uncharged misconduct. As to which you instructed a
L6 jury, you're not here to decide what happened, whether

L1 this is proved or not. It's offered for some other
1B reason. That was what 404(b) was used for at triaI.
I9 And now it's being used as substantive evidence proved
20 to the satisfaction of someone under some legal rubric
?1 that. nobody has identified.
22 THE COURT: What application are you
23 talking about? To the guidefines?
24 MR. GREEN: When counsel savs that
25 rr.rrtrF
_Yvu nol- e l i cri hl e f or intermediate nttn i shment because
2 of this history of violence contention, they point to

3 the uncharged misconduct.
4 THE COURT: So when they say history of
5 rli olFnr-e- cloes the Statrrte sav that thiS conviCtiOn iS
'Vvvgegj
a history of viol-ence?
7 MR. GREEN: The statute doesn't define .
B THE COURT: So it is saying so I can

9 only tefl you that you can save any more words. I have
10 no intention if I was to read the statute, I think I
11 r:otrld fairlv
!gt!!), read it to sav this
uqY con\/'i r-iinn-
4uulvrrl hrrl I wilI
I2 noL read it as to any prior uncharged conduct or
13 appfications of t.he Sentencing Guidelines which, as
1,4 you'11 hear in my sentencing reasons, is a very strong

15 consideration for this Court in imposing sentence.
I6 So I wil-I noL . But I 'm not sure and
I1 I want to hear the Commonwealth tal-k about present.ly
1B charged conduct as is clearly defined as a violent
I9 offense. So the history of violencer dgreed, but does
20 the of f ense charged and convicted, i s that a viol-ent
21 offense that would exclude him? And maybe people have
22 cases . I couldn't find anv.
23 MR. GREEN: I don't think therer s anv
24 case that tells us whether the instant offense can be
25 the history of violence of f enses. I woul-d suggest not
1 COMMONWEALTH vs. WTLLIAM H. COSBY, JR. B1
2 because it's duplicative. And to interpret the stat.ute

3 as drrnl ir:af irre- in ini_ ernraf lannrra.re as harli no nO
4 effect is whv t.he rules of the statute were

q
constructed.
o THE COURT: I understand.
7 MR. GREEN: With regard to the facts,
B those are t.he legaI issues to whi-ch I wanted to apply
v with regard to the facts.
10 Mr. Steel-e says Iif e without deIay, that
11 fhcrerq nlenfrr
".y-Y"J" nf o'l d hlind r.rrr\/s in iail There are.
t2 They're l-ifers. They went there when they were young

13 men. Now they've gotten oId and blind and soon they
L4 wiIl die. That's not the sentencing question presented
15 here.
,LO Your Honor has much more sentenci-ncl
I1 experience than I, but f don't remember anyone ever
1B sentencing a blind octogenarian who was a first
T9 offender to state prison. Laurel Hiqhlands is a nice
ZU place if it's the kind of place you have to go, but
21, please recognize that to get to Laurel- Highlands, one
22 woufd have to go spend some weeks at Montgomery County

23 Correctional FaciIity, some weeks or months at SCI
24 Phoenix, then some weeks or months at SCI Camp Hill for
25 designation before one would get to Laurel Highlands.
I COMMONWEALTH vs. WILLIAM H. COSBY, JR. BB
z Four to six months in transit sounds generous to me.

Mr. Steele, for some reason, keeps
4 €'i hAi n^
!rrrvrrrY i + !rrrl/vr
ru i mnorf uqrru
ant fLvo uqlr
sav that
Lrrqu the
urr\ def endant hired a
5 band while he was on supervi-sion.

6 THE COURT: I will- not consider it, so
1 you may move on.

B MR. GREEN: Thank you.
9 THE COURT: It. was reported in a
10 newspaper. I wil-I not consider it.

11 MR. GREEN: I'm asking you to
I2 THE COURT: If they want to put evidence
13 \Jll7 l-.rrt-
UULt =^: i n
AljA!Lr, T
f hoarrl
llEq!u \zArr
yvu I nrrrl
rvuu rnrl
qrlu nl a:r
U!9q! radarrli
!9VorurrrY nn
I4 court of public opinion, court of 1aw. If t.hey had

15 a-riAanâ rr e e t fhorr r.rnrrlrl harro nrrl-
I/* il- nn
"
1"6 MR. GREEN: FinaIly, I want to finish

I7 with this. Mr. Steele suggests that there's a l-ack of
1B remorse because the defendant went' to trial in a case
I9 that was a slam dunk. I think he said that three
20 times.
2L THE COURT: I'1.1- stop you now.
zz MR. GREEN: Excuse me?
23 THE COURT: The fact. that he has not

24 testified, the fact that he did not allocute will not
25 be considered bv this Court. If the Commonweal-t.h
1 COMMONWEALTH vs. WILLIAM H. COSBY, JR. B9
2 believes they have case Iaw that says that if I did

3 consider it and that's not reversibl-e error, I want to
4 hear that, but I have revi-ewed this very caref ul1y.
) He stood on his ricrht. to remaln sil-ent.
6 That doesn't say that t.hey I re not allowed to use
7 evidence that came in at trial. And that would be the
B deposition testimony. And t.hat's the uniqueness of
this case.
10 But if you want to move on so that you
11 don't have to argue and wonder why I did it. or not, I

I2 have prepared f or this ext.ensively. And, agai-n, if he
13 chooses not to all-ocute, there' s a number of things

T4 that I cannot do with my sentencing.
15 So the Commonwealth will have a riqht to
16 rFRnnnd-
rsol/ulrut l-rrrt ITtmrtl
!uL
-irrsf tell'i
LUrrrrrY ncr _Y""
\/rrlr ricrhf now T dOntt
I1 intend to in any way hold that. against him under

1B sentencing.
\9 MR. GREEN: So l-et me then compress what
20 T was ooi no to sav aborrt- that
r YvflrY ""J
to this. The f irsf irrrv
2I didn ' t think it was a s lam dunk . And onl-v when t.he
22 number of 404 (b) witnesses quintupled did t.he jury
23 reach a verdict. I think it's extraordinarily unfair
24 of the Commonwealth to make that conLention here in
25 this courtroom. I'd ask Your Honor to apply the rule
1 COMMONWEALTH vs. WILLTAM H. COSBY, JR. 90
2 of law.
3 THE COURT : AlI right . Response ?
4 MR. STEELE: Your Honor, f guess f 'f1

5 start with the legaI aspect and fol-l-ow along those
o Iines.
1 In t.his case we prepared a Memorandum of
B Law in regard to the defense ' s request for house
v arrest. I think that's the thing that they're bringing
10 forward on this case.
11 f would suggest to the Court that based
1,2 unon the rules aL the time of the offense where there's
13 no eligibility for house arrest based upon the fact
T4 that it is one of the ineligible offenses, based
15 rrnon and TId srrcrcresi to the Court that we looked at
16 a hisf nrrz nf offenSes.
I1 And I think where defense counsel was
1B going on this, when you consider a violent offense' you
79 can consider the fact and there's no requirement

20 that that defendant be convicted of the offense. And
27 so when you're considering the history of viol-ent

22 offenses and you Iook at the testimony from the prior
23 bad act wit.nesses, again, I would suggest under that
ZL} review of it, inel-igib1e.
25 And ihen-
nlrv , laqtlrr
Ls ,
\^rF
vve tttrn fo fhe naft
I/*-
1 COMMONWtrALTH vs. WILLIAM H. COSBY, JR. 9I
2 where he's asking for the benefit of changes in the
3 law. And I woul-d suggest to the Court that even under
4 thaf- he is not because under that. vou
vu look af tifetime
_Y
5 registration. And we've just gone through that and we
o just col-loquied him on it. He has Iif etime

1 registration as a sexually viol-ent predator as a
B Megan's Law aspect of it and, therefore, ineligible for

9 house arrest.
10 And then I'l-l- move to the f actual
11 orottncls on this that f srrcrcrest to tho r-nrrr+-
YYeu evsLvf 1^\:Sed
L2 upon, you know, Dr. Foley's testimony and the arguments

13 that defense is trvincr to make is that this should
L4 somehow be available to him. I suggest to the Court
15 that theyrre asking for special treatment . They're
t-o asking for a pass on this that should not be given.
11 And, you knowr dfl ability to commit
1B further offenses in this l-ine is not excfusive to his
19 sexuaf tendencies, but it goes beyond that and to the
20 power role that he had and exhibited over time and
ZL directly in this case with Andrea Constand where to
22 say that that woul-dn't be a possibility some time down
23 the line, I suggest, is just wrong.
24 And to say just because somebody is aged
25 and somebody has sight issues, that that. somehow, you
2 know, takes him out of thisr w€ forget or they would

3 rnl-
ClDA yUU fn
LU €nrnal-
IUI9CL l-ho
LlIE raenrrrâq
!gOVU!Uso, 1-ha
Lltc r.rorl1-lr
wsqILlIt 1-ha
ulIL hnmaq
IIvlltuJt
4 the things that have been done. And to suggest that

5 somebody coufdn't be drugged and somebody couldn't be
sexually assaul-ted in some f ashion, whether that's

1 because of his sexual procfivities or because it's
B power to him over these people.
v So to put forth a risk assessment to
10 present to you in sentencing where there has been no
11 testi^g, no testing that was done, to assessment of
L2 other factors, only things that would benefit the
13 defendant and I get. it. I mean, they've hired him.
L4 They're paying him. They only want certain things
15 considered. They don't want the biq picture ]ooked at
_LO in this case. And, Your Honor, based upon those
r'7 reasons, this risk assessment by Dr. Foley, I think'
1B should be put to the side.
I9 And defense counsel brings up Laurel
20 Highlands. Okay? There's a procedure, there's a
21, nlane-
ytsvet fhere is accommodations that are best. Not at a
22 county facility. At a state facitity. And Your Honor,

23 wFr\/F
ws ve recruesl-od
!u\au and hone fhaf vor'1
i "" will- consider that.
z+ We've asked for an aggravated range

ZJ sentence on this. And I think that's supported by the
1 COMMONWEALTH vs. hIILLIAM H. COSBY, JR. 93
z case 1aw that we spoke about on why this should be an

3 aggravated range. We talked about the Smit.h case and
4 Mill-er case where an abuse of confidant is a proper
5 factor to be considered, a person in a position of
6 f rusf i s A rrroner f ar-f nr: to be conS j-dered.
1 And there's a number of other cases that
B go down and look at things to sentence somebody outside
9 of the aqgravated range or in the aggravated range that
10 f ooks at the victim and what they suf f er, l-ooks at the
11 emoLional scars, fooks at the att.empts to intimidate
I2 the victim, looking at the defendant showing no remorse
13 for what he has done.
L4 In the Fuect case, the Court found in
15 that case above the aggravated range of the guidelines
t_o where the defendant's indecent assault conviction was
L1 proper, though the def endant i-n that case actual Iy

1B expressed remorse, actually accepted responsibility,
1,9 actually had no prior record. The Court properly
9n considered the sufferins endured bv the victim in that
21, case to sentence the defendant in an aggravated range
ZZ or above the aggr avated range.
./a So T'I1 sum up, Your Honor. There Is
24 been a request, I think, by the defense based upon

z3 infirmities in terms of d9€, that this should somehow
) equate to mercy on this Court. And I would just ask

3 the Court to consi-der in this ask for a pass that he
4 was oood af hidi no f hi s f or a l nno t ime- , crnod

Yvve et
5 suppressing this for a long time.

6 And so it's taken a Iong time to get
1 there, but in the considerations that he asks for based
B upon him, I would ask the Court to weigh the
9 considerations in what was done to Andrea Constand and
10 her family and I know Your Honor has the victim
11 impact stat.ement that says it al-l- and what he has
L2 done to others.
13 And I suggest to the Court that, based
T4 upon that, this should be a state prison sentence.
15 This should be a sentence that happens today because
I6 he's earned it. Because he's earned it.
T1 THE COURT: AII right. Thank you alI
1B \7Fr\/
vsrJ mttr:h -
lrruurr Tsr there
urru!u anvthi nr^r el sc pnrzhndrr ^2n think Of
I9 regarding procedures? Again, when I return f will-

20 issue the sentence of this Court at 1:30. That will
21- r "" al reaclv have the time built
mean vou in that at 10
22 after 1:00, dssume that Mr. Kehs is giving you the

z5 10-minute warninq. It wonft be 1:30. I intend to come
.A
Zq in and issue the sentence of the Court at that time.
25 MR. STEELE: Can Mr. Green and I see you
2 about one thing?

3 THE COURT: Why?
4 MR. STEELE: I can't submit something to
5 Clerk of Courts unt.il- I get a judge's signature on it,
o and I don't think I should take it to Miscel-laneous
1 Court.
B THE COURT: fs it on this case?
I MR. STEELE: It is.
10 THE COURT : It can I t wait ?
11 MR. STEELE: It can, and I think that

1a
IZ was sllclctested
eqYY earl ier-
rv! but f also
t
13 MR. RYAN: It's the costs.

I4 THE COURT: Okay. Itrs the cosLs. Is
15 it something that needs to be done in open court?
t_o MR. STEELE: No, it does not.
I1 THE COURT: Stay here because what I'l-l
1B do is r'11 give him all hj-s post-sentence rights and
19 just come in and put a reason for sentence and impose

)n sentence. Does that work as well? Do you have his
2L MR. GREEN: I 've explained t.he
22 post-sentence rights . I've put it on the record. I've

23 alreadrr sicrned the form.
24 THE COURT: Irm a big bel-iever in belts
25 and suspenders. Just hang in there. I wiIl see the
2 two of you. So we wil-l go f or a littl-e bit. We're

? stiIl going to issue t.he sentence at 1:30.
4
tr
J /WherFlrnnn - a COnf erence waS held at
o c i rloha r nn1- rann rl- eve.arl
I \/
B THE COURT: AfI right. Mr. Cosby, in

regards I do intend to issue sentence; therefore,
10 \/1^.;ll
-I ""
wi I I harro nori-:in nOSt-SentenCe ricrhfs
11 Mr. Green has informed the Court that he
I2 has taken time to orally go over the form that I am
13 lonkincr af ricrhi nnw with \/oll

I "" ancl fhat Mr. Green
1,4 initialed it indicating the understanding that he had

15 that you did understand the rights.
1,6 I will suffice it. to saV bV the nature
77 of this case, its l-ength for 34 months, that everyt.hing
1B that has been fited of record in this case that
I9 means motions, that means Motions in Limine, Motions to
20 Suppress, any pretria.l- motions, any motions f iled
21" during court, any objections made during trial -- they
22 are alI preserved.
23 THE DEFENDANT: Say the last word again.
24 THE COURT: They are all preserved for
25 AnnFl I afe
*t/i-- rFView.
1 COMMONWtrALTH vs. WILLIAM H. COSBY, JR . 91
2 THE DEFENDANT: Thank Vou.

3 THE COURT: Now, again, that is the
4 overview. So you have two ways of addressing it to
J either this Court or the Superior Court of
o Pennsylvania, fr€aning you have an optional
'l post-sentence motion to this Court. And i-t is not
U necessary to do so in order to be able to appeal to a
q higher court. However, you do have that right. It is

10 within the Rules of Criminal Procedure.
11 If you do file it, it simply has to be
I2 in writitg, it must be within 10 days of sentencing,
13 and it. has to state with some specificity and
L4 particularity of the relief requested. And again, it

15 can be any kind of Motion for Judgment of Acquittal,
t_o Motion for ArresL of Judgment, a Motion for New Trlal'
L1 Motion t.o Modif v Sentence.
1B Those are the recognized post-sentence
I9 moti-ons that vou can address to this Court for the
20 reasons that Vou would set forward. And, again, the
2I re'l 'i cf rFcllrested "'"
mav be based on issues which were
_r
22 preserved by motion or objection before triaI, during

23 tria1, or at the Sentencing Hearing.
z.r
.A
Again, it is not necessary to include
25 alI of the issues that you may want to appeal to a
1 COMMONWEALTH vs. WILLfAM H. COSBY, JR. 9B
2 higher court. You may put whatever motion whatever

J issues you wish in a post-sentence motion if you choose
4 to file it. If you financially qual ify, it can be
5 without the payment of costs. That does not appear

o :nnl
*rF * i nahl a
1 And again, if you do file LL, I must

B render a decision within 120 days. I guarantee that I
I wou1d, if you did file it, render a decision within
10 thaf time neriod.
1_1 And then if the maximum sentence is two
L2 vears
ry Uqr o or
vI loncrer-
fvII\jlE! t ihn
Lllg filino
! IfIITV nf
V! a IJvD L-DEllaanr_
A rrcrs-+ LEIIUC motion
I
13 wiIl not ordinarily delay the commencement of the

I4 qonf cn-p - arra i n a I thorroh 1_ hc -irrdcrc does have diSCretion
'gYqll!vuYr]JugYu
15 to allow bail pending any appeal to a higher court.

t_0 THE DEFENDANT: Would Vou run over that
r'7 Iast sentence?
1B THE COURT: If the maximum sentence,
T9 which in this case it is again, the maximum sentence
20 in this case is two years or Ionger. Again, f'm not.
21, issuing what it is, but potential- is there for a
22 maximum sentence of two years or Ionger. The filing of

23 a post-sentence motion wil-l- ordinarily not delay the
24 commencement of sentence, dfthough the judge does have
ZJ discretion to aIl-ow bail pending an appeal to a higher
-L COMMONWEALTH vs. WILLIAM H. COSBY, JR. 99
L court. It is fullv discretional within the Court.

3 Again, if the maximum sentence was Iess
A than fwn \/FArc vnli
Jvq
r.rnrrl_61 haVe the riohf
Samtr lrYrru fO
u bail
5 as before sentencing pending the outcome of any

b post-sentence motion or appeal to a higher court.
1 Now, if you elect not to fil-e a
B nneJ- -eantonno mnl- i nn \raJU may appeal directly to the

-r
9 .Srrneri
vqt/e or Corr-.t- nf Danno.rl-Vania and it WOUId have t.O be
10 within 30 davs of todavrs date.
1I Arya i n - 'i f no nosf -sentence motion waS
L2 fiI
!!leu, ed - the
LIlu lrlnf
I\vLIUEir-c nf
vI Anr-^-'r
nyIJgAr --- i^
AVArlr ^1n
U( contain whatever
13 \7nrr
lvs thrl- TrrAa nrnnarlrz
r-v.t-vlt-I nraqarrrorl hrz mnl-
...--aon,
^nne'irlar
I4 pleadi.g, objection at trial. Essentially everything

15 that \/r:lr
-I "*
raised anr.l nreserved on the record of this
I6 case is available for review upon appeal-. Again, if
17 you were to financially qual-ify, you may be able to
1B f il-e it without paying t.he costs.
19 And acra'i
nrIU AYqLLI r ,
T -^*i^r
MlttIIlU './orri
JVU ssrres that
foousD L are
20 ra'i sed on annea I don I t have to be raised in the
2I post-sentence motion. Any issue can be raised on
ZZ appeal- which has been preserved by motion or objection

23 before tria1, during trial, or at this Sentencing
24 Hearing.
25 Alsn- \/nr mav raise
, iv issues whether the
2 sentence constitutes an abuse of discretion, whether

3 the sentence is ilIe9al, or whether the Court Iacks any
4 irrri.sdir:tion in this case.
5 Acrain- the bail- is if the maximum
6 sentence is two years or longer, the filing of an
1 appeal to the higher court will- not ordinarily delay
B the commencement. of a sentence, dlthough the Court does
9 have discretion to a1l-ow bail pendlng appeal- to a
10 h'i nhar nnrrrf
11 If the maximum sentence imposed is less

L2 than two years, the defendant wiII have the same right
13 to bail as before the verdict pending the outcome of
I4 :nnoal {- n : hinhar nnrrrf
15 Do you feel- you understand those as

aa
IO explained by Mr . Green and now reit.erated by me ?
I1 THE DEFENDANT: CIearly, sir.

1B THE COURT: Thank you very much. We
I9 will- return at 1:30 for the sentence of this Court.

20
21" (At L2 21,7 p.m. , a recess was taken until-

ZZ 1:39 p. m. of the same day. )
23
2A (Proceedings were reconvened with the

25 Court, Mr. Steele, Mr. Ryan, Ms. Feden,
COMMONWEALTH VS. WILLIAM H .^qpv
vvuu L t .rD 101
a Ms. Piatkowski, Mr. Green, Ms. Redmond,

Mr. Gofdberger, and the defendant being
a nraqonl- . \
5 THE COURT: We're about to proceed with

6 sentencing of the Court. Again, the Court reviewed at
1 the beginning of the sentencing exactly what it is
B rel rri no on And acra
sYe+r" i n - I ref erenCed the materials that
I had considered in preparation for this Sentencing
10 Hceri ncr - and T i nr.rlrncrrate them into t.he reaSons f or
11 sentencing.
I2 Therefore, it would be aII of the
,LJ contents of the Presentence Investiqation. It would be
1,4 the guidelines that. were attached and agreed to by the
15 part j-es.
1"6 It would be t.he victim impact
I1 statementsl that is, both testimonial of t.hree of the
1B victim impact st.atements and t.he writings of Andrea
I9 Constand.
20 It woul-d be the def endant's SenLencinq
2L Memorandum with the attached letters with the
ZZ additional letter that he entered during sentencinq.
23 Tt woul-d be the testimonv and the
24 psychological- examination report by Dr. Foley.
z3 I woul-d incorporate any wit.nesses that
1
-L COMMONWEALTH vs . WILLIAM H. COSBY, JR . I02
2 testifled on behalf of the defense and/or the
3 Commonwealth or any addit.ional documents that. may have
.iA been admitted here at trial.
5 I heard the argument s of counsel- . The
o defendant has been given his post-sentence rights.

7 So I have to put certain reasons on for
B sentenci-ng, but it is important that we understand the
sentencing considerat.j-ons that. are imposed upon a
10 Court. And I start off with the most important

11 doctrine, that the imposition of a proper sentence is a
12 matter that is vested i-n the sound discretion of the

13 Trial Court. But I do feel I have a dutv to the
I4 public, to the defendant, to the Commonwealth to
15 explain the certain statutory considerations and
l_o constraints that are imposed upon that discretion.
L1 Section 912I of our Sentencins Code is
1B instructive in determining the sentence t.o be imposed
I9 hrr the Cottrf As anJ-lrr nnfpd hrr nntrnqel hora-
rre!e, f have
20 to consider or select one or more of the foflowing

21, alternatives to impose as a sentence.
22 I may consider an order of probat.ion. I
23 harzp- and T will
t qrrs not sentence this defendant to an
24 order of nrohafion as nre\/iorrslv sel- before it. I can

25 make a determination of guilt without further penalty.
1 COMMONWEALTH vs . WILLIAM H. COSBY, JR. 1 03
2 This case does not warrant such a penalty. Partial

3 confinement. I have read it and will issue the
4 stat.ement. the Court's reasons of whv I am not
q i ssrri no a sentence of nartial- conf inement. Total
o confinement, which is what the Court wil-1 issue in this
1 case. I find, which the Court wilI issue in this case,
r:orrnf v i nf ermecli af e nttni qhmnni
v v u rr u )r
whi ch the Court f or the
I reasons to be set forth fater in the reasons for
10 sentencing I do not find appropriate. And, finally'
11 sLate intermediate punishment for which this defendant
I2 does not qualify.
13 The general sLandards that I must apply
L4 in sefecting from these al-ternatives is that any
15 sentence of total- confinement has to be consistent with
t_o the nroter:t
t/! v L i nn nf t-he nrtblic.
I1 I must take into account the gravity of

1B offense as it relates to the impact of the life of the
I9 victim and the community, and the rehabilitative needs
20 of the defendant.
2I Mnqf imnnrf anf"-1,lrz- T am instructed that
ZZ the Court must consider any guidelines for sentencing
23 adopted by the Pennsylvani-a Commission for Sentencingt
24 which is a wing of the legislature. So that is a
25 Iegislative pronouncement.
1 COMMONWEALTH vs . WILLTAM H. COSBY, JR. 1 04
2 aa:.i n
lr\Jurlrt r haVe COnCIUcled
uvrturuusu fLtrqL
haf nroha1-
I/rVUOLMl,
.i nn
3 partial confinement, county intermediate confinement

4 simnlrz is nnf annrnnri
uy-yrvI/!rqr ,ale.
5 But in making any other determination as

o the proper sent.ence, I must have the sufficient and
1 accurate information.
B I must afford the defendant the
9 onnorfrnitrr
v-tsvv to make a statement on his own behalf which
10 he has waived. I cannot hold that. aqainst him under
II the faw.
72 The Commonwealth and the defense have
13 both had the opportunity to present argument and
I4 inf ormation rel-ative to sentencinq.
15 I must consider the defendant's
t-o individual characteristics and circumstances of the
17 particul-ar offense and, as previousJ-y noted, I am
1B compelled to consider the guidelines.

19 When imposing a sentence, again the
20 Court must consider the protection of the public, the
)1 gravity of the offense in relation to the impact upon
t) the victim, the community, and the rehabilitative needs
23 of the defendant. It must be within the statutorv
24 limits, and I assure you that it wiII be.
25 Again, if f impose tota] confinement,
1 COMMONWEALTH vs. WILLIAM H. COSBY, JR . I vJ
2 which I intend to do, it must be consistent with the

3 nrnf anf inn nf
V! l-Lllgtra nrrl-rlin
yUVf!Ut fLIICha nr:rrif rr nf
V! l-LrrUha V!IEllDET
I/rvLLULrVll 9rAVALli ^f€^h-^
4 the rehabilitative needs, and all other considerations

5 for a Court in issuinq a sentence.
o At sentencing, the Court must seek to
1 vindicate society's interest in imposing appropriate
B sanctions against those individuals determined to be
Y criminally culpable, but at the same time I must give
10 fair and fulf consideration to the particufar
11 circumstances of the individual- defendant and t.he
I2 adherence to proper sentencing procedure that will
13 nrorririe fhe crrA^toq1- ^<SUranCe that the intereSt Of all
t4 concerned wil-l be protected.
15 Again, I have said I've considered the
I6 defendant's background, hi-s individual characteristics,
r'7 and the relative culpability of the prospects and will
1B comment on that.
1q Again, T woul-d note this is a serious
20 crime, but it would be error for the Court to base its
2I sentence solelv on the seriousness of the crime.
ZZ Again, the crimers victim and the impact
23 on a victim continues to be a siqnificant element of a
24 sentenr:incr
ogIILsIrurIrY irrdcrcrs
Juvvs o r-nnsiderafinn-
uvrf D!us!qurvrrt and T harre oiVen that
25 due consideration and weiqht as I wiIl comment on.

2 So thatts the backsround from which I

3 have to begin to proceed. The reasons for the Court's
4 sentencing are as folfows.
5 Mr. Cosby, your guilt has been
o determined by a j ury. You were convict.ed of a very
1 serious crime, that you penetrated Andrea Constand's
B crenifals r^rith \/oltr hand without
v vs4 her ConSent.
In exercising discretion, f must not
10 overlook these pertinent facts. I shall not disregard
11 the force of the evidence that the iurv considered in
I2 finding you guilty. You were convicted by a jury of
_L -t three counts of aggravated indecent assaul-t.
I4 Merger is a Iegal concept. that is
15 annl'i ed au
qyIJrIsu at ourluefruarr\:j.
sentenr:ino- The
rrr9 ya! ^^*^^r r-^-^
narfLr9oies o9!Ecu Ilc!c that
76 Counts 3 and 2 merqe into Count 1. I am allowed to
I1 consider t.he jury's verdict; however, I am not al-Iowed
1B to sentence Vou on it. Brf fhe irrrv doesn't
J "- f know about
I9 merger. However/ the facts considered by this jury led
20 them to be convinced bevond a reasonable doubt that an
2L aggravated indecent assaul-t was really three different

22 i-rrnps
u_Y _He nf r-riJ1 gg.
23 Thev forrnd tha1_ _r""

\/nrr Started the aSSauft
24 trrz srrl^rsfanf iallrz imnairi

-It....y"y"
no Andrea Constanclts nower to
25 appraise or controf her conduct. You did so by

1 COMMONWEALTH vs. WILLIAM H. COSBY, JR. r07
Z admi-nistering, employing without her knowledge a
r-erl-ain rlrrrcr for fhe nttrnôa nf hr6\/An].inr-r rcqiStanCe
4 to the assault. That's the crime that thev convicted

5 you of. It merges. T can't sentence you on iL, but
fhe irrrrzrs
) "- l rrerdict must be heard loud and cl-ear.
1 That at the time of the assault, Andrea
B Constand was unconscious or that vou knew that she was
9 unaware that the penetratj-on was occurring. Again,

10 that is 3125 (a) (a).
11 And then what you wiII be sentenced ofl,
1,2 which j-s what aIl t.his culminated oD, which is what
13 indecent sexual assauft is about, that in the end and
I4 what you'Il be sentenced on is the penetration was done
15 without her consent.
t_o That evidence i s overwhelmins t.hat it
71 was planned predation, a planned assault, the giving of
1B tha ni 1 I o the unCOnSCiOUSneSS Or the unawareness, the
LY Iack of consent. Your own words in vour deposition
20 testimony made it clear to the fact finder that in your
2I own mind you had no verbal- consent. You heard no
22 verbal- consent. You cl-aimed her silence was consent.
23 That is not the law. The jury found
24 that she was silent because she was unaware or
25 unconscious because of the intoxicant you gave her.
2 Your version of consent was implicitly rejected by the

3 irrrv
J"-JJ"". Thaf is what underscores irr.st how serious this
4 crime 1s.
5 I agree with Mr. Green. This is a court
o of l-aw. And I intend to sentence vou under t.he 1aw.
1 First and foremost, I again am aware in
B imnosincr fhi s sentence f do have to conSider the
et!rY
q nrnf
I/!VLsULrVlr er:f ion of
v! ihe
urru ntrl'rl
12vpLLv,
ir-- .l_
he Y!sv+u_),
rrrarli f rz nf 1-he nf f ense
10 and its relation on the impact. of the victim, and your

11 reh.abilitative needs .
I2 As I will state Iater, again the

13 rehabilitative needs I can qlean from the PSI. I've
I4 reviewed it. There does not appear to be
15 rehabilitative needs. You have neither souqht them out
t_o hAr radllac1-arl 1_ ham nnr
- are you currentlY in anY
77 treatment.
1B In fashioning a sentence, I will appfy
19 f he nri nr-inl c nf F.rlr^l - irrsti
J" r:e ttnder the Iaw.
20 Sentencing Guidefines are the legislative pronouncement

2I of that principle. No one is above the law and no one
22 should be treated different.Iy or disproportionately
23 because of where they Iive or who they are, in terms of
24 ,.,a:lt_h
WEdaLlIT fIAltrgt
:ma nolahr-il_
uE!EU!LuIt rr nr
v! a\ran
uvvlr nhiIenl-hrrrn\/
I/rr!!qIrLIr!vyJ.
25 Sentencing Guidel-ines were promulgated

2 so that the lenqth of the sentence would be more

3 standardized across the state and between iudqes. That
4 was bot.h to increase sentences that were too low and
J reduce sentences that. were too hlgh. They were meant
o f n l^re a .rrli d'i no f nrr-p - one t.hat is to be conSidered in
7 the discretionary aspects of sentencing by a judge.
B This Court is not free to reiect the
I assessment of -iust punishment conLained 1n the
10 Sent.encing Guidefines and interpose its own sense of
11 just punishment, so I wiII embark on the Sentencing
I2 Guidelines standards. They are set forth. They are
13 the law of this Commonweal-th and this court of Iaw
I4 under which you are being sentenced.
15 I shaIl consider the Sent.encins
16 Guidel-ines 1n determining the appropriate sentences for
11 offenders convicted of felonies. The guidel-ines apply
1B to a1f offenses committed while theV were in effect.
1,9 Again, the guidelines that were in
20 effect in your case were those that were promulgated
2I originally in amended June 13th of I991, and they
22 were in ef f ect up until June 3rd of 2005. I wil-1
Z5 utilize the quidefines in effect in 2004.
24 In every case in which the Court of
25 record imposes a sentence on a felony' I must make part
1
COMMONWEALTH vs. WTLLIAM H. COSBY, JR. 110
2 of the record and discl-ose in open court at the time of

.J the senLencing the st.atement of the reasons or the
4 reasons for the sentence imposed. I am doing so at
5 this time. That is a requirement of the guideli-nes.
o I am instructed under the quidel-ines
1 after you are convicted, you are assigned an offense
B orarrifrz s.:crre. ThattS hOw it wOrkS.
9 The purpose of sentencing that is set
10 forth in the guidelines, which is the Iegisfative
11 pronouncement of what this Court is to do, will provide
12 a benchmark for alI iudqes of this Commonwealth. The
13 sentencing guidelines provide sanctions proportlonate
I4 to the severitv of the crime. And this establishes a
15 sentencing system with a primary focus on retribution,

I6 but one in which the recommendations all-ow for the
I7 fulfillment of other sentencing purposes, includi.g,
1B and I quote, "rehabilitation, deterrents and
19 incapacitationrr .
20 To facilitate consideration of
2I senfenr-'i ncr nntions r-crnsi.stent with the intent of the
22 Sentenr:i ncr
vIIvfIIYv++r.v9' Grr i dal i neq - r.he Commission eStabl-ished f ive
23 l-eveIs of sentencing. It has been determined by the
24 Presentence fnvestigation that indecent assault, which
ZJ you were convicted of , is an of f ense gravity l-evel of
COMMONWEALTH vs. WILLIAM H. COSBY, JR. 111
2 l0,aLevel5offense.
3 Goinq further in the guidelines, Level 5
4 provides a sentencing recommendation, and I quote, "for

5 t.he most violent offenders such that the conviction has
o an offense gravity score of nine or great.er or at the
7 standard ranqe requires state incarceration".
B Such a sLandard range, it goes on to
v sdv, that "the primary purpose of the sentencing
10 nnf inns af f h'i s
vyurvllu"r. h icrhest l errpl are nrrnishment
11 commensurate with the seriousness of the criminaf
12 behavior and incapacitation to protect the public".
13 So under the guidelines, this LeveI 5
I4 call-s for the following:

15 Total confinement in a state facility.
I6 Acrein- ii
LrY s L lt I
r-affs for total confinement in a state
I1 f ar-'i I i f rr w ith nart i r:i naf.ion in a state motivational
1B boot camp. You are not eligibl-e in that you are
I9 nrarfor l_han LO j-*--
\ra.arq.
-- age'
nf
20 State intermediate punishment pursuant

2L to Code 303.12. You are simply not it. is not
22 rnnl
g.yy'Jvg i nrhl o fnr \7.rlr ri- fhi e. qfarro
23 There is no substance use disorder

24 de f ined .
ZJ TotaI confinement in a county facility.

1 COMMONWEALTH vs. WTLLIAM H. COSBY, JR . 1I2
Z Again, pursuant to 42 Purdon's 9762, the Court simply
f inds that that. is not applicabl-e nor appropriate.
4 Partial- confinement in a county facility
5 pursuant to 42 Purdonrs 9162. Aqain, I find it. not
o annronri
"t/}/-*-yr- ate nnr ennl i r-abf e.
1 And then, finaIly, the arguments towards
B r:nrrntrz
vvgrrufl/grrf.Y*9 infermediatc nrrnishmcn1- nrrf fnrfh hrr Mr Green.
9 Again, he t.ook an approach as to a current analys i s of

10 a recently-enacted Sexually Violent Predator Assessment
11 or the sexual offender code as to whether it woul-d or
I2 not. I am not sure I aqree with him, but, in any
13 6176hi-
v v v rr u t T rtn not find a senLenCe Of Corrntv
v v u rr e _Y
infermediate
T4 punishment to be appropriate nor applicable to this

AACA
I6 Again, I have made it clear that this

1_1 Court does not. consider that probation, partial
1B confinement, or county intermediate punishment is
I9 appropriate.
20 So f have to consider all the statutorv
21, consideraLions, but I intend to apply significant
22 weight to the Sentencing Guidefines because those are a
23 I aa'i q'l rf i rro pronouncement. They are a pronouncement of

z.r
.A
our elected officials that are applied by this Court on
25 what are appropriate senLences for serious sexual
1 COMMONWEALTH vs . WI LL IAM H . COSBY, JR . 113
2 assauf ts t.hat you are convicted of committing.

3 I do have other statutorv
4 considerations. Again, I have reviewed them. T have
5 to foflow the general principle that sentence imposed
o should only call for confinement that is consistent
1 with protection of the public. And again, I harken
back to the deterrents set forth in the quidelines and
I nrni- oni- i nn nf tho nrrlrl i c aS it would be the victims in
10 this case and in the future.
11 Again, I have weighed any risk of
I2 re-offense. I have discounted them to a certain
13 degree. But this is a sentence that is consistent with
T4 the protection of the overall public.
15 The gravity of the offense as it relates
I6 to t.he impact of the l-ife of t.he victim and on the
I7 community. I wilI speak to t.hat shortly.
1B And, agiain, the rehabilitative needs of
T9 the defendant. f have again reviewed them from the
20 Presentence fnvestigation and everything contained in
2I there. And again, the defendant has neither requested
ZZ rehabilitative, nor do I see any indicated from the
23 record as it stands now.
24 Again, I am reminded by Section 9725 if
25 T t m YvrIrYuv
rrni ncr f n i mnnqa : centenCe Of tOtaI COnf inement,
1 COMMONWEALTH vs . WILLIAM H. COSBY, JR . II4
2 agfai-n with due regard to the nature and circumstances
3 of the crime, again a serious crime, the hist.ory,
4 charact.er and condition of t.he def endant.
5 It. woufd be the opinion of the Court
6 that total confinement of the defendant is necessarv
1 because there's an undue risk that durincr the period of
6 nrnl^ratinn rrr narJ_ ial r:onfinement which this Court has
Y already rejected because not appropriate under the
10 guidelines nor the seriousness of this crime of whether
11 the def endant will commit anot.her crime.
I2 f heard the testimony of Dr. Fo1ey. f
t-J recognize the defendant's age. f recognize the
I4 defendant's blindness. However, again, that is not the
15 factor that I am putting the most weight on. The
1,6 defendant is in need of correctionaf Lreatment that can

L7 be provided most effectively by his commitment to an
1B institution.
1,9 I find, based upon the seriousness of
20 the charge and t he Sentencing Guidel j-nes, that
2t correctional treatment can be provided effectively by
22 his commitment to an institution.
23 And the final is a l-esser sentence would
24 depreciate the serj-ousness of the crime of this
25 def endant. I do put weight on it. It is not the sol-e
2 reason, but this is a serious sexual assault and I nrr

-r""I
3 weight on the seriousness of the crime as it came to
4 Iiohf in the testimonv of this case. So t.he Court
5 incorporates all of the evidence in this caser ds Irm
rF.rr i rcd I o dn s,n
9v, - when f conclude that thiS waS a
'7
serious crime.
8 So, as I said, the nature and
g circumstance of t.he defendant comes from the PSI. And
10 I don't have any evidence to base any finding about the

11 defendant's rehabilit.ative needs, no testimony except
t2 for the evaluation regarding his risk facLors which I
13 have taken into account. So, therefore, t.hat must be
I4 discounted in that there is iust no obvious
15 rehabilitative needs.
t_o The Court is aware in a state
I1 confinement there is programming for t.hose who are
1B designated to be sex offenders, and he wil-1 be required
I9 to undertake that programming in a State Correctional
20 Institution.
2I I have looked at the historV, the
22 character, the condition of the defendant in light of
)') the fact that equal justice under the Iaw requires that
24 I'm not permitted to treat him any differently because
25 of who he is or who he was.
1 COMMONWtrALTH vs. WILLIAM H. COSBY, JR. 116
2 I'm reminded of Judge McEwen, Superior

3 Cnrrrf - lafe His WordS wFre crrrnter^l direr-f lrr from
4 Commonwealth versus Lee. It references the Old

q
Testament. It tells us that fallen anqels suffered
h\ most from the torture of their fall- from qlorV and
7 nl ttmmet f rom ctrAr-F - heset with the cOnStant and
B unyielding knowledge of abandoned magnificence, and
consumed with the certaintv that what was once can no

10 longer be. And, of course, the higher the ascent, the
11 sharper the faII. The more precious the gift., the more
72 shameful its loss. f recognize that impact upon You,
13 Mr. Cosby. And I am sorry for that .
I4 So statutorilv total- confinement is

15 warranted. The nature and circumstance of this crime
IO and the history, character and condit.ion of the
I1 defendant, again, is in need of correctional treatment.
1B That is what is recommended by the guidef j-nes. Any
19 lesser sentence would seriouslv depreciate the

20 seriousness of the crime. Those factors have been
2L considered.
22 When I consider the seriousness of the
23 nri
u! mc- i_he
Iltrs, Lrrs
'i mnar:tL on the
rrrtl/9u rrir-l-im- the likefihood to
24 re-offend, I do have to be cogntzanL of the 404 (b)

25 testimony and to assure that I am not taking that into
1 COMMONWEALTH vs. WTLLIAM H. COSBY, JR. 1L7
2 accounL t.hat any of those wj-tnesses were vict.ims

3 because the conduct was uncharcred.
4 But I recognize, from the evidentiary
q
value that there was, the jury heard that evidence.
And now the Court, noL as victi-m impact testimony as I
1 read that testimony once again, but to hear voi-ces from
B l-Lrruho n:ct
yqoLt \/^rrr
jvsL n:qf
yqrul Mr
LrL Cnqhrr
ovJ,
q:rri
rujrrr:J nrr i-hi e hannanod l- n
q me at the defendant's hands six times over.

10 My ruling regarding the evidentiary
11 value of that was based on 1aw, the Doctrine of
1,2 Tmnlarrs,ih'i lifrr- fhaf fhose voices said over and over
13 and over again over timer Rdking them plausible' that
L4 it would not be a val-uable evidentiarv piece to be abl-e
15 l-uun rrea
uDs hrr
py 1-ho
LrlE -irrrrr
)vL.y
i n
rll doi-
uuuu ormi ni ncr \/a\rlr r^rrli I t
T6 I have reread the testimony, as the

t1 Court is required to do, in fashioning this senLence.
1B I heard their voices loud and clear. I hear vour
79 af l. nrnarzl
ouLv!rrsJ Je Ar.rrrmenJ-q
q!vurrlsrrLo fLrrd.L
h:r ^'i*^1'-
DflttPry ^^f h
rruLrrrrrv incr has
lraD hanncncrj
rlqt/yslrsu
20 in the Iast. four years and you are old. Some might say
2I you were old back then at the time you committed the
)) assault on Ms. Constand, but some might also say that
23 it. ended because a powerfully bright light was focused
24 on vour behavior.
25 T harre oirren rrreal_ weicrht to the victim
I
COMMONWEALTH vs. WILLIAM H. COSBY, JR. 118
z impact testimony in this case, and it was nothing short

3 of powerful. Ms. Constand merely t.ook the stand and
4 said You have read it, and I did, and now do justice.
5 Her victim impact. t.estimony puts meaning
behind the true gravity of the offense of indecent
1 sexual assaul-t as it does relate upon the impact of t.he
B life of Andrea Constand and her community and by
9 that I mean her family as to the night of the
10 ,,
ctDSclt-lrLt 1f . r'L.a
LIIe dasr.r.i
usDur nt-i on of
!Pufvrr vr the
urre Dar,^1--^.:
t2sLO, ryDrDt ^^*Ie
LlIlaU tO
1,r speak yet screaming in her own headr urabl-e to move her
I2 lipsr hor flor oo, because you were drugged. The
13 defendant never heard those words of dnguish. He made
1,4 sure of that because of the administration of an

15 intoxicant. The iurv heard those words. I have heard
I6 those words.
I7 Other passages from her victj-m impact
1B t.estimony have impact upon this Court, of the person
I9 she was before, confident in the Iife ahead of her, the
20 nightmare of the assault, the traumatic aft.ermath, the
ZI shame, the self-doubt, the confusion, the afienation
zz frnm
!!vlLL famiIrz
!qrar!!J and
qrrs friends-
!!rurrur, fee'l 'i no urvaru,
!uurrrrY a'l nna- rrnak'rlc to
f rrrcl- nli qh arri l l-

23 Fe+rl n I :narli
v" ni ahf mrraq nrrnqrrmnl_
-OnSUmPtIOn
i nn nf
O' Yulru.
24 She came forward. No charges were

25 filed. A civil suit, deposit.ions' the serious
1 COMMONWtrALTH vs. WILLTAM H. COSBY, JR . 7I9
2 re-traumati-zation of a victim in depositions. As she

3 said, Mr. Cosby, you took her beautiful, healthy, younq
4 spirit and crushed it.. I don't know whether the
5 defendant read vour statement . I did. I heard the
o very clear impact on your life.
1 I also heard from your family of the
victim traumaL:_zation because traumaL:-zation of this
9 sort is a family experience. And it is especially
10 devastating when such an extraordinary family ]ike the
11 Constands were put through this devastating trauma. So
I2 T
! nrrf
I/uu
a
q h i crh derrree of wc'i crht on the imner-f nf the
13 crime and the victim and her familv.

I4 So I have said the reasons why the Court
15 and the importance it is putting on the different
I6 sentencing factors.
I1 Thirty-four months. Thirty-four long
1B months since this Cri-minal Complaint was brouqht. It
19 is time for justice in a court of 1aw. Mr. Cosby' this
20 is all circled back to you. The day has come, the time
2L has come.
22 SENTENCE OF THE COURT
23 THE COURT: Accordingly, you have been

24 given your post-senLence rights. There's nothing
25 f urther to come bef ore this Court. It is t.he sentence
Z of this Court based upon the reasons set forth that you
3 be senLenced to not Iess than three years nor more t.han
4 10 years in such State Correctionaf Institution as
5 shalI be designated by the Deputy Commissioner for

o Proqrams, Department of Corrections, and sent to the
'7
St.ate Correcti-onaI Institution at Phoenix forthwith for
B this purpose. You are not RRRT eligibIe. You shal-l
9 pay the costs of prosecution and a fine of $25,000
10 within the first 72 months.
11 Count 2 and Count.3 of the Bitls merge
I2 for the purpose of sentencing. You are to have no
13 contact. with Andrea Constand or any family members.
14 And Jvu
nrruvolr sha'l I he
rrrs!! ve srrbiect
ouu)uuut
:E
fL DLJ nnria1- e-
AIJI/rUIJrf,ALCt t'rrz the
py
15 Department of Corrections for sex offender programming.

16 A11 right. The sentence of the Court
1,7 has been imposed.
1B MR. GREEN : We 'd move f or bai l- pending
1,9 appeaf.
20 THE COURT : AI l- r i qht . You have no
21, right to it. At this stage I'm not sure you have
22 reasons. Why would I give you bail pending appeal?
23 MR. GREEN: I do, Your Honor. There
z4 are, as you know, substantial- legal- issues to be
25 assert.ed on. And there's one of which vou are not
1 COMMONWEALTH vs. WILLIAM H. COSBY, JR. 1'2L
2 aware that I would like to bring to your attention.

3 T have a and this has been provided
4 to Mr. St.eeIe last week. There was a news report. that
5 the tape recording of Mr. Cosby made by Mrs. Constand
o was inauthentic. And as a result of that news report.,
1 we've had the tape recording assessed by an expert. A
B preliminary expert review is available. f've provided

g a copy to counsel. I've marked the copy as D-Bail-1
10 and move its admission and ask you to consider it.
11 MR. STEELE: But f ask that the Court
I2 not consider it.
13 THE COURT: I'm not considering it.
14 This Court is qoing to Iose all jurisdiction. I have
15 sentenced this defendant. So T'm not sure what you're
I6 lrri noi no url with this Court.
T1 MR. STEELE: He's bringing up
1B THE COURT: And why at this stage you're

t9 hr i ncri ncr i I when this def endant has been sentenced to
20 t.hree to 10 years.
27 MR. GREEN: Because it's going to be the
22 subject of a Motion for a New Trial as well dsr if that
23 motion is denied, part of his appeal.
24 MR. STEELE: It I s PCRA.
25 THE COURT: We11, you' 11 file a motion,

1 COMMONWEALTH vs. WILLTAM H. COSBY, JR. 722
2 won ' t you? Yourre going to f il-e a motion, T am
3 assuming. And if you file a motion, then this CourL

4 will consider bail pending appeal. Or a Superior Court
5 wi11.
Right now at this stage that Itve
1 imposed sentence I don't understand just saying that
B you're going to you read something in a newspaper
v and that you're going to file some sort of a motion by
10 it. You'11 file the motion, and then it will be
11 appropriate. So I canrt take on newspaper accounts as

1,2 to what I do for bai1.
13 MR. GREEN: I didn't ask you to take a
I4 nFIÎqn:nar
_t/q_ye
aca\Allnf
vvsLLv,
qi r
15 THE COURT: You said you read in the

1"6 newspaper.
1,7 MR. GREEN: No, I said I read it in the
1B newspaper and so we hired experts, and we had an expert
L9 ^.'-
cvof l rr=f
uaLg a fLrlg
ha nri
vrrYf ni rra!
nrl l_ rna
Leyg urhi
wrlrurr nh r^rc
ws rrn]-
YvL
f rnm
!!vlLL Mr
fl!.
20 Steele.
21_ THE COURT: And you'Il make that part of
aa the mot.ion.
23 MR. STEELE: And the expert's about as
24 good as all the other experts they have gotten in the
25 case, so f don't know where we're going with th j-s.
1 COMMONWEALTH vs. WILLIAM H. COSBY, JR . I23
) THE COURT: Let it be part of Vour
3 motion. f don't know why I didn't hear a Motion for
4 Extraordinary Re11ef. Nobody prevented you from doing
5 that today. f don't know why you waited untif the end
o to do it. f've sentenced this defendant.
7 MR. GREEN: Because it requires a
B recoro
q THE COURT: It requires a record?
10 MR. GREEN: which would require a
11 postponement of sentence. And I pay att.ention to the

I2 ru1es. That.'s whv I didn't make it an oral motron.
13 THE COURT: f don't know if it required
74 a record or noL or what the position is, but at this
15 stage, look, I've imposed sentence. So simply the fact
I6 that you're going to file a post-sentence motion is not
I1 one of the discretionary aspects for bait.
1B I mean, look, this case has been 34
I9 months. This defendant, you know, again, f 'm not

20 permitted to treat him any differently than anybody
21, eIse. Hers been convict.ed of a very serious crime and
22 I've just sentenced him to three to 10 years in a state
23 correctionaf facilitv.
24 Now, so far that is not if thatrs
25 your reason, you know again, equal justice under the
1 COMMONWEALTH vs. WILLIAM H. COSBY, JR . I24
2 law j-s a reason. I just have to at this stage do

3 vor
_t "* harre anv other reasons?
4 MR. GREEN : Only hi s const itut ional
5 right to appeal and t.he issues of substantial- lega1
o question that you've already reviewed over that, ds you
7 sairl- trJ
34 mnnths.
B THE COURT: WeIl, do you have cases that
say simply that somebody has a constitutional right to
10 appeal when it comes to discretionary bail?
11 MR. GREEN: f dontt have to have a case
T2 that says that. there's an express right to a there's
13 an express constitutional right to appeaJ-.
14 THE COURT: Yes, there is. f agree a
15 hrrndred nFrr-ent. Does that come with a concurrent

76 rir-rh1_ l-n haill
r rYrr
I7 MR. GREEN: No.

1B THE COURT : Okay . We I l-, then, again,
I9 the fact that you have LL, I know that youfre going to
20 appeal. You've told us . And weII you should. But
21" I've just not seen its connect j-on to the discretion of
22 this Court on his riqht to bail. He has been sentenced
23 to a maximum sentence of 10 and a minimum sentence of
24 three years. I'm just not seeing it. I don't know
25 dn \/nrr harre anrrth'i no el se?

,Yvs
1 COMMONWEALTH vs. WTLLIAM H. COSBY, JR. I25
2 MR. GREEN: No. Thank Vou.
3 THE COURT: AII right. I have imposed
4 ^^h+
DErlLEllus. rf
nL fhis
LrrrJ sfacre
oLavg if
t! \/nrr
JUU r^ranl
warlL tO
Lr-J take
LclAc: it
IL ltn
ulJ rîifh
wrLrr
5 another court, you can. That is just insufficient.

0 The Courtts, again, reason for not
7 granting bail pending an appeal which f'm expect.ing is,
T h:rzon l l- <aan i | :nrl fr^rn l_hal- \/n
B ^na -v, f -- rr lrn
,...owr
I again in appfying the guidel-ines in this case, t.his

10 case was called for a sentence of three years. Again,
11 t.hat's a serious of f ense.
T2 I have put the reasons for the sentence
13 on the record. Those reasons also support this Court's
I4 discretionary aspects regarding baiI, you know, that
15 whether because of his public persona, whether that
I6 shines light on hirn such that he is not a risk to
I7 rF-nffcnd- r.ertainlv I the
u rr findincrs that Itve made
1B indicating that he was a risk.

1_9 And at this stage Irm just not going to
20 treat him differently than anybody else that comes
2I through this courtroom. I don't know why I would.

zz There are- nennlp
r,vl/!s fhef
urraL ar^
q!C :- -:-:I^
JII Jct-Lf > :row
I who believe that
23 fherr
Urrgy also
afov harre
rravE riohis
!aYrrLo fr-
LU -*^^^'r
A},yVAL, i^,,t
VUI this is a
24 statutory pronouncement that, again, the discret.ionary

ri ohf -irrst h: qntt_ heon
25 rDrOVen tO thiS COUrt.
I COMMONWEALTH vs. WILLIAM H. COSBY, JR . 126
2 If you wish to try to bring it back

3 before this Court. as an application before you file a
4 mnf ion- \/nr'r

I vu Can dO SO.
5 MR. GREEN: Would the Court rely on the

o statements made here on the record as its reasons for
1 rlanrri nn l^': i I ?
tJ THE COURT: Would I rely on it?

MR. GREEN: Yes. I have to ask for a
10 statement of reasons, and I'11 ask the court reporter

11 to prepare it. f'm trying to give you the courtesy of
t2 asking you if you'd Iike to say anything eIse.
13 THE COURT: Here's what I wifl do. I am
I4 going to retire and T'm going to Iook up and I will

15 come up with exactly what my reasons for denying bail-
16 at th i s st aoe are . And I ' l-1 hear both sides on it
I1 because t.his is an application to the Court. This is
1B an applicat.ion to the Court under the rules, and you
I9 may apply to the discretionary aspects of the Court.
20 So, again, if you're going to rely upon
21 what you said, I will take that as your application.
zz I ' II give Mr. SteeIe an opportunity t.hen to respond,
23 unl-ess you have something el-se.
24 MR. GREEN : No . I 'm -iust trvins to be
z3 rra\11 rr An 11 q
1 COMMONWEALTH vs . WILLIAM H. COSBY, JR . I27
2 THE COURT: Huh?
3 MR. GREEN: I'm just trying to be
4 courLeous and professional about this.
5 THE COURT: You have been nothinq but
o courteous and professionaf .
1 MR. GREEN: I wasn't able to tell t.hat

B that was your view.
THE COURT: f am simply at this stage
10 you know, you brought a moLion and I have to decide it.
11 And it's a Motion for Bail Pending AppeaI; correct?
I2 Anrl \/nrrr ra:
--*sons are, so that Mr. Steele can respond,
13 that you have filed an expert report with the District
I4 Attorney saying that there's something wrong with the
15 tape and that you do intend to make it part of a
I6 post-sentence motion. That's your reason.

r'7 MR. GREEN: No, sir.
1B THE COURT: And you intend to file an
19 - ^^ ^ -
crIrI/cor.
I
20 MR. GREEN: That's one of the reasons

2I about which you hadn't heard before today. The other
22 reasons you al-l heard about before today. They are the
23 issues being tendered on appeal. Like, for instance'
24 the 404 (b) ruIe. Regardless of its rightness or
25 rrn-r-i
ulr npss- if rs cerf ainlrr
crhfurrvrut worthv of review.
1 COMMONWEALTH VS. WILLIAM H. COSBY, JR. T2B
2 THE COURT: Help me understand that.

3 MR. GREEN: All of those reasons are
4 going to be raised on appeal.
5 THE COURT: Agreed. So I understand it,
but is there anv one particular in that this comes
up in every case where somebody is sentenced to more

x than two years, to a maximum, you know, two years. The
v fact that you say werre going to appeal, I understand
10 that. And I welcome it. And vou should. You should.
11 But I'm just not. sure where if that
I2 ':
f> ^ Ct^ €^ ^!
LdLLT I- -irrst rrueu
Juuu neecl cA
a UdDC
case that
LllctL savs
i--l -
the f act that
13 you're going to file an appeal somehow obviates this
I4 Court's or somehow mitigates or somehow vacates this
15 Court's discretion regarding bail pending appeal.
T6 MR. GREEN: The fact that there are
T1 meritorious issues should affect vour exercise of
1B discretion. That's all I was saying.
1,9 MR. STEELE: I would submit that that is
20 not a factor and there is not support for that in the
21, law.
22 Number two, in terms of this new Haif
23 Merrr- tn talk
, vv about a tane that is and I don't knOw
24 the exact. term that he used there on a collateral-

25 matter in this is not new to this case. And, you know,
.L COMMONWEALTH vs. WfLLIAM H. COSBY, JR . I29
2 it was something that, Lf you fook at the deposition,
3 was recognized by Mr. O'Connor dur j_ng the deposition as
4 not being a full transcript of the recording because it

5 was turned on af ter the recordinq start.ed.
o And for this to now have gone through
7 that proceeding, t.he f irst trial and t.he second tria1,
B and then all of a sudden this is some issue, weII, then
9 that I s oo'i no to be an inef f ect.i-ve claim on those
10 af1_nrnF\/q And i f fherrrre wi I I ino to waive alI their
11 appeals and go to a PCRA, weI1, that's the time period
I2 that this woul-d come up.
13 So for this to be inserted right now, I
14 srrcrcrest - i s more of i rr sl- the nOnSenSe and show that
""YYvgv,JqgL
15 werve had to deal with for too Ionq. And I'd submit to
I6 the Court that this and this issue on bail, they're
L7 asking you to treat him differently than others in this
1B circumstance. And that's not appropriate. And I t.hink
I9 the Court recoqnizes this.
20 And I ask: What state prisoner or
2I proven sexually violent. predator gets bail? The
22 defendant has gone through a process of due process.

23 And
nrlu fif r \/rlrr'l^^r.
yuu ruuN ^r
qL rL^
Lrrg -->rocess
F----.-- here, he was affowed out
24 on bail-, $100,000. Okay. Itrs 10 percent of a
25 mil-1ion. Then af ter his conviction, he was put on

2 house arrest.
J And now we've gone through a sentencing.
4 He's been sent.enced to state prison. He has been
5 nro\/en to he a sexrral I v rri ol ent nre6latOr. And i f vcrlt
_Y vu
look as this process goes through, your individual-

1 ri rrhts i_ n remain f ree on bail diminish as the ri crhf to
! r Y rr
B incarceration comes up. And as the Court noted when

Y \/1^1l'l were cfo'i ^^
YvuYvtIlYLII!vuYlrIliLy-yulI/vJU
1- hrn"al-' l-h'i s_ nrimarv nltr1.1nSF of LeVeI 5
10 offenders, a primary purpose is an incapacitation to

11 protect the public.
I2 And I would suoqest to the Court that no
13 amount of bail I mean, this is he should just be
I4 remanded. No amount of bail to a man thatrs

15 purportedly worth $400 mil-lion supports that he will be
15 here to serve a sentence and/or to do this.

I7 So no amount of bail- can assure a
1B sentence or protect the public. Again, I'd submit that

19 this is askinq for special- treatment for him in a
20 circumstance that I bel-ieve they're asking for him to

21, be able to stay home and enjoy the comfort.s of his home
zz ancl en-iov 1-hat weal-th.

J e ++
23 And that's just not the place where, you

24 knnw- s.nmet'rodrz whnrs lregn convicted of a state sentence
ZJ and or sentenced to a state sentence as wel- I as
Z found to be a sexually violent predator works in

3 materiafs of protection of the public.
4 I have a Memorandum of Law that we
5 prepared in anticipation of this that I'Il give to the

Court.
'l THE COURT: You have a memorandum?
B MR. STEELE: I do.
u THE COURT: WeIl-, I have to review it. .
10 The Court wilI recess for ten minutes to review the

11 Arcrlrments of r\clunsel - the Rul-es of Criminal
UvL, Procedure
LZ and the memorandum of the Commonwealth.
13
L4 (Recess. )
15
76 /\r Pror-eecl i ncrs were reconvened

!v with the
I1 Court, Mr. Steele, Mr. Ryan, Ms. Feden,

1B Ms. Piatkowski, Mr. Green, Ms. Redmond,
T9 Mr. Goldberger, and the defendant being
. \
20 nraqanf v r! e . /
27
22 THE COURT: A11 riqht . The Court. has to

23 make the decision based upon, dgain, t.he Court revoked
24 the defendant's bail. And cosnizant to Rule 52I(b) (3),
25 when the defendant is released on bail- when a
2 sentence imposed includes imprisonment of more than two

3 \lea rs - t he def endant shall not have the same ricrhi ! I Y r1 t n
4 baif as before verdict. BaiI may only be aflowed in

q t.he discretion of the judge. So there is no automatic
h' requirement under the 1aw.
7 Now, in t.hi s case I 've heard the
B arguments of counsel forwarded by the defense. The
v arcrrmenf was hc has l eoi-timate issues cln annea l and he
10 has a matter that he is going to incorporate in a
11 post-sentence motion that he will bring before this

L2 Court.
13 f am incorporating al-I of the record of
74 the sentencing. fn that record of the sentencing,
15 agi ain, my reasons for the sentence is the reasons t.hat
T6 T am rclrz'i no nn in denrzincr this
svrrf rrrY defendant bail. This
I1 is a serious crime for which he was convicted. This is
1B a sexuaf assault crime.
I9 I know the testimonv dealt with whether
20 he would be Iikely to recidivate or coufd be a danger
2I to the communitv. The nature of the crime and what
22 this Court has before me indicates that he coul-d quite
23 possibly be a danger to the community.
24 I recognize that we're relying upon his
25 ecre
uYv and T i nr-nrnnrated that i nto mv SentenCe aS well aS
2 his blindness, but, aqain, I harken back to all the

3 reasons that I made for his sentence and incorporate
4 them as to the reasons as to why he would be denied
5 baif pending appeal.
o I will revisit that if you fil-e a
1 post-sentence motion with t.his CourL because you may
have different reasons. And you would then be able to

q inr-6rnnrafe
rrruv!yvrqLs r^rha|_
wrrqL \z1^1tl -irro+ 1.'rnrrnht-
urvuYrrL r1 thiS COUfttS
Jvu JuoL
10 attention as a basis for this sentence.

11 So the Court has heard your arguments of
L2 counsel and, again, the defendant is remanded to comply
13 with the order of this Court.
I4 MR. GREEN: Your Honor, one other
15 maf
rrtuL fuu!pr t- mi nor ma1- l-cr I- r-rn
vL the reCOrd. I t Ve been aSked
I6 to hand in my copy of the PSI.

T7 THE COURT: I'm going to order that both
1B parties keep their PSI. There's going to be an appeal.
I9 You're not to release it to the public, but. both
20 parties can keep it. I do routinely when there's an
2I appeal.
22 MR. GREEN: Thank you.
)? MR. STEELE: Thank you.
24 ( At 2: 42 p . m. , proceedings were
25 concluded. )
1
I
1,3 4
3 qERTIFICATE
4
5 I hereby certify that the proceedings

o and evidence are contained fully and accurately in the
7 notes taken bv me in the above cause and that this is a
B correct transcript of the same
10
VIRGINIA M. WOMELSDORF, RPR
11 Official Court Reporter
72
13
I4
15
16
1,7
1B
)-Y
20
2I
22
ZJ
24
25
1990 [1] 17l18 s:27l1l 1113
1992 [1] 83/13
MR. GREEN: [98] 4/9 4l't2 4120 5114 A
1996 [3] 66/19 82i18 83/8
6t5 6t12 6116 6t21 7t4 10119 11/11
1997 [1] 10e/21 a.m [1] 1/13
13/13 13/18 14/816t11 16t17 19t5
19/13 19/19 2016 2019 20117 20124
1:00l1l 94122 abandoned [1] 1 16/8
1:30 [a] 94120 94123 96/3 100/19 ability [3] 31110 8115 91117
21t20 22t13 23t4 23t18 23t21 23t23
1:39 [1] 100122 able [9] 33117 7113 8016 9718 99117
24125 26113 29119 29121 35/3 35/13
1 17 I 14 127 t7 130t21 133t8
35t21 36t2 36/4 36/1 6 36t23 37 t4 37 tl 5
abnormality l20l 14113 14116 14121 15/2
37 121 4718 49125 5019 53/1 0 54/8 55/3
20l1l s1t22 15t415t7 15t7 15t11 15/15 15t2416t2
55/9 55/12 55t17 55t23 62t14 62t16
2000 [1] 17l19 58/25 60/3 60/1 4 60/1 I 61 t14 62/4 66t6
63t23 67124 68117 68121 711237713
2001 [1] 17l19 67t4 67/7
80/11 81/9 81120 83116 84118 85123
2004 [9] 30112 47119 66122 66125 82fi8 above [6] 31114 7519 93115 93122 108121
86t6 86t22 87t6 88t7 88/10 88/15 88/21
83/2 83/6 84114109123 13417
89/18 95/20 120117 120122121120
2005 [3] 82t19 83t8109t22 absence [1] 58/19
22t12 122t16 123t6 123t9 24t3124t1
2009 [1] 26/6 absolute [1] 69/5
24t16 124125 126t4 12618 26123127
20 l1l 2216 abuse [3] 4A2O 931410012
27 t61 27 I 1 6 1 27 / 1 I 1 2812 28115
2012 [3] 66t20 82t11 85t3 abused [1] 46/15
33/13 133/21 AC l1l 41t22
2014111 2216
MR. RYAN: I28l 5117 10/18 1 1122 11
201s l1l 53117 Academy l1l 2215
12116 1312 13/8 13/16 16/10 19i 15
19t23 21 t7 21 t1 4 23t7 3419 37 125 381 4
2018 [3] 1113 46125 65115 accept l4l 45110 56121 5713 6818
38/8 50/14 53/8 54t15 54t18 55t22

21 111 3t8 accepted [5] 26/8 26111 4016 40115
22nd [1] 66/19 93/1 8
58112 64125 7715 79123 95112
24111 3114 accommodations [1] 92/21
MR. STEELE:[13] 90/3 941249513
24th [1] 53t17 accordance l2l 78124 7918
95/10 95/15 121t10 121116 121123
25l2l 1/13 18t9 according [2] 30/16 56/20
122122 12811 I 1 31 17 1 33122
26 [1] 3/8 Accordingly [2] 65/16 119123
MS. FEDEN: l1l 1213
THE COURT: [1a7]
2:a2[l 133124 account [5] 63/21 103117 11511311712
122t14
THE DEFENDANT:[12] 69/13 69/18 accounts l1l 122111
69t22 70t5 70t9 70112 7214 72113 96122 17l8 74t17 99t10 accurate l1l 10417
96/25 98/15 100/16
30 [3]
303.12111 111/21 accurately [1] 134/6
THE WITNESS: [15] 6/2 101221214
30rh [1] 66/19 accusations l1l 44118
14t13 14t17 14t23 15t5 15t1215t19 accused l1l 42119
16t216t516t7 16t14 29t20 50t3
3125 [1j 107t10
34 [3] 96/17 12311812417 acquaintance [1] 30/1 1
$ 340 [1] 28/3 acquired [1] 66/6
3932-16 l1l 117 Acquittal [1] 97115
$100,000 Fl
129124
3rd [1] 10e/22 across [1] 109/3
$25,000 [1] 120/s act [8] 66/12 66120 67114671157115
$400 [1] 130/15 78t24 79t8 90t23
$400 million [1] 130/15 40 [1] 111/1e acting [3] 9/8 9/16 9/19
404141 85t18 89/22116124 127124 activities l1l 75125
42 l4l 2215 7313 1 1212 1 12ls acts [2] 6619 70123
'54 [1] 40/16
'90s [1] 18/20
actual[4] 14l16 35/13 3511437/3
actually [3] 93/17 93i 18 93/19
'97lll 18t20 50 percent l2l 27114 27116 actuarial [3] 39/10 39114 39124
'98 [1] 18/20
521 [1] 131124 add [1] 6/1e
53 [1] 3/8 addition l2l 231125918
s4 [1] 3/8 additional [5] 7518 76122 77 13 101122
10 [10] sl21 1614771169412197112 102t3
11 1t2 1201 4 121 t20 123122 124123
address l10l 20125 5817 7711277114
10 percent l1l 129124 60 [3] 49/2s 84t4 84t7 781578112 8214 82114 83110 97119
10-minute l1l 94123 addressing l1l 9714
11 [1j 5s/16 adherence [1] 105/12
11.201121 781257919 70 [6] 25t 12 2612 13 17 40112
391 391 adjacent [1] 33/9
1 19
[1] 3/21 56/1 3 adjustments l1l 32/23
12l2l 53125 120110
120 [1] e8/8
administering lll
107 12
12:17lll 100t21 81 [6] 25110 39111 48123 4913 56111

administration lll
118114
admission [7] 10/16 1115 19114 22114
13 [1] 19/2 56/1 5 23/7 23120121110
13th [2] 65/15 109/21
admit [2] 21119 45112
14 [6] 9/18 1912 38121 58117 60114
admitted [8] 1 9/1 7 22116 23122 28116
74t13 9-11-18 [1] 3/14 2919 29115 36115 1044
15 [3] 25114 4711556t25 s7l1l 84t23 adopred [1] 103/23
16l1l 1t7 9721 l1l 102117 adult [1] 30i 1 1
18 [3] 3/14 78/25 79te 9725 [1] 113t24 advancing l2l 50113 50117
18th [1] 2313 976212) 1121211215 advice [4] 42111 4412 44117 72111
152111 2215 9799 [1] 15/25 advise [1] 74110
193 [4] 7110 1214121s 2119 9799.5s [1] 7313 advised [2] 80/8 80/13
1954 [1] 40/6 99l2l 391't0 39t24
A 48t21 20111 20119 20120 41113 4219 42118
answered 121 451227014 4312 44113 44117 44125 4512 45t19
affect [1] 128117
anticipation [1] 131/5 54t18 58t2 64/15 68/18 70t19 71t19
affects [1] 66/7
Affidavit [5] 30/19 30121 4118 4319 43110
antisocial[1] 15/9 7216 8017 80t25 82113 89125 S2l3 94/2
anybody [6] 58/8 69/15 81/15 94/18 94t3 94/8 121t10 121t11 122t13 126/9
affinity [2] 45124 4616
123t20125/20 126t10129/20
afford [1] '10418
anyone 161 49121 49124 5016 50/20 56/1 asked [9] 515 32123 42116 42123 4515
aftermath [1] 1 18/20
87t17 4714 54/19 92124 133115
against 161 11121 12111 6919 89117
anything [18] 10/7 10/8 10/10 1315 14115 asking [15] 8l2o 8120 15118 20114 20122
104i10 105/8
15t24 21t20 24t16 55/12 67t23 67/25 3417 50t1288t1191/2 91/15 91/16
age [12] 2411626/12 39/13 39/16 39/17
69124 7 012 721 1 8 81 I 1 4 941 1 8 1 24125 126112 129/17 130/19 130/20
40t12 5212 5216 93t25111/19 114t13
126t12 asks [1] 94/7
132125
anywhere [1] 63/17 aspect [3] 61/8 90/5 91/8
age-related l1l 26112
apart [2] 33120 5312 aspects l4l 10917 123/17 125114126119
aged [1] 91/24
apologize l2l 34112 65115 assault 1231 3112 4'1122 42119 50121
agencies 121 7818 7811 5
appeal [35] 4413 9718 97125 98/15 98/25 s1 l1 4 51 t20 61 120 73111 93/1 6 1 06/1 3
agency [1] 75115
99/6 99/8 99/12 99/16 99120 99122 106t21 106t23 107 14 107t7 107 113
agentlll 7117 00/7 100/9 100114 120119 120122 1 07 I 17 1 1 0124 1 1512 1 17 122 1 1817
aggravated l'l1l 41121 73t11 92t24 93t3
21t23 12214 12415 124110 124113 118/10 118t20132t18
93/9 93/9 93h5 53121 93t22106t13
24120 1 2517 125123 127 11 1 1 27 /19 assaulted [6] 30/1 1 30117 41125 49125
106t21
27t23 128t4 128/9 128/13 128115 1 50t892t6
aging [2] 25fi225/23
33/5 133/18 133/21 assaults [2] 30118 1 1312
ago lll 1912
appeals [1] 129/1 1 assert [1] 61/10
agree [20] 8/11 11/181217 271212812
appear [6] 9/14 1415 1416 32/6 98/5 asserted l1l 120125
3114 33120 34124 38117 4015 40114 4918
49t14 52t16 52t21 53167716 10815
108114 assessed lll
12117
112t12124rt4
APPEARED ll 42 assessment [33] 18/6 19/22 2012 2015
appears l2l 5121 9/13 20t7 22t21 22125 2717 27124 34121 3513
agreed [4] 86/19 101114 106/15 128/5
appellate l2l 70125 96125 35/18 36/19 37117 3816 38/12 38/15
agreeing [1] 35/10
applicabilities l1l 64112 38t20 38t22 38t24 39t2 39t6 39n $h3
agreement lll 17123
applicable l7l 8115 8/19 98i6 111122 44t6 44t9 59t24 63118 9219 92111 92117
ahead [1] 118/19
112t3112t6112t14 109t9112t10
alcohol l4l 46110 46111 46114 69/21
application [8] 8212 83121 8511 4 85122 assessments l9l 17 122 1813 2013 34122
alienation l1l 118121
126t3 126t17 126/18't26t21 38119 57118 57118 65121 67/3
allegations I2l 41120 49/2
applications [1] 86/13 assigned I1l 11017
alleged l'll 49/24
applied I7l 65121 66/4 83/18 83120 83124 assist [2] 33/10 81/6
allocute [9] 68/14 69/5 69/8 69/9 69/1 1
106/15 112124 assistance l2l 24118 32124
69t17 70t9 88t24 89t13 Assistant l1l 216
applies l1l 9112
allocution [4] 55/6 68111 69117 80117
apply [12] 58/6 63/25 7714 77110 8518 assume [6] 41119 41120 50122 50125
allow [5] 15117 98115 98/25 100/9
87t8 89t25 103/13 108/18 109117 112121 6911294122
110/16
126t19 assumed [1] 8/6
allowed [5] 89/6 106/16 106117 129123
applying [1] 125/9 assuming l1l 12213
13214
appraise [1] 106/25 assumption [3] 51/2 5111251118
alone ['l] 118122
appreciate l2l 78120 78121 assurance [1] 105/13
along [1] 90/5
approach [3] 5/15 1916 11219 assure l3l 104124 1 1 6125 1301 17
already [4] 94121 S5/2311419124/6
approaching l2l 5119 56124 attached l2l 101 l1 4 101 121
alternative [1] 60/23
appropriate [1 71 39/9 64123 76114 81 16 attacked l1l 62112
afternatives 121 102121 1 03/1 4
103/10 10414 10517 109/16 11213 11216 attainment l1l 1715
am [26] 15113 20118 3815 6812470121
112t14112119 112125 11419 120114 attempts [1] 93/11
83/5 83/6 9611210314 103121 104117
122t11 129t18 attend [1] 31/10
106/1 6 106t17 108t7 11014 11016 11211
approximately [8] 17l8 17118 1819 2314 attention [6] 9/3 581248411012112
113124 114115 1 16i 13 116t25 122/2
27113 27113 27114 49/25 123/1 1 133/'t 0
126t13 12719 132113 132116
April [2] 46/24 66t19 attorney 161 214 27118 42111 4412 4415
ambulate l1l 32114 127t14
April 22nd [1] 66/19
ambulates 111 24118
aptly [1] 102119 attorney's [1] 1 17l19
amended l2l 82fi9 109121
argue [3] 36/1 1 55/21 89/1 1 attorneys l2l 216 1291 1 0
amendments [1] 85/6
argument [10] 55/8 58123 59117 6319 authenticity t1l 20121
American 111 2214
68t3 80t2281125 84111 104113 13219 authoritative l3l 22110 26111 35123
amount [3] 130/13 130114'130117
arguments [13] 55/16 6414 67/11 67118 authorities a1l 76114
analogizes l2l 5213 5216
67/1 9 80/1 8 91 112 10215 11217 1 17 119 automatic [1] 132/5
analogy 111 57115
131tl1 13218133111 automatically [1] 64/1 1
analysis 131 25123 5912311219 availabilities [1] 83/23
around [2] 63/17 68/1 1
and/or [3] 8'l119 10212 1 30/1 6
arousal l2l 816 52fi2 available [9] 39/9 7818 78115 83124 8414
Andrea l11l 1219 28fi2 30117 91121
arrest [7] 4718 5413 90/9 90/1 3 91/9 8416 91114 99/16 121/8
1 01/1 8 10617 106124 107 17 1 1818 12011
angels [1] 1 16/5

97t16130t2 average llj
31/14
article [1 1] 6/1 I 2212 2219 26/10 36114 avoided [1] 61/5
anguish [2] 1 18/13 118123
36/1 5 36/16 37 18 3711 1 37 111 37 112 aware [13] 28115 2919 29114 33125 3418
announced [1] 69/2 34t16 46t18 46120 4716 49117 10817
ascent [1] 1 16/10
another [6] 1 1/8 11/8 63/3 74/7 114111 115t16121t2
aside [1] 42i6
125t5
ask [38] 5123 6119 8111 14110 15118
answer [6] 20/10 29119 29125 4315
break [1] 2116 checklist [1] 81/16
brief [4] 17125 58115 64/3 80/19 child [2] 1814 5116
bad [1] 90/23
brietly [1] 81122 choose [1] 98/3
bail [35] 5414 98115 98125 991410015
bright [1] 117123 chooses [2] 68/15 89/13
100/9 100/13 120t18 120t22 121t9 1
122t12123t17 124t10 124t16 124t22
bring [7] 35/13 36/14 37128411012112 chose lll
47124
125t7 125t14 126t7 126t15 127t11
12612132111 circled [1] 119120
bringing [6] 3718 58/23 90/9 121116 circumstance [4] 1 15/9 1 16/15 129118
128t15 129t16129t21 129t24 130t7
121t17 121t19 130/20
130/1 3 13011 4 130117 131 /24 131 125
brings [2] 37111 92119 circumstances [3] 104/16 105111 11412
13214 13214 132/16 133/5
broad [4] 21 120 23115 23115 23117 cited [1] 3218
balance [1] 58/17
broken [11 52125 city l2l 7417 7417
band [1] 88/5
Barbaree l10l 25120 25121 25/2225125
brought [7] 35/1 1 36i9 36/13 36/14 civil[1] 118125
119/18 12711013319 claim [2] 59/10 129/9
26t3 26t10 39/19 39/21 39t22 49t6
built [1] 94/21 claimed [2] 46/19 107 122
base [4] 4315 51112105/20 1 15/10
burden [2] 62113 65118 classification [3] 16/4 571226212
based [31] 8/6 1218 19124 20/15 21/11
business l2l 7 5113 75116 classified [3] 10/14 5714 5715
21t13 2218 33/3 36/20 39121 4112 43119
49t8 51t12 51t18 67t8 67t14 80/4 90t11
clear [1 9] 5118 3117 55125 56117 58110
59t12 60/24 65/19 65/19 65t23 65t24
90/1 3 90/1 4 91 t1 1 92t16 93t24 94t7
calculate [1] 40/8 67 t12 69t4 88/1 3 1 07i6 107 /20 1 12/16
94t13 97t21 114t19 117/11 120t2131
called [6] 917 2116 34116 47/6 79/2 11711811916
basically l2l 25124 39115
125110 clearly 171 9112 5814 60122 82116 8317
basis [2] 10/9 133/10
beautiful [1] 1 19/3
calling [6] 4116 4117 4118 20115 20119 86/18 100/17
21t12 Clerk [1] 95/5
become l2l 48124 7619
calls [2] 111114 1 1 1/16 client [1] 68/14
becomes l2l 251122612
camp [2] 87124111118 clinical 121 4012 40/7
begin [2] 18/8 106/3
can't [13] 39/13 48/5 49116 50122 57/14 close [1] 59/20
beginning 161 13/2213123 73119 74119 7 1 t25 72/ 1 2 7 2t 1 I 72120 95i4 95/1 0 closed [1] 55/20
84t7 10117 107t5122t11 closing 161 67117 67119 68/16 80/18
behalf [3] 44/6 1021210419
cane [2] 24118 32115 80122 81125
behavior [10] 8/7 1111912111 14131417
cannot l4l 63121 69/9 89/14 104110 code [4] 8317 102117 111121 112111
40/1 1 60/1 5 62t3 1 1 1 t12 1't7 t24
capacity l3l 2712 61120 66n cognizant l3l 70122116124 131124
behavioral[1] 61/21 care [1] 21110 collaterallll 128124
behind [1] 118/6
carefully [1] 89/4 colloquied [1] 91/6
being [18] 416 8115 8119 2116 23111
30/10 35/5 50t18 52t7 65t10 69t2 71t3
cany [1] 76/15 colfoquyl8l 64117 64/22701570120
case [69] 13/1 1 15/6 2018 23117 2817 79125 80117 80125 8113
85/19 101/3 1 09/14 127123 12914 131 l1 28t10 28t13 31t2 34t24 38t12 40t3 41/5
believe [1 4] s/1 9 7124 18125 19113 2315
combine [1] 56/16
5s120 57112 59/19 61/14 6112261123 comes [6] 60/13 11519 124110 125120
28fi82918 40120 4618 46121 47114
64/9 68/10 68124 6912 69/3 69/6 69/18 128/6 130/8
84117 125122130120
73t10 77t10 79t14 86t24 88t18 89t2 comforts [1] 130/21
believer l1l 95124
8919 9017 90110 91121 92116 9312 9313 coming [1] 2815
believes 121 81115 8912
93t 4 9311 4 931 1 5 93117 93121 9518 commenced [1] 4/3
belts ['l] 95/24
96/17 96/18 98/19 98/20 99/16 100/4 commencement [3] 98i13 9812410018
bench [2] 6113 23124
10312 1 0317 10317 109120 109124 1 1211 Commencing [1] 1/13
benchmark [1j 1 10/12
1 13/10 11514 11515 11812 122125 12311 commensurate [1] 1 1 1/1 1
benefit [3] 83/25 911292fi2
124111 12519 125110128/7 128112 commenl [2] 105/18 105/25
benefits [1] 83/23 128/25132t7 comments [1] 67119
beset [1] 1 16/7
cases [9] 18113 181'14 21114 51111 57/17 commission [4] 66i9 83/11 103/23
best [3] 20110 841292121 70t24 86t22 9317 12418 110t22
bestiality [2] 40123 44122
better [3] 6118 4019 5714
cataloged l1l 40117 Commissioner 12015 lll
catching 111 78120 commit l2l 91117 114111
between [5] 66/19 68120 82118 8318
calegory [3] 23115 23117 52125 commitment 121 114117 114122
109i3
celebrity l1l 108124 committed [4j 83/8 8512 109118 117121
beyond l3l 60124 91/19 106/20
certain 161 9211 4 96110 10217 102115 committing I2l 77 125 1 13/2
bigl2l 92t1595t24 107t3113t12 common l2l 112 45122
Btlll2l 791279110
Bills [1] 120/1 1
cerrainly l5l 2012 61125 62113125117 CoMMoNWEALTH [26] 116217 55119
127125 56/7 56/10 64114 65118 67/11 6813
bitl2l 591229612 certainty [2] 32122 1 1 619 70t19 70t23 7 1 t7 81 t24 82t9 84t 17
Blanchard [9] 25/20 25121 25122 25125
certify [3] 80/8 80/11 13415 86117 88125 89115 89124 10213 102114
26t3 26/10 39119 39122 4916
chance [1] 40/9 104t12 1 09/1 3 1 10112 1 1614 131 112
blind [8] 31124 32125 4913 49122 5618 CoMMoNWEALTH'S [3] 3/3 57t9 57/9
change l5l 7 4/1 4 7517 7518 75/12 7511 4
87/11 87t13 87118
changed l2l 8212282123 community l7l 46123103/19 104122
blindness l9l 24114 24115 24117 32/8 1 13t17 118t8 132t21 13?,23
changes l2l 83119 9112
33/5 33/6 53/19 1 14t14 133t2
chapter [4] 11/8 731378125 84123 compared l1l 52122
blood [2] 5214 5217
character I3l 1 1 414 1 15122 1 1 6/1 6 compelled [1] 104/18
board [2] 20/17 63118 characteristics [3] 61/21 104116 1 05/16 compile l1l 27121
boot[1] 111/18 characterized l1l 6214 compiling [1] 39/8
both [10] 15117 7011570121 84111
charge l1l 114120 Complaint [1] 1 19/18
1 01 I 17 1041 13 1091 4 1 2611 6 1 331 17
1 33/1 9
charged [3] 19/23 86/18 86/20 complete l2l 77115 8017
charges 131 47119 47120118124 completed [1] 81/10
box [3] 5813 58147614
c constitutional 131 12414 12419 124113 63/6 63/10 6412 64122 64/23 65t8 65t12
constitutionality [1] 65/13 6716 68/17 6919 70118 70121 80t7 80t10
compliance [1] 60/6
constraints [1] 102/16 80/23 86/1 5 88/14 88114 88/25 90/1 1
compliant l1l 5414
construct [3] 59i2 59/16 60/4 90/15 91/3 91111 91114 93i14 93/19
comply 131 7 4124 77 123 1 33112
component [3] 35/9 64118 64119
conslructed Ul 8715 94t2 94t3 94t8 94t13 94/20 94t24 95t7
construing [1] 83/18 95/15 96/1 1 96121 9715 9715 97t7 97t9
comprehensible [1] 31/7
consult l1l 14117 97t19 98t298t15 99t2 99/2 99/6 99/9
compress [1] 89/19
consultation l2l 6117 15115 100/3 100/7 100/8 100/10 100/14 100/1
compulsive [1] 46/1 1
consumed [1] 1 16/9 100125 101/6 101/6 102/10 102t13
concedes [1] 57110
consumption [1] 1 18/23 1 021 19 1 0316 1 0317 1 03/8 103t22 1
concept [1] 106/14
contact l4l 41111 4518 61118 120113 105/5 105/6 105120 108/5 109/8 109/13
concerned [1] 105/14
contain [1] 99/12 109t24 110t2110/1 1 1 12t2 112/17
concerning l2l 73124 73125
contained l5l 7110 3512109/9 113120 1 12124 114/5 11418 11514 1 15/16 1 1 6/3
conclude [3] 56/17 701511516
134t6 117 t6 117/17 11 8/18 1 19t14 119t19
concluded l2l 10412 133/25
contention [4] 58/9 81122 86/2 89124 1 1 9t22 1 19/25 1 20t2 120t 1 6 1 21 / 1 1
conclusion l4l 4817 5514 58120 59124
contentions [1] 81/23 121t',14 121t16122t3 122t4 124t221
conclusions l3l 24122 3515 48120
contents [1] 101/13 125t25 126t3 126t5 126t10 126t17
concurrent l2l 70/17 124115
contesled [3] 56/6 56/10 56/13 126118 126119 129116 129/19 130/8
condition l12l 24117 5612 56118 57113
context 171 111181217 59/25 60/8 60/14 130t12 131/6 131/1 0 131t17 131 t22
57t13 60t5 60/9 60/20 66t6 114/4
60t17 62/11 1 31 123 1 321 1 2 1 32122 13317 1 331 1 1
115t22 1 16/16
continue [1] 11/3 133/13 134/11
conditions l1l 5414
continues [1] 105/23 Gourt's l9l 58124 6419 103141061312516
conduct l8l 22120 38111 62125 TShg
contrary l2l 2711937120 125113 128114 128/15 133/9
86/12 86/18 106125 11713
control [1] 106/25 courteous l3l 126125 127 14 127 16
conducted l2l 34121 3912
conversation l2l 41110 8014 courtesy [1] 126/1 1
conducting [1] 22125
convicted l23l 25110 41121 42110 4914 Courthouse [1] 1/16
conference [1] 96/5
50t21 66t21 66t24 73t273t10 78t13 courtroom l3l 1 112 89125 125121
confidant [1] 93/4
8211 8 86/20 90/20 1 06/6 106112 107 I 4 courts [7] 17113 17116 17120 17125 1811
conf ident [1] 1 1 8/1 I 109t17 110t7 1 10t25 1 13t2 123t21 70t2595t5
confined l1l 47/7
confinement [18] 103/3 103/5103/6
130t24132t17 l2l 2112't 66/20
conviction 46124 5413 6418 65124
[11] credible [2] 9/16 9/19
103/15 10413 10413 104125 1 1 1/15
82112 84122 86/5 86/1 1 93/1 6 1 1 1/5 1261 78124 7912 7918 791 10 7911 1
1 1 1 t1 6 1 1 1 t25 1 121 4 1',t2118 1 1316
129t25 105t20 105/21 106t7 107 t4 108t4 1 10t1
1 13125 1 1 416 1 1 418 1 151 17 1 1 611 4
convictions l'll 47120 1 1 4t3 1 1 4t3 11 4t10 1 14t1 1 1 14/24 1 1
confirm [3] 3213 32110 32116
convinced [1] 106/20 11517 116/1 5 1 16120 116123 1 19113
confusion lll 118121
convincing [9] 55/25 56/18 58/1 1 59112 1 23t21 132t17 132t18 132t21
congenital [1] 66/6
connected [1] 33/10
60/25 65/19 65t20 65123 67112 rl
105t22
copy [6] 6/1 3 1 9/1 1 23/24 12119 12119 crimes [2] 8317 106/22
connection l2l 17/10 124121
1 33/1 6 inal [11] 114 23117 2715 33/23 5017
conscious [5] 43/23 43125 44116 48116
correcting l1l 78121 62t24 66t9 97t10 111 t11 119/1 8 1 31/1 1
48t18
correctional l11l 3412 73119 7513 87123 inally [1] 105/9
consensual l1l 11121
114t16114t21 115/19 116117 12014 :riteria [23] 7 11 4 7 118 814 8/12 8113 8121
consent [7] 106/8 107115 107119 107121
120t7 123t23 9t3 9t7 9t2210t17 1114111611117
107122 10712210812
Corrections l2l 12016 120115 12n5 1225 fi/23 35t7 35/23 36/6 3713
consenting [10] 7/15 9/9 10/15 1 1/5
correctly l1l 4415 56124 57110 57/25
1211213124 52/19 56122 5716 6215
corroboration l2l 32125 3316 :ross [12] 314 317 10120 10122 26116
consider 1291 51123 61/12 6314 63111
cosBY l21l 118 8121 22123 2313 24t12 26117 36112 36i13 37115 37124 5617
63112 6413 88/6 88/10 89/3 90/'18 90/19
40t10 57t3 68t2371111 7111571121 67t10
92123 9413 991't3 102120 102122103122
7216 72110 77 110 9618 1 06/5 1 1 6/1 3 cross-examination [8] 10120 26fi6 26/17
104115 104/18 104/20 106117 10818
1 17 /8 1 19t3 1 19t19 121 15 36t 1 2 37 | 1 5 37 /24 5617 67 I 1 0
109/15 112117 112120 116122121/10
Cosby's l1l 1416 cross-examine [1] 36/13
121t12122t4
costs [5] 95/13 95/14 98/5 99i18 120i9 crushed l1l 11914
consideration [6] 67i 10 86/15 105/10
counsel 1261 212 5/19 617 12125 35116 crystallized [1] 85/14
105t24 105t25 110/20
36118 62121 63123 67/11 6913 6917 culminated l1l 107112
considerations l7l 9417 9419 10219
74t11 74t20 76t7 80t22 85/7 85t12 culpability [1] 105/17
102t15 105t4 1 12/21 1 13t4
85124 90117 92119 102/5102fi9121/9 culpable [1] 105/9
considered [1 1] 88/25 92/15 93/5 93i6
131t11 132t8133t12 current [10] 64/10 65114 67115 70116
93/20 101/9 105/15 106/11 106/19 73t23 73t24 7 3/25 82/ 1 0 841 1 2 1 1 219
Count [3] 106/16 120111 120111
116121
Count 1 [1] 106/16 currently [2] 64113 108/16
considering l2l 90121 121113
Count 3 [1] 120/1 1 Curriculum [3] 3/17 19/3 19/1 1
consistent [5] 1 03/1 5 10512'110121
counter l2l 4318 44124 custody [6] 49/9 49111 49115 49118
113/6 113/13
counts I3l 41121 106/13 106/16 49/2161t3
Constand l11l 1219 30h7 51121 9419
county l17l 1 13 1 116 73/18 7512 82119
1 01/1 9 107t8 117 /22 11813 1 1818 12011 D
82t24 84/3 84113 87122 92122 103/8
121t5 D-3 [2] 6t2019t14
104/3 1 11125 11214 11218 112/13 112/1
Constand's [3] 28113 106/7 106124 D-Bail-1 [1] 121l9
course l7l 1417 59122 6016 6011 4 6917
Constands [1] 1 19/1 1 D-SVP-1 [5] 3/14 61222316 23120 2412
72t21 116110
constant [1] 11617 D-SVP-2 [6] 6/19 6121 714 2212 22fi5
court [132] 112 1116 3121 413 6/6 2815
constitute lll 83121
51 t1 1 5517 57 /7 58118 58125 6012 62t6 22t17
constitutes [1] 100/2
D Dengler l2l 34124 38118 10/15 1 1t4 11 t9 13t24 14t21 14t23 15t5
denied 151 41111 45117 46111 121123 15/8 15/9 31t20 44t21 52t19 53t3 53t4
D-SVP-3 l4l 619 1914 19111 19/18
133t4 57 t6 62t5 67 /4 67 t7 111 t23
daily [1] 32123
denying 131 12617 126115132116 disorders [1 2] 3/16 7 13 7 119 7 122 8124
danger l2l 1 32120 1 32123
Department l5l 5412 8216 82121 12016 11t7 14t4 22t4 37t13 40t23 45t4 56t22
date [4] 67114 75113 77117 99110
dated [2] 3114 53117
120/15 ]
disproportionately [1 108122
departments I1l 1812 disregard [1] 106/10
dating [1] 40/5
departure [1] 60/12 distinguish [1] 38/19
days [10] 74113 1 74117 75113 75116 77/1
deposition [1 1] 28/10 28113 28116 29110 District l3l 214 216127113
841 4 84t7 97 I 1 2 9818 991 1 0
deal [2] 3413 1129115
29t15 29t18 29t25 89t8 107t19 129t2 DlvlsloN lll1t4
12913 doctor [12] 515 719 9114 10113 11117
dealing [1] 61/13
depositions l2l 1 1 8125 1 1912 21t25 22t20 26t19 36t13 53t15 53t24
dealt [1] 132/19 1
depreciate l2l 114124 1 16/19 54122
December [2] 66/19 85/3
December 2012 [1] 85/3
Deputy [1] 120/5 doctrine l2l 102111 117111
December 30th [1] 66i19
described [3] 12123 4515 7519 document [6] 5/20 5/25 12/2 1314 1315
describing [1] 5/13 13/16
decide [2] 85/16127110
description [2] 3113 1 '18/10 documents l1l 10213
decided [1 42111
designated l4l 6711370115115/18 1 doing [7] 35/16 40/9 51121 63119 70121
decides [1 64122
designates [1] 64/11 1101412314
decision l20l 43124 43125 44113 44116
designation 141 6415 70118 80116 87125 done [14] 1819 18114 25122 2717 27112
45t9 45t11 48/16 48/18 55i12 55/16
designations [1] 65/21 55/20 72t7 92t4 92111 93/13 9419 94/12
62124 6415 69/6 69/8 6912270127019
designed l3l 22121 341234117 95t15107/14
98/8 98/9 131123
destination l1l 7612 door [2] 33111 6418
decisions [1] 69/2 doubt [3] 51 125 106120 118121
detail [1] 48/1 1
declare [1] 64/10
determination [3] 84/3 102125 10415 Dr lzal 4111 4113 16/18 1912't 2415
declines l1l 25111 28t2 3617 37121 43113 58/2 59i5 59i
determine [1] 33/6 11
defeat [1] 35/9 61116 62/22 6719 67110 67121 6812
determined 161 67 12 6716 7316 10518
defendant [91] 2/10 416101141114 80120 91112 92117 101124 114112
106/6 110/23
12t10 19t20 23t16 28115 2912 2915 2919
determining [4] 73112 102118 109/'16 Dr. [1] 56/12
29t1 4 30110 30115 30117 31 14 31 123
Dr. Foley [1] 56/12
117/15
32/14 32fi9 33/4 33/1 8 33/23 35/6
deterrents [2] 1 10/18 1 13/8 draw l1l 24122
41t10 41125 45117 4616 46110 46118
devastating [2] 1 19/10 1 19/1 1 drink [1] 46/19
50t9 52t9 52t11 5612 56/8 56/11 58120
development l1l 18117 drug [5] 50121 5114 51114 5111914713
59/18 59/23 60/13 60/18 61119 62/2
diagnoseable l2l 57112 6015 drug{acilitated 141 50121 51 14 51 I 1 4
62/13 63t17 65/1 0 66/25 67113 68121
diagnosed [1] 60/19 51/19
80/8 83/20 8sl2s 83125 88/4 88/18
diagnosis [5] 8/3 16/4 52118 52123 56121 drugged l2l 9215118112
90120 9413 93112 93117 93121 100112
diagnostic [16] 7/13 7118 8112 8113 917 drugs [5] 46110 46111 46/13 46119 69121
01 t3 10216 1 021 1 4 102123 1031 1 1
9t2210t17 11t6 12114 12125 13123 DSM [32] 31157127113 9123 11/9 11110
03120 10418 104123 105/1 1 1 13/19
35122 35125 56124 57122 6017 11t17 13t2414117 15/1615121 1617
13121 1141411416 114/11 114116
dichotomy [1] 83/5 16t8 22t3 22113 35113 35114 36114 3713
14125 11519 115122 116117 1 18/13
die [1] 87/14 37/9 37t12 52t22 52t22 52122 5312 5317
19t5121t15 121119 12316 12s119
different l12l 27 122 2813 37 11 I 5213 52/6 56120 57125 57125 5913 59/6 60/6
29t22 131 | 19 131 /25 13213 132116 DSM-4-TR [1] 11/9
59122 6315 74/13 82115 106/21 1 19/15
33112 DSM-s [16] 3/15 7127113912311/10
133/8
defendant's l27l 316 31127137111 1914
differently l5l 108122 1 15124 123120 13/2416t7 22t3 22113 3713 37112 52122
19118 22117 2412 28110 3913 40117 4112
125t20129t17 53t2 53t7 56t20 57t25
44123 53119 55/5 61/8 62123 68111
difficulties 131 3317 3318 46124 DSM-IV-TR l3l 52122 52t22 57t25
93/16 101/20 104115 105/16 114113 Dudley [13] 4/11 4113 4124 2812 3617
diminish [1] 130/7
114114 1 15/1 1 1 1719 131124
dire [2] 16123 5119 37121 5812 59/5 59/11 61/16 621226719
defense [15] 20/16 27118 5819 58121 67t10
direct [5] 314 317 21123 35116 65123
5919 59117 6114 67122 90117 91113
directed [1] 66/12 Dudley's l3l 27124 35/9 43/13
921 1 9 93124 1 0212 1 041 1 2 13218
directly l4l 64121 91121 991811613 due [6] 14121 1513 6713 1osl25 11412
defense's [2] 60/12 90/8
deficits [1] 31/9
disabilities lll
24112 129t22
disadvantage [1] 83/20 duly [3] 412516121 71112
define [2] 35/19 86/7 dunk [2] 88/19 89/21
disagree [1] 59/4
defined l5l 65122 66/12 85/5 86/18
disclose l1l 11012 duplicative [2] 8712 8713
111124
discounted l2l 113/12 1 1511 4 during [1 2! 24115 43116 5119 72121
definition [23] 5/6 5112 14112 14116 81125 96121 96121 97122 99123 101122
discovery 111 2814
14t20 15t2 15t14 15123 16/2 2119 23/13
discretion [1 1] 98/14 98125 10012 10019 114t7 129t3
27110 5717 57114 6013 60/4 61/13 66/5
1 02t 12 1 02t1 6 1 0619 1 24121 1 281 1 5 duty [1] 102113
82t11 84t21 84121 84125 85111 dwellings l1l 75124
12811813215
definitionaf l2l 519 618
discretional[1] 99/2
definitions l4l 15123 201226613 6719 E
discretionary [6] 109/7 123117 124110
fegree [7] 32121 6619 77125 7812 83122
1 13/13 119112
125t14125t24 126119 earlier [5] 32fi9 43119 591278118 95112
discuses l1l 5212 earned l2l 94/16 94116
Delaware [1] 18/11
discuss [3] 42/12441374111 leatlll 75124
l4l 87t10 98113 98123 100t7 discussion [5] 6/1 1 5516 62120 68/20 leducational [1] 1715
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l25j 517 5112 7 11 4 7 125 814 81221 109t23
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examined l4l 412516121 2311671112 fame [1] 108124
effective [3] 65/14 8414 8418
effectively I2l 114117 114121
example lll
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except [1] 1 15/1 1 familiarity l1l 33122
effort [1] 35/15
exclude [2] 82110 86121 family [8] 94/10 118/9 11812211917
either [4] 4'l15 63112 64117 9715
excluded [1] 85/10 119/9 1 19/10 1 19113 120113
elaborated [1] 80i6
excfudes l1l 84122 tar l3l 21116 62/19123124
elect [1] 99/7
exclusion l2l 84120 8518 farther l1l 4317
elected l1l 112124
exclusions l2l 84113 85/2 fashion 111 9216
element [1] 105/23
exclusive [1] 91/18 fashioning [2] 108/18 117117
elicit [1] 41l13
Excuse [3] 10/5 50117 88122 FEDEN [5] 2t5 4t4 65t8 100/25 131t17
eligibility [1] 90/13
1
eligible l8l 8217 8211 84121 84122 8512 l2l 16t16 s5t2 federal [5] 17120 171231712518110
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85t25 111t18 120t8
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ELfZABETH l1l 2t9
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else [13] 15124 15125 2112O 44124 55112
2412 felonies [1] 109/17
69124 81 11 4 941 18 123121 124/25 1
exhibited [1] 91/20 felony [3] 77125 77125109125
126t12126t23
exhibiting [1] 5715 felt [1] 3716
embark [1] 109/1 1
exhibits [1] 6/18 female [1] 30/11
emotional [3] 66/7 69/21 93/11
exist [1] 84/14 fetishism l2l 40124 44122
employed [1] 76/15
expand I1l 83122 tew [1] 26121
employing l1l 10712
expecting l1l 12517 field [a] 2219 2416 2618 40115
employment [3] 7 3125 7 41 1 2 7 41 13
experience I7l 17112 18112 21113 2218 fight [1] 8/9
enable [1] 65/23
51t2't 87t17 119t9 file [16] 97111981498/7 98/99917 99118
enacted [1] 1 12l10
expert [16] 19121 20fi3 21119 23110 121125 122t2 12213 12219 122110 12311
ended [1] 117123
26125 33t3 33t17 3717 5719 6A17 6114 126t3 127/18 128/13 133/6
endured [1] 93/20
6116 12117 12118'122/18 127113 filed [6] 84117 96118 96120 99112 118125
enforcement [3] 75115 7818 78115
expert's l1l 122123 127t13
engage [3] 67/5 70115 75125
expertise [5j 33/3 33/15 33/1 I 33121 filing [3] 98112 98122 10016
engaged [3] 12111 4416 4516
51/10 final [5] 54115 68112 68/16 69/5 114123
engaging l1l 6212
experts l3l 57 120 1 221 1 8 1 22124 finally [3] 88116 103110 11217
enjoy [2] 130121 130122
explain [3] 2519 8114102115 financially I2l 9814 99117
enrollment l1l 7412
explained l2l 95121 100/1 6 finder [3] 56/17 58/10 107120
entailed [1] 1 8/8
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entered l1l 101122
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entire [2] 35/17 36/19
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expressed l2l I 22122 93118 finds [1] 1 12l3
equal [3] 108/19 115123123125
extensively [1]rI 89/12 fine [2] 36117 12019
equate l1j 94/2 pl
extraordinarily 2518 25/15 39/18 finish [2] 51/16 88/16
error [2] 89/3 105/20
89t23 finished [1] 2113
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ESQUIRE [7] 2t4 215 215 216 218 219 219 121 119t10123/4 fir [4] 39/10 58i4 59/3 59/6
extremely l2l 25124 2814 titslll 57122
essentiaf lyl2l 52125 99114 five [5] 919 9115 27122 56123 110122
establish l2l 7518 75120
flare [1] 63/20
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establishes [1] 1 10/14
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facilitate [3] 30/18 66/15 1 10/20 110/15
establishing [1] 75116
facilitated 141 50121 5114 51114 51119 focused I4l 58122 59117 84120 117/23
evaluate [2] 6117 122119
facility [9] 7513 87123 92122 92122111/11 FOLEY [19] 3/8 31143117 61226124
evaluating 111 27110
1 1 1 t17 1 1 1 t25 1 121 4 123123 16118 16120 17/2191319121 2415 56112
evaluation [5] 23118 35/9 43/3 43/16
fact [28] 26111 32fi0 32114 38118 4913 67t21 681280120 92117 101124 114112
115112
54t6 56t4 56/5 56/9 56112 56/17 58110 Foley's l1l 91112
evaluations l4l 1814 18110 5116 51121
s8124 62112 63122 65124 88123 88/24 foflow [5] 53/1'f 65/17 82125 9Ol5 11315
event [2] 12121 112113
90/1 3 90/1 9 107 120 1 15123 123115 following t71 412 73122 751 1 0 75122
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1 241 1 9 1 2819 1 281 1 2 1 281 1 2 1 281 1 6 80123102120111114
87117
facto [1] 83/21 follows l5l 2/2 5121612271113 10614
everybody l2l 64/8 6817 factor [5] 39/16 93/5 93/6 1 14i15 128120 Footnote l1l 2614
everything [3] 96/17 99114113120 force [2] 106/1 1 109/6
factors l17l 34125 36110 38120 38121
evidence I29l 313 3/6 13/1 1 19119 22118
58111 58117 58/18 58/19 58125 60114 forced [1] 69/15
24t3 36t15 36/20 37118 55/5 55/25
61 115 7817 78/14 92^2 115112 116120 foremost [3] 58i16 7411010817
56/18 58/9 58/1 1 59/9 60122 60124 6414
1 19/16 forensic l12l 17113 1711519121 2116
65/2285t19 88/12 88/15 8917 106111 facts [7] 4219 56116 65125 8717 8719 21t1221119 2311223114 33/3 33/16
107 116 1 15/5 1 1 5/10 1 17 15'13416 't06/10 106/19 33t2157t17
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factual [3] 53/20 81 123 91 110 forget [2] 9212 9213
ex [1] 83/21
tail l3j 7 4124 7 5120 77 123 formed l1l 1218
exact [2] 6118128124 failure [1] 69/10 forms [1] 45/19
exactly l4l 5917 6111410117 126/15 fair [4] 10/1 1 10112 2914 105110 forth [12] 35/23 56/5 5619 56112 5718
examination [20] 5/3 10120 1111512119 fairly 92/9 10319 1091121 10/10 11218 11318
1 6123 21 123 261 1 6 26117 3213 321 10
[1] 86/1 1
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32t16 36fi2 37115 37124 53/13 54111 forthwith l1l 12017
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54115 5617 67110101124
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forums lll
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83/2 83/3 83/6 83/12 83/19 85/23 86/13 home [3] 4717 130121 130121
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93/15 101/14 103122 104118 108120 homeless [1] 7619
118124
108125 109/10 109112 109/16 109117 homes l1l 9213
foruarded [1] 132/8
109/19 109123 110/5 110/6 110/10 Honor [23] 4110 5116 5119 716 19/7 1
found [9] 25114 25124 2719 78125 79/9
1 10i13 110122 1 1 1/3 1 11113 112122 2315 2512 261 15 29/22 50/1 0 53/1 0
931 1 4 106/23 107 123 131 12
1 13/8 1 14110 114120 116/18 12519 58113 79124 87/16 89125 9014 92/16
four [11] 8114 8123 10117 1117 1414
guiding [1] 109/6 92122 93123 94t10 120t23 133114
58t24 61t17 88t2117t20 119t17 119t17
guilt [4] 102125 106/5 1 17115 118123 HONORABLE [1] 1/19
fourth [1] 62120
guilty [3] 7816 78118 106112 hope [1] 92/23
free [2] 1091813017
guys [1] 8711 1 hours [1] 2314
frequent l1l 75125
house [10] 33/8 33/9 33110 4717 4717
friends lll
118/22
54t3 90/8 90t13 91t9 130t2
front [1] 36/20
habitats l1l 75123 however 161 74119 8312 9719 106117
frotteurism [2] 40124 44122
Hail[1] 128t22 106/19 114t14
Fuect [1] 93/14
hand [2] 106/8 133/16 hundred I1l 124115
fulfillment [1] 1 10/17
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full [7] 9/5 918 9122 56120 56123 105/10
hands [1] 1 17l9
129t4
hang [1] 95/25 l'd [15] 5122 6t18 912 16118 2316 5817
fully [3] 8118 9912134t6
happen [1] 10/1 1 64n5 726 7916 81121 8214 89125 90115
nction [3] 25112 5212 5216
further [15] 5/3 11115 12119 21117 4316
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happens [1] 94/15 rx 1241201 1 1 20120
21 12 21 13 23115
45t3 45t10 45t11 46116 47124 67123
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91 t18 102t25 1 1 1 13 1 19125
harassment l1l 4U20 63124 6811876/7 88121 9014 91110
future [4] 10111241232517 113110
harken 121 11317 13312 93/2395117 95/18 126/10 126/16 1
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having [5] 4124 16120 70115 71111 8713 I'm [67] 41108188111 1012315117 15118
gauging l1l 40112 he'll[1] 20125 17t4 17t11 19/10 20t18 20t19 20t19
l1l 107t25 he's [26] 5120 13117 2012 21110 21/18 20122 2112 2114 21118 25124 28120
l5l 23fi2 34t22 83t 17 1 03/1 3
23t1125fi0 25110 35/10 3512435125 29113 31121 3214 3417 34119 3519 3812
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generally l4l 2618 26111 4016 40115
63/4 80/1 3 91 /2 94116 94116 121/17 52/5 5313 55/1 5 61/9 6312 65115 70/19
generous l1l 8812
123121 13014 71/16 71118 72t18 72123 75125 8314
genitals [1] 106/8
head [1] 1 18/1 1 86/16 88/1 1 89/16 95124 98120 113125
gets [1] 129/21
heads [1] 6/7 1 15/5 1 15124 11612 120121 121/13
getting [1] 33/8
heads-up 11) 617 121115123119 124124 12517 125119
GIBBONS [1] 2t5
health [1] 66/10 126111 126114126124 12713 128111
GTBBONS-FEDEN [1] 2/5
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ng l3l 52117 94122 107 117 107 121 114112 117 ls 117 118 1 18/13 rcD [1] 16/4
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lll 26t11 97123 99124 01/1 0 1 identified l7l 517 7125 8114 8119 9122
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1 31/1 9
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161 45t23 83/10 91/5 ',t2916129122 helpful identifying 121 7817 78114
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governmental l1l 1719
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grace [1] 116/7
hesitancy [1] 65/25 imagine 121 57114 57115
granting 111 12517
hiding [1] 94/4 impact [1 8] 94/1 1 1 01/1 6 1 01/1 8 1 03/1 8
gravity [9] 103/17 104/21 105/3 108/9
high [2] 109/5 1 '19/12 104t21 105t22 108t10 1 1 3/1 6 1 16112
1 10/8 1 10t25 11 1/6 1 13/15 1 18/6
higher [9] 9719 s8lz 98/15 98/25 99/6 1 1 6123't 17 16 1 1 812 1 1815 1 1817 1 18/17
greater [2] 1 1 1/6 1 11/19
100/7 100/10 100/14 116/10 118/18 119t6119t12
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highest 121 1715 1 'l 'll1 0 impairing I1l 106124
GREEN l24l 2t8 4t5 4/8 4t16 32t13
Highlands l5l 34117 87119 87121 87125 lmplausibility l1l 1 17 112
42t17 44t17 48114 5914 6519 67124
92120 implementation [1] 83/1 3
68121 69113 69125 8014 81/19 94125
96/'f 1 96/1 3 1 00/1 6 10112 10815 11218
Httllll 87124 implicitly [1] 108/2
himself [1] 63/18 importance [1] 1 19/15
131i 18
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gross [1] 31/21
grounds [1] 91/11
history [23] 18/5 39/3 40/18 41/11 45/8 ilfiz7222 88/4 10218 102110
45t16 45t23 61/3 61/6 6118 62122 83113 importantly l2l 62123 1 03121
group [2] 40/10 5113
85/13 86/2 86t48616 86/19 86/25 90/16 impose [4] 95/19 10212'1 104125 113/25
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institutions l1l 33122 June 13th [1] 109/21
instructed 15) 44112 63/10 85/15103/21 jurisdiction l3l 75117 10014 121114
imposed [11] 100/11 10219102116
1 10/6 jury [13] 85/16 89/20 89122 10616 106111
102118 1101411315 120t17 12217 123t1
instructive [1] 102/18 106t12 1 06/18 1 06/1 I 107 t23 108t3
1251313212
imposes [2] 68117 109/25
insufficient [3] 40/8 5819 12515 117t5117t15118t15
intact [1] 31/12 jury's [2] 106117 107/6
imposing [4] 86/15 104119105/7 108/8
intelligence [1] 31/14 justice [5] 108/19 115123 11814 119119
imposition [1] 102/1 1
intend [12] 617 64123 68114 83114 89117 123125
imprisonment l1l 13212
94123 3619 105/2 108/6 112121 127t1s
improper [1] 61/10
127t18
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intended l5l 4419 73/23 73124 7 412 keep [2] 133/18 133120
inauthentic [1] 121/6
intense [1] 8/6 keeps [1] 88/3
incapacitation [3] 1 10/19 111 112 130/10 .l
intent [1] 10/21 Kehs [1] 94/22
incarcerated [2] 33123 7512
inlention [2] 84/5 86/10 KEVTN [1] 2t4
incarceration [3] 73118 11117 13018
include I8l 42113 49121 49124 50/6 50/20
interactionslll 24119 kind [4] 64116 64117 87120 97115
interest l2l 10517'l 05/1 3 knew [3] 32124 481210718
63115 82124 97t24
intermediate 1161 73120 7514 8212 8217 knowledge [3] 9/19 10712 11618
included [1] 84/15
82124 8413 8416 84113 85/25 103/8 known [5] 25113 40111 46123 47114 79/9
includes l1l 13212
103/1 1 1 04/3 111 120 11218 112113 knows [2] 38/8 58/3
including [6] 48/1 1 5214 7612 76/4 80/19
112118 KRISTEN I2l 2t5 4t24
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incorporate [5] 101/10 101 125 132110
internet 161 45117 45121 4615 46197819
133/3 133i9
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incorporated l3l 22113 8216 132125 lack [2] 88117 107119
interpose [1] 109/10
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interpret l2l 87128713
incorporating l1l 132/13 language [3] 11/10 11111 8713
interview l4l 29122917 401248/4
increase [1] 109/4 large [1] 51/3
intimidate [1] 93/11
indecent l8l 41 122 7311 1 93116 1 06/1 3 last [14] 9114 9118 16125 18/9 18125
intoxicant I2l 107125 1 1 8/15
106121 107 113 1 10124 11816
lnvestigation [5] 53/16 53/25 101 113 25114 46122 47/15 7112 8214 96123
independent l4l 32123219 32lS 32115
110/24113120 98117 11712012114
independently l4l 3415 3418 34116 42/7
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indicate 181 2411 4 30/S 31 122 34/25 later [3] 75115 103/9 108112
invite [1] 9/2
45116 46113 8216 82117
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indicated [6] 30/10 30114 39123 40122 92119
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issue [1 6] 21 13 21/4 6415 64/24 65/25 law [43] 2A5341245717 5815 58/5 61/10
indicates l2l 82110 132122 63/6 63/20 63t21 63/25 65/14 65/16
85112 94/20 94124 9613 96lS 95121
indicating [2] 961 1 4 1251 18 70117 73/3 73t7 7 4t24 75113 75115 7818
103/3 103/6 103t7 129t8 129t16
indications [1] 31/9
issues [1 5] 18/22 21 12 7218 87 18 91 125 78t15 79t15 88t14 89t2 9012 9018 9113
individual [11] 39/1 1 4316 59123 60/12
97t21 97t25 98/3 99/19 99t25120t24 91 18 9312 10411 1 107 123 1 08/6 1 08/6
61 12 61 16 80/6 104i16 105/1 1 105/16
1 24t5 127 t23 128t17 132t9 108/19 108t21 109t13 109/13 115123
130/6 117t11 119/19 124t2128t21 131t4 1
issuing [4] 65117 98/21 103/5 105/5
individuals [9] 39/12 39117 40110 4'1124 laws [1] 65/22
iteration l1l 83112
49121 6217 6219 79/18 10518
iterations l1l 82115 lead [1] 60/20
ineffective [1] 129/9 leading l2l 10119 50112
itself [4] 1316 34125 52/2 67121
ineligible [3] 90/14 90124 9118
inferences [1] 69/10
w l3l s21225212257125 learn [1] 28/19
learned l2l 28122 28/25
infinite [1] 57115 least [4] 815 919 1112o 1413
infirmities [1] 93/25 jail [1] 87111 leave [1] 13/6
influence [1] 69/21 jails [1] 125122 led [1] 106/19
inform [1] 75121 Lee [1] 116/4
January 111 66122
information [38] 7/10 2219 2813 28fi9 lettl2l 42123 46117
January 2004111 66122
28122 28125 29/5 3015 30120 39120
Jersey l8l 17111 17117 17119 17121 1812 legal [14] 3514 4414 4516 5912 59115
41114 4212 4214 4318 43121 43123 47112
18110 18115 27114 61 113 8't 122 85/20 87 18 90/5 1 06/1 4
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48t19 53120 73122 73/24 73125 7413
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Journalnl 244 legislation l2l 18112 18117
78t1410417 104114 legislative 171 18117 8413 8415 103/25
JR [3] 1/B 2t871111
informed [1] 96/11 judge [1 3] 1/1 9 6/1 3 6117 2519 55124 108t20110i10 112t23
initialed l2l 81 11 1 96114 legislature [3] 18/20 70125 103124
73t6 73112 81 121 98114 98124 10917
initials [1] 81/12 legitimate l2l 61 /5 13219
116t2132t5
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inmates I2l 3413 34118
judge's [2] 95/5 105124 lll
leisure 75125
judges [2] 109/3 110112 length [3] 5121 96117 10912
inquired l1l 62/7 less [4] 56/15 99/3 100/t1 120/3
Judgment l2l 97115 97116
inquiry l2l 59121 60/18 judgments l1l 4017 lesser [2] 114/23 1 16/19
inserted [1] 129/13 letter [7] 6122 6124 6125 3811 4 3918
July [2] 23t3 6st1s
instance l2l 18124 127 123 53t17 101122
July 13th [1] 65/15
instant l1l 86124 letters [1] 101/21
July 18th [1] 23/3
institution l7l 3412 73119 1 1 4118 1 1 4/22 level [8] 82117 82123110125 1111211113
June [3] 82fi9109121 109122
115t20 120t412017
meant [1] 109/5 119/19 12114 12115 122119 126122
medical 131 3212 3219 32115 127t12 131 t17 131 t17 131/1 8 131/19
level... [3] 11 1/'10 1 11/13 130/9
medications [2] 30118 51123 Mr. [31] 418 4116 22123 32113 42117
levels [3] 5214 5217 110123
meet [8] 814101161116 57110 57113 44117 48114 50111 58112 5914 6319
licensed l2l 171417111
65t19 71t2 85t9 63/13 63/19 63122 67124 68/21 69/13
licensure [1] 1719
meeting [2] 241153114 69125 71/6 72112 8014 81119 94t22
tite l7l 45/25 87110 103/18 1 13/16 1 18/8
meets [6] 8121 1114 27110 35/6 6212 94125 96/11 96/13 100/16 108t5 112t8
118/19 119i6
62t13 119t3129t3
lifers [1] 87112
Megan's [1] 91/8 Mr. Cosby [2] 2212311913
lifetime [12] 60/5 60/9 60/20 64111 6411
member [1] 20117 Mr. Green [19] 4/8 411632113 42117
64115 70115 73115 77123 77124 9114
members [1] 120/13 44117 48114 59/4 67124 68/21 69/13
91/6
memo [1] 84/18 69125 8014 81119 94125 96/11 96/13
light [4] 115/4 115/22117123 125116
memorandum l7J 81 125 851 13 9017 100/16 108t5 112t8
likelihood 161 22122 2416 3217 60116
80t21 116t23
101t21 131t4 131t7 131112 Mr. Kehs lll
94122
memory [1] 31/12 Mr. O'Connor [1] 129/3
likely [7] 37117 5612 56/3 56/19 60/9
men [1] 87113 Mr. Ryan l7l 50111 58112 63/13 63/19
67t5132t20
menace [1] 66/10 631227116 72112
Limine [1] 96/'19
mental l21l 1411214116 14121 15121514 Mr. Ryan's [1] 63/9
limit [3] 37114 37123 80118
15t7 15t7 15t1 1 15t1 4 15t24 16t2 58t25 Mrs. [1] 12115
limited [2] 2012235120
60/3 60/14 60/19 61/14 61/19 62/4 6615 Mrs. Constand [1] 12115
limiting [2] 20118 36125
6713 6717 Ms [14] 414 414 415 6518 65/9 65/9
limits [1] 104124
mention [1] 43/15 100/25 101 t2 101 t2 117/22 1 1 8/3 131/1
lines [1] 90/5
mercy l1l 94/2 131/18 131/18
lips [1] 1 18/12
merely [1] 18/3 Ms. [1] 35/9
tisrlsl 27/22 2814 48119 merge [2] 106116 120|11 Ms. Dudley's [1] 35i9
listed [4] 2312 281273127519
merger l2l 106114 106/19 multiple l1l 3112
lll
literally 1314
merges [1] 107/5 must [26] 65118 73121 74114 74117 7511
literature l2l 2415 251 18
meritorious l1l 128117 75t21 76tS 76t13 77/14 97t12 98t7
litigation [1] 18/13
met [3] 2313 28115 67112 103/13 103t17 103/22 104t6 104t8
living [1] 32/23
Michaellll 2213 104115 104120 104123 105/2 105/6 1
located lll 7612
middle [1] 57119 106/9 107/6 109/25 1 15/13
location l1l 75123
might [9] 10111 28120 42119 4516 4517
long-term l1l 31112 N
5818 8't 112 1 17 120 1 17 122
longer [5] 9811298/20 9812210016
116/10
Miller [1] 93i4 nature [6] 61/18 96/16 114/211518
million [2] 129/25 130/15 116115132121
lose [1] 121/14
mind ['l] 107/21 necessarily [1] 61/10
losing [1] 65/15
minimum l1l 124123 necessary [4] 58/1 I 9718 97 124 11416
loss [1] 116112
minor [1] 133/15 need [10] 13115 3717 37124 5518 68112
lot [1] 48/23
minute l2l 613 54123 70t4 70t10 114/16 116t17 128t12
loud [3] 88/13 107/6 117118 needed 121 24118 32124
minutes [1] 131/10
M Miscellaneous [1] 95/6 needs [13] 5125 15121 32114 95115
misconduct l4l ?5113 41/16 85i15 86/3 103/19 104/22 105/4 108/11 108/13
M.D [2] 22t3 53118
missed l2l 54118 81/15 108/15 113/18 115/11 115/15
ma'am [1] 16/13
mitigates l1l 128114 negligible l2l 25fi3 2612
magnificence [1] 1 16/8
mail[1] 76/3 Modify lll 97117 neither l2l 1081 1 5 1 13121
neurological[1] 31/20
moment l3l 4111 611207017
maintain l2l 7 4113 74117
monitoring l1l 5412 neurologist [1] 31/21
maintained [1] 66/14
MONTGOMERY [3] 1/3 1116 87122 never [6] 2816 28/9 28fi2 3416 46115
maintaining [1] 31/16
month [1] '11l20 118/13
makes l4l 5612 56119 66110 6714
months [12] 8/5 1219 1413 87123 87124 news [2] 1211412116
making l3l 69122 10415 1 17 113
8812 96117 119117 1 19/18 120110 12311 newspaper [6] 88/10 12218122111
manner [1] 66/8
124t7 122t14 122t16 122t18
mark [2] 7214 8115
morning l2l 26/19 26120 nice [1] 87119
marked [10] 3/13 6119 61237137111
motion l34l 9717 97115 97/16 97116 night [2] 821411819
19t4 19t10 22t2 23t6 121 t9
97117 97t22 9812 9813 98112 98123 99/6 nightmare [1] 1 18/20
Mary [1] 128123
99/8 99/11 99/13 99121 99/22 121122 nightmares [1] 1 18/23
match [1] 39/13
121 t23 121 t25 12212'12213 12219 12211 nine [1] 111/6
matching [1] 40/10
1 22122 1 2313't2313 1 231 1 2 1 231 1 6 1 nobody l3l 57121 85121 123/4
materials l4l 4114 4117 1011813113
127t10 12711't 127116132111 13317 non [12] 7115 919 10/15 1 115 11121
matter [7] 5613 5718102112128125
motions [6] 96/19 96/19 96/19 96/20 12/1213t24 52119 56122 5716 57117
132110 133/15 133/15
96t20 97t19 6215
matters [1] 58/5
motivational [1] 1 1 1 117 non-consensual l1l 1 1 121
maximum [9] 98/11 98i18 98119 98122
moved [1] 23119 non-consenting [1 0] 7/1 5 9/9 1 0/'l 5 1 1/5
99/3 100/5 100111 12412312818 12t12 13124 52/19 56122 5716 6215
moving [1] 2114
maybe l2l 13112 86121
Mr [a2] 413 414 414 415 8121 1416 2313 non{orensic [1] 57117
McEwen [1] 116/2
24112 40110 5713 6518 65/8 65/9 65/10 none [1] 39/9
Meaf [2] 4016 40116
meaning 141 76120 811297/611815
68t23 71t15 71t21 7216 72110 77/10 nonsense lll
129114
81119 87110 8813 88117 96/8 100/25 nor [9] 69/10 108/16 108/16 11213 11?/6
meaningfullll 62112
100t25 101 12 101 13 1 06/5 1 16113 1 17 18 112t14 113122 114110 12013
means l4l 5717 7915 96/19 96/19
N opening [1] 35/17 particularly l1l 25118
ophthalmologist [1] 53/18 parties 161 6417 64/15 101/15 106/15
Norristown I1l 1117
opining [1] 35/10 133/18 133t20
not [1 94]
opinion [18] 8/8 8/9 10/9 1113 1218 2011 pass [3] 7112911169413
note [2] 83/14 105/19
22t10 22t1227t19 32t20 33/3 33/16 passages l1l 118117
noted [3] 1OZl19 104117 13018
33/17 36/8 37121 52117 8811411415 past [3] 46/18 'r 1718 11718
notes [3] 55116 62119 13417
opinions [5] 20123 22121 23111 2516 Pause [1] 34/1 1
nothing [6] 38/3 44/2411711911812
opportunities [1] 83/23 paused l2l 76120 76125
119t24127t5
opportunity [8] 5s/19 6117 68156817 pay [2] 120/9123111
notice [6] 24112 24116 5812 64117 64123
104t9 104t13 126t22 paying l2l 92/14 99118
99t12
payment [1] 98/5
notified 141 78/24 79/8 791 15 791 1 I oppose [1] 80/12
opposed [1] 84114 PCRA [2] 121124129111
notify [2] 75111 79117
option [1] 68/10 penalty [2] 102125 10312
November [1] 53/17
optional[1] 9716 pending [12] 98/15 98/25 99/5 100/9
November 24th l1l 53117
options [21 110121 1 1 1/10 100/13 120/18 120t22 122t4 125/7
numeric lll 82122
oral [2] 8119123112 127111 12811513315
o orally [2] 8117 96112 penetrated [1] 106/7
oratorical [1] 63/19 penetration l2l 10719 107/14
O'Connor [1] 129/3
order [15] 814 15119 27120 2Sh1 29116 PENNSYLVANTA [29] 1t31t6 1/17 17t11
o'NETLL [1] 1/19
3213 32116 45/13 65117 66/15 9718 17116 17118 17/21 1812't8111 18114
oath [3] 41124 5018 68/25
102/22 102t24 1 33/1 3 133117 27 t3 27 t13 34t2 70t17 73t3 73t7 73t1 4
object [2] 13/319124
ordinarily [3] 98/13 9812310017 73t21 74/14 75111 75/21 76/3 76110
objecting [1] 1317
oriented [1] 31/5 77 t1 4 77 /17 77 122 97 16 9919 1 03123
objection [16] 10/19 19115 20113 2115
21/12 2318 29122 3514 3515 4719 50t2
original I1l 122119 Pennsyfvania's lll
70122
originally [1] 109/21 percent l4l 27114 271'16124115 129124
50/10 8218 9712299114 99122
others [3] 12110 94112129117 percentage l2l 49117 50123
objections [1] 96/21
otherwise [4] 11/10 52123 6117 74124 perception [1] 31/23
observations [1] 33/12
obtained [3] 2915 29111 29/15
outcome [2] 99/5100/13 Perhaps lll
6817
outline [1] 58/15 period [1 1 ] 8/5 1 1 120 1219 1412 5415
obtaining [1] 28/16
outside l4l 3317 4811976129318 66120 76119 76124 98110 11417 129/11
obviates [1] 128/13
obvious [1] 1 15/14
overall [6] 1 1/18 1217 59125 60113 62111 periodically lll
77112
113114 permission [1] 6/19
obviously [1] 36/1 1
overcome [1] 59i12 permitted l4l 5125 501 12 1 1 5124 123120
occasion l2l 1811 6 21 125
overlook [1] 106/10 person [14] 9/9 2719 57/12 60/9 60/21
occasions [3] 30/1 2 30115 3112
overnight l1l 7418 66t7 6618 66/8 66/10 66/13 66/23 6715
occurred [3] 4115 53/6 66/1 8
Overruled [1j 10/21 93/5 118/18
occurring 121 4120 107 19
octogenarian [1] 87i18
overview lll 9714 persona [1] 125/15
personality l8l 14121 141221515 1518
ovenrrhelming [1] 107/16
offend [8] 56/3 56/3 56/19 60/10 60/21
15t9 62t5 6714 6717
80t21 116t24125/17
personally l2l 4812 52112
offender 1111 52114 64112 6512270116
p.m [3] 100121 100122133124 persons l4l 11121 1211219/23 66111
70123 84121 84122 85/2 87/19 112111
page [21] 3120 6/8 619 7 110 11 122 11/23 pertinent [1] 106/10
120115
offenders 1161 171221816 20/4 40111
12t4 12t15 21/9 23t2 24110 2614 2816 PETER lll
2t9
2819 28112 3014 40120 45116 46122 Ph.D [7] 319 3114 3117 16120 1716 17/7
49t9 49111 49114 49/18 51/3 51120 71/3
53/16 53/25 19t4
7114 109117 1 1 1/5 1 15/18 130/10
Page 11 [1] 53/16 philanthropy 111 108124
offending l9l 2416 3217 39/3 47115 58122
Page 12 [1] 53/25 Phoenix l2l 8712412017
I
59/1 5 59/1 60t17 61t6
Page 193 [3] 7/10 1214 12115 photographed l1l 77116
offense l44l 24123 25111 25111 25/15
Page 2 [1] 30/4 physical l1l 24117
26t227/5 3915 40/13 42110 44114 66117
Page 3 l2l 40120 45116 physically [1] 80/6
66/18 66/21 66124 66125 671147312
Page 4 131 24110 2614 46122 physician [1] 3214
731 10 7816 78113 8217 82117 84123 8519
pages [2] 5121 2215 PfATKOWSKI [5] 2/6 4t4 65t9 101/2
86/19 86/20 86121 86124 90/12 90/18
pain [1] 118123 1 31/1 8
90/20 103/18 't04/17 104121 105131
paragraph l3l 131221412 46122 picture [1] 92/15
1 10t7 110t25 1 1 1 t2 1 1 1 t6 1 13112 1 1311
paralysis [1] 1 18/10 piece [2] 37120117114
118t6125/11
paraphilia [5] 1 5/8 15112 3714 52123 pieces [1] 25118
offenses [16] 18/4 19123 41111 4519 5115 pills [1] 107118
paraphilic [20] 3/16 516 51127127114 814
51 17 67 /6 82111 8512 85/3 86/25 90/1 4
1 0/1 5 1 1 t4 1 1 t9 13124 2213 37 113 40123 places [2] 75124 81111
90/16 90t22 91/18 109/18
44t21 45t4 52t19 5313 5314 56121 5715 planned 131 7612107117 107117
offer [4] 3217 33117 55/19 68/10 plausible l1l 117113
paraphrasing I1l 25125
offered [8] 23/1 1 2513 3518 39120 4912
parole [4] 17124 73118 76121 7712 pleading [1] 99/14
50/1 8 68/1 0 85/1 7
partial [6] 1031210315 1041311214 PLEAS [1] 112
offering [3] 33/2 3517 63117
112117 11418 please [9] 4/19 7/7 16125 53/11 72113
offers [1] 19/21 participate [1] 18/16 72t21 78t11 83t9 87t21
otlice l1l 7614 participated Ul 18121 pled [2] 7816 78118
Official [2] 1 116 134t1 1
officials l1l 112/24
participation llj 1 1 1 117 plenty [1] 87l'l 1
particular I5l 25117 59119 104117 105/10 plummet l1l 11617
older [2] 3413 34117 point [5] 35115 45125 72120 81/24 8612
128t6
ones [1] 83/6 particularity 111 97 11 4 pointed [1] 59/2
open [3] 16/10 95/15 1 10/2
P previously [5] 6/23 65113 71112 102124 psychologists [1] 57118
104t17 psychology [10] 1716 1717 1711317113
pointing [1] 37110
primarily [5] 18/3 1814 5116 51/11 59/18 17/16 19t22 21/19 23t12 23t14 33t4
points [1] 85/7
primary [6] 39/1 6 48122 11 0/1 5 1 1 1/9 public [17] 78/9 78116 88114 102114
police [12] 4716 73114 73121 7419 74115
130/9 130/10 103/16 104/20 105/3 108/9 111t12 11
74/18 75111 75122 76/10 77115 77118
principle l5l 40114 83117 108119 108121 1 13/9 1 13114 125115 130/1 1 130/18
77t22
1 13/5 131/3 133/19
pool [1] 39/12
prior [7] 2815 41119 48125 62122 86112 published [2] 2214 2616
population l3l 49120 50/6 50/20
90122 93119 punishment l19l 73/20 75/4 8213 8217
pornography [10] 18/4 45117 45120
prison [5] 761227713 87119 94114 13014 82120 82124 8414 8416 84113 85125
45t21 45t23 45t24 46t5 46t7 46t9 51t7
prisoner l1l 129120 103/8 103/11 109/9 109/11 111/10
portion l2l 618 2512
Probable [5] 30/19 30122 4118 4319 1 1 1 t20 1 12t8 1 12t1 4 1 12t 18
posed [1] 74120
43110 punitive l1l 83122
position [2] 93/5 123/14
positions l1l 17120
probably l4l 18125 29125 35112 47123 purchasing lll 17123
probation 11 41 17 124 1812 5412 73120 Purdon's [2] 11212 11215
positively l1l 45122
751 4 76121 77 12 8215 82121 1 02122 purportedly [1] 130/15
possibility l1l 91122
1 02124 1 04t2 1 1A 17 1 1 418 purports l1l 57121
possible l5l 1017 '10/8 10/10 10110 57/16
problem l2l 78122 8419 purpose l8l 7112 10713 110/9 1 11/9
possibly lll 132123
problems l2l 31116 4714 120t8 120t12 130/9 130/10
post [20] 7614 83121 95118 s5122 96h0
procedure l4l 92120 97110 105112 purposes [3] 4/19 7618 110117
97t7 97t1898t398t12 98/23 99/6 99/8
131i1 1 pursuant 171 6712 80/5 80/9 8515111/20
99t11 99t21 10216 1 19124 123116 127 11
procedures [1] 94/19 112t2112t5
132t11 133t7
proceed [5] 7/6 2513 55114101/5 106/3 push [1] 45/9
post-sentence [18] 95/18 95122 96110
proceeding l1l 12917 puts [1] 1 18/5
9717 97118981398112 98/23 99/6 99/8
proceedings 171 412 65/7 7316100124 putting [2] 1 14l15 1 19/15
99t1 1 99t21 1 02t6 1 19124 123116 127 /1
131/16 13312413415
132t11 '133t7
process l4l 129122129122 129/23 130/6 o
postponement [1] 123/1 1
proclivities l1l 9217 Quaaludes l5l 28117 2916 29110 29116
potential[1] 98/21
produced [1] 81/25 45/13
Potentially l3l 9124 9125 1012 qualifications 121 20113 21111
profession l2l 53122 54/7
power [3] 91/20 9218 106124
professional l2l 127 | 4 1 27 16 qualifies l2l 12121 12123
powerful [1] 118/3 qualify l5l 9121 7316 9814 99117 103112
professionally l1l 15117
powerfully l1l 117123
proffered [1] 59/9 qualifying [1] 56/2
practically [1] 56/14
programming [3] 1 15/17 1 15/19 120115 questioned [1] 35/6
practice I4l 171121815 53121 5417
Programs [1] 120/6 questioning [1] 35/17
practicing l1l 17115
pre [1] 82/1 1
promises [1] 69/16 quintupled lll 89/22
promoted [1] 66/15 quite [1] 132122
pre-2012[1] 82111 quote [4] 1315 4915 11011811114
prompted [1] 39/5
precious [1] 1 16/1 1
promulgated l2l 108125 109120 quoted l2l 25120 11613
precise [2] 35/15 65/25
prong [1] 57113
predation l1l 107117
pronouncement [6] 103/25 108120
predator l17l 4115 4/181412015/3 18/1
1 10/1 1 1 12123 112123 125124 raise [1] 99/25
50t14 66t23 67t2 67113 70119 7317 raised [5] 99/15 99/20 99120 99121 1
proper [9] 35122 35/25 36/6 93/4 9316
73112 9117 112110 129121 130/5 13112 raises [1] 85/12
93t17 102t1 1 104t6 105t12
predatory [4] 60/15 6213 66112 6715
properly [5] 10/14 3617 5714 93/19 99/13 raising [1] 20/12
predicate [5] 7/19 7121 7125 81231414
proportionate [1] 1 10/13 range [9] 92124 9313 93/9 93/9 93/'15
predicates [2] 8/15 10/18
prosecuting I1l 2715 s3121 9312211117 11118
predisposes [1] 66/8
prosecution l1l 12019 rate [1] 39/17
preliminary l1l 12118 rates l1l 25124
prospectively l1l 83124
preparation [1] 101i9
prospects [1] 105/17 rather [1] 60/18
prepare 121 80124 126111 rel17l 1111424163217 5613 56i3 56/19
protect l3l 111112130/11 130/18
prepared l4l 8215 89112 9017 131 15
protected [1] 105/14 58t2259115 59/19 60/10 601't7 60121
preparing l2l 28123 30124 80t21 1 13t12 1 16t24 1 1912 125117
protection [8] 103/16 104120105i3 1
prescriptions l4l 28117 291629111 29116 re-offend [8] 56/3 56/3 56/19 60/10
113t7 113/9 113/14 131/3
present l7l 416 63/20 65/1 1 92110 10114 60t21 80t21 1 16t24 125117
proved l2l 85117 85119
104113131120 re-offending 161 2416 3217 58122 59115
proven I3l 125125129121 13015
presentations [1] 18/18
provide [5] 64122 73/21 1 05113 1 101 1 1 59/19 60/17
presented 141 22122 64/4 67 122 87 /1 4 re-offense l1l 113112
1 10/13
Presentence [7] 53/15 53/25 56/6 56/9 Re-redirect l1l 11114
provided [10] 5/20 30117 59111 74124
101/13 110124113120 re{raumatization [1] 1 19/2
7817 78114 114117 114121 12113 121 18
presently [1] 86/17 reach [2] 2516 89123
provides l1l 11114
presents l1l 24113 reached l2l 48120 59125
provisions l2l 83122 84124
preserved 161 96122 96124 97 122 99113 reading [1] 59/21
PSI [8] 54113 54120 8216 8219108/13
99115 99122 ready l1j 7/5
1 15/9 133/16 133i18
press [4] 28120 28/23 29/2 45111 realize[1] 78118
PSY.D l1l 4t24
pretrial[1] 96/20 ly [6] 1 0/9 39/1 0 60113 7714 84120
Psychiatry l1l 2215 reaf
prevent l1l 69/22 106t21
psychological [2] 18/3 101124
prevented l'11 12314 reason [1 1] 39/5 39111 8219 85/1 I 88/3
psychologist l5l 1714 2116 21/1233116
preventing [1] 107/3 95/1 9 1 1512 123125 12412 12516 127 116
33121
previous [1] 21113
24122 2516 35121 6415 6613 67119 80120 request [3] 22120 9018 93124
8212 84112 88113 94119 115112117110 requested [5] 92/23 97114 97121 108/16
reasonable 141 32121 56/17 58/10 1
125t14128t15 113t21
reasons l33l 25114 4414 5818 80124
Regardless l1l 127124 require l4l 141215/15 60/6 123110
86114 92117 97120 101110102t7 103t4
regards [3] 23118 82123 9619 required l18l 12124 56124 57123 58111
103/9 103/9 106/3 1 10t3 110t4 119t14
register l7l 73113 74114 74118 75115 59t2 61124 68124 73113 7413 75113 77t7
1201212012212413 125112 125113 1
76t9 76t13 77t22 77121 79125 81 112 11 5/6 1 1 5/1 8 117 t17
126110 126115 127112127120 127122
registered 111 77113 123113
128t3 132t15 132t15 133/3 133/4 133/8
registering l1l 7113 requirement l5l 57124 77/24 90119 11O/5
rebut [1] 59/10
registrant l2l 64111 70116 132t6
rebuttal [5] 55/19 55122 80119 80119
registration [15] 64/13 64118 64119 7011 requirements [6] 58i1 6 71 15 71 19 72112
81t20
70t23 74125 76115 76119 76t25 77t24 74t25 80116
Rec'd [1] 3/13
79115 79119 80116 9115 9117 requires l9l 55124 59122 6017 60121
recall [3] 5111 2713 43112
rehabilitation [1] 1 1 0/1 8 76/14 111t7 115t23123t7 123t9
recalling [2] 4111 4112
rehabilitative [10] 103/19 104122 10514 reread [1] 117/'16
receive [1] 76/3
108/11 108/13 108/15 113/18 113t22 residence l9l 7 4116 7 4/17 7 4118 7518
received [3] 19/18 22117 2412
115/11 115/15 75t8 75t1275t14 75t17 75t21
recent [1] 19/1 1
reiterated [1] 100/16 residences l1l 73123
recently l2l 1 Bl24 112110
reject [1] '109/8 resistance l1l 10713
recently-enacted [1] 1 12l10
rejected l2l 10812 1 1 419 resources [1] 92/3
recess [5] 64/3 6515 100121 131/10
relare [1] 1 18/7 respond [9] 62/15 62117 6814 6817 7118
131114
related l1l 26112 81t22 89116 126122 127112
recidivate l2l 39112 132120
relales [3] 58/17 103/18 1 13i15 responded 111 4517
recidivism [12] 22122 2417 24123 2517
relating [1] 67/3 response l3l 43120 81117 9013
25t11 25/16 25t23 26t2 26t12 39t17
relation l2l 104121 1 08/10 responsibility [1] 93/18
40t12 56114
relationship [2] 61/19 66/13 rest [2] 37110 37/25
recognize [9] 7/9 71137117 87121 11411
relative l2l 10411 4 105117 result [3] 6211073111 12116
1 1 4t 13 1 16/12 1 17 | 4 132124
release l2l 73117 1 33/19 retains I1l 27118
recognized l2l 97 | 18 12913
released [9] 49/9 49/11 49114 49118 retire [2] 80124126114
recognizes [2] 36/18 129/19
49121 61 /2 74125 75/3 131 125 retribution [1] 1 10/15
recommendation [1] 1 1 1/4
relevant l2l 25fi9 371'18 return [2] 94/19 100/19
recommendations [1] 1 10/16
relied [3] 32111 61116 62123 returning [1] 4/15
recommended [1] 116/18
relief [3] 9711497121 12314 reversible [1] 89/3
recommitted l2l 76120 77 12
rely [8] 4818 48118 53121 5416 63124 review [1 6] 5125 614 13116 21125 2218
reconvened [3] 65/7 100/24 131/16
12615 12618 126/20 41/4 55t16 69t2570/3 90t24 96t25
record l24l 4114 5118 6111 46123 61122
relying [3] 101/8 132/16 132124 99t16 121 18 127125 131/9 131/1 0
61123 62122 68120 6914 93119 95122
remain l2l 891513017 reviewed 11 41 2312 27 120 27 122 301 1 0
96/18 99/15 109125 11012 113123 12318
remainder 131 67117 7311477123 30t16 31 t22 47 t21 69t12 89/4 1 01/6
1 23t9 1 231 1 4 1 251 1 3 1 2616 1 321 1 3
remanded 121 130114 133112 1 08t 1 4 1 131 4 1 1 3119 12416
132114 1 33/1 5
remark 11! 84117 revisit [1] 133/6
recording I4l 121 15 121 17 12914 12915
remarks [2] 58/15 83/15 revoKed [1] 131/23
records 1111 231224114 27120 27/22
remember [5] 5/8 5/11 43/15 63/16 revolves [1] 68/1 1
30/9 30/16 31123 32111 32112 47118
87t17 rightness l2l 1 27 124 127 125
47t21
remind l4l 11125 6417 66118 99119 rights [15] 701207117 791279110 8019
Recr [2] 314 317
reminded l2l 1 13124 1 16/2 80t1 4 80120 9511 I 95122 96/1 0 96/1 5
recross [4] 5/3 1419 54111 54115
remission l7l 913 9/5 9/8 9122 56/21 102t6 119124 125123 13017
RECROSS-EXAMINAT|ON l3l 513 1211
56123 56123 risk [34] 181319125 2013 2015 2ol7
54111
remorse [3] 88/18 93fi293/18 25t6 25/15 34120 34121 35/3 38/6 38/15
recurrent [7] 8/5 12/21 1212414131415 removing [1] 6/20 38/19 38/20 38/21 3912 3917 4018 4416
14t614t7
render [2] 98/8 98/9 44t9 48t22 48t25 56t14 58t22 59t14
Redir [2] 314 317
reoflend l1l 37117 59119 9219 92117 113/1 1 1 1417 115112
redirect 151 1111411/15 36/19 53/12
repeat [2] 10124 29113 125t16125t18
53/1 3
REDMOND 151 219 415 6519 10112
rephrase lll
13112 Ritch [1] 53/17
report [51] 3114 6125 812 9116 9/19 1 1/19 road [1] 36/19
1 31/1 8
12t8 19t25 20t15 2313 24110 25117 26/4 Robert [1] 53/17
reduce [1] 109/5
26t23 27121 28123 2Sl7 30/4 30/9 30/14 role [1] 91/20
refer [2] 30147617
30t24 30t25 31/18 35/23 35/25 39/19 room [1] 33/8
reference [2] 15/23 53/16
39t21 40117 40122 4112 42114 42116 roster [1] 57/20
referenced l3l 14122 39/18101/8
43t7 43t13 44t21 46/8 48/8 48t12 48t20 routinely [1] 133/20
references [1] 116/4
52116 53/16 53/25 56/6 56110 62111 RPR [2] 1/15134/10
referral l1l 48122
67t21 77114101124 12114 12116 127/13 RRR|[1] 120/8
referrals l1l 27115
referred l1l 62121
report's lll
2316 rubbing [2] 11121 12111
reported [6] 31/19 41118 4713 47117 88/9 rubric [1] 85/20
referring l2l 13118 13120
96/6 rule [6] 58/5 58/5 63/6 89/25 127/24
regard [31] 2013 22|122419 25119 26/22
reporter [3] 1/16 126110134/11 131124
29110 3217 38117 4114 44120 46110 4817
reporting [3] 61/23 711480116 ruled [1] 65/13
48125 51113 51119 52114 52118 52/21
reports l2l 14111 4514 rules [9] 5718 5718 6316 8714 90fi29711
59/11 61/15 64/15 69/6 7411274116
represented [1] 30/21 123112126118 131111
82t14 84112 84119 8717 87/9 9018 11412 ruling [2] 6419 117110
reprint [2] 7111 2212
regarding l19l 7 114 17 121 18122 20116
82116 8314 83111 83112 83/15 83/18 sit l2l 2815 4213
84124 86113 86114 87114 87116 87118 six [7] 8/5 11120 1219 1413 41123 8812
run [1] 98/16
89/1 4 89/1 8 92110 97 112 97 123 9915 117/g
runs ['l] 64/8
RYAN [14] 215 414 50111 58fi2 63113
99/23 101/6 10117 10119101111 101120 six-month l1l 11120
101122 10218 10219 102117 1 03/1 0 slam [2] 88119 89121
63119 63122 6518 7116 71115 71118
103/22 103t23 104t14 105/6 105/12 sleep [1] 31i17
72112100125 131/17
105t24 106/4 106/15 108/20 108/25 sleeping [1] 31/16
Ryan's [1] 63/9
109/7 109/10 109/11 109/15 110/3 11 Smith [1] 93/3
1 10/13 1 10/15 110t17 110t21 110/22 soAB [1] s7l18
1 10123 11 1 12122 1 1 4120
14 11 1 19 society's [1] 105/7
1
safety [1] 66/10
1 19/16 120/12 13013 132114 132114 sole [1] 114125
sanctions [2] 105/8 1 10/13
separale [3] 30/12 30/15 33/20 solely [1] 105/21
satisfaction [1] 85/20
Separately l1l 20125 somebody l8l 91 124 91 /25 9215 9215
save [1] 86/9
September [1] 1/13 93t8124t9128/7 130t24
scars [1] 93/1 1
serious [1 1] 105/19 106/7 108/3 112125 somehow [6] 91/14 91 125 93125 128113
scheme [1] 64/13
114t3 115t2115t7 118125 123121 12511 128t14128t14
scholarly [7] 36/13 36/15 36/16 3718
132t17 someone l3l 27 /4 27 116 85120
37/10 37tl1 37t12
seriously [2] 56/13 1 16/19 somewhere [1] 15/25
scl [3] 34t16 87t23 87/24 seriousness [8] 105/21 111/11 114110 soon [1] 87113
science [1] 56/4
114t19 114t24 1 15/3 1 16t20 116/22 sorry [6] 10123 29113 51117 5215 5313
scientific [1] 32121
serve [1] 130/16 116/13
score [2] 110/8111/6
sets [1] 82116 sort [8] 3212 39124 4017 46111 52117
screaming [1] 1 1 8/1 1
seven [4] 28116 29/5 29fi5 5017 61151191912219
second [4] 2114 3419 77125 12917
severity [1] 1 10/14 sought l2l 35fi2 108/15
secondary [1] 83/19
sex [21] 171221816 19123 2014 25111 source [1] 53/20
section [14] 3/15 71211/813/18 15i5
25t 1 1 25fi5 26t2 29112 291 17 3913 sources [3] 2813 48112 48119
15t25 46121 4915 55124 65114 78125
40t11 41111 45t8 45113 5113 52114 6116 speak [5] 34120 71117 7217 113117
79t9102t17 113t24
71t3 115118 120115 118/11
seclions [1] 15/23
sexual [30] 816 24123 25113 30118 3112 speaks [1] 13/5
seek [1] 105/6
40118 41115 42119 45116 50121 51114 special [4] 3/15 71291115130/19
seeking [1] 36/12
51119 52fi2 61/18 61/20 64112 65121 specific l7l 3912 46/9 59/16 60/18 61/15
select ['l] 102120
66/9 70/16 701227317 84123 9'1119 9217 68t274t20
selected [1] 1312
107 t13 112t1 1 1 specifically l9l 19122 2013 33125 34117
12t25 1 1512 1 1817
selecting [1] 103/14
132t18 35t11 44t12 61t4 63110 65t20
selectively [1] 13/5
sexually l28l 4115 4117 14/20 15/3 18/13 specificity [1] 97113
self [9] 2412032120 33/4 33/18 4112431
30/1 1 30/1 6 41 t25 49125 5018 50114 specified [7] 11/1011111 52118 52123
47t3 61/23118/21
66117 66121 66123 66/24 6712 67/5 53125315 6215
self-doubt l1l 118121
67t13 70118 7312 73110 73112 91/7 9216 speech l1l 3117
self-report l2l 4'l12 4317
1 12110 129121 13015 131 12 spell[1] 16/25
self-reported l1l 4713
shall [1 1] 55/20 76119 76125 78123 7917 spend [1] 87122
self-reporting [1 ] 61/23
106/10 109/15 12015 12018 120114 1 sphere I1l 37112
self-sufficient l4l 24120 32120 3314 33118
shame [1] 118/21 spirit [1] 1 19/4
sense [1] 109/10
shameful [1] 1 16/12 spoke [1] 93/2
sent [2] 7711312016
share [1] 41116 stage [1 4] 4115 67118 7213 8013 111 122
sentence l97l 3121 12124 4612264124
68t17 73t20 7513 86/15 92t25 93t8
sharper[1] 116/11 120t21 121/1812216 123115 124121
shines [1] 125116 125119 126116 12719
93/21 94t14 94t15 94t20 94124 95118
short [2] 3111211812 stages [1] 55/17
95/1 9 95/20 95122 9613 9619 961 1 0 97 17
shortly I1l 113117 stand [3] 55120 63111 118/3
97117 97118 98/3 98/119811298114
showing [1] 93/12 standard l8j 26112 4312 59113 60125
98117 98fi8 98119 98122 98123 98124
sidebar [1] 96/6 65/19 65/20 11117 11118
99/3 99/6 99/8 99/1 1 99121 100/2 100/3
sides [2] 84111 126116 standardized [1] 109/3
100/6 100/8 100/1 1 100/19 10216 102111
sight [3] 481247217 91125 standards [2] 103/13 109112
102118 102121 102123 103/5 103/15
sign [3] 31119 7214 8116 stands [2] 36/16 113123
104/6 104/19 105/5 105/21 106/18 102
'108/6 108/8 108/18 109/2 't09125 11014 signal[1] 43/5 starr [3] 4111 9015102110
signature [1] 95/5 started l3l 82114 106123129/5
112113 1 1 3/5 1 13/13 1 13/25 114123
signed [1] 95i23 starting [1] 30/4
1 16/19 117t17 119t22 119124 119125
significant [3] 61/17 105123 112121 state [43] 16125 1719 18110 3412 57119
12011612217 123111 123115 123116
signing [1] 84/5 57121 73114 73/18 73121 7419 74115
1 24t23 1 24t23 1 251 4 1 251 1 0 1 25/ 1 2
silence [2] 61/11 107122 74t18 75t275111 75121 76110 76114
127116 130/16 130/18 130124 130125
sifent [2] 89/5107124 76t1 6 77 | 1 5 77 11 I 77 122 8519 87 / 19
13212132111 't32115 132125 133/3 1
1 33/1 0
simple lll
8/17 92122 94114 97113 103111 108/12 109/3
simply [12] 36/25 82124 83114 84114 111t7 111/15 1 1 1/16 1 11117 111120
sentenced [16] 23/16 76121 7713 8417
97t11 10414 111 121 11212 117 119 12311 1 15/16 1 15/19 12014 12017 123122
107 t1 1 107 I 1 4 1 09/1 4 12013 121 | 15
124t9127/9 129120 13014 130124 130125
121 I 19 12316 1 23122 124122 12817 1
130/25
since [9] 1711817/19 46124 47119 5413 stated [1] 40/15
sentences l4l 10914 1 09/5 1 09/1 6
66t2 83112 83/13 1 19/18 statement l8l 4614 63123 94111 103/4
single [3] 2816 2819 28fi2 104t9 110/3 119/5 126110
112125
sir [10] 19110 26120 37122 54124 72118 statements [3] 101/17 101/18 126/6
sentencing [70] 1/10 21122513 44110
7 2t25 79t 4 1 00t 17 1 221 1 4 1 27 I 17 states [1] 14/20
55/5 55/17 67117 67120 80124 81116
summary Lzl 46121 4915 16112 16113 16115 34112 5419 54124
summation l2l 67120 68116 58/13 65/3 70t12 70t13 74t22 81t13
Static [2] 39110 39124
summations [1] 68/12 88/8 94t 17 97 t2 1 00t 18 125t2 133t22
Static-99 l2l 39h0 35124
Superior 141 9715 9919 11612 122/4 133t23
station [1] 77115
supervised l1l 4914 therefore [6] 65/16 67/12 9118 9619
statistics [2] 51/13 51/18
supervision l2l 46124 8815 101t12115/13
status [2] 6416 70122
support [3] 66/16 125113 128120 third [1] 6/e
statute [30] 15/18 15120 34125 3512
supported l2l 3618 92125 thirds [1] 9/4
38118 57123 57124 59121 60/8 60/17
supports [1] 130/15 Thirty [2] 119117 119117
60120 60121 61124 62114 64/10 66/3
suppose l1l 57111 Thirty-four [2] 119117 119/17
67t374t377t7 80t2 80/5 80/9 82/3
Suppress [1] 96/20 thought [1] 51/9
82t 1 0 84t7 86t5 86/7 86t10 87 t2 87 /4
suppressing [1] 94/5 threatened [1] 69/16
statutes [3] 65/17 7112 83118
sur [2] 80/19 81/19 three [16] 2314 41121 52/3 5216 6314
statutorily l2l 79/1 4 1 1 611 4
surrounding l1l 42118 75t13 75t16 88/19 101 t17 1 06/13 1 06/21
statutory l12l 1411214116 27110 65116
suspenders [1] 95/25 120t3 121 t20 123t22 124t24 125t 10
66t2 67t8 84t12 102t15 104t23 112t20
Sustained 121 47110 5013 throughout l3l 5414 68/24 68125
11313125124
stay [2] 95117 130121
I
svP [55] 1110 3114 6/9 6/1 6121 6122 time-defined [1] 85/5
7/4 7t11 18t17 19/4 19/1 1 19/18 20/16 times [4] 27112 63/5 88120 11719
STEELE l13l 214 4t3 65t8 81119 87110
20t20 20/23 2212 221 1 5 221 17 2316 TTMOTHY [8] 3/8 3t14 3t17 16t18 16t20
8813 881 17 100125 121 /4 122120 126122
23t20 241227t7 27110 27/17 27124 3512 171219/319t21
127112131117
35t6 35t17 35t21 36119 37114 37116 Title [2] 7sl3 7919
step [2] 16114 54125
37t17 37t25 38/6 38/1138t1838t24 titled [1] 2213
STEVEN [1] 1/19 51121 5519 55/1 1 55/16 57118 57121 today [12] 2816 33/13 42/3 64124 69120
STEWART l3l 2t5 71 115 71 118 58/1 6 58/20 59/1 6 59/25 6014 62114 83/3 83/4 83t7 94t15123t5127t21
stiil [2] 1o/13 96/3 62120 6415 64/18 64/19 80/15 127122
stimuli[1] 31/10 svP-2 [1] 7/11 today's l2l 7315 99110
Stockholm [1] 18/25
sworn [3] 412516121 71112 together 111 64121
stood [1] 89/5
symptoms [1] 31/21 tolled [2] 76120 76125
stop [1] 88/21
system [1] 110/15 tool [5] 3513 3917 39114 4018 6017
stranger [1] 66/13
tools [1] 39/10
strictly [1] 43/5 T top l1l 46122
strong [1] 86/14
table [3] 719 7110 8112 torture [1] 116/6
structured I1l 4012
taken [5] 941696112100121 115113 total [9] 1 03/5 1 03/1 5 10412s 1 1 1/1 5
student l2l 741276116
13417 1 1 1/1 6 1 1 1 t25 1 13125 1 1416 1 16114
studied l1l 49120
takes [1] 922 touch [1] 7419
study [7] 22121 25122 4918 49120 5016
taking ['l] 116125 touching 121 1 1 120 1211 1
51t23 5212
talks [2] 43/11 60/5 towards l1l 11217
Subchapter l5l 84123 8514 8517 8518 TR [4] 1 1tS 52t22 5?,22 57125
tangent [1] 36/7
85/1 0
tape [5] 1211512117 122119127/15 tracked [1] 83/13
Subchapters [1] 85/5
128123 TRACY l1l 2t6
subject [5] 55/5 84122 8514 120114
121122
tasked l1l 52117 transcript l3l 2817 12914 134/8
technical [3] 59/17 61113 6418 transient l1l 7619
submit l4l 9514 128119 129115 130/18
technically l1l 77110 transit [1] 88/2
Subparagraph l2l 7 117 12125
temporary l2l 75123 75124 trauma [1] 1 19/1 1
substance l1l 111123
ten [1] 131/10 traumatic[1] 118i20
substantial l2l 120/24 12415
tendencies [1] 91/19 traumatization [3] 1 1912 11918 11918
substantially all 106124
tendered I1l 127123 treat [5] 68/25 1 15124 123120 125/20
substantive [1] 85/19
tenuous l1l 70124 129117
such ['f 5] 1517 1518 34124 40123 44121
term [4] 31 112 76122 77 13 128124 treated l1l 108122
51 t23 67 17 69122 761 1 5 1 0312 1 1 1 15
terms [8] 2311027120 33/15 81/15 85/4 treatment [121 171221816 49112 49115
111/8 1 19110 12014 125116
93125 108123 128122 49118 61 14 91/1 5 1 08/1 7 1 1 4116 1 1 4121
sudden [1] 129/8
test [2] 5219 52111 116t17 130/19
suffer [1] 93/10 Teslament [1] 1 16/5 trial [19] 12110 28n 50ft 6218 85118
suffered [1] 116/5
testified l15l 4125 515 12110 16121 18119 88118 8917 96121 97 | 1 6 97 122 97 123
suffering l2l 10114 93120 26t25 32119 4'U24 5017 5915 6'U25 62/8 99114 99123 99123 102/4 102113 12'U22
suffers [1] 5713 71t13 8812410212 129t7 129t7
suffice [1] 96/16 trials [1] 4115
testify [3] 2012 27119 6018
sufficient 161 24120 32120 3314 33118
testifying 5/11 50/16
l2l trier [1] 65/24
5911210416
testimonial[1] 101/17 triggers [1] 85/10
suggest l22l 5712 58/21 59/6 59/10
testimony [33] 10/13 21113 23110 23115 true [5] 32116 32122 44120 6115 11816
59/15 59/20 60/1 1 60/25 62110 74/19
26t23 30120 3312 35120 46/5 50/18 trust [2] 9316118123
86i25 90/11 90/15 90123911391111
59t10 62t11 63/11 63/14 63116 6719 truth [2] 43112 65125
91t14 91123 9214 94113 129114130112 1/13
suggested l2l 60122 95112
80/20 89/8 90122 91112101123 107120 Tuesday [1]
114112 11514 115/1 1 1 16125 11716 11 turned [1] 129/5
suggesting [1] 63/2 117/16 11812 118/5 1 18/18 132119 two-thirds 111 914
suggestion [3] 5713 59/5 85i13
testing 14 9?/1192/11 type [2] 2015 2017
suggests [1] 88/17
teslosterone l2l 5214 5217 types [1] 106/22
suit [1] 118125
text [3] 2616 2618 4916
sum [1] 93/23 U
thank [24] 4122 615 1111211113 1419
summarized [1] 53/18 ultimately [5] 59/4 5917 61117 61121 6213
50t14 66t17 66t21 66t23 66124 6712
67 ts 67 t13 70t18 73t2 73t7 73t10 73t12
un l1l 127125
86/18 86/20 90118901219117 11115
un-rightness I1l 127 125
1 12110 129121 13015 131 /2
unable [3] 1 18/10 118111 118122
Virginia [3] 1/15 18111 134110
unaware [3] 4715107/9 107/24
virtually l1l 25/12
unawareness [1] 107/18
Vitae [3] 3117 191319112
uncharged l5l 62124 85/15 86/3 86/12
vocation [3] 17l3 1711076116
117t3
voice [1] 65/15
unconscious l2l 1 07 I I 1 07 I 25
voices [3] 11717 117112117118
unconsciousness [1] 1071'18
voir [2] 16123 51/9
unconstitutional [1] 64/10
volitional [1] 66/7
uncontrolled [1] 9/10
Volume [1] 22/5
undergo l2l 49115 49118
voyeurism l2l 40123 44121
undergone l1l 49112
voyeuristic [1] 8/21
underlying [8] 7/19 7121 7125 8123 10117
11t7 37t3 44113 W
underscores [1] 108/3
wait [1] 95/10
understanding [8] 1 9/25 30125 51113
waited [1] 123/5
70120 74112 80/3 8112 96114
waive [2] 69117 129110
understood [2] 55/6 68/4
waived l2l 80117 104/10
undertake [1] 115/19
warning l1l 94123
undue [1] 1142
warrant [1] 103/2
unfair [1] 89/23
warranted [1] 1 1 6/1 5
uniqueness [1] 89/8
wealth [3] 92/3 108124130122
unless [2] 74123126123
website [3] 7819 78116 83111
unreported l4l 41111 41115 42123 45/8 weeklll 12114
unspecified [1] 53/3 weeks [3] 87122 87123 87124
unyielding [1] 1 16/8 weigh [1] 94/8
urges [1] 9/8
weighed [1] 113i11
usage [1] 15/16 weight I8l 6217'l 05125 1 12/22 1'l 41 1 5
utifize [4] 1411221118 83/3 109/23 114t25 115/3 1 17125 119112
utilized [2] 15121 61 122
utilizing [4] 15/3 15141511137/14
weighty [1] 65/23
welcome l2l 7 4123 1281 10
whatsoever l2l 4617 5919
Whereupon [1] 96/5
vacates lll 128114
while [3] 4717 8815109i18
valuable 111 117114
whole [1] 66/15
value [2] 11715117111
whom [1] 66/13
various l1l 33122
wlLLtAM 121 1t871111
VDire [2] 314 317
willing [2] 4818129110
vehicle l2l 37126612
wing [1] 103124
verb [1] 5715
wish [6] 67123 691257012711229813
verbal [4] 31110 31114107121 107/22
12612
verdict [5] 89/23 100/13 106117 10716
Womelsdorf l2l 1 115 134110
13214
women l9l 29112 29117 42119 45113
verification l3l 77113 77115 77117
49125 5017 52119 62/6
version [1] 108/2
won't [2] 94123122/2
versus [4] 38/6 5313 67120 11614
wonder [1] 89/11
vested l1l 10412
works [2] 110/813112
Viagra l1l 51/24
worry [1] 38/4
victim [29] 10115 5716 61118 61119 61121
worth [1] 130/15
78123 7917 79/11 79114 93rt0 93112
93t20 94110 1 01/1 6 101/18 103/19
worthy I1l 127125
wrap [1] 68/12
104t22 105122 105/23 1 08/1 0 1 1 3/1 6
wrap-up [1] 68/12
116123 11716 117125 118/5 1 18/17 1 1
writes [1] 54/3
119/8 119/13
victimization [1] 66/16
inglll 97112
[1] 101/18
victims [19] 7/15 1014 1016 1115 41115
41t17 41119 42123 43111 43115 56122
written lq 2427112271124 80/25 81/3
78t24 7912 7918 79110 79/13 79113 [3] 63/3 91123127114
11319 11712
view [2] 85/1412718 yesterday
viewing l1l 45117
[8] 5/5 712214122 5517 6419
8014 80122 81124
views [1] 2419 young
vindicate [1] 105/7 [5] 2911229117 45113871121
viofation l2l 76121 7712
violence [6] 85/13 86/2 86/5 86/6 86/19 zerol2l 56/14 56/15
86125
violent l28l 4115 4117 14120 15/3 18/13
EXHIBIT 2
rN THE COURT OF COMMON PLEAS
IN AND FOR THE COUNTY OF MONTGOMERY, PENNSYIJVANIA
CRIMINAL DIVISION
COMMONWEAIJTH OF, PENNSYIJVJT'TTA,-
v€t. : NO. MD-3156-15

WILITIAM H. COSBY, JR.
PETITTON FOR WRrT OF HABEAS CORPUS/lqOrrOU TO IS

DISQUAIJIFY MONTGOMERY COUNTY DI STRICT ATTORNEY
OFF I CE
Courtroom A
Tueeday, F€bruarY 2, 20t6
Commencing at 9245 a.m.
Virginia M. Womelsdorf, RPR

official Court, RePorter
MontgomerY CountY CourLhouse
Norristown, PennsYlvania
-1
BEFORE: THE HONORABIJE STEVEN T. oTNBIIJL' JUDGE
COUNSEL APPEARED AS FOI-rI-,OWS:
KEVIN R. STEELE, ESQUTRE

District Attorney
KRISTEN M. GIBBONS-FEDEN, ESQUIRE
Assistant District Attorneys
f or Ehe Cornmonweal th
BR IAN .I . ESQUI RE
MCMONAGIJE ,
CHRISTOPHER TAYBACK, ESQUIRE
MONIQUE PRESSLEY, ESQUIRE
.]OSEPH SARLES, ESQUIRE
for the Defendant
INDEX
DEFENDANT ' S EVIDENCE
Witness VDire Di.rect Cross Redir Recr
BRUCE L. CASTOR, JR. 12 111 239
EXHIBITS
COMMONWEALTH I S
Number Descriptio_n Marked Rec t d
C-l ABC News "New Developments j-n l-30

Cosby Fondling Investigation"
C-2 Pottstown Mercury article 138
rCosby meets with authorities
over sex assault allegations"
C-3 Bloomberg. com article dated 1.47
November 25th, 201'4 "Why Did
Bruce Castor Pass on a Chance
to Lock Up BiIt Cosby?"
C-4 Southeast Missourian article I52
dated January 27, 2005
rrProsecutor calls case against
BiII Cosby weak"
C-5 Daily Mail article published 158
November L8, 2014, "I wanted to
arrest BiIl Cosbyrf
C-6 Washington Post article dated 1-65

November 19, 201,4 "Prosecutor
who declined to charge Bill
Cosby in 2005: t I didn't saY
that he didn't cornmit the
crime t "
C-7 CNN video 169
C-B WNPV audio 173

E-XHIBITS
COMMONWEALTH ' S
Number De s cr ipt i o*q. Marked Rec'd

C-9 Philly. com article dated L76
September L4, 20L5 rrTime hasn I t
run out on Possible charges
against Cosby in Pa. rr
C-L0 People.com article dated L79

7A-22-LS rrPennsylvania District
Attorney Candidates BattIe it
Out Over the 2005 Bill CosbY
Sexual Assault Allegations"
C-11 The Intelligencer article dated L9'1
September 24, 2015 "MontgomerY
DA candidate Castor urges delaY
n Cosby case until after
elections "
C-t2 Philly. com article dated 21"8
1-31-16 'rCastor coul-d be keY
witness at Cosby hearing"
DEFENDANT I S
Number nS:Sr r-Pt i oq. Marked Rec'd

D-1 Castor I s biography from 20LG L9 L9
campaign website
D-2 Castorrs biography from law 19
firm website
D-3 Canadian Incident RePort 35
D-4 Press Release dated 2-L7-Os 70
D-5 E-mai] dated September 23, 20L5 96

to Risa Ferman from Bruce
Ca st or
D-6 Letter dated September 25, 2015 104
to Bruce Castor from Risa Vetri
Ferman
EXHIBITS
DEFENDANT'S
Number Descr_i$ron Marked Rec I d
D-7 E-mail- dated September 25, 20'l'5 105

Ca st or
D-8 E-mai1 dated September 25, 2015 1-08
Ca stor
1 COMMONWEALTH vs. WILLIAM H. COSBY, JR.
2 (The fol-Iowing proceedings v,rere
3 commenced with the Court, Mr. Steele, Mr. Ryan, Ms.

4 Gibbons-Feden, Mr. McMonagle, Mr. Tayback, Ms .
5 Pressley, Mr. SarIes, and the defendant being

6 present: )
c THE COURT: Good morning.

9 Again, f want to thank the members of the press,
l_0 journalists, media. There j-s a Decorum Order that has
l-1 been in place, and my understanding is everybody has
L2 respected it, followed it. Again, that was
13 promulgated by our president judge and through our

L.t court administrator, so I thank alI the members of the
15 press that have followed that to keep this in an
l-6 orderly process and to the members of the public that

l7 have been able to abide by that.
L8 Let the record reflect that ltre
I9 did have a brief prehearing conference with counsel

20 just t,o try to get an idea of how we will proceed this
21 morning. The Court bad previously issued an order
22 that was limiting the nature of today I s proceeding to
23 the claim raised j-n the Habeas Corpus Petition of the
24 def ense that there vras a valid exist ing
25 non-prosecuLion agreement and that that would affect
1_ COMMONWEALTH vs. WILLIAM H. COSBY, JR
2 whether this case could, in f act, procee,d or should it
? be disrnissed based upon such an agreement.
4 By my order, I indicated that
5 that was the only issue I was going to consider today.
6 AII other issues raised in the defense Habeas Corpus
7 Motion would be preserved for more appropriate times
I according to the RuIes of Criminal Procedure.
9 So, again, read nothing into
10 that other than what we did discuss in our conference
11 as to the motion regarding the removal of the District.
L2 At.torney's Office in prosecuting this case as to how
13 that would be handled in the future, but it. is not

L4 envisioned that it would be handled todav.
1"5 Now, with that said, the
15 District Attorney's Office filed the Iast pleading in
L7 this matter which was in opposition of this Courtrs
18 power under habeas corpus to hold this hearing.
L9 As I I ve indicated informalfy,
20 there's very l-ittle case Iaw about this, the nature of
21 this proceeding. But under general principles of the
22 jurisdiction of the Court and habeas corpus, I felt it
23 best, based on what was at least alleged by the
24 defense, to hold it in the form of a Habeas Corpus
25 Hearirg, to have this hearing.
L COMMONWEALTH vs. WILLfAM H. COSBY, JR . 7
2 But, Mr. Steele, I wanted you to

3 have the opportunity to have the record as to say why
4 you beLieve under the rules or the existing case law
5 in the Commonwealth of Pennsylvania that there just
6 does not envision such a hearinq.
7 MR. SfgnLE: Thank your Your
I Honor.
9 THE COURT: And anybody who
10 wants to use the podium can. If you want to sit down,
t_1 ftm okay with it. I respect thatr lou know, every
L2 member of the Bar here wouLd follow the Rules of
13 Civility, but I also want you to be comfortable. So
L4 if you dontt feel like standing, you donft have to and

L5 the Court wiII take no offense or use the podium or
r.6 whatever.
L7 MR. STEELE: Thank you, Your
18 Honor. As indicatedr w€ are of the position that this
1_9 motion is prernature. And we rely on the case of
20 Commonwealth versus Cosgrove which is, I believe,
2I 680 A.2d 823, a 1996 case, holding that a crimj.nal
22 defendant may not challenge the authority of the
23 Comrnonwealth to prosecute hirn until after a formal
24 arraignment. we outline that j-n our brief .
25 THE COURT: Let me ask you. The

1 COMMONWEALTH VS . WILL IAM H . COSBY, ,JR. B
2 one thing that I know that a couple members of the

press asked me was please remind the attorneys to use
4 the microphone. You're talking at me. Apparently
5 there's a whole other courtroom. The closer you can
6 get it to you, please use it so that theyrre able to
7 hear. Sorry to interrupt, but that $/as a specific
8 request,.
9 MR. STEELE: I was done, but I
10 can repeat mYself, Your Honor.
L1 THE COURT: I heard You. That's
1"2 important. Let.'s hoPe
13 MR. STEELE : lale I re re 1Y ing on
l4 Commonwealth versus Cosgrove. And our position with

1-5 this is premature because we have not gone through a
L6 Preliminary Hearing. The Rules of Criminal Procedure
l7 outline a method for contesting the evidence in the
1_8 case, and it's our position t,hat itrs premature.
1_9 THE COURT: And that was an
20 Attorney General case in regards to making an election

21" to prosecute a case and the defendant was challenging
22 whether they have the authority to prosecute. I
23 understand. That I s from L996. I've reviewed it.
24 Do you want eo resPond?
25 MR. McMONAGLE: Judge, aII I can
1 COI.'IMONWEALTH vs . WILLIAM H. COSBY, qJR. 9
2 say is obviously it's our position that the right to

3 habeas corpus is one that needs to be protected, that
4 this United States citizenrs Iiberty is at issue.
5 With respect to where we are
6 novr, we have submitted to the Court the idea that this
7 prosecution must be barred because of a decision that
B was made, the intent which was to bind the
9 CommonweaLth of Pennsylvania to prevent a prosecution
10 ever in this case for the defendant, Mr. Cosby.
t1 And we believe based on the case
t2 law we have submitted, Levine versus Fair,
1_3 Commonwealth versus Owen and all of its progeny that
I4 the tirne to do that is now. It does go to the heart
15 of the jurisdiction of this Court. It goes to the
L6 idea of whether or not this individual citizen has the
t7 ability now to say this must end.
18 We woul-d ask the Court to give
19 us an evidentiary hearing on the subject so that we
20 can request this Court to do what v'te submit should

2T have been decided and remain final for the last L2
22 years.
z5 THE COURT: All right. As the
24 Court indicated by my order to schedule the hearing,
25 again, the right to habeas corpus is one guaranteed to
t- COMMONWEALTH vs. WITLIAM H. COSBY, JR. 10
2 i-ts citizens of this Commonwealth and this country.

3 And I donrt see any prejudice at
4 this stage to this important issue that is raised by
5 the defense to having a hearing on it, so we will
6 proceed with the hearing today.
7 And the Commonwealth I s rnotion
I to, at this stage, postpone it or not hold the
9 hearing it wasn I t f or any ot.her rel-ief t,han just
t_0 not holding it today and allow a Preliminary Hearingr
LL under the Rules of Criminal Procedure. r would deny,
t2 in effect, that request.
13 So, therefore, I have read the
1_4 initial motion, the Comrnon$realth's Iengthy response to
L5 it t.hey are of record the Commonwea I th ' s sur
I6 motion, so frm ready to hear evidence and then
T7 argument as to what you believe $tas proven or not
18 proven, what exists, what doesn't exi.st.
19 So with that said, if you feel
20 the need to give an opening remark as to how you're
2t going to do it, you can. If not, you may call your
22 f irst wit.ness.
23 MR. McMONAGLE: Thank your Your
24 Honor. The defense, on behalf of William Cosby, calIs
25 Bruce Castor.
l- COMMONWEALTH vs . WILLIAM H. COSBY, ,JR. 11
2 DEFENDANT I S EVIDENCE
4 BRUCE L. CASTOR, JR., having

5 been duly swornr wos examined and testified as
6 follows:
MR. McMONAGLE: Your Honor, with
8 your permission, may I ask that this exhibit be
9 brought. up to Mr. Castor so that, when we get to them,

L0 we can have him go through them?
L1 THE COURT: Has the Commonwealth
l2 seen it?
t_3 MR. RYAN: We have not. We
L4 would love a copy.

15 MR. McMONAGLE: .Judge, f have
t6 all the exhibits. Irm going to mark them, and theyrll
1.7 be dernonstrated on the screen one-by-one so that the
l_8 Commonwealth has them.
19 MR. RYAN: Before the witness
20 sees an exhibit, I'd like to see it.
21, THE COURT: I understand. He
22 can have the book up here. Don't you have them all on
23 the screen? You were setting uP in here Last night

24 until the wee hours.
25 MR. McMONAGLE: YES. WEITC A11
L COMMONWEATTH vs. WILLIAM H cosBY, JR. T2
2 ready to go.
? THE COURT: You can flash them
4 up. Please do not flash anything up there therers
5 obviously not a jury here, but I do want to keep to
6 the Rul-es of Procedure so that the Commonwealth knows
7 what yourre about to bring up.
I MR. McMONAGLE: Yes, Your Honor.
9 May I proceed, Your Honor?
10 THE COURT: PICASC dO.
1- 1_ DIRECT EXAMINATION
1"2 BY MR. McMONAGLE:
13 0 Mr. Castor, good morning.

I4 A Good morning.
15 THE COURT: Irm going to hold
L6 you up. If thatrs that's perfectly just move
t7 that over to an area. You can actually drop it on the

L8 bar in front of you there so that right here. Put
19 it there and it's going to pick your voice up.
20 Can the members of the audience
2L hear? Give them a little test.
22 MR. McMONAGLE: Testing.
23 THE COURT: No? T think You
24 have to push the red button. Can you hear me?
25 AUDIENCE: Yes.
L BRUCE L, CASTOR, JR. - DTRECT 13
z THE COURT: Okay.

? BY MR. McMONAGtE:
I O Mr. Castor, good morning.

5 A Good morninq.
6 a Mr. Castor, how long have you been a member of
7 the Bar?
B A Just about 30 years.
9 0 I'd like to take you back and ask you when it was
t0 that you joined the Montgomery County District

11 Attorneyrs Office?
I2 A Well, I think I joined on June the Lst, 1985.
13 The county seems to think it was June the 3rd, l-985.
L4 And so much time has passed, I didnrt think it was
15 necessary to argue with them over two days worth of

J-O pen s ion .
L7 O Okay. f think that was a wise decision. Take me

1_B throughr ds best you can, your starting point in the
19 Dist.rict Attorney's Office and how you worked your way
20 through the office and where you ended up.

2t A WeII, when I was hired, f l'ras appointed to the
22 to a position as an intern in the Sex Crimes Unit and
23 as a person that wrote briefs in the Appellate
24 Division. After I was interviewed by then Pirst
25 Assistant District Attorney William Carpenter in
t L. CASTOR, JR. - DIRECT
BRUCE 1'4
2 December of t984, T assumed the position. I believe

it was the first day after Labor Day, which is why I
4 think it's the first of June, in 1985.
\ So r vras in my third year of law
6 school- and I -- concurrent with going to law school
7 and in the summers and vacations, I worked in the Sex
8 Crimes Unit and in the Appellate Division.
9 Upon graduation from Iaw school
10 in May of 1986' I was appointed as an Assistant
1L District Attorney. I worked as an in an intern
T2 capacity until I had taken the Bar exam.
13 Then District Attorney Thomas E.
14 Waters, Jr . l-et me have August of f , and I started

15 on as a ful-1-time sbrorn Assistant District Att'orney
16 on September 2nd, L986. I was assigned to the
L7 Appellate Division because that was the only opening
1_8 that was available.
19 In short order, within weeks, a
20 member of the office had an Assistant District

2T Attorney had left, and I was moved from the Appellate
22 Division to the Pretrials Division so t would be on
23 track to be in the Trials Division ultirnately t,rying
24 jury cases.
25 O And did that, in fact, happen? Did you get to a
L BRUCE L. CASTOR, ,JR. - DIRECT 15
2 point after joining the office where you began

3 actually being involved in major crimes cases and
4 sexual assault cases?
5 A Yes.
I -- either at the end of 1986 or early
6 1987, I was prornoted to the TriaLs Division on account
7 of an emergency pregnancy leave. It was a temporary
I promotion to the Tria1s Divis j.on. And when the lady
9 came back from pregnancy leave, I was allowed to
10 remain. I was assigned to the Major Crimes Unit.
aa
l-t There was a change in the
1,2 admin j-stration, and District Attorney Mj-chaeI D.
r_3 Marino assumed chargre of the of f iee in 1988. I was
L4 the first person that he prornoted when he became
15 District Attornev.
16 f had served on the I.4a jor Crimes
L'1 Unit and the Sex Crimes Unit while I was in the Trials
18 Division in '81 and the latter part of | 86. I was
19 promoted to captain of t.he Major Crimes Unit effective
20 JuIy of 1988.
2L I served in that capacity,
22 captain of the Major Crimes Unit, from.TuJ-y of 19BB
23 until September the 6th of 1991, whereupon I was
24 promoted to chief of the Trials Division. And I was
25 put in charge of the county fnvestigating Grand Jury

1 BRUCE L. CASTOR, JR. DTRECT L6
2 which is ordinarily two positions, or was then, but

3 there were budget cuts in the county and I was
4 required to do both jobs.

5 Then in the Spring of 1993, then
6 First Assistant District Attorney William Carpenter
7 hras nominated to be a j udge of the Court of Common
I Pleas . Back in those days, that rneant that, he was
9 going to, absent sornething very strange, going to be
10 elected in November, whereupon District Attorney

1t_ Marino had instructed Mr. Carpenter that he was not to
12 take on any more investigations and cases by virtue of
13 the fact that it was contemplated that he would
t4 shortly become a member of the bench. And I was put
15 in the position of actj-ng First Assistant District
T6 Attorney.
l7 in November,
After the election
18 the governor appointed Mr. Carpenter a judge having
19 while he was judge elect. There were vacancies that
20 the Court needed fi1led. The g'overnor appointed Mr.
2L Carpenter to a judge.
22 And as of that dater ds of the
23 confirrnation by the senate, I became First Assistant
24 District Attorney, which had no significance
25 concerning the work I was doing apart from it was a
1 BRUCE L. CASTOR, JR. - DIRECT 77
2 substantial increase in pay.

3 O WeII, that never hurts.
4 A It did not hurt. I learned while I was at the
5 F.B.I. academy, in f act, in the FaIl- of 1993.
6 A Okay. So you become First Assistant District
7 Attorney of Montgomery County in 1993. And how long
B do you serve as First Assistant District Attorney?
9 A From 1993 until I was sworn in as District
10 Attorney in the first week in January of 2000.
1t O So now wetre in January of 2000. You become the
12 Dist.rict Attorney of Montgomery County. And how long
13 did you serve the people of Montgomery County as
T4 District AttorneY?
15 A Eight years' two terms.
16 A And upon your comPletion in your service as
1.7 District AttorD€Y, what then did you do?
1.8 A I was in 1987 I decided not to run for
T9 reelection as District Attorney and instead ran for
20 election as a County Commissioner of l4ontgomery
2L County.
22 O What year was that?
23 A 2007.
24 O 2007
' okay.
25 A The election was in 2aa1. I took office in the
l- L. CASTOR, JR. -
BRUCE DTRECT 1B
2 first week in January of 2008.

3 O And with respect to that position, did that
4 involve any type of particuJ-ar safety concernsr €t
5 cetera ?
6 A In my first term, no. I actually didn't have

7 much of a portfolio in my first term as County
8 Commissioner. My second term as County Commissioner I
9 held the portfolio that was for supervision of the
10 Public Safety Departments, which would be the
1L Emergency Operations Center, dispatching ambulances,
1,2 fire, policet Coordinat,ing for major events, you know,
13 Iike the Pope I s visit and things l-ike that.
T4 f was sort of the f was
15 the the cornmissioner that was in charge of aII

L6 those things, but of course the people that were under
t7 me were very capable in and of themselves and hardly
18 needed my input. But that was what I did.
19 And then I acted as a liaison to
2A PubIic Safety Department row officers in the county
2t and provided the County Cornmissioners I perspective on
22 al1 public safety issues.

23 0 I want to go back to when you were District
24 Attorney of Montgornery County and Assistant District
25 Attorney of Mont,gomery County. Did you receive any
1 BRUCE L. CASTOR, JR. _ DIRECT 19
2 awards for your servj-ce as an Assistant District

J Attorney and as the District Attorney of Montgomery
.i Count y ?
5 A Your Honor, there would be so many, I donrt know
6 that I would am able to do it without seeing my
7 c. v.
I MR. McII4ONAGLE : We11, maybe f or
9 the sake of expediency, if we could if we could
1n
IV publish Exhibit 1?
11 MR. RYAN: We have no objection

1,2 to that, Your Honor.
13 (Castor's biography frorn 20L6
1,4 campaign website marked Defendantrs Exhibit D-1- for
15 identification. )
THE COURT: Okay. It I s admitted

16
T7 into evidence.
tB (Defendant's Exhibit D-1
t9 received in evidence. )
2A BY MR. MCMONAGLE:
2T O Mr. Castor, is this, in fact, a document that you

22 recogni ze ?
23 A No. It rnust have been written by somebody in the

24 campaign.
25 (Castor I s biography from law
1 BRUCE L. CASTOR, JR. DIRECT 20
2 firm website marked Defendant's Exhlbit D-2 for

identification. )
.r BY MR. MCMONAGLE:
5 O All rigrht. Letrs go to Exhibit 2.

6 THE COURT: Everybodyfs watching
7 T.V. but me here, and my eyes ain't, good.
I BY MR. MCMONAGLE:
9 O Mr. Castor, you've asked for a paper copy. IrlI

10 give you a paper copy of this exhibit.
1_1 MR. McMONAGLE: Your Honor, ildy
T2 I approach?
1_3 THE COURT: Yes. FeeI free to
L4 approach.
15 MR. McMONAGLE: Thank you.
16 THE WITNESS: Okay.
L7 BY MR. MCMONAGLE:
r8 0 Mr. Castor, for expediency purposes, I just want

19 t,o take a f ew things down, and r think it will help us
20 move along, but I want to be clear on some of these

21 items that I I ve referred to.
22 In L99O' did You receive the
23 Chamber of Congress Law Enforcement Man of the Year
24 award ?
25 A That I s true, y€s.

1 L. CASTOR, JR. - DTRECT
BRUCE 2'l'
z O In 2047, were you inducted into the Pennsylvania

3 Police Hall- of Fame?
4 A f was . To rny knowledge, I 'm the only prosecutor

5 that has achieved that honor.
6 0 In L995, did the Attorney General of the United
7 States issue an award to you?
8 A Yes. The Attorney General of the United States
9 acting at the recommendation of the National
1_0 Association of Government Attorneys in Capital
11 Litigation recognized me as first place in the country
L2 f or j-nvestigating and prosecuting homicide cases.
l_3 O And while you were District Attorney of this

L4 county and Assistant District Attorney of t,his county,
L5 First Assistant District Attorney of this county, did
16 your in fact, pf,osecute significant homicide eases?
L7 A WelI, they certainly were significant to the
rB people who were deadr so. . .
19 O Capital cases as well?

20 A Yes.
21" O Do you have any idea how many homicide cases you
22 prosecuted while Assistant District Attorney of
23 Montgomery County ?
24 A If you include the cases that pled guilty'

25 probably 50
1_ BRUCE L. CASTOR, JR. - DIRECT 22
2 A Okay. And did you receive any awards or

J citations groups that you remember?
from any victims'
4 A A11 of the major victims I groups in Montgomery
5 County gave me their highest awards. Laurel House.
6 O What is Laurel House?
1
A It I s a support group for primarily for women
B vi-ctims of violent crime and sexual abuse. Victim

9 Services Center which does the same tbing. And I
10 think that there's another one, but I canrt remember
t1 what it i-s.
T2 In factr they I think in 2007
L3 Laurel House granted me the highest distinction that

14 they brere able to at a grand ball they had that was
15 covered by Philadelphia Magazine, which I thought was
16 a little over the top myself.

L7 0 And with respect to peer reviews, have your in
l8 fact, r€ceived various citations and awards with
1,9 respect to those?
20 A By npeer review, " you mean other lawyers granting
2t me honors?
22 0 Yes.
23 A Yes. I am a fellow of the Litigation Counsel- of
24 America, a distinction that I have had for, I think,
25 about nine years. I was designated a Pennsylvania
L BRUCE L. CASTOR, JR. DTRECT 23
z Super Lawyer 10 or L1 times, four of those times while

J I was District Attorney.
4 I am rated by Martindale-Hubbell
5 as AV, which is the highest rating, five out of five,
A a perfect rating. The AV letters, I donrt know
1 exactly what they stand for, but one of thern has to do
I wit.h lega1 ability and the other has to do with

9 integrity and ethics.
r-0 That group is further delineated
l_t in tbe Martindale-HubbelI Bar Register of Preeminent
T2 Lawyers in Arnerica, and my peers have seen fit to
r-3 grant me that distinction as we1l.
t4 O Lastly, with respect to background, you've
15 indicated to us that when you left the District
16 Attorney I s Of f ice, you became a Count.y Comrnissioner.
L7 Are you still, in any capacity as we speak today,
18 involved in prosecuting cases?
19 A Yes. Tomorrow I'11 be arguing a case in the
2A capitol as an Assistant District Attorney of Centre
2T County. On the peer review things, I think I also
22 have been four times sel-ected as a Top 100 Trial
23 Lawyer in America.
24 O Okay. With respect to what you just said prior
25 to that about prosecuting a case tomorrow, how is it
L BRUCE L. CASTOR, JR. - DIRECT 24
2 that you're stiII involved in prosecuting cases in the

State of Pennsylvania?
4 A In April of last year, a weII, in January of
5 last year, a scandal broke in Cent^re County that
R caused the District Attorney there to have to defend
'l herself and her office against attacks that they were
8 too f riendly with rnembers of the bench.
9 As a result thereof, the
1n District Attorney asked me to prosecute cases for that.
11 office where her office was under attack for too close
t2 a relationship with the bench because, of course, r
L3 didn't know any of the bench up there. And I did
1,4 guite a number of thern.
15 The trial IeveI prosecution
76 seemed to be over because the defense lost them all,
T7 and now I am dealing with the appeals, and one of them
18 is tornorrow.
19 0 All right. I want to take you back nor^r to what
20 brings us here. In 2005, you were District Attorney
2t of Montgomery County. And did you oversee the
22 investigation of allegations made by Ms. Andrea
23 Constand against my cl-ient, Mr . Cosby?
24 A r did.
25 O As District Attorney of Montgomery County in
t- L. CASTOR, JR. - DIRECT
BRUCE 25
z 2005, did you delegate others t,o investigate t,hat

J al-Ieqation?
4 A Yes. The procedure then was the same procedure
5 that had been in place when I was First Assistant D.A.
6 Field operations were directed by the First Assistant
't District Attorney and such mernbers of the County
8 Detective Bureau as that official decided he or she
9 needed. Then the information was gathered and was
1n presented to the District Att,orney.
l-L That is the procedure I utilized
1.2 in t,his case. I appointed First Assistant District
13 Attorney Risa Ferman to supervise the investj-gation
L4 along with Detective Richard Peffall and a Cheltenham
15 detective, D€tective Schaffer.
16 O Okay. I know we're going back in time, 2005' but
I7 to the best of your recol-lectionr are you able to teII
l_B us where it was? And by rrwhere, " I mean what country
it was this cornplaint originated from?
20 A Yes. The chain of events was that the
2T complainant complained to Iaw enforcement officers in
22 Canada where she lived. The Canadian authorities' I
23 want to say it was Toronto police or I don't know
24 if theyrre called police there, but Toronto Iaw

25 enforcement officials, believing that Temple
t_ BRUCE L. CASTOR, JR. - DTRECT 26
2 University was in Phitadelphia as it, in f act r rnostly

? is, referred the complaint to Philadelphia police
4 authorities who ascertained that the event complained
5 of actually occurred on our side of the border in
6 Montgomery County.
7 And Philadelphia Police,
8 pursuant to protocols, long-standing protocols,
9 referred that to the Cheltenham Township Police
r.0 Department. Cheltenham PoIice Department referred it
11 to our office to assist them in the investigation.
t2 O And when it got referred to your office, vrere you
13 able to determine preliminarily whether or not
T4 Ms. Constand had made what we know in the law as a
15 prompt complaint of an assau.l-t?

r"6 MR. RYAN: Objection, Your
L7 Honor.
18 THE COURT: NaIurE?
1_9 MR. RYAN: Relevance. I don't
20 see how the substance of the underlying al-legations
21 have any play into the narrow issue werre here for
22 which is non-prosecution agreements.
23 THE COURT: Wel1, at this stage,
24 obviously, it's going to be in the whole narrative as
25 to relevance as to what reason the case was not

BRUCE 27
2 prosecuted, whether it was an agreernent, whether it

3 was prosecutorial discretion, whether it followed the
4 ABA standards. So it's relevant in that regard as to
5 any decisions that he mader so I I 11 overruLe the
6 objection.
7 BY MR. McMONAGLE:
B O Do you remember my question?

9 A f do. There was no what we referred to as a
l_0 prompt complaint in this case made by this

1L complainant.
t2 0 Do you have an independent recollection of how
r-3 long it tookr rr€aning how long it took frorn the

l4 so-called event until the complaint was made?
15 A It was almost exactly a year,
16 O Was that of significance to you as a former sex
1,7 crimes prosecutor and the District Attorney of
l-B Montgomery County?
t9 A WeII, it was of enormous significance.
20 O why?
2t A Pennsylvania law grants prosecutors the license

22 to argrue that the credibility of witnesses is enhanced
23 if they complain promptly to law enforcement
24 officialsr €specially if primarily if they're
25 adults. Children is have a special set of
2 circumsLances, but we're dealing with an adul-t,. And

? in this case it wasnrt even a young adutt. I believe
4 she was in her 30s.
5 So it was of enormous
6 significance from a Iegal standpoint because when
7 something bad happens to a person and the person

B considers themselves to be victimj-zed, the law
9 recognizes that if it is very scary or hurts that
10 person, that if they go to the police and tell them
11 about it or go to a relative who then goes to the
72 pol j-ce and tells them about it, that you can utili ze
t3 that to say that, when you're argui.g, that no one
I4 would go to t.he police and put themseLves in the

15 position of having to explain what happened unless it
16 reaIJ-y did happen.
17 So it I s a way of bolstering the
18 credibility of a complaining witness, and it j-s of
t9 extreme importance in cases where you have no forensic
20 evidence and yourre going to have an oath against oath
2I case.
22 O So you've 9ot, as I understand it, an issue in
23 terms of the duration it took, how long it took to
24 make the complaint for credibility issues, and yourve
25 also referenced forensics; is that fair?
l_ BRUCE L. CASTOR, JR. - DTRECT 29
2 A Right. There's a secondary component. The first

? component is the Iegal component that the prosecutor
4 can use to enhance the credibility of the complainant.
c But the second component which
6 is of investigatory value as opposed to courtroom
7 tactical value is the passage of tirne tends to make it
I so that the abi l ity to coI.Lect. f orens ic evidence,
9 trace evidence, if you wi11, hairs, fibers, DNA,
10 anything of that nature the longer time goes by,

L1 the less likeIy those things are going to be found.
72 Yourre talkinq about a sex
t3 cr Lme . It's particularly of significance because
L4 trace evidence on the person's body who was victimized
15 is going to disappear when the person takes a shower.
r.6 So thatrs a big problem.
L7 But a lot of people don I t know
18 we can sometirnes get some forensic value even weeks

19 later, if we had hair samples for example, because Lf
20 somebody's taking drugs and or was drugged, as we
2t thought might be the case here, if we can test their

22 hair, if we can find it somewhere from the root out
23 we know hair grows at a roughly constant rate -
24 As a result, if we find some
25 indication of t.he drug in the hair, w€ might be able

z to back it up to where it had been ingested. Same
with f ingerna j-1s . But af ter a year r you r ve cut your

4 fingernails and you've cut your hair.
5 O Did you l-earn when you first got involved in
6 looking at this matter, did you ascertain whether or
7 not Miss Constand had contacted civil- attornevs before
8 rnaking a complaint to the police?
9 l4R. RYAN: Objection.
L0 Relevance. Again, we're getting into the substance of
11 the underlying claims which has no bearing on the
1,2 non-prosecution agreernent. .
1? THE COURT : WeJ.lr the

, Mr . Ryan
L4 question is if the you know, it seems it t s rel-evant

l5 if the District Attorney at t.he time made just an
16 independent decision he wasn't going to prosecute.
L7 It I s very rel-evant as to why bother doing anything
t8 else. I mean, thatrs their c1aim.
r9 He made a determination.
20 Reviewing the American Bar Association Standards,
2I whatever standards he had professionally, he's telling
22 you why he didn I t prosecute.
23 Now, if he's going to go on as
24 to other reasons, I mean, it's relevant to their

25 cl-aim. I mean, it it ' s not relevant to anything
'1
L. CASTOR, JR. - DIRECT
BRUCE 31.
z eIse, but the claim that we're here for today, Ifm
3 afraid that it is.
4 MR. RYAN: My suggestion to you,
5 Your Honor, is that it's rel-evant to the extent
6 what t s relevant for this hearing is whether or not
1 there was an agreement Irm sorry a decision to
8 charge.
9 I certainly agree that that may
t0 be relevant and have bearing on this hearing. As to

11 the underlying substance, this hearing is not a forum
L2 to litigate the underlying substantive clairns of this
13 case. Itm suggesting to you that that's where we are
t4 going.
15 THE COURT: WeII, I would hope
1"6 ure're not . At this stage, you knowr 1lou
I ve given a
t'l basis to a simple basis that you're stating the

1B witness is stating he felt he did not have a case that
T9 he was going to prosecute.
20 Now you're moving orlr so we
2t don't need to get into anything more about it. f

22 meanr you'-re now about to move on to, I assurner the
23 agreement.
24 MR. RYAN: I would hope so.
25 MR. McMONAGLE: Judge, there Is
1 BRUCE L. CASTOR, ,JR. DTRECT 32
2 an enormous arnount of investigation that he did

? step-by-step-by-step that brought him to the
4 concl-us j-on that there was going to be an agreement.
q
And they have challenged, quite
6 frankly, in their moving papers, the credibility of
1 this witness. Theyrve challenged his ability to make
8 the decision. They've examined his reasons for making

9 the decision.
10 And I think it's completely
11 relevant to where $rerre going, which is he spent a
T2 significant amount of timer Ers did his staff and his

1? team, in investigating this rnatter and why it was that
T4 he came to the conclusion that he had to make this
L5 agreement. And so I think I have to develop this
1-6 record, and I'm going to do it as quickly as I can.
I7 And Irm certainly not at this
l_B point in time trying to try the case. But what he was
19 thinking in real-time in 2005 and why he made these

20 decisions is of paramount importance to our issue here
21 because I know, unless I'm wrong, theyrre not going to
22 agree with me when Irm all done.
23 And so theyrre going to sdy,
24 we1l, €ither he didn't do it or he didnrt do it the
25 right way. And I vrant to establish, A, he did it the
2 right wdyr why he did it and what he did.

3 So I | 1I move it as quickly as
4 possible, sir. I rm not trying to

5 THE COURT: I didnrt know
6 whether that was it because you just asked about an
7 agreement.
8 If he's saying he's not
9 finished, you're going to have to wait for each
10 question or make a broad relevancy objection.
1_ l_ I mean, at this stage it's
T2 relevant to get to the place to where they're claiming
13 that there is a non-prosecution agreement that was in
t4 existence and enforceable. And if it is related to
15 the fact of whether he thought, he could prosecute this
r-5 case, then it I s refevant.
t7 So that t s my overall, You know,
18 general ruling as to each time he asks a question.
19 I'II note that if you feel the need to, continue to
20 object to it, but r think at this stage werre going to
2t have to hear it.
22 MR. RYAN: I will object where
23 necessary. I do apPreciate Your Honor and the
24 perspective that you have that this is not a forum to
25 re-Iitigate this case, and so I'll- object when I feel
l_ BRUCE L. CASTOR, .JR. _ DIRECT 34
2 it fs necessarv.
? THE COURT: Not a forum to
4 re-litigate that case
5 MR. RYAN: Or litigate it in the
6 first pIace.
7 THE COURT: Re-lit.igate the
I investigation. We'l-1 leave it at that.
9 MR. RYAN: Yes.
1n THE COURT: ftrs not. If he
11 thinks it t s a forum for some sort of a basis for a

I2 decision that he's made, I tm afraid it's relevant.
l_J BY MR. McMONAGLE:
1_4 0 And, Mr. Castor, let me be real clear.

15 Obviously, when you received this allegati-on, I take
i-6 it you wanted to give it as much care as you could?
t7 A WelI, c€rtainly. I mean, the case was referred
18 by Philadelphia Police from an international source.
19 f wanted the international referring agency to think
20 that we took it seriously. I assigned who I thought
2t were our best people to the case. And f took an
22 active role as District, Attorney because I thought we
23 owed it to Canada to show that, in America, we will

24 investigate al-legations even against celebrities.
25 O And obviously we were dealing with a celebrity
l- BRUCE L. CASTOR, JR. - DIRECT 35
2 here.
3 A Yes. Actually, it was the first I learned that
4 he lived in our county' but Yes.
5 a By uhen you're referring to Mr. Cosby?
6 A Yes.
1t
0 f rm going to try to move as quickly as f can
8 through this, &lthough important, mindful of t'he
9 Court's view of this.
10 With resPect to
Ll- THE COURT: We11, Mr. McMonagle'
L2 my view is I overruled the relevance objection- Ask
13 quest j-ons. Develop the case that you want to. Right
t4 now you've indicated why it I s relevant -
1"5 (Canadian Incident Report marked

lo Defendant's Exhibit D-3 for identification.)
L'l BY MR. MCMONAGLE:
1B O I want to 9o to Exhibit 3.
r_9 A I didn't answer the question that you asked. Do
20 you want me to or not?

21 THE COURT: WhY don't You l-eave
22 it to Mr. McMonagle?
23 BY MR. MCMONAGLE:
24 O Let's go to Exhibit 3.
25 MR. RYAN: Your Honor, if I
t_ BRUCE L . CASTOR, ,JR. - DTRECT 36
2 could just ask that before vre publish documents, if

J the wit,nes s could be shown to lay the proper
4 foundation.
5 THE COURT: To the electronic
6 operators there, the Rules of Evidence are stiII
7 working even if wetre using T.V. cameras I mean,
I even if we're using electronic publishing. They've
9 got to see it.
10 Now, if you have
11 MR. McMONAGLE: TheY do.
1.2 THE COURT: Before theY see it,
13 before the witness sees it, if you have the ability to
L4 publish it on his screen alone I thought that I s
15 what the book was for. You say we're going to Number
16 3. You look at the book. He may not want it
L7 published. He may not want may have an objection
18 to it. Just publish it on that screen.
19 MR. McMONAGLE: TheY have the
20 book. I say we're going to Exhibit 3, publish it on
21- his screen.

22 MR. RYAN: If I maY ask the
23 Court Lf Mr. McMonagle can come show me the exhibit -
24 I believe he has Exhibit 3 Labeled as '8', in my book.
25 I don't know if thatrs going to be a persistent
1 BRUCE L. CASTOR, "TR. - DTRECT 37
2 problem. Or if he just, wants to corne show m€r that. Is
3 fine.
4 MR. McMONAGLE: Tab 7 in your
5 book.
6 THE COURT: Let me ask. Do You
a
I have the ability to publish d1 you knowr document to.
8 at this stage, the prosecutor and the Court without
9 publishing it to the public? I mean
10 THE TECHNICIAN: No.
11 THE COURT: Itrs aII going to be
L2 through the paper version, and that's going to leave

13 you in charge of that to sdY, this is what I s coming
1,4 up. Then you'I1 turn to your people and sdy' you
15 know, publish it after Irve made a ruling. Or if you
16 need him to look at it in terms before I make a
l-] ruling, then you may be abfe to do that as weII.
18 THE WITNESS: Your Honor, if I
19 may ? I have trouble reading it on the screen, too.

20 MR. McMONAGLE: What I s that?
THE COURT: Right now there Is
2l
22 nothing up there, so let's see what happens -
23 THE WITNESS: Do You have a
24 paper book for me?
25 MR. MCMONAGLE: May I approach,

1 BRUCE L. CASTOR, JR. - DIRECT 3B
2 Your Honor?
THE COURT: Yes.
4 MR. McMONAGLE: Can vte publish
5 this on the screen?
6 THE COURT: That's the Problem.
I Ask him guestions about it. This happens aIl- t'he
I time. You know, he has the document. You ask him
9 questions, establish a foundat,ion.
10 MR. McMONAGLE: A11 right.
LL THE COURT: There's got to be a
1.2 preliminary test of relevance.

I4 O Mr. Castor, please take a look at what is before

15 you. And it wiII be, for our purposes, Exhibit 3.
16 WiIl you Please tell me what it
I'l is that you I re looking for what you I re looking at
l_8 which is Exhibit 3?
19 A I believe that this is t,he initial report that

20 was taken by the police in Canada-
2t 0 Okay. And f take it you reviewed that document
22 as part of your investigation in this case, what she,
23 in fact, informed Canadian authorities of and what she
24 told them?
25 A Yes.
2 O And did you rely on it in making a determination

J in this case?
4 A Partiallyr !€s.
5 0 Okay.
6 MR. McMONAGLE: Judge, a't this
7 time I'd like to publish the document.
B MR. RYAN: And I would object.
9 As I've indicated or as Your Honor has indicated
r.0 and I have no issue with this wit.ness explaining at
1l_ this stage the underlying rationale of his decj.sion.
L2 re now getting to a Point
We I
-LJ where we're adrnitting investigative documents, and I

t4 would renew my objection that this is becoming a forum
LJ to re-]itigate the underlying case.
16 And if the witness wishes to
l7 make statemenLs about what his rationale was with
tB reqard to a charging decision, I understand Your
19 Honor's ruling as it relates to that, but this, I
20 would suggest to your is different.
2t THE COURT: Let I s start wieh
22 this. How did you get it,?
23 MR. McMONAGLE: The District
24 Attorney's Office provided it in discovery in the
25 civil litigat.ion. And it was given by the District
L BRUCE L. CASTOR, JR. - DTRECT 40
2 Attorney I s Of f ice years ago in the c j-vi] Iit igation.

3 THE COURT: So this is discovery
4 in a civil titigation to which you're now utilizing it
5 in whether Mr. Castor believed that he had sufficient
6 reason to prosecute this case. This is what he knew.
7 This $ras a statement.
8 Now, can it be used in a
9 fashion and, again, I'm just throwing this out

10 there. Can it be used in a fashion for him to look at
11 it, because the case thatrs going on here isnrt
t2 whether I think. It I s not. whether vou think.
13 MR. McMONAGLE: Yes, sir.
L4 THE COURT: Whether he had
r_5 it t s j-n time. So if he looks at something and says,
r6 yeah, I remember this, this was that statement. In
L7 order to try to at least protect this record should,
1_B you know, I rule against you, and if, in fact, a prima
l9 facie case is established, and shoul-d this case
20 survive the motions or whatever and end up with a jury
2t pool, that is really what I'm looking at here as to
22 beginning to have discovery not be published to the
23 public domain here via an exhibit.
24 I mean, I don I t want to seal
25 records and documents. I mean, it's something that
l_ BRUCE L. CASTOR, JR. _ DIRECT 41'
z hefs familiar with. He can look at it. He raises a
? very important concern, sor I mean, I don't know what

4 else you I re going to say about it.
5 MR. RYAN: WeIl, f have a
6 secondary concern which is that the document itself is

7 hearsay. I mean, it appears to be a police report.
8 So I certainly woul-d have no objection if counsel were
9 to ref resh the witness's recollecti.on with such a
10 do cument .
LL I would suggest that coul-d be a
L2 proper purpose for a subsequent question, butT again,

L3 even at the stage of admissibility, it's also a
L4 hearsay document that , for the purpose that Mr.

l-J McMonagle is intending to use it, I don't think j-s
r-6 appropriate.
L7 THE COURT: I mean, Bt this
Ld stage I just dontt know. If yourre showing it to him
L9 and you're saying that this is part of the, you know,
20 documents and t,he evidence and the intervi-ews and
2t forensic evidence that he may have had in 2005, I
22 mean, he can make reference to it. But the
23 particulars of it we're not trying this case, I can
24 telI you that. That I s not what we I re here for today.
25 And I reallv believe that I can
1
I BRUCE L. CASTOR, JR. DTRECT 42
2 make this decision based upon his testimony. If you

3 have an agreernent that cites alI this it's f iled of
4 record frm sure you would have displayed it
5 earlier. But if it's what he knew at the time, it's
6 just not I don't believe it j"s relevant to be
7 published or the Court to rely on whether he, in fact,
I had enough with al-l the documents you're going to
9 give.
10 So if you want to show him the
LL docurnents, reference the documents, ask him what they
T2 are, ask him what his reliance was, I think you can
r_3 accomplish the same thing without pub1ishing the
T4 documents to the record to where then they potentially
L5 could effect the case.
16 MR. McMONAGLE: I understand the
l7 Court's ruling.
18 THE COURT: So thatrs going to
19 be the ruling here. So he can l-ook at what you have
20 to utilize to refresh his recollection and the like as
2t to why he made decisions.

22 BY MR. McMONAGLE:
23 A l4r . Castor, Iet me f ollow up on something I asked
24 previously before we get to the exhibit. One of the

25 questions that was objected to as it was overruled was
1 BRUCE L. CASTOR, JR. - DTRECT 4S
z whether
3 THE COURT: Again, that
4 ob jection, Mr. Ryan, was sustaj"ned as to the actual
tr publishing of the document and any admission thereof.
6 It may be used for his testimony.
7 MR. McMONAGLE: Yes I'm going
8 back to something previously, .Iudge.
9 BY MR. McMONAGLE:
1n
0 I had asked the question, and I don't believe I
11 had gotten an answer from your on whether or not your
1,2 investigation confirmed whether or not Miss Constand
L3 had spoken to or tried to contact civil attorneys
1,4 before making a complaint.
15 Do you remember that guest.ion?
16 A I remember that questionr !€S.
77 0 Vlhat I s the answer ?
18 A The answer is that she reported to Ontario police
t9 that she had spoken had contacted a lawyer in
2A Philadelphia prior to speaking to thern.
2t O And vras that significant to your ultimate
22 deterrnination?
23 A Yes, that like with the exhibit when you asked
24 did I rely on that in making my decisions, a1l of
25 these vrere pieces of the things I relied on. So the
z lack of prompt complaint and the inability to gather

3 forensic evidence frorn the horne or frorn the person is
4 one piece. The contacting of a civil lawyer before
5 going to the police department is another piece.
6 0 Let me stop you there. Did Ms. Constand give
7 interviews to Cheltenham Police and also the
8 Montgornery County Detect ives in this case?
9 A Yes.
10 O Was there more than one?
l_1 A Yes.
72 0 Were the statements that she made in each of
13 those int,erviews and what she said in those
L4 interviews -- I tm not qoing to show them on the
t_5 screen, but is what she said at different times' was
16 that part of your decision making in this case?

L7 A Yes.
r-8 O And what is your rnemoryr as you at the t,ime were
L9 Iooking at these various statements, of what your
20 conclusions were about what she said?
2T A Your Honor, Irve been doing this a long time '
22 I I m wonderi-ng i f you sh ou ld hear that an swer in camera

23 f irst.
24 THE COURT: First time a witness
25 has ever asked me for something in camera. I donrt
L. CASTOR, JR. - DIRECT 45
1 BRUCE
2 know the answer to what you're about to do. He's

3 interjecting something. Do you need to speak to your
4 counsel counsel that called you in this case? Is
5 that your counsel there?
6 THE WITNESS: NO.
7 THE COURT: You said You had
I counsel here?
9 THE WITNESS: NO.
11 O Let rne ask the question about your request ' I

L2 take it this has nothing to do with you needing
13 coun seI ?
I4 A No, it doesn'! have to do with me needing

L5 coun seI .
16 THE COURT: But he's a witness
I7 and hers asked the court to hear some testimony in

18 carnera.
t9 THE WITNESS: Mr. McMonagIe , if
20 I answer that question accurately
2I THE COURT: Do rne a f avor.
22 Don I t answer the question. Go t,alk to Mr. McMonagle.

23 TeII him why you surprised him with that answer.
24 l4R. McMONAGLE : I don't think he
ZJ did.
2 THE COURT: He didnrt surprise

? you ?
4 MR. McMONAGIE: No.

5 THE COURT: WelJ., I would have
6 liked to have known back there somebody was golng to
7 ask f or an in-camera hearing. At t'his stage I r m going
B to go back to conference if people are going to answer
9 a question that they say they don't want to answer.
10 But you stay here, Mr. Castor, because it sounds like
Lt you know what he's talking about.
1"2 MR. McMONAGLE: I think he's
13 trying
t4 THE COURT: No, Do, don't. Go
l5 talk to him, find out what he's saying before I go and

1,6 talk to you. Take a brief recess.
L7
1-8 (Recess. )
,
19
20 (A conference was held in

2L chambers, not rePorted. )
22
23 (The fol-l-owing proceedings were

24 reconvened with the Court, Mr- Steefe, Mr. Ryan, Ms'
25 Gibbons-Feden, Mr. McMonagle, Mr. Tayback, Ms.
I BRUCE L. CASTOR, JR. DIRECT 47
2 Pressley, l4r. Sarl"es, and the def endant being present: )
4 THE COURT: Let the record

5 reftect that we had a conference regarding a statement
6 made by the witness that he requested something to be
7 in camera which is hiqhty unusual. I directed the
8 attorney who called this witness to find out what it
9 was and how it can be handled in a different way.
10 So we don I t have any formal
11 objections because the question waS never answered
L2 beCaUse an anshter was of f ered up, So let I s rewind a
13 little bit and start over.

L4 MR. McMONAGLE: Yes, sir.
15 BY MR. MCMONAGTE:
L6 0 Mr. Castor, obviously as part of your

t7 responsibilities, it was to, in fact, examine the
1"8 various interviews that were given by Ms. Constand; is
t9 that correct?
20 A That's correct ' Yes.
2L O And I know we're here now, but going back in 2005
22 and 2006, did you actuallY do that?
23 A Not in 2006. In 2005.
24 O 2005 you did that. And did you draw at that
25 point in time as District Attorney in this case and
1 BRUCE L. CASTOR, JR. - DTRECT 4B
2 prosecutor in this case, did you draw any conclusions

a about those statements, those various statements?
4 A r did.
5 0 And was there at that point in time, in realtime,
6 any difficulties with those statements that you saw as
7 you were making a decision as to whether or not to
8 bring a prosecut,ion?
9 A Difficulties for a prosecutor who has those
10 statements already memorialized? Yes. I mean, the
11 statements there werer &s I recall, dt least three
L2 statements: The one given to the police in Canada,
13 one given to the Cheltenham Police who were screening
.lA
It the case to determine whether it needed to be brought
15 to the attention of the District Attorney, and a
16 statement and maybe even a second statement, I
t7 canrt recall with County Detectives and Chel-tenham
18 Police.
19 There vtere a number of
20 inconsistencies among the statements that Ms. Constand
2L had given that caused me concern because I knew that
22 inconsistencies on mat.erial points would be things
23 that would affect her credibility at trial.
24 0 Were there inconsistencies about, for instance,
25 when the event happened?
2 A Well, that was
J MR. RYAN: Objection, Your

4 Honor. And pardon ffi€r Mr. Castor. ftrs the same
5 objection f f ve had.
6 THE COURT: At this stage, Iook,
7 I am not here and nobody else is here to determine
I what vras in the witness I s prosecutorial discret,ion in
9 bringing it. Okay? I am not going take a chance
10 here that now he sits here as a witness, former
1_1 District Attorney making a decision.
t2 So he has said inconsistencies.
1-3 He is allowed to make in his discretion any decisions
L4 that he wants to under certa j-n standards, and he rnade
r.5 them. So he said inconsistencies.

16 I donrt think at this stage it Is
L7 relevant to continue to point them out. If we
L8 continue, then we're going to go down a road here that

L9 is just not at aIl the focus of this hearing. It. is
20 whether there was an agreement not to prosecute.
2L MR. McI4ONAGLE : .Tudge, at leas t
22 so as I understand it based on your ruling, I will not
23 delve further into what the inconsistencies were?
24 THE COURT: Thatrs correct. He
25 can make statements, in his position as a prosecutor,

l- BRUCE L. CASTOR, JR. DIRECT 50
2 with discretion as to why he didn't.

TA THE COURT: I don I t need the
5 specifics because they arenrt relevant because I'rn not
6 making the deterrnination of whether he had basis.
7 They're not making the determination. And I assure
I you the public is not going to make a determination.
9 And I don't want to risk it being out there.
10 So he's allowed to make these
11 decisions. So let's try to keep it' and then move
L2 forward to how it connects up with an alleged

13 agreement not to Prosecute.
T4 MR. McMONAGLE: Yes, sir.
16 0 In addition to looking at the interviews of

T7 Ms. Constand, wEs there, in factr dr interview
18 conducted of [4r. CosbY?
19 A Yes.
20 O And did you evaluate that interview in coming to
2t a conclusion as to whether or not to bring a
22 prosecution ever in this case?
23 A r did.
24 o was there any searches conducted in this case at
ZJ your direction?
BRUCE L . CASTOR, JR. - DTRECT 5l-
1
2 A Yes. We searched his horne, Mr. Cosbyts home, in

J Cheltenham. And I believe he had a home in New York,
4 and I sent detectives there to search that horne.
tr
0 And did you in making your own decision factor in
6 the results of those specific searches?
7 A I did, yes.
8 O After interviewing Mr. Cosby' was Ms. Constand
9 re-interviewed to Your knowledge?
10 A Yes.
11 O And after interviewing Ms. Constand again, did
L2 you reJ-y on what you .l_earned in that intervi-ew in
13 making your decision in this case?
L4 A In part, Y€s.
r_5 O Agrain, without getting into specifics, were there
L6 things said in that finat interview that you
l7 determined were inconsistent with prevj-ous interviews?
18 A Yes, there were.
19 O AII right. So we're at a point now where yourve
20 interviewed or you've interviewed, Canadian police
21, have interviewed and when f say ttyour" itrs the
22 royal you. Itts members of the police department,
23 members of the County Detectives- Mr. Cosby's
24 interviewed. Searches have been conducted'
25 Did there come a Point in time
1 BRUCE L. CASTOR, ,JR. _ DIRECT 52
2 where you then spoke with Mr. Cosbyfs counsel?

? A Yes.
{ 0 And tel} the Court who his counsel was.
5 A Mr. Cosbyrs counsel at that time was Walter M.
6 Phillips, a very renowned criminal defense

Jt.,
7 attorney in Southeast Pennsylvania, a man for whom I
I had great respect then and do now.
9 O Obviously, Mr. Phillips has passed away?
1_0 A Yes, that I s true.

1-1 O But at that time you obviously spoke with
72 Mr. PhiIIips. And did he provide you with information
13 that was important to your ultimate determination in
L4 this case?
15 A Mr. yes. l4r. Phillips made an appointment to
16 see rl€r and he asked me to review certain possible
I7 evidence in the case or asked the detectives to review
18 certa j.n possible evidence in the case.
19 O What was that evidence?
20 I4R. RYAN: I would object, Your
2t Honor.
22 THE COURT: Do they know about
23 it?
24 MR. McMONAGLE: Of course- I
25 only know about it because they know about it.
q?
1_ BRUCE L. CASTOR, JR. DIRECT
2 MR. RYANi Perhaps I can speak

3 with Mr. McMonaqIe.
4 THE COURT: Why don't you teII
5 them what t.hey already know that they donrt know.
6
7 (Discussion off the record

8 between counsel. )
10 MR. McMONAGLE: See, I was

L1 right.
L2 MR. RYAN: Turns out I did know
13 about it, Your Honor.
t4 THE COURT: A1I right.
16 O TeIl us what that is.

17 A Mr. Phillips told me that during that. year period
L8 between the alleged incident and the reporting to the
L9 police that Mr. Cosby and Ms. Constand had had
20 multiple contacts, some in person and quite a number
2I over the telephone that would be supported by
22 telephone records if we would be able to obtain them.
23 He also told me that he
24 suspected that there had been wiretaps conducted by
25 non-Iaw enforcement Personnel during that period of
1 BRUCE L . CASTOR, ,JR. - DTRECT 54
2 time that he believed were efforts to obtain

3 incrimlnat j-ng recordings of Mr. Cosby.
4 He told rne that there were two
5 types of telephone records. And the explanation for
6 the fj-rst set of records were a series of continuing
7 banter back and forth between two people that he said
R were friends.
9 And that later he said that
L0 if we inve st igat,ed and recovered phone records and
11 possibly wj.retaps that were conducted by non-1aw
t2 enforcernent personnel, that we would concl-ude from
l_3 that that Ms. Constand and, I believe, her mother were
1"4 involved in a an effort to convince Mr. Cosby to
15 pay them money in order that he wouLd not go to the
16 police or that she would not go to the police and
T7 report him for the incident that allegedly occurred in

18 Chel-tenham in January of 2004.
19 O AII right. So let me take thern kind of one at a
20 time. With respect to did you actually

9o about
21 trying to confirm whether what Mr. PhiIlips told you
22 was true?
23 A Yes. Mr. Phillips is there was j-n my mind,
24 there was no chance at all that Mr. Phillips was lying
25 to me about the existence of records. I had known the
L BRUCE L. CASTOR, JR. - DIRECT 55
2 man for 20 years. He was a former prosecutor of a
J generation before il€, a man that did high level

4 corruption cases and import.ant government work. He's
5 not going to lie to the District Attorney.
6 So I was pretty well convinced
7 that if I directed t.he detectives to go look for those
I records, that they would be found. WhaE I would
9 conclude from t,hat I did not necessarily agree that
L0 Mr. Phillips would know the conclusions I would draw,
1_1 but I did think the records must have existed and I
L2 did tel-I the police to go find them.
l_3 0 And did they?
L4 A They dj-d, yes.
15 O And so were you able to confirm wilh respect to
L6 what Mr. Phillips told you that, in fact, there was
'J-7 evidence of extensive phone conversations that
18 occurred between Ms. Constand and Mr. Cosbv after a
19 time period in which he said she was sexually

20 assaulted?
2L A Yes. And I remember it vras in I remernber
22 thinking it was an inordinate number of contacts. And
23 sometimes, in sex crimes prosecutions especiallyr we
24 wiIl wefll generate the contact using a wiretap to

25 try to gather evidence. But there was no police
z j.nvolvement in that r so thi s was not a

3 police-initiated investigation over the telephone.
4 I also believe that we were able
J to confirm face-to-face meetings between the two after
6 the alleged incident.
-t And I believe Lhat I was made
8 aware from the detecti-ves of at least two wire

9 interceptions, what we would call here in Pennsylvania
10 hard wires where the people on the telephone are
t1 hard wires that would require approval of the Superior
T2 Court upon apptication of the District Attorney or the
13 Attorney General, and that the information contained
t4 in those wiretaps could be construed as incriminating
15 if f wanted to try to make them parts of evidence.
16 The reason f remember this so
I7 clearly is I had a great deal of experience with the
r.8 Wiretap Act here in Pennsylvania because I held the
L9 positj.on in the office that approved and applied for
20 the wiretaps and I was one of the people who helped
2t revise the act when it needed to be updated, so I had
22 a great knowledge of that.
23 And what concerned me was if we
24 were going to be abLe to use anything frorn these

25 wiretaps, what law was going to be applied because my
t BRUCE I-.,. CASTOR, JR. - DIRECT 57
recollection was the wiretaps were over the telephone.

? They were not conducted by police officers and they
4 were not neither party was in Pennsylvania at the
time the interceptions occurred.
6 Some states allow only allow
7 one-party consent. Some requi-re two-party consent.
I Pennsylvania is a two-party consent state, and I was
9 trying to figure what 1aw a court here would apply.

10 And I ul-timately determj-ned that.
l-L there were cases in Pennsylvania that said that the
T2 wiretap 1aw is to be construed strictly against the
13 Commonwealth because of its inherent importance and
T4 reliability.
15 And I thouqht that the Court in
16 Pennsylvania woul-d use Pennsylvania 1aw and,
L'l therefore, if no law enforcement was involved in
18 intercepting those ca11s, that meant that the Wiretap
19 Act was not compl-ied with and the people that had
20 committed the had done those would potentially have
2t engaged in felonious behavior under Pennsylvania Iaw.
22 And certainly if we used them,
23 we would be violating the statute that says that you
24 can't use iIlegaIIy intercepted wire communications
25 when you and make them public without yourself
qq
1 BRUCE L. CASTOR, JR. DIRECT
z committing a felony.
J 0 So just to summarize thenr ds I understand it,
4 Mr. Phillips gave you the information, you followed up
5 on it and you confirmed the fact that the cornplainant
6 in the case had extensive phone contact with the
7 defendant after a time period in which there was an
8 alleged assault. And you were concerned about the

9 fact that maybe either she or her mother had committed
10 a felony?
l_ 1_ A That was what I was concerned about.
t2 O okay.
13 A Yes.
t4 O AlI right. As a result of all that, did you also
15 take steps at that point in time to look at other
L6 alLegations as it related to Mr. Cosby?
t7 A Yes. The publicity thenr ds now, was worldwide,
1"8 and anyone who had access to television or newspapers
19 or radio media would hear about it. And some people
20 came forward and said to contacted us and said that
2t Mr. Cosby had done similar things to them that he is
22 alleged to have done to Ms. Constand.
23 O And as the District Attorney of Montgornery
24 County, did you endeavor to investigate those
25 a1 legat ions ?
1_ BRUCE L. CASTOR, JR. - DIRECT 59
2 A I delegated that. to First Assistant D.A. Ferman,

3 yes.
4 0 And did you reach certain conclusions about those
q
allegations at that time?
6 A Yes. The al] of the allegations that we had
I as of that date in February of r ds I rernember,
2 005
I hrere decades oId and they were never reported to the

9 police. This is an area of part.icular interest to me.
10 At the time we had had here

1t in Montgomery County we had had a major death penalty
I2 case reversed on this when the Supreme Court ruled
13 that a prior murder used to show a cornmon scheme, plan
14 or design for the murder we prosecuted I prosecuted
15 it personally was the Supreme Court of
16 Pennsylvania reversed that in the case of Commonwealth
L7 versus Thomas Hawkins.
l_B And in this case, while there
19 was a span of years -- f believe it was 16 years
20 between the murders -- most of that time the kill-er
21 was in prison, so he wasn't, available to go and commie
22 other murders. In that case the two murders lined up
23 almost perfectly. And the Court here allowed it, but

24 the Supreme Court of Pennsylvania reversed it.
25 O Being avrare of what the st,at.e of the law was and
'l
BRUCE L. CASTOR, JR. - DTRECT 60
2 your conclusions regarding these other allegations,

did you ultimately factor that determination into what
4 you ultimately decided j-n this case?
5 A Yes. I determined that the other crime's
6 evidence would not be adrnissible by use of the
7 probative value versus prejudicial test because they
B were t,oo remote in time to be reliable. And f thouqht
9 a Court here would not allow it.
10 O AIl right. We I ve gone over many things that you
11 examined in 2005 concerning this allegation. Do you

L2 come to a point in time after examining all these
13 things, and f'm sure nany others, where you reach a
1.4 conclus ion ?
15 A Yes.
L6 0 And what. riras that conclusion?
L7 A I decided that there was insufficient credible
18 and admissible evidence upon which any charge against
L9 Mr. Cosby related to the Constand incident could be
20 proven beyond a reasonable doubt.

2t 0 end as a resull of reaching that conclusion, what
22 did you decide to do?
23 A I -- my choices were to J-eave the case open and
24 hope it got better or definitively close th. case and
25 allow the civil court to provide redress to
2 Ms. Constand.
J On the issue of leaving the case
4 open, for example, if somebodyrs house is burglarized
5 and the police find fingerprints and they canft match
6 those fingerprints up2 they leave the case open in the
't hopes that someone wil-1 ultimat,ely be arresLed, their
I fingerprints taken and theyrll match the fingerprints
9 at t,he burglary. So the case remains open because
L0 there I s the possibility that the case could get
11 better.
L2 In this instance, I did not
13 think there was any possibility that the case could
L4 ever get better, The passage of time from the date of
15 the incident until when Ms. Constand came to the
16 police made forensic collection of evidence
L7 impossible, and it would also be impossible and could
18 never be resurrected.
19 The fact that Ms. Constand had
20 given multiple statements t,hat had inconsj-stencies
2L within them and also behavior detailed within them
22 that I thought was inconsistent with the behavior of a
23 person who had been sexually assaulted, I knew that

24 that end of the case, what Ms. Constand said, would
25 never get any better.
1 BRUCE L. CASTOR, JR. DTRECT 62
2 And in fact, her actions on her

3 own, including going to a lawyer before going to the
4 police, had created a credibility j-ssue for her that
could never be 5-mproved upon.
6 So whoever $ras si-tting at the
7 table here in front of me would never be abl-e to
I repair that credibility damage. I concluded that
9 those elements oh, and I -- f concluded that
1"0 because of the international publicity, and all $re got
11 from that was very old statements from people who I
1.2 could possibly have used as common schemer plan or
13 design evidence, none of them had gone to the police.
T4 And I didn't think that that. end of the case would
ever get any better because the prejudicial effect
I6 would always the probative value would always fail
T7 to be to overcome the prejudicial- effect.
18 Not reporting it to the police
L9 was a the other people who came to usr by not
20 reporting those instances to the police ever until
2L they heard about this and decades going by, led me to
22 conc.Lude that that possibility of using common scheme,
23 plan or design was never going to get any better.
24 So f carne to the conclusion
25 thatr urrlike t.he example I gave about the fingerprint
l_ L. CASTOR, ,JR. - DTRECT
BRUCE 63
2 when your house is broken into, that there was no way

3 that the case could ever improve and get better with
4 time absent Mr. Cosby confessing.
5 At that point I concluded it was
6 better for justice to make a determination that Mr.

't Cosby would never be arrested. I did that because of
I the rules that there I s special rul-es that
9 prosecutors have to operate under.
r-0 And while defense counsel are
L1 supposed to do everything that is within their ability
t2 legally and ethically to represent their client
13 vigorously and try to avoid a conviction, the
I4 prosecutor, according to the Pennsylvania Rules of
15 Disciplinary Pennsylvania Disciplinary Rules for
L6 Lawyers, says that the prosecutor is a Minister of
L7 Justice.
18 And I did not believe it was
I9 just to go forward with a crj-minal prosecution, but I

20 wanted t.here to be some measure of j ust ice . So I made
2l the final determination as the sovereign. You
22 understand I am not Bruce Castor, the District.

23 Attorney. I am the sovereign Commonwealth of
24 Pennsylvania when I arn making these decisions.
25 And as the sovereign, I decided
1_ L. CASTOR, JR. - DTRECT
BRUCE 64
2 that we would not prosecute Mr. Cosby and that would

3 then set off the chain of events that I thought as a
4 Minister of ,Justice would gain some justice for Andrea
q Constand.
R,
0 How so?
7 A The Fifth Amendment to the United States
8 Constitution states that a person may not be compell-ed
9 to give evidence against themselves. So you can't
10 subpoena somebody and make thern testify that they did
l1 something illegal or evidence that would fead
L2 someone to conclude they did something illegal -- on
1-3 the threat of if you don't answer, you'11, be subject
L4 to sanctions because yourre under subpoena.
1q So the way you remove that from
16 a witness is if you want to, and what I did in this
l7 case is I made the decisj-on as the sovereign that
18 Mr. Cosby would not be prosecuted no matter what. As
19 a matter of law, that then made it so that he could

20 not take the Fifth Amendment ever as a matter of Jaw.
27 So I have heard banter in the
22 courtroom and in the press the term "ag'reement.r't but
23 everybody has used the word wrong. I told
24 Mr. Phillips that I had decided that, because of
25 defects in the case, that the case could not be won
-L BRUCEL. CASTOR, JR. - DTRECT 65
2 and that I was going to make a public statement that

? ere were not going to charge Mr. Cosby.
:
A
f told him that f was making it
q
as the sovereign Commonwealth of Pennsylvania and, j_n
6 my lega1 opinion, that meant that Mr. Cosby would not

7 be allowed to take the Fifth Amendment in the
8 subsequent civil suit that Andrea Constand's lawyers
9 had told us they wanted to bring.
r0 Mr . Phi t I ips agreed wi t.h me that
t_ l_ that, is, in fact, the law of Pennsylvania and of the
L2 United States and agreed that if Cosby was subpoenaed,
13 he would be required to testify.
14 But those two things were not
1_5 connected one to the other. Mr. Cosby was not getting
15 prosecuted at all- ever as far as I was concerned. And
L7 my belief was thatr ds the Cornmonwealth and the

18 representative of the sovereign, that I had the pohrer
19 to make such a statement and that, by doing sor as a
20 rnatter of law Mr. Cosby then would be unable to assert

2L the Fifth Amendment in a civil deposition.
22 Mr. Phillips, a lawyer of vastly
23 more experience even than me and I had 2A years on
24 the job by that point agreed with my legal

25 assessment. And he said that he would communicate
2 that to the lawyers who were representing Mr. Cosby in

? the pending civil suit.
4 O Okay. So then, to summarLze, you've indicated
5 that considering the fact t.hat you were a Minister of
6 ,Just,ice and based on your evaluation of the case and
7 what you had hoped to accomplish, you inforrned
B Mr. Phillips that Mr. Cosby would never be prosecuted
9 for the allegations made by Ms. Constand; correet?
10 A Correct.
r_1 0 And you did so for the specific purpose of making
L2 sure that Mr. Cosby could not, assert the Fifth
1-3 Amendment in any subsequent civil proceedings as they
L4 related to Ms. Constand?
15 A For all time, y€s.
L6 O And both of those decisions were for al-l time,
L7 you acting as sovereigni is that fair?
18 A That is that's the truth.
19 O After Mr. Phillips told you that he would honor
20 your decision and what you had informed me that you
2L rirere going to do in never prosecuting Mr. Cosby f or
22 the Constand crime, did you then take steps to provide
23 some type of formal document that would tell- the
24 public and would tell the parties what you had
25 decided?
.,1
I BRUCE L. CASTOR, JR. - DIRECT 67
2 A The premise of your question contains an error.

? Mr. Phillips never agreed to do anything in exchange
4 for Mr. Cosby not being prosecuted. What he agreed to
5 was my legal analysis was accurate and that, he would
6 telI the lawyers representing Mr. Cosby that Bruce has
7 the legaI knowl-edge correct and that he would affirm
B that he also agreed with that.
9 And, frankly, neither one of us
10 thought it &ras that hard a concept to understand

11 because once the Fifth once the possibilit,y for all
1,2 time of being prosecuted is removed, the ability to
13 take the Fifth Amendment is also for all time removed.
L4 0 And that was your intent?
15 A That was absolutely my intent..
16 O And you communicated that intent to Mr. Phitlips?
t7 A r did.
18 O Okay. Moving on now to, f guess, the next step,
19 did you inform all of the parties of your decision in
20 this case not to prosecute Mr. Cosby? And when I say
2t oyour' f mean you or your office.
22 A I told Mr. Phillips, I told First Assistant D.A.
23 Ferman, and I directed her to contact Constandrs
24 lawyers. She had earlier in this whole process,
25 she had told me the First Asslst,ant had told me
BRUCE 68
2 that she knew one of the lawyers from school, And I

J assigned her the duty to liaise between the victim and
4 her lawyers and the D.A.rs office.
5 So f asked First Assistant D.A.
6 Ferman to communicate the decision to Constandrs
7 Iawyers that Cosby was not going to be prosecuted and
8 that the purpose for that was that I wanted to create
9 the atmosphere or the legal conditions such that Mr.
J-IJ Cosby would never be allowed to assert the Fifth
11 Amendment in the civil case because I thought at the
L2 time I still think that making Mr. Cosby pay
13 money to Ms. Constand vras the best I was going to be
t4 able to set the stage for because a criminal
15 prosecution, in my professional judgment, was not
t6 viable and never would be.
t7 0 At some point did you take steps to issue a press
18 release in this case?
19 A Yes. Yes, I did.
20 O At I right . I f !{e could go
2L THE COURT: You want to take a
22 break here?
23 MR. McMONAGLE: Sure, Judge.
24 THE COURT: I intend to go until
z5 t2:30, so I will give at this stage a LO-minute break
l_ BRUCE L. CASTOR, JR. - DIRECT 69
2 so that we're back and wit,nesses will testif y until

3 about 12:3A, and then we'll take our Luncheon break
4 which will be about an hour.
5 So please, members of the public
6 and to the pressr you've been extraordinary in your
'l cooperation and I know that you'II continue to do so.
I So you'11 continue to abide by the Decorum order.
9 This is a scheduled break,
10 again, but we will be picking back uP at by that
t_1 clock on t,he wa1} t.here at 11:40. So you better be in
I2 your seats because the Decorum Order will take over.
r_3 So we are subject to the call- of the crier, but we
t4 intend to start at 1- 1:40.
t5
r6 (Recess. )
t'7
18 (a conference was held in
19 chambers, not rePorted. )
20
2L (The following Proceedings were

22 reconvened with the Court, Mr. Steele' Mr. Ryan, Ms.
23 Gibbons-Feden, Mr. McMonagle' Mr. Tayback, Ms-
24 Pressley, Mr. Sarles, and the defendant being present:)
25
i
-L BRUCE L. CASTOR, JR. - DIRECT 70
2 THE COURT: AIl right. You may
3 resume the questioning.

4 BY MR. McMONAGLE:
5 O Mr. Castor, I believe before we broke I was
6 asking you about whether you issued a press release.

7 A I did, yes.
I MR. McMONAGLE: If I may
9 approach, Your Honor?

10 THE COURT: Yes. Again, if I
11_ don I t respond, you may keep moving.
L2 MR. McMONAGLE: frm going to ask
r-3 this be marked as D-4, Judge.
t4 (Press Release dated 2-17-05
r-5 marked Defendant's Exhibit D-4 for identification.)
L'7 O Mr. Castor, please take a look at what's been

r"8 rnarked for identification as D-4 and tell- me if you
r-9 recoqnize that document.
20 A Yes.
21" THE COURT: Do you have a book
22 for me?
23 MR. McMONAGLE: Itts going to be

24 on the screen in two seconds.
25 THE COURT: Not until I say it
1 BRUCE L. CASTOR, JR. - DTRECT 7l
2 is. This Irm abrare of .
J MR. McMONAGLE: Werve got an

4 agreement coming forward with t,he rest of these,
5 ,Iudge, with your permission. we tried to work that
6 out during the break so we can move.
7 MR. RYAN: Your Honor, if You
I want this book, I have it right here.

9 THE COURT: If You have an
10 agreement .
11_ BY MR. MCMONAGLE:
T2 O Mr. Castor, taking a look at Defense-4, do you

t_3 recogn j- ze that document ?
L4 A I do.
15 O And what is it?
l6 A It is a photocopy of the original press release
t7 that, I issued actually, I personally issued on
t_B February 1 7th , 2005 .
t-9 O What do you mean 'personally issuedu?

20 A WelI, it was kind of a weird situation because
2I ordinarily I would not author a press release
22 personally. And ordinarily I would give it to the
23 First Assistant to see that it was released.
24 First Assistant D.A. Ferman at
25 that time had, I believe, three children and left
1 L. CASTOR, JR. - DIRECT
BRUCE 72
2 before the tirne I was going to be able to release it,

.(
so I had to figure out how to do it myself, which
4 everybody wil-t laugh today, but in 2005 I did not know
5 how to use attach a document to e-mail, so it was
6 all going to be faxed.

I And so I typed it mYself. ft
I took quite a long time to get it worded just the way I
9 wanted it . And I s igned it . And t.hen I was
l_0 responsible for sending out the faxes because I was --
l1 actually, you had to put the paper in the machine so
L2 it would come out, on the letterhead. Now we don't do
1? it t.hat way.
1"4 0 You're right, we're laughing. A11 right. Let me
l-5 ask you a guestion. How long did it take you to put
16 this press release together? I don't mean faxing it
L7 and figuring out how you were going to transmit it,
18 but preparing it.
19 A It took me several hours.
20 0 And would you say that you exercised great care
2t in the preparation of this document?
22 A That would be an understatement.
ZJ O And why would it be an understatement?
24 A f was writing this fot three audiences. I was
25 writing it for the general consumption of the media

1
L. CASTOR, JR. - DTRECT
BRUCE 73
.)
4 who would then transmit my decision to the world. I
J knew that the media would read it through the lens of
4 wanting to inform t.he public of what the outcome was,
q
but they would not parse the words because that I s not
6 a reporter's job. A reporter's job is to inform in
7 the big picture.
I So I wrote it in such a brav that
9 I knew what the reporters would take from it, but I
L0 knew they also wou.ldn I t read it as a lawyer would read
l_1 it. I wrote it for the greater legal community who I
T2 assumed would be analyzing my decision and would read
L3 it as a lawyer would read it, attaching meaning to
L4 every word and every sentence in context.
r-5 Then f was writinq it for the
L6 litigants to 1et them know that I did not want the
L7 case tried in the press anymore and f wanted them to
l_8 go into the civil court and resolve their differences
t9 without so much rhetoric.
20 And it was a warning to the
21. litigants that if they did not heed my advice to stop
22 making public pronouncements and speeches and press
23 events, that I would reeall the national media to my
24 office and explain my reasoning for why I didn't

25 approve a prosecution of Mr. Cosby.
2 On that 1a st point, the ent j-re

3 Eastern District of Pennsylvania Federal Court is
3t wj-thin the Philadelphia media rnarket . In 20 05 my
5 words would have been heard by vj,rtually every

6 prospective juror in the civil case.
7 What I did not want those
8 prospect,ive jurors to hear, since I had already
9 decided that I wanted Mr. Cosby punished in the civil
L0 court, I did not want them to hear that District
11 Attorney Castor had serious doubts concerning the
12 credibility of Ms. Constand because I did not want to
13 mess up the carefully laid plan that Mr. Cosby would
l_{ be punished by having to pay money for what he had
15 done.
t6 O And to that end, did you fashion this press
T7 release ?
18 A r did.
19 I4R. McMONAGLE : Could T, Your
20 Honor, have this published at this time?
2L THE COURT: YCS.
22 MR. McMONAGLE: Thank you, sir.
23 (Defendant's Exhibit D-4
24 published. )
25
1- BRUCE L CASTOR, JR. - DIRECT 75
2 BY MR. McMONAGLE:
? O Mr. Castor, taking a look at this press release,

I it is two pagesi correct?
q
A There is another paqe Lhat's not here where I am
6 telling the media that if they didn't get the fax, to

7 go to the website.
I v Okay.
9 A That's not here.
L0 0 But in terms of the actual substance which
11 precedes your signature, is it on here?
L2 A It is. The significance of the last page is it
r-3 has the ti.me where I completed it
1,4 0 Iunderstand. funderstand.
15 A which I believe was 5:45 or something.
16 O If we could get the first page uP, I want to go
t7 through this, I know the document speaks for itself,

18 but I just want to go through it,
L9 paragraph-by-paraqiraph. Yourve told us you took a
20 great deal of time to prepare this document.

2L Paragraph 1 of this document, it
22 just basically references the fact that there was a
23 joint investigation that went on into allegations

24 against actor and comic Bill Cosby and that it was
25 concluded; is that fair?
2 A Yes.
3 0 The second paragraph relates to Ms. Constand;
4 correct ?
5 A Yes.
6 0 And in it you describe her, that she was a forrner
7 employee of the Athlet,ic Department of Ternple
8 University and that she had complained to detectives
9 that Cosby touched her inappropriately during a visit
10 to his home in January of 2004; is that correct?
1_1 A Yes.
l2 0 You document in that second paragraph that she
13 reported the allegation to her native Canada
t4 January 13th of 2005?
15 A Yes.
16 0 I take it it was important, at least for your
I7 consideration at that point in time, to show the time
l-8 lapse that had actually lapsed between the so-called
19 event and the complainti correct?
20 A Precisely, to dernonstrate t,he lack of prompt
21 complaint.
22 O And then you also there indj-cated that Canadian
23 authorities had turned it over to Philadelphia Police
24 which, of course' we know is true; correct?
25 A Yes.
1 BRUCE L. CASTOR, JR. - DIRECT
2 O You then put in Paragraph 3 that everyone
? involved in this matter cooperated with investigators,
4 including the complainant and Mr. Cosby, and this
5 Level of cooperation has helped the investigation
6 proceed smoothly and efficiently. The District
7 Attorney commends all parties for their assistance.
I Why did you put that paragraph
9 in there?
l-0 A I put that in there becausef in the civil case, I
11 wanted the jurors in that case potential jurors in
L2 that case to think that everybody did what they were
13 supposed to do in dealing with the police and draw no
L4 adverse inference between either side.
r-5 0 And that was important to you?
t6 A It was very important to r yes.
rl€
t7 O Your goal being, I take it, that Ms. Constand be

18 able to obtain som'e success i-n her civil case?
L9 A Right. And the idea, of course, is, as I was
20 weighing the scales frorn the crimj-na1 perspective, the

2t scale tumbled way down in favor of Mr. Cosby and
22 against l'1s. Constand.
23 I thought by including that
24 paragraph, I would be telling jurors that everybody
25 talked to the police and cooperated with the police,
1 BRUCE L. CASTOR, JR. - DTRECT 7B
2 so nobody should draw a negative conclusion against

? Mr. Cosby or against Ms. Constand just because I
4 decided not to arrest Mr. Cosbv.
5 0 So arn I to understand then that it was your goal
6 not to adversely affect Ms. Constand j-n the civil case
7 by not bringing this criminal prosecution?
I A YeS.
9 A In Paragraph 4, the District Attorney has

r_0 reviewed the statements of the parties involved, those
11 of alI witnesses who rnight have firsthand knowledge of
L2 the alleged incident including family, friends, and
13 co-workers of the complainant, and professional
t4 acquaintances, and employees of Mr. Cosby.
15 You put that in there?
L6 A r did.
1,7 O And was that, in factr dccurate?
18 A It was.
19 0 Detectives searched Mr. Cosby's Cheltenham home
20 for potential evidence. Investigators further
2L provj-ded District Attorney Castor with phone records
22 and other items that might have evidentiary vaIue.
23 You referenced that. You
24 thought that important to this press release?

25 A Yes. In the first sentence, I the code word,
2 if you wil1, that, I expected lawyers and the litigants

3 to pick up on was "firsthand knowledgerr because
4 whisper-down-the-lane hearsay I did not consider.
5 And I wanted people to know that
6 inadmissible hearsay was not part of anything that f
7 consi-dered, but I did consider firsthand knowledge.
B O You al-so referenced phone records in this same
9 press release; am I correct?

10 A In the next in the third sentence I Im
11 sorry. The reason I used the phone records is I knew

I2 that the Iitigants were aware of the significance of
13 the rnultiple phone contacts between the complainant
t4 and Mr. Cosby, but that the press would read over that
1"5 and not hiqhlight it.
r_6 And f donrt think that thev ever
t7 did, but f thought lawyers examin5-ng t,his would
18 conclude that those phone records might be detrimental
19 to the successful prosecution.
2o And then I used the nebulous
2L term'and other items that might have evidentiary
22 value" because I did not want to say that I had
23 concl-uded that there btere il-l-ega11y obtained wiretaps
24 in the case because I did not want anybody to think
25 that. Ms. Constand, her mother t ot anyone else invoLved
1 BRUCE L. CASTOR, .JR. _ DIRECT BO
2 in those in the production of those wiretaps had

? done sornething illegal because I, again, didn't want
4 prospective jurors to conclude that Ms. Constand was a
5 bad person and therefore hold it against her in the

6 civil case we all knew was cominq.
7 O The last sentence in that paragraph reads:
8 Lastly, the District Attorney reviewed statements from
9 other persons claiming that Mr. Cosby behaved
t0 inappropriately with them on prior occasions.
1L Why include that in the press
72 release?
r_3 A Because with the publicity, we had some people
L4 that had contacted us saying that they had been
t5 mol-ested by Mr. Cosby. And Flrst AssisEant D.A.
16 Ferman revi-ewed those statements and then forwarded
L'1 them to me.
1-8 And I wanted the public I

r9 wanted the public to know that we didn't ignore the
2A fact that we had that information. We, in fact, did
2L look at them and consider whether they were of
22 evidentiary value.
23 O And then to the next paragraph, which actually
24 speaks to that: Howeverr the detectives could find no
25 instance in Mr. Cosby's past where anyone complained

t- BRUCE L . CASTOR, ,JR. - DTRECT 81-
z to l-aw enforcement of conduct which wourd constitute a
{ criminal- of f ense.
4 You wrote that and you thought
5 that was of significance to write?
6 A Yes. I wanted, again, the anybody who thought
-1
that these other reports were of value, evidentiary
tt value to the Commonwealth, to real-ize that we tried to
9 dj.scern whether there $ras any way to enhance their
l_0 probative value. And the best way to enhance their
11 probative value is if they went to the police and had
L2 given statements.
1-3 And I asked the detectives to
1,4 Iook for them, and there were no statements that I
15 recall that they were able to find where the event
L6 occurred that the other complaining witnesses were
L7 saying with Cosby and then that other complaining
18 witness wenL to the police.
L9 So to the masses who were going
zv to read the media accounts, it was simply to be read
2L on its face, that yeah, those guys looked at this
22 issue, but they decided it wasn't of value because
23 they hadn I t been reported to police.
24 I thought the greater legaI
25 community would say that I was applying the Rules of
1_ L. CASTOR, JR. - DTRBCT
BRUCE 82
2 Evidence knowing that a judge would not admit that.

? And I was communicating to the litigants that if they
4 went down that road, it was my opinion that they would
5 not be able to get that information in.
6 O Okay. And for that end then, that last I
7 shouldn I t say the last paragraph. The second to Iast
B paragraph and it's a lengthy one if you're okay
9 with it, I'm going to paraphrase it.
10 You do, in fact, in that
11 paragraph discuss your consultations wit.h other
t2 members of your team. You discussed your findings,
13 that there was insuf f icient. t cxedible and adrnissible
L4 evj.dence that exists upon which to bring any charge
IJ against Mr. Cosby which could be sustained beyond a
t-6 reasonable doubt.

L7 And then you in a rather general
18 fashion discuss facts and elements of the offenses,
L9 criminal intent, the RuIes of Evidence, the
20 admissibility of evidence, and then, fLnally, conclude
2t with: After this analysis, the District Attorney
22 concl-udes that a conviction under the circurnstances of
ZJ this case would be unattainable. As such, District
24 Attorney Castor declines to authorize the filinq of
25 criminal charq'es in connection with this matter.
2 I rve summarized that correctly?

3 A Yes. There are a lot of things in that paragraph
4 that are to be read on different leve1s.
5 O f understand. I want to get to the last
6 paragraph. The last paragraph you actually begin
7 with: Because a civil action with a much lower
8 standard of proof is possible, the District Attorney
9 renders no opinion concerning the credibility of any
10 party involved so as not to contribute to the
L1 publicity and taint prospectj-ve jurors.
l2 Did I read that correctly?
r.3 A You did.
14 O You saw fit at that time, recognizing your goal I
r_5 take it, of making sure that there was at at least in
L6 some measure, successf ul reso.l-ution f or Ms. Constand.
1-7 You made sure that the public, the potential jurors in
L8 that case would not be affected by the fact that you
t9 didn't bring a prosecution.
20 Is that a fair way to summarize
2L that ?
22 A It is, but there's an addition. At that point I

23 dontt want to tell the public that I thought Andrea
24 Constand had compromj-sed her credibilit.y because I
25 didn't want her to be vilified publicly because, A, f
I
L. CASTOR, JR. - DIRECT
BRUCE 84
2 thought that was unfair to her.

3 But therers a broader reason,
4 and that was that I wanted I wanted to encourage
5 people to come forward if they're sexually assaulted
6 or assaul-ted in any way. And what I didn I t want to
7 have happen is this high publicity case act as a
8 deterrent for people who are molested going to the

9 police.
10 And if I had written in there
11 the reason why I didn I t think the case should go
I2 forward in explicit terms that were easy to

13 understand, I was afraid that other victims would say
T4 look what happened in that case, if theytre abused,
15 I'm not going to the police because now this woman is
1.6 being vilified by the very people who are supposed to
17 be protecting her.
18 O Okay. And then it gtoes on: The DistricE
19 Attorney does not intend to expound publicly on the
zv details of his decision for fear that his opinj.ons and
2T analysis might be given undue weight by jurors in any
22 contemplated civil action.
23 And youtve obviously spoken to
24 that previously. And then it says: District Attorney
25 Castor cautions all parties to this matter that he
1 L. CASTOR, JR. - DIRECT
BRUCE 85
2 wiII reconsider this decision should the need arise.

J Did I read that correctly?
4 A You did.
5 0 And what was your intent in writing that?
6 A That was telling primarily Andrea Constandts
7 lawyers, but also WaIIy PhiIlips, that if they went
8 out in the media and criticized the D.A.'s office for
9 our decision, I was then going to caI] the press back
L0 and explain what I have explained here i-n court, that
1l- Andrea Constandrs own act.ions during that year ruined
'1,2 her credibility as a viable witness to win the case.
L3 If I had said that, the civil
L4 case woul-d have been severely hampered because, back
15 j-n 2005, what f said on the matter of Iaw enforcement
L6 in the Philadelphia media rnarket was generally
I7 accepted by the public as accurate and true based on
18 lengthy years of service and successful prosecutions

r.9 that I had brought. Thatrs a warning.
20 0 So as I understand it, yourre warning both sides
2L don't take advant,age of this decision one way or the
22 other and go about your business in the civil realm
23 and do it the right way?
24 A Correct -
25 O Contextually the next sentence reads: Much

1 L. CASTOR, 'JR. - DIRECT
BRUCE 86
2 exists in this investigation that couLd be used (by

J others) to portray persons on both sides of the issue
4 in a less than flattering liqht.
A I don I t know how I could have been any clearer.
6 Irm not speaking to the general public there or even
7 to the greater legal community. Irm speaking directly
I to the litigants, the complainant and Mr. Cosby.
9 And Irm saying that we have put
10 together and documented things that would make the
t_ 1_ married Mr. Cosby look bad to the world, a man whose
L2 reputation at that time, f'm sure, and probably sti11,
l_3 does mean something to hirn. And I am telling Andrea
I4 Constand and her lawyers that we documented a number
L5 of things that would make her not look good in public.
t6 So I was saying that everybody
t'l better keep their mouths shut because you don I t want
18 Lhose things out there because that would put a monkey
T9 wrench into the success or failure of the civil case.
2A O Which, in fact, Vou speak to in the last sentence
2L of this paragraph: The District Attorney encourages
22 t.he parties to resol-ve their di spute f rom thi s point
23 f orward with a rninimum of rhetoric.
24 A Earlier in my testimony I said that, I detailed
25 First Assistant D.A. Ferman to act as Iiaison wit,h the
1 BRUCE L. CASTOR, JR. - DIRECT B7
2 constand side. That was because one of the lawyers on

3 the Constand side, f believed, was trying to influence
4 rne by extrajudicial statements in the media, and I
5 didn't like that.
6 And f was in this paragraph
7 telling those lawyers and Mr. Cosby and his Iawyers
B t,hat that as far as the crirninal matter is concernedr
9 it I s over. We have other methods in America to
L0 redress grievances.
t_ l_ In the civil court, I have
1.2 created a scenario where you'11 get a statement frorn
r_3 Mr. Cosby under oath with all the extra discovery that
L4 is alLowed in civil- cases that you don't. have in
1.5 criminal- cases, and t.hat, was al-1 I was going to do.
t6 0 And you did thatr ds I understand your testimony,
1,7 by making a decision and informing Mr. Phillips of a
1_8 decision t,hat Mr. Cosby would never be prosecuted?
19 A Thatrs correct.
20 O Did you find out that your hope, your goal of a
2t civil suit being brought was, in factt taalized, heck,
22 three weeks after the press release?
23 A Yes. ft was reported in the newspaper and in the
24 lega1 publications that I readr so I saw that the
25 civil suit had been brought. I had no doubt that it.
2 would be brouqht.
? And once f had decided that
:
A
there could not be a prosecution that would be viable,
I operated under the certainty that a civil suit was
b coming and set up the dorninoes to fall in such a way
7 that Mr. Cosby would be required to testify.

8 O And ult.imately do you learn that, in fact, not
9 only does that not happen, that there I s a civil suit
L0 here that Mr. Cosby does testify, and that ultimately
1t- that J-awsuit is settled?
L2 A I read the I read the Complaint. Somebody had
L3 sent me the Complaint. I think maybe a reporter. And
T4 I -- now, of course, the civil Complaint is written in

15 the }ight most favorable to the plaintiff, and it
16 contains in it the things the plaintiff hopes the
L7 plaintiff is going to be able to prove at a civil
18 trial.
19 But I remember smiling to myself
20 thinking t,hat if I could have proven all of those
2L things, Mr. Cosby would have handcuffs on him right
22 now. But I later learned that the case was settled'
23 but f donrt know how.
24 0 While it's up on the screen and I'11 have it
25 taken off the screen the press reLease that we
2 referred to, you actually signed it; is t,hat correct?

J That's your signature?
4 A That i s, yes .
5 O Was that typical for you to do? And if it was or
6 wasnIt, nhy did you sign it in this case?
7 A f don't recollect that f generally signed them.
B This was so unusual for me to actually be the one who
Y wrote it that I don't remember wbether we signed them

10 routinely or not.
1L But I remember in this case I
t2 absolutely signed it. And I used my title because I
r_3 intended that this was t.he decision of the sovereign,
T4 the District Attorney being the Commonwealth of
J-J Pennsylvania, and therefore the representative of the
16 sovereign.
1,7 O You talked about the Cornplaint, and I want to
18 kind of rnove f orward. At some point in time you come
19 to the realization that that lawsuit that you had

20 hoped would occur is settl-edr'is that fair?
2L A Yes.
22 0 All right. Now, let me ask you this. At any
23 point in time from the time you signed that press
24 release until you Ieft as District Attorney, did you
25 ever take any steps, any efforts to investigate the
I BRUCE L. CASTOR, JR. _ DIRECT on
Z civil case, obtain documents from the civil case,

3 obtain depositions from the civil case or anything of
.l the Iike ?
q
A No. I directed that the office cooperate with
Ms. Constand in providing discovery materials without
7 any hassle, but I did not do anythirg, nor direct
I anyone, to continue the criminal investigation because
9 the criminal investigation was dead by virtue of the
L0 decision I made as the representative of the sovereign
L1- that Mr. Cosby would never be prosecuted.
1,2 0 And to that point, that decision that he would
13 never be prosecuted to your knowledge, after you
t4 Ieft, Miss Ferman became District Attorneyi is that
l-5 correct?
16 A Yes.
L7 O And she becomes District Attorney in 2008;
18 correct ?
19 A Yes.
20 o 2008, 2009, 20\0, 20Lr, 2012, 2013t 2014, to your
2L knowledge, did District Attorney Ferman do anything to
22 conduct an additional investigation of a case that you
23 had already determined and promised would never be
24 prosecuted?
25 A Not to my knowledger Do.
1 BRUCEL. CASTOR, JR. - DIRECT 91
2 O Okay. The finalization of that civil case, did

3 it allow you to conclude, based on what you knew about
4 it and what you read about it, that, in fact, after
5 you had informed Mr. Phillips that you were never
going to prosecute Mr. Cosby so that he could and
7 woul-d have to give up any opportunity under the Fifth
tt Amendment to not be imposed, that he, in fact,
9 followed through with that and that Mr. Cosby was
10 deposed as you had hoped?
t_ t_ A Ms. Constand followed through with it as I had
t2 hoped and filed a civil suit, put a subpoena on Mr.
13 Cosby to testify, and he did so.
I4 O Okay.
15 A The matter was resolved and I was hopeful that I
16 had made Ms. Constand a millionaire.
T7 O Okay. And so tirne moves f orward. You obviously
18 Ieave the office. You've discussed with us vour
1.9 career subseguent to that.
20 Does something happen in the
2I Summer of 20L5 that allows you or causes you to become
22 aware of, again, somethinq involving the Cosby case?
23 A Yeah. ft was the second time though. But the
24 the second I recaIl three tirnes having the natj-onaI
25 media descend upon ne on Cosby without warnirg,
1_ BRUCEL. CASTOR, JR. - DIRECT 92
2 because obviously we're giving it a great deal of

? attention now and the Court is hearing a motion.
4 But other than other t,han
5 when some comedian makes some joke about Cosby being a
6 sexuat predator or a rapist or something, I never gave
7 the case another thought.
I And I don't recall giving any
9 interviews until that time or thinking anything other
10 thanr ds a Minister of rf ustice, I had done the best
11 that f couId.
T2 So in, I think it was, November
13 of you said ' 15, but I think it vtas November of
I4 '74, the joke comes out and three days of my life are
1_5 spent explaining to the media what the situation $tas
1,6 from back in 2005.
t'7 I felt that since I was stilI a
18 public official and I was still part of the same
1_9 qovernment here that I had to respond-

20 O Okay. Let me interrupt you because I want to try
2T and. hustle along here in terms of getting us to some
22 of the issues that we're raising.
23 THE COURT: Do me a favor
24 because he corrected a question that presurned a date.
25 The question, f read it as Summer of 2015 '
o?
l_ BRUCE L. CASTOR' !TR. - DIRECT
2 MR. McMONAGLE: Okay.
3 THE COURT: He I s now talking
.'A about November of '14.
5 MR. McMONAGLE: Yeah.
6 THE COURT: So did
'1 BY MR. McMONAGLE:
I O I had asked you a question about learning of

9 something in the sumrner of 2015. You I re offering
l_0 something in the sumrner of 20!4, which is why I was
1"1 movi_ng him along, but I don I t want to interrupt your
1.2 answer.
r_3 THE COURT: I just want to be
1"4 clear. Is it you learned Something in Summer of 2OI4

15 and then, in Novernber of 20L4, three days of
16 something? Irm just trying to be clear on the dates
1-7 here.
18 THE WITNESS: No. In November
t9 of 2014 the case the case exploded onto the
20 national media scene and I addressed questions as they
2T came in.
22 There was then a second time
23 when information was released in the Summer of 201-5
24 where I was, again unexpectedly, drawn into the
25 maelstrom of the CosbY case.
2 BY MR. McMONAGLE:
? O And what wa s t.hat ?
4 A f never did completely understand the procedural

5 aspects of what happened, but evidently, according to
6 what I read and what reporters told ft€r a judge, a
7 Federal District Court judge released or unsealed
8 portions of the of some of the deposition testimony
9 that Mr. Cosby had given in the original 2005 civil
10 suit.
r.1 And contained within the portion
I2 that was released were statements that could be used
13 as incriminatinql statements in a criminal prosecution
T4 had we had those back in 2005.
15 O Got you. And at some point do you find it
16 necessary to contact the Montgomery County District
t7 Attorney's Office in any way about that particular
18 subject?
79 A Yes. I think it's important to point out that
20 the District Attorney's Office did not consult with me
2T on anything that went on in the Cosby case. They were

22 doing their job as the law enforcement arm, and I was
23 doing my job as the legislative and executive arm for
24 the county. So itrs not like they're asking ny
25 advice. They're doing their own thing.
2 So I don t t know what thev're

3 doing, but it gets reported in the newspapers that
4 the as a result of the Cosby the unsealing of
5 the Cosby deposj-tion, that the case has been the
6 criminal case as it reLates to Andrea Constand had
7 been re-opened.
I And I read numerous report s that
9 said that. I had learned that it had been re-opened,
10 but I never actuallv did learn that unti-l he was
11 arrested. What I learned was that there was
t2 specul-ation in the nevtspapers in September of 2015
13 that Mr. Cosby might. be arrested imminently.

L4 0 What did you do as a result of that?
15 A f knew that I had bound the Commonwealth as the
1"6 representative of the sovereign not to arrest Mr,
1,7 Cosby. And at the time District Attorney Ferman was
l_8 running for judge of the Court of Common Pleas, and I

19 wanted to rnake sure that she didn I t make a mistake and
2A go ahead and move against Cosby and it turn out that
2t she shoul-d not have done so and af f ect. her election.
22 O And with that in mind, what did you do?
23 A I wrote her an e-mail explaining the situation
24 frorn 2005 to tell her to tread carefulJ-y here because,
25 in my opinion, she was exposing the county and herself
2 to civil Iiability because the decision on whether to

3 go forward in Cosby was put to rest by my decision in
4 2005. And I went in some detail about that, so that
5 she would have it on record.
6 (E-mail dated September 23, 2Q15
7 to Risa Ferman from Bruce Castor marked Defendant's

8 Exhibit D-5 for identification.)
9 MR. McMONAGLE: Judge, with your
l-0 permission, Ird like to apProach.
t-1 BY MR. MCMONAGLE:
L2 O Itrn going to show your Mr. Castorr whatrs been

13 rnarked for identification as Defense-5 and ask Your
14 first and foremost, if you recognize that document?

r.5 A I do.
15 O And what is it?
L't A This is an e-mail that I sent from home because I
1B was off that was my wedding anniversary that day
19 to Dj-strict, Attorney Ferman at her Montgomery County
20 D.A. rs Of f ice address.
21" And I signed it intentionallY or
22 I typed intentionally my name and my title as
23 Commissioner because this was an official

24 communication from a fel-Iow member of the government
25 to the District Attorney to let'her know that if the
t
2 speculations in the newspaper are true, there are big

3 problems with this case if you decide to go ahead.
aA MR. McMONAGIE: Your Honor, if I
5 may pubtish this?
6 THE COURT: Any objection?
7 MR. RYAN: No, Your Honor.
I THE COURT: You may publish it.
9 (Defendantrs Exhibit D-5
10 published. )
t_1 BY MR. McMONAGLE:
t2 O Mr. Castor, what's being published, this is the

13 e-mail that you sent to District Attorney then
T4 District Attorney Fermanl is that correct?
A It is. There's a caveat. I didn't realize that'
16 that was a holiduy, a Jewish holidayr so I had it
!7 hand-delivered the next day. So I donrt know whether
18 this is the one I actually sent or the hand-delivered
I9 copy. I figured the District Attorney gets a lot of
20 e-mails and might have missed it, so I made sure to
2L have it delivered.
22 O Obviously, the document speaks for itseJ-f in
23 terms of what's said. I'd like to explore sorne things
24 that you did say.
25 Obviously in the first ParagraPh
1_ BRUCE L. CASTOR, JR. DIRECT 9B
2 you reference that you had read something in the

3 newspaper. And after you compliment Ms. then
4 District Attorney Ferman, you then say: So you almost
5 certainly know this already. I'm writing to you just
6 in case you might have forgotten what we did with
7 Cosby back in 2005. Attached is my opinion from then.
B fs that correct?
9 A That's correct.
t0 0 You then in the next paragraph say: Once vre
1l_ decided that the chances of prevailing in a criminal

t2 case were too remote to make an arrest, I concluded
13 that the best way to achieve justice vras to create an
T4 atmosphere where Andrea would have t.he best chance of
l_5 prevalling in a civil suit again Cosby.
16 And that obviously you testified
L7 to much of the morning; is that correct?
l_B A Thatrs correct.
1.9 0 With the agreement of 9'Ia11y Phillips and Andrea I s
20 lawyers, f wrote the attached as the only cornrnent I
2T would rnake while the civil case was pending. Again,
22 with the agreement of the defense lawyer and Andrea I s
23 lawyers, I intentionally and specifically bound the
24 Commonwealth that there would be no state prosecution
25 of Cosby in order to remove from him the ability to
t_ L. CASTOR, JR. - DTRECT
BRUCE 99
2 claim his Fifth Amendment protection against

3 self-incrimination, thus forcing hirn to sit for a
4 deposition under oath.

5 Did I read that correctlv?
6 A You did.
'7
O And that's what you did?
8 A Correct. That was not an agreement. That was a
9 statement f rom rne that. Mr. Cosby would not be

r.0 prosecuted by the Commonwealth of Pennsylvania and
Ll- thatr ds a matter of law, removed frorn him the ability
12 to claim his Fifth Amendment protection against
1_3 self-incrimination.
T4 So I am t.eIling District
L5 Attorney Ferman that there wasn't any quid pro quo
16 here. This was a definitive statement by the
L7 Commonwealth and, as a result thereof, Mr. Cosby would
18 be required by law to testify without Fifth Amendment
19 protection.
2A 0 Right. A decision by you to never prosecute
21 Cosby articulated to his lawyer that was then
22 obviously relied upon in submitting in the deposition;
23 correct ?
24 A I would assume, yeah

25 0 Yeah.
1 BRUCEL. CASTOR, JR. - DIRECT 100
z A Cosby would have had to have been nuts to say

3 those things if he thought there was any chance of
4 being prosecuted.
5 O WeIl, more importantly, after you communicate to
6 Mr. Phil-lips that he's never going to be prosecuted
.I
and removing' his Fifth Amendment right, then in fact
8 it I s cJear that it was relied upon and that he
9 test.ified; correct?
1_0 A I think he testified even nore than once.
11 0 Let rne move on: Wally was speaking f or Cosby's
L2 side at the time, but he was in contact with Cosbyrs
1_3 civil lawyers who did not deaL with me directly that I
1_4 recall. I only discovered today that WaIIy had died.
15 A Well, yeah, that was sort of embarrassing because
15 I wanted to get ahold of Wally when I saw in the
l1 newspaper that there was the possibility that Cosby's
18 arrest could be imminent. I wanted to call WaIIy up
19 and say to him, you know, do I have something wrong

20 here, because f was absolutely positive of what I did.
2I And I put in Google, and the
22 first thing that came up was his obituary. I
23 discovered that he had died in February. I f elt badJ-y
24 that I didn't know that because he and I had served on

25 the Judicial Reforrn Comrnission in Philadelphia and I
l_ BRUCE L. CASTOR, JR. - DIRECT 1 01_
2 Iiked him
3 THE COURT: Readv to take a
4 break?
6 THE COURT: A1I riqht. It Is
'7 L2230 and I want to keep to a schedule here. And
8 we I ve been going rnany of you have been s itting here

9 f or a Iong tirne.
r"0 Now, t.his is a Iuncheon break.
11 This j-s not a situation where there's a juryr So I
t2 don't have to give any kind of cauLionary instructions
13 to a jury, but the only cautionary instructions that I
1"4 have for the members of the public and press j-s follow
the Decorum Order. Again, that was put together with
16 a great. deal of thought and it is an Order of Court.
l7 As to the parties, Mr. Castor,
18 you are a witness under oath. You are not to speak
L9 with anyone while you are waiting to return to
20 continue with direct examination and subsequent
2t cross-examination.
22 Essentially use this time to go
23 get lunch, stretch your Iegs, file reports if that's

24 what you need to do, and we will start as close to
25 1:3 0 as we can.
1 BRUCE L. CASTOR, JR. DIRECT L02
2 There's a very good likelihood

t,hat !,re go through until tomorrow this is moving at
4 a sfower paqe than I thought, So Irrn going to address
q that with counsel even if I was to consider all of
6 the evidence today and then take the overnight to make
7 a decision, so you might want to plan accordingly.

8 So with that said, You know,
9 counsel, try to be back maybe five minutes early. If
r.0 something comes uP, You can address me.
t-1
L2 (At , a recess
1'2:3 0 P. m. was
13 taken until 1:40 p.m. of the same day.)

L4
15 (e conference was held in

16 chambers, not rePorted. )
L7
18 (The foltowing Proceedings were

19 reconvened with the Court, Mr. Steele, Mr. Ryan, MS.
20 Gibbons-Feden, Mr. McMonagIe, Mr. Tayback, Ms '
2t PressIey, Mf. Sarles, and the defendant being present:)
22
23 THE COURT: Werre readY to
24 resume the guestioning of the witness.

25 MR. McMONAGLE: Thank You, Your
t BRUCE L. CASTOR, JR. - DIRECT r_03
2 Honor. If we could jusL resume with the last

3 exhibits ?
4 THE COURT: And iust for the

5 record, we did have a brief conference with just the
6 tead counsel on both. It was to try to figure out
7 whether we will be going over until tomorrord or not.
8 Again, r'rI not lirniting anybodY.
9 I t m clear ing rny schedule if we had to . Right now it

1_0 doesn't appear it, but that was all we had gone over.
Ll- MR. McMONAGLE: YCS, SiT.
13 O Mr. Castor, I just want to ask you with respect

t4 to this document and if Irm retreading over what I
LJ did, I ' 11 do it quickly that this was a document
L6 that you sent to Miss Ferman after dealing with being
t7 made aware that there was activity in this ease; is
l-8 that fair?
r-9 A No, that's I read in the newspaper
not fair.
20 that there was speculation that something was going to
2T be happening in the Cosby case, so I didnrt learn
22 anything.
23 O okay.
24 A That's why I started off by saying 'I certainly
25 know better than to believe what I read in the
2 newspaper. tl
0 Okay. But you sent this to l'ls . Ferman; correct ?
4 A r did.
5 O And thereafter did Ms. Ferman respond?
6 A (No response. )
7 O Thereafter did Ms. Ferman respond and how?

I A WelI, she sent me a letter. I didn I t irnmediately
9 consider it a response. I considered it a request.
r.0 O okay.
t-1 (Letter dated SePtember 25' 20L5
L2 to Bruce Castor frorn Risa Vetri Ferman marked
r.3 Defendant's Exhibit D-6 for identification - )
l4 MR. McMONAGLE: ANd if I COUId
l_J approach, Your Honor?
16 THE COURT: Yes.
T7 BY MR. MCMONAGLE:
18 0 Mr. Castor, I want to show you we're now up to

T9 D-6 what's been marked for identification as D-6.
20 Do you recognize that item?
2t A f do.
22 O And is that, in fact, the request or at least a
23 responsive e-maiI that you received from then D.A.

24 Ferman ?
25 A Yes. It was not an e-mail. It was a letter.

1 L. CASTOR, JR.
BRUCE DTRECT 105
2 O I 'm sorry, l-etter.

MR. McMONAGLE: And if we could
4 demonstrate that without objection, I believe?
5 MR. RYAN: I do not have an
5 ob j ect ion .

8 published. )
9 BY MR. McMONAGLE:
10 O This is a letter from D.A. Ferman. And in it she

11_ is referencing the really referencing the e-maiI
1.2 t,hat you sent to her; is that correct ? When I say
13 "referenci.g,rt she's clearly responding to your
L4 e-maiJ; is that fair?
r.5 A No, 1 donf t t,hink so, l4r. McMonagle.
16 O Tell me what she was doing.
L7 A In the intervening day between the 23rd and the
18 25th, a newspaper article appeared that seemed to
19 suggest that there was another writing in addition to
20 the writing that I had sent to the D.A. which f
21 don't know what you've marked it, but what was my
22 opinion in the case that was issued as the press
23 rel-ease.
24 As a result of that, it created
25 the impression that there was another writing. I
t BRUCE L. CASTOR, ,JR. - DTRECT 106
2 actually asked the reporter to clarify that, and I

? don't know whether it ever happened. And that
4 generated when I read this Ietter, I thought that
5 that was a request from Mrs. Ferman to me for any
6 other documents t.hat I rnight have had.
7 And then ]ater oD, further down
8 in the letter, she says she makes a reference to my
9 e-maiI.
10 O okay. And as a result of receiving this from
1l" then D.A. Ferman, do you respond to her?
L2 A Yes.
13 (E-mail- dated SePtember
' 20L5 25
L4 to Risa Ferman from Bruce Castor marked Defendant's

15 Exhibit D-7 for identification.)
16 MR. McMONAGLE: Your Honor, if I
L7 may approach with D-7?
t_B THE COURT: YCS.
1,9 BY MR. MCMONAGLE:
20 O Please take a look at what I s been marked for

2L id.entif ication as D-7 and telL me what t,hat is.
22 A This is an e-mai-l from me to District Attorney
23 Ferman on September the 2sth.
24 0 And this is you responding to the letter that she
25 sent your Mr. Castor?
1o
1 BRUCE L . CASTOR, lTR.- DTRECT 7
2 A I think so. I havenrt read it in a long time.

3 O Take a second. And I don I t rnean to rush you
4 through it. P1ease take a second and, when you're
5 comfortable, I I 1I ask the next question.
6 A The reason whv'I'm not sure is because this was
7 that holid.ay that r referenced when I thought maybe
8 she had not received it.

9 (Witness reading document. )
10 Yes. Yes, this is in resPonse

11 beCause it references what I said was an error in the
T2 newspaper storY.
13 MR. McMONAGLE: OkaY. If we
L4 could publish this then without objection, Your Honor?

15 THE COURT: Yes .
16 (Defendant's Exhibit D-7

t7 published. )
19 O Just to surnmar ize, Mr . Castor, in Ms . Ferman' s
20 letter to you, she had requestedr ds I understand it

2T and as I read iL, any type of written agreements,
22 declarations, 9t cetera; correct?
23 A No. She was referring to a specific statement in
24 a newspaper article that there was a written
25 declarat ion Lhat I s igned of f oD I and she want'ed to
I BRUCE L . CASTOR, ,JR. DIRECT 108
2 know what that r,ras. And the newspaper reporter had

become confused because the written declaration was,
4 in fact, the press release that I had signed.
5 0 I see. And in this particular e-maiI, you do
6 indicate that the attached press release is a written

7 determination that we would not prosecute Cosby; is
I that correct?
9 A Yes.
10 O A11 right. Thank you. And then if we can go to
1t the next exhibit.
T2 (E-maiI dat,ed September 25, 20ts
13 to Risa Ferman from Bruce Castor marked Defendantrs
1,4 Exhibit D-8 for identification.)
1_5 MR. MCMONAGLE: YOUr HONOT'
16 again, if I may approach?

1,7 THE COURT: Yes.
1B BY MR. MCMONAGTE:
l9 0 D-8, would you please take a look at that and

20 tell me if you remember what that was?
2T A I do.
22 0 And what is it, sir?
23 A Also on September 25t.h it was a couple of
24 hours -- it was a couple of minutes after I sent the
25 previous one. I recoll-ected a conf erence that I had
2 had with Wal1y Phillips when he and I served on the

3 Judicial Ref orrn Commission together.
4 0 Okay.
5 A And I didn't know whether it rdas j-mportant, but I
6 sent it along anyway because I deduced from
7 Mrs. Ferman's communication to me that she was lookinq
6 for writings that might be helpful in her
9 determination of what to do based on my September 23rd
10 e-maiI.
11 O And in this e-maiI, you do reference obviously
L2 that you had served on the Reform Commissj-on with
r_3 Mr. PhiIlips and that, during a meet,ing with him, he
T4 had told you that the civil Settlement Agreement in

15 the Constand/Cosby case was baked in, that, there would
r6 be no prosecution for that incident.
L7 Am I correct that you wrote that
t_8 in this e-mail?
19 A Well, it wasnrt a meeting. We were at well,
20 we were at a Judicial Reform Commission meeting, and
21 he happened to sort of out of the blue say to me that
22 t here that the deci s ion that Cosby woul-d not be
23 prosecuted was baked in, was his words, into the

24 Settlement Agreement.
25 Now, I had nothing to do with
.L BRUCE L. CASTOR, JR. DIRECT 1_ 10
2 the Settlement Agreement and f have never seen it, and

3 I don't know what the words "baked intt meant.
4 0 Okay.
5 A But I thought maybe District Attorney Ferman
6 might be able to get that Settlement Agreernent and it
7 might be rnight assist her in her analysis.
I O Okay. After writing the e-mails that we have
9 seen and which you sent to Ms. Ferman, did either
10 Ms. Ferman or anybody at the District Attorney's
11 Office ask you to come in to be interviewed about. the
L2 decision that vou made in 2005?
L3 A No. Much to my surprise, actually, I thought
l4 that when it became common knowledge that I would be
15 testifying here today that the County Detectives would

r_6 want, to take a statement from me or interview me to
t7 find out what I was going to testify to, and I was
18 actually kind of disappointed that they didnft.

19 0 Going back to the date in which you sent the
20 e-mails, that time period, did you receive any phone
2L call-s f rom Ms. Ferman orr again, anybody in the
22 District Attorney's Office asking you what exactly you
23 had decided in 2005, what you had told Mr. Phillips or
24 anything of the like?
25 A No, not that I recallr Do.
l- BRUCE L. CASTOR, JR. _ DIRECT 111
2 0 And on the flip side of that, have I called you

3 and spoken to you on numerous occasions about what
4 you've t.estif ied here today?
q A Yeah. You call me on numerous occasions on alL
6 sorts of thingsr but this this is among them.
1 O Well, specifically I want to talk that's
I probably true. But with respect to thisr You and I
9 have spoken numerous times about what you told
L0 Mr. Phillips and obviously relevant t.o what you've
11 testified here today?
L2 A Yes.
13 0 Would you have in any way said no to any overture
I4 or request by the District Attorney 's Office to speak
l-5 to them?
r_6 A Let t s be cfear, Mr. McMonagle. I I m not on your
t7 tearn here. I want them to win.
18 0 We're crystal clear.
19 MR. McMONAGLE: I have no
2A further questions
21, THE COURT : Cros s-exarnination .
22 CROSS-EXAMINATION
23 B Y MR. RYAN:
24 0 Good afternoon, Mr. Castor.

25 A Good afternoon.
L L. CASTOR, JR. - CROSS
BRUCE TI2
2 O We met earlier just now' you'11 recall, right

3 over here?
4 A Yeah. You were nice to introduce yourself.
5 0 lt's my pleasure. So I have some questions for
6 you. And what I want to start with are sorne
7 statements that you made on your direct exarnj-nation.

8 Do you need a moment to get
9 comfort abl e?
10 A Yeah, j-t ' s I have to turn the chair so I don I t

11 have to turn mY back. Go ahead-
t2 O Ready? On cross-examination I rm sorry. On
13 d.irect examination you said that it. was your posit ion
L4 that the victim in this case, Andrea Constand' had
r_5 "compromised her credibititY. n
t_6 Do you recall saYing that?

I7 A Yes.
18 0 And that when you were talking about the scaLes
19 of justice as you were looking at them in evaluatinq
20 this caSe, those scales had "t,umbled way downrr in the
2I favor of Mr. CosbY.
22 Do you recall saYing that?
23 A Yes.
24 A Is it your testimony here today that you did not
25 believe Ms. Constand's account?
l_ BRUCE L. CASTOR, JR. - CROSS 1- 13
2 A No.
J 0 No, it's not your testimony or it is your
: testimony and Dor you did not believe Ms. Constandrs
5 account of what occurred?
6 A I believed Ms. Constandrs account of what
7 occurred.
8 O Okay. And that, I gruess, is despite a1l these
9 various issues that you said she created for herself
10 with regard to her credibility?
11 A WeIl, what I think and what is proveable in a
I2 courtroom are two different things.

13 O And I understand that. What I'm asking you here
t4 right now is what. you think.
15 MR. McMONAGLE: I don't mind,
16 but if he could just be permitted to fully answer the
L7 question.
L8 MR. RYAN: I apologize.
19 THE COURT: This is
20 cross-examination and you cantt hear. You know what?
2t Now that you're back and he's going to let's get
22 the microphones. Give him the microphone.
23 MR. RYAN: I have one.
24 THE COURT: You can use the
25 podium if you I d l-ike. Make sure you use the
'1
I L. CASTOR, JR. - CROSS
BRUCE 114
2 microphone and you use your microphone.

3 BY MR. RYAN:
4 0 And I apologize, Mr. Castor. You paused and I
q
took that as the conclusion of vour answer.
6 So go ahead and finish.
7 A What I think is Andrea Constand was
I inappropriately touched by Mr. Cosby. I am not

9 analyzing it back in 2005 as to what I think. I am
10 analyzLng it back in 2005 as to what I can prove. I

1-1 can probably rattle off a half a dozen people I think
t2 committed murder in Montgomery County, but that
13 doesn't mean that I can prove it. And that's why they
t4 didn't get arrested.
15 And the problem with the
16 Constand case is, setting aside whether I believed her
T7 or not, we have to follow the Rules of Evidence and we
1_8 have to produce sufficient evidence to convict
19 somebody beyond a reasonable doubt.
20 By virtue of Ms. Constand's
2t behavior in the vear between when the incident
22 occurred and when she went to the police and the
23 multiple inconsistencies after she went to the police
24 and gave staternents and the behavior that she
25 exhibited witb Cosbv after she clairned that she was
1 L. CASTOR, JR. - CROSS
BRUCE ].15
2 molested by Cosby, a1I of those things combj_ned

together in my mind created the situation where she
4 had ruined her own credibilitv and would not be
5 believed by a jury.
6 That does not mean she was not
't telling the truth. It simply means that as a matter
B of applying my training and experience in 20 years of
Y this job that I did not believe that 12 citizens with
10 her exposed to those inconsistencies, the contacting
11 of a civil lawyer before a criminal lawyer, the delay
L2 in reporting, the inability to gain forensic evidence/
13 I did not think she could withstand cross-examination
1i
a{ to the point where reasonable doubt would be overcome.
L5 O And how many times did you meet with her
L6 personally in order to make this credibility
L7 assessment that youtve given us?
1B A f never met with her personally. I assigned
19 people to interview her and then I read what t,hey
20 wrote. And, for example, within days she had changed
23. the date of when it happened from March r 04 back to
22 ,January of r 04. I don't need to be looking in her
23 eyes to know that that's a problem when you're bei-ng
24 cross-exarnined,
25 And there are numerous examples
t BRUCE L. CASTOR, JR. CROSS 116
2 of that. That is why f asked the Court to consider

3 this privately, because I can go through that very
4 extensively and demonstrate to alI assembled here how
5 Ms, Constand would be easilv discredited in a
6 courtroom.
7 A And now f want to talk about a little bit
8 about your experience because, as yourve said, you
9 were experienced certainly as a prosecutor generally,
10 but al-so as a prosecutor of sex crimes; right?
11 A Thatrs true.
l2 O And frequently, it,'s fair to aay, in sex crimes
13 cases you find the prosecutor finds themselves making
L4 the decision about whether or not to file charges in
t-J those sorts of cases?
16 A When I was on the Sex Crimes Unit, somebody above
T7 me decided that.
18 O A prosecutor?
19 A Yes.
20 O And you vrere involved, it t s fair to sdy, at least
2t in decisions with regards to declining charges or
22 approving charges in all types of cases, not just sex
23 crimes cases, during your career as a prosecutor?
24 A I was invol-ved in the deci sion-making process on
2s whether to prosecute or not prosecute frequently from

1 BRUCE L . CASTOR, JR. - CROSS 1'1'7
2 abouL 1988 until January of 2008, but certainly not in

3 every case. And in fact, it would be only a small
4 percentage of cases.
5 O But still a good number of cases, yourd agree
6 with rne?
7 A f donrt know what you mean by rra good number." I
8 would imagine that it wou.Id be in the thousands of
9 times.
1.0 O ffd say thatrs a good number. So in those cases
11 where you're deciding whether to file charges or not
l2 file charges, can you ever recall another instance
13 where you declined charges and made the same sort of
1,4 binding legal analysis you did in this one for the
1_5 purpose of stripping someone of their Fifth Amendment
16 rights for a civil lawsuit?

]-'l A I cannot recall doing it in that way in
18 Montgornery County. The bray it I had done it in the
19 past was and the way this comes up a couple of
2A times a year, someone already has a civil- case going
21. and a witness is refusing to testify because of the
22 Fifth Amendment. The lawyers and the judge adjourn to
23 the judge's chambers.
24 And if I was D.A. or First
25 Assistant D.A., they would call me and say are you
1 BRUCE L. CASTOR, JR. - CROSS 118
2 ever going to prosecute this person for this offense?

f would say no. The assertion of the Fifth Amendment
4 would be denied and it would go forward.
5 O And how many times did that happen while you were
6 in the District Attorneyts Office here in Montgomery
7 County ?
I A I don't know how many times it happened because f

9 woul-dn't have been the only one j-n power to do that.
L0 0 Did it ever happen?
l-1 A It I did it on a half a dozen occasions
t2 perhaps over 14 years where I was First Assistant or
13 D.A., but they were always cases where I had never
L4 heard of the case and it was somebody saying they were
1J going to take the Fifth Amendment and the judge
L6 wanting an assurance that we were not going to
L1 prosecute the person so that they could get on with
r"8 the civil case. MosL of the time I didnrt, even know
L9 the names.
20 O So if I ask you what those half a dozen cases
21- were over the 14 years where you received these sorts
22 of phone calls, you would be totally unable to tell me
23 what those cases were?

24 A Thatrs true.
25 O Now, in this particular case, the defendant now'
L BRUCE L. CASTOR, JR. - CROSS IL9
2 Mr. Cosby, he gave a statement to the police in 2005i

? correct ?
qt A Yes.
5 O And he did so with his attorneys present?
6 A I donrt know.
7 0 Okay. Certainly you rernember him giving a
8 statement ?
9 A Yes.
10 O And it was fairly let me rephrase that - He
11 gave a statement in which he did not invoke his right
T2 to silence, he did not invoke his rights against
r_3 self-incrimination during that statement; correct?
14 A Correct.
L5 O Now. you spent some time on dj-rect examination
16 going through the Press release that you issued with
1.7 regard to this case in 2005, and of course you recall
18 that ?
19 A I do.
20 0 Just a short time ago. And you spentr ds you
2t ind.icated, in 2005 a good deal of time and, in your
22 wordsr great care j-n crafting that statement?
23 A r did.
24 O And you then took the time here in court to
25 describe almost on a sentence-by-sentence basis what
1
I BRUCE L. CASTOR, JR. - CROSS L20
2 each of those statements were intended to impart;

{ corre ct ?
4 A Correct.
q
A And so is it your testimony here today that all_
6 the explanation that you provided about the various
7 statements in that press release, you expected those
8 t,hree audiences, the public, other attorneys or the
9 litigants, as you described them, to understand what
t_0 you were what you had explained here in court?
11 A No. Exactly the opposite. I wrote it so that
L2 the three distinct groups would not know the entirety
IJ of what I meant because I knew that t.he media who
ILI would then report, it to the public, they wanted to

l_5 know the answer was Cosby getting arrested or not,
16 which is why you'11 find 1r000 artj-cles where it is
L7 stated that I said there was insufficient evidence to
1B prosecute Cosby.
t9 T, in fact, did not say that. I
20 said there was insufficient credible and admissible
2t evidence upon which any conviction could be sust.ained
22 beyond a reasonable doubt. But f knew the press was
23 shorthanded into Castor said there I s not enouqh

24 evidence to prosecute Cosbv.
25 I knew that lawyers, who are
BRUCE L2L
z trained to parse out words and look at each word for

3 what it means and take those words in context, would
4 read it and would recognize that what I was aetually
5 saying was that there was enough evidence to arrest
6 Cosby, that I thought the evj-dence was not credible
7 and I thought that the evidence would be inadmissible
I so that we were at a situation where, because the
9 representations of the Commonwealth must be taken as
10 true by the issuing authority, and right up until the

1L matter goes to a jury, there was enough evidence to
12 arrest Cosby because credibility of witnesses is noL
13 an issue until you reach the jury. I then concluded
1.4 that when credibitity became an issue, there was no
15 way that I could see that a jury would ever believe
t6 Ms. Constand.
t7 Furthermore, dt a Preliminary
1B Hearing or in pretrial hearings, the wiretaps which
L9 may have been gathered iIlegalIy could have been used
20 to get the case to a trial, to a pretrial stage where
2t a Cornmon Pleas judge would decide on its
22 admissibility. I thought that those wiretaps would be
23 suppres sed.
24 So I wrote it so that the larger
25 legal community would come to those conclusions which
.L L. CASTOR, ,JR. - CROSS
BRUCE L22
2 are quite different than the way I wrote it for the

3 Press.
1t And then the third audience was
5 the litigants, and I wrote it to t.hem telling them

6 that you don't really want me explaining all of this
7 or it will be detrimental to the civil case that I was
8 hoping the plaintiff would prevail in.

9 O So you wrote the press release just so I
10 understand that answer that you just provided, you
11 wrote the press release understanding it was directed
L2 at three different audiences, but that those three
13 audiences wouLdn't necessarilv understand alI of the
L4 press release?
-LJ A f thought that the litigants woul-d understand all
16 of the press reLease. f thought that the J-arger 1egal
t7 community would understand most of it. And I thought
18 that the press would understand little of it.
19 0 And so I hope you're not offended. So as it
20 relates to this broader legaI community, is it your
2L testimony here today that you anticipated the broader
22 legal community to understand this press release to be
z3 you stripping Mr. Cosby of his Fifth Amendrnent rights

24 and, thereforer €ngaging in a lega1 analysis by which
25 the prosecutor's office in Montgomery County could
1 BRUCE L . CAS TOR, ,JR CROSS 123
z never prosecute Mr. Cosby?

? A I don I t think that f cared what the greater legaI
4 community thought about that. What I --
5 0 Which parts did you care
6 MR. Mcl'{ONAGLE: If he could just
'1 finish.
a THE COURT: Let him finish.
9 THE WITNESS: What I cared about
10 was the greater legal- community seeing t.he a nalys i s
11 that I had gone through because I wanted to be able to
T2 dj-scuss with other Iawyers, should the need arise, the
13 legal analysis that I went through because,
L4 unfortunately, then, as now, almost all of my friends
15 are lawyers or cops.
16 BY MR. RYAN:
t7 O So the press j-s not supposed to understand it.

18 The broader legraL community is supposed to understand
19 all- of it except f or the portion where you strip [4r.
20 Cosby of his Fifth Amendment rights and promise,
2L therefore, by implication not to prosecute.
22 So necessarily then the
23 litigants in this matter shoul-d have understood the
24 press release to represent you stripping the defendant
25 of his Fift,h Amendment rights and binding the
1 BRUCE L. CASTOR, JR. CROSS 124
2 Commonwealth int,o perpetuity forever to never

prosecute Mr. Cosby?
4 A Is that a question?
A It is a question. Shall I repeat it?
6 A If you can.
7 0 Sure. So bear with me because you gave me a lot
8 of information. The press is not supposed to
9 understand the press release; correct?
10 A No, that's not correct. I expected that they
11 would not.
L2 A Okay. So the broader lega1 cornmunityr you
13 expected them to understand the press release in all
t4 the vrays you described before with the exception of it
15 being a document that strips Mr. Cosby of his Fifth
16 Amendment rights and binds the Commonwealth never to
1,7 prosecute him?
18 A That also is incorrect. I didn't care about
I9 that the broader legal- community knowing that.
20 What I wanted them to know was the process. I figured
2t that any Iawyer who knows the practice of criminal law
22 knows that when someone is not going to be prosecuted.
23 they cannot t.hen assert the Fifth Amendment. But it
24 made no difference to me whether the broader legal
25 community understood thatr Do.
1_ BRUCE L. CASTOR, JR. * CROSS L25
2 O And my question, sir, was not did you care

3 whether they understood that. My question was did you
4 anticipate them or expect thern to understand this
q concept that you I re describing?
6 A And my answer is 1 didn't carer so therefore I
7 did not consider it.
I O Did you expect the litigants in this case to
9 understand that aspect of the press release, it
i.0 stripping the defendant of his F.ifth Amendment rights
1L and binding the Commonwealth never to prosecute?
T2 A Again, it makes no difference to me whether
13 first of all, the Iitigants, there were no Iitigants.
T4 O That's a word you used, That's why I was trying
1J to familiarize. But please, by all means.
L6 A AII that rnattered was that Cosbv understood that.
L'l That was the only thing that mattered because what
LB the what the complainant betieves and what the
19 complainant wants is not an issue that was before me
20 at the time.
2t The issue that was before me at
22 the time was is there sufficient evj-dence upon
23 which admi-ssible evi,dence and reliable evidence
24 upon which a convj-ction could be achieved beyond a
25 reasonable doubt? And if the answer to that question

1 BRUCE L. CASTOR, JR. - CROSS 1.26
2 was nor was there a way to achieve a measure of

3 justice.
4 And f wanted to make sure that
5 Mr. Cosby understood that, but I did not want it to be
6 a matter of public debate because I wanted the tamping

7 down of the enormous media coverage to begin so that a
8 jury could be selected to decide the case.

9 So the only person who I had any
10 interest in understanding what was happening was Wa11y
1-1 PhiIIips and Bill Cosby.
L2 O So during the course of direct examination, you
r-3 made several different statements about various things
L4 that you recalled and what formed the basj-s of your
15 ultimat,e charging decision oE r in this caser rro
1_6 charging decision.

L7 You recall those portions of
18 direct testimony?
1_9 A I did not give a complete account
WeII, I do.
20 because I understood the judge to rule that he did not
2L want a compJ-ete account because he did not want to try
22 the ultimate issue in todayrs hearing.
23 0 And it appeared to me as though you more or less
24 were recalling these things from your memory.
25 Is that fair to say?
z A Some I recalled f rom my rnemory. Some I recalled

from reports that Mr. McMonagle gave me to read from
4 back then.
5 0 And that was my next question. Which items did
6 you revj-ew in preparation for testirnony?
'1 A I reviewed the report from Canada, the report
tt from the the inltial report from Cheltenham orr r
9 guess, a statement f rom Chel-tenham, a subsequent, rnore
1_0 thorough report after Cheltenham had decided that the

1l- case should be given to the D.A. rs office. I think I
t2 reviewed Cosby t s statement, but I can I t, remernber . And
r_3 then I reviewed the e-mails and the letters that have
L4 been put in or marked. I donrt know if theyrve been
15 admitted, but marked.
L6 O And these items were provi-ded by Mr. McMonag1e?
L7 A Yes.
18 O Now, as it relates to that 2005 investigation,
1,9 you have said that at the point in time you decided
20 charges would not be warranted or successful, you
2T wanted to create the best atmosphere, as you described
22 it, for civil recovery.
23 fs that a fair staternent?
24 A Yes.
25 O Now, I want to draw you back to 2005. And I want
-L BRUCE L. CASTOR, JR. _ CROSS t28
2 to draw you to this wiretap issue that you discussed
J during your direct testimonY.
4 Now, you described a meeting
5 beLween you and Mr. Phillips in which he discussed the
6 existence, potential existence of some wiretap
7 evidence.
8 Do you recall that?
9 A Yes. He susPected ie.
L0 O And the vlay it occurred in Mr. McMonagl-e's
11 guestioning, it was after you discussed the victimrs
L2 statement on February the 9th of 2005 -
13 So did this meeting with
t4 Mr. PhiIlips occur after that last statement taken
15 from the victim in this matter?
t6 A I cantt remember.
t'l 0 Do you remember in any sort of time frame when
18 that meeting would have occurred?

79 A I thought that Mr. Phillips brought me
20 inf ormat ion t,hat he wanted that he thought we
2I should review earl- j-er in the investigation. I thought
22 it was right in the first few days, but, Your Honor, I
23 can't remember well enougth to state that with any
24 certainty.
25 O And what I took from your direct testimony was
1 BRUCE L. CASTOR, JR. _ CROSS 129
2 that up until that point in timer you had no knowledge

? of any sort of wiretap evidence that existed in this
4 case?
q
A f canf t rernember if I did or not. I recalL that
6 r was told by someone I can I t remember if it was
7 Mr. PhilIips or invest,igators that they thought.

I that Andrea Constand's mother was invoLved in these
9 wiretaps. And I could very well have been told by
10 both investigators and Mr. Phi1lips. I donrt
L1 remember.
L2 a Do you recall in ,.Tanuary of 2005, and in
13 particular January 26Lh of 2005, giving a press
L4 conference related to this case, the Cosby
15 investigation?
L6 A No.
t7 O You do not remember that,. Do you remember being
1B at a press conference that you were offering and
19 making statements, any statements about the Cosby
20 investigation in January of 2405?
2I A No.
22 A So if I were to read you a quote which is nI did
23 hear a report that said I had determined her
24 testimony, her statement was credible. That is
25 inaccurate. I haven't made anv such determination one
t- BRUCE L. CASTOR, JR. - CROSS 130
2 way or the other. "
3 That quotation, Lf I told you it

4 was attributed to you, you would have no recollection
5 of that?
A A I do not recal-l.
7 (ABC News nNew Developments in
8 Cosby Fondling Investigation" rnarked Commonweafth's
9 Exhibit C-1 for identification.)
1_0 BY MR. RYAN:
Ll- 0 So, Mr. Castor, Irm going to approach you with
!2 MR. McMONAGLE: Judge, I just
L3 want to inform the Court I just received some
14 documents. It mav take some time for me
-tJ MR. RYAN: I handed hirn the i.tem

1-6 that Irm going to be referring to'
t7 THE COURT: He said vou handed
1"8 him a bunch of documents.
t9 MR. RYAN: I did both.
20 THE COURT: Are you intending to
2I use the bunch of documents?
22 MR. RYAN: Irm intending on
23 using some of them.
24 THE COURT: WeLl, let r s start
25 with the one you are going to use. He has to have a
1 BRUCE L. CASTOR, JR. - CROSS 13r
2 chance to look at it.

MR. RYAN: Yes. And this is the
4 issue we had raised with Your Honor in conference
5 about potentially having a recess. And obviously
6 Mr. Castor's testimony went past Iunch.
7 THE COURT: So the tirne is here.
I MR. RYAN: I'm sorry.

9 THE COURT: This would be the
10 time so vre don t t have to cont.inually interruPt. He
11 has the right to review.

L2 MR. RYAN: I have no doubt.
t< THE COURT: He hasnrt had these
L4 documents before.
L5 MR. RYAN: So if he would like
r6 the time
L7 THE COURT: I'm going to take an
18 early midafternoon break because f generally like to
L9 go at feast an hour and 15 minutes-
20 MR. McMONAGLE: OkaY.
21, THE COURT: But it allows You to
22 review the documents that potentially are going to be
23 used in cross-examination.
24 So, again, this wasn't a
25 scheduled break, but it's going Lo have to do. So

1 BRUCE L. CASTOR, JR. CROSS t32
a
L we'1I pick back up at 2230. Does it look like
something you can handle within that time frame,
4 Mr. McMonagIe?
q MR. McMONAGLE: Yes, sir.
6 THE COURT: AII right. We will
7 reconvene at exactly 2:30r so be back in your seats.
B Again, the witness is under oath. Hers not to
9 converse with the parties calling hirn while under
1_0 cross-examination.
11
1.2 (Recess. )
1?
T4 (The following
Proceedings were
15 reconvened with the Court, Mr. Steele, Mr. Ryan, Ms-
L6 Gibbons-Feden, Mr. McMonagle, Mr. Tayback, Ms-
L7 pressley, Mr. Sarles, and the defendant being present:)
L8
19 THE COURT: Mr. McMonagIe, have

20 you had an opportunity to review the documents?
2T MR. McMoNAGLE: Thank You, Your
22 Honor. I have.
23 THE COURT: Okay.
24 BY MR. RYAN:
25 O So, Mr. Castor, I'm approaching you with a
z document that I have rnarked as C-1. And you're now

3 holding that document in your hand. And the document
4 is, in fact, a newspaper article from ABC News with
R the headline 'New Developments in Cosby Fondling
6 Investigation. "
7 Is that what I just handed You?
B A That t s what it saYS.
9 O January 27th' 2005?

10 A That is what it says.
Lt- O Okay.
1.2 MR. RYAN: And, Your Honor, at
13 this time I'm going to Publish.
t4 THE COURT: Any objection?
15 MR. McMONAGIE: No, sir.

L6 (Comrnonwealthr s Exhibit C-1
T7 published. )
18 BY MR. RYAN:
19 O So, Mr. Castor, I know that you've suggested that
20 you have some difficulty seeing the screen, but you're
2T able to see fine with that. document right in front of
22 you ?
23 A Yes.
24 O Now, I 'm going to point you towards the port j-on
25 of the articJe where therers a small bolded phrase
1 BRUCE L. CASTOR, JR. - CROSS L34
2 "Prosecutors CouId Make Decision in Two Weeks.I'

3 Do you see that portion right
4 towards the middle of the document?
q
A Yes.
6 O And this is on Page 1 of what I've marked as C-1.
7 And it says: At a news conference Wednesday,
I Montgornery County District Attorney Bruce L. Castor
9 said Cosby is fully cooperating.
10 A It actually says: Bruce L. CasLor, Jr. said.
11 O f apologize to you and your father.
t2 A I don't think he's going to hear this.
13 0 So does this help you recall at all holding a
\4 press conference where you made statements about the
1R Cosby investigation?
16 A No.
L'7 O So the quote down there in t.he next paragraph:

l-B fr
J did hear a report that sa.id that I determined her
19 t,estimony, her statement was credible. That is
20 inaccurate. I haven't made any such deterrnination one
21- way or the other, rr Castor said.
22 Continuing the quote: "He
23 (Cosby) is presumably innocent and can come and go as
24 he pleases, " you do not recall making t,hat statement

25 at any tirne in your entire life?
l_ BRUCEL. CASTOR, JR. - CROSS 135
2 A I do not recall makj-ng that statement on that

3 day. I assume that at some time in my life I have
4 uttered the words that people are presumed innocent
5 and can come and go as they please.
6 O How about the part t.hat it I s inaccurate that you
7 made a determination about the victim in the Cosbv
I case being incredible?
9 A Sir your name is l4r. Reilly?
1n
IU O No, it I s Mr. Ryan.
11 A Mr. Ryan, f do not remember having a press
T2 conference on this case. It would not have been
13 unusual for me to do so. But I was in public life for
t4 30 years and I have given so many press interviews and
15 conferences, I cannot reca11.
1_6 O Hard to rernember, as I can understand. So would
L7 you have any reason to believe that the quote that I s
1_8 provided there is inaccurate based on something that
19 you said at a press conference as of tfanuary 27Lh,
20 2005?
2T A We1l, in the first
sentence it says "I did hear a
22 report that I had determined her testimony, her

23 statement was credible. n I can I t answer your
24 question.
25 The second is I can say that
1 BRUCE L. CASTOR. JR. _ CROSS L35
2 if the first was true, the statement that I said it

J was inaccurate would fo1Iow from the first because I
4 wouldntt make a final determination on anyone I s
5 credibility until I was making the final decision on
6 the case.
7 O And I want to get to that point, but I just want
B to get that quest.ion f had answered '
9 So my question to You was:
r_0 Woul-d you have any reason to believe that the quote
1-1 that I've pointed you to that's attributed to you is
t2 inaccurate ?
L3 MR. McMONAGLE: That's been
t4 asked and ansvtered.

15 MR. RYAN: RespectfullY, it
16 hasn't.
THE COURT: I don't know if it Is
I7
1B been answered, but it has been asked.
L9 MR. I'4cMONAGLE : He doe sn ' t
20 remember.
2t THE COURT: If the answer now is
22 going to be I see it, but f don't remember, t'hen you
23 can move on. So if therets anything more you want to
24 ask outside of that
25 MR. RYAN: There was' Your
1 BRUCE L. CASTOR, JR. - CROS.S 1,37
2 Honor. I asked the question is t.here any reason you

3 would have to believe that this is inaccurate, and I
4 am not sure'what the answer was, but it was not
5 responsive to my question.
6 THE COURT: That is a different
7 question and I r lI a.Ilow hirn to answer t.hat.
8 BY MR. RYAN:
9 0 So, Mr. Castor, rny question was: Do you have any
10 reason to believe tbat the quote provided here is
11 i nac curat e?
I2 A I have seen myself misquoted hundreds of times,

13 so I would have to say that I have every reason to
14 believe that it is inaccurate because I have seen
r-5 mysel f ml squoted so rnany times .
16 O This particular quote you donrt remember making,

t7 but other than the fact that yourve apparently been
t8 misquoted so many times, no other reason to belleve
t9 it I s inaccurate?
20 A I assume the reporters try to do the best they
2L can. I assume they record these things. I assume
22 they transcribe them from recordings. So based on

23 that, I dontt I canrt say that I have any reason to
24 disbelieve the accuracy of it. I just flat out don rt
25 remember giving a press conference in this case.
2 (Pottstown MercurY article

? ttCosby rneets with authorities over sex assaulL
4 allegations" marked Commonwealth's Exhibit C-2 for
5 identification. )
6 BY MR. RYAN:
7 O So I'm going to now hand you another document.
I Bef ore I do that, You had said t,hat with regard to
9 this quote, it would rnake sense f or you to say
L0 something Iike this because, as a prosecutor, you
11 wouldn't want to make credibility determinations prior
I2 to a final charging decision-
1-3 Is that a fair descriPtion of
I4 what you said in one of your last' answers?
1-5 A No, I wouldn't make them Public.
L6 O Okay, fair enough. You wouldnrt go out in the
1-7 press and talk about credibility determinations?
t_8 A Right.
t9 O So now I'm going to hand you what I've marked as
20 Commonwealth t s Exhibit C-2. And this one has a bit
2T smaller print, but that is a newspaper article that is
22 entitled r,Cosby meets with authorities over sexual
23 assault allegations. "
24 Ts that accurate? Thatrs what

25 the titl-e is?
-L BRUCE L. CASTOR, JR. CROSS 139
2 A f rnean these are internet searched print.outs off

J of the computer, so I assume that it I s a newspaper
4 article. But it says: "Cosby meets with authorities
q over sex assault allegations. n
6 O Now, do you see at the bottom of this document

7 there appears to be a web address? fs that right?
8 A It does appear to be a web address. We started
9 with pencils and typewriters, so Irm not that savvy.

L0 0 I'11 try not to push your knowledge on
11 technology, but this web address is www.pottsmerc.com.

L2 Are you at all famiLiar with
13 that web address?
I4 A Yeah.
l-J O And thatrs for the Pottstown b'lercury newspaper;
16 correct ?
t7 A Yes. And CarI Hessler is still here today. I

18 think I saw him.
L9 A He I s right t,here in the f ront row.
20 A He looks a little older.
2t O You certainly wouldn't catch me saying that.
So you weren tt sure, ME. Castor,
22
23 whether or not this was a ne$rspaper article, but is it

24 fair to say that you and I can now agree seeing that
25 there is headlines and that this document is written
2 by Mr. Hessl-er, who is sitting right there, and that

3 there's a web address, pottsmerc, which is the
4 Pottstown l'lercury website, $re can officially now agree
5 that this is a newspaper article; right?
6 A What we can agree upon is that this is an
7 internet search, from the Pottstown Mercury website,
a printout. Many times I have seen printouts from
9 websites of newspapers that are not the same as t,he
t_0 print paper. And when I see the print paper, I
11 consider that a nebrspaper art j-cl-e. And when I see the
t2 internet, I consider that to be an internet articl-e.
13 So if we're going to broaden the
L4 term of "newspaper article'to be internet articles,
t_5 then I --
1_6 0 frm sorry? Then you what?
L1 A Then I agree.
18 O Okay. Thank you. So this has a date written on
L9 t.here and it says : Posted. I r m going to point it out

20 for you. It says: Posted I-21-05; correct?
2I THE COURT: That's
22 MR. RYAN: Itm going to put ir
23 up right now.
24 THE COURT: You got something
25 different up there. You have the ABC News one up
1 BRUCE L. CASTOR, JR. - CROSS 1,47
2 there.
? MR. RYAN: f want.ed to lay a
4 foundation before I projected it.

5 THE COURT: This one?
6 MR. RYAN: Correct, C-2, which
I've identified.
8 THE COURT: Turn that off then
9 until they're ready to go. You're on to another
1_0 document. Don I t publish it.
l1 MR. RYAN: With Mr. McMonagle' s
L2 permission
13 THE COURT: The problem is they
L4 had one up while he I s showing him another one. When
15 yourre done with a document, shut that, one down and

L6 then come up with the next one.
18 BY MR. RYAN:
19 0 So, Mr. Castor, I|m going to direct you towards
20 the top of this document, C-2, that I have handed you-
2I And when I say ttopr " I mean toP of the portion that
22 begins with this art j-cle.
23 Therers a quotation there. It
24 says: "Cosby and his lawyers have been fully
25 cooperative with us without delay or hesitatioDr"
1
I BRUCE L. CASTOR, JR. CROSS 1,42
2 District Attornev Bruce L. Castor ,Jr. conf irmed

3 Wednesday, adding that the interview occurred
.t ttrecently. t'
5
It I am not, groing to get into what
6 he told us. He \Îas cooperative and he appeared to be
7 not withholding anything," Castor said.
It I s that what i-s ref lected on
9 c-2?
r0 A Yes.
L1 0 Do you recall making that st'aternent?
L2 A No.
r_3 O Would you have any reason to bel-ieve that

L4 Mr. Hessler there in the front row would have
15 misquoted you about that?
16 A He usually gets it right.
t7 O I think sor too.
18 A Am I done looking at this one?
19 0 For now. So j-s iL f air to say that when you tal-k

20 about well, strike that. When you said that or
2t specifically, rather, r+hen you declined to comment
22 publicly on ,January 26th, '05, about the victim's

23 credibility saying that any such reports were
24 inaccuratef was that in an effort to create the best
25 possible atmosphere, as you deseribed it, for Andrea
1 BRUCE L. CASTOR, JR. - CROSS tqJ
2 to succeed civilly?
3 Is that what you were attempting
4 to do by making that statement?
5 A Mr. Ryan, I haven't testified that I made that
6 statement because I don't recall-.
7 O Had you rnade that statement, do you think that
I that would have been in an effort for you to create
9 the best atmosphere, as you described you were
10 attempting to do, for Miss Constand to succeed
11 civilly?
L2 A You want me to speculate on what I might have
13 thought of something f don't recall?
l_4 0 Thatrs what frm asking.
1_5 A I -- now, you understand, Your Honor, this is
L6 simply a guess' but my best guess is
1-7 MR. McMONAGLE: Judqe' I
18 don't I don't like to object' but I object to
19 guessingr sp€culation, things Iike that.
20 THE COURT: He's Your witness
2t and they are doing cross-examinat'ion- He's got an
22 statement that he doesn I t recall making. He has said
23 that the author of the article generally gets it
24 right, so hets now much of what we're doing here is
25 go ing back in t irne .
2 Memories may fade, but I think

J it's a permissible question to probe what he could
4 have been t.hinking. He clearly did a lot of that with
5 that press release. we dissected it. So if this is a
6 statement that he attributes that he thinks t,hat he
- gets it right, he can certainly comment on it.

8 Overrule the objection.
I THE WITNESS: Mr. RYan, You're
10 referring to C-1 which is the article that was not
11 authored by Mr. Hessler; right?
L2 BY MR. RYAN:
L3 O What I'm referring to is C-1. And my question to
t4 you, sir
L5 THE COURT: I aPologize. I
16 thought we were on the Hessler article. WeIre back to
1.7 the ABC article?
18 MR. RYAN: Yes.
19 THE COURT: It aPPIies either
20 wdy, although he didnrt say that ABC oftentimes gets
2t it right. But at this stage it is a recounting of
22 something that occurred 10 years ago that he doesn't
23 remember giving. But that t s a lot of what we are
24 doing here todayr so Irm going to permit it in that
25 context.
l_ BRUCE L. CASTOR, JR. - CROSS 145
2 THE WITNESS: Okay. My best

guess j-s that I was stopping speculation in the public
4 that we were goinq to come to a rapid conclusion, and
5 I did not reach the point in my thinking by the 27Lh
6 of January 2005 that the case was impossible to win.
-|
So I did not come up with the
8 idea of trying to creat,e the best poss ible atmosphere
9 to win a civil case because I had not given up on the
L0 hope, the hope that we could create a criminal- case
L1 out of what we learned and what we would subseguently
T2 di s cover .
13 BY MR. RYAN:
L4 O Now, look at C-2, Thatrs where the quotation is
15 'rhe was cooperative and he appeared to be not
16 withholding anything." And thatIs in reference to Mr.
L7 Cosby.
r_8 When you made that statement,
19 were you atLempting to create the best atmosphere for
20 Andrea to recover?
2I A My best guess, again, as these are dat.ed the same
22 day, L2zOL a.m. on that duy, is that I had not reached

23 the point in my thinking that the case could not be
24 won, so I was -- I was trying to let the public know

25 t,hat, we are working on working toward building a
1 BRUCE L. CASTOR, JR. - CROSS r46
2 prosecut.].on.
3 It was only after I determined
4 that the case could not be hton that I began to think
5 of other opt,ions to obtain some measure of justice in
6 the case.
7 O So on the same day where you I re confronted with
8 reports that you found the victimrs statement credible
9 and you deny those reports, on the same day that you
10 say Mr. Cosby appeared to not be withholding anything,
11 that's your attempt to inform the public that you
t2 haven't given up on the case Yet?
L3 MR. McMONAGLE: Objection '
14 Asked and answered.
15 THE COURT: Overruled.
T6 THE WITNESS: I -- Mr. RYan, I
t7 do not remember making these statements -

L8 BY MR. RYAN:
L9 O That vtasn ' t mY question, sir.

20 MR. McMONAGLE: Judge, I would
2L just ask if he's going to be permitted to ask the
22 question, that he be permitted to answer it -
23 THE COURT : Plea s e l-et him
24 answer the quest j-on.
25 THE WITNESS: I don't reca11
BRUCE 1'47
2 making these statements. You asked me to speculate if

J f had done them, was I doing so to try to create the
4 best possible atmosphere for Andrea Constand to
5 recover civi1lv.
6 If you want me to assume that f
7 made those statemenLs, the answer to your question is
8 f vras not at all concerned with the best possible
9 atmosphere for a civil recovery. I was concerned with
10 the best possible atmosphere for a criminal
Lt- prosecution and I am trying to tel-l the public
I2 essentially we're working on it.
l-J (Bl-oornberg. com article dated
t4 November 26th | 20L4 "Why Did Bruce Castor Pass on a
15 Chance to Lock Up Bill Cosby?" marked Commonwealth's

t6 Exhibit C-3 for identification.)
L7 BY MR. RYAN:
r-8 O I rrn going to hand you a document I rve marked as
19 C-3. This is a Bloornberg news article written by Lisa

20 DePaulo on November 268h, 2014. The headline is "Why
2t Did Bruce Castor Pass on a Chance to Lock Up BiIl

22 Cosby? "
23 Do vou recalI this article?
24 A No.
25 O Do you recall being well, let me ask you this.
I BRUCE L. CASTOR, JR. - CROSS 148
2 This is dated November 26th of 20L4; correct?

? A Yes.
4 0 You're saying you have no recollection of
5 speaking to this Lisa DePauIo for the purpose of
6 writing this article?
7 A I donrt know who tisa DePaulo is, so Do, I don't
8 recaIl speaking to her. When I was inundated with
9 media every time something popped up in this case' it
10 was always national media. And I don I t know any of
r"1 themr so I -- their names go in one ear and out the
L2 other.
13 O So I 'm going to Lurn you to Page 2 of this
L4 document. I'm going to point you to the second full-
1_5 paragraph, the first sentence of that: At the time of
L6 Constandrs complaint, he, being Bruce Castor, said at
'J.7 a press conf erence that her case was frweak. "
18 Do you recall sayj-ng that at a
t_9 press conference in 2405?

20 A giving a press conference in
No. I don't recall
2I 2005. That doesn I t mean I didn I t. I just, don I t
22 recaIl it.
23 O Do you recall ever saying that the case was
24 "weak( at any point prior to declining charges?

25 A In public' you mean?
t- BRUCE L. CASTOR, JR. CROSS t49
2 0 Yes.
A I donrt remember.
4 O Now, Irm going to go back towards I'm sorry,
5 back to C-1 in the area of t,hat same guote. Te11 me
6 when you have C-1-. Do you have C-1 in your hands?

7 A I do.
I 0 This is on Page l agai-n towards the middle of
9 that page. Continuing on in that quote that ere had
L0 read earlier, you were further quoted as saying: I
11 think the factors such as failure to disclose in a
12 timely manner and contacts with the alleged

13 perpetrator after the event are factors that weigh
t4 toward Mr. Cosby.
15 Do you remember saying that?
1_6 A No.
I7 0 Vflhen you sa j-d that the case I I m sorry. Let I s

18 speculate again. If you were quoted as saying that.
L9 the case was weak in 2005, would that be in an effort
20 to explain to the public that you guys were still
2I giving it a go and making a criminal case out of it.?
22 A Could you repeat your question?
23 a I sure can. Letrs aqain assume that the quote is
24 accurate in the newspaper article I provided at C-3
25 which is not, in fact, being displayed, but so that we
2 can all be on the same page

? MR. McMONAGLE: Judge, just so
4 you know, we're not in control of this.
5 MR. RYAN: Right. I was just
6 about to puII up C-3 because I realize itrs not.
7 THE COURT: You're usinq the
I other side's expert in electronic transmission of
9 documents.
t0 BY MR. RYAN:
t1 O So, again, you have to assume, because you donrt,
t2 remember, that you said that this case was "weak." In
13 2005, would that again have been in an effort for you
l4 to explain to the public that you were attempting to
15 build a criminal case?
t6 A Yes, of course. Irm telling the public what the
I7 hurdles are that we're trying to get over. That's
1B if I said that, thatrs exactly what I'm doing.
1"9 O And referring back novr to C-1, when you said or
20 when you hrere describing factors that weighed in the
2L favor of Mr. Cosby as early as January 26th of 2005,
22 was that again you attempting to tell the public that
23 you were doing your best to build a case?
24 A Oh, I thought I was answering that question on
25 t,he last one.

1
l. BRUCE L. CASTOR, JR. - CROSS ].51-
2 O We've moved on to the next one. That would be
3 back Lo C-1.
4 A What was f doing on the question before that
5 because I was Iooking at C-1?
6 O You t re going to have to tell me. f donrt know
7 what you I re looking at.

8 THE COURT: Okay. We need to
9 coordinate those who are publishing documents with
1_0 what Mr. Castor has. So what is important is note the
1_ l" document by its exhibit number.
t2 BY MR. RYAN:
J-J 0 Letrs try to get, Mr. Castor letrs talk about
74 c-1
1-5 A Okay.
L6 O which is the document that t s being projected
t7 right here.
L8 When vou rnade the statement
19 describing different factors that weigh toward

20 Mr. Cosby on January 26th, 2005, were you making that
2L public statement in an attempt to inforrn t.he public
22 that you were still to build a criminal case?
trying
23 A I donrt recall this press conference, but if I
24 said what you quoted, that I think the factors such as
25 failure to disclose in a timely manner and contacts
1 BRUCE L. CASTOR, ,JR. * CROSS 1'52
2 with the alleged perpetrator after the event are

3 factors that weigh toward Mr. Cosby, I am informing
4 the public of the hurdles that we are trying to get
5 over on the case.
6 (Southeast Missourian article
7 dated January 27, 2005 rrProsecutor calIs case against
I Bill Cosby weakn marked Commonwealthrs Exhibit C-4 for
9 identification. )
L0 BY MR. RYAN:
t1 O And novt I'm going t,o hand you another document
L2 which is marked as C-4. And this is an Associated
13 Pres s wire article dated 'January 2 5th , 2005 ,
L4 rrProsecutor cal1s case against BilI Cosby weak."
r5 Is that what the headline reads?
16 A The headline is Southeast Missouri-an, which is
L7 not a paper that I am f amil-iar with. And then
L8 underneath it it sayS: Prosecutor calls caSe against
1_9 BilI Cosby weak.
20 O And it says it comes from The Associated Press;
2L correct ?
22 A It does.
23 O Is that sornething you're f amiliar with?
24 A I'rn f arniliar with The Associated Press.
25 0 And novt looking
2 MR. McMONAGLE: Judge, I just

3 want the record to reflect that's not a quote. That Is
.t a conclusion in an articl-e. So I don I t know why he I s

5 being asked about it.
6 I,lR. RYAN : I
7 MR. McMONAGLE: Hold on. I 'm
8 almost done. I have no objection to
9 cross-examination, healthy CroSs-examination on what'5
r.0 being attributed to him by guote. But no$t we're
l_1 having some reporterrs concl-usion attributed to himt
1,2 and it's unfair.
13 THE COURT I And I wouldn't at
T4 all use a headline from the newspaper in any purpose
l-5 in that regard. f mean, it says what it says. I
1,6 assume, Mr. Ryanr Yourre moving towards a quote in
1.7 that article?
18 MR. RYAN: I am.
19 THE COURT: So letrs not get
20 caught up in what a headline says.
2I BY MR. RYAN:
22 O So, Mr. Castor, I want to point you towards the

23 bottom of that articte. Do you have C-4 in front of
24 you ?
25 A Yes.
1 BRUCE L. CASTOR, !TR. _ CROSS 154
2 \. I'm going to point towards that quote right

J there: rrln Pennsylvania, we charge people for
4 criminal conduct. We don't charge people with making
5 a mistake or doing something foolishrn Castor said.
6 Did you say that in January of
7 2005?
8 A f donrt remember saying that, but that is a true
9 statement.
1-0 O ft is a true statement. But, again, you don't
11 recaIl saying it in the context of a press conference
L2 because you don I t recal1 the press conference?
13 A Right. Mr. Ryan, it would be fair to say that I
l4 have probably done a thousand press conferences in my
l_5 career. I don't remember all of them. And f donrt

16 remember doing one in this case because the media
I7 attention was so much that f was trying to tamp down
1-8 the flow of information out into the public because f
19 was hoping that we were going to be able to pick a
20 jury and run a prosecution.

2L Now, it would not have been
22 unusual when the case came in the door for me to have
23 given a press conference. but f simply donrt remember.
24 0 So I want to move Co the press release that you
25 issued in this case at least for a portion of time.
l_ BRUCE L. CASTOR, JR. CROSS 1 55
2 And so this would be Exhibit D-4.

3 Do you have that in front of
4 your Mr. Castor?
5 A I do.
6 O And I want to point you to the second page of
7 Defense Exhibit 4.
8 You woul-d agree with me that if

9 your intention at tbe time you determined charges
10 would not be successful against Mr- Cosbyr dL that
11 time if you agree now that your intention going
),2 forward from there was to create an atmosphere by
13 which Ms. constand could successfully sue civilly;
L4 right ?
15 We've agreed on that?

L6 A WetI, more precise than that. I wanted Cosby to
t7 have to testify under oath which I thought would Lead
18 to an irnproved likelihood of recovery civitly.
19 0 So are you now denying that one intention of
20 yours was to create a ttatmosphere in which
21. Ms. Constand could succeed civilly"?
22 A I'm not denying that at all. Irm saying that the
23 way I wanted to go about that was to force Mr. cosby
24 to testify under oath.
25 O But you'd agree with me that you've said in the
2 past your intention at the time you decided charges

3 wouldnrt be successful was to ereate an atmosphere by
4 which Ms'. Constand could succeed civilly?
And while that may entail- Mr.
6 Cosby testifying, you agree you said in the past that
7 t,hat was your intention at that stage?
I A Yes, that was yesr that was the balloon under
9 which I hoped we would get to by making Cosby have to
L0 testify under oath,
11 O And so certainly at the time you wrote your press
'J.2 rel-ease, that would have been something in the back of
r.3 your mind, that you wanted to create an atmosphere
l4 through which she could succeed civilly?
15 A It was not in the back of my mind. It was in the
16 front of my mind.
L7 0 Front and center. So when you wrote in the press
18 release "much exists in this investigation that could
19 be used (by others) to portray persons on both sides
20 of the issue in a less than flattering lightr" was
2L that written with the intention of creating an
22 atmosphere, the best atmosphere by which Ms. Constand

23 could succeed civilly?
24 A YES.
25 O And in f act r oo your d j-rect examination, you

2 identified that line as a threat to her and her

lawyers; correct ?
4 A Yes.
5 0 And that threat was actually intentioned to
6 create such as atmosphere that she could succeed
7 civilly?
8 A Yes, because if she if the office was attacked
9 for its decision, I would have responded by saying
r.0 that Andrea Constand had created an atmosphere on her
tL own where she made her credibility so suspect that a
L2 crimj-na1 prosecut.ion could not go forward, and I would

13 be telling all potential jurors in the civil case
L4 essentially that District Attorney Castor didnrt
1q believe her testimony would support conviction and
L6 might not therefore support a civil recovery,
L7 So, y€s, by making that threat.
18 in that line, r was telling her don't attack the
19 office for this because, if you do, your ability to
20 recover civilly wilI suffer.
21 O What you were sayJ-ng was I want you to succeed,
22 but you better not question my authority or my
23 decision makj-ng in this case?

24 A No. What I was saying was that I want you to
25 succeed, but 1f the office comes under attack based on
L BRUCE L. CASTOR, JR. CROSS 158
2 our decision making, f wiIl explain to the public why

{ it is we decided t,he wav we did. rf I was required to
4 do that, it woul-d dramatically damage, in my v j- ew, her
J
tr
ability to prevail civilty.
6 (Daily Mail article published
7 November 18, 20I4, "I wanted to arrest Bill Cosbyrl
8 marked Commonwealth's Exhibit C-5 for identification. )
9 BY MR. RYAN:
10 O . Castor, f rm handing you now a docurnent that f
Mr
11 have marked as Commonwealth's Exhibit C-5. And that I s

L2 an article that appeared in the Daily Mail which is a
13 British newspaper; correct?

L4 A f donrt know.
15 O And it was published on November 1- 8th of 2014 .
l6 Is that what that indicates?
I7 A November l- 8th .
i-B O Yes. I'm sorry if I didn't say that.

19 November 18th, 20L4?
zv A Yes.
2t 0 And looking at the fourth paragraPh, this is an
22 interview, or at Ieast the article indicates that you

23 made statements directly to MailOnIine. This is
24 M-A-I-L, MailOnIine.
25 Is that what that says?
.L BRUCE L. CASTOR, *lR. CROSS 159
2 A I think yes.
3 O You think yes or yes?
q A I never heard I never heard of MailOnline, but
5 that's what it says.
6 O So you don t t recal,l- making statements that
7 ultimately were inciluded in this article?
I A I don't recall this intervi-ew. I'm much more
9 like1y to recal1 interviews from the locaI press corPs
l_0 than nationaL or international press corPs because I
L1- know the reporters.
t2 O Well-r you faited to remember that one from Carl
13 Hessler earlier. We can agree about that; right?
14 A I said I was much more likely. And I a.l-so said
15 that hers 1ikely to get iC right.
lh
O So I want to turn you to Page 3 of this article,
T7 and Ifm going to Project it.
18 (Commonwealth's Exhibit C-5
19 published. )
20 BY MR. RYAN:
21, O Are you turned to Page 3 of the article, Mr.
22 Castor?
23 A I am.
24 THE COURT: MY clerk has
25 returned. What's the number of this?

L BRUCE L. CASTOR, JR. - CROSS L50
2 MR. RYAN: This i s C-5 .
3 THE COURT: C-5 you called Daily

4 Mail?
5 MR. RYAN: Correct.
6 BY MR. RYAN:
'l O Do you see a quotation at the top, underneath the
8 pictsure at the toP of the Page?
9 IT4R. McMONAGLE : YOUr HONOT, if I
10 may just for the record purposes? And again' I
11 understand the rulings and you know I | 1I respect them.
I2 On di-rect examination I tried
13 carefully Eo, when I referred to stuff that was
t4 prepared in the past, t,hat it would be t'he actual

1q preparer that I asked the questions of.
16 The press reLease' as You
T7 referred to it, was something that Mr. Castor
l8 prepared. I had to ask him if he wrote it first
1-9 before I asked him before about it. And we went over
20 it in detail.
2L He I s not being asked quest.ions
22 about the Daily Mail's articles from the internet and
23 atl over the world that he may or may not have either
24 been interviewed for and he doesn't remember in some
25 instances, guotes that are attributabl-e to him, which
2 is a whole different element. They don't come in

? under admissions unless they can be in some way by
4 evidence, by competent evidence, established.
5 When the witness indicates he
6 doesn't remember, unlike the press release which he
7 authored, I would submit to the Court that the Court

8 should exclude it completely. And that's my argument.
9 THE COURT: Mr. McMonagle, I
10 believe this falls under the category of
11 cross-examination. He's impugning his credibility
L2 which is what he is attempting to do, and I think
13 that I s a classic cross-examination. Thatrs what he's
I4 doing.
.t- 3 Now, clearly on direct
T6 examination he had pinpoint accuracy as to a Iot of
L7 things that occurred in 2005. If he doesnrt remember,
L8 he can answer that he doesn I t remember. And then
19 he'11 try to either refresh his recollection but
20 it's not an attempt to get a fact into evidence, I
2I beI ieve .
22 Correct me if I'm wronq'. ft is

23 an attempt to impugn his credibility in terms of his
24 direct testimonv?
25 llR . RYAN : f have no need t o
l_ BRUCE L. CASTOR, JR. CROSS L62
2 correct it, Your Honor.

? THE COURT: But that is
4 cross-examination of what he believes to be his prior
5 statements. If they're not, he can deny them or he
6 can answer I donrt remember.
7 MR. McMONAGLE: Okav.
8 BY MR. RYAN:
9 O So, Mr. Castor, Ifm pointing you towards a
10 quotation that's at the top of the text on that Page.
1L And I have it hiqhlighted on the screen. It begins,
t2 t'there was almost. tt
13 Can you find that quotation or
T4 do you see it in front of you? If you would like, I'ffi
15 happy to come up and Point it out.
16 A I see it.
L'l O This reads quote: There was almost no evidence
r-8 on which to base a crirninal case. The lady could not
19 remember what happened with any detail, and she didn't
20 report it for a year. AIl this made the case very
27 difficult.
22 Do you recall making that
23 statement?
24 A No- I just don't recall this interview. I
25 don't I don't recall the Daily Mail, but
2 0 Do you ever recall- making that statement in

J November of 20I4?
4 A I donrt. I don't remember doing t'hat. I may
5 have, but I canrt recall.

6 O Now f rm going to go Lo Page 4 of eight in this
7 Same document which is in front of you marked as C-5.
I And I rm going to be in that same section of text I
9 described before which is to say the text at the toP
10 portion of the page, but the fourth paragraph down.
11 Do you see where I am? It
L2 beginsr "Comrnissioner Castor said."
r_3 A I see.
14 O The quote reads: Commissioner Castor said nAlI
L5 she could say is that she was there (at Cosbyrs house)
L6 and then something might have happened due to how she
L7 was when she next rernembered something. rr
L8 Do you remember giving that

19 quote in November of 2Ql4?
20 A No, I donrt.
2L O Now Itm going to refer back to C-3- Do you have
22 C-3 in front, of you?
23 A I do.
24 o And I arn going to go to Page 4 of that document.
25 Are you on Page 4 of that document?
1_ BRUCE L. CASTOR, .TR. - CROSS 164
2 A Theyrre not numbered, but I think so.

3 0 You can count it out okaY?
A I can count to four, but sometimes itrs

5 difficult.
6 0 And at this late hour, I understand. So I think
7 it would be easier for me to point out for you this
B paragraph.
9 Do you see that paragraPh?
10 A Yes.
11 O And it has a quote attributed to you- "WeIf,
72 believe what? I mean, she didn't tell us anything
13 that was actually criminal,'r Castor chuckles a bit
14 nervously.
15 Do you remember giving that
16 quote in November of 20L4?
l'1 A I canrt recall ever chuckling nervously in my
18 Iife, so therefore r think that that quote is wrong.

19 O So this one you're saying it's not that you don't
20 remember, it's that this is definitely wrong?
2T A I don't remember and I donrt beLieve I ever

22 chuckled a bit nervously ever in my life.
23 THE COURT: WelI, Iet me be
24 clear. You donrt remember giving the quote? You have

25 never chuckled nervously? I just want to make sure,
l_ BRUCE L. CASTOR, JR. CROSS 165
2 is that the answer?

MR. RYAN: Thatrs what f took
4 the ansvrer to be.
q THE WITNESS: I don't recal}
6 ever chuckling nervously.
7 THE COURT: No, no, I know. But
I there's two guestions there. It seems to be I
J wouldn't have rnade the quote because I never chuckled
1n nervously, therefore the whole quote is wrong. But
11 you've said I never chuckled nervously, but you donrt
T2 remember making the quote.
13 THE WITNESS: Itrs the second of
t4 those two.
15 BY MR. RYAN:
16 O Later on down in that page, do you remember
T7 making or giving this quote? I'WeI1, I donrt remember
18 what she said aII these years later. "
I9 Do you remember giving that
20 quote in November of 2014?
2L A No. Mr. Ryan, Irve never seen these before nor
22 read any of these stories bef ore, so rlor I don't.
23 0 So no$t I want to give you another one.
24 (Washington Post article dated
25 November !9, 201-4 "Prosecutor who declined to charge
l- BRUCE L. CASTOR, JR. - CROSS 166
z Bitl Cosby in 2005: 'I didn't say that he didn't

? commit the crime "' marked Commonwealth I s Exhibit C-6
.t for identification. )
q
BY MR. RYAN:
6 O Irm approaching you with what I've marked as
7 Commonwealth's Exhibit C-6, Mr. Castor. This is an
8 article from The Washington Post.

9 Are vou familiar with The
10 Washington Post?
11 A No.
L2 O You're not familiar with The Washington Post?

13 A Well , Lf you're asking rne if I I ve ever read The
T4 Wash j-ngton Post, the anslÎer is no.

t5 O okay.
r_6 A If yourre asking if Irve ever heard of it, yeah-
L'1 I folLow Bloornberg/Zernstein, too, like everyone else-

t_B O So this article has a headline: Prosecutor who
19 declined to charge Bill Cosby in 2005: 'I didn't say
20 that he didnrt commit the crirne.'

2L And Irrn asking you f or
22 foundational purposes, t,hat I s what C-6 says; correct?
23 A That's what it says.
written by an individual or it Is
24 O And it's
25 attributed to an individual Justin Moyer from
1 BRUCE L. CASTOR, JR. - CROSS 1,6 7
2 November 1-9th of 2AI4?

A It is.
4 O So this is, as I said, dated November 19t,h, 20L4.
5 The quote is: rr
I didn't say that he didn't commit the
6 crimeril Castor said. "What I said was there was
7 insufficient, admissible, and refiable evidence upon
I which to base a conviction beyond a reasonable doubt.
9 That's 'prosecutorrs speak' for rI think he did it but
just not enough here to prosecute. r'r
1_0 there's
l_1 Do you remember saYing that?
1,2 A No, but that's true.
L3 O Now, what I next want to ask you about j-s
T4 actually related back to C-2. You want to pick C-2
L5 back up for me?
r.6 A (Witness complied.)

T7 O Wealready said there's a quotation in here you
1B dontt remember, but the quotation Irm referring to is
19 "he was cooperative and he appeared to not be
20 withholding anythingr. "
2'l_ That's the quotation in that

22 article we discussed, correctr o1t Page 1- right at the
23 top there? Do you remember us discussing that
24 quotation?
25 A Yes.
2 0 But you don't remember giving it?

? A I donrt I donrt rernember giving the press
4 conference on that day.
5 0 But thi s quotation, do you remernber ever giving
6 this quotation or stating the words contained in that
7 guot,ation in January of 2005?
R A No.
9 O Rightr you don't. But we had said that it was

l_0 written by Mr. Hessler and he usually gets things
t_1 right. That I s the article we were talking about.
l2 Do you remember talking about
13 that ?
t4 A Yes.
15 O Do you remember giving an interview on CNN' for a
16 T.V. appearance on CNN November 19th of 20t4 related

l7 to this case?
18 A I don't remember specifically CNN. I remember
19 being inundated by national media, so I would imagine
20 CNN was one of them.
2T O So you don't remember appearing on CNN in
22 November of 2074?
23 A No.
24 O Letfs see if we can refresh your recollection.
25 Ird like you to watch this and tell me if you remember
t_ BRUCE L. CASTOR, JR. CROSS 1,6 9
2 this appearance on CNN.
3 MR. McMONAGLE: Is this an
4 exhibit ?
5 MR. RYAN: I apologize. I'm

6 going to mark this as C-7. If f can just have a
7 moment, Your Honor.

8 THE COURT: Sure.
9 (CNN video marked Commonweal-th's
10 Exhibit C-7 for identification.)
11 MR. RYAN: Your Honor, therers
I2 apparently a technical issue with the computer. If I
r.3 can have a few moments. I don t t know if you want to
T4 take a break or you want to wait. The detective here
15 is telling me it might take a minute.
16 THE COURT: What's the issue?
t7 MR. RYAN: That's what we're
18 attempting to figure out.
r_9 THE COURT: SOUNd?
20 BY MR. RYAN:
2I 0 All right.Mr. Castor, I apologize for that
22 delay, but where we just were was that 2 005 articl-e
23 where you were you said you don't remember it
24 quot,ed as saying in ref erence to Mr. Cosby: "He was
25 cooperative and he appeared not to be wit'hholding

2 anything. "
3 And I was asking about. a
4 November 20L4 CNN interview and seeing if I could help

5 ref resh your recollect j-on.
6 (Commonwealth's Exhibit C-7
I published. )
I BY MR. RYAN:
9 O Do you remember giving that interview on CNN?
l_0 A I remember Chris Cuomo. I didn't know that he

11 was with CNN.
T2 O So you do remember that interview?

13 A I do.
L4 O So now I want to rnove and hopefully this will
15 improve your memory a l-ittle bit to.Tanuary of
16 2015.
L7 At that stage, in JanuarY of
18 20L5, you had announced that you'd be running again
L9 for District Attorney of Montgomery County?
20 A I don I t remember when I did that. I think it was
21, early in ,f anuary. The Bth maybe' something ]ike that.
22 O Okay. So January Ethr in and around that time
23 you decided, or announced, rather?
24 A Well, it would be whatever day then District
25 Attorney Ferman said she was not running, it would
t_ BRUCE L. CASTOR, JR. - CROSS t7L
2 have been the next day.

3 O Regardless, January of 2Ot5?
4 A That sounds right.
5 0 Wellr you certainly sound more sure than in my
6 initial question. You're thinking either January Bth
7 or January 7th?
8 A For some reason I think January 8th, but I canrt
9 be certain.
10 O Okay. So when I say January 2015 at the very
l1 least, it doesn't not sound right; that is, in fact'
L2 right?
l_3 A What?
L4 A In reply to my question about January 2015, You

1"5 said that sounds right, but we can both agree that was
L6 definitely,JanuarY of 20I5?
L7 A The only reason that I think that I have
L8 ,January 8th in my head is because when Andrea Constand
L9 sued 6€, she said that f was -- I had announced I was
20 running for District Attorney in 20L4. And we checked
2L and it wasn't untit 20L5. And I think we responded in
22 an ansrter it was January 8th. That would have been
23 only a few weeks ago. That's why I think it's that
24 date.
25 O So when you decided to run again for Montgomery
L. CASTOR, JR. 1.7 2
L BRUCE CROSS
2 County District. Attorney, it's true that you sat down

? with individuals reLated to your carnpaign and
4 attempted to determine what issues may be used by
5 opponents, so to speak, aqf ainst you f or that campaign .
6 Is that fair to say?

7 A No. I just decided I was going to run and that
I was that.
9 O And at no time during the campaign did you sit
L0 down with anybody and discuss past caseS, for example'
11 that an opponent may use to rnake you appear in a
t2 negat j-ve I ight ?

13 A I donrt recall that. Usually this was my
t4 sixth campaign you hire people and they do research
IJ and they come up with things that they think might
16 hurt you, and then they teII you what they think you
1,7 might need to be prepared to defend against.
18 I dontt remember any such
t9 meeting, but it certainly was not before I decided I
20 was going to run.
2t O Riqht. I'rn saying after you decided you were
22 going to run' did you have such a meeting?
23 A I just tol-d you I don't recall having such a
24 meeting. You hire people to run these campaigns. You
25 put somebody in charge. They figure out what the
2 problems are. They figure out how to defend against

3 the problems. And then if the problem develops, the
4 candidate is the last to know.
q
O Now, do you recall giving a radio intervj.ew in
6 October of 2075 to WNPV? It's a local I t.hink it's
7 a Lansdale radio stationi is that right?
B A It is a Lansdale radio station. And I -- October
9 of 20LS would have been near the el-ectionr so I
L0 probably would have accepted an invitaLion, but I
11 donrt specifically recall.
1.2 O And you don't recall well, let me see. And
r.3 I'm going to mark this as C-8, this audio file. Irm
t_4 going to mark this as C-8. I want you to list'en to it
L5 and see if that refreshes your recol-Iection about a
L6 radio interview that you gave in October of 20L5.

t7 (WNPV audio marked
18 Commonwealth's Exhibit C-8 for identification.)
19 (Comrnonwealth's Exhibit C-B
20 published. )
2t BY MR. RYAN:
22 0 Do you recall giving that or making those
23 statements during a radio interview at WNPV in Oct'ober
24 of 201,5?
25 A Yes.
2 0 So when you said in t,hat radio interview, "We sat

? down and figured out what mlght be used against m€, "
4 were you talking about a meeting t.hat you had where
you and indivj-dua1s involved in your campaign
6 determined what could be used against you?
7 A No. ItIs "weu being the campaign, not nwen
I meaning me personally.
9 O Okay. So now if I can have a moment. Now I'm
t-0 going to talk about sort of where you ended with your
t"1 direct examination, which would be this agreement that
L2 was made not to prosecute the defendant.
-LJ A There was no agreement.
14 A Yes, analysis; right? You made a legal analysis
r5 that stripped the defendant of his Fifth Amendment
l-o rights and bound the District Attorneyrs Office never

L7 to prosecute him; correct?
1_8 A I made a judgment as the sovereignr the
19 representative of the Commonwealth, not to prosecute
20 Cosby. And that, by operation of Iaw, made it so that
27 he would not be permitted to take the Fifth Amendment.
22 I went to Wal1y Phillips and told him that was my
23 Iega1 theory, and he agreed to that.
24 O So one of the areas I want to start one of the
25 dates I want to start with is Septernber 23rd, which is
1 BRUCE L. CASTOR, JR. _ CROSS ].75
2 the first e-mai1 that you sent to then District

3 Attorney Ferman and r see that you I re searching for
4 it which is Defense Exhibit 5, if that assists you
q
in finding it.
6 A It doesnrt, because they're not in order.
7 Take your time.
I A I have it.
9 O Now, one of the things you indicated on direct
r.0 examination or stated on direct exarnination was that
11 even up until the date of Mr. Cosby's arrest, you
T2 never had confirmed that the case was actually
l.J re-opened by the District Attorneyts Office; correct?
I4 A No one in 1aw enforcement told me that. I read
15 in the newspaper speculation about it.
T6 0 What about Mr. McMonagle? Did he ever telI you
l7 prior to the defendantrs arrest that the case had been
18 re-opened by the District Attorneyrs Office?
r_9 A I think Mr. Mctr,lonagle called me and asked if I
20 had heard that the case had been re-opened. f donrt
2I think he told me that it had. As a matter of fact,
22 I'm quite sure about that because f never knew as a
23 fact f rorn anybody on the inside.

24 I recall reading in the
25 newspaper speculatj-on and I recaJ-1 Mr. McMonagle
L BRUCE L. CASTOR, JR. _ CROSS L /b
z calling me and say j-ng, "WhaL do you know about this? "
? And the truth of the matter is I didn I t know anything
4 other than what was in the paper.
5 0 And what you read in the paper was an article
6 that appeared in the Inquirer on September 12th' I
7 believe; is that accurate?
I A I canrt remember.
9 0 WelI, it's fair to say that well' do you
L0 recal"l rnaking a post on soeial media, on your
11 Facebook, after an Inquirer article where you were
L2 quoted as saying n Inky: Cosby vict j-m told police much
L3 different than she told the Court in her lawsuit.
t4 First I saw that in a story. Troublesome for the good
1q guys. t'
r.6 Do you remember making that

L7 rnedia post?
18 A I do.
19 O And that was in a November LzEi;r Inquirer article?
20 A I donrt know the date, but I do remember whether
21 that happened.
22 (Phi11y. corn article dated
23 September :-4, 20L5 "Tirne hasn I t run out on possible
24 charges against Cosby in Pa. " marked Commonwealthrs
25 Exhibit C-9 f or identif icat.ion. )
BRUCE L. CASTOR, JR. - CROSS 1.7 7
1
z BY MR. RYAN:
3 O Mr. Castor, Irm handing you what frve marked as
4 Commonwealth I s Exhibit 9 . Do you recognize that

q
article?
6 A The print is very sma1l and it will take me a
7 longer time to read it, but I donrt immediately
I recognize it -
9 O So that's not the article, at l-east. as you recaII

10 it, that informed you at Ieast sPeculation at Ieast
L1 in terms of speculation that the Cosby case was being
t2 re -opened ?
13 A I thought you said it was Septernber L2th and this

1"4 is September 14th.
L5 O And I realize looking at that that it is
16 September l- 4th and I rnade an error in that regard.
t7 But that article, does that look
18 familiar as the article you read where you learned
1_9 thaL this speculation was the case was being
20 re -opened ?
21, A I don't know.

22 0 OkaY.
23 A But it was around this time. I remember it was

24 around the middle of September that I first began to
25 think that Iaw enforcernent was reconsidering whether
BRUCE 1'78
z to prosecute Cosby. I don't know if it was this

art,icle or another one. And the print is just so
a smaIl, I canft read it.
q
0 I understand the difficulty. You're being sued
6 about an issue that arose in the press about you
7 making commentary about Ms. Constand allegedJ-y in the
B press. You know thati right?
9 A I thought that I was bej-ng sued because I
10 commented on a social media post that the Inquirer had
11 mentioned that t,he allegations in t,he civil complaint
L2 were more detailed than the than what Andrea
13 Constand had told detectives.
I4 A Right. And that social media posting was made
15 appended to an article entitled from the Philadelphia

16 Inqu j.rer "Time hasn't run out on possible charges
1'l against Cosby in Pa." Is that correct?
18 A I don't know. If you had shown it to me in the
t9 reverse, f could have said yeah, but I canrt remember
20 by looking at it in a vacuum. And I canrt believe
2t anyone could read print that. smaII.
22 THE COURT: Do you have it
23 electronic then? You don I t have it?
24 MR. McMONAGLE: They have it.
25 THE COURT: Some things you
2 have. Do you have this one?
3 MR. McMONAGLE: No. A lot of

4 these things that were turned over, Judge, I do not
5 have. I would publish it gladlY.
6 MR. RYAN: I have it.
7 THE COURT: I know. He has it.
I He can't read it.
9 MR. RYAN: We']1 qet there.
10 ( People. com article dated
11 LO-22-1,5'rPennsylvania District Attorney Candidates
12 Batt1e it Out Over the 2005 BilI Cosby Sexual Assaul-t
1"3 Atlegations rf marked Cornmonwealth' s Exhibit C-10 f or
t_4 identification. )
t5 BY MR. RYAN:
t6 O If I can turn this back over, this is what Irve
1,7 rnarked as Comrnonwealth's Exhibit C-l-0. I'm not
tB ant j-cipating you being a reader of People Magazine.
19 Is that fair to saY?
20 A That I s fair to say.

2L o But, nonetheless, I'm going to direct you towards
22 the last page of this document-
23 Do you see that?
24 A Yes.
25 (Commonwealthts Exhibit C-10
1- BRUCE L. CASTOR, JR. CROSS 180
2 published. )
3 BY MR. RYAN:
A
H 0 Okay. Now, I don't know if you're able to see it
5 or not, but, I I m groing to use the screen, understanding
6 that you may have some trouble with the screen as
7 well, but is that the Facebook posting that you were
I referencing earlier?
9 A Yes, but this says September 12th and you were
1_0 showing me a September 14th article.
1L O Right. And so let's just look at that. So
L2 September l-2th is the date that you make the reference

13 at issue in the lawsuit. And that, article was the one
1_4 where you learned this speculation that the Cosby case
15 was being re-opened, or do you not remember?
r_6 A f thought that f was commenting on the Inquirer's
t7 figuring out that the allegatj-ons in the civiL suit
r.8 are wildly more precise and more concise than Andrea
t9 Constand's statements to police. I did not think of
20 that article that the case had been re'opened.
2I The point that I was making was
22 if the speculation was that the case was going to be
23 re-opened, the discovery by the Inquirer that the

24 averments in the civil suit were much more precise and
25 cogent than what Andrea Constand told the po1i.ce, and
L BRUCE L. CASTOR, JR. _ CROSS 181
2 they and law enforcement wanted to be able to bring

? a prosecution, that would be detrimental to 1aw
4 enforcement's interests. So hence the statement that
5 I wrote " t,roublesome f or the good guys ."
6 0 But you don I t remember the substance underlying

7 that article that you were posting about on Facebook
8 is my question?
9 A f thought the substance was that the fnquirer was
1_0 pointing out the differences between what Andrea

L1 Constand had toLd the police and what she alleged or
L2 her lawyers al leged in her lawsuit . That I s what rny
13 recollection is for why f tweeted that.

1,4 A So going back to, like I said, the conclusion of
15 your direct testimony, what you said as an initial-
16 matter was that you had a meeting with Mr. Phil1ips,
t7 and that was really the first place that the decision,
18 the written decision not to prosecute would act to
19 officially strip the defendant of his Fifth Amendment
20 right.s.
zt ft's fair to say that that's
22 where that was first discussed?
23 A No.
24 0 lrlhere was it. first discussed?
25 A f had multiple meetings with Mr. Phillips before
1
2 t,hat issue cane up. Once I reached the point where f

3 did not t,hink the prosecution a conviction was
4 attainable, I made the decision t.hat we were not going

q
to prosecute Cosby as the representative of the
R Commonwealth, then I told Phillips of my decision.
"t And I told him that I thought that that meant, as a
8 matter of law, Cosby could not take the Fifth

9 Amendment in any deposition. And he agreed with that.
10 And it was thereafter his job to cornmunicate that to
L1_ Cosby or whoever was representing Cosby civiIIy.
L2 Now, whet.her that was the first
r.3 time I had ever discussed that idea with anyone, I
1,4 doubt it. f probably discussed it with my wife.
15 O And, again, when you say ttthat idear'r you mean as
16 it specifically applies to the Cosby case?

t7 A Right. I mean the general concept is black
18 Ietter 1aw. I wouldn't need to discuss that with
19 anybody.
20 0 Black letter law coming from a case?
2L A Probably. We1I, I just finished a case thatrs a
22 reported decision, V€loric v. Doe, from last summer
23 that says that if there is no chance of a prosecution,

24 a witness in a civil case may not assert the Fifth
25 Amendment.
L BRUCE L. CASTOR, JR. - CROSS 183
2 When I briefed and argued that

J case in the Superior Court and allocatur was
a refused re-argument was refused and allocatur was
5 refused, so that is the law of Pennsylvania. There is

6 many cases I cited for that proposition. If the
7 testirnony is incapable of j-ncriminating a person, then
I the Fifth Amendment right against self-incrimination
9 no longer exists. So I would consider that to be
10 black letter 1aw.

11 O And being a civil practit,ioner, you know that as
1.2 a litigator in an instance where an individual such as
1_3 a suspect or a criminal defendant even has given a
14 staternent to law enforcement, to authoritj-es during

15 the course of an investigation, that would be a basis
16 by which a civil practitioner could argue they no
r'l longer have Fifth Amendment rights.

18 Yourd agree with me about that
19 proposition?
20 A No.
2L O So I want to briefly go back. You said that you

22 received a phone call, was it, from Mr. McMonagle
23 asking you whet.her or not you knew anything about the
24 case being re-opened by the District Attorney's
25 Office?
L BRUCE L . CASTOR, .JR. - CROS S 184
2 Was that your earlier testimony?

A I beLieve he did, and f believe it was right
.t around mid-September, because that vlas when rumors
hrere in the newspapers about it.
6 0 Would it have been September 22nd?
7 A Could have been . I don 't recaJ.I .
8 O Were you aware that Mr. McMonag1e and Mr. Patrick

9 OfConnor, who was a civil attorney for Mr. Cosby, had
10 a meeting on September 22nd with then District
11_ Attorney Ferman and then First Assistant District
I2 Attorney Kevin SteeIe about the Cosby case and
13 reopening the investigation?
1A
L.f A If he told rl€r I don't recall-.
1q 0 So let me ask you about the procedure behind this
15 2005 decision that you made. So you indicated that
I7 perhaps you first spoke with your wife about this;
18 correct ?
19 A I probably spoke with her about it because, like

20 every other person in the count.y, she hras interested
2't in what was going on. and I probably told her before
22 I tol-d Mr. Phillips that this was what I thought I was
23 going to do.
24 0 And then you told Mr. PhilJ.ips by telephone?
25 A f think it was in person.
2 O At the District Attorney's Office?

3 A Yes.
4 O And he agreed with the legal analysis portion of
q that conversation you were having?
6 A Yes.
7 0 And then when did you discuss this legal analysis
I with your First Assistant District AttorD€Y, Risa
9 Ferman ?
L0 A I don't rernember. f don't remember whether I

tL discussed it at length with her or not. I probably
I2 just told her that that was what we were going to do.
13 And she was f told her that she was to contact
T4 Iawyers for Constand and let them know. And I don't
15 recall ltrs. Ferman coming back to me with any
1-6 THE COURT: She btas then Fi-rst
t7 Assistant D.A.; correct?
r-8 MR. RYAN: ThaL's correct, Your
19 Honor.
20 THE WITNESS: I don't recall
2t Mrs. Ferman comj-ng back to me and saying that there
22 was any objection raised. It wouldn't have mattered
23 anyhow, but I went ahead and told Mr. Phillips that
24 that I s what. we were going to do, and that I s what we
25 did.
L BRUCE L. CASTOR, JR. _ CROSS 186
2 BY MR. RYAN:
3 0 So when you say you just or directed at the

4 time First Assistant Ferman to inform the victim and
q her attorneys of the decision, when you say
6 "decision," you mean decision not to prosecute and,
7 along with that, your legal analysis that such a
I decision would strip the defendant of his Fifth

9 Amendment rights?
r_0 A That is what I recall- telling Mrs. Ferrnan to do,
11 yes -
t2 O Now I want to turn to D-5. Do you have D-5 in

13 front of you?
L4 A I do.
l_5 THE COURT: You want to take a
L6 short break here?

L'l MR. RYAN: That's fine.
18 THE COURT: We've been going for
19 about an hour and a half . I'm committed to go until
20 about 5:00. I know that people r^re generally donf t
21, take court much past 4:30 here, but in an effort, I
22 recognize that I'm assuming that Mr. castor told
23 you something about not being able to come back- I'd
24 like to complete his testimonY.
25 MR . I4cMONAGtE : Yes, s ir .
L BRUCE L. CASTOR, .JR. CROSS 187
2 THE COURT: I would like to take

3 a short break here and then plow on for a little bir
.t and see where we are. So, again' Irm going to
q
recommence at 4:00, so be back in your seats at 4 :00.
6
7 (Recess. )
I
9 (The foLlowing proceedings 14'ere
1_0 reconvened with the Court, Mr. SteeIe, Mr. Ryan, Ms-
11 Gibbons-Feden, l4r. McMonagle, Mr. Tayback, Ms.

t2 Pressley, Mr. SarIes, and the defendant being present :)
13
t4 THE COURT: Mr. RYan.

15 ( Defendant I s Exhibit D-5
r_6 published. )
t7 BY MR. RYAN:
18 0 Mr. Castor' I was about to ask you questions
t9 related to D-5, which was the e-mail you senE to then
20 District Attorney Risa Vetri Ferman on September 23td
21" A I have it.
22 O Now, what yourre laying out in this e-mail htas
23 your recollection of what occurred in 2005. And what
24 I want to ask you initialty was, in 2005 it was your
25 testimony on direct that you assigned Mrs. Ferman to
1 BRUCE L. CASTOR, JR. * CROSS 188
2 discuss your decision which included this

3 non-prosecution anaLysis with the plaintiffrs Iawyers;
4 correct ?
5 A I instructed her to telI them what we were doing,

6 so yes.
7 O And in this 9-23 e-mai.l, you indicate in the
B third line of the second paragraph: trwith the
9 agreernent of WalIy Phillips and Andrea's Iawyers, I
10 wrote the attached as the only comment I would make. f'
11 So when you say in that e-mail

l2 "With the agrreement of Wally Phi Il ips and Andrea I s
13 Iawyersr" did you speak with Andrears lawyers about
1.4 this being your only comment?
r-5 A No.
l-6 O Did Mrs. Ferman report back to you that Andrea's

]-'1 lawyers were in agreement with this being your only
18 public comment?
r.9 A I donrt remember.

20 O So when you say in this e-mail that was written
2t on September 23xd of 20L5, "With the agreement of
22 WaIly Phitlips and Andrea I s lawyers, I' what agreement
23 are you referencing?
24 A The agreement that my decision not to prosecute
25 Cosby would set the dominoes falling to make hin
.L BRUCE L. CASTOR, ,JR. - CROSS 1-89
2 testify in a civil case.

? 0 And so when you sdy, I'With the agreement of
4 Andreats lawyers," which conference are you
5 referencing that you had wlth her lawyers that's now
6 contained in this e-mail?
7 A I arn using the term "with the ag'reernent of Wally
I PhiIlips and Andrea's lawyers, I wrote the attached"
9 as my immediate subordinate did not report to me any
10 objection.
11 A So you telling Mrs. Ferman to do something and
1"2 the omission of her returning to you with any
13 information as the plaintiff I s lawyers agree with this
t4 being my only comment?
15 A Yes. Mrs. Ferman followed orders. Also,

16 Andrea's Iawyers were not necessary to be part of the
t7 discussion. ft was a courtesy that I delegated to now
18 Judge Ferrnan.
19 O Because, like you saidr the only person you cared
20 about knowing about this analysis was the defendant;
21, correct ?
22 A No. I thought I said that I -- I needed Wally

23 Phillips to agree that my legaL analysis was correct
24 so that when he told that to Cosby, Cosby would
25 believe him.
2 O And vour frankly, didnrt care what the

3 plaintiff's lawyers opinion of it was?
4 Is that a fair statement?
5 A I didnrt from a legaf perspective, I didn't
6 care because I had already concluded the case could
7 not get any better and that this was the best way to
I get some measure of justice for Andrea.
9 O So in this next L j-ne you say again: "Wit'h the
r.0 agireement of the defense lawyer and Andrea I s Iawyers '
11 I intentionally and specifically bound the
T2 Commonwealth. "
TJ Are you again referring to
74 Mrs. Ferman not returning to you with any sort of
.LJ objection from the plaintiff's Iawyers when you talk
16 about thi s ag:reement ?
t7 A Correct.
18 0 And, of course, you didn't lay out in this e-mail"
79 Well, hey, Risar lou remember I sent you to the
20 plaintiff's lawyers and you didntt say anything about
2I them objecting?
22 You didn't put that in the
23 e-mai1, did you?
24 A I put in the e-mail what's written on the paper.
25 O So you didn ' t put in, H"y, Ri s a, You r ernernber how
1 BRUCE T. . CASTOR, JR. _ CROSS L9L
2 I sent you to talk to the plaint,iffs I lawyers and you

understand you didn t t say anything about them not
objecting?
5 You did not put t.hat in the
6 e-mai1 ?
1 A I did not consider that t.o be signif icant. What
I is significant is I wanted to make sure that now,Iudge

9 Ferman knew that I had specifically bound t'he
10 Commonwealt.h that there woul-d be no state prosecutj-on
11 of Cosby.
L2 0 What. you said in the f irst paragraph vtas: Dear
13 Risa, in case you might have forgotten what did
I4 with Cosby back in 2005, R€aning you and Mrs. Ferman?
A NO.
16 O Is that the royal nweil?
r'1 A Itrs rrwer meaning w€r the D.A. rs Of fice.
1B 0 The sovereign? Or are you the sovereign in 2005?

19 A In 2005 I was the representative of the
20 sovereign, Commonwealth of Pennsylvania.
2t o so let,s move on down to the next paragraph where
22 you say: fn fact, that was the specific intent of all
23 parties involved, including the Commonwealth and the
24 plaintiff I s lawyers.
25 When you talk about the sPecific
1
r BRUCE L. CASTOR, JR. CROSS 192
2 intent of the plaintiff's lawyers, are you again

J talking about when Mrs. Ferman just never returned to
4 you with any sort of objection from the plaint,iff's
5 Iawyers ?
6 A Which sentence are You looking at?

7 0 Can you see it on the screen right in front of
t' you there? rt I s highlighted.
9 A Not exactly. The specific intent was that the
1_0 non-prosecution of Cosby would make him have to
11 testif y. And that was the intent of fll€, Wally
L2 Phil1ips, and t.hose were the only parties.
1? O So right here when you talk about the specific
L4 intent of alt parties including the plaint j-f f 's
15 Iawyers, you're now saying that what you rea1ly meant
L6 was just you and WallY PhilliPs?
L7 A WeLlr dnything that Irm referencinq the
18 plaintiff's lawyers was what I deduced from whatever
19 it is that Mrs. Ferman' now Judge Ferman, told me.
20 0 Or didn't tell you?
2T A Or didn 't teII rl€, right .
22 O Incidentally, did Mrs. Ferman report' anything

23 back to you when you directed her to go inform the
24 plaintif f 's lawyers and the victi-m about your
25 analysis ?
t_ BRUCE L. CASTOR, JR. CROSS L93
2 A I assume that she did, but I just donrt remember.

3 0 Because certainly if there were something to
I^ report, your First Assistant District Attorney would
q have done so?
6 A Well, she's a very capable lawyer and judge, and
7 knows that what t.he what the victim and her lawyers
B want has no bearing on the decision that there was no
9 evidence upon which a prosecution could succeed and

10 that, therefore, removing the Fifth Arnendment barrier
L1 would enhance the case.
T2 So if the answer that she got
13 from Andrea's lawyers was we don't like it, but if
14 that's the best werre going to do, then that's the
L5 best we I re going to do, she might not consider it
16 necessary to teLl- me.
t'7 O But certainty Mrs. Ferman didn't report the

1_8 information you just described?
L9 A No. What I told you was I don't recall whet"her
20 she did or not. At that point was an insignificant
21, matter. Once I was convinced that the victim had
22 comprornised her credibi Ilty to the point. where the
23 case could not be won, added to t.he delay in the case '
24 it no longer rnattered what the vi ct im' s lawyer and the
25 victim wanted.
2 A1l that matt,ered was the

3 decision of do we leave the case open and he doesntt
4 get arrested, ot do we do something to try to get the
5 vict,im some compensation.
6 And the analysis wds7 if I
7 thought the case cou.l-d have gotten any better, I might
8 have decided to leave it open. But, because I .thought
9 it could never get any better, f decided the best
10 possible course for the victim, reqardless of what her
1l- lawyer said, was to engage in the legal analysis I did
t2 with Mr. Phi1lips, state the Commonwealth woul-d not
13 prosecute Cosby, and make him testify under oath.
1,4 O And as you just said, when as soon as you
15 determined that you weren't going to be able to
16 prosecute BiIt Cosbyr the opinion of the victim, the
t7 opinion of her attorneys, becarne insignificant; right?
18 A ft became irrelevant.
19 O The word you used was insignificant.
20 A Okay. Insignificant, I | 1l- agree. Irrelevant,
2L ins ignificant .
22 O So let's move down to the final paragraph, and it

23 may carry over onto Page 2 of the document you have in
24 your hand. I cannot be sure without it in front of
25 me.
2 You state:
"But one thing is
fact. The Commonwealth, defense and civil plaintiff's
4 lawyers were aIl in agreement that the attached
5 decision from me stripped Cosby of his Fifth Amendment
6 privilege. "
7 Again, what yourre saying in

B this e-mail- is that the agreement coming from the
9 plaintiff's lawyers would have been the fact that
10 Risa f'm sorry, then First Assistant District
1L Attorney Ferman never reported anything back to you
L2 that you recall?
r_3 A Correct. I don't recalI that she told me of
14 anything coming from the civit plaintiff's lawyers'
1_5 side that would have been of value in the
L6 decision-making process because, as you weIl know, you
T7 represent the Commonwealth. You do not represent the
18 victim.
19 A Now, Iet I s turn to what I believe is marked as
20 D-6, which is a letter from then District Attorney
2I Ferman on Septernber 25th | 20L5, to you.
22 Do you have that in front of
23 your sir?
24 A I do.
25 0 And as you can see by the dates on the letters,
1 BRUCE L, CASTOR, JR. - CROSS Jvo
2 this is coming Sept.ember 25th which is, of course,

3 after your September 23rd e-mai1; correct?
I A Yes, but f was not in the office, so it was not
5 hand-delivered to me. It was ultimatelv scanned and
6 faxed or scanned to ner so f don't know if I got it
7 that day or the next day.
I O But what the then District Attorney is stating in
9 t,his letter is that she's attempting to determine an
L0 appropriate course of action, but that she read a
l_ t_ newspaper article that you were quoted in talking

t2 about a I'written declarationI that you signed in 2005
13 indicating the Montgornery County District Attorney's

l4 Office would not prosecute BiII Cosby on information
15 coming,out of the civil litigation with Andrea
16 Constand. And thatrs what this letter is initiallv
l7 regarding?
18 A I am not 100 percent sure that I was quoted in
t9 that art i c.l-e . f remember there was an erroneous
20 article in the Intelligencer that led me and any
2t reasonable person who would read it to think that f
22 had said that there $ras more than the press release
23 written to memorialize what happened. I immediately
24 contacted the reDorter and asked for a retraction and
25 a correction. I donrt know whether that ever
1 BRUCE L. CASTOR, JR. - CROSS r97
2 happened.
3 I deduced from this letter that
4 Mrs. Ferman had the same reaction thaL I did and is
q
now looking around for something else and asked me
6 about it, and asked me to send it to her if there was
anything.
I The last sentence which states:
9 "Since I know you keep copies of important documents,
10 I am writing to request that you provide a copy to us
t_ 1- now, so that we may properly resol-ve thi s important
t2 matter" is simPlY untrue.
1-3 I happen to have the Press
t4 release on my computer because it was one of the few,
15 if not the only, I actually wrote myself. So when I
T6 brought my when I moved across the street and took
T7 my personal f iles with rl€, it was there.
1_8 So I don I t know whY Mrs. Ferman
19 would make such a statement' but that is, in fact, not
20 true.
2L (The Intelligencer article dated
zz september 24, 20L5 'tMontgornery DA candidate castor
23 urges delay in Cosby case until after elections"
24 marked Commonwealth ' s Exhibit C- 11- f or
1 BRUCE L. CASTOR, JR. - CROSS r.9B
3 BY MR. RYAN:
4 O Irm going to hand you what Irve marked as
5 Commonwealth's Exhibit, C-1L. Take a look at that and

6 tel- I me i f you ' re f ami I iar with it .
7 A Yes, f remember this newspaper articl-e.

8 a And this is the newspaper article that you were
9 just talking about that was written by Peggy Gibbons
i.0 that you felt was inaccurate?
11 A I don't know t,hat. I'd have to look at it again.
72 0 Take your time.
13 A The date is cut of f on rnine. Can you tell me the
T4 date ?
l_5 O The print date is 9-25, but I believe it was
L6 actually on September 24th, 20LS,

t7 A Okay. Yeah, that would have been the day in
18 between.
19 O ExactIy.
20 A And you just let me know if you have come to the
21, eonctusion that you're familiar with it.
22 A I am familiar with it, but Irm not familiar with
23 it enough, unless you point me to specific parts.
24 O But this is the article you were just referenci"ng
25 that made first mention of this written declaration;
2 is that accurate?
3 A Yes.
:
A
O Okay. So now I am going to point you to a
5 particular page. And if you look at the top, it has
6 Page 1 of 5. You see that? f'm going to turn you to
7 Page 3 of 5.
B A Okay.
9 0 Are you on that Page?
L0 A Yep.
1l- (Commonwealth's Exhibit C-1-1
I2 published. )
13 BY MR. RYAN:
L4 O And we see it blown up on the screen in front of
L5 us. And I believe the quote you're talking about
16 says, At the the statement in the article: At the
L7 same tirne he decided not to pursue criminal charges
r-8 against Cosby, Cdstor said he signed off on a written
L9 declaration saying his office would not prosecute
20 Cosby.
21, That I s the misstatement that
22 you're referring to?
23 A Right. And you'll notice t'hat that is not a
24 quotation.
25 O Riqht. And I'm not suggesting that it is, but
1 BRUCE L. CASTOR, JR. - CROSS 2AA
2 that was what you sought a retraction for?

J A Right, because the written declaration that I was
4 referring to was the signed press release. And I

5 could see how anybody reading that would think there
6 was something elser and that's what I asked for a
7 retraction of.
B A Now, do you see above that the sentence that
9 starts: Castor, who would have norrnally made. "
10 Do you see that sentence?
l_1 A Yes.
L2 O Castor, who would have normally made the
t3 announcement at a press conference' said he opted for
L4 a f'more carefully worded" press release than his noff
L5 the CUff remarks" at a press conference so aS no to
16 "poIIute jurors" in a potential civil Iitigation.
L7 Do you recalI saYing that?
18 A Yesr I do.
L9 O And nowhere in that do you mention, wel1, I
20 actually didntt hold a press conference because I
21, wanted to issue a press release because it would be a
22 writing signed. by the District Attorney as sovereign
23 and, therefore, stripping the defendant of his Fifth
24 Amendment rights?
25 You didntt state that or it
1 BRUCE L. CASTOR, JR. - CROSS 20t
2 wasnrt quoted in tbe article?
3 A f am quite sure I did state it, but you dontt
4 know what I said before or after the portlon that vras
5 quoted.
6 O So it is your testimony that in an int.erview with
7 Peggy Gibbons on Sept,ember 24E}rt 20t5, you stated to
I her that the purpose of the press release was so that
9 it would be in writing that you were not prosecuting
l_0 Mr. Cosby, therefore stripping him of his Fifth
11 Amendnent privileges?
t2 A Yes, I said that many times to reporters. The
13 problem with quotations in newspaper articles is you

t4 don't know what's said before or after. But I have
L5 said every tirne every time that this case has
L6 resurfaced since the comedian made it an item, I have
77 said that the reason why we did this was to strip
18 Cosby of his Fifth Amendment privilege.
19 O And you aJso certainly told Ms. Gibbons that that
20 Iegal analysis acted such that the Commonwealth could
2L never prosecute Mr. Cosby for this incident?
22 A f think I told every reporter that.
23 0 Every reporter you ever talked to about this
24 case?
25 A I think sor because that was the whole point of
-L BRUCE L. CASTOR, JR. CROSS 202
2 the exerc j-se. It had to be set up so that Cosby, when

3 he's sitEing there under oath answering questions, has
4 to be completely convj.nced that he could never be
5 prosecuted for that case, the Constand case.
6 Otherwise, he's not he t s not
7 in a position where he can waive his Fifth Amendment
I privilege without fear of it being used against him.
9 O And so in 2005, you issued the press release and
10 you didnrt give interviews on this case in 20O5;
1L correct ?
L2 A want my words to be
Correct, because I didn't
l_3 given any undue weight by potential jurors, because I
t4 was hoping that Andrea Constand would sue Cosby, make
i_5 a lot of money and, j-ncidentally, her lawyers make a
16 big contingent fee.

L7 O And what you're saying is that subsequent to
18 thatr r€alIy in November of 2OL4 when the case came
19 back in t,he news and you started giving interviews,

20 what you're saying is that you always t.old reporters
21_ that you had made this analysis, and part of that
22 analysis was that the Commonwealth could never
23 prosecute Mr. Cosby for the sexual assault incident in
24 2004.
25 That's what you've just
z testified to?
3 A My recolleetion is I always said that because
4 r --
5 0 ft I s interesting because
6 THE COURT: HOld ON.
1 MR. RYAN: I apologize.

8 THE WITNESS: Because when I
9 wrote in the press release on February L?th, I wrote
10 tha t
t-1 BY MR. RYAN:
t2 0 Are you finished, Mr. Castor?

13 A No. I'm trying to find it. I made it absolute
L4 in the press release
r_5 0 Please, tel1 me in the press release where you
16 made it absolute.
T7 A I will if you'I1 quiet down and let. me look at
18 ir.
19 When I said that the After
20 reviewing the above and consulting with County and
2I Cheltenham detectives, the District Attorney finds
22 insufficientt Cxedible and adrnissibfe evidence exists
23 upon which any charge against Mr. Cosby could be
24 sustained beyond a reasonable doubt.

25 So I used the present tense that
i
I BRUCE t. CASTOR, JR. - CROSS 204
2 the that there is no there's n j-nsuf f icient,
J credible, and admissible evidence exists," exists in

4 the whole wor1d, exists, t'upon which any charge
q agaJ-nst Mr. Cosby could be susta j-ned beyond a
6 reasonable doubt. "
? So Irm making it an absolute. I

I said f found that there was no evidence there was
9 insufficj-ent t credible, and admissible evidence in

10 exi stence upon whi ch any charge agrainst Mr . Cosby
11 could be sustained. And the use of the word "exists"
t2 and "could" I meant to be absolute.
13 O And you told that to news reporters when you
74 talked to them?
1q A Wel], I didn't parse it out the way I did there'
15 because f figured lawyers could figure that out. but
T7 I told newspaper reporters that he was not going to be
r.8 prosecuted in order to make it so that he would be
19 required to give a deposition under oath.

20 I f there was any wiggle roorn at
2T all, then he would not be able if there's any
22 wiggle room at all, he could take the Fifth Amendment

23 and. the judge would sustain his Fifth Amendment
24 assertion by virtue of the fact that there was wiggle
25 room.
2 So it was my specific intent to

3 create no wiggle room so that the judge would say
4 sorry, l4r. Cosbyr you can't take the Fifth Amendment
q
because the D.A. has said that you will noL be
6 prosecuted for this case.

7 O And you told that in whatever form you told it to
I them, to newspaper reporters, every time you talked
9 about this case?
l_u That was your statement Irm
L1 trying to clarify, Mr. Castor.
72 A I told newspaper reporters -- if I didn't tel1
L3 them every time, it was darn near every time, because
t4 eventually you get tired giving 20 and 30 interviews a
1"5 day.
L6 But the I have been
L7 consistent from the first time this case came back
18 into the media that it was designed so that for all
L9 time Cosby would not be prosecuted for the Constand
20 event i-n order that he could never claim the Fifth
2I Amendment and there would be no wiggle room that he
22 could say in sorne remote way that he could ultimately
23 be prosecuted 10 years Later, because if that was the
24 case and the judge overseeing the civil suit agreed'
25 then I would have failed in the endeavor that I was
/, trying to achieve in making him testify and enhancing

3 what I thought would be the chance for a 1 arge
4 recovery civilly.
5 O I just find it interesting that you have such a
6 specific recollection of telling newspaper reporters

7 this, when I showed you perhaps half a dozen newspaper
8 articles that you had no recolfection of maki-ng any
9 quotations contained in those newspaper articles.
l_0 A I am very pleased to know what you find to be
1l- j-nteresting, but the portion that I have just

L2 testified to was the actual kernel of the case, the
t3 most important thing in the case.
L4 Specific st.atements at a press
15 conference on the 27Eh of January I don't remember
r-6 having. And I'm not going to sit here and lie to you
t7 and tell- you that I do have an independent
1B recollecti-on when I don I t.
r-9 But on this single-most
20 irnportant aspect of the case, I am absolutely certaj-n
2t that f have explained that to every reporter who has
22 ever asked ft€r because they always ask me why did you
23 do that? so I told them.
24 O The rnost important aspect of the case, and you
25 wrote in your September 23rd e-mail that you never
2 made an important decision without discussing it with

J your First Assistant, Mrs. Ferman; is that accurate?
4 A I did. And I wrote that I wrote it
5 ambiguously because I could not remember specifically
6 talking with her, so f am I am assuming that f did
7 because f had faith in her judgment and I would have
B discussed it with her.
9 But f was absolutely certain as
10 of the 16th of February 2005 that that was the right

l_L move, and there was no one was going to change my
t2 mind on that. So I would be surprised if I did not

13 speak to her about it, but I did not I don't have
t4 any specific recollection of it.
15 O So you must have been very surprised when she
t6 wrote in a letter to you on September 25Lh; "The
17 first r heard of such a binding agreement was your
1B e-mail sent this past Wednesday. The first I heard of
t9 a writ,ten declaration documenting the agreement not to
20 prosecute was an article authored on 9-24-I5 and
2L published today by Margaret Gibbons of The
22 Inteltigencer. "
23 That must. have come as quite a
24 shock to you, seeing as how such an important decision

25 you most assuredly would have discussed with your
t_ BRUCE L. CASTOR, JR. CROSS zu6
2 First Assistant at the time.

3 A It did not come as a shock to me that. then First
4 Assistant D.A. Ferman did not know of any other
F
3 written ag'reement, because that was an error in the
paper.
7 O What about the binding agreement t.hat she
I references ?
9 A The binding agreement, it doesnrt come as a shock

10 to me because I trusted her. And she remembers things
11 or she doesnrt remember things. And I believe that
L2 she telIs the t.ruth as she recalls it, as I am telling
13 the truth as I recall it.
L4 But on that duy, the 17th of
15 February 2005, I vtas the only person in Pennsylvania
L6 that had the power of the people to make that
r7 decis j.on, and I made it. And whether she was present
L8 at that time or not, I don't know.
t9 But I have a great deaL of faith
20 in Mrs. Ferman, Judge Ferman's lega] acumen and her
2L prosecutorial skiIIs, and I simply don't recalI
22 whether I discussed it with her in as stark a terms as
23 I am doing now.
24 o so earlier when you testified that you directed
25 her to explain your decision to the plaintiff's
l- BRUCE L. CASTOR, JR. CROSS 209
2 Iawyers, you're now unsure as to exactly what terms

3 you discussed with her?
4 A No, I'm not unsure at alL. I told her what we
5 were going to do, and I assumed t,hat she would carry

6 out my order to communicate that to the victim's
7 lawyer or lawyers.
I When you're the District
9 Attorney, you expect to be obeyed without question,

10 and she always did that.
L2 published. )
r_3 BY MR. RYAN:

t4 O I am going to refer you to D-6- Irm sorry, D-1-
t_J TeIl me when you have it in front of you.
16 A I have it.
1.7 O You have it. Atl right. So let's look at and
18 so this is Mrs. I'rn sorrlr then District Attorney

19 Ferman has written you a letter asking for any sort of
20 writtendetermination og any evidence of a binding
2t agreement with regard to the Cosby case.
22 And You write: The attached
23 press release is the written determination that we
24 would not prosecute Cosby. And of course you go on in
25 this e-mail to explain that you think perhaps the
a
l- BRUCE L. CASTOR, JR. - CROSS 2L0
2 article was misconstrued, there was a
? misunderstandinq.
4 But, what I want to taLk about is
5 the next sentence which states: That was what the
6 lawyers for the plaintiff wanted and I agreed.
7 Is it your testimony here today
8 that, again, when you say that I s something the
9 ptaintiffs wanted and I agreed, that. that statement is
r.0 based of f of Mrs. Ferrnan simply not returning to you
11 with any objection from the plaintiffrs attorneys?
t2 A Which line are You looking at?
13 0 tet me point it out for You.
L4 THE COURT: TheY have it uP in
15 yellow.
16 THE WITNESS: OkaY. We11, this
L7 is you want me to look at a different yellow part?
r"8 BY MR. RYAN:
t9 O I'rn sorry. I aPologize.

20 THE COURT: Are You controlling
2L that or are you controlling that?
22 MR. McMONAGLE: Judge, we've
23 been out of control for a couple hours.
24 THE COURT: TheY set it uP and
25 suddenly I saw a new ye]low appear' and Irm like where
1 BRUCE L. CASTOR, JR. - CROSS 2TL
2 was that cominq from?

? MR. RYAN: That was my fau1t.
4 THE COURT: Not a f aul-t. It Is
5 okay.
d BY MR. RYAN:
7 O Mr. Castor, f apologize for that. Letrs first go
I back to the first highlighted portion where 1t said:

9 The reason f agreed and the plaintiff's lawyers
L0 A Wanted it in writing.
r_1 O Ifm sorry, the first sentence: That was what the
1.2 lawyers for the plaintiff wanted and I agreed.
13 When you say rrthat is what the
L4 lawyers for the plaintiff wanted and I agreed, " what
are you talking about?
16 A The plaintiffrs lawyers, knowing' that Cosby was
J.7 not going to be arrested, wdnted to make a 1ot of
1B money for their client and a contingent fee for
1.9 themselves.
20 0 Where did that information come from?
21. A It must have come to me from Mrs. Ferman. I
22 don't recalI, but it certainly makes sense, because
23 once the decision is made that Cosby is not going to
24 be prosecuted, if f leave the case open, then the
25 civil case is infinitelv more more difficult and would
2 move more sIowly.

{ So I thought that was
4 corroborated by the fact that they would want as much
5 money for the plaintiff as possible and as much money
6 f or thernse l-ves as pos s ible .
7 And putt.ing in writing that we
e would not prosecute Cosby, which is what I did in the

9 press release, would be evidence that they could show
10 to a civil judge that Cosby is not getting prosecuted.
1"1 O Tf, of course, they could parse the language as
L2 you've done here today?

13 A It I s not difficult to say to a judge
t4 0 and I'm not going to ask you to explain it again.
What Ird like you to do is look
L6 at the next highlighted portion of this e-mail where
77 you wrote: I signed the press release for precisely
r-8 this reason, at the request of plaintiff's counsel.
L9 fs that because Mrs. Ferman told
20 you that plaintiff I s counsel wanted you to sign the
2L press release?
22 A Somebody told me they wanted it signed so that. it
23 had my actual signature on it binding the
24 Commonwealt.h.
25 0 But you don't rernember at this date who that was?
L BRUCE L. CASTOR, JR. CROSS 2r3
2 A I assume it was Judge Eerman, but I am not 100
3 percent sure. But what I recall is that once the

4 hurdle was over that Cosby was not going to be
5 arrested, the plaintj"f f 's side the f uture

6 plaintiff's side wanted it to be signed and I signed
7 ir.
I O What percent sure are you that it was
9 Mrs. Ferman?
r_0 A What percent? I am 90 percent sure. Part of the
tl- problem is that the detectives had a relationship with
t2 the victim and her lawyers as wellr so it coul-d have
13 come from there.
I4 0 That I s only 1-0 percent possible?
15 A The reason I can't be sure is there were other
16 people apart. from rne who were in contact vrith the
t7 future plaintiff's side.
18 O Right. You said t.hat vtas Mrs. Ferman on direct
L9 test,imony. You said she had a relationship with, I
20 believe it was, Bebe Kivitz out of a case which was
2t the Nevison (ph) case. And as a result of thatr lou
22 assigned Mrs. Ferman to deal with the plaintiff's
23 lawyers?
24 A I did not say thatr Do. What I said was
25 Mrs. Ferman had a relationship with one of the

1 BRUCE L. CASTOR, JR. - CROSS 2L4
z lawyers, because I thought she said that she had gone

3 to schooL with one of them.
4 0 Right, that was your testimony.
5 A I don't know the name of the lawyer and I don't
6 know about that lawyer I s involvement in the Nevison
7 case.
8 O I apologLze. That was mY fault.
9 So going down to lhe final
1_0 paragraph in this e-mai1. the first sentence, it
11 reads: The attached which was on letterhead and
1,2 signed by me as District AttorD€Y, the concept
13 approved by the plaintiff 's lawyers was a 'rwritten
T4 declaratj-onrt from the attorney for the Commonwealth.
1_5 When you say "the concept
IO approved by the plaintiffts lawyers," where is that
L7 information coming from?
1B A They wanted they wanted the government to be
1,9 bound by something in signed, saying that Cosby is

20 not going to be prosecuted, so that's what I did.
2L O Who told you that?
22 A Well, it was either Mrs. Ferman or one of the
23 detect ives who l/rtas involved in the case who had
24 developed a relationship with the future plaintiff's
25 side. Also, it makes logical sense.
1 BRUCE L. CASTOR, JR. _ CROSS 21.5
2 O AtI right. So I want to ask You now and werII

? return to this e-mail, but I want to talk to you about
4 the press release. Letts go back there. And that 's
5 D- 4 - Tel l- me when vou have it .
6 A I have it.
7 ( Defendant's Exhibit D-4
I published. )
9 BY MR. RYAN:
r.0 O So'in D-4, I believe itrs the final paragraph
t_ l_ and I pulIed it up here on the screen in the event you
t2 can't see it, but you wrote: District Attorney Castor
13 cautions alt parties to this rnatter that he will
L4 reconsider this decision shoul-d the need arise.
15 That's what that reads; correct?
t6 A Yes.
T7 O Now, what you testified to on direct was that
t_8 that sentence modifies the one before it, meaning that
L9 that sentence is actually a comrnent on whether or not
20 you would make any further public statements about the
2L case; is that right?
22 A That sentence modifies the entire
PartiaIly.
23 paragraph because the entire paragraph deals with t.he
24 civil action and how I wanted the parties to conduct
25 themselves in the pursuit of the civil action '
t_ BRUCE L. CASTOR, ,JR. - CROSS 2t6
2 So what I was saying was I
3 recognize the civil action, with a rnuch lower standard
4 of proof , is possible. I could have wr j-tten
5 trprobable" or even "certain. tt
6 I said that I didn't want to
7 express any opinion on the credibility of the parties,
8 because the publicity thenr BS it is now, was
9 overwhelming and the Philadelphia media market would

10 cover it alI and taint prospective jurors.
11 So f then went on to sdy, agai-n
12 referring to the civil case, that I would not expound
13 on the details of my decision for fear that my
1,4 opinions and analysis might be given undue weight by

15 jurors in any contemplated civil action.
1,6 And then f said that I cautioned
I7 all parties to this matter that I will reconsider this
18 decislon should the need arise.
l9 So all of that has to do with
20 the civil aspect of the case. I have seen that' taken
2L out of context, there is a suggestion that I was
22 referrj-ng to the entire decision of whether to

23 prosecute Cosby or not. Had f meant for that, I
24 wouldn't have put it in the paragraph dealing with the
25 civiL action.
2 But I also would have said that

District AtLorney Castor cautions all parties to this
4 matter that he will reconsider "the" decision should
5 the need arise, not nthisu decision, because "this" is
6 referring to the decision not to comment publicly and
T taint prospective jurors
R
O Thatrs what I wanted to ask you. Yourve said on
9 direct, and you're still maintaining nor^r, that that

10 sentence was not intended to mean that you will
11 re-open the decision as to whether or not to prosecute
I2 Mr. Cosby, because what, you said during direct was
13 that your legaI analysis bound the Commonwealth and he

t4 could never be prosecuted for the sexual- assaul-t
15 allegations that arose in January of 2004; correct?
L6 A No. I said that once I had made the decision
77 that Cosby would not be prosecuted ever, then the
l-8 Iegal analysis, ds a matter of law, made it so that he
19 could no }onger take the Fifth Amendment.

20 But if I felt that the office
2L needed to defend itself further than what I wrote
22 here, I would expound on ny reasons for not
23 prosecut j-ng Cosby. He stil] would not have been
24 prosecuted, but now the entire Eastern District of
25 Pennsylvania would know t,hat I did not think Andrea
l. BRUCE L, CASTOR, JR. - CROSS 2tB
2 Constand's testimony would be found credible by

J jurors.
4 (PhilIy.com article dated
5 1-3f-16 rrCastor could be key witness at Cosby hearing"
6 rnarked Commonwealth I s Exhibit C-]-2 f or
't identification. )
B BY MR. RYAN:
9 0 Did you read the Inquirer this Sunday?

10 A No.
1L O Okay. I rm going to hand you a document that I rrn
t2 marking as Commonwealth's Exhibit C-Lz and f want you

13 to take a look at that.
14 A Do you want me to sit here and read it?
15 O Are you familiar with it? Have you ever read it,
1"6 before?
L7 A No.
r.8 O Yourve never seen it before?

r-9 A No.
20 O Okay. So I want to direct you to Page 3 of 6.
2). Can you find Page 3 of 6?
22 A Yes.
23 O All right. And at the very bottom of that page
24 there's a quote: I have said repeatedly and for
n
25 mont,hs that i f I ever get the oPportunity where I get

l_ BRUCE L. CASTOR, ,JR. CROSS 2t9
2 the power to review the investigation into Cosby' I

? would do sort' he said before the election, referring
4 t.o you.
Do you remember rnaking that
6 statement?
7 A Yes.
I O Before the election, so sometime during 20L5?
9 A Yes. Well, it could have been 20L4.
1_0 O Either way. You'd agree with me that you made
11 that statement in either 201-5 or 2014?

L2 A Yes.
13 0 Okay. Let I s go up above towards the sixth
L4 paragraph. And it's actually a quotation on that same
15 page. It begins: ttI Put in there."

1_6 Do vou see that?
L7 A You say it I s the Page ?
".*"
l_8 O Yes. tet me know when you've found it'.
t_9 A I found it' Yes.
20 o I'I put in there that if any evidence surf aced
2T that was admissible then I would revisit the issue, "
22 he told The Inquirer in September- 'He* is you. And
23 evidently that is what the D.A. is doing.
24 Do you rernember making that
25 quote?
2 A Yes.
0 Now, the paragraph above it, that paragraph is
4 referencing the press release, meanirg, as we've
5 learned from what you're testifying to here today,
A that quote is modifying the statement ahead of it;
7 correct ?
B A No, that I s not. The article that t,he
9 paragraph that's in quotes, I put it in there. The
10 paragraph above that is not my words.

11 O So when you're saying: n J put in there that if
L2 any evidence surfaced that was admissible then I would
13 revisit the issue, and that evidently is what the D.A.
t4 is doingn -- you give that quote in September of 2015
15 in reference to this Cosby investigation what. were
L6 you talking about, Mr. Castor?
T7 A I don't. know what the what the "put in Lhere"
18 is, but I was and have maintained all along that if
1-9 Cosby could be prosecuted for criminal violations that
20 occurred in Montgomery County other than against
21- Ms - Constand, that I thought that vte should do that.
22 I first thought that the thing
23 vre should do was try to rnake a per jury case out, but
24 the statement that we could prosecute him for Constand
25 is not true.
1 BRUCE L. CASTOR, JR. - CROSS 22L
2 O Because what you said was that, you bound the

3 Commonwealth such that we could never prosecute him
4 for any charges related to Andrea Constand or the
5 incident that you were investigating in 2005; correct?
6 A This one arn f supposed to be looking at ?
7 0 ffm asking you a question. The reason that you
I donrt that you're saying that, that article is not
9 referring to anything in the press release or not
10 referring to your comment about the possibility that
l-1 the Cosby case could be re-opened is because you have
t2 maint.ained that in 2005 you specifically and
l_3 permanently bound the Commonwealth that we could never
1,4 prosecute the charges related to that investigation in
15 2005; correct?
16 A The sexual assaul-t cases, yes .
L7 O Right?
r.8 A If there was perjury, r thought we could
19 investigate that. And with all of the 50 or so women
20 coming forward saying t,hat they have been molested by

2t Cosby, I thouqrht that it was possibLe he lived in
22 Montgomery County that maybe some of them happened
23 in Montgomery County. And f saw no reason why we
24 couldn I t prosecute him f or t.hat. We just wouldn I t be
25 able to use the deposition or anything derived

l_ BRUCE L. CASTOR, JR. - CROSS 222
2 therefrom.
3 0 Let's turn back to D-7. That I s this e-mail that
4 you wrote to then District Attorney Risa Ferman on
q September 25th.
6 Do you have it ?
7 A Yes.
I O And in this e-mail, again you're talking about
9 agreements that were made in 2005 thatr €XactIy what
10 you just sa j-d, You wouldn I t use anything f rom the
L1 deposition.
L2 Now, you've testified here today
13 that you would never prosecute Mr. Cosby, but I want
I4 to direct you to the bott.om paragraph of thi s e-mai 1 .
15 Do you see that?
r.6 A Yes.
1'l O You write: Naturally, if a prosecuti-on could be
18 made out without using what Cosby saidr or anything

19 derived from what Cosby said, I believed then and
20 continue to believe that a prosecution is not

2T precluded.
22 Is that what You wrote to the
23 District At.torney of Montgomery County on
24 September 25th, 201-5, in reference to this case?
25 A That I s what I wrote. That's what I meant - And
2 that is what I stiII think todav.

3 But you are missing the point.
4 Tf f was referring to the Constand case, I would have
5 written: Naturally, if the prosecution could be made
6 out without using what Cosby said or anything derived

'l therefrom, I believe then and f believe now is not
I precluded.
9
oA prosecuti-onn refers to other
L0 victims, not Constand, that occurred in Montgomery
11 County. And I thought that with the enormous
t2 publicity of the 50 or so potential vict.ims that maybe
13 they had one in Montgromery County and then they could

14 prosecute that one, but they simply couldnrt use the
r.5 deposition or the anything derived therefrom.
1"6 MR. RYAN: I donrt have any
t-1 further questions, Your Honor.
18 THE COURT: I have a coupLe
L9 questions and then I'LJ open it. back up for redirect.
2T THE COURT: Let me start with
22 that. You believe that that statement was that there
23 could be other cases in 2015 of other potential
24 victims that may have arisen that you knew nothing
25 about that Mr. Cosby may have dj-sclosed in his
2 deposition testimony?
THE WTTNESS: NO. I WAS
4 readirg, like everyone else, al-1 of these women coming

5 forward saying that they had been rnolested. I thought
6 that if any of them had been molested in Montgomery
7 County
o THE COURT: You mean sexual
9 assaul-t. Molest is not a charge; correct? I want to

10 make sure. Itts not an indecent assault, sexual
11 assault. I just want to make sure that we're talking
L2 about molestation is not a charge under the Crimes
13 Code, is it, because the words are important here?
1,4 If youtd made an agreement
IJ regarding a charge that didn I t exist you mean
16 sexual assault of some sort?

T7 THE WITNESS: Yes.
18 THE COURT: OkaY.

L9 THE WITNESS: So what I'm in
20 that last paragraPh, what I'm trying to convey to
2L Mrs. Ferman is my binding of the Commonwealth not to
22 prosecute cosby vras not for any crime in Montgomery
23 County for all time. It was for only Lhe sexual
24 assault crime in the Constand case.
25 So if they had evidence that
1 COMMONWEALTH vS. WILLIAM H. COSBY, JR. 225
2 some of these other women had been sexualty assaulted

3 at Cosby I s house in Cheltenham, then I thought they
4 could go ahead with the prosecution of t,hat other case
wit,h some other victim, as long as they real-ized they
6 could not use the Constand deposition and anything
7 derived therefrom.
B THE COURT: But she wasn't
9 soliciting your opinion about prosecution of unrelated
L0 cases. We agree with that? Irm just trying to
l_ 1- yourve said it and thatts obvious. If it has nothing
T2 to do with the Constand case and has nothing to do
13 with the Cosby.deposition, then the District Attorney

l4 is free to prosecute any case it wants.
15 Is my understanding of that
t6 correct? You donrt have to tell her, h.y, prosecute
L'1 any case you want, just not the Constand case. Thatrs
1_8 what you rnean by that?
19 THE WITNESS: No, not. exactly,
20 because if youfve got to if the D.A.'s Office
2t had qotten to this other victim or gathered evidence
22 on t,his other victim by using what Cosby had said in
23 the Constand deposition or anything derived therefrom,
24 she had to be cautious and separate that out before
25 moving on that other victim.
2 THE COURT: You also mentioned

3 possibly that if she wouJ.d have an independent basis
4 for a perjury charge. You mentioned that?
5 THE WITNESS: I did.
6 THE COURT: Now, where my
7 understanding from everything that Irve read is that

B there was never anv statement that was taken under
9 oath by Mr. Cosby, is that correct, in your
10 investigation of the Constand case?
11 THE WITNESS: NO.
L2 THE COURT: Let me just make

13 sure. There was no statement under oath in the
L4 original investigation? They were statements to the
r_5 police?
1,6 THE WITNESS: Right.
1,7 THE COURT: And if there had
r_8 been a statement under oath by Mr. Cosby' that would
L9 be dif f erent than his statement to the police, t'hat
20 might be a basis for a perjuryi would it not?
2t THE WITNESS: COrrCCt.
22 THE COURT: Now, Lf he gave a
23 statement in his September depositions, in his

24 depositions while he was under oath, that was
25 different from his statement that he gave the
L COMMONWEALTH vs. WILLIAM H. COSBY, JR . 227
2 officers.
? Are you saying that I s the
4 per j ury ?
5 THE WITNESS: YES.

6 THE COURT: But that's derived
7 from the very statements that you were encouraging him
B to give in a deposition, is it not? Itrs derived.
9 Itrs a crime. Hers saying that I didnrt do it.
10 You meant to bar his prosecutj-on
11 for this case so as to encourage him to give a
L2 deposition. If he then gave the deposition and it
13 differed with the statements that you had in your
L4 file, are you saying you'd turn around and she should
L5 as welI prosecute him for PerjurY?
r_6 THE WITNESS: YCS.
t7 THE COURT: OkaY. Let me make

18 sure that I'm clear. Are you now saying that there
19 vras no agreement not to prosecute? Irve heard you say
ZU that a number of times, there was no agrreement not to
2L prosecute.
22 THE WITNESS: Correct.
23 THE COURT: There was a decision
24 by you not to prosecute.
25 THE WITNESS: Correct.
2 THE COURT: And you gave al_I

your reasons for doing that. And so at that stage you
4 did that because you wanted to strip Mr. Cosby of aLl
5 his Fifth Amendment rights; is that correct?
6 THE WITNESS: For aII time in
I that case.
I THE COURT: In that case. Now,
9 for instance, if he had gone and one other thing.

L0 There was no civil case at that time; is tbat right,?
1t_ THE WITNESS: Yet.
T2 THE COURT: There was no civil
1-3 case filed by the plaintiffs at this stage. You made
L4 your press release on February ?th. There was no
15 filed civil case in the Eastern District of

r_6 Pennsylvania at that time; is that correct?
I7 THE WITNESS: Yes.
1B THE COURT: It is correct there
19 was not. And vou had learned from whom that there was
20 a possibility of a case?
2L THE WfTNESS: I believe it was
22 from Andrears lawyer's comments in the newspaper and

23 Mrs. Ferman, and the deduction that I concluded that
24 Andrea and her mother were trying to extort money from
25 Cosby to keep from going to the police.
1 COMMONWEALTH vs . WI LL IAM H . COSBY, .JR. 229
z THE COURT: So there was no

3 case. And the depositions, in fact, didn't occur
t until September, is that right, when there eventually
5 was filed a case?
6 THE WITNESS: f think the case
7 was filed in March.
I THE COURT: That's correct. And
9 then the depositions that you wanted to strip him of

10 any clairn of the Fifth Amendment had not even been
11 scheduled? This wasn I t imminent or pending or people
1,2 were coming to you saying, wel1r w€ want to move
13 forward? There's nothing there? You were looking to

1,4 the future?
l_5 THE WITNESS: CoTTect.
l_6 THE COURT: And j-n doing sor if
I7 at that stage other cases had come out, because there
18 were cases that were out there, you had made a
I9 statement that they didnrt go to the police, so
20 therefore they may not be, but there were other at

2L Ieast allegations out there; is that correct?
22 THE WITNESS: Yes.
23 THE COURT: And if they occurred
24 in some other state, California, that somebody made a
25 statement, but maybe they didn't go to the police, and

2 the plaintiff's lawyers began to ask him questions

3 under a deposition about criminal- conduct, you would
4 not believe that that would be any basis for your
5 statement that you wanted to strip him of his Fifth
6 Amendment rights to raise the Fifth Amendment; is that
7 correct ? He can raise the Fifth Amendment any tirne he
I wants, couldn't he?
9 THE WITNESS: For any

L0 incriminating evidence in any other case apart from
11 Constand.
L2 THE COURT: But assuming that
13 you didntt prosecute. There had not been a civil case
L4 filed. It wasnrt filed until almost a month after you
15 made your press release. And in a deposition in
1"6 September, if he just chose on advice of then counsel
L7 to say f stand on my Fif th Amendrnent rights, there is
18 nothing that you could do about that because you're
t9 the District Attorney of Montgomery County. You're
20 not counsel in the case. There's just nothing you
2t could do about it.
22 THE WITNESS: That's not true,
23 Your Honor. What woul-d happen in that circumstance,
24 and has happened, is tbe plaintiff's lawyers go and
25 complain to the judge that the exercise of the Fifth
1 COMMONWEALTH vs. WILLTAM H COSBY, JR 237
2 Amendment is improper.
3 The judge then would ascertain
4 the questions that were objected to under the Fifth
q Arnendment and then would ascert,ain from if they
6 were involved in the Constand caser oscertain from me
7 t,hat there would be no prosecution and order Cosby to

I testify on those issues.
9 THE COURT: The question wdsr
10 you could do nothing about it. You couldn't order him
L1 to testify. do anything other than be
You couldn't a
L2 witness in some case in which some judge in the

13 Federal Court would have to make a decision as to
1,4 whether he was granted immunity from that testimony,
15 but there's nothing you could do about it. You would
L6 be a witness, much the way you are here.
L7 THE WITNESS: In my experience,
1B it has not worked that way. In my experience, the
19 judge has cal-led and saidr'Are you going to
20 prosecute?" I wouLd tell him no and he orders them to
21. go ahead.
22 THE COURT: I'm not sure I've
23 never experienced that, but in Pennsylvania we have an
24 irnmunity statute, don't we? You're f amiliar with it?

25 THE WITNESS: Is that a question
L COMMONWEALTH vs. WILLIAM H. COSBY, ,JR . 232
2 f or ttl€, Your Honor ?
? THE COURT: Yeah. You're

4 familiar with the immunity statute, which is 5947 of
5 Purdon's?
6 THE WITNESS: Your Honor, on the
7 issue of immunity, that is for use and derivative use
8 immunity only. At common law, the sovereign has both
9 the power of transactional imrnunity and use and
10 derivative use immunitv.
t-1 THE COURT: Irm familiar with
L2 it. Irm just trying to get to your point. Let me ask
r.3 you 1ook, it wasnrt utilized in this case because
L4 you never even charged Mr. Cosby, and you didn't
15 charge hirn because you rnade independent reasons.
L6 Let me get to this. If you felt
L7 there was an agreement, vrhy did you not make that
l_8 agreement j-n writing with the plaint.if f I s attorney,
r9 wit,h Mr. Phillips, yourself, create a miscellaneous
20 docket number and simply file it away?
2L Why did you not do that, because

22 your intention was to bar prosecution at aII times? I
23 mean, do you know why you didn't do that?
24 THE WITNESS: The it was
25 unnecessary because f concluded there was no way that

I COMMONWEALTH vs. WILLIAM H. COSBY, JR - 233
2 the case could ever get any better. And if

3 Mr. Phillips and Mr. Cosby's lawyers wanted more than
4 Ehat to protect themselves, it was up to thern to
5 provide it. But the plaintiff's are not party to any
6 of that because the litigants are the Commonwealth and
a
the suspect.
8 The utilization of the statute
9 requj-res permission of the Court, and I did not want
10 to first of all, there was no judge to file it in
1t- front of,
I2 THE COURT : We],1, in this
13 countyr 1lou know, there's miscellaneous dockets for
L4 all kinds of seizures of property where person never
15 gets prosecuted, but somebody makes a deal that we I 11
16 give you back $5,000, we I l-I keep him, and we want a
l1 judge's signature on them.

18 f meanr you can create
19 miscellaneous dockets and do whatever vou want.
20 Thatts your experience at least with forfeitures,
2t isn I t it?
22 THE WITNESS: It is. And I
23 donft want to argue with the Court
24 THE COURT: Itrs not an
25 argument. I'm not really, I'm just trying to

I COMMONWEALTH vs. WfLLIAM H. COSBY, JR . 234
2 wonder that if this agreement existed and we
3 definitely have, you know, this I recognize your

4 common law immunity of witnesses, but we have a
q statute that talks about how to do it.

6 THE WITNESS: No. I disagree,
7 Your Honor. There are two types of immunity in
I Pennsylvania. There's transactional immuniey and use
9 and derivative use imrnunity. At common law, the
1,0 sovereign has both.
1_1 The leqislature has taken that
L2 power has taken the use and derivative use immunity
r_3 power away from the sovereign so that you if you're
L4 going to grant use and derivative use immunity, the
15 sovereign has to go and ask permissj.on of the Court
t6 and explain why.
L7 THE COURT: Exactly. You
18 just at this stage you felt you didn't have to do
19 it. I understand it. Irm not I'm trying to find

20 out if there were mechanisms that were at least in
2t existence, something to memorialize what werre doing
22 L0 years later in trying to put together whether there
23 was an express agreement not to prosecute. ReaIly, I
24 mean, I understand it.
25 If you wanted to create it, Itm
1 COMMONWEALTH vs. WIILIAM H. COSBY, JR. 235
2 asking were you aware of obviously there I s a
statute that does deal with use immunitv in

aA Pennsylvania; not specific to this case, O"a it was a
q
way to at least get a judicial sanction on it or
6 judicial approval of it. You file it away and you
,7
bring it out'should something like this ever occur.
8 You just felt it was not
available to vou?
10 THE WITNESS: f f elt it lras
11 not f felt it vtas not appropriate for several
t2 reasons. The first is the civil case hadn't been
13 filed. And in order to go and seek use and derivative
L4 use immunity in a civil court, you'd have to go to the
15 federaL judge. You'd have to ask him to grant use and
16 derivative use immunity. Not a Montgomery County
T1 judge. So hers utilizing a Pennsylvania statute.
1_8 That's number one.
L9 Number two, from Cosby's point
2A of view, the request for immunity woul-d be a
2t suggestion in the Court of Public Opinion that he had

22 done something wrong and he, therefore, needs
23 immunity.
24 And number three, I didnrt want
25 there to be use and derivative use immunity. I wanted
1 COMMONWBALTH vs. WILLfAM H. COSBY, JR. 236
2 there to be the equivalent of transactional immunity,

which by default lays soIeIy with the sovereign and
4 does not, lay with the Court, because the legislature
( took the power of use and derivatj-ve use immunity
grantj.ng away from the sovereig,n and requires
1 application to the Court and approval of the Court.
I fn order to achieve approval of
9 the Court, I would have had to tell the Court in
10 public filings that the victim in this case had
11 engaged in conduct that drastically damaged her
1"2 credibility. That would have been publicized and it
13 would bave acted as a deterrent for other victims
_Lq comingr forward.
t_5 THE COURT: Al-1 right. I
L6 believe you had testified you had said, to your
L7 knowledge, Mr. PhilIips did nothing in exchange for
1B your decision not to prosecute r' is that true?
20 THE COURT: And then I assume
21. that you utilized there are certain disciplinary
22 rules regarding roles of prosecutor and decisions to
23 prosecute; is that correct?
25 THE COURT: You've reviewed
t- COMMONWEALTH vs. wILLIAM H. COSBY, JR. 237
2 them. There I s certain ABA st.andards that I assume

? yourre familiar with. You have said once you made the
4 decision not to prosecute, which was your sole
5 discretion to do sor why did you feel compel]ed to do
6 anything else ?
7 I I m just you I ve explained it,

R but Irm just saying if you could answer it one other
9 time. Why were you compelled to do anything else in
10 this case?
11 THE WITNESSI WeII, I have to
1,2 tell the public what the decision is.
13 THE COURT: Where is that in
I4 your Rules of Conduct that you have to te1l the public
1_5 what your decision is?
16 THE WITNESS: In the special
1.7 rules of a prosecutor, it says that the prosecutor
r.8 shall not make extrajudicial statement.s beyond what is
t9 necessary to j.nform the public of what he or she is
20 doing and the outcome of a prosecution or an
2I investigat,ion.
22 So f had to tell the public what
23 we did. And ot.her than that, the only thing I wanted
24 to confirm was WaIIy PhilIips I agreement with my legal
25 analysis that if Cosby could never be prosecuted, he
L COMMONWEALTH vs. WTLLIAM I{. COSBY, JR . 238
2 therefore could never Eake Ehe Fifth. And t,hose were

J the only things I did.
4 . THE COURT: Right. But you,ve
5 testified here today you wanted him to be punished,
6 and t,hey got a lot of money f rom the civil case. I
7 mean, yourve stated that that was clearly once you
I c\eared the hurdle of his Fifth Amendment rights, that
9 theyrd, be free to bring a civil case. And you were
10 convinced at that, stage they would be able t,o
11 capit,al ize on it, that they would geE money and in

T2 sqme form he would be punished.
13 r i But Ehere's nothing t,hat
14 rqquires you to do something like that to eneure if
I3 youtre not going to prosecute that something else will
i
16 happen to a defendanb?
a
t7 l THE WITNESS: I took Lhe word in

18 the the words in the disciplinary rule that says
79 the prosecuEor is a Minister of ,JusLice to mean thaE I
20 should find a way of achieving j ust ice , and that 's
2L wliat I did.
22 THE COURT: Okay. That was the
23 Cqurt's questions. So I don't know what he whether
24 ygu have some redirect
25 I MR. McMONAGLE: Very brief
!
l_ COMMONWEALTH vs. WILLIAM H. COSBY, JR. 239
2 THE COURT : We're going to

3 recommence, after this witness completes, tomorrow
+ mdrnirg, if we just have to do argument, or any other
5 wiEnessesr aE that time.
6 MR. McMONAGI-,E: Yes, sir.
7 THE COURT: Because we have nov/
I pushed t,he bounds
9 ,
MR. McMONAGI-rE: May I , Your
10 Hqnor?
11 THE COURT: Yes
t2 REDIRECT EXAMINATION
t3 BY MR. MCMONAGI,E :
14 O Mr. CasEor, I want to follow up on some of the

15 queeEions thaE His Honor just asked and maybe a couple
16 qqestions by Ehe Assist,ant Dist,rict AEtorney.
L7 You jusE indicaEed that, de a
L8 Minister of ,fustice in thls case, You wanted Eo see

19 that justice was served; is t,haE faire
20 A Yes. Mr. McMonagle, those are the actual words
2r' in the comment to the ru1e. And it's capitalized-
22 T4u prosecutor is a Minister of rJustice. And I
23 t,hought that meanb f was supposed to seek justice t'o
24 the best of my abilitY.
25 Q r And seek j ust,ice to the besL of your ability in
L BRUEE L cAsToR, JR. . REDIRECT 240
2 this case led you to a conclusion t,hat you should in

3 t\is case make a decision that Mr. Cosby would never
4 be prosecuted for the allegations involving
5 Mq. Constand; am I righL?
6 A You are right.
7 0 And being a Minister of rlustice in this case, you
I a\so came Lo the conclusion that you wanted to make it
9 clear
\
to Mr. Phillips as his counsel t,hat that's
L0 exactly what, you were doing?
11 A r Yes.
t2 O And you did? You actually gave your word
13 strike that. You gave the word of the Commonwealth of
14 Pqnnsylvania in this case to Mr. Phillips that, you
L5 would not prosecute his client for the allegations
16 involved in the Constand matEer; am I correct,?
L7 A. I was noE acting as Bruce CasLor. I was acting
1B as the Commonwealth. And on behalf of the
19 Commonwealth, I promised that we would not, that, Lhe
20 Commonwealth, the sovereign, would not prosecute Cosby
2L tlr the Constand matter in order to forever st,ri-p his
22 Fifth Amendment privilege from him in Ehe Constand
23 sexual assaulb allegation case.
24 Q; Ever?
25 A .r Ever, ye s .
1 BRUCE L. CASTOR, JR. - REDTRECT 24r
2 Q, And you told that to Mr. Phitlips; correct?
? [: I told it to him in no uncertain terms, and he
4 understood it explici-t1y.
5 O And relied on your word?
6 A: It was, noE my word. It was the word of the
7 Commonwealth of Pennsylvania. And the people of
I MonEgomery County granLed me the power to bound Lhe
9 Commonweqlth of Pennsylvania.
10 I
MR. MCMONAGI.,E : YOUT HONOT,
11 thank you.
t2 THE COURT: Is that iE?
13 MR. McMONAGI-,E: Yes, s j"r.
t4 THE COURT: Any final recross
15 ertami nat i on?
1.6 MR. RYAN: No, Your Honor.

L7 I THE COURT: AJl right. Thank
18 you very much. You may step down.
L9 THE WITNESS: Thank You, Your
20 Honor. May I be excused?
2t ; THE COURT: Yes. At this stage
22 ftm releasing him as a witness in this case. And
23 whoever subpoenaed him holding the power of that
24 subpoena, hearing nothing, I wiIl release it and he's
25 free to go.
1 . BRUCE L. CASTOR, ,JR. - REDIREET 242
2
, MR. McMONAGLE: f subpoenaed
3 n_,t*, j udge, and I have no ob j ect ion to him being
4 released,
5 (Vlit.ness excused. )
6
7 _ THE COURT: We will reconvene

8 tomorrow morning at 9:30. The Decorum Order remains
9 in effect. Again, however many witnesEeE you intend
t_0 Eo calI, you will caII.
11_ f do want to make a decision in
72 this case Lomorrovr, so i.f Ehere are briefs that are
13 accompanying any of your arguments with some of the
t4 t,estirnony that occurred today, I guess you'11 work
15 ]ate.
t6 ; And I intend to revisiE the
T7 issue regarding removal of the prosecutor and hear you
l_8 on iE at best,. f hope again, I donrt believe
19 therefs any testimonial evidence necessary there, but
20 I;would like to make Ehe decisions in this case one
2L w4y or the other so we can move fbrward.

22 AlI right?
25 MR. RYAN: Thank you, Your
I COMMONWEALTH vs . WILIJIAM H. eOSBY, ifR 243
2 Honor.
3 (At 5;20 p.m. , proceedings were
4 concluded. )
t_0
11
L2
13
I4
1.5
r-6
L7
1B
19
20
2L
22
23
24
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244
CERTIFICATE
I hereby cert i f y that t.he

proceedings and evidence are contained fuIly and
accurately in Ehe noEes Eaken by me in Ehe above cause
and that thie is a correct transcript of the same.
VIRGINIA M. WOMELSDORF, RPR

OfficiaL Court ReporLer
245
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a.n [2I Llt2 115122
lo-ninura [1] 68125 163/20 L6sl25 L5112 t6114
1oo t3t 21/22 Le6lt8 2L312 t68ll6 L6gl22 L1Olr L77120 t2t 27/4 23712
11 I{t ?312 L97l2r t98ls LeelLL 2021L8 2L919 2L9l7L 161 2/10 L3Al7 73311 Ltll2s
11: rto t2l '59tLL 69/Lr 15 t3?l 3ls sllt 3122 3/24 t44lr7 74r/2o
12 lfl sliL Lrsls 27516 2t8l]2 416 u8 9712t 92125 e3l9 e3123 t2l 5lr7 6e/8
12:01 a.u [1] Ll5l22 95112 96/6 1o{/11 LO6lt3 toBlL2 i.ty tl{t elLT 2318 29/8
12:30 t,ll ;68/2s 69/3 L0Ll1 t7o/L6 L?O|L' 17113 LTLlLo 3217 361L3 s7l7 63ltt 67112
t02lL2 a ]::-lLe L7L|L6 r?tl2L t'7316 9S/25 ee/Lt ts?lre tssls 239124
12th tst L76/6 L76/\9 l77lt3 n3/9 A73lL6 L13124 L16123 239125
t8ol9 18O/L2 r88l2L L95l2L 197/22 198/15 t3ot sltl 8/6 Lel6 22/L4
13th llt 761L4 2Or/1 2L918 2L9ltL 22o/t4 251L1 261L3 29/2s 37/L7 53/22
1{ I{l 3ll tt8/L2 LLB/2L 176123 222/24 223123 55/t5 56/1 56124 6217 58llr
lath t3l |tzltt L77lt6 180/10 1212 771L8 87lLs 82ls s8ll7
2015 t3l LllL 3/r7 L9ll3 tlo/6 L23ltL L33/2L L54lL9
ls tsl Ll\ 318 L3tlte L1ellt znd l2l tsrl6 lB4lto LgOl4 t8L/2 LS6l23 19{/1s
207120 I 3 t3t 3/22 9616 L8817 20a/2L 22Ll2s 238lLO
16 t3l 3ltr selt' 2t8ls 3rd t7t 1'O5lL7 Lg9l9 L74125 about [135] 6120 L2l7 L3l8
16th t1l 107llo LS7l2O t88/2L L9613 206125
22125 2312s 28/Lt 281L2 291L2
l?t}r t3I ltll€ zoslg 2o'ltr 24 tzl 3lrr t97122 3u2t 31122 33/6 3el7 39/L7
1s t2l zlis Ls8l7 2{rh tzl t98lt6 2OL/7 4Ll4 44120 $12 eslLL 16/7L
18th t3I lsalrs L58lt7 1s8/19 25 t?l 3l2r 416 418 LO{ILL a8l3 48124 s2122 s2l2s 52/25
1e tzl 2l?L t65125 106/13 L08lL2 198/1s s3/L3 sr/20 5u2S Sels 58lLL
198rr I1l +412 I9l tos/18 106123 LO8l23 58/L9 S9l4 6212L 52125 6913
1e8s I3t I3/L2 t3l'-3 U/4 L52lL3 Lgsl2l 19612 2o1/L6
5914 7Ol6 8s122 891L7 9rl3 etl4
1e85 t3t tu:3 ulrc tsls 22215 222124
92/5 9314 9318 941L7 9614
198? I2l L5/6 L7/L8 I8l 2lLr t29lr3 L42122 110/11 LLLI3 rt1-le LL2|LB LL6l7
1e€8 t.l t5lL3 Lsl2O tsl22 r47lL[ L41l2o 14812 t'ol2L LL6l8 Lr5l'-r rt112 t2ol6 L23/r
L'Ll20 L2319 L?4178 t26113 t29lL9
20/22 27 tzt 2lL6 t'2l7 L3tl5 L34lr{ 13s/5 t3317 r38/L7
is/23 27th t{l t3319 L3S|L9 1{5./s L42/LS Lr2l20 142122 L3Ol6
lets nls fi17 LTle 206lts 1s1/13 t5315 Ls'l23 1s9/13
2Ll6 2:30 t2l L3212 t3217 L6O|L9 t6\l22 L51lLt 168/11
7lzt 8123
L68lL2 l7o/3 L7rlLl L73lLs
\6712 L6714 L68lt6 17414 L14lL0 1?5./15 L73ll6
iot/zs L?s/22 L7612 nel6 L7816 t78/1
7o2lL3 30 l3l r3/8 L35lt4 2O5lL4 Lstl'' t83lr8 183/23 18{/5
30s t1l 28lr
LeA/12 LS4/t5 tgtlL? LBrlLg
L86179 L86120 L86123 l87lLB
2-17-03 t2t 3/2L 7olL4 1s8/13 t89l2} L89120 190/15
5512 63123 r1s/8 205/1'l rl:00 t2l /5 L9O|2O r9L/3 L9L/2s 19213
20 t{t t87 L8715
L92lL3 L92124 L96/L2 197/6
2OOO a2' L7lto LT|LL L9819 L99lL5 2oL/23 20sl9
2OOa t{l s4lt8 76lLO 202121
2t7 lL'
2O1l!3 2lal7 2tol4 2LL/r5 zLrl6
2L125 22L/L9 2231L2 2L313 2L5l2o 220/L5 2zrlto
2oo5 tToI s2/16 2122 319 2rl2o t3t 22218 223/25 22411.2 22s19 2SOl3
2512 251L6 321L9 4tl2L 4712L 9rr7t1l 23214
23OlL8 23Ol2L 237lt0 23LlL5
47123 47tir, SslT 6ottL TLlLs :oo Ill Le6l2o
r20 t1l 2341s
12lA 7414)761].4 85/L5 e2lr6 24313
slls s4/L7 esl2l e6l4 9811 above [?I LL6ILG 2OO/8 203/20
t t1l 8212 ahead [8] 95/20 97/3 LL2|!L
tted t2l LglLG 127/Ls Ltll6 t8sl23 22016 22s/1 23L/2L
trtl 27elt3 22013 tting t1l 39/L3 ahold [1] 100/16
220lLO 24116 t t2l 2812 28/3 ainrt [1] 2Ol1
bcent r2lr L6/g 69/4 tg [1] 27125 all [112J 5ll4 6/6 8125 glLg
ute ltll 203113 203/16 t1t 8s/27 9/23 Lt/76 LL/22 Lrl25 LS/L5
20417 20rIL2 11l 771r4 L8/22 2O/s 2214 21/L6 2{lL9
utelyi [5] 67175 89/12 advaraoly [1] 7816 32122 31ltr 3817 38lLO 12/3
Loolzo 206/20 2O7/9 advice [3] 73121 91125 23O/L6 4218 r3l2r 49/t9 5L/L9 53/L4
€ [1] .22/8 ffect llll s/25 4'E123 1816 s4lLe srl2r s8lL( 5a/tr ssls
ed lrl ;. a4/t4 95/2L 60/Lo 6olL2 62lLO 6s/t6 66/Ls
Ill LllS ffocted [1] S3l18 651L6 67lLL 671t3 671L9 68120
I?l 85117 L13lLa fftra I1l 6717 7O12 72/6 721L4 't7/7 7e/7L 8Ol6
accels Ill' 58/18 fraid [3] 3Ll3 34/LZ 841L3 84125 87/L3 e7lLs 8s/20 89/22
acconpanying [1! 242/L3 I41l 3lL2 7123 L3124 L4l3 LOtl6 L02ls 103/to 108/10 1111s
acconpliah.I2l 421L3 66/7 Ls/z L6lL1 3Ol3 311L5 sLlS Lr3l8 Lrslz LL6l4 lL6l22 72015
r3l 618 63/74 e4l5 Sslrs s6ls 5817 60172 12216 L22lL3 L22/Ls L23111
ccordinglf [1] LO2/7 'L/tL
66/79 82/27 81/22 90lt3 9714 ,231L9 t24/L3 t25lL3 L2s/L5
ccount [6f t'516 tL2/25 ).L315 9813 LOO/s 103/16 7O8/21 rLOlE a23lr6 13216 L3r/t3 L39ll2
tr3l6 t26IL9
-a-- r26l2t LL4l23 LL4l25 r27lLO L2g/LL Lr118 LsOl2 t53/t4 Lsr/ts
---. --
ll! eLl2O 72SlL4 t49lr3 15212 !55122 t57lLs 760/23 L62/2O
t2l t37124 161/16 L72l2L l76lLt
'4613 1e613 L91/23 L63lL4 t6slL8 76s/2L L9L/22
tdt 67ls 18.1t1 851t7 2'tl4 aOLIL{ 203/19 230llr t92lr4 L9412 t9sl4 z0rlzL
L38l2r LA5/24 L76/1 19912 207/3 23913 204/22 2os/L8 20914 2g9lt7
uEatory;tzl asl2o 21416 ternoon [2! tL1l24 LLL/2i 2LS/2 2LS|L3 2L6/LO 2'-6/L7
reve I{f 981L3 t2612 20612 in [{91 slg 5lL2 519 9125 2r6lt9 2r713 2t8123 22OlL8
30/10 {0,/9 lLlLz 4313 SllLL 2211L9 22tlr 221123 22812 z7slr
ed I{t zrls L25l2r 5L/L5 69/10 7OllO 8Ol3 8L/6 22s16 232/22 233/LO 2331L4
ins l1l 238120 gLl22 e3124 9elt'5 9812L 101./15 2361L3 21tlL1 242122
ntan6ec [1] 7Al!1 LO3l8 LO8/t6 LLol2L L25lL2 ell.agarton [5] 25.13 34lLS 6oltl
t1l t97lL6 L31124 L32/8 L45l2L t49ls 761L3 240123
t6'I S6lL8 s6l2r 571L9 SA|T L49123 150/11 150/13 legaclonr [22] 2/L2 3/9 24122
86125 LgLltg '.19lL8
L5'Ol22 15{/10 160/10 L7O/LS 26120 3412r 581L6 38125 se/s
ctad [3t itsltg 2oLl2o 23611-3 L'rLl2' L82lr5 L81lr Lgole sgl6 6012 6619 75123 L3814
crins ...f
tsl i 16/1s
.8tl.
2Ll9 Ectln
qa t6
661L7 LgolL3 19212 L9517 2LOl8 L38123 L39ls tTSlLL L79/r3
24OlL7 2461L7 2L2/r1 2L6|LL 22218'-gBlrl-
212/9 tso/L1 2/71L5 229/21 2.O14
ction [8] ! eslz 81122 L96llO 2421L8 2rolL5
atsl2r 2Lsl2s 2L613 2r5/L3 t38l 2lL7 316 2rl7 llegod J1ll 6123 5olL2 S3lLg
2L5/2s j 24/23 28/20 31124 4O|LS 57112 s6l6 ss/8 58/22 181L2 Lrgl1z
ctiona t21 62/2 85llL 6OlL8 64/9 75124 77122 7812 ts2l2 rALllL LBL/L2
ctLve [lt' gal22 7813 8Ol5 S2/L5 9sl2o 9912 l.egedly [2] 541L7 L78l'l
viw t{t to3/t7 9elt2 tLglLz Ls2l7 ts2ltr a2, LB3l3 L8314
t l:-l '7512t L52lL8 155/10 17215 L72lL7 Ior [?l Lollo s7l6 57/6 60/9
r t6I i 8/A TslLO 160/1tl t7sl2 t7{/3 ]-7116 L76l2r L78/L7 60123 e]-l3 L3717
206172 2L2123 239120 L8318 tgglts 20218 203123 2ou5 a7, 1s/9 {9/13 50/10
ccually [51] L2IL1 7513 L8l6 204lto 220120 5e123 6517 68lLO A7lLA
26/5 35/3 17/22 Srl2O 1L/L7 t1l 3llLe llora [2] 9tl2l L3L|2L
72/Lt 76/r8 80123 8316 8912 t{t 4ol2 LL9|2O L44122 lnoct [9] 27lLs 59123 9814
89./S esl10 e?lle Lo6/2 110/13 LL9/25 L23/r4 L5318 L62lL2
LLO/18 t27lr L34lt0 15?/5 I2Ol 3t/9 32122 s5le L62h1 23OlL4
L64lL3 r7s/t2 L97lL, LL713 L99/2r LlO/r 110/6 L4O|LI one [1] 36/14
'6llL4 2L5ltg zrell{
1e8/16 2Ogl2O L5518 L'5/LL L55/2s t5616 long [?l 2o/2o 25/L4 9212L
2401L2
ILa .-) tssll3 LTLILS 183/18 t89l13 93ltL to9l6 ts6l7 zzolLg
en [1]': 2O8/2O L89123 t94/20 2tglLO 223lLO raady [8! 48/LO 5315 7418
I16t 65lt' 6SlL2 65/2r 90123 9815 1L7l2O L67117 LeOl6
":
d t1l ,Le3l23
ng tll I uzls 6713 6714 67la t'slL5 174123 t26l 7lL3 2312L 2el2s
tion tJl 5o/L6 93122 1os/19 L82/9 L8514 2Asl24 27O16 2LOle 4L/L3 r4l7 s3123 5611 581L4
tlonall [1] e0122 2LLls 2tL/L2 2ltlLl 6LlL7 6t/21 67/8 611t3 73lt0
eaa [8] 96120 LO2l4 LO2/LO r tsll sl2s 613 27/2 76122 1e/s 8517 LOBl23 ttalta
tssl? L3918 L3gltL t39lL3 lrols 3|lt2 3Lh 3L123 3211 321L5 rzrltg t59ll4 189./15 2oLllg
addresaed l1l 93120 3317 33/L3 .2/3 r9l2o 5olL3 2Lrl2s 2L712 22612 21018
rdjourn [1] Lt7l22 64122 7L/1 TLlLo 981L9 98122 tlrough [2] 35/a L4rl2O
nictratlon [1] LSIL2 sg/8 tosl:.4 L}gl2r LLol2 t.tol6 alray! [8I 521L6 521L6 118/13
adrdnictrator [1] SlLl tzllrl t7r/L3 18819 LBglLz L48/to 2O2l2O 20313 2a6122
a'r"tiaribil{ty l3l l1/L3 82120 188/r? L88l2L l.88122 L88124 209lLO
L2Ll22 { L8gt3 t8sl1 190./10 190/16 195/rt an ttlsl t9l6 22123 2314 2rlL1
[11] 6016 60lLB
adniccl.blef tssle 2o7/11 2o7l'-g 2o8ls 208/7 1917 4919 63/2286113
63123 63/24
821L3 L2OL?O t25123 t6117 2ASle 209/2L 22rlL4 2271L9 7515 18ls 7919 99111
203122 20113 20419 2t9l2L 227120 232/L7 2321L8 23r/2 LO9/L7 LLrls LL4l9 L31lr Lr2ls
22o/L2 i 234/23 231/24 r42/LA L{:lt]. L5213 t52lL7
adsireion [1] 43lS agreeuentr [3] 26122 lo1l2l 153/18 Ls9l23 163/11 L63l2r
acionr! [1] I6Ll3 222/9 L'sl7 L96/78 L97ltO L98122
18/2 A8/6 l9/L3 50/24 601L8 13 0/ 11
6L/t3 6L/25 62/7s 62123 66/L3 approechlng [2] L32/25 t66/6
Ilrf l' 199,/{ 2Or/3 2O6/LO 9Ll9 821L4 s3/e atl6 8r/2L 86/s appropriate [{l 6/7 4!/16
206120 20?/6 20716 2Oe/L2 8e/22 89/2s 8912s eOlT gLl',t 196/10 235ltl
2,al23 2}blLl 2L312 ?L?/LO e2l8 94/t7 e7/6 99115 to$l3 t{t 56ltt 23s/6 236/7
22L16 240/s 210116 roLltz 106/5 toll2l t\o/2o 23618
Eruouelf [1] 2O715 111/13 111/13 t2O/2L L24l2L t1I 73/25
[1] LellL
:, L26/9 L2e/t7 t2e/23 t29/3 approved t3l s6/L9 2L4lL3
t tsll 64/7 64/20 65/7 r29lL9 729125 133/L4 L34l2O 2L4/L6
6sl2t 66113 671t3 68/LL 9tl8 134123 L3slL? r36lto 73712 rt4rtovinE [1I ll6lzz
99/2 e9lLz 99178 LOO/7 11?/1s t3719 137/23 L42lL3 Lr2l23 Aprtt [1! 2414
7L7/22 Lt8l3 Lt8lL' L22/23 l.f8l10 t4Sl24 153./1{ 162lL9 are [8{] Tlte 915 lo/Ls 231t7
L23l2O r2tr/25 L24/16 t24123 t65122 t12lLS L8219 L851l'5 2slL1 29lLL 3t/L3 36/6 421L2
L2'|LO t71/L5 L74l2L L8L/L9 L85/22 Ls9l9 rsglLz t9017 46/S 56lLO 63lLO 691L3 83/3
L82/9 t82/,2s 183/g L83/L7 L8619 LgOlLr t9211 19417 t94le L96l2O 8314 84le 84/L6 92llr 97/2 97/2
te3lla Le9/5 200/24 ?OL|7L 2O2/L3 203123 201/r 204lLO toLlLS 101./1S LOL/L9 t1216
2Otn8 202/7 204122 204123 2O4l2O 2O4l2L 206/8 2o1llr LL3/L2 LLSI2S LL1l25 L2O/2s
2islr 2isl2t 2t7ltg 22e15 20814 2O9lL9 2o9l2| 2LolLL L2212 :,23/ts L3O/20 L3ol25
229lt' 23Q16 23016 23017 29olt7 2t5l2, 21617 2L6lL5 2L9l2o L3Ll22 L35lr L39/2 r39lL2 L[O/9
23L12 23L43 23e18 24A/22 22OlL2 22L14 22317^6 22416 Lr3l2L L(rlzE L4sl2L tt5l2s
nnreriea tsi 22124 23/L2 23/23 221122 225lLr 2251L7 22618 tr9h3 Lsoll? L5tl9 1s2/2 L5214
34123 87/* 229lLO 23014 23017 230/9 23OlrO 155/19 L59l2L L60l2s t63/2s
Aaericen. tLrl- 233/2 233/3 23el{ 2rrlL4 2421L3 t6619 L7312 180/18 L8714 t8al23
a.uong ^,221 ?9.,.
[2] :&l2o tLLl6 242179 1,es/4 L90lt3 7et/18 te2l2 L92/5
!.nount tzl'r 3212 321L2 tlol 7le 7e124 8tl6 Legl9 2O3lL2 2LO/72 2t0l?o
analyrta [d6t 5715 8212L 8412L 103/8 110/10 ttolzt L17|LO 2ro/2\ 2LtlL5 2t318 2L8lL5
LLOIT LtTlLi t22l2a t23lt0 L15/23 L82lL9 2o$l5 22313 2241L3 22713 2271L4
1.231L3 L74lL4 t7rlrl rgsl4 t1l L8sl23 227lLe 231116 23tlL9 23315
LeslT LA6l7 L8813 tBel2o t8el23 t1l 731L1 23315 23r/7 23612L 23el2l 24016
Lg2l23 rsl/6 tgr/Lt 2oL/2O t?l s8/r8 19125 8A125 242/12 212/L2 2441s
2O2l2L 2(,l,l22 2t6lt4 .2L1/13 eols LoL/79 L78/2L t82lL3 area f3l L2/t7 59/9 L49lS
2L7ttl ,3ll25 'r [1] 13614 areac [1] L1Al2l
nalyztns [3t 731t2 LL4l9 nythtng [{21 1214 29lLo 3olL7 arenrt [1] 5Ol5
11{/10 . 30125 3712L 56124 6713 1el6 argue [{t L3lL5 27122 t83lL5
p7{ 2tn2 64tt 6sl8 9Ol3 9Ol7 9O/2L 9219 9112t 233123
83123 8516 BsILt 861L3 gsl6 LO3l22 tLol2[ L36123 112/7 rgued [1] L8312
selLl Lt4l7 t2e/8 t42125 Lrslt' 146/LO L6rlL2 L67l2o arguing [2I 231L9 281L3
Lrsl2o':2lLr
Llzl{ LSTILO L7LlrB L7Ol2 776/3 183123 Lgolzo L9L/3 ergnrnent LO/L1 L6L/8 LS3/4
[5]
L7e/L2 180/1S !80/25 181/10 Ls2lL7 L92122 19s/11 L9s/L4 23312s 23914
Lgols tg6lL5 2o2ll4 2L7lzs L9717 22719 221-125 222lto ta lll 2r2lL3
22714 228/2r 2221L8 22316 223lr.s 22516 t5l 8sl2 L23/L2 2L5/t4
nndrea'a [l3t gSttg 98122 Lselg 225123 23tlLL 23716 23719 2L6lL8 2r7ls
Le8lr2 $en3 7881:-6 r8sl22 tll 1oe/6 tlt 223124
Lsslr L8918 189/16 190/10 rr I3l L6l2S 2L3ll6 230lLo t2l e4122 e4123
L93lL9 228122 izo [10] lLllle ]-L(ll I2t L7816 2t7lLs
anniwerrary [ll 96178 13'll1r 744lls L5915 L69/2L round [6] L7o/22 L77123 t77124
announced i3t LIi|LB L7ol23 20317 2!Olr9 2rLl7 2trl8 L84lA r9713 2271L4
LTLIL9 i y t3l 8lr t37lL7 r t1l 7l2r
announcencit [1] 2OO/L3 reat [10t 2lL9 78lr eslr6
anorher [1!l 2zll.o 4415 7515 I1l 241L7 gslr2 Loolls L2Lls t2L/72 L5811
s2l1 ro,lte 7osl25 aL7/L2 L3817 I4t 103/10 L3918 L72/Lt L7sltt L7s/L7
L4u9 L0L4LI L52/1L L6Sl23 ted tel 6Ll7 6317 95llr
L7sl3 i arance [2t L6el16, L6912 951L3 Lr4/74 L2O/L5 L9414
newer [35i 351L9 l3ltl 431L7 ered [10I 1/19 105/18 2ta/L7 2L3ls
431L8 441e2 $12 1s/2o 45122 L26123 t4216 t4slLs t46lro arricl€ [7?] 2lLL 2ll3 2lL6
4s123 45li r6le 471t2 641L3 r58lL2 t67lLg t69125 L1616 2lts 2l2o 3ls 317 3/to 3lL3
931L2 LL3lt6 Ltrl' L20/L5 t1t L68l2r LOSILB tO7l21 t3s/r L33l2s
t22lLO 12116 L25125 L35123 c l2l rLlT L3917 L3al2 L38l2L L39lr t3elzs t4ol5
t36/2L 13114 L3717 L46/22 re [{] L3123 t{/s t4lL7 1{0./11 L{O|L? 14O/L4 t4L/22
146121 L[il7 76L178 t6216 L6S/2 L13123 L4alto t41lL6 11rlt7
t6slr L66lLr L7L/22 t1l L78lts L47lt3 L47lr9 147123 tr8l6
23718 r '.93/12 icatLon [2] 36112 23617 L49l2r ts2l6 L52lL3 1s3/{
t$t 47lrr t36la t36llr
T
j.ed t2l 56lLg 56125 L33lL7 Ls3l23 1s8/5 1s8/12
!36ltd t46lta ier [2] L4A|L9 182116 158122 t5917 L59lL5 L59l2L
nerering {2t ls,olzl 20213 t1l 57le L65l2r L6618 156l]-8 L67122
nswerr [1] t38/ta applying t2l 8L125 Ll5l8 168/1r t69122 L76ls L16lLL
cipatei [1] L2314 rst L9l2L l4lLo t6llg L76/L9 176/22 177/5 L77le
cipated [1] L22127 "pp"int"a
16/20 25/12 L77lL7 r77lLa n8l3 L78l7s
ictpatiiig 11! L?glLg appointrlent [1t S2lL5 Llstto 180/10 180/13 180/20
ny I116t
[Il6J i1Ol3 Lole
LulY L6lL2
LotL. Lsltt
L appreclate [1I 31123 L8tl7 t96lL1 196/19 L96l2O
ILUfs ts1lzL t9sl7 L9818 Lgglzr
LCl2s 2tlAL 2212 2213 23/L7 epproach t9l 2oll2 2olLl 31/25
2rll3 2611L 2715 4315 47lLO 7-olc gelfi Lo4lLs LollLr Lo8/r6 Lgslls 2ot/2 207120 2L0/2 2L8/4
lrEuranoo [1] 118/16 attorney [110] 3/8 8/2O 13/25
ssure [1] 5O/7 L4ltL t4/L3 1{/15 Lrl2L Lslt2
articl.e.,,(a2) 220/8'22Lle 6lurodly [1] 207125 LslLs L6/6 L6/LO t6lL6 L6124
IFI t2o/L6 L[OlLr r [211] LlLz 3lt4 6/23 8/r 9/r L7l7 L7l8 LTILO L7lL2 L7/L4
760/22 zollt3 20618 206/9 to/3 rols tsls L7l4 2Ll9 221L4 L7/r7 LTlLe L8124 L8125 L9/3
alriculatei [1J 9912L 25123 29/23 30/6 3o/r5 3Llr6 L9l3 2L/6 2L/8 27/L3 27/L4
ts 1263J i 32/L7 33llt 33/20 34/8 36176 2Llrs 2t/22 2313 23/20 24/6
taln [{l 30/6 23L/3 23Us 31lS 37115 38lt{ 38111 3e/6 24/rO 24/20 2./2s 2517 2slLO
23L/6 39/t0 4OILA 40/Ls 40177 4O/2L 25/t3 27/L7 3}lr5 34/22 4718
arcertained [1t 26/l 4rl2 4!/L3 4L/17 42/S 42/t9 47/2s 481L5 49lta S2/7 55/s
aalde [1] trLlllLG l4l7$ 441t8 rrllg 16/1 4112r 56112 561L3 Sgl23 63/23 741L1
aak [3el 7tl2s 9ll8 LL/e l3l9 48/5 48/LL 48/23 4916 4e/L6 7717 7819 7812L 8O/8 82/2L
3S/L2 36/? 36122 3716 3811 38/8 49/19 49/2L s0l76 5O/2a 5tlt9 82/24 83/8 84/19 er/24 85/2L
42lLL 421+2 rslrt 4617 7olt2 s2l5 52lLL 341L9 Srl24 56/8 89114 89124 90174 901]-7 ellzL
72/LS 8e122 96/L3 t03lt3 LO113 5714 58/tS s8/15 s9ls s9l10 951L7 961L9 96125 971'-3 97/L4
110/11 Lt$l2O L36l2r t46l2t 6719 6216 63ls 651L6 68lLL e7lle e8/4 991L5 L06122 LLO/s
t46/2r Lr?./25 L6O|L8 L67lL3 681t7 68/2s 6elLO 6elLL 6elL4 L3118 L4212 L57lL4 LTOlre
18{/1s L87lLB L87l2r 206122 7OlL7 7tlr2 77/2r 7412O 7s/3 L1Ol25 L7r/2O L7212 l7'l3
2L2lL1 21F/2 2L718 23012 2321L2 761L6 761L7 8Ol2L 8tl2t 83llr t?glLl L8rl9 LSa|LL te4lt2
234/-Ls_23111^7- e3/Ls 83/22 86/L2 Aglfl 89118 L8S/8 L87/2O L93/r Lg5ltL
aked [33t -^ 2rlt0 3315
i 813 2Ol9 e9/22 941L5 9slL7 96119 LoolL2 r95l2o L9618 2OO/22 2O3/2L
35119 42123 13lLO 13123 rrl25 LO2l3 LO2/L2 LOrl22 t06l2o 20919 2091L8 2L4/t2 ztllLr
4s/L7 S2lt6 521L7 6el5 811L3 LOelLg to9/2o 110/10 2Ls/72 2L7/3 222/1 222123
s3l8 LO6ti !L6t2 t36l1,4 L36lt8 'O9lr9 72L12 r21.la
rl2lte Lr6l2o 2231L3 230/L9 2321t8 2391L6
t3712 746l'r Lts112 1s3/s 160./15 t2tll7 L22lL2 L25l2O L25/2L 's [20] ve 6112 6lL6
L3lLt L3lL9 2?lL6 39124 1Ol2
L60lL9 760/2L L7slL9 L96121 1211L9 L29lL8 L3rl2 73tl1e
a97/s 19716 20016 206122 239/15 t32/2 13217 r33lt2 a3417 L3llL3 911L1 9u2o 110/10 trol.2z
sking l13i 1016 94124 L31l2s t35/3 L35/L9 L3916 tLLlL4 LL8l6 L71/t6 L73lL3
'Lol22
tL3/L3 Lrllu L66lL3 L66lt6 L39lL2 t12/L8 L[rl2r t{Slt4 L7slLe 18312a ta5l2 l96lL3
r66/2L fl6/3 t8sl23 2oslLs L47/8 L48lts 1{8/16 L48lL8 torneya t10l L/22 e/3 2LILO
22L17 23512 L48124 1A9l2r 7SLl5 r5tl7 3O/7 431L3 ttels L2Ol8 LB6l5
ska [1t 33/18 1s3113 754125 1ss/9 1s5/10 t94ll7 zLolrL
spect [{l , L2319 206/20 206/24 L3sl22 ts6/2 15617 !56/11 trilrutable [1] 160125
2L6l2o I ts9l2L ts8/22 L6O/7 L6O/8 t6I t30l4 t36/LL
rti s{ts
"oilil tlfit 2lL2 3td tsll
araurt,
l62lLO L6319 763lts L6rl6
L67122 L1O|L7 LlLltO L7219
153/10 LsslLL 164/LL 155123
c tll L4416
26/Ls 5816 L3813 L3e/s t73123 L17/9 L71lLO r77lLO t3l r2l2o L2l2s r22/1
'3e/B
L7elL2 20?123 2L7llr 22Llt6 L11lL' L18120 180/11 180/13 t{l 7212r L2O/8
22119 22r7LO 22{/LL 224/L6 18512 L85lt1 196/3 L87ls t81ls r22l|2 t22lL3
224/21 246/23 L9216 L93/20 193/5 L9S/LL L99/S t3t 2l2S t73ll3 L73/L7
agcaulted [5] 55/20 6L123 8415 199/16 79elt6 2OOlL3 2OOlLs r I1l L4lL4
8416 22s12 2o3lL7 2Orl2O 204122 295lt4 t t2l 7Ll2L 143123
asrenblad [1] Ll6ll 20812 2O8/Le 2O9/4 209/L7 red t3l l-lrlLt LGtlT
asrerr tsl I 6sl20 661L2 68lLO 2toltz ZLO|LT 2L2/t6 2L2lL8 201 120
a2rl23 Le2l24 2L2125 2L815 2L8lr3 218123 I9l 2lt2 25122 2614
eeacrrlon {2t tlSlg 2o1l2l 22t16 22513 22513 228lLO 2281L3 38123 76123 t3813 L38122 t3914
allerrnenttlzJ oJIza
arcegcnenti[2] 65125 LL)/Lt
tL5/L7 2281L6 229/L7 229/20 23218 La3lt4
arsi.gmed [?l t{ll6 l1llO 34120 232122 233/20 23419 234178 aurhority lill 1/22 8122 L2LlJ-o
6S13 t1slLa lg7l2s 2L3122 234120 235/5 238/tO 2391s L57 /22
artat [2] ' 26lLL Lt0l7 24112L 212/8 2r2lte 2$/3 thorize [1] 82124
cgiatancef [1] 17 l? I2t 23ls 23/6
sstgtant t39I tl22 13/25 LllLo tnorphere [18] 6819 98114 rvetlarrte [3] t4lLB 5912t 23519
t4lLs t4t1a L6l6 761t5 L6/23 L21l2L t.2/25 L4319 1.4518 avernents [1] l80l2l
L1/6 rTlstLS/24 L9l2 2tlt4 L4SlLe trll{ 7a719 L47lLo avoid [1] 63/L3
2LlLs 2L/i2 23120 2sts 2sl6 L33/L2 ts'l2' Ls6l3 7s6/73 t2l 20121 2717
25112 sela 67n2 67125 68ls t36122 156122 15716 L57170 rde [tl! tslz 22/2 2215 22118
1L123 7t124 solrs 8612s rL1l25 tach [1] 7215 re [8] 56/e s9l2s 7Il2 791t2
ltalL2 t'r/tl t8318 t85lL7 .rtached [8] 9el7 98120 108./6 eLl22 Lo3lL? L9{le 23512
18614 t93(1 19s/10 2O7/3 2ogl2 188/10 L89/8 L9sl4 209122 away [5I 52/9 232120 2341t3
2081A 2391L6 2I4ILL 23516
gaicrr t1i t1514 tachins [1] 73/L3
ssocirtod; l3l L52lL2 LS2|TO I3l 24lLL rs7l'-g rs1l2s Isel t3le Lsls t6la ).8123
L5212^ $ tll L5718
241L9 25/L6 3Al2 43/8 1616 1618
.srociatioi [2] 21179 3012o tachs [1] 2117
r!u!!e [15] 3L122 99124 13513 ttataalrle [1] L82l{ 4712L 5417 6el2 6elLo 8s/9
737120 L37/27 13112L L3913 rtespr trll t46l'r 75Ll2L 83lLr 921L6 94lLr e8l7 LO2l9
747/6 r.9123 1s0/11 L53/L5 L67/2O L6Ll23 110/19 tL2lLL 1t3l2L LLAl9
79312 2L312 236120 23112 ttenpted [1] 112/4 11{/10 LL'|2L L27lr t21125
rsuned t{f L4l2 L5lL3 731t2 tteapting [8I t43/3 LlSllO L3212 ],3217 t4tl2s 1{{/16 1{e/4
20e/s l L13/Ls L3o/t1 LsO/22 L6tlL2 t49ls LSO/19 151/3 7S6lL2
l''-i"n ri: as6lz2 20116 L69lL8 1-9619 1s6l15 163/2L L67/L4 L67lL5
230112 rrenrlon [3t 48/Ls 9213 LSrlLl t79ll6 181/1tl L83/21 185./15
E
4r/2L st/24 33/24 6L/23 69/6 L43/9 L43/L6 Lr5/2 L45/8 Lr5/19
7o/L7 7r/3 8o174 8t/23 851]-4 t45/2L L47lr r47/8 t47lLO
bach... t14l Lgsl2L L86/23 8615 8712s 9515 esl1 9319 e6/L2 Lso/23 L56122 t9O/7 te3lL0
187/s 188t16 tgrlL4 tg2l23 LO0/2 Lotlg 70rl8 LO4|L' LO6|2O L93lL5 L94/9 239/21 23e125
Lss/Lt 2otlLs 2o5ll7 2tt/8 rL8/9 L2t/L9 L2L/L9 L27lr4 2t2/Lg
213/4 222/3 223/19 233/t6 r27/14 t2919 L35lt? L36/13 tter t16l 60/24 6tltr 6L/t4
kground [1] 231L4 L36/tS t36/L8 L37lL7 L4Ll24 6Ll2s 62/7s 62/23 6313 6316
t3l 2817 eols s6lLL t4318 144/{ lso/13 lsrl2t 6917L 86/L7 103/25 L57/22 L9011
$l ;Loo/23 L56lt2 L6O/24 L7l/2 t7tl22 Lga/7 L}lle 23312
t3l :109/rs 709123 LLOIs L73/9 t75lL7 t1Sl2O 7AOl2o Ilst $le 331L8 s4l1
tlt 22/L4 L84/6 a8417 t86/LA 195/9 195,/1s ssl18 s6ls 59120 6813 76/Le
t11 Ls6/8 L98lL7 203176 207/L5 2LO/23 77 ltl 7e/L3 tosl1.1 LL(|2L L28/s
a2lli 5rl7 61121, 2L7/23 2L919 22L/2O 221lS 22.16 181/10 198/18
ar [8] 1l,LZ l,2ll8 L3l7 Lrl72 22512 226/tB 229110 2301L3 eyond [9] 50l2o 82115 7rrl19
23/Lr 3Ol2O 227lLA 232122 235112 2361L2 L20/22 L2s/24 L67/8 20312r
rred [1I', 9/? ore [{01 u77 LLlrg 3017 2OAIS 237118
rrl.sr [1r' 193/10 3612 36112 s6/73 37116 38lJ-r lal 291t6 73/7 9712 2o2/16
ae 121 I62/LA l67le 12/24 131L4 44lr 46/t5 5s/3 t18l 2lLs 2/t7 2lts 2127
aeed [13] i 613 6123 gltL 4212 62t3 7o/s 72/2 LLs/tt L24/L1 319 7sl2r L26|LL Lr7lt5 L17l2t
rsl22 66/6 85/L7 e'-ls r0ele L2sllg L2s/2L t3L/L4 138/8 Ls2l8 I32/L4 ls2lLg 15817 L6612
L3s/t8 L3il22 Ls7l2S ztOlLO L1Ll4 tsalr L6olL9 L6ollg L6319 L66/L9 L79lL2 L94lL6 L96lL4
asiceuy [1] 1s122 L6s/2r L6sl22 t72lLe t8ll25 nd t1! 918
ia I10l 3LlL7 3tlr7 3rlLL L84/2L 20L14 2ot'lrr 2l1lre nc t9l rt7ltl L23125
so/6 LLgl1s r26lt4 ls1/Ls 226/3 2r8lL6 27e/L8 2L9/3 2L918 LzslLL 2O7/L7 20817 2081e
226/20 23014 223121 2O9l2O 2t2123 22412L
ttre [2]: 318 r19lLz I{1 L5/2 t4614 t77l2r nde tll L2ll76
t2?01 ; y t{l 3lL7 3lre telL3
i;i lzon
ns I31, 3OllL 3LltO L9318
begtn t2l 8316 L2617
beginning [1I 40122
re/2s
r t?I 411L3 LL6l7 t38/2O
I1I 1r3l2o beglng [ril trtlzz L62/LL t63lL2 t6r/L3 L61122 t7olLs t8113
ocane [8] y Li/L! 16123 23116 2L9lts t3t re2lfi Le2lzo 183./10
9O/1{ 11071r t2LlL4 Le4lL7 t2, LOl24 24OlL8 oouborg [2] ll?llg L65/L7
t94lL8 I t1! EOle .con [2] 2lL3 lr7lL3
ecause [1$01 sl]-s 917 L4lL7 ior [5] 57/21 6]-l2t 6L122 rrglBernatein [1] t66ll7
2rtt2 24/1.6 2816 2elt3 29/L9 Ltr/2L LLrl24 tu 199./14
32/2L filA 34/22 4OlLa $/n I1l L84lL5 ue [tl L0gl2l
47/LL 47/I2 4S/21 sols 5Ol5 ng [{?] s/5 L5/3 r7l2 solg tlt 291L4
s2/25 s6/i8 s6l2s s7lt3 6011 5s125 6114 61/L2 69121 77/L7 t1t t33l21
6t/s 621L0 62lLs 5317 64lLr sr/L6 8112L s9lL4 92lS e7112 rtering l1l 281L7
64/21 67lLL 68ltl 681t4 6e/12 LQol4 LO2l21 103/16 LL5l23 tet ttl22 36lrs 36/L6
7L/2O 72liO 13ls 71/L2 77lLO L24/L5 L29/17 t32/L7 L3sl8 36120 36/24 37/5 37/24 7O/2L
78/s Tsls;7s122 7s121 8Ol3 LA7l25 L18/r6 L19/25 LsLlts 7tl8
80/13 8L/22 8317 83124 83125 L5315 L53/LO L6O/2L L68/L9 r t1t 26ls
84/1.s 85114 e6/L7 861L8 8712 t7417 L77lLl r71/L9 t78/S L7819 t11l L6l4 65/L6 8sl2o 8613
sel12 eol$ s2l2 s2l2o s2l2r t?sl1,' 1S0/1s L*3ltr r89l2r LO3l6 L29llo 130/1e ls6/19
s5/24 9612 961L7 96123 100/1s 186123 781172 rsgltl t88/L7 LIL|LS 2321s 234llo
too/2o Logl2r to?l6 to?lLL tsgll( 20218 240/7 24213 tll 301t7
fi8/3 $9/6 LL6/3 LL6/8 LLl/2L tef [1] 631L7 tou [{l t39/6 L53/23 2L8/23
Lr8l8 L207.L3 L2Ll8 L2rl12 Leve [5?t 7lr 1/20 9lL]. 222114
r23ttl L2i./L3 L2rl7 izslt| LOILT L{12 2eft 36124 381t9 tlol 9'lr5 98/23 L74lL5
L2616 L26l2O L26l2L L3Llas Ar/25 r2l6 43lLO 5tl3 salLs 190/11 L9Ll9 2t4lr9 2t7/13
Ls6l3 L37lL{ 138./10 L4316 L4Sl9 5614 3617 59lLe 63/L8 TOls 22L12 22LlL3 24L18
1so/6 lsozll 151/s 1341L2 7L/25 TSlLs to1l25 Lo5l4 Ll2l25 boundc [1] 23918
L34t16 1si/l8 L3718 157/79 tr3/4 LL5l9 rzllLs break [12] 65122 68125 5913
1s9/10 r6s/9 L7uae nsl6 L36/LO L37/3 L31lto'-35lr7
t37lL4 6919 7t/6 LOLI4 LOLILo 131./18
L75122 17819 L'rll tgrllg L37lt9 t42lr3 1s7l1s 161/10 t3Ll25 L69/r4 Ls1/3
18e./1e tegl6 Le?13 19u8 19s/16 t6Ll2L r54lt2 L64l2L L7617 t1t Ll23 '86lfi
ts7lLr 200/3 200120 200/2r L7Sl20 Lsll3 L8413 tggl2s tst slLe 7l2r 46/L6 LO3l5
|OL|2S 2O?lL2 2O2lL3 20313 tsslLs 198./1s 1e9/15 zogltt 238125
2lsls 20318 201116 2OSl5 205173 2L3l2O 2L'ltO 222120 22311 iefed tll 78312
2OSt23 2oE/22 2O715 2o717 2o8ls 22317 223122 22el2t 2?o/4 iefly I1t t83l2L
2}elto 2L1 122 2L2lLs :21-412 235/t6 2421t8 iefg 121 t3123 2421t2
213123 2LSl8 2r7ls 2L7lt2 22L12 a?t 4ols s4l2 8713 ring [9I t2/7 4el8 solzL 6519
ZTL|LL 22tlL3 223120 22af4 LL3/6 LL4|L6 LL'/s 222119 821t4 s3ll9 LaI/2 23s17 23819
2291L7 2301L8 2321L3 232lts 12' L2slt' 16214 lnging [2] 1919 7el7
23212L 23316 23614 23917 t1t 23/25 ingr [1] 21/20
"39/2s
€ccrDe aslrt ,61L1 L7 16 LTILL bench I{l LGILI 24/8 24112 tj.rh [1] t58lL7
ellzt to8[3 241L3 t1l 331L0
econer [lt 9OlL1 teln [1I L66/t7 11l 1{0/13
ecatng [{] 39lta t3ol 6123 r3/L8 231L1 t?l 8413 L22/2o L22l2L
een [?{t slLl 5lL1 9l2t Ltls 3r/21 681t3 sLlLO 92lLo e8ll3 tz3l]..S t2ll:.2 tzrlLs L24l2r
t3/6 L9123 2s122 2515 3012 s}lLl t?712L L37l2O Lr2/2r 12, 24/s 70/5
rl
I
l
c-11 t3I L97/24 Leg/s ree/LL capitalize [1J 238/Ll
B
c-L2 t21 2L8/6 2l8ll2 capitalized [1t 239/2L
broken (Ll) 63/2 c-2 t8l L38/4 L38l2O LIL|6 capitol [1t 23120
bsought [9] !L/9 3213 481t4 r4Ll20 L1219 L15lL1 t67lt4 captrln [2! L5IL9 L5/22
gs/Le 81/2L 87/25 e8/2 ]-28lL9 L67 /L4 care [9t 341L6 72/20 Lt9l22
!91 /L6 c-3 t6l Lell$ 747/19 tl9/24 t23/5 124178 L25/2 Lzs/5 L90/2
Bruce [20] " 2/7t 3123 3125 417 lso/6 L63/2r t63122 L90/6
4/9 L0/zs!,rt/4 63122 6716 e6l't c-{ l3l 13218 7s2lL2 cared [3! t2313 123/9 789/19
LO4/L2 106/1{ LOBl13 13418 c-s t6l 7s818 L58lL1 1s9l18
'-53123 care€r [31 9LlL9 tt6/23 15rt/15
L3A|LO L4212 7r7/L4 L47l2L t6o/2 L6ol3 163/7 carefully [{l 7l/L3 95124
]!8lt6 2101t7 c-6 t3l L6613 L6617 166122 150/13 zOOlLr
budget tlt ! L5l3 c-? I3t L5el6 L69|LO L7Ol6 carl [2] t39lLI r59/r2
build t3l tlso/ls Lso/23 LSL|22 c-8 t{t L73/L3 L13la4 l73ll8 Carpenter [5I L3/25 76/6 l5ltL
bulrding t3t L{'slzs L13lL9 L6lt8 L6/2L
bunch [2] ?rso/rs 13ol2]- c-9 t1I L76125 carry l2l L9rl23 20915
Bur€au ILI) *ls c.v [1] L9/7 eage [2561
ceres [3{t L4124 l5l3 LSl4
burglarired [1I 6114 Callf,ornia [1] 229124
lurglery [1] 6Ll9 calr I10t Lolzl' s6l9 691L3 8519 L6lL2 2LlL2 2LlL6 ztlLe 2Ll2L
bueinear [ft 8s/22 1oo/18 LLLI' LL1l2s 183122 2'-12. 23/LS 2{12 24/LO 2slLe
but t203t 6lL3 6l2L 712 Tlrg 242/LO 242lLO 5514 57lLL 87lLA 8717s Lr6/r3
8/7 tle L2ls L6l2 LslL6 t8lt8 called [9] 2sl2r 27ltr 45lr Lt6lt5 tt6l22 LL6l23 LLllr
2O/7 2,l2o 22lto 2317 231L6 4118 16118 rtt/2 L6ol3 L?sltg LtTls LLllLo 118/13 LLS|?O
2512t 28/2 2915 291L7 3013 3L/2 23tlL9 tL8l23 L12|LO Le3/6 221/L6
32/L8 33/20 3314 39lLe 4Llr2 calllng [2] 13219 17612 223123 zzsllv 2291L7 229lLe
4L/22 42lA {{lLs 451L6 r6lro calla [8t 2lr1 Lo/24 slltg caaror [92] 2lLA 3lLL 3lL4 3123
47/2L s2liL ,slLL s5/2s 59123 tLolzL 7L8122 t52/7 Ls2lL4 3125 417 419 LOl2s Lt/4 LLlg
63/te 6r/22 6s/L4 6elLO 691L3 152/ts L2lL3 L3l4 L3l6 rel2L 2019
12/4 72lLq nls 7319 75lLO ca:ne I13l L5l9 32/t4 58120 2O/L8 311L4 3elL4 4Ol5 42123
15/18 79/?.791L{ 19/r7 8L122 6Llls 62179 6212a e3l2L LOo/22 a6lro 47/L6 4914 63/22 1Ol5
83/22 8r/1 asl? 881L9 Asl22 751122 L82/2 202/Ls 2oslt1 7Olr7 7Lll2 Trlt| 7sl3 1812L
88ln egliiL 9017 9L123 9214 21018 82124 8r/2s 9611 961L2 971L2
921L3 e3ltl e4l5 9513 95lLO eanera [5] Ul22 lll25 451L8 ro'-lL7 ro3/13 t04ll2 LO4ILS
loolL2 1Oi,/l3 to3/Lo to4/3 46/7 r7l7 L''ltr Lo6l2s L01lLg 108/13
rO'l2L 109/s 110/5 LLr/6 LLLIB canerar [1] 3617 Ltt/24 LLrl4 LzO/23 130/11
113/16 L1.llt2 LLalto rL112 canpatgm [9] 3ltg Lglll 19124 L32l2s L33lL9 L34lS L341fi
LL?/5 LL87t3 L20122 r22/L2 t7213 L7215 L7219 r72/Lr L74/5 L34121 L3719 L39122 L0Lltg
12u23 LzslLs L2613 L27lL2 t7417 L42/2 Lr2l7 L47174 Lr1l2L
tz7lts pql22 L3L/aL L3ll23 ca4ralgrna [1] L72124 148/16 1s1/1O 151/13 L53122
L33t2O 13f/13 L3617 L36lL8 carr [?91 Tl'-O Bls S{LO 8125 L5415 L57lL4 1s8/10
L36122 13ilr l371L7 L38l2L sI2O LOI2L LIILO Lrl22 t2/3 L59122'-sslr
L6OlL7 16219 l63lL2
r39/{ 13e71:- L3sl23 L43/L6 r2ll7 t2l2i t2l2r t3lt8 281L2 L63lLr L61lt3 L6617 L6716
Lrslrs L4il2 truz]- lr4l23 2slr 2elL8 2e/2r 29122 321L6 L69l2L t7113 L86122 LellLS
tlsl2s Lsll?3 1s3/ro 1s118 3s/7 s6t23 3811 4Ol8 4Al,o $12 L97122 199/18 2OOle 2O0lL2
t54/Lo Lsit23 Lislz' ts1l22 1t122 rLl23 rrl2s 421L2 12lLe 2i3lt2 2OslLL 2ttl7 2t5lL2
ts7l2s Lsitl4 t6LtL9 L6213 rlls 49125 5312 7Ll6 LOL/2' 2L713 21815 2201t6 2391L4
L62l2s L6i/s 763lLO L6112 L6rlr to2lto 108/10 t''3l2l Lrllro 2rolt7
t6517 L65Iro 165lLL L61le 114/11 lL[lLs Lt5/3 LL1/L2 calrorr! [5t 3/L1 3179 19/L3
t67lL2 L6ilL9 L68t2 16815 L6819 Lzrl6 L3213 \34123 L3315 L35lr6 L9l2s L3rl6
L6sl22 L7i/8 L7ut5 L|zl|e L3sl25 t36123 t37l2l t39124 catch lll t39l2L
t73lLO L7E/2o L7'I17 r77/L7 L1o/r tlol5 74117 L49123 Lso12 cat€gory [1] 161/f0
L77/23 Ltiltg L19/2L L80ls 1s9/13 L6r/3 L6Llr8 L62/5 752/6 caught [1] ls3l20
180/7 18019 LeLl6 L85123 ts6l2r L62lL3 L6r/3 L6411 16812r t6916 caure [1t 24416
Lgg/z Lg3/13 L%la7 L94/8 L9S/2 L69/L3 L7L/75 L7el9 L79lL6 caused [2t 2al6 l8l2L
L9614 L9618 Lg5lto L97/L9 rs2l7 Ls5/25 L98/L3 202/7 cau3es [1] 9Ll2L
198/15 $qlZz ,,s8/2r tge/25 2L8/2L 230/7 2331L8 242127 ceutionary [2I tOl.lt,2 LOL/L3
2OLl3 zoLxtt 20111-6 205116 can.r t2{l 22lLO 481L7 5712{ cautloncd [1] 2L6lL6
2O6/Lt 2O9/Le 2O7le 2O7lL3 6L/5 6119 LL3/20 L27lL2 t28116 caurionr [3] 84/25 2t5lL3 2L713
2OalL4 2oelLg zLOl4 2tLl22 L28/23 t29/5 L2sl6 L35123 cautiou! [1] 225124
2l2l2s 2L512 21313 2i513 2t5/L2 Lg7l23 t63ls L54lA7 LTLIA n6l8 cav€at [1] 97175
2L712 2L7y2o 2L7/2r 220/18 L7814 !781L9 L78l2O L79/8 20511 celebritiea [1] 34124
220123 222113 22313 2231L4 zL3lls 2L5lt2 celelrrity [1] 34125
2251e 227t6 229120 22s125 eana& t6l 2s122 34123 38120 center [3] LSlLt 22/9 L56/L7
23|lt2 23ll7s 23L123 23313 48112 761L3 12717 Centre [2] 23120 2415
233/LS ,3ll4 235,14 23718 2381r Canadtan t6l 3l2O 25122 3S|LS lcertain [1ol 49/14 521L6 52lLg
23elL3 24?he 38123 5rl2o 16122 sslr tTLle 206120 2o7le 2L615
orrtton ILtr. L2124 candidate [3] SltL L7311 L97122 I 23612t 23712
candidates [2] 318 179/tt lcarrainly [2OI 2llLl 3Ll9 321L7
cannot llt LL7lt7 t2r/23 135/15 I se/n a:-lg s7122 esls Lo3/24
:-r t13l .3o/9 L3312 133/16 L91l2l I rrelg fl112 r'L911 Lsgl2L L44'17
L31/6 L14 t10 L11lL3 L4915 L4916 capabl.e [2] t8l1-7 L93/5 I rselrr alrls Ll2lLe 1e3/3
1{9/6 1s0 '19 151/3 151/5 151/1t! capactty [3t L4lt2 75121 23/11 I tgsltz 2orlls
2LLl22
c-10 t3l i79lt3 L79lt7 L19/25 Capital [2t 2Llto ztlLg lcertainty [2J 88ls L2e/24
230/73 235/L2 23Sllr 23816 coanlt [5] 2/22 59/21 166/3
238/9 L66/20 L61/s
t1l 2r1/4 ivltity [1] 7/73 couritted [{] 57/2O 5819 lL4/L2
121i Lsls t,l/22 {vllly tl{l L4312 L43/LL t47/5 L86lL9
t2t i.25l2v 6413 155./13 155/18 l55l2l L56/4 tting [1] 58/2
t1li:112,/10 !561L4 7s6/23 75717 tS1l2O t11l t/2 L6l7 s9/L3
chal.lenge I1l 7122 15815 ts2lLt 20614 621t2 52122 9s/18 110./14 tztl2t
chaUensedt [2] 3215 32/1 in tsl 5123 3olta 30125 3L/2 23218 234/1 23119
ing [ll 8/2L 99/2 99172 203/20 229lLO [sll 714 Ll22 7/5
tlt 201"3 tll LLr/25 7l2o 7123 8lt1 ele ell3 LOl2
t{l 46/2L 691/9 LOzlL6 tzt 33/L2 8Ol9 trllL tr/t8 t2/6 571L3 591L6
LL7l23 I t2) 3olLL 3tlr2 63123 6s/s 65/L7 srlA 89/L4
hancc [101 2lL4 4919 s4l2r ry t2l 10612 2o3/Lt gslls 98124 99lLO 991L7 L21/9
sal'l too73 L3Ll2 L47ll,s 1471?'L aic [1] L6Lll3 L2412 L2a/L6 L25/L7 L74lL9
L82123 20613 llot 20120 xrlrr 93/14 L8216 tg0lt2 L9L/LA LeLlzO
I [1]ri 98lLt s3/L6 rools 11r/16 L17lt8 L9Ll23 Le4/L2 L9s/3 L95lL7
I2l 15/11 207llL t5rl2r 2271L8 24019 2oLlzo 202122 2L2/24 2t1lt4
llt \!sl2o tll 23818 2L7lL3 22113 22lft3 22rl2t
l22l 2/2L t5lL3 !s125 t1t s6l5 23316 240/L3 210/18 2ro/L9
tslls 3Ll6 371L3 6O/L8 6313 nc [1] Lo3/9 2r0l2o 21L17 24L/e
Lsrlr L65/2s 166/19 ry tsl 56/L7 rosltl L41lr rs I30l 218 313
a2lL4 L5113
172125 203123 2orl4 zollLo r6LlL5 238/7 LO.T 70lLl l0lt' L3Ol8 L33lL6
22rlg 224/,12 2241L5 22611 lll L59124 t3alr L38/20 Lt?lts 13218 ls8l8
2s2lLs * ient J{t 24123 631L2 2t,tllg 158/11 159/18 L6513 L6617 l6el9
chargod[1] 232lti 17016 L13178 t73.lte t76121
hrrgaa (lJl 316 8212s t!61L4 Ilt 6ellt t7714 L79lL3 L79ft7 t79l2s
LL642L LL6/ZZ LLTl'.t 1L7ltz t3l 2rlLL 60124 lo,-lzl 1e7l2r L9815 t99ln 2t816
LL7lr3 L27t2o Lr8/24 rs'gle oloser [1] 815 2L8l12
ts5l2 !16'124 t78lr6 r99lL7 cllr,r t11l 2124 L68l1-5 L68lL6 I5l 5512s 6816
22Lla 22LilL4 15s./18 t68l2o L68l2L t69/2 L}ols 182/LO 20915
harging ti.t 391t8 L26lL5 L6919 L7o/4 L7o19 LTOltL t1t 611L6
L26lL6 13qnz t1l 181L3 ns lll 8213
lll t1ll2o I11 781L3 carion l2I 96124 li9l7
tenhrr [1{l 25l1.l 2619 tzl 78/25 22rlL3 cationa [1] 57124
26lto 4rl7 481L3 481L7 5Ll3 r t1l Lgol2s t13l 73lLL 8t125 8617
s4ll8 'r8l\9 L27/8 LzTle L27lLO t1l 2el8 L2L|2S t22lL7 L22l2O t22122
2O3l2L 22513 t1l 6LlL6 L23/4 L23lLo L23/L8 L24lt2
ief, t1l ilsl2l ned [1] Lt5l2 L24lt9 L2ll2s
tldren ti1 27125 1ll2s 126' 36/23 37 /2 5u25 conpelled [3] 64le 237/5 23719
oicer llll 60123 60/L2 721L2 srls 89/18 110/11 coupensation [1! lgUs
t1l ;nolL6 t2tt2s L34123 L4Llt6 coapetent [1] L5Ll4
r [1] L4514 L4517 L6ll2 L62lLs 1.721L5 couplain [2] 27123 230125
'3515
tLTolto tlol 2512L 27lLL
sroPEE$ [1] Ll24 L86/23 LeBl2O 2O7123 20813
rred
huekJ-ed rir
[{l t6u22
t6U22 L64l2s 2}8ts 2LL|2O 2LLl2t 2t9lL3 2sl4 s9/s 71lr 18113 191L3 e6l8
L6519 tdsilrt 229|L1 L2slLS L25lt9
buckles lll L54lL3 en l2I 9215 201176 conplalned [{l 2sl2l 2611 7518
rruckung [2] L64lt7 .L6516 s I5l e2llr LO2llO LLTlLg 80/2s
rsuaetrnte [1] 230123 1s2/20 ts1l25 copplaining [3] 28lLS 8Lll6
rcurnstan{ea I2l 2812 e2122 t3I 7lL3 LOTIS etlfi
rarion. i2l 2213 22lta coopl'aint [1?l 251L9 2613 26lLs
ted [1] L8316 t1t 7s124 27lLA 27lLr 28124 3ols 131L4
teg [1] t4213 trSl 37/L3 3Ol2O Ttlt a4l2 761L9 76121 881r2 881L3
tizan [1I 9lL6 80/6 8A16 L82/2O 18s/15 reslzr es/a4 s9lL7 LrslL6 L1B/LL
ti!€n' t .( 11 914 Lssle tsslll t9612 L96lLs 2tLl2 t6 t3l L26lLg L26l2L
tiraar [2] to/2 tL5l9 2t4ll7 22Ll2O 22llr 229112 LS6l2a
ted t1t 751L3
vil [83]
J'vil sott Jvlzr
t83liL 3sf't 1Ol2 .oI4 2361L4
39125 lvtz
r3lL3 Aua 6O/2s 6518 6S/2L tll 3/3 coEPI€tely t{l 32lLO 9414 L6tl8
6613 661L3 68ltL 73118 7116 t11 LlLz 20214
coapletes [1t 23913
74ls 771L6 771t8 1el6 8ol6 8311 tll 7717 coupletion [1] L7lt6
84122 8sli3 A3122 86lLe 87lLr coonent [11! 98120 t42l2L L4417
87/L4 871?L 8112s Eels 8f'19 188./10 188/1{ 788lLS 1s9/1{ coaplied [2] 571L9 L67lL6
senl sell.1 eol2 eolz golt 9Ll2 2L'lLs 2L715 a2L|LO 23912t co4rlinent [1t
couponenb [1tt
9813
2912 29/3 2913
9L/L2 9u9 9612 981L5 9812L cona€nttry [1] 17817
29/S
roolL3 ro9/r{ tl'slrL LL1/L6 cortanted [1] L?B|LO
t3t 83124 LL2|LS
tL7/2O 11-d./r8 !2217 L27122 coonenting [1! L8O/t6
coDo€ntr [tl 228/22 L93/22
L45ls L4719 Ls7/L3 L57/L6 ter t3l L3913 L69lt2
L7'|LL 780/17 LBOl2l L82124 Conniarion illl LOO/25 l09l3
L'34LL LS3lt6 Lel/9 L89/2 Lesl3 LO9/L2 t09/2o Le7 /74
LsslL4 /961t5 2001L6 205/2r rsioner [8] L7/2O l8/8 r tsl 61lLA L2sl3 tBzlL?
2L:-125 2Lilro 2L5/24 215/25 L8l8 L8/L3 231L6 96123 L63/L2 2t4lL2 2L4lL5
2L613 2L6iL2 2L5lL3 2t6l2l 1.63ltr t3l rLl3 rv6 4e121
2L6125 22eho 22'E11.2 .22alt5 scionerar [1] L8l2t l7l s6/23 S8/8 s8/7L
a
223/4 223/L0 22r/24 225/6 76/7e 16/21 7e/e e5/24 e7/L9
225/L2 225/L7 223/23 226lLO e9/2 90/L5 9OlL8 97/L4 e8/8
rned.{. lrf l 65/L6 87lA 230lLL 23!/6 240/5 2101t6 9819 981L7 981L8 99/8 99123
t47/8 L1179 24012L 240/22 Lool9 tor/3 LO5/1.2 LO1l22 708/8
rnrngl t{l L6l2s 60lLl lcrBdr. t13l 65/8 67123 68/6 LO9|L1 LL9/3 Ltg/L3 119/1{
8sl6 e'/tL 172125 LL3l4 LL3l6 t2ol3 r2olr L24ls tzrllo L39lL6
r tll r8l4 rlrlzo L2el8 Lr8/L6 L8O/t9 ttol2o L41/6 tlS/2 Ls2/2L 15713
se [1] 180/13 2t8/2 1s8/13 L6o/s L6t/22 L62/2
rude [til s4/L2 s5/9 62/22 tend,/cosby I1l 109/15 L66/22 L67122 L74/L7 L75/L3
64/L2 19/18 Solr S2l2O 9Ll3 tant [1] 29123 L78lL7 18{/18 Le5lL? 185/18
concluded flll 62/8 6219 6315 tute [1] 8ll2 L8814 t8e/2L LB9/23 teolr?
75125 7gli3 s8l],2 ]-2L/L3 190./6 citutlon [1] 64/8 1es./13 L96/3 zOz|LL 2O2lL2
228123 Bll25 24314 trued t2l 561L4 571L2 2L5lL5 2L7lLs 22017 22Lls
udec [1] 82122 r tll 94120 22LlL5 22419 22s/r6 22619
aLon [15] 321{ 32lLr ionr [1] A2|LL 22612t 221122 22112s 2281s
so/zL 601L4 6olt6 6O/2L 62124 t1l 203120 228/t6 2281L8 229/8 2291L5
1812 LL4ll tlslr rs3l4 rs3lrl t1l 72/25 229/2L 2sO/7 236/23 210l|6
tsL/rl L9d/2t zrol2 2eolB oonte.ct [8f a3ll3 55/21 3816 2ru2 21417
t6t 44120 4812 67123 9llL6 tooltz 18s/13 ted [1] 92/2r
5sl10 sell 6012 t2Ll25 2L3/L6 tion [1] L96l2s
[1I L4l6
onsurrentlt tst 3ol7 r3lL9 s8l2} rry [{l B3l2 831L2 8sl3
tlonc [1] 68/9 80/L4 L96124 e9l5
onduct [?! contrctl.ng [2] 44la LlslLO
81/2 90122 154/4 roboreted [1t 2t214
2L5121 nQn ?36/LL 237llr trcB [sl 53120 ssl22 79173 tion [1] 55/4
onductea [61 ,olLe s.ol24 sLl24 LrglL2 r3Ll25 t2L7t Ll6 2lLO 2/72 2/1s
53t2. 54llt _1!13 _ t6l s6lr3 e[lLL L6816 2lL7 2lLe 2122 316 319 3lL2
onrercncei[3ot sl\9 6110 1618 Ls9l6 206/9 2441s 3lt4 e/Lo lol2r 24123 3sls
46120 47ll 6el'-9 LO2|L5 103/s t2t fi12 e8ll6 50/18 sllS 531t9 5413 51/t4
to1t.?3 L-1',.114 l3l L6/L3 84122 sslts ss/L6 s8/2L 60l!9 63lA
\?21\ L3slrg
73a17 131'1,L4 L35/L2 -\?L,t-l 63/1 6412 64118 6513 6sl6 65112
L37l2s L4Sl]-7 r{8/19 t48/2O conteating lll 8lL7 c5/L5 65120 6612 66ls 66112
LSL/23 15{./11 t5rl12 ls1l23 context [5] 73114 L2Ll3 141125 6612L 6711 6716 57120 5817
L68lr 789114 20olr3 2oolLs lsull 2L6l2L 68110 681L2 7s/25 74/9 141L3
2Ool2O 2oglts trl 85125 75124 76/9 1714 7712L 78/3 78lr
I2l
-
13sl1s t1rlL4 tingent [2I 202116 2L1lt8 79lt4 79lLr sDle sDlt' 8LlL7
tlt 63/4 tlnuatly [1] L1LILO 82/Ls 8618 86lLt 87/7 871L3
rd t{i s4l2t 551L5 s6l5 tsl 331L9 491L7 49/L8 87lLe s8/7 88l]-o 8e/2L 9olLt
6s/7 6el8 eo/8 toL/20 222120 eLl6 9r/9 etll3 97122 eV25-
onfiraatign [1] L6123 t3: s4l6 r3r/22 92/S 93/2s 94le 9412'. 9514 9515
onfrrned ${l a3/12 58/5 L4212 e5lt3 951L7 93120 e6l3 9817
7731L2 I ibute [1] SSILO g€lrs 98125 9919 991L7 9el2L
onrrontedf'I1l ]-1611' l2l L3Ol4 2tol23 LOOI2 to3l2L Lo8l7 los/1s
onfured [il 7ogl3 ling tzl 2LO|2O 2LOl2r LO9l22 LL2|?L LL4l8 LL4l25
ongresa [tI 20123 rlatlon [1] 185/5 LLsl2 Lre/2 L2ol75 r2oltB
onnectod tll 6slls rsatlona [1] 551L7 t2al2r L2716 L2rlL2 L22123
onn6crtonl [1] g2/2s l1! L3219 L23/2 L23l2a L2413 LzrlL5
r lll SolL2 oy [1] 22rl2l t25176 L26ls L26/LL L29lL4
t3l s7l7 5717 5718 ict lll LllllB LzslLg L3Ol8 L33/5 t3rle L3rlts
consider [13] 6/5 79/r 7917 ict'ion l?l 631t3 82122 L34123 L3517 L3813 t38122 L3914
8Ol2L LO215 to4le LL6/2 L2517 rzolzl L2sl24 L57lLS L6718 L4Ll24 t45lL7 145/10 uTlLs
L4OlLr L4A/L2 t8319 L9Ll7 t8213 Lall22 L49/L4 tsolzt L5L/2o
ts3lLs s ince [1] 5lll4 ts2l3 L5218 L52lL4 LS2/L9
idaratj.on [1] 761L7 rnccd [{l 5516 L93l2L 2o2ll 155/10 Ls5/L5 L55/23 ts6l6
rderod'[2] 7911 loelg L56/s t5al7 L6612 L66lt9 169/24
ering tll 66/5 tll eols t16l2t L16h2 L76/24 L71lLL
err flt 28le tzl 1713 77125 L7A/2 L1elLl L79lL2 r80/141
rentttll 2o3/L7 ns trl L34/9 t82ls L82/8 Lszltl L82/tL
onctand [91] 2r/23 26/Ll 30/7 on [2] 69/7 7715 te2lL6 !54/9 LellL2 188123
431L2 4416 r7lL8 4el2v 501L7 rative [5] Lll/25 L4216 ,,a9l2e L89/2a LgLltL L9LlL.
s:-ls s7/Li 53lte 341t3 sslrs L4slls r61lL9 L69125 tg2lt} L94lL3 L94lr6 L9sl5
38122 6OlIs 6tl2 6LlLs 6tlte I1l ]^sLlg L96/14 L91/23 LgglLs L99l2O
6Ll2r 6115 66le 661L4 66122 rting [1] LglL2 2otlto 2oL/L8 2oLl2L 20212
681L3 711i2 7613 77/t7 77122 tll Ie?le 2O2lL4 202123 203123 20415
7813 7816 7e125 8Ol4 831L6 11l 7231L5 2O4lL0 2o5lr 205179 2o9l2].
83121 86/+. n12 e7/3 eol6 I5l t'-lrr 2o/e 2olLo 9't/L9 209/21 2L7/!6 2trl23 2t2/A
stlLl s:.li6 e'l6 Loe/L3 Lt2l\r 2L2/70 2l3ll 2741L9 215123
LLl17 L74'lL6 Lt6/s t2r'/r6 a2l 1s9l9 159/10 2L1lt2 2771L7 2L7/23 zLsls
tr3lL} t1't/4 tss/L3 L55/2L lst us sl23 616 6lt8 2L912 22o/ts 220/L9 2zLltL
L5614 L56122 tsllLo L1L|La 6122 6124 913 9125 22L/2L 2221L3 2221L8 2221L9
L7817,J8rL3 L8Ol25 lguLa 22316 223125 224122 2251t3
185/1{ L96lL6 20215 2o2ll4 orreer [85t 47/t9 47120 49124 22s122 226/9 225/18 22Slr
z}slLs 22612L 220124 22L14 66ls 66/10 67/7 7sl4 7614 76/LO 22e125 23t17 232/LA 237f2s
f
)
I
94/7 9517A 701/L6 7O2lLe LL6/2 3 t1l 3s/L6
Ltg/24 L2OltO 130./13 L32/L5 -{ t8l 7o/L3 7o/L5 7o/r8 74/23
cosBr... all 2rol3 24O/2O L6Ll7 t61h 7761L3 ae3l3 t86/2L L55/2 2rsls 2L5/7 2L5/LO
Coabyrr tl$t sLlz 3L/23 5212 L87lLO 23Llt3 23319 233123 5 t6l e6/a 9719 L86lL2 L86/L2
52/s 78119 80125 Loo/Lt roolL2 234lLs 23SlL4 233/2L 23614 L87lLs t87/L9
!oo/L1 L27lL2 L63lLS r?s/11 236/7 236/7 2361e 23619 244/ro 5 t?l 10{,/13 to4lLe Lo[lLg
233',43 23slle
22s13 233'trs 23sl:-g 'r lrtl 6lL7 35/9 42/L1 LOslI L95120 2O9/tL 2o9lL4
ve 121 7120 8lL4 ? t6l Lo6/t3 !O6/L7 LO6/21
I11ei 3lL4 612 rele Lgle tery [1] tB9/17 LO?lL6 2o9/L4 222/3
3s/r5 31116 36/2 3613 IL|LL re [1] Llts t2l LoBl14 1o8/19
42/Ls 56/i4 6OlLe 6L/70 6LlL3 roou [6] LltL 815 2916 .A I19t 2s/5 s9/2 67/22 68/s
6L/17 62/5 621L2 6313 6rlLe 64122 Lt3lL2 tl6l6 7L/24 8'lr5 86/23 Lo4/23 los/10
6U25 66/L2 68120 74/19 7sll6 r [1] 2L6lL0 t9sl2o to6/LL Lt1l24 tt1l2s
80121 82li' 8612 S6ls 88lr tll L2617 118/13 Lssl/1 205/5 2O811
88/20 gLlF s2lLt 9uL2 1oo./18 t1l 22lLs 2L9123 22OlL3
to3l2 torlt{ 1os/3 Lo7llr I1l tLel22 .A.'r [6] 6sl4 8518 96120
113/15 LL'/L3 LL1|L7 t2Ol2L ro t18l 6818 981L3 L27l2t L27ltL LeLlLT 225/20
L2tlLi Lzi/Ls L22/2s t'2316 142121 t4318 L45/s 1{s/1o t2l 3lLL 197/22
L2s/2t L26/8 t2919 t3412 t4a13 r45ll9 r4713 r55/L2 Ls'l2o ly t6l 2lLg L5816 L58/L2
1{s/10 Lr1l23 L4611 L49122 t5613 L56lL3 75716 2Os/3 232/L9 L6O/3 L6O/22 162/2s
1ss/13 l'i-l2L L5614 Ls6/Lr 233118 234125 a2t 6218 t58/4
156/18 L561z: L5716 Ls1lL2 ced [6] 52lr 87/L2 to5/24 11l 236lLL
L62lL8 163/15 L7Ol{. L1416 LL3l9 7LSl3 15?/t0 Ill 205lt3
r16t2r L8218 L83lL6 ting tll Ls8lzL llsl t6,122 s9l7 6tlL1
'Js1'prsol6 L9319 L93/23 L9417
18417 redibiltty l28l 27/22 28lIA s2/24 LLO/L9 lLs/2L 1{0/18
tslls 2ool5 2oLl2O 202/4 202122 25124 2sl4 3216 48123 6211 62le r7l/2t L7slLt L16l2O LSO|L2
203123 2OllS 204/rL 2041L2 741L2 8319 83121 851L2 tL2lLs 198/13 t98lt4 \98/Ls 2L2125
2O4lL6 201122 2O5l2O 20s/22 113/10 tr-sl4 Lr5/t6 L2t/L2 tad t28l 2113 2/t6 2l2o 3/s
205122 20715 2L219 2LZ|LL tz:.lr4 L36ls L38/L1' t38h7 317 3lLO 3lL3 3/2L 3/22 3121
2L3lt2 2L614 2t7ltt 2111L9 t42123 L57lLL tat.lr]. t6tl23 416 4la 7o114' e6/6 104/11
2t8ts 2Lete 22OlLe 22O/2r 22113 ts3/22 2t617 2361L2 LO6|L3 LOg/12 115/2L t47/L3
22L/71 22IlL3 22L/L8 2221L7 ,redible [12] 60117 821L3 L48/2 \5217 L52lL3 165/2r L61lr
223t5 223'1"L3 223123 22514 22516 L2O|?O t2l-l6 L2el21 L3{lLs L76122 L79|LO L97l2L 2L814
t35123 74618 203122 20413 20419 dater [3] 93176 L14125 l9'l25
2solLg ?34t2L Z3L|LO 23LlL5
23s12 23718 23712s 23812 2L8/2 1191 t4l3 Lrls e6lL8 e1lL7
tll 6elL3 LO24L3 LO'|L? 135/3 r-rs/22
ouldnfr lgl 22L124 223/Lr L45122 14617 t46/e L6814 L70124
8o/e ,3rlLo 21uL\ t?l2218 291l'3 65/22
t1rl2 L9611 L9611 t98lL7 2oslls
ounrel [2it Lltg 5lL9 22123 16716 221122 22u24 22719
208lLr
4Lt8 a't141sl4 45ls 4318 rslt3 iaef t2l 2123 L6613
921L4 e3lrs
lslL' sLla s2/. s2l5 s3l8 63l'^0 'r [1] 60/s t6t L3lL5
Lo2/5 t0zls LO3l6 2t2lta 2L2l2o .' I1l L66l2O tlsl2o L2Al22 '-618
2solt6 2sgl2o 24019 tlst t3/22 trlB rsl3 I2l 2tlL8 90le
ounr [2] ltstls tslLO 751L6 LslLT Lsl'-g L5122 tlol 561L7 7S/2o 9212
271r7 5s/23 116/10 rl6la2 1OO/r3 toLlaa tL9l27 ?OB|L9
orrntrv t{i lol2 'f,alt
2r/7t 2slL8 2L3122 2t3ll3 23513
1t6/L6 LL6l23 2241L2
t6{t Llz LlS LlLs L3lto i-ainal [35t Ll3 618 7/2L 8116 t6I 24/L7 2Sl2 34125
r3/L3 L5123 1613 L7l7 L7/L2 LOILL 5216 631L9 68lre 1712O 77/t3 LO3/L6 2L6124
r7tts L7l2O L7/2L L8l7 tslg 78/7 8rl3 821L9 82/25 S1l8 t1l 215123
L8/2O tsliL L8/24 :-8125 Lelt 87lLs eols eo/e 941L3 9516 I1l L9L|L2
2L174 2Lli4 2LlLs 2L123 22lS 98/11 11s/1L L2llzL Llslto death I1l s9l11
23/L6 2slit 24/5 24/?t 24125, tr?lto L{912t 1so/15 L5Ll22 debete t1l L2616
'2511 2616 211L8 3sl4 44/8 481L7 t5414 L57/L2 t62l'.8 L64/L3 decadea [2] 5918 5212L
5Ll2s 5et?4 59lLL 9rlt6 e4124 t83/L3 L99lL7 22olt9 230/3 suber [1] L4/2
9s125 961\9 LLOILS LLrlL2 crttictzod [1] SS/S ide trlt 60/22 9113 L27/2L
cross [16t 2lr LLLlzl p6le
LL1lL} Lr6l7 122125 r3rl8 t27t 9l2t 111L8 23lS
t70/Ls L1il2 r96/L3 203120 rLLl22 rL2lLz l,rsl2'
'.oLl2LLL'/L3
LLs/2r tsLt2} r32lLO r43l2t 6Ot4 5OlL7 63125 61/24 66/25
22Ol2O 22i/22 221123 222123 18/r 81122 8Al3 98/LL
2aS|LL 224/8 22417 22r/23 Ls3/g 1s3/s L6rlLL L6t/L3 a62lr 7119
cross-eranination [1{] LOL/2! LLO4a3 LL5lt1 L27lLo t27/19
23OlLs zsilL3 23slt.6 24t18
tJtl 812 ro8l23 LO8l24 LLL/2L LLL|22 LL2lt2 LL3|2A L5612 ts8l3 L7ol23 L7Ll25 L7217
Lr5/L3 Lstl23 t32lto L$l2a t72lL9 L72l2L L94ls re4l9
La1llg 2tol23 2231L8 239113
oursc [16] LAIL6 2ur2 s2/24 Ls3ls Lstls L6tlLt Lc'lts L62lr L99lL7
7612{ 771+9 88lrr }tgll7 -L26lL2 roet-eranincd tll LL5l24 I1l LtTltL
Lso/L6 tsilrs 1eo/18 LerlLO crygtal [1] 111/18 declrion [8{l 917 L3lL7 3OlL6
cuff tll 3Ll7 32/8 32/9 34/L2 39/Lt
Ls6l2 rsf,lLo 209124 2!2lLL 2OO|L5
3stre Ql2 441L6 1817 AeltL
court [63t 1 ll2 LIL.L 5/3 5lL4 r t1l LlolLo 5LlL3 641L7 66120 571t9
st2l 6l22i1lL1 el6 elrs 9/L8 t31 3Ol3 3O/4 LeBlL3 5Ll5
6el6 73t2 731L2 8rl2o asl2 asl9
s/20 sl24 1617 L6l2o'36123 3718 8Sl2L e7lL1 871L8 e9lL3 eolLo
42/7 r5lt7 16124 s2l4 561t2 go/72 9612 96/3 99120 tv2l1
s1ls 37lt$ 5elJ.2 59lLs 59123 Lells Lo9/22 LLolL2 Lt6/L4 LL6/24
5et24 6019 60/25 6e122 73118 t a2l Le/L4
L34/2 L36/s
7413 7rlr9 85lLO 87lLL e2l3 2 tll 2ol2 L26/rs 126/L6
t
Ill gllr0 79/7 791L7 7e/22 79/24 80/2O
tlon [19] 6sl2l 9{/e 9s/5 83/L2 83/ts S5/3 es/r 87/16
€cilion. .:, 1421 L38/t2 L51/9 99/4 9e/22 L82/9 2O4/L9 22L/25 8112O 89/6 8e/2r 90/7 sO/27
1.57/23 $a/2 LBL|L7 181/18 222/Lt 223/L5 224/2 22s/5 9tl2 91/L3 93/6 94/4 94/20
182/1 L8276 L82/22 Lgrlr' fi6/s 22s/L3 225/23 227/8 221172 95/LO 951L4 9s122 97124 98/6
18616 L86l_6 t86/8 L8e/2 Lee/24 227/t2 230/3 23olls 99/3 99/6 99/7 LO0/LS 7OO/2O
193/8 19{/3 re5./5 195/16 2O712 epoaitlonr [5] 9Ol3 226123 tosls Lo3/L5 LO4l4 Lo4/5 LO417
207124 2081L7 208125 2LLl23 226124 22913 22919 LLAl9 LtOlzO LL2lze Lr3l4 tLsle
2L5/L4 2L6/L3 2L6ltS 2L6122 vatlve [9f 23217 232lLO L15./13 115/15 Ltl /Lt 7L815
2771{ 2L7lS 2L716 2L7ltL 2L7/L6 23119 231112 2341L4 235/13 118/10 118/11 119/5 119,/11
221123 2371L3 2361L8 237/4 2351L6 235/25 236/s Lt9lL2 tt9l23 rz0lt.g 72315
2311L2 231lLs 2.0/3 2r2/Lt ved [8] 22Ll2s 222119 223/6 L25/2 L2513 L2sl1 t2sl8 L2515
ecilion-Eaking 12I fl6/24 223/Ls 225/7 22s123 22716 22718 L26/19 t26/20 1.27/5
195/15 ! deacend [1t 9l/25 '-26/2LL30/L9
L28/t3 a29/s r29122
l"onc [11] 21 15 32/20 42121 deccr1be [2] 7616 1L9123 L34/L8 !3s/21 L0r/4 L0S/s t4s/7
43121 r9lt3 5O/7L 63124 66115 deacribed [8f L2{lt4 lr7lLr 71712L L5416 758/3 767/9
LL6l21 236/22 2r2l2o '.2ol9 L4319 L63/9
L27l2t L28lr lr2lzs nal2o t72le L72122 L7S/L6
arrrlod [8] Lo7/2s LO8l3 L8o/!9 182/3 La4l3 tSsl? L8s/2s
ts6ll2 tsitl2s LgelLe 2OOl3 sorlbing [3I L2515 t50120 18S/13 tgalt6 L8919 Lgol29
2O7/t9 2L*lL4 L5L/L9 L9rl5 L9L/7 191/13 re2/22 t93/2
eclaatiog'c l1l LO7l22 2/9 3/r 3lt6 L93l2O 794/LL L9111 207/3
ecltned [$I 2l2t L]-7l13 L42l2L 415 L38lL3 2orl77 2O4lLs 206/22 2o7lr
L6s/25 L66ltg rlgrn l3l 5911-1 621L3 62/23 20116 2O7lt2 2O7lr3 20813 20814
ecltner [{l s2l2l ted [1] 22/25 209lro 2L7l2o 21218 2L3121
eclinlng [2] LL6/2L llsl2l igmed [1I 2O'|LB 2rll20 2L7125 278/9 22615 2281r
tsl 5i10 6e/8 691L2 te tll :,L318 232/L7 23212L 2331e 236/L7
Lotl7s 21218 t3t e6l4 L60/2O L62lre 237/s 237123 23813 23812r
t3i Loel6 L92178 19?/3 railed [3] 6Ll2L 86/24 L78lL2 2KIL2
ion fll 228123 tauc [2] 84120 2L6lL3 fe [?sl 2/22 2122 L3/11
r tlI 23613 ve [5] 2518 2s/L4 25lLs L8/6 241L3 30122 32124 32124
IU 61125 25/L5 t69lt4 33/s 351L9 4612 5O/2 62/L1
tc,t; 2416 L72lL7 L7312 vec [16] 4rl8 l8l:-7 5Ll4 73124 7515 8Ol3 8O/$ e3lL9
5L123 52117 3517 5618 7618 $l2s e4l6 84lLL e1l5 95/Le
.efendant [22] ll25 515 7122 rclLg 80121 8LlL3 lLOlLs L78lL3 e7lLS LOO|2I rO3l2L 1o{/8 109/s
8l2L elLO;4112 sel1 69/2r 203121 2L3/LL 2Lu23 110/18 LLllLr 118/18 L2rltB
LO2|2L LL6l25 L23/2r L?'|LO ternination [18t 3O/L9 39/2 L2516 tA4l20 L4al2L L57lL[
Ls2lL? LTaJV L74lLs 181/19 43122 5Ol6 50/7 5'Al8 s2lL3 6013 158/18 t62lL9 L6rlL2 L66/2
183/13 L8618 Le?lL2 tlel20 6316 6312L 7ogl7 ro9l9 t29l2s L6612 L66lLe 165120 L67ls L67ls
2ool23 ?3q5l'6 L3^/2O L3517 73611 2O9l2O L7A|L' L7513 t9Dl2 190/5 190/s
ef€ndrnt,,i [21] 213 S|LS 4/1 209/23 190/18 L9O/2O LeOl22 LeOl2S
LL/2 tslLi L9/L8 2Ol2 3SlL6 inations [2] L3glLt t9tl3 L92120 79212r te3lL7
7OlL5 71123 96/7 9719 70rlt3 2OO|2O 2OOl25 2O2ltO 2A2lL2
LOslT t0cllr LA7176 108/13 tsl 261L3 4Blat $11 204115 2051L2 2t616 22rlLs
L7S|L7 L87lL5 z}gltL 21s17 L72/4 L9619 22719 22913 22elL9 229123
efence [1$l slzr 616 612r LOls tenined [11] SLILT 57 ILO 23O/L3 2321L1 232123 23{/L8
LO/24 2uI6 5216 63/LO 7L/L2 6ols 90123 L29123 t3ll'.e L3s/22 235121
*r1" 73st7 '-75/4 1eo/10 L46/3 L55ls r71/6 1911t5 121 100/r. Loolz3
illriz I2t 8418 2361t3 ered [1] 2271L3
fenre-e tll 7LlL2 trjrental [3] 79lLB L2217 fference [2] t2U24 L25/L2
fenre-S [1] 961L3 fferences [2] 73llg Lglll0
a2, 3211s 39lt3 fferent [16] 39120 l4ll5 4719
;t ii- 'l-
ftnlrelylt3t - t6al2o L7L/L5
tll 2tu21 8314 Lt3lLz L2212 r22lL2 L26lt3
efinitLvet[1] 99/L6 t3l 2lLO t3gl7 t3716 L40125 15,LlL9 r6u2
L76lL3 2LO|L1 226/79 226125
::ili:lY"{Y,::t
eray [6] i3lLr ..22(?o
LLi/LL Llrlz5 11l t7313 ficult [,s! L62l2L L6lls
L69122 Leen3 Lell23 I2O8l 2lt4 5lL9 6lLO Lr/25 2LLl25 2t2/L3
esate [tt 25/2 r4l2s t714 L1lL3 L7lL1 t8l3 ffi-culttec [2] 18/6 4819
ogated [2] s9/2 L89lL7 LslrB t8123 20122 2tl6 zLfls fftsrrlty [2] L33l2O L78/5
Iinertcd [1] 23lLO 2212 241L3 24121 2al2r 2sl2 12Bl 214 L2lLr 9o/7
Lvered l{l 971L7 91llg 97l2L 281L6 30ls 3016 3ll:.e 3212 toLl20 Ll2l7 L72lL3 119/15
321L2 3212s 3312 3312 3el2 7261L2 L26178 L2813 L2sl25
ve [1] itg/zs 3s122 43124 4116 a5123 41122 LALIL9 L56l2s t6OlL2 L6tlL5
t3l 7612O LOt/4 47/24 47124 1812 4elr 5ol2o L6Ll24 L?{lLt L7sl9 r7slto
sol23 5Ll5 sLlT Slllr stl2s L19l2t 181/15 tSIl25 2L3lt8
trrtird [1] LLltl s2lL2 s3lL2 31120 ss/3 5sl9 2LslL1 2L719 2L7112 2L8/2O
t1I. sslLL SslL2 S5lL3 S5lL4 ssl'-r 222llr
-lo/rr
118/{
L$/s L62ls s8124 59/4 6013 60122 6LlL2 rected [9! 25/6 4717 5sl7
tgi 67123 9013 t'22l1'- L86/3 L92123
ns I2l lss/19 Lss/22 6317 63/18 64lto 641L2 6rlL6
rtrenrl [6] LSI2O 26lto 66/11 66/22 671L7 671L9 68/L7 208124
26/LO 1rl5 SLl22 76/7 6s/r9 7O/1 72/4 721L5 731L6 rection l11 50125
I1l 18/10 73/2L 7dll 7l/Lo 74/L2 7rlL6 irectly t31 8617 tOO/13 ts8/23
t3i t47l2O r4815 Lr8l7 74118 7718 171r2 181L6 7el4 aagr€€ I1l 23116
35/L9 36/rL 37/6 37/L7 37/23 65/L9 91122 9l/23 e4/25 9s/3
431L5 45/2 rS/3 45172 4s/L4 L0s/L6 LL1/L7 LA3/2L t43/24
eappear [11 29/L5 4S/2t 47/22 52/8 s2122 6O/7L L44/24 L47/3 r5O/LS tso/23
isagpointid [1] 110/18 60122 63lLL 66/2L 67/3 69/7 t'r/A L54/5 7s4/76 t6t/t4 L63/4
labelieve;r [1] t37/2A 7ol2L 7LlLz 7t/L4 7L/L9 7213 LB8l5 208/23 219/23 22o/a4
iccern [1] 8ll9 72/L2 771L3 e2lLO 85/23 87/75 228/3 229/t6 234/2L 237/2O
insra' [{l 63lLS 63lts e8l8 89/5 9Ol1 9o/2L 92/23 240lto
235/2L 238/t8 e1/L5 9slLr es/22 96/L3 loo/19 tll 40123
dicclore [2] Lrg/tL LSL/25 LO7/2t 103/ts Lo4l2o to4/2L c 12) 88/6 L88l2s
LOs/s LO6|L1 108/s LOB|?L toelg don't [1?1I TlLa 7lLl LOl3
109/11 LO9/25 !t2t8 LL2lt6 L1122 Lgls 2316 25123 261L9
ccovered![2] 1oo/1{ Lool23 rL2l22 LLalg tlel'-' L26lt9 2elL7 3t/2L 3Sl2L 36/2s 40/24
Lacovcry [6t 39121 4ol3 lo/22 L28/8 r28lL7 r29lr2 Lzel\1 rtl3 4rlr5 4LlL8 4216 a3lLO
871!3 eol6 L80/23 L29/L7 t3O/6 13ll2s L3413 rr/2s 15122 45/24 46/9 46/L4
scredited [1] lt6ls 734/24 t35/2 1331L1 13sl13 17lto 49/L6 SOla so/g 53/4 33/5
ccretloni[5] 2713 19/8 49/L3 73719 L31l2o 138/8 L39/6 L(2ltL 641L3 70lLL 72/12 72/L6 79/76
14311 L4317 1't3/10 L46lL7 s3123 85121 86ls 861L1 871L4
ISI 6lLO 82lLL 821L8 147123 L47/25 trBl'-g L18123 88/23 8917 8el9 9218 93/LL 9512
L23/r2 r7?ll0 L82118 tASlT L4el6 L4917 1{9/1s L53123 t5sl3 97/!7 LOLltz LO'/L5 LO5/2L
]-88/2 | L5515 157/r9 lss/{ L6Ol7 t6Llr2 to6/3 L0713 LLOI3 LL?ILO 113/1s
i.'o"""a hsl a2lt2 s:./78 L62lL4 762122 16312 L63lLt 7Ls/22 LLll7 LLBIg LLgl6 L2216
t2812 L28Is I?S|LL L67122 L63lL8 76312L t63/23 L6rl9 72313 L27174 t29/to 131/10
t8rl22 t8I/24 t82l:-3 L82lt4 r61/Ls t6s/L6 15s/19 L67/17 L341L2 L36lt7 L36122 L37lL6
t9slll 20718 207125 2OAl22 L51123 765/5 t68lt2 L68lL5 L37123 L31l2r L47/LO L$16
20913 . L1Ol9 tl0ll2 L1Olr3 L72lr4 L43lL3 1{3/18 L43/L8 L16125
rcuaaingr[2] L67123 2o712 L13ls a13122 L7612 L76/9 L76/L6 L[e/7 t4el7 1{8/10 Lr0/2O
ecucrioni'[2]
Ecs-algra{ l4J 5317
rJa . L89lL7 L76lL8 176120 17711 77e122 L48l2L L49/3 L'ol11 1s1./6
LsL/23 Ls3/4 L54la L5418 ts4llA
.
anirred tll 613 L7912 L1914 L79123 180/1s

rprtchini llt L9ILL
tchJ-ng Jlt LuILL L84123 r85ll'2 r8sl24 L86lto r5a/L2 Ls4/L3 1s{/1s 154123
ayca fz; 12/4 Llel2s ts6/L2 186/L4 regltl- L93lL4 Ls1/r8 L5e/7. LSgl6 ls9/8 L6tl2
to t1l s6122 1e3/1s L9r/3 t911. te4/4 t95/L7 L6216 L52124 L62/25 L52l2s
rT'i11I 1/8 ts5l22 t9S/24 20018 2oolLo L63/4 L6314 L6gl2o L64lr9
cectcd (11 l-(ll1 2OO|L7 2OO|LS 20ol'-e 2o6lt7 1,6u2L t64l2l L64124 L65ls
rrncr tII L2O/L2 206123 2oels 2t2lts 2L6lL9 L65lrL L65lr7 165122 t67ltg
rinctios t3l 221L3 2212r zLBltr 2Lsl3 21et5 21ell6 L6812 L6813 L6813 t68/e 168/18
2L9124 22Ol2L 22O123 22216 L6A|2L L69/t3 ]-69123 L7O/2A
I+261 Lle t/22 318 2221L5 225/L2 221lt2 22719 t72lL3 L12ltS L72123 t?3lLL
6ir3./10 L3lr9
6/LL 6lL6ir3lto L3/r9 L3125
L3123 23}lr8 23O/2L 23LltO 23LltL L13lL2 Llsl2| L76120 L77/7
t{-lLt LllI3 L4/2o L5lL2 23tll5 232121 232123 232123 L77l2L L78/2 L?Blta t1al23
'rl'-s r6lt5 t6124
tslls L5l6 r6lLO 233lLs 23d.ls 2x4lL8 2371s 23715 t&oll L81./6 L8rl1 LsrlL{ 18sl1o
t716 L7l8 t7l9 r7lL2 L7/t4 23719 238114 23elr 212llt tB5/10 res/14 \85120 1a6l2o
t7/L7 77lte Lal23 L8124 r9l2 tll 232120 188/1e Ls3l2 t93lL3 1e3/1e
Lsl3 2rlL! 2uL4 2L/r5 2L122 I2l 233/L3 2331t9 19s/13 L9616 L96125
2313 23lli 23/20 24/6 24lto I.?l r9l2L 3717 3818 198./11 2otl3 zorlLl 2O6lLs
'-97lLB
24120 24t25 23/7 25lrO 2s/L2 38t2L 3e/7 rLl6 (L/rO 4rlLl 2}5lts 2o7lL3 ?OS|LS 2Oel2L
211L7 3oll5 31122 Ssl23 39125 a3l5 66123 70119 7tlL3 72/3 2LLl22 2L2l2s 2L4lS ztlls
47125 48115 rslL'- 5515 s6lL2 72t2L 751L7 7s/2o 7sl2L 76172 22OlL7 22L18 2231L6 225176
g'€123 63122 7u3 74/LO 77/6 s6tt4 97122 Lo3lrr 103/1s 10?/9 23Ll2r 233123 238123 242lLS
7819 7Sl2I EO|A S2l2L 82123 t24lLs t33/2 L3313 t3313 L33l2L t18t 819 32122 s7/2O sst21'
8318 s1/76 84121 8612t 89/t1 tsllr r3sl7 L3sl6 L39l2s 1{1/10 58122 7r/t5 8013 92lLO 95121
8sl2r solll solr? eolz'' e4l7 tlL/Ls 14Ll2o tr7lLa rrg/L4 Lr1/18 L4L/L5 LA2/L9 t47/3
941L6 e4l20 eslL1 e6/Le e6/25 151./11 151/16 l1glLo L5318 Ls4/74 L93ls 2t2lr2
91/L3 e7l\r 91/te s8l4 geilr '52/LLL79/22
L6317 L63124 L63l2s 235122
to6l22 r'-'ls tt0lLo LLo/22 L94123 2tBlLL t1l t5rl22
LLr,lLttLll6 L3418 14212 t57lL4 ted t2l 86lLo 861L4 t12l 60120 82fL6 8712s
t?ollg t7il24 t?Ll2o L7212 ting t1l 2O7lL9 Lll/rg 115/1{ L2Ol22 Lzslzs
L74lL6 L1512 L75lL3 t75lL8 ts t19l s6l2 391L3 40125 t3LlL2 L6718 18211'4 203124
L7glLt L83l2A 18{/10 L84l1L 4L/2O e2/8 ttzlll- 42lLL 421L4 204/6
LS5l2 t85i8 L87l2O Ls3l4 r95lro so/2 LO6/6 130/1{ 130/18 L3ol2t 11l 14/LL
Lsslzo Ls6/8 2OOl22 131/14 L3Ll22 t32l2o t3ol9 t22l Tllo 2olL9 49/L8
20slt8 2Lut2
203t2L 20rle '-s6l',3 r3tl9 L9719 77/2L 79/1 82/1 tO6/7 Lt2lzo
273lLz 2Li13 2r7124 22211 t1t ts2l22 L2617 L3rlL7 L{,LlLs L54lL7
222123 22ilrs 23'lt9
2281L5 grlle
t16I 716 elLr 22le11s,/6 t63lLO 16s,/15 L7212 L17|LO
861L3 S8l9 Egllo 9ll2o L7413 Lg:-lzt L94122 2o3lt7
sroN [[1t Ll3 r3/2r L4l8 13212 r3a/L3 139/8 L52122 2LA/9 2rLlLS
14/L7 Lrl22 Ul22 L4/23 73/6 L77lL7 23513 2361r t{l tt[lLL 118/11 tlal2o
Lsls rsltg L5124 ,ts [1?t t0lt8 1s/L4 103/10 20617
t1t 29le 11{/13 136/79 ta3/22 L44122 anatically [1] L58ll
o 12001 9121 9lr4 sl2o LolzL t48l2l L6Ol24 16L16 L6rlL7 icelly [1] 236lLL
L2l1 Lzl'lL2lro t6l4 r718 771L7 !6tlL8 t71l1-L 77s16 19413 20819 I?l 47121 1el2 ssllo 771r3
1-st6 2u2t 2311 2318 2718 2719 20eltL 7s/2 t2rl25 t2s/2
211t2 321i6 32121 32124 33123 dotng [30t t6125 30/17 4412r t1I 93124
D
62/Lr 74/L6 82/6 averyone [3] 77/2 166/L7 22414
P
€ndeavor (21 35124 205/25 rverything [2] 53/LL 22617
drop [1] |2/L7 ended [2] L3/20 L?llto rvidence [66] 2/3 8/L7 LOlt6
drus [1] 29125 enforceable I1t 33/14 LLlz L9/L7 LelLg 28/20 2e/8
drugged [1] 29120 enforceuent [11] 20/23 25121 2919 29/14 3616 41/20 4Ll2L
drugr [1] 29120 25/2s 27/23 S3/2s 54/72 51/t7 4413 s2/L7 s2/t8 52/19 S5/L7
due I1l L63/LG 8Ll2 85/t5 94122 L75/74' L77125 s5125 56/ts 6016 60lt8 6LlL6
duly t1l ltli 78L/2 L83ltr 621t3 64/9 64ltL 18120 8212
duratioa lll 28123 onfoac€r€ntft [1l t'all4 821L4 e2/L9 a2/2O LO2/6 1Lu77
durinE [15J. 53/L1 53/2s 7r/6 engage lll L94/LL Lt4/t8 tL3/L2 t2o/L7 l2Ol2L
76le 85/tl loe/13 tt6/23 Lr9/13 engaged [2] 57/27 236lLL L2o/2r tz''ls L2L/6 L2tl1 L2L|LL
L26/L2 126n n2/9 113/23 engagtng [1] 122124 L25.122 125123 L2sl23 12817
183/t{ 2L7/r2 2L9/8 enhance [{t 29/4 8Ll9 81-/10 L2913 t6L/1 L6Ll4 t5Ll2O t62177
durv t1l Eats L93lLr 16717 L93/9 203122 2O4/3 201/8
enhanced [1] 27122 204/e 2O9/2o 2t2/9 2t9/2O
E s enhencing [1] 206/2 22O/L2 224/25 22512L 230llo
e-aarl [{2f 3/22 416 118 72/5 enoruour [5] 271t9 2el5 32/2 212119 24415
e5/23 e6l6 e6lL7 971t3 LO{123 72611 223lll rvldentiary [5] 9179 78122
tou2s 10$/11 10s/1{ 106/9 enough [8] 4218 L2Ol23 L2ll5 79121 80122 8Ll7
Lo6/t3 106/22 LO8/5 LDglr2 t2LlLL 725123 L38lL6 L67lLO rvid€ntly l3l 94/5 279123
109/10 109/11 LoglL8 17512 t98123 2201t3
t87lr9 L87122 L8817 LSA/LL enaure [1] 238174 rractly [13] 23/7 27lLS LLO/22
L8e/2O L8916 te}lrs Leo/23 enletl [lI 155/5 tzoltL L'O/L8 L9219
tso/24 1e{/6 1es/8 L9613 2O6/2s antire [6] 7.12 L3U25 2L3122 20912 2221e 22sll9
Ls}ltg '-3217
207/L8 2OtlZS 2L2lL5 2trlLo 2L5123 2t6122 2L7124 2341L1 240l1.o
2t5ts 22223 22218 222lLr enttrety l1t 72Alt2 rxan [1] l4lL2
e-aailr [{1 97120 tLo/e L7Ol2o entitled [2] 138122 L78lLs rranlnation [28] LZILL LOLI?O
L27173 i enviolon [1] 716 LOLI2L ltt/2L tlt/22 LL2l7
eaeh [5t ?319 33lLB 441L2 L2Ol2 envisioned [1] 6lL4 Lr2lt2 LL2|L3 LL3|2O Ll.slL3
:-2:-l2 i equivalent [1] 23612 Llglt' L26/t2 L3Ll23 L32lto
eer [1] lfBlLL erroneoua [1t L96lLg L{3/2L t5319 Ls3/9 L56l2S
earlier [lQl 42/5 67/24 86124 error [4] 67/2 !O1|LL L71lL6 r6olL2 L'LlLt 161/13 L6Ll16
LL2l2 725t21 1{e./10 L59lL3 2081s L6211 L74lL1 1?s./10 r?sllo
L8O/8 78rL2 208/2r egpectelly [2] 2712e 55123 239/12 2ltlts
oarly [5] itsls tozls L3L|L' esQurnE lrl Ll2O Llzt Ll2L Ll23 rxanine [1t 17/L7
L5O/21 LTQlZt tl2r tl21 L/2s rxaniaad [{l Ll/s 3218 60/rL
sagler tLt't 15417 esgentlally [3] LO1-/22 la1ltz tLsl2r
eastly [1t !L615 157 lLA rxarinl.ng [2] 6olL2 19117
Eartera I3f 7413 2L1/2A 228115 establish [2] 32125 3819 rxaaple I5l 291L9 6tl4 62125
easy [1] erlt2 establiahed [2] 4O/L9 L6tl4 LL5/20 772lto
effect asti tolL2 42lLS 62lLs et t2l t8l4 ro7l22 axenpler [1] ltSI2S
521t7 21219 etlrtcally [1] 631L2 oncept l1t L23lL9
€ffectiTe I1t L'ltg ctlrLcr IlI 2319 axceptl-on [1t L24lL4
off,tcionrri [1] 7716 evaluete [1t sal2o rxclrange l2l 6713 236117
effort t6t' 5{/1{ ll2/21 L1318 evalueting [1] lL2ltg Excludo [1] L6t/8
!191L9 1s0/r3 L86l2t evaluatlon [1I 6616 arcrrced l2l 21Ll2O 24215
erfortg [2i 5rl2 e9l2, even [1?t 2813 29/L8 34124 36/7 axecutive [1] 94123
eight 12! JtllLS r$16 3618 47/L3 48/16 65123 8616 Exercige [2] 20212 230125
either t12l L5l3 32121 S8l9 1OO/10 LO2l5 tt8lL$ t?'lLL exerciged [1] 72120
77ltr Lto'lg L4.lL9 t6ol23 tsslL3 2t6ls 229/Lo 2321t4 arlriJcit t62l tlle LLI?O Lgll0
L6L/ts t7L/5 2L4122 2t9lLO event [9] 2614 27lLl 48125 LglLr LglLe 2Ol2 2ols 20lLo
76119 87lls t49lt3 L52/2 2Osl2O gslL6 35lLe 33124 36120 36123
2Lslt:- i 36124 381t5 38lLs 40123 a2121
elect llt it6lL9 2LSlLt
13123 7OlL5 71123 e6l8 97ls
el.ected [1] l6lLO eventc [4t L8lL2 2sl2o 64ls
eLectlon [8] 8l2O L6//7 L7120 73123 Lo4lt3 LO5l7 LO6lLs tO?lL6
L7l2S sSl{L r73le 2Lel3 2'-el8 eventually [2] 2}Sltl 22914 108/11 108/1{ r30l9 7331L6
olectionr i2t 3lt2 L97/23 ever [3?l glLO 1r/25 50122 t38lr L38l2o 1{?/16 151/11
€lectronicl[{l 36ls 36/8 LsolS 6tlLr 62lrs 6212a $13 61120 t5218 L5512 Lss/1 L58/8 LSSILL
L78/23 i 6slL6 79/L6 89/2s LO6l3 Lr-11L2 159/18 t6613 L66/7 L69/4 r69lLO
eleaent [11 l6Ll2 LLelz rLglto L2r/Ls tls/23 L7Ol6 L?3lre 77514
erenenta ltl 6219 e2lLa 76312 t64lr1 t6u2L 161122 '73ll9 179/L1
L76l2s t77lr n9/a3
e].ra l12t l3OlL9 3Ll2 at.l4 l9l1 !6s16 a66lr3 t66/t6 L68/5 L19l2s La?lL5 L97/24 L9815
7s125 L66lt7 7e7ls 20016 22411 L7s/L6 L82/L3 t96/25 20L123 tss/Lt 2}elLt 2LSl7 2tel6
23716 2s71.9 238lLS 206122 2L1/L7 2L8l/s 2t8/25 2\glt2
enbarraaaifig l1t 100/t5 29312 2s517 24,l2r 210125 exhj.blted[1] LL4l25
e-erqency t2J L5l1 LEltL every [16] llLL rclLA 73/L4 exhibita [2] L1./16 LO3l3
erployee [it 7617 Trli ,J113 t37lL3 L48le L84/2o exist [2] l0/le 2?4/15
euployeea [1] 7elt4 2Ot/Ls 2}tlLs 2oL/22 2oL/23 exlgrod I3l sslLt t29/3 23412
encourage t2l 8111 227/LL 2O5/A 2O5lL3 2O5/L3 20612r exigtonce 161 331L4 5l/25 128/6
encourrEea [1t 8612L everydcody [6] Sltl 64123 12/4 L2816 2O4/Lo 23412L
encouraging [1t 22717 771L2 11/24 861L6 exisrlng [2] 5124 7/4
end [?t 94L7 Lsls 4il2o 61121 Everybocly'a [1] 2016 oriats [10] LOILI 821L4 86/2
f
fairly [1f LtglL0 L22/23 L23/20 L23/2s 724/LS
E faith [2] 20717 2OS/L9 L24123 L2'|LO L74lr5 t74/2t
exicte. ,. 171 L56/Lg L8319 fall [2] t7/s 88/6 L8t/L9 L82/8 L82/24 L83/8
203122 204/3 204/3 204/a 2O4ltL falllng [1] LAe/25 LS3lL1 Le6/8 793/70 7ss/s
exPect a3ti. 12514 L25/8 2}glg falk [1] 161/10 2Oo/23 2OL|IO z0tllg 202/7
e4rected [{l 7912 L2Ol7 L24ltO Fame [1] 2Ll3 204122 20r/23 205/4 2Asl20
L24lt3 i faailLrr [17] A1l2 l39lL2 2t7ltg 22815 229/LO 230/5 23016
expediencZl: IZI rglg 20/79 1,52/L7 152/23 tS2l2. L6619 230/7 23OlL7 230/25 23L/4 23812
experience- [?l 561L7 65123 t66lL2 r17l'8 L9816 L98/2L 23818 2a,l22
LLSI0 tt6l8 23LlL7 23L/LS 198122 t9el22 2t8l'-5 23L124 flgrrre I?l S7 19 't213 LO3l6
233/20 | 23211 232lLL 23113 169118 L72125 L7312 2O4lL6
el1)arlencoe [2] ,L6/g 231/23 faniliarlze [1] L25lLs figrured [{l 97/L9 t24l2o L14/3
.xp€rt tlll 150/8 fanily [1] 7ell2 204/L6
ercpletn [l6t 2slLs 13121 85lto fer [2] 65/L6 8718 fisrurtng [2] 721L7 LgolL?
149/20 L$b/tr 208/25 farhlon lrtl 4O/9 {OILO 74lt$ sile [9] Lotl23 LL6/L4 LL1/L\
'5812
2oe/25 zLrlLr 2341L6 82178 LL1lLz t73lt3 22'tlll 232120
e:pletned l{l 85/Lo Lzolto father [1I l34llL 233/tO 235/6
206121 237/7 fault [3I 2Lll3 2LL/4 2LAl8 fired t10l 6lLB 4213 9LlL2
o<plaininE [rt] 39lt0 92lls fevor [5t 4s/2r 7712L 92123 2281t3 22al7s 22915 22e17
es/23 1221.6 tL2l2r L50l2L 230/74 23OlLr 2351t3
e:rpranatiori [2t 3A/5 Lzol6 f,avorable [1] $elLs files [1] L97/L7
e:pltcit If,l 8rlL2 fax [1] 7516 fillng tll 82124
ercplicltlyi tll 24L14 faxed [2] 7216 L9616 f,tllngs [1] 236/10
erlrlod€d [1] 93/L9 faxer [lt 72/LO fil].ed tll t6l20
rr<1rlore [11 91 123 faxing [1] 721L6 ftnal [10] 9l2t stlL6 6312L
expoaed [11. 115/10 f,ear [3t gll2o 20218 2I6lL3 L3614 L36/s L38/72 L94/22 2L419
rebruary f9l LltL 59/7 7t/18 2L'lrO 2{Llr4
expound t3l1 8rlr9 2r6lL2 2t7122 LOO|2} L28lL2 2a319 2O7lLO finall.zation [11 9112
express [2[] 21617 23a123 20ell5 2281L4 flnarly tlt e2/2O
ertenaive [2t 55ln 5el6 s€bruaaf, 17th I2l Ttl'â 20319 find t20l 2e122 29121 46/Ls
errenaivelf [tl tl6ll EEDEIT t?l LlzL 514 1612s 6s123 rTls s5ll2 6Ll5 80124 8LlL3
extent t1t; 31/5 Lo2l20 7321L6 tgllLr s7l2o e(lLs LLO/|1 116/13
orrort aTti'e7lL3
228124 f,ederal [4] 7ll3 9417 23'.ll3 t2oll6 r62lL3 2O3lL3 20615
ertra [lt 2351L5 2O6|LO 2L8l2L 2341L9 238120
exlrajudiciaf t2l eTll 237lLB fee [2t 2o2lL6 zL'-l'.g f,inding [1I L7315
extraordLntry tlt 5915 feel [6I TlLr Lollg 201L3 331L9 findlnga [1I 821L2
extraae [1], 281L9 3312s 237|s flnda t2l 116/13 2o3l2L
ewag I2l 2O/7 lj.sl23 fe].lor [2I 22/23 96/24 fine t3l 3713 73312L Lg6lL7
f,elonioua [1] 57121 fingernaiLa [2] 3ol3 3Ol4
F felony [2] 5812 SBILO flngerprint [1] 52/25
F.B.r 11l r1?/5 f,elt t11l 6/22 Srlls 92/L1 f,:Lnserpriats t{l 6L/5 6Ll6 67/e
fece [3] 56/5 56/5 8L/2t LOOlzs 198/10 2l7l2o 2321t6 6L/8
face-to-fa{e [1] SGIS 23r/LS 235/8 235lLO 23S|LL finiah [3] LL4l6 L2317 L23/8
Facebook t3l L76l7L L8Ol7 Lstl7 Fenan [??l 3123 3/2s 4/7 419 fjnlrhad [3] 3319 LS2/2L 2O3lL2
facie t1l llo/rs 2slL3 s9/2 67123 6816 7Ll2r fire [1] tslL2
facr [53I te/z ulzs t6lt3 LTls 80//6 86/25 e0174 eol2L 951L7 fila t2l 3lL9 2012
Ls/2L 2tll6 221L2 221L8 2612 s6/7 96lLe e7lrj eell selLs fl-rst [?71 LOl22 L3124 Lrl3
331L5 38lrs l}lLe 4217 47/t7 tos/r6 ao4n LArls ro4l7 ,041L2 trl( L5lL4 L6l6 L6lLs L6123
solLT 551i6 5815 S8l9 61119 :04124 1Os/10 LO5/5 toallt r716 L7l8 LTlrO aelz t8l6 Le/1
6212 6slLr 66/s 75/22 nlLT 106/1{ ta6l23 108/13 110/s 2Ll7L zrl\s 2515 25/6 251L2
8Ol2O 8Ol2O suLO e3lt8 86120 trolg Lto/Lo t:.ol2L L1olzs 2912 3O/5 3u5 3513 44123 44124
81t2L 8818 ellr eL/8 rool7 L1513 L8r/L1 185/9 18s/15 5416 5e/2 67122 6712s 6el5
!or/22 LO6/4 LL713 L2O|L9 L33/4 L85l2L ].8614 Ls6lLo t87l2o 7L123 1t/24 75116 78/2s
737|L1 L49125 L56l2S t6Ll20 L87125 L8glL6 189/11 189/1s 86125 961L4 97125 rOOl22'aoll5
:-L?l2r
\?L|LL L73/2L L75123 L9Ll?2 189/r8 LgO/L4 tgll9 LgLlrr LL'4L2 t2slt'3 t28122 1.3sl2t
19s/3 195/e L97lte 2o4l2r 2L214 ts2l3 192/t9 tgzlLe L92122 L3612 !3613 Lr8/75 L6OtrA L7sl2
229/3 9 1s3ll7 L95/LL t95l2t L97le L76lLr 71712r r'LlL? L8Ll22
factor a2l' s]-l' 6013 1971L8 2o713 20814 2,alzo t8rl24 t82lL2 lerltL L81lL7
factota [6t. 1{9/U L49ll3 2OslL9 2tolLo 2Ltl2t 2L2lL9 18s/8 185/16 ts6lr LeL/L2 t9314
Lso/zo 1s{/19 L5tl24 L5213 2t312 213/9 2L3ll8 2L3/22 19s/10 L98l2s 2OslL1 20713
factc [1] :82llg 213125 2L4/22 2221A 22412L 2O7lL7 2011t8 2oel2 20813 2Ltl7
fade tll t4412 22A123 21L18 2r].l11 21rl10 220122
feil. [lJ Q,2/16 Feroanf a [3t LO7 lL9 10917 233lro 233/L2
failed a2ll t59lr'2 205l2s 208/20 firnthand [3] TglLL 79/3 7917
fellure [3l 861L9 tlgltL LSL|21 f,er tSl 2ol!9 128122 L69ll3 ftt I2l 23/L2 83114
falr [25] I9lL2 28125 661L7 t7r/2? t97lt{ five t3l 2315 2315 70219
7s/2s $120 8e120 to3/L8 103/19 fibers lll 2919 flaah t2l L2l3 t2l4
tosl1f LL6/r2 LL6/20 L26/25 Field t1l 2s/6 f,lat [1] L31121
L27/23 138/13 138/16 t39l2r Flfth t53l 6417 61120 6511 fl-ettorlng [2] 8614 LS6|2O
LLzlLs Lsiltz L72/6 L76/e 6312L 661L2 67lLL 671r3 68lLO ;fllp t1l LtLl2
LTslLe r1gl2o L8L(2L t9o/1 sL/1 ssl2 99/t2 99lLB LOolT ,ftorr t1l L$4/LB
2391L9 r LL7lL' Lt7/22 118/3 118/15 leocuc ttl 4g/L9
I
F
2Ll8 33/78 56/L3 72125 82/L7 421L8 r3/7 4415 4rlL4 46/6 46/7
86/6 t82lt7 4618 47/2L rele 4elL8 5O/B ssls
lrorror a71? 71r,2 42/23 LoL/t4 s€norrlly [6] 85/16 8917 ll5l9 56124 S6/2s62/3 6213 6212L
I tte/tt Ls6l3 t66lt1 239lrr t3LlLS L43123 786/20
genente [1] 55121
62/23 6s/2 65/3 66/2t 6S/7
68/13 70/t2 70123 7212 72/6
lfouov€d [7] 5/12 slLS 27/3
I sala 9L/s sLlTL 18el1s generated [lt LO6/4 72/11 8L/\9 82/e 84/8 e4/Ls
lrolloviug [.5] S/2 46/23 69/2t gonaration [1] S5l3 ss/9 87/ts 88/11 9L/6 96/12
I Lo2/L8 t32/Lr L8719 set t53) 5/2o 816 tLlg L{I2S LOO/6 70tl8 Lo2l4 LO3l7 LO3/2O
follovr [2] LlLg LLl6 2911.8 37/2L 331L2 3e122 42/2r LLO/!1 110/19 Lr3/2L LL1l2o
Fondllng [3] 2/10 L3O/8 L33/3 6r/LO 6tlL. 6L/25 62lLs 62/23 LL8l2 tL8/L5 118./15 tL9lL6
f,oollsh [1] 15{/5 6313 72/8 7516 751a6 82ls 8315 L2rl22 130/11 130,/16 L3Ol25
force [1] i155/23 871L2 LOO/L6 LoL/23 r]-o/6 LL2/8 t3Llt7 L3t/22 L31,l2S 133/13
forcing fli 9913 l13l2l LLrlLr lLslLT L2Ll20 t33124 L34lt2 L36122 13811
foreaoat [1t 96lLl t3617 73619 L4215 L5O|L? 151./13 L38lt9 1{0/13 t40lL9 t40122
foronaic [7] 28lLg 29/8 29llg 152/t t53lL9 156./9 159/15 L{tllg L4215 L43/25 Ltr/24
4ll2t 1113 67/t6 LLSll2 L6L|2O L7919 re0l7 t9ol8 t94lr L45lr La6l2t Lrzlts L4elL3
forenelcc [1! 28125 tgrlr t9419 205/L4 2LAl2s L.8lt4 L49/4 L't/6 L'zlt]- L5412
forever [2i t'2412 2eO/2L 27812s 2321L2 232116 23312 Lsrl|g 1ss/tl LsglL? L63/6
forf.irure$ t1l 233120 23'ls 238lLL L6318 t63/2L L63/2r L6916 L1211
forgotten [2] 9816 79L/L3 Serc t8t 95/3 971t9 t12/L6 t72l2o L12122 l13lL3 L73lL4
foro t3l ql24 20sl1 2381L2 L13123 L1417 t4rl20 168/10 L7AltO L79l2t LsOlS LBO/22
for:ual rcl: 112? 41 ll0 66123 233lLS LBL|L{ L8214 L'aAl2L L6rl23
forued l]-l t a26lLQ pttLng J?! 3OlLo 391L2 s7175 rlsllz Ls€lzr t86lt8 rs?l4
fomer t|ri 271t6 l9lr} 5512 6s/L5 e2/2L t2olLs zr2lLo 193/1{ 193/rs Ls{lLs LgSl4
7616 t 3rBBoNS t1ll Ll2t 514 46125 L9914 L99/6 2O4lL7 2061t6
forrh l1l is{/? 69123 t|2l2o L32lL6 L87lrl 2O7ltl 2O9/S 2O9/L4 zLLlL1
foruo tst istltt 33124 3413 19819 20L/7 2o1lL9 2O7l2t 2LLl23 2l2lLr 2L3lr 2L1/e
3rlLL 3el|4 erBBo[s-FEDEn ]?l LlzL 514 2L4l2o 2tBlLL 228125 23t179
torrrrd [1?] sol!z s8l2o 631L9 4612s 6e123 L02120 L32lL6 23rlL1 238/L5 239/2
nle 8r/si84/L2 86/23 8elL8 L87 lLL sone [?t 8/L3 60170 62/13
gL/L1 96lt tLslr L5s/L2 Lsllt2 slve I21l 9/rB LOl2o L2l2L Lo3llo L23|LL 27412 228/9
22tl2a 2241s 2291L3 2361t4 2olLo 341t6 4219 a.l6 64/9 good 116I sls t2/t3 L2/L4 7314
2a2/2L t 68125 7L122 9rl7 L0L/L? tt3l22 t3l5 2Ol7 85lLs to2l2 LLtl2A
forrarded [1] 80/16 7251L9 155123 2O2ltO 20{lt9 tltlzs Lllls lL1/7 LLI|LO
found [?l &29lLL 55/8 L4618 22O/Lr 22718 227lLt 233116 tLglzl 116/Lr LsLls
20418 2L812 2791L8 2L9/re siven [19] 3l/L6 39125 47lLg Google [1] Lool2t
f,oundattonl[31 3614 38/9 Lltll 48n2 4elL3 A8l2L 6L120 8LlL2 sot t15t 251L2 28122 3Ol5 3619
foundationel [1] 766122 8412L s4l9 Lt5/L7 127/LL 13s/1tl 3A|LL 60124 62l:-0 7tl3 91175
f,our [3] 23/2 23/22 L6411 1,451s Lr6lL2 t'5rl23 L83/t3 1.40l2r t43l2L Le3lL2 L9616
fourth t2l't LSI42L t63lLO 202lLt 2t6lr4 225/20 23816
frane [2] ':tZaltl tTZlg Itvlng [22] 9212 92le LL9l7 sorren [3] 43/tL t9117 22512L
frenkry t3i 32/6 67/9 L9O/2 r29/L3 L37125 tr1l23 L4a/20 goverau€nt [5] ZLILO 55ll 921L9
free [{t 2!lt3 2251L4 238/9 74912L t63/L8 16{/ls t61124 96121 2L4lL8
24L125 l, 76slL7 16s/19 L6812 L68i3 L6e/s governor [2t 76lLA L6l2O
rresuentlyl[2I LL6|L2 tt6/2s L68|LS L7019 L73lS L73122 gtaduation [1] Lllg
frtendly [1] 2llS 2a2/L9 205114 srand [2] t5125 22114
friendc [3j 5418 181L2 t23lL1 gLadly tll t79/5 grant [3] 23/t3 231/L4 235lLs
f,ronr [19] L2lL8 62/1 t33127 so t6sl glLi ttl]-o L2/2 L8123 srented [3] 221L3 z3]-lLl 24LlS
139/19 t42/Lr Ls3l23 L5513 2Ol5 28lLO 28lLL 2en4 30123 grantlng [2] 2212A 236/6
Ls6lr6 L56177 L62lL4 ]-6317 351L8 35124 4s122 4618 461L4 grants [lt 21121
L63/22 1S6/13 t9217 L94124 46/L5 491L8 54/Ls s4ll6 srlzo greac [9] S2l8 561L1 56122
rssl22 Lsltt( 209/15 233lLL 5sl7 551L2 5912L 631L9 68/20 72120 75120 9212 LOLIL6 lL9l22
fult t2l \4lLS L4glra 6A124 731'.8 7517 751!6 751L8 20elL9
furr-rbe Ill Lll]s 9llLt 55122 s5/2o e6l3 e713 greater [5] 73lLL eU2l 8617
^1L3/LG L3419 t4Ll24 \oL/22 Lo2l3 LOS|LO LI?|LL t2313 Lz3lto
fully [4I
24415 i 7Lrl6 LL6l3 LLsl[ L3L/Le t3u23 grlevaneea [lt 87lLO
further [9] 23lLO 19123 78120 13s/s 13S/16 1{1/9 tl$lL]- Lr9l4 group [2] 2217 23lLo
Lo6l7 Lt'-l2o 1{9/10 2t5120 L1slzl Ls5l23 Ls7lL2 L6316 groupr [3] 2213 2214 t2AlLz
2L7l2L 2211L7 L63l2a t83l2t t86ll9 Le2/23 grors [1I 29123
E\rrtharaorg [1] l2LlL? 209/24 2LLl1 2lile 2telL3 22514 guaranteed [1] 9125
futur€ tst: 6/13 2L315 2L3lL7 22glt9 229/25 230124 23Ll2L gruegr [8] 67118 Lt3l8 t27 19
2L4124 2291L4 234lts 2351L3 2351L4 24Ll2s L43lL6 L43lt6 L4sl3 l43l2l
soat [{l 771r7 7815 83/t{ 87120 242fLr
G
soer [5] 9ll5 zBlLr 29170 84llg guersing [1] 1{3/19
guilty [1I 2tl2l
sal.n l2l 6414 LLSIL2 t2L/Lt
gether t2l: all2 55125 qoing [150] 615 Lo/2/ LLIL6 Suys t{t 8t/2t Lr9l20 176/1s
sarhcred tjl 2519 t2L/L9 22312L L2/ts L2lL9 L4l6 ,'619 L6l9 181/5
save [16] sZzls salt 62/25 9216 25/L6 26124 28/20 29ll,t 29/L3 H
tt4l24 LLllz LLeILL L2417 t2113 30lL6 30123 3Lltr 3Llt9 3214 habeas t8l ll8 5123 616 6lLB
t73ll6 226/22 226123 2271L2 92/LL s2lr6 3212L 32123 33/9
22812 zr'lL2 2$/L3 33/20 3517 361L3 36120 36125 I etzz 6/2r s/3 sl2s
seneral (10I 6l2t 8l2O 2Ll6 37|LL 371\2 AOILL 4rla 42le lrr"a terrt s/2L tr/L2 L4/2o
I
94/S Lo6l3 Loel2L LLSl2t Lr'/8 204/22 2O5l2O 205/2L 2os/22
L62/L9 L63/L6 L76l2L te6/23 2L5/73 217/r 2L7/13 2L1lr8
.,. a20q1 L4/2L LSIL6 L6ILL 19712 22L/22 230/24 2L7/23 2L9/3 219/22 2L9/22
L5124 22ltr 22/21 2sl5 261L4 , t2) LO3/2L L26/Lo 22t/2L 226/22 226/24 226/2s
2elle 3ol2 3ol7 3O/2L 321t4 t3! 2817 37122 38/7 2211L2 22sle 23017 23017 23018
AOls 4olLi rt/2L 42/8 43/tO t1l L62/75 23OlL6 23L/Lr 23Ll2O 235/2t
43llr $/L3 r3lLe r3he 45/7 tfl 56lto 36ltt 67lLO 235122 2371t9 231/25 238/L2
4715 18/2t [e/s SOl6 SL|S s2lS 235123 2rLl3
s3lt9 53/L9 s3/24 5rl2s 561t7 rdly [1] Ls/r1 herll [1] 161/19
s6/2t s7ltg s7/20 5816 38le c I55l slLo slLL elLG IL|LL he'a [35] 3012L 30/23 $lA $18
38/L8 s8/2t 39/6 59/10 selLO L7lt8 73114 2Lls 23/7 23/8 3r/72 4Ll2 rsl2 45/L6 45/t1
59/LL 591t7 6L/L9 6L/20 6L/23 3OlrL 36/24 3e/8 3el9 4r/25 46/tL 46/L2 46lLs 1olLO ss/4
62/4 62/t3 61124 6519 6s/L8 $/v $19 491L2 s2/9gsls 64/23 e3/3 toot6 LL3/2L L32/8 L34/12
65/23 66/1 66120 66/24 67/24 6116 75/L3 77lS 7819 L39/L9 L4t/L4 L43/2O 7r3/2t
67125 67/25 71125 7213 72lLL LL?l2O LlO/25 L3rlr-L L36la8 ,,43/21 Ll6l2L 153,/1 159/1s
7r18 7utt, 141L4 76lg 76lle L38l2O l4llle L43/22 151/10 t60/2t L67/LL 161./13 202/3
75/23 79/22 8Ol2 eDlt3 8o/L4 ts9/21 16rlL7 L66/r8 L7911 2O2/6 20216 22719 235/17 21L/24
8OlL4 00120 9L/LL s3/24 srlLo 183/\3 !93/8 L99/5 zoLlLS 202/3 tll t7L/L8
85/73 Ssl+e 87125 87n3 Asl3 20s15 20612L 20e/L9 2L6/L9 l?l L33/s r47120
88/12 89179 90/23 9L/5 9LILO 225/Lt 22slL2 230121 23Llr8 L52lL5 L52lL6 153./1{ Ls3/2O
9L/r7 eLl\6 92/LO 92/19 e3ls 23LlL9 2e2/s 23rlLo 2341L7 L66/L8
slts sr/r4 s4lrr ssl6 9s/e eslg 2s4lt2 23ll1s l1l L3el2s
sstrs s7li5 ssl2 Loo/2 1oo/1il 'r [sl 3ls L37lL3 L26/t6 tll LS3le
LOol23 LOil2A 103/e 103/10 t76123 778/t6 r I15I 817 $/L6 t2l2L a2/24
LOsl2O 106/6 1o?/8 L07/2O r08l2 Ie l1l 9O/7 33121 4r/22 r5lL7 5ell9 74/8
108/{ lOSr2s LOs/2 LOslL2 ve 12111 74/to rL3l2O L29/23 t34lL2
LOs/7r LO|l2s ALO|a3 LLO|23 venft [5t tOI12 t29l2s L3r/2O L34/tl L35l2L 2421L7
rt2ltr Lt2l2o aL'l4 tLslzo Lr3l5 Ll6/L2 rd t12l slLL 62121 6412L
11?/18 118/13 r2OtLO Lz3lLt havtng t12l aOlS tlll L6laB lrls LLslL| L'el4 L5914 t66lt6
L26/9 L27lro L2el2 L2el2s L3rl4 28/Ls 741L1 9Ll2r r3tl5 L3slLa L|sl2O 2O7lLl 2O7ll8 2271L9
r37/L3 t3?l2, L35122 L36/8 153/11 L72123 L8315 2061L6 hearlnE [22] 3/14 6/L8 6/25
138/8 Lrtlrr 1-43/7 Ll'lg L4Sl22 inc [1] S9lL7 6l2s 716 8lL6 el'-e e/24 Lols
rr1t3 Laslg LsTl':o L6olL8 t2r?l 2122 LLI?L l5/t4 ,,51L4 LOl6 tDlg L}lLo 3Ll6 StlLO
r6L/L6 $a/e l:olLs L7t/r9 tsle L6lLt L6lL3 !61L9 2518 3LltL 1617 rglle e2l3 L2L/L8
L7414 L75Ir2 LTslLT L75l2O 27ls 3OlL6 SolLe 3o/2L 30122 L26122 2LSl5 2rtl24
Llsl2! L1sl2L L18lL0 t18lr3 31/18 31/18 3tlLs 3212 32lLt hearJ.ngs [lt L2lltg
L78178 t8O/20 tgLlt'- r8LlL6 321L1 32lLr 32lLs 321t9 32124 hearcay lal lU1 {1I!! 7914
rcLlzs Llil:-3 Lells L89ls Leol6 32124 32125 3312 33/2 33/LS 7916
LsL/s L$I2L Ls6t22 ts?tr 202/2 33/rs 33lLS SrlLO 3sl4 35/s heaac [1I 9/L4
2O2/2L 20hl8 20111 2Og/L6 36116 361L7 36124 31/2 3S/8 hech [1] 87/21
2t2123 2Ltltt 2t3l'-9 2t3/25 4O/5 1016 4011,4 4O/L5 4Ll2 rLl2 heed [1] 73/21
2L412 2L4ln 2L6123 2771L6 lll2L 4L122 42ls 12/7 42/L9 held tsl L8l9 46120 s6lls 69/LB
2231L3 224/5 22416 224125 22512 42/2r 15124 4612 1716 491!0 7021ts
22sl2L 22i122 22sl2r 226/t7 4sll2 191L3 491L4 A9lt4 49115 hslp t3l T|lrs t34ll-3 L7ol4
2211L3 2261s 22817e 22elLo 4e124 3Ol2 5016 sL/x 521L2 her.ped[2t 56120 7115
229117 2291L8 23OlL3 23512L s2lt6 53123 53123 5112 s4lr helpf,ul [1] 109/8
236/e 2361'-0 236176 2361L6 5417 5419 srl'-s 5512 sslle hence [1I LBLI(
237122 i s8/21 Sel27 64lLe 651L3 63125 her [93] 2417 2rlLL 2Al4 48123
adn't [2]) 81123 233/L2 6s125 66/19 6714 6115 6717 6118 s4lt3 s8/9 62/2 62/2 6214 67123
air t5l lsln zslzz zelzs 7Lllr 81125 9olr2 9Ll6 eL/8 6813 6s/4 76/6 76le 161L3 771L8
2s/25 30lI sllt3 92124 esl10 loo/3 1oo/8 19125 8015 83124 8312s 8al2
dr! Ilt [2919 1Oo/1O LOOlt2 tool23 Lool2r 841L7 831L2 861L1 861L5 9512L
a1f tSI iTrltt t]^'ltt LLsl2o to9l2 t09lt3 LoglzL LL3|L6 s5t23 9s/24 e6lL9 96125 to5lL2
t86lLe 20617 ,,Lelz LLg/s 11el10 11e/11 106/11 togle rLolT LtolT Lt2lts
arr [1] ?U3 7L9lL2 L2316 L26l2o L26/2L tL3lLO t!-rlL6 115/'1 115/10
aspoted [: 85174 L2815 t2819 t2Bl20 L28120 115/1s 11s/18 11s/19 LL3l22
end [11] igtltt 91/L8 L33/3 t3o/L7 L30l2S 131/10 L37lL3 t29123 t29121 13{/18 13{/19
L38/7 L38'Il9 t47l]-g LszlLL 131/1s L31122 L34124 t36ll9 L35122 t33122 14818 Llell?
L9r/21 L96ls L9814 ztelLL L3sl20 11216 Le2/6 L4216 142l]-6 L5712 L5112 LsllLO 15?/11
end-delivdrad t3l 971L7 97/Lg Lr3l22 Lr3l22 LA4l3 14414 L1116 1s?/1s LSTne $814 L76lL3
Ls6lS i L4rt6 lrll6 tr4l7 L44l2o t4al22 LALIL2 LBL/L2 18u19 tau2L
11t 88/2L 1rt5./15 1{5./15 L46122 L48l16 L''|LL L85lL2 LBslL3
t{t 130/1s L3O/L? t3317 160/18 L6O/23 L6ol24 L6Ll5 138/5 r8e/s tee/L2 t'92/23
'861s L9317
t 1tl20 i t-6L16 t6Llr2 L6,.lr6 L6Llt7 1"93122 19{/10 Lgell? L9716
handins l2l 158/tO 11713 r6LlL8 L6L/7e L62/1 162/5 L62ls 2OLl8 2ozlts 20716 207/7 2O'r18
Le l]-l) L32/3 t66/2 L66/2o L67/5 L67/9 t67lLe 2o7lt3 208/LO 2O8l2O 208122
Ied t3[ 6lt3 6lL4 4119 t67lts 168/10 L69l2r L69125 208125 209/3 20elr 2L3lL2
s lLI i.L49l6 1?o/10 t74l2L L7{-123 L1slL6 2251L6 228124 236ltL
tloi r{125 28116 8rl7 L75l2L L79/7 L7918 LB2l9 L8413 ls{I 7lt2 Ltlz2 LLl23 L2/s
88/9 9Ll2g 118,/s 118/10 19?/13 LS{IU L85/A t89124 L9rl3 L2lL8 2O/7 24/20 2512t 2912L
230123 23Qlt6 L99lt1 19e/10 2AolL3 2O2lr 3Ll2 32120 3sl2 AoltL 4ol2t
heppened []51 28lLS 48125 8{/1{ 20211 2O4lL7 zorlta 2o4l2L 40123 4Ll2r 42/L9 1518 46lLo
I
Issl 7/8 7/Le 8/ro 10/24 L55/22 t55/22 158/10 Lsg/L8
1L/1 L2/8 L2/e L9/s L9/12 20lLL L5918 L59/77 L6L/22 L62/9
... t6il r7l2L r9/7 rell ?L/s 26/L7 37/S 33/23 35/2s L62/74 L63/6 L63/8 763/2L 766/6
rglto 49/lo {eltB 5619 56lla 371L8 3812 3e/e 44/2\ 4e/4 L66l2L 167/L8 L69/5 772/2L
s9/23 6019 62/7 5212L 53/L3 66/L9 1ot9 7L/7 t73lL3 L73/L3 L7419 L75/22
68/22 1uq 7513 7s/9 15lLL 74120 9714 9717 LO3l2 LOA|L5 L7713 L79/17 L79/2L L8Ol5
85./10 88/10 e2/L9 9212L e3/t7 106/16 tO1lL( 1oB./15 128/22 186/19 t86122 18714 L92lt7
ssl2r 991t6 LOOI2O t,tlT L}tlg t3tlr L32122 L33lL2 L3712 19s/10 19811 L98/22 r9916
110/1s LL!/4 LLLILL rLt/\1 1,03./15 t6'l9 L6212 L6917 l69lLt L99l2s 2O3/L3 204/7 ?O'/LO
LL2l3 LL2/2{ 113/13 Lt6/4 LrBl6 185/19 2231L7 23O/23 23212 206/76 209/4 209/Lr 2o9/L8
tl9/2r L2Ol5 L2OILO L22/2L 232/6 23r/7 239lLO 2391L5 2La/19 2LO/23 2LllLL 2L2lL4
L3tl7 L37/L0 L39lt7 t43/24 24LlLo 24L/L6 24L/2O 243/2 2LA|1L 2LBlrt 22t/7 224/L9
L14/2r L5!./L7 L67lLA L67/L7 ! [1] 391L9 224120 225lto 227lLg 237/22
L59ll1 186./16 L86/2L t87/3 tl tll rltT 232ltL 232/12 233/25 233125
re2ll3 20QlL6 2L011 2t2/72 Irl 2212r 234119 231/19 234123 231/7
275lLL 2L7lZZ 2l8l7r 22013 t9l 8/L2 3LlLs 3tl2{ 60124 23715 24L122
2221L2 22t/13 23tlt6 23815 8112O L22lL9 1{s/10 145/10 I've l23l 6/t9 8/23 2Ol2L 37lrs
reby [1I . 24114 2121L8 3919 4112L 49/5 e3l2 LsA/6
rcelf I3I 2ll7 95/25 LL3l9 hoped t5l 6611 89/20 9LILO L36/tL 138./19 L4t/1 Lr1lLg
treritatron?I1l L4tl25 9t/L2 L56/9 L65/2L L6616 t66/L3 166/16
Eaaeler [?fi 89171 Llo/2 Lr2/!4 hopeful t1t gL/tS L7713 L79/76 t98/4 226/7 227lte
L44l1t 7441t6 L'elL3 768/L0 ly t1l tlolLa 23L122
hey [3] 1{0/19 Le0lz' 22sl'-6 t8t s/20 916 9lL5 2L/2L
hrsh t21 i5l3 S4l7 hoping [3t L2218 Lslllg 202lLr 771L9 L0sl8 1.8211.3 tg2l75
tifl.catlon [211I L9ILS 2013
highecr f3f' 22lS 221L3 2315 t{t 6e/4 L3L/L9 t6116
hrEhltshr tlt 79lts 186/19 3sll6 7OlL5 ',t,ll8 96/8 961L3
ighted [{l 162ll:- L9218 rrours [4t tLl24 72/19 roel24 Lo4/13 104/19 106l'-5 10612l
2ttl8 2t2lt6 270123 108./t{ 130/9 138/s L47116 Ls2/9
highly at.l | {7/7 ae [7] 22ls 22/6 22/L3 5Ll4 L5el8 t66/4 169/10 L73lr8
hiE t?21 il23 LLIIO 32/3 37/L6 63/2 L63lL5 22s13 L76/25 L79/Lr L97125 2Le12
38/7 3}ls;40llo 4tlL8 42lto hor [36] slzo 6lL2 70l2o L3l6 tiftod t2l L4\17 \s1f2
-et . J-a
42/LL r2ll2 1s123 4s/23 e6l'5 L3tL9 L7/7 L7lLz 2u2t 2312s f, t21sl 1/LO 7lt1 LOIL9 LOl27
s4lr7 6511 861L3 88121.93lLL 26120 271r2 271L3 28/23 39122 L2lL6 Lgle Lgle 2Ll2r 25124
98125 gslS eel1l 1oo/19 LOL12 47ts sotL2 6r/6 7213 1215 72lLs 27123 2712r 27124 28/e 28lt0
ro9/13 Lt1l22 Ltel? L2318 121L7 86ls 58123 r}ll7 115/1s 2919 291t9 291L9 2912L 29122
L24lL7 136/1s L3O|L} L3219 rt6l4 tLBl5 118/8 13s/6 L63lL6 2e124 3OlL4 l0lls 30123 3318
73117 L39118 L4tl]-r L46123 L7312 t90125 20015 207124 33/Lr 33/L9 3rlLO 3s/23 3612
L33/LO 1s{/11 160/18 LsolLe 2LSl24 23a/S 36/7 36/8 36110 361L3 35122
t6ol2s L74lL7 L14122 t8217 r 12: 80124 21219 36123 36123 3712 s7/L5 37lta
L88125 tgzllo t94l'-3 Er:bbeu [2] 2314 23lLL 39./16 {0./1s 4olL8 4Ll8 r\/Le
'39125206/2 220124 22L13
2ortto 2o1,/s I1t L37lL2 4212 r2/5 42/LO 41122 431t9
22:-l2r 221/7 227tLL 227lls rdlo l2l 2L314 23818 4618 49/L7 53122 s4ll0 5sl7
229/9 23012 23015 23L/to 23L120 rdler [2] LiO|L? Lizll s6lls s6123 571L1 57122 6Ll^
2321L5 2331L5 23'lt5 2381s t2l r7l4 L72lL6 641L3 61116 651L2 68120 7O/A
240122 2rL/3 21L/22 2au23 t2t L713 29le TOILA 7ol78 7Ll7 71/e 73/2t
21213 24213 t1e t1l 92/21 75/6 75/L6 7912 sLlLL e2h A2l8
tre t2l lzzltt L72124 8al5 suro 8rlL4 e5/7 8'lr3
! ttl LL3|2L s8/2O 8e/5 e6ltr e6/2s e713
[1oI LLl20 t3l9 s9l7 96110
t66l i2l7 32/8 32/L2 32./72 rd97/23 91lr roo13 roL/23 LO2ls LO2/9
36174 36/iL 3el\L 3ell1 42/2 lt?lLO L68/23 L86123 LO3l2 to3l9 Lo4lLa tos/3
12172 r2llt 43/6 491L3 49/25 198/11 2t2lt5 106/16 tO7/r3'o3lL[
108/10 108/16
5u2 s2l4E76lLO 84120 84120 I'l1 11{l 2O/9 231L9 2715 3313 LO9|2O tL3lr6 rL3l2s lL1/21
s7t7 sslzlsslL2 s9l2L tool'l 33tls 33125 8812r to3lrs Lo715 tL8/20 72316 1,24/6 L2sl25
7ool22 Loql23 Lr9l5 Lrgltt L37/7 t39/LO 160/11 L94l2O L27lrr 72915 t2el6 L29122 r30l3
LtelL2 72zl?3 L23l2o l,23123 2231L9 131/1s 13612 r36lL7 t36l2l
L24lL5 125/10 t4'-l24 76L|LL 1u [l3gt T|LL LO/t6 LLIL6 L36/23 1{0/13 LAA/S t16l2L
L6L/L9 r6i/23 L6L/23 a6211 L2lLs 2l/a 3Ll2 3Ll1 3tll3 Lt112 14716 L49lte 1so/18
L71|LS 18i/1e r8,2l1-o 786/8 321L5 321L7 3212L 32122 3314 r3tl23 tssls 755lLL t57/8 L5718
ts6l2r L9.g/s Lgelle 20olr4 3AlL2 tsl1 4ole 4ol2]- 4214 4317 t37lL9 Ls1l23 158/3 158/18
2OOl23 2OL|LO ?OL|L9 20217 44lL{ 4u22 4611 5ol5 60113 160le L60lLr t6Llt7 75L122
2A4123 221125 226lte 226123 70tL2 7Ll2 79lLO 8219 841L5 L6215 L52lt{t 166/13 7661t3
226123 22612s 227lLO 228/5 8616 8617 86le 861t2 e3lL6 L66lt6 166/16 t6el2l L6el25
23015 238'18 239lLs 21ole 2[olLs g6lL2 98ls lo2l4 1o3l8 to3l9 L6916 L69lL2 L70lr L7tl3
LO3lLl r0sl" Lo?16 11u16 L75/4 tj'lLg r7Sl2
L7'|LS L7419 ',691t3
24Ol2L i r78lt8 L79/L6 L80/4 180/22
old [8t bl'-e 6/24 LOls L2lL5 LL2lt2 tL3/L3 130/11 L3O/L6
sOlS LS3li. 2OOl2O 203/6 Lso/22 L3Ll8 L3L/71 t32l2s t82/23 L8316 L84lL{ 193/3
holdinE [5f 7l2l LolLo a33/3 L33/L3 L33124 L38/7 L38/t9 Ls3lL2 193/13 t9416 L96/6 L97/6
L3rlL3 24t123 t3s/s Llo/L6 1{O/19 tro/22 Ls7lL' L9816 L98120 199./5
oliday l3f e7/L6 971t6 Lo7l7 L4LlLs L43/L4 L.4/L3 L44/2r 2O3lL1 2O4/2o 2O4l2L 205/12
one [8] !t/z stlz 5Ll2 sll3 t{J/LA L48lt3 L18/L4 Lrglr 205123 2O7lL2 2LLl24 2L2/1L
stlr 16l1i 78lte e6lL1 LAs/4 L49/L7 15OlL6 1so/18 2L7l2O 2L8/2s 2L9l2O 22O/1L
onicide [3t 2tl',2 2LILG 2Ll2l LSI|L7 L52124 L53/1 Lsr/2 22Oltl 22IlL8 2221L7 223/4
!
94/L3 L8317 230lr0 232122
incriaination ltl] 9913 99/L3 intentj.onally t{l 96121 96/22
Lf,,... t2'.tli 223/s 224/6 2241L4 119/13 183,/8 98/23 L90/Lt
22412s 225lLt 225120 225/20 indecent [1] 224lLO intention€d [1] L57/S
226/3 226/L7 226/22 227/L2 independent [5] 27/L2 3O/L6 lntercepted [1] s7124
225/9 229/16 229/23 23o/L6 2061L7 226/3 232lLs intercepting [1] 57/LS
23Lls 232/16 2s312 23u2 2341L3 Lndicate l2l t0gl6 L8817 Lntorceptlona [2] 5619 5115
23r/20 23./25 231/A 81/2s lndicated [1{I 614 6lL9 TlLg lnterest 12l 5919 L26ltO
238/Lr 239/4 242112 e/24 23/Ls 3s/7A 3919 39/e 65/4 ntetected [1] tBr/20
t1I 80/rs 76122 L13/e L84lL6 cting 13l 20315 20615
illesal t3t 64lt1- 64/L2 8O/3 2391L7 '.79/2L 206lLL
rl:.esarrY f3l 57/24 79/23 indlcater [3] 758/L6 l5A/22 Interests l1l LSll4
L2L/L9 i L6rl5 intorjectlng [1] 45/3
tiiilii rri' LLtte t6e/rs indlcattng [1] t96lLg
lndicatlon [1] 29125
intern [2] L3122 LAILL
internationel [{l 3llLB 3llLg
trDBdiate Elt 189/9
tely t3l ro4l8 L7717 IndivLdual [rll 9/L6 t66124 62/!0 L59l1O
f L66/2s intarnet [6] 139/2 L4O/7 L[O/L2
'96123 l.Ct 1oo/18 zzelrl '€3ll2
tndivlduala [2] t7213 L7415 L[O/L? L4olt4 L6o/22
tlyf t1l 95/tg ' lnducted [1] 2L/Z inrerrupc ltll 8/7 92/20 93/Ll
ruuniry [{11 23Llt4 23L124 lnf,erenee [1] 77/Ll 131/10
23211 232/t7 23218 23219 232lLo Lnfinitely [1] 2LL/25 LntervenLng 11l tO9lL7
23114 23r'17 23118 23r19 23r/L2 lnfluence [1t 8113 inter:wler [19t 5OlL7 50/20
2341L4 ?3,9n ?3SlLr 23s/76 lnfo:cr [9] 671L9 7311 7316 sL/L2 sLlr6 110/16 tLs/rg t4213
235120 73512s 23sl2s 23612 130/13 r46lLL tsL/2t 186lr L58122 Ls9/8 L62/24 L68lLs
t92123 2371L9 L1ol4 L7Ol9 t?olL2 t73ls L73116
t1l L2o/2 inforaally [1] 6lL9 L73/23 L7412 2aL/6
npllcatioq [1] L23l2L Lnforuatloa [15t 2519 521L2 lnterviered [8] L3/21 51/9
Eporrancei[3] 28l]-g 32120 s6lL3 sslr 8ol2o B2ls 93123 5Ll2O 5tl2o sL/zL 5t/24 1to/11
571t3 I L2418 L28l2o 15{/18 189./13 L60124
interviering [2I 5L/8 sllLl
irPorranr i21l 8lL2 L0l4 35/8 193/18 t96/Lr 2LLl20 2L4/L7
4L/3 521ltr Ssl4 761L6 77lls inforaed [5] 38123 6617 66120 intervierc [13] 4Ll2O 4417
171L6 78.i. 941L9 LOe/5 tsr./to gLl5 L77lto 141t3 rrltl 47lLS sOlL6 5LlL1
LsTls L97|LL 2O6/t3 206/20 Inforalng [2I e7lL1 L5213 s2l9 L35lL4 L3919 z|2ltg 202179
205/21 20712 2O7124 22uL3 ingerted t1l 3Ol2 20511r
funportanili I1l 100/5 Lnhgrent [1] 571L3 lnto [22I 619 L9lL1 2712 2612L
iapoaed[1] 97le
i-apoaed initial t5l Lll]-r 381L9 L2718 3OILO 3L/2L 49/23 5r./1s 60/3
rnposatbleft3l 6LlL7 6llt7 L1tl6 LsLlLs 63/2 73/18 75123 86119 e3l2r
L4st6 I. nitiarly t2l L96lL6 to9l23 l2il23 L2112 7421s
n{t1: Losl2s initlated [1] '87121
5513 Ls0lLg r6tl20 2031L8 2L912
til 23L/2 lnky [1] L76lL2 introduce [1I tL2l4
l-uprove [2] 6313 LIO/LS innocent [2] t34123 L35/4 inundated [2] L4818 t68l]-9
iaproved [2] 6215 LS5/LS inordinate [1] 55122 te I5l 2512 3rl2a
bpugn alt , L6rl23 inpuc [1J LSlLg 5A124 89/2s 22tlL9
Iupugntng [1t rdLlll ror [9] L7616 r76ltl invertigated [1I 5{/f0
in [819] I L16lL9 LTglLO L78lt6 L8ol23 inveatigatins [{l LSl25
t8L/9 2L819 2L9/22 321L3 22115 "L172
n-canera [ll a6l'l
nabi]-ttY {21 1rl2 LL5/L2 rnquirer'a l1I L8O/L6 invertlg.tlon [31] 2l7o 24122
naccuraro([12! t29123 L34/2o tll L7sl23 2SlL3 26/LL 3212 34le 38122
13sl6 135{18 L3613 L35lL2 L3713 lclnt lsl L93l2O tgrlr1 431L2 s6l3 7sl2s 77ls s6l2 9018
L37lrL L3ilLl t37lte t42124 Lgrlre \e4/20 L9r/2L sols 90122 L27/L8 r28/2L t29/15
1e8/10 i inatance [5] 48121 6llt2 80125 L2el2o !?ols L33/6 L34lL5
inadnlasi-bfe [2] 7916 l2ll7 L77lL2 L83lL2 22819 L56lLe 183/1s te4lt3 2L912
lnappropriitaly t3l 7619 gollo nrtances [2] 62120 t60125 22OlL5 22LlL4 226lLO 2261L4
LL4l8 j instead l1l lTlLg 237 lzL
incapable [1] L8317 inrtructed [2] 15/11 188/5 investigattona [1] 161L2
rncidene [i3l 3/2O 351t5 s3lLs instructions [2] 7OLl72 toLll3 investigative [1I 39l1'g
541L1 s6l6 6OlL9 6LILS 181L2 inaufficlent [8] 6OlL7 821L3 inv€ltigatorl l,ll 7713 78120
1oelr6 Lr4/2L 2O1l2L 202123 L2Olr7 72Ol2O L6'rl7 203122 L2917 t2glLo
22L15 204/2 20419 investlgatory t1l 2916
incidancelly [2] 192122 2O2/Ls integtity [1] 2319 invitation [1] t?3lLO
include [2i 2Ll2l SOlLa Intel].J.gencor [{l 3lLO L96l2O 121 119/11 LL9|L2
included [?l L5917 LB8/2 L97l2r 207/22 ve [1] ISlr
including i6t 6213 ?7/4 77123 rntend [5t 6el2l 69lLr 841L9 ved [18! Lsl3 23lLs 21/2
781L2 L9tr23 rg2ltr 24219 242116 30/5 S4lL4 S7lL7 7713 7elr0
t9l
inconcistencter [9] l8l2o
l8l20 lSl
lsl22 lntended [3t 89lLi L2Ol2 2t7lt0 7s125 83lr1 t16l2o LL5l24 L29/e
18/24 4e/*2 491L5 19123 6Ll2O intendins [3t 4LlL5 t30l2o LTrls t9Ll23 2L4/23 23L16
LL4/23 LtSlLO t30122 240/L6
intenr [12] el9 61/Lr 61lLs 12l 3612 2L416
inconciateft [2] sLlLT 6L/22 volving [21
incorrect [1t L2{lLg 671L6 821L9 85lS t9tl22 Le2l2 9L122 24014
Ls2/9 Lg2lrl L92/t4 20512 rrelevant [21 L94178 t94l20
lncreaae [1t t7l2
incr€drbleflll 135/8 intention [?! 155./9 155/11 ts I{201
incririnatinE t5l 5tl3 S6ILA ls5/19 t',612 L5617 L56l2r isn,b [2] AOltL 23312t
JoSEPH [1I L/25 91/3 9sl15 t2O/L3 L2O/22 t2o/25
Journallrta [1] SlLO t7s/22 tS3l23 L9r/9 223/24
icsue [31] i e/s gla tol4 2l/7 I6l Ll6 LLlr L4/L4 52/6 [11.] 1lLL e/2 L8/72 Lsls
26/2L 28/?2 32120 3elLO 6Ll3 L34|LO tr2/2 2316 24/L3 2s/L6 25/23 26/L4
62/1 68lL'' 8L122 8613 LztlL3 judge I50l rlLT s/L3 8125 Ltlts 29/L7 29/23 3OILA 3L/L6 32/2L
t2L/L4 L2s/L9 Lzs/2t L26/22 L6/1 L6118 76119 L6l2t 3t/25 33/s s3/L7 3612s 3717 37lLS
73LlA rs6l20 L69lL2 3el6 4318 rel2l 68123 7o/L3 38/e 40lla 4L/3 47/L8 4r/79
'-2812 L78/6
r6e/16 ra'lt3 t8212 7Ll5 82/2 e4l6 9417 9slL8 96le 4Sl2 46lLL a7/2L 52122 52125
2OO(2L 2Li/2t 22,lt3 232/7 Lt1l22 118/15 12Ll2L t26/2o s2123 s3l' S3l3 531L2 sslLo
2.21L7 : L30/12 t43lL7 L45120 75013 69/7 12/1 73/76 751L7 76/24
j-ggusd lstt slzt 70/6 7LlL1 Ls3l2 L19/r Lggltg L9L/8 te2ltg lels 8olL9 8615 A8123 9512
7tlt7 1LlI9 tosl22 11e/16 L9316 201123 20s/3 205124 96125 971L7 98/s 1oo,/19 tOO/24
754125 20219 2O8l2O 2LOl22 zr2llD 2t2lr3 LO2la L$l2s LO5/2L LO6/3 ro8l2
!!u€! [?l i 616 L8/22 28/24 21312 23O/25 23L/3 23LlL2 lOe/S 110/3 tt3/2o LL5/23 LL1/7
92122 \L319 t7214 23118 23L/L9 233lt0 2351L5 2351L7 LL8/8 Lt'lLg LLgl6 L2O/L2
aauing lli \2ll1-o 24213 LzOl1' L24l2o r27lrl L33/19
rt t6{3t
r6{3t r judse,a [2I LL1l23 2331L7
judsaent [3] 68lt5 L74/Le
L36lt7 L45/21 l49lt0
'{A|TLss/L{ 1s9,/11
Lso/4 LsLl6 Ls3/4
t'a [85] !e/L8 SlLs 9/2 rzlLe 2O717
t60/tt L6517 L69lL3 L?ol7O
L4l4 L9lt6 2217 26121 2714 Ju4ictar t5l Lool2' LO9l3 1.1314 L7612 11613 176120 L77lzL
281L7 2el\3 3}lt4 3tlt7 30121 LO9l20 23sls 23s16
sotzs 3Llk 32lLO 33lLL 33/t6 y t2t L5l2O 15122 71812 L1slS ]JelLe fl9/7 L8014
34/2 31/LO 34lLL 341L2 lsltr e t3l L3/t2 t3ll3 l1l4 183/11 185,/1{ 186/20 195./16
31lLL 1olt2 1o/L5 4ol2s lLlt3 Jurlrdiction [2] 6/22 9ll5 Le6l5 te6l2s L9719 t97lt8
12/3 4215.,4215 49ll 191L6 su2L Juror [1I 7416 19S./11 tgSl2o zot14 2OrlL4
57122 70/13 e2/e e7le s8124 jurore [15] 74/e 77lLI 77llL 2O6|LO 2OSl4 2OS/L0 2L4lS 2Lr/6
941t9 9412r to0l8 LoLl6 1t2/s 77121 8Ol1 $lrL 83/L7 8412t 2L7l2s 2t9lt8 22OlL7 232123
LL?ILO rL3/3 LL6|L2 LL6|2O LS?lL3 2OOl16 2o2/L3 2L6lLo 233/t3 23113 238/23
L3tl25 73$/6 t3slto L36lt1 2L6/L3 27717 2t813 noving [{f 82/2 72{-l'-9 t89l2o
7s7lLs J.rls Lsol6 L53lL2 t12l t2ls L4l2r 1512s 2Lu16
'36/s 164lre t64120
t67120 L6414 4A120 L0Ll71 101/13 115/5 knorledga [1{] 2l/4 5L/9 56122
,6slr.3 L69124 L56lZ4 L7L/23 L2LlrL L2l/L3 L2'-lrs L26lB 6117 78/Lt 1913 7917 eallS
11212 17316 L7316 L1r17 77619 !5A120 sol2t 90/25 110/1{ t2912 L3glto
tl:-l2t LeL/L1 Le2l8 2O3lS 2LLl4 ust t88l 5l2o 715 to/g t2lt5 236117
2121L3 2L5/LO 2telLr 2L9lt7 L3l8 20118 23124 3}lt5 3316 a21 4616 5412s
224lLO 22718 227|e 233124 36t2 3617s 37/2 4ol9 4LlL8 4216 knowg Itll L2l6 L2rl2L L2al22
23912L ; 49/L9 s8l3 63/19 7218 75lLS L9317
iiii'iir l,ootro L3otts 2oLtL6 75/22 78/3 93/t3 93/L6 98ls
tosl2 to3lr Losls Lo3/t3 to1llg
itenr [5] '2ol2L 78122 7912L
1,27lS t27/L6 Lr2l2 LL3lr6 tl6l22 LL,|?O
J.tc [7t 9lL3 L0/2 s7l]-3 8712L 12219 LZ2|LO L2316 t30lt2 led tll 36124
L2tl2L t't/Lt L3719 130/13 t3317 L3617 137124 r I1l L1/3
trolf l{!i 4Ll6 7sll1 97122 L46l2L rso/3 Lsols t5312 lack [2] r4l2 76120
'Iel2t t61l2s L67lto
160/10 t62l2r t2t LslS L62lL8
t6sl6 169/22 L7217 172/23 t7813 latd [1] 741t3
180/11 L82l2L L85/r2 t8613 lane [1] 79/l
1361 2lL6 L?llo LTlrl t9213 L92lL6 19312 193/18 lenguage [1] zt2lLt
$/2 r{-lAi^s4/Ls 16lLo 76/L4 1s1lL4 Lsgl9 L98l2O Lgel2tl azl r73t7 173/8
LL5/22 tLi12 t29l],2 L29lr3 202125 2o6ls 2o6lLL 22rl2r lapre t11 76118
t2sl2o n!19 r3slrg t42122 222lLO 22./LL 225lLO 22s/t1 t1l 761L8
tr'l6 rsol,zt L5L/20 L5217 226112 23OlL6 23Ol2O 232112 t1l 20513
tszll3 7sil6 L6811 r7olrs 233/25 234lLS 23717 23715 t2l L2tlzr L22lL6
17OlL7 710tZt L7Ol22 L77/3 "35/8
23914 2391L5 2391L7 t t23l 6lL6 9l2L !7ln 2e/4
77L16 t7LI7 r7ll8 L1tlLo r?LlL4 Justice [20! 6316 631L7 63120 2415 7rl2 7sll2 8ol7 8216 82/7
L7L|L6 L7ilL} t7Ll22 2O6lL5 6A14 6114 66/6 92lLA e8l',3 8211 83ls S3l6 86120 LO3l2
2t7 /13 ll2lLs t26/3 L46ls reol' 2381L9 L2lllt r38/L{ l5O/25 t1311
13th tll 761L4 23el2} 239lLA 239/t9 239122 L79/22 182/22 797/e 224/20
2o1s r2t L7_\1.\9 L?LlLl 239/23 23912s 21011 tly tzl 231L4 8O/8
itanuary 25ih tll ts2l'-3 lare [2] L64/6 242/ts
26tlt t4l L29lL3 tr2t22 later t8l 291L9 S4l9 eel22
L5012t Lsil2i LO6l7 L65lr6 L65lt8 2lsl23
rnuarfz 27Eh l2l 133/9 135/19 eep tel slLS 1215 soltl TolLL 234122
January ?ts t1l t1lli e6lL7 LOLIT L9719 22812s 2331L6 lettor [1] LSlLg
itanuela' 8t$ t5l L7o/22 t7Ll6
t5l L7Ol22 L7Ll5 t1l 2o6/L2 laugrh [1) 1214
L7L/8 L7trre t7tl22 t21 LlzO Le4/L2 ng [1] 72lLr
Jorirh lllj 9?/16 t2l 3lLr 2rel5 11 t3l 22/5 2216 22/L3
job t?l 6i124 73/6 1316 e4122 l].er [1J s9/20 I{91 3/L9 6/20 1lr 9/r2
94123 LL5l9 LB?|LO ind [5] 541]-9 7L/2o eglLg L4/s trl6 L4/9 t9/25 20/23
jobc I1l 'i6/4 Lvllt2 110/18 25/2L 2s/2{ 26/L4 21/2L 27/23
'i !3lLO L3112 t1l 2331L4 2818 53123 5417L 56123 s1l9
Jolncd 121
s7lL2 571L6 571L1 5712L s9l2s
Joinl.ng [1i L5/2 vitz [1] 2L3/2O
tl
joint t1! 1sl2t ner [19] 40/6 4215 4812L 67123 64/L9 64/20 6sllt 65/20 8L/2
92ls 92lLl 68/2 7313 73ls 731L0 TelLL E0l6 85/Ls 94122 99lLL 99/78 724/27
Joke [2]
3't16 42/23 4416 aslrL r714 longer [6f 29/LO I77/? t83/9
s4ll9 72/11 73/76 e9122 92/20 L83/L7 L93/24 2L7lL9
ar... [15t LIr/2O L1Sll4 96125 LOO/tL tLglr,O t2318 look [3{l 36/LC 37/L5 38/L1
L17125 L8u2 L8Ll3 L8218 !82118 Lr5/21 L46/23 L47/25 L64123 40llo 4tl2 42/19 4e/6 s5/7
782/20 L83/s Lg3lao L83/LA L73/L2 L84lL5 183/Lt 198120 sslLs 70/L7 7L/L2 7sl3 80/2L
2L7lLe 232/8 23414 23419 203117 2LO|L3 2791L8 223/2L 8LlL4 841L4 86lLL e6lL5 LO6/20
larsuit [6] 88,/11 89/19 LLTILG 226112 227|t1 232/L2 2321L6 108/19 L2Ll2 L3L/2 r3212 L45lL4
L76lt3 L80lL3 1.SL/L2 letJr [25I 8ll2 2O/S 35/2{ t77lL1 180/11 L9Als L98/7L
laryer l19I 2312 23123 431t9 37/22 391"r l7lt2 30/Ll lLLlLi Lgels 2031L1 2091t7 2tO/L7
A4l4 62l3L6s/22 73/LA 73/ts LL3|2L L3Ol21 l49lL7 L49123 2t2ll5 2L8173 2321L3
98122 99/2L 115/11 11s./11 L5L/t3 1s1/13 1s3/19 L6e/24 I1t 8tl2r
r24/2L 19Q/10 L93/6 L93/24 180,/U tgLl2L 194122 195/19 tooking t21l 3ol6 3glL7 381L7
19al11 20917 2L4lS 2'9lt7 2LLl7 2L5/r 2t9lt3 22213 4Ol2L 4rlL9 50./16 109/7 LL2/L9
lerryor,r lit 2t1/6 22a122 letter I19l 3124 lOale 10{/11 L/s122 LrzltB LSLls L5tl7
leryerr [?[] 22120 23/L2 63/L6 Lo4lzs to5l2 LOSILO 706/4 10618 L52l2S L58/2t L77/Ls L78/20
65lS 6612't6716 67124 6812 6814 LO6/2r tO7l2O tgzlLS L8?l2O L9216 L9715 2LOlt2 22L/6 2291L3
68/1 1s/2t7slr7 85/7 e6/L4 87/2 183/10 t|sl2o L96/9 L96/!6 looks [2] {0/15 139/20
8717 87/T r,etzo sa/23 Loolt3 L9713 207/L6 2aelLe logt [1] 2l/16
L77122 L2g/25 L23/L2 L23/1s Iatterheed [2] 72/L2 2l4ltl ot t11l 29117 83ls 91lrs 1.2r/7
t4tl2. 1s?/3 181/12 LB'ILI terterq 13! 2316 L27lL3 L95125 llal( L4rl23 t6L/L6 L7el3
1S8/3 188/9 188/13 188/13 revet [3] 24115 55/3 17/5 202lts 2LL|L? 23816
t88lL7 L89/ZZ t89/r Le9l5 t8918 r [1] 8314 love [1I LLlll
189/13 189/re t90l3 LgolLo lorer [2f 8317 2].613
leo/15 L90,l2O t9L/2 LgLl2a iability t:.I 96/2 lunch t2l LOL/23 L3ll5
ts2l2 Le2I5 L92/LS L92l'-e atee [1] 68/3 luncheon [2] 6913 IOLILO
192121 t9t/7 t93lL3 19s14 L95/9 lron [2] 86125
2O2lts 2o4lt6 2oel2 20917 2tol6 ltberty [1] el4 '-8lL9
2tLl9 2LL/.L2 2LL|L[ 2LL|L6 Licenae [1] 27/Zt
2L3lL2 2L1123 2L112 ztrlL3 ie [2I 5515 2O6lL6 r-L I1l ts8l24
2rrlt6 23612 230/21 23313 Llfc t6I 921L4 734125 13sl3 t1l 72lla
rrrf tIt L95lLa 13s/13 t64l'-8 L64122 1161 918 24/22 26/L4 27lS
t{l 38/3 L4tl3 LeOILS 236/4 r t{I 8611 88/Ls ]-56120 27lLO 271L4 3OILS 3OlL9 321L9
r t1l;, L87122 r72lt2 341L2 371L5 42/2t 411L2 4716
tll 23613 lko t38l 1/Lt tLl2O r3l9 L8/!3 491L4 s2lLs s6l7 6tll5 63/20
gOILO
f3t v3O/5
6rlLL LO3/6 L55lL7 L8lt3 3917 42120 43123 15lro 6A/t7 64/L9 6619 831L7
I{l 88/8 eslLo 87/5 gOlA 94124 95/LO 97123 eLlt6 9712o Lo3lL1 L'-olLz LL2l7
LLO|2[ 7l3l2s 73rlLs L3L/t8 LL1lt3 L24124 L26lL3 L2el25
earned [1?l \7/r 3513 5llL2 1.3212 t38lt0 143/18 1{3/19 t3rl7A L34l2O L3Sl1 L43ls 143/7
88122 93/i4 93le esl1t Lasllt t62l:'4 166111 r6s/2s t7ol2r L[sllg L4117 L5t/18 L57lLr
L77lL' 789,ltt 22015 2281L9 r8L/L4 t0elLg 186/2r L8712 Ls8l23 L62120 t6319 L71lL2
earning [ft %/e 189/19 193/13 270125 2rzlls t74/t4 L74/L8 t74l2o t77lt6
1 z6123
oarr [201.1 tsq tA ta4 to
4Ol\7 t11
rSlLL 22414 23s17 2381L4 242120 t1gltr t8214 L8{lL6 te8l25
4sl2l 56/Q 761L6 83/15 ro4l22 iked t2l 4616 LOUZ 2OOl9 2OO|L? 2OL/L6 2O2l2L
116120 r3i/1e t54125 L38122 ikelltrood [2] LQ2/2 Ls5ll0 2O3lL3 2O3lL5 201/2 2O8lL7
tlLltL L7719 L17lLO L77lto lLkcty [,0] 29lLL 75919 159/t{ 2LLl23 2L7lL6 2L1lLA ?L9/LO
22sl2L 23il2o 23rl2} 235.15 15e/1s 22219 2221t8 22313 2241t4
eave [11] I Slt t,/s 3rl8 3s/2t l'J'riting [2] 5122 t03l8 2281L3 22911-8 229121 z3olLs
371t2 61les flt5 sLl]s Le4l3 lsl Ls112 Ls7 lL8 188./8 232113 237/3
79t18 2tLlzr 2to/t2 lrtron l1l 93125
leaving [1] 6Ll3 '.9019 [1] 59122
l1ned zine [2] 22115 t-?glLs
lecr t3l 6212r !s5l2l 240/2 t3l L47lLe Llgls L4817 t{?l 2lL8 3122 4/6 418
rafr I5t 1412t 23lrs 71125 Laten [lI L73lL4 7215 95123 9616 96/L7 e7/L3
89121 901L4 ltisenra [1{! 13/16 73121 79/2 LOel?3 fi4125 1os/11 l0slLr
tegal [38] 2318 2el6 29/3 6516 791L2 82/3 8618 120/e L2215 ro6/e Lo6/L3 Lo6/22 Lo8/5
65124 67/3 6711 6819 73lLL t22lL5 r?3123 L25lB t25ll3 ro8/L2 109/10 109/11 loe/18
87/24 86/tr 87/2r Lt?lr4 t2rl25 t2slL3 233/6 L'el6 $ell2 L6Ol4 L62/25 L7s/2
L22lL6 Lz\lZo L22/22 r22/2r irlgare [61 3LlL2 33125 3Al4 La1/L9 LA1l22 L8817 LesltL
L2313 t23iLo L23lt3 L23|LS 34ls 3417 39lls Laalzo t8916 LgOlLB t9Ol23
L2rl12 r2ille t2rl24 t74lt4 itigation l?l zrl].]- 22123 Lg0l2r l9ll5 L9sl8 re5l3 2o6l2s
t1.l2s L83/1 L8sl7 $6/7 t89/23 3s125 4Ol2 4ol4 L96/Ls 200116 2O7/18 209/25 2r2lt6 2lrlJ.o
Leols Le{ltl 2oLl20 2o8l2o ltLgator llt L83lL2 2L513 22213 22218 2221L1
2L7lr3 2L1/LS 237124 ttle t9I 6120 L2l2L 22fL6 fc [1] t6ol22
legally tl! 631L2 471L3 t:-6l7 t22lt8 ]^3glzo Iine [3] L58123 L58124
tegislativi t1l 91123 r70lts t8113 L'el4
losillatur6 [2I 23r/LL 23611 ived [3t 2s122 35/1 22Ll2t lrs [4J 97120 Llole L'-ol2o
r lll 1,O1-l23 local [2] L5919 L7316 L27 lL3
I3l 2lL5 Lr?lt' t{712t ntained [2] 2?O|LB 22LlL2
stn tll i res/rr ntaining [1] 2L719
lengthy I3t LolL4 82la gslts icsl [1] 2l-4125
ajor [8I 15/3 15/10 15/16
lena [1! 73/3 t13t L3/6 L7/7 L7/L2 26/e L5lLg L5122 L8lL2 2214 59lLL
l'ecr [{l 29ltL 8614 126/23 27/L3 27lLt 28/23 .112L 72le
ts6l2o ! 121L5 LOtlg to1/2 22sls t61l 2S/24 29/7 3217 321L4
t3{t il'€ tlzs Lll:l 341L1 long-rtandins [1] 2618 33/tO 37176 39/77 1r/22 12/2
n
t
t4lLO 20lrt 3LI9 36176 361L7 L9t/L4 L9t/17 ZL5|LS 220/4
36/L1 36122 37/77 31/t9 37/2s ueana [3] Ll5/1 l2L/3 L25/15
urke... t52l 49/t3 19/25 50/8 4t/2t 4316 61/8 7Ol2 7o/8 ?olLt tLzJ t6/8 s7/L8 6s/6
,olLO 56l+5 57/25 63/6 54llo 91/5 9718 Lo6lL7 Lo8lL6 tztlLg L7O/3 L2O/L3 L82/7 192/rs
6s/2 6s/79 85lrc 861L5 95/t9 L3,ltt L14/2 L56/s 160/10 2O4lL2 2L6123 222/25 227lLO
e5/79 98/+2 98/2L LA2/6 LL3/25 L6O/23 L6ol23 L63/4 772/4 239123
Lr5/L6 L2614 L3412 L3614 L38le L12lrL L80/6 L82124 L94/23 rure [5] 63120 8?/16 L26/2
138/11 13b/1s L6rl25 t7zlL1 Le1/t7 223/21 223/25 22el2o t46/5 7eO/8
78o/t2 188/10 L88/23 LsLle 23919 24LlL8 24r/2O anirna [1] 234/20
192/ro Le4lL' Le7lLg 202/Lr aL2t Le/8 18/16 ssle ia 126l SlLo s8/19 72125
2o2lr5 2041fi 2oSlL6 2LL|L? ss/r3 Lazl9 L0717 Lrols t1O/2L 73/3 73123 7414 1516 8tl2D 83le
2t5t2i 2261?3 224lLO 22r/LL 22L122 2231L2 22912s 239lLs es/rc s7l4 9L125 92lLs 93120
226/L2 22iltt 23LlL3 232/L7 t27' rl23 slr 3slLL L54/L6
LzOlLs L26/7 rr8/s 1{8/10
L68lt9 L16/Lo L76111
23711.824d/3 24O/8 212ltt 3s/22 36/23 4LlL5 aslL9 45122
242t20 i 46/25 5313 69123 Llzlzo 10s/1s L78/LO t78/L4 2O5/LB 2L6/9
rkec [6I i9215 Lo6l8 t25/L2 t7a/L6 L2713 L27lL6 13214 t1l 115/1s
2lrl22 211125 2331L5 t32lL6 L32lL9 L6Ll9 773/16 lng [12] LOs/a3 109/19
lsst 8l2o 3018 3218 3912 t75/t9 L1sl25 t83122 tsrla LO9/2o L28/4 t28/73 128./18
43114 43/21 441L5 4817 rglLt LsTlLt 239/20 L72/L9 L12122 L12124 L74/4
50/6 50h;Sl/s s1l13 63121 65lr ta'a [2] L2g|LO L4tlL! L87lt6 184/10
66lLL 681!2 13/22 83lr' eTln tll Lls aeetlnsa [2] 5615 LgLl2'
tL6/L3 LtilZe L2slrs t34l2r -31s6-1s tll tls neetc tlll 2lL2 L3813 138122
t3sl2 L37lLf, Lr2lrr L43/4 I1?1t 7125 813 8lr L2l2^ L39lr
qeuber [5] 7lL2 L3l6 74120
143122'36Is
L4E4L1 tr112 trel2L t3ll7 L4lL4 L8lt7 2Ol7 2LltL
lsLlzo Lsll4 L5619 Ls1lL1 2215 221L3 2212L 23113 24lLo L6lt4 9612r
t51123 #ql2 t3el6 t6312 32122 srlLr 35120 36123 3712 rr [121 sle slll s/L6 812
t6slL2 L6glL7 '-62122
1.73122 776/LO 3116 3712A 3SlL6 42123 r4l6 L2l2O 2418 2517 srl22 5L123
r76lL6 Lss/L6 41/25 IS|LL eslL{ 45/2t 4812L 6e/s 821L2 LOl/La
'7d/120618
20417 206I:2 '€Ol2L
2L9ls 2L9124 rst4 521L6 S2lL6 531L7 53123 nenorlalize a2l Le6l23 234121
ân [5] 261?3 5211 s5/2 5513 srlr 541L9 5412s s5l3 56123 tll rsllo
86/LL i 5919 6217 6212L 65lLO 6s123 l4enorioc [It t 4r12
anDer f2I' L49lL2 LSL|21 66120 67125 6712s 7OlL8 7O122 aaory lttl {4/L8 t26124 t2712
any tlst itels zttzt eolrc 72/14 721L9 771L6 8OlL7 A714 L10lLS
6OlL3 t0Lls 115/1s LLels Ll8le 881L3 8918 89122 9Ll2s e2/20 tLon [2] t9s/25 2OO|L9
L33/Lr L31/r5 L37lL' t.O18 s2123 9rl6 94120 e9l9 100/11 ttoned [3] 178/tl 22612
L83/6 2OrlL2 24219 loo/13 LO?ILO l04l8 Los/16 22614
rch [2I iLLSl2r 22917 to6/s to6l2L to6/22 LO8/2O ry tsl zlLt L3812 139/15
rgaret [ft 2o7l2l ro9l7 to9l21 110/16 110/16 14014 t4017
rino [2] i tslu rcln TLtls LL6lt7 Lt?16 tL7l25 c tll 7alt3
inttts rcets n3tL3 LL8t22 LrglLO L2216 L24/7 L2417 t2t rL2l2 lLSltB
iiirllt L24124 L25l''2 123/19 L23l2L
L26123 L2113 L28lr9 l3olLl
Ilt 8lL1
11t 81le
arked [tf{[ 219 3le 3l!6 415 1 t1! r5lr2
$lr4 2ol2 35lts 7olL3 TolLs 135/13 L39l2L Lr3lL2 ta712
t{l alr LL3l22 LLAI2
7ot78 e6li 96/13 10u12 rolll.e Lt't16 LrTl2s 1{9/s 15].16 L5rl22
to5/2L toiltt \06120 ts5/8 L5sl25 t6Ll22 L6rl7 rL4l2
Ill tt3l22
t21lLl t2i.lLs 'o8/L3r34/6
L3018 ].3312 L64/23 L66lL3 L61lL3 t6s/25
L38.t1 L38].ts L17lL5 t17lLB 169/15 t?Lllg t73l12 L7413 tlI Lsal4
Ls2l8 Lszlr2 L5818 LsSlLL t6317 t7rl8 t7sl14 L75/L9 L73l2L 11I L8414
L6613 L6616 L6919 L73lL7 L76121 17612 t7716 l78l]-8 180/10 ternoon l1l 131/18
L7713 LTgJLg t7glLl 19s,/19 La3l78 L'llLl L84lr5 Ls'/Ls t3l r34/r L49/8 L77121
L97l2r L98lr 2L816 L85l2t t8919 r92/7L L92lt9 isht I28l 2912L 29125 781L7
rlet [3] . Ttll 85lLG 2L619 L92/2t L93lL6 L94/2s 19515 78122 19lLA 7el2t 8Al2t eslLs
rking tll
rkinc tlf 2L8ll2 1e5/13 t9615 L9516 L96/2O L9715 9712O 9816 t0217 Lo5l6 toels
rried [li B6ILL a9716 197/L7 t98/6 198/13 rLo/6 tLOlT rLAlT L43lL2 r57lL6
Etlndale:[2t 2314 23/Lt t98l2' t98123 2O3/LS 2o3lL7 163/16 L6elt3 L72175 L72ll7
rtindrr€isubb€Il t2l 2314 2O6t22 206122 2Os/3 ?oBlto t7rl3 tg].lt3 te3lL' L9rl7
209/75 2rO/L3 ZLO|L? 2tLl2L 2L6lL4 226/20
srea [1] 81/19 2L2/22 2tslL6 2t4/L2 2tsl5 lJ-lona:Lre [1] 91116
tzt i6]-l5 6Ll8 2L8lL4 zLe/Lo 2t9lL8 22312L tsl 54123 9s122 LLI/L'
al t*l 18122 226/L2 2271L7 23716 23212 LLsl3 as6lr3 t56lL5 L56lL6
atg irt 90/6 2321L2 232/L6 2e718 21116 207 /L2
t31i 6lt7 sol6 32/L3 t{31 22/20 251L8 3OILB t1t 3sl8
64118 6u+e 6,4120 65120 7713 gol24 3ol2s 3L122 33lLt 341L7 trl L9S|L3
82/25 84/15 esl's 8718 g'-/Ls 3617 37/s 40/24 rol25 4L/3 rtl7 ninnn [1] e6123
sslLl LL5l7 L2tlLt 123/23 12616 4LlL7 4L/22 49/LO 6712L Ttlte inicter [8] 63/L6 64/1 6615
t2alts L75l2L L7613 L8tlt6 72/L5 86/L3 tO713 tt0ll'3 LLsl6 92lt\ 238/19 2391L8 239122
1.8218L93/2r L97lr2 2LslL3 LL?l7 L3912 Lrtl2L 1(sl2L 2rol1
2L6/L7 21714 2L7lr8 2r0lL6 L48125 153/Ls L61172 Le2lL, nute [2] 68123 169l'.5
24o/2L t L82lL7 L8616 zL'rlLo 224/8 nutea [3] L02/9 L0Sl24 L3L/L9
.attered [$J L2s/L6 72slL1 224lLs 225lLA 232/29 233/L8 rcellaneous [3] 232/L9 233/L3
tesl2z teilzl tell2 234121 23817 238119 2331L9
strued [1]
I{4t 7122 t0l2'. tug 7219 ns t?l 211L3 73/73 L74lB 270/2
l,
36/23 38/t4 4O/s lLlLr 42123 t28/L9 L29/7 L29/to t87/L6
4s/L9 45122 46/LO 46124 46/2a L8L/25 t84/22 Le4/24 Lss/23
Laguoted t{l L37/L2 L37lLs 46/25 46/23 4712 41/L6 4914 t9r/L2 232/L9 23313 2361L1
L37/L8 Ltzll5 sa/L8 sL/2 5L/8 sll23 5212 52/5 24O/9 24o174 247/2
a t5t to/t tsltz gona s2/L5 53/3 s3/t9 5al3 s1/L4 . Rellly I1l 13s/9
103/16 L43|LO s5/L8 5e/76 s8l2l 6OlL9 63/4 . nyan [11I 3O/L3 r3l4 135/10
s Conltlnd [2] 3017 L43{LO 6316 6412 641L8 65/3 65/6 65/tS 735ltL Lr3ls tr4/9 L46lL6
ao reraai 12! 9o/L4 to3lL6 6sl20 66/2 66/8 66/L2 66/2L 7s3/t6 15{/13 L65/2t
caed [1] i 97/20 6714 57/6 6712o 6e/9 681L2 I1l 20slLg '.87/14
raLng [1! 22X/3 69/22 6e/22 6e123 69123 6e124 . t29l \0615 LOslT 18s/15
raouriani[3] 2116 t52l6 7Ol5 70/77 1tlL2 73125 7rle 18512t 1S5,/10 L87 125 188/16
152/L6 l 74/L3 Tslt 1714 7712L 7813 7Sl4 789lLL 189/15 LgOlLr LeLlLA
irrrateDeit [1] L99l2L 78/L4 7s119 't9lLr 8Ol9 80lL' 192/3 t92/L9 L92/22 L93lL1
take t2t. 9slt9 154/5 8o/2s 82115 s6/8 86/Lt 87/7 t97lr a97Il8 207/3 2O8/2O
gunderrtandlnE ItI 2LO/3 e7lL' 8817 88lt0 88/21 eO|LL 2LOlLo 2LL/2L 2L2/L9 2L319
fier [2] zLslla 2L5/22 eL/6 9t/9 9]-lt2 94/9 9SlL3 2t3lL8 2L3122 2L3/2s 2L4/22
f,ying [1] 220/6 eslt6 96/12 e1lL2 9919 99/L7 224/2L 22e123
lolert lLli 22a19 Lot/L7 LO2/L9 LO?|LI LO2|?O s. Feraan [28] 106/5 185/15
.olertrtiofi [1t 22llL2 LO2|2O LO2|2L 103/13 LOrlLs 18512L t86/LO LS1l2s t88ll5
olacted I61 8olL' 84/8 L',5l2 LO6l25 Lo?llg 111/16 Lttl2r LgglLL LsglLS 190/1tl L9L/L4
22r/2o 2241s 22416 LLzl2l LLll. LL4l8 tt9/2 122123 79213 192/L9 L92/22 193/L7
l3l: 112/8 r6el7 L71/e L2s/2 L23/L9 L2rl3 t21lLS L2615 L97lr LgTllg 207/3 208120
ta [1] t69ll3 L27/3 L21/16 L28/LO 130/11 2LOILO 2LL|2L 2t2lt9 2L319
tlol I s4l15 6el]3 74174 L32lLs L32/Ls L32/t6 L32lL6 213/L8 2L3122 2L3l2s 2L4122
z6i'tti ziilt te' itz/s ztzts L32/L7 L32lr9 L32l2S L33lLe 224121 228/23
. Ferann'g [1] LO9/7
228/24 23q.16 2381L7 L3719 t39/22 L4L/LL 1{1./19
oNrguE tll Ll24 t45/t6 146/LO t50l2L ts]-lL0 t15l sl3 514 45124 4612s
onkey tll: 85/18 1s1/13 t53/22 1s5/a 15s/1O 69122 6e/23 e8l3 Lo2lrg L02l2O
oNrconRr:[a3l Ll? Llg Llts L55123 r56/s 158/10 LSgIzL t04/3 ro7/L9 L32/rs L32lL6
stit ttt$'nil L;ttL2 L7lL3 L6O|L7 r6Ll9 L6219 16617 L5e/2L L87/L0 L87llL
L7/20 L8124 tgl2s Lel3 2L/23 L69124 t15lL6 L75/L9 L75l2s . tsol 24122 26/t4 4116 17/Le
22/4 2112L 24125 2616 271t8 L77/3 LA3/22 L8{-18 Lsrlg Le6/22 48120 soll1 5Ll8 s3lL9
41/8 58123 39/LL e4176 96lLe L87llo 18?/10 187lLL L87lLL s4ll3 551L8 sSl22'LILL
6Ll2 6LlL5
Lt4lL2 11?/18 L1,8/6 L22l2S Le7lL? 18?/18 20L/LO 2AIIZL 5tlt9 6L/24 6619 66lt[ 681L3
L3U8 t7OlLg L1L/25 te6ll3 202123 2O3lL2 203123 zorls 741t2 7613 171L7 17122 18/3
t97122 226120 22L122 22l123 2O(lLa 2oslr 2o5/Lr 2Lrl7 7816 19125 solr 83/L6 eol6
222123 225lto 223tts 22r/6 2t7lL2 2201L6 222/L3 223/2s eLILL 9LlL6 LO4l5 to4l7 Lto/g
221122 ,36t19 23slr6 z$le 22619 226/L8 232lLr 23313 LLO/LO Lt}lzt tL2/2s 11314
t1l 23OlL4 239lrr 2ril3
239120 LL3l6 LL4l20 116/s L2rlL6
a:-l!.2Le123 . t73l slto t6l7l L6ltS zolLs 1s5./13 Lssl2L L5611 t56122
ore [2{I ?6/7 L6/r2 3Ll2L lrlLo 24123 3OlL3 3sl3 Ble 52le L7el7 2OL/L9 22Ol2L 24015
6sl2s Loois 1oo/1o 726/23 12719 s2lL2 S2lL5 531L7 s4l2r srl23 . Andrea [1t 24122
136123 1s5/re $918 L1elll 34124 ssll0 5s/L6 s8l4 6e124 . Constand [39] 26111 4416
rjl/s L1slL2 Lsolrs Lgllte 65lLO 6s122 6618 66119 6713 47118 4u2a 5olL7 5Ll8 SLILL
t80/24 Le6l22 zAOlU 2rll2s 671L6 67122 87n3 A7lL7 g'.ls 53119 s4ll3 S5lL8 sel22 6Ll2
2ttl25 2t212 23313 100/6 1os./15 7091L3 1L0l23 6L/t5 6t/L9 6L121 66le 66/Lr
ns t9i 518 sl2L L2/L3 111/10 t2Sl5 lzelLr t28lt9 6elt3 741L2 7613 771L7 77122
72ltA t3l4 13/5 98/17 23914 L29t7 Lzgllo r3rl6 L3214 t3519 78/3 1816 7912s 80/r 83/L6 9016
24218 135/10 L3slLr L4Ol2 L42lL4 gLltl 9L/L6 Ll6/5 !2Llr6 L55lL3
osr [8t $elzo eels 118118 L4315 a4419 llllL'- Lr6l1-6 L55/2L L5614 t56122 L7S/7
t22/t7 2OF/t3 2o6/Le 206121 L49lL4 rsLl2o L5213 r53lt6 220/21 240/3
2o7/2s B L5,4lL3 L65l2r 168/10 l75llL . Constand'e [lt LL2/25 Ll3l4
ostry [1] \ 2612 L8L|L6 t8Ll25 t8418 L8r/22 LL3l6 LL4l20
other [5] 1 5rlL3 58/9 79125 L'rlzl t85123 t87lL{ l94lr2 . Feraan I5l LO4l5 l04l7
L2els 228124 2281r 2321L9 23313 2361L1 24019 t1o./9 110/10 LLO/zL
tal r, 1/8 617 6/tr 7lt9 2401L{ 24L12 . Gi-bbong tll zoLllg
tol1 Lo/t4 LolL6 9213 . carpenter [2] L6ltL t6lLS t21l L3lr4 L8l7 34/L6
ionr 11) 40120 . Cartor [1] ztlLg 73/t9 8317 8slzs 98117 110/13
ths tlll esln . Castor'a [1I L3L/6 L43124 L54lL7 1s6/18 159/8
a tlel iL2lL6 2Ol2O 3L122 . cosby t8l elLO 24123 3sl5 t59lL4 t16lt2 L8O/24 L86l2L
3313 3517ElolLL 'tLl6 Sglra 871L3 trelJr LsLlz} 1s213 22811 2L214 2t215 2t613 23tll6 24L118
9sl20 L}olrt L36123 Ls{l2r . Coaby"r [1] L?S/LL riple [5] s3l2o 6Ll2o 191L3
L1O/L4 tsrl22 2o7lLL . Eegsler [{l LIO/2 L42lL4 LL.l23 LaLl2s
'sit2L21212L
27212 2291t2 L44/LL L68lLo t3I s9ll3 Selt[ LLrlr2
l3t Lrl2L LStl2 L97/L6 . t{c$ronagle [2J ].OSILS 13214 3 [3t 59/20 s9122 s9122
I1I ;9tlL7 . Patrlcl [1] 18418 r t8I ell 9/t1 L9123 s1lLL
oving [8] 5 37/20 3216 67/t8 , Phillipa [41] 52/e s2lL2 L2L/9 201/Ls 201123 2tLl2L
TOlLa $l\L to2l3 Ls3lt6 22sl2s 521L5 s3ll1 5412L 54123 s4124 t1211 slLL 5/r 9/21 L4/S
oyer [1] i,tSAlZS 55lLO 551L6 58/4 6412r 65lLO LSl6 Lall L8l8 t8ll8 1.e16 2Ol1
tl9st s/3 513 sl4 511 sls 65122 66/e 66/L9 67/3 67/t6 2L/t 23112 2a123 27lA 3Llr
112 Ltlg L2lr3 L3l1 L3l6 t6l2o 67122 87/L7 91/s 100/6 109/13 33/11 3s/L2 36/21 3e/u 43/21
t9l2L 2ol9 31111 sslLL 35122 trol23 111/10 L2gl3 L28lL4 5'-123 56/25 60123 6516 651L7
tl
265
I 237/25 238/2 240/3 note [2] 33/19 151/10
td 5 Nevicon [2f 213/2L 2tl/6 noteo [1] 244/6
. .
l95lt 6s/21 61/5 67 lLs nEw [5] 2/L0 5L/3 L3O/7 L3315 nothing [15] 6/9 31/22 45/12
'y.
581r5 131? 73/L2 1312t 73/23 2L0/2s t09/25 223/24 225/1L 225/L2
73121 7rl4 82/4 S6/24 89/12 nerrg [8] 2/t0 t3ol7 L33/4 L3417 2291L3 23O/L8 23o/2O 23u7O
eo/25 s2llr e4/23 e4l2r e5125 L4O/25 L47lL9 202/19 2O4lL3 23LlL5 2361L7 23glt3 2rll24
96/3 s6ltg 96/22 96122 9817 nowsprper [3fl 81123 9712 9813 notic€ [1] L99123
70319 LO'|ZL LO6IS !0919 LtolLS LOO|L1 LO3|L9 rttl2 to5/L8 Novenber [29] 2/14 zlLg 2l2L
LL2l5 Llzltl 115/3 t]-s/8 L23/L4 LO7lL2 LOll2l t0812 L3314 L6ILO L6/L1 921L2 921L3 93lr
12512 L2Sl.3 L2S/6 12712 t2115 L38l2L t3gl'-s L39/23 93lLs 9slL8 7171t4 r47/2O Lr8l2
L35/3 736i9 L31ls L3719 L43lL6 ',3913 L4alL4 r49/2r
LAO|s 74O/7L 75817 Ls8lts 158./17 158/19
741/L3 74512 L.515 rrsl2L L53lL4 LS8/L3 t1'lLs L7sl2s 16313 L63lL9 L64/t6 L65l2O
745/23 1{6/19 Ls.lLA 756/15 r96lLL L98/7 79818 2OtlL3 r6sl25 t67 12 L67,/4 1,68/1,6
ts6lL6 t57122 Ls1l22 tss/4 2o4lL7 2osl8 205/L2 206/6 20617 t68122 t7o/4 L76/Le 2O2/L8
L59/21 L6718 L64lL7 t6r/22 2O6/e 228122 Novarber 12th (11 L76/Lg
tTLlS LTL/L( L7tlrg r72ll3 newlpap€rr [5! 58lLg 9513 951L2 Novanber 18th t3l L58/LS 758/L7
L14122 Lsile 7$/r2 L8216 LlO/g L84ls 158/19
L82lt1 L88124 L89le t89lL4 n€xc [2Ol t lr, ,rlt0 Novenb€r 19th t3l L67/2 aAlA
L89123 LgilL( Le7176 .L97/L1 8s125 971L7 98lLO tOTls "Olr"
108/11 t6SlL6
202112 20113 2usl2 2O7lLL 20el6 L2715 t34/L1 t4LlL6 LsL/2 Novenber 2011 l1l L7Ol4
zLLI3 2L2I23 2t118 2L6lL3 L63/r7 t67lL3 L7Ll2 Leo/9 Noweober 26th l2l L47/2O L4812
2L6/13 2L1122 22o/LO 22412t LsLl2L t96/7 2LAls 2L2lL6 nor I105I 5lr5 9/6 glLt 9lL7
225175 22F.16 23OlL7 23LlL7 nl,ce [1] LL2ll L1lLL 2rlL7 2lll9 30123 3ll2o
23u18 23'l;l2r 239124 zrLl6 Dtght I1l tLl23 3t/22 351L4 36lla 3712L 3elt2
yaelf lgt" 8/to 221L6 7213 72h nLne [1] 22125 4Olr Aole 47121 49ltO 5t/L9
a8lL9 L37l.L2 L37lt' t97179_ no t1{31 ll5 7lL5 L2/23 L5/21 s2l8 s8/L7 67/fi 72/L2 a4l'-5
L8/6 rs/rr L9/23 27ls 28/t3 881L1 88/22 89122 9213 9313
N ( 28tls 3O/7L 37lto 39lLO 4Ll8 101/10 LA3l9 LOrlls LO9l23
nane [3] 96/22 L35/9 2Lll5 4sl6 4sl9 lslll 1614 46lLr L72/2 LL3|LA Lt3l2L LL6l7
nanes [2t 1f8/19 L49lLl 46114 s4l2r 5312s 371r7 6312 tLSl2' llells t23/Lr
narretiva flt 26124 64/18 77lLs 80124 8tlt4 8319 !27118 '.t8/25
L27125 L2a/4 L3312
narror aL, t 26121 87t25 sols 90125 931'-8 9711 L33121 t36l2L t3el7 L38lL9
national [?t 2L/9 73123 9ll2a s8t2r Lo3l]-e 106/5 10s/1s L3el6 r3e/24 tro/4 L4Ol23
s3l2| LA}ILO 1s9/10 168/1e LO1t23 109/16 110/13 LtOl25 L42/L9 L43lt5 t43/24 L45lL1
nltlvs J7l'4 761L3 LLO|2' 111/13 LLLII9 lL3l2 t4914 $al19 L'zlrt rs2lzs
xarurally t2t 2221L7 22315 LLs/3 LL3lr LLel3 L2OlrL L2L|Lr 1s3/10 L3r/2L rss/ll Lss/Lg
neturo 141 ) 5/22 6120 261L8 124tr} L24l2r L2rl25 r2s/L2 tsl/Lo 15r/1s L63lz|
29lLO 7251t3 L2512 L26l1s L29/2 165/23 t67lL3 t1OlL4
'.6316 173/5
near [21 73/e 205113 72str6 L29l2L t30l4 1.3ur2 7'ru9 L7r/9 L1sle L8Ol4 L82lt2
nebuloua I | 79/20 L33lr5 L3rlL6 L3S|LO r37lL8 7861],2 r81/22 189/5 189./17
I3t S5l9 r22lt3 138/15 rr2lL2 147124 7a814 L9u8 t92l''5 L92lL9 19s/19
L23122 t4817 L[al2o L49lL6 t5318 Lg?15 t97ltr teslr 2ool8 208123
nececoary [81 t3lLs 33123 3ll2 t57124 l6Ll2S 162117 L62/24 20912 2L512 2LSlr? 2t618 2L719
' 2L7124 22013 222/L2 22317 22616
s4lL6 taglL6 193/16 2371L9 L63l2O t6317 r5sl7 L65l2L
2121L9 L65/22 t66lLL L66/tr r67lt2 226/22 2271L8 22818 239/1
need [18] LAI2O 3Ll2L 331L9 L6818 t68123 L72/7 L7219 t7417 noshere [1I 2OOlLg
371L6 1s/3 50/4 8Sl2 roLl2l a1rll3 L?'lLl L7913 t8tl23 nuEber [20] 219 3lr 3/76 4ls
tt2l8 tLs)22 L23lL2 LsLlS Le2l23 L$19 L83/L6 L83l2O 2rltr 35lts lalLe 53120 ssl22
t6rl2s t7g/t7 t82l1e 2L5lL4 138/15 tS9l22 191/10 tgllLs 861A4 LL7/5 tL7/7 LL7 lto 151,/11
2L6lL8 2Li15 Ls3l8 L9318 t93lL9 ,-93124 L59/2s 227/2O 232120 23slL8
needed l7l1 l5/2O LBltg 2519 2OOlLs 2ogll3 20412 2o4/s 20513 235/t9 235124
48tr{ 5612L 7e9/22 2L7l2r 2O5l2L 20618 2O7lLL 20914 nurbered [1] t6412
needlng [2t 451L2 451t4 2L3l2r 2:-71t6 2L7lLg 2rslLo nuDerous [5] 9Sl8 LLLI3 LlLlS
neadg [2] '?9/3 235122 2r8lr? 2t8lL9 22018 22t123 rLtlg LL5/25
negrtive [Ql 1812 t72ll2 22113 225lLe 226lLL 2251L3 ?utg [ll 100/2
neirher [2j 5114 6119 221/Lg 221120 22S|LO 22Blr2 o
ncrvoualy i71 ]-ill]-l 161117 22el14 22912 23t17 23Ll2O It!
O,Connor [1] t8419

t6rl22 L6ll2S ].6516 L6SlLo 23212s 233lLo 23416 24a13
L65ILL ? 24LlL6 24213 o.NErr& [1] llLT
n€ver [5ol j tzll 47lt]. s9l8 nobody [2] 49/7 78/2 oath [15! 2el2o 28120 871L3
6tll8 67/2s 62ls 6217 62123 nonlnated l1l 1617 ss/4 toLlTS L3218 L53lt7 !55124
6317 6618 6612L 6113 6Alro noa f8t sl2s 26122 3o/t2 331\3 I rselro LgrlL3 20213 2o4lt9
5elL6 871+8 gollt eoll3 eol2t s3125 s{.lLt L8sl3 Lg2lLo | 2261e 2261:-3 2261t8 225124
stls e2l6iell4 gsllo eelzo non-1ar [2t 5.3125 54lLt loueyed I1l 20919
tool6 rLO'12 115/18 tL'lr3 L2312 non-proaesution [5] 3125 25122 lobituary [1] LO0l22
12412 n4lt5 L2slLt Lsglr L5914 3oll2 331t3 L8813 LgzlLo lobject t7t 33120 33122 33/2s
L64125 L6b/9 L6s/Lt L6sl2L none [lJ 62/L3 I gglg 5,2120 143178 1't3/1S
L74lL6 t73lL2 t75122 Lezl3 nonetheless [1! L79l2L lobjected [2] 4212s 23t14
1s419 tg'llt 2oL/2t 202/r nor [2] 90/7 l65l2L loblecting tzt Lgo/2L lg:-l4
202122 20$/20 206125 2t7lr1 noraally [2] 200/9 2OO|L2 fobjectlon [25] Le/LL 26/t6 2716
2L8lL8 22+13 22LlL3 2221L3 Norriatovn [1] L/!5 I golg 33/to 3s172 36/17 39/L4
22618 23L{23 2321t4 233111 not [3?1] | $le $/4 4el3 4e/5 e7l6 Lo5/4
I
I
a
t2331 2/L4 316 5/23 7/L9 242/20
8173 e/7L glre Lols 10/24 t7/t7 one-by-ona t1l ,,L/L1
bjectl.on. r'. t12l L0515 lO7 lt4 !L122 t2lL7 t3lL2 L4lL5 one-party Jll 57/7
133/1. t4-Il8 Lr6lL3 1s3/8 t4/22 t5/6 LslL6 L6/L2 tslzL
'1176 nry t29J 615 74/77 zt/r s2/25
L!s/22 180/10 Lgclls Le2/r 2O/2O 23/21 26/5 29/Ll 3AlLl 57/6 88/9 98120 LOOILA LOtlL3
2LOllL 24213 30123 3tlLo 3tl20 3t122 35ltr Lt113 LLelg 12slt7 L2619 tr6l3
€ctlonr: [1] 47/71 361L8 36120 37lLe 3815 3e/2 L7L/17 t7L/23 188/10 LBBlLr
obrain t6l? $122 s1l2 77 lte, AO/IL 42/7 12123 431L7 43/24 L88lt7 189/1{ 189./19 rs2/L2
eo12 9013't4615 43125 441L. 48122 49122 sL/72 t97175 2O8/Ls 2L3/t4 224/23
11t 79/23 56110 5815 s9lL2 6r/3 6212 232/8 237/23 238/3
Louc l1l 225/LL 64/L2 6s123 66/6 611L8 69/tL rlo [1I ,03/18
ary tlet elz 72ls 2612r 7Ol2l 1LlL7 72/t2 74/2 Tsllr a2l 93179 1srl23
341!s 3rl25 411L6 52/9 52llr 75/23 7913 sOlLA $l2t 83/4 Iel 60123 6Ll4 6L/6 5L/9
84123 sL/f.1 s2/2 s7122 e7/2s 84/18 e4/L9 8s/L5 S5lL7 A6/3 L9413 Lgrls 2LL/24 2L7lLt
e8l1-6 eel22 109/11 1t1l10 131/s 87/2 Bs/2L 8s124 e:-l3 9LlL2 223/L9
23s/2 : sLl25 93/L6 9rl2L e1l2L 9612 t12t e5l7 95/e 775113
rlonc l{I eol7o ttl/3 Ltlls s6/5 LOO/LL tOOl2r LO3l6 Lo6l7 yslre L75/2O r77lt2 L77l2o
to6l23 to?l2s 7os/23 Lo9l2 180/1s Lsol2o 180123 L83124
ll3lti., 'q,ot^ L2stLa 22st3 tosls LoglL2 LtLlz L7tl3 Lltls 22LlLt
t21 tol2o trlL?
235t7 t 111/s 111/16 LL2l7 1L2lL2
te [1I 6319
occurred [{81 26/5 stilLT 55118 7L2lL2 Lt6/L6 LL6/24 tLsltL
57ls 8LlL6 LL3/s LL3l7 tL4l22 trsll7 11el15 Lt9/25 r2llzL ted [1] 68/5
L28/Lo t26/L8 rr2/3 Lr4l22 t28lr2 t3ol22 L3rl6 L35/2 tion (11 L74l2O
t6LlL7 t87123 22Ol2O 223lLO t35lL2 13s/1S L36lt r36ls operationc [2t IA/LL 2516
229/23 21?lL4 L36123 L37122 139/10 1{0/18 oparetorr [1t 3616
t{l L7316 L73le L73lL6 LlLlg lQle L42122 r4'31L2 1{417 lt2l 6516 82lr e3le
773123 t44ll6 L4519 trsl22 L45l2s 95/25 e8l7 LOs/22 r9O/3 L94lt6
off llrt LAIL. s3l7 6413 88125 LA6/1 L4619 rl6lL2 Lr1ltz LsAltT 2L617 22s19 23sl2l
961L8 L03I2. toll2s LLTILL L47lrr lr7l2o tr1l2L L4918 r [2] 84120 zr6lLr
Lss/z LrLIs 198/13 1eel18 t4gls r5olz Lsol2| L5Ll2 75rlr I1t L12lLt
2,ollr 2L$lLo t'Ll2O L52ls 15317 1s3./9 155/15 tc t1l L72lS
ffended tll t22119 ts6/L9 L56/25 L37110 7s7l2s ty t{l 113 eLlT r32l2o
offenee [3] 7lL5 8Ll3 Ll8l2 15S,/1s r6OlL2 t6LlL5 L62ltO 2L8/25
offencer [lt 82118 L62ltL 7621L8 t63125 L6slL6 tll 2el6
offered [11. 471L2 L67/22 L6814 t68lt5 L68/t6 ite [1] t20lLl
offering [fl 9319 129/18 t68l2r 16s/2 r7ole Llsle t7slao tion [1] 6lL7
office [{8$ Ll9 6/L2'6/t6 L3ltt tIsl23 L1616 L76lto 176110 red [1I 2Dol13
Lslts fi/20 r1l2o ts/2 L5/L3 L76123 1?8/10 L78lL6 180/16 tion! [1] L16/5
L7l2s 231i6 2417 2rlLL 2rl'.t L8Ll7 tg4lLo Lgll2'. ts7l3 LL62t 612 714 7lLs TlLs 9lL6
2617L 261+2 39/24 rilz 561L9 L8712o L87l2s LaBl2L t9ol21 to/8 LOltT tsls L6l2 2212 2312
6712t 6811 13124 8518 9ol5 tgLlzl Le2/7 L93/8 L95l2L 2518 2512t 261L3 2819 28lLL
sLlLS s4ti7 s4/2o s6/2o 110,/11 L9Sl23 Le6/L4 t91lL{ 198/13 2sl2o 3016 3Ll6 32126 33/LO
LLO/22 LLLIL( rLE/6 t22125 Lssl76 lgel9 teg/!l 199/18 34ls 35/20 3712 31175 3919
L27lLL tS?.lE 7s7llg L57125 2OLl7 2O2|LO 20316 2o3le 2o6l\s 4Ol2O 421? 43lLL 431L2 131L3
L74/L6 L7ilL3 L7slL' r83l2s 2O6lL9 2A7172 2O7176 207120 4413 Ae/1 5}l2t stl20 521L7
18s/2 191f17 L9614 t96lL1 2o8l:r 209124 2L2123 2t3ll8 s4/L6 s6lL2 s8/9 s8l18 s8/19
Leglre 2t?.120 225/20 2L4lL7 zr'lJ.t 2L5lL7 2]-5lLe 39/L4 60121 621L2 62123 6AltL
officera t{t L8/2O 25/2L 5713 2L617 2t6/tl 2t6173 2L718 67/2L 6819 7slr5 7813 79125
2L7122 2L9/L4 222/t 222123 erl6 8s/2t 8616 86/79 89lS
225122 22512s zzgltr 2301L6 8e/10 9Ol3 9L/2L 9216 9216 9219
96/23 2r4llo 230/77 23lle 232/6 2331t1 23sls 94/7 9612L 971L8 LO3l7 LO4l22
fftclruyl
Letllryr l.J Leollr aBrlLg
t2l rrv.. 238lLL 239114 240/18 24Lls 110/10 110/16 LLOl27 rLolz3
rcl.arr f.zl 25/25 27124 24ZlL8 LtLlLr afii3 LLrlLT tt6lL4
rntruet'1 [1] 144120 l1z1 67lLr 67lLL 8813 tL6l2L 7L6/25 LLTILL LL1l24
t2t 62le L5O/24 98/10 100/10 L82/2 L93l2L tL}/L2 72018 L2o/Ls t2t/t8
t6{f itltt ttlz LsfLt
L3lL7 L'
L7l62LL/23 2L3/3 2L7lL6 23713 23811 L2217 L23lL5 L25/r L26lt3
kaYr [6{f iTlLL L5l2 r27/8 r27lLr L27/20
17121 L9ll6 2O/L6 22/2 2312r one [?1] 8/2 913 9/25 rL/L1 L26123
25/L6 31l2t 39/s 49/9 S8lL2 LLlrl 22/LO 2317 241t7 2elt3 tzsls t2el7 t3ol2 L31l2t t3el23
6611 67lta 7sl8 8216 82/8 8rlL8 42124 l4l1 44lLO 481L2.81L3 L4Ll25 L42120 1'50lt9 L5415
sL/2 gLltr 9LlL1 e2l20 9312 srlLs s6l2o 5717 6slL5 6719 t31122 ts8/22 159/3 159/t0
LO3/23 LOll3 to,lto 106'/10 6812 8218 8312L 8't12 8918 971t8 L6O/23 16215 L52lL3 L65/L7
LO7lt3 tDrl4 110./8 113/8 LO'l2s LL3l23 IL1lLl Lr8l9 L66121 t6el6 L6elL4 L70123
'-Lol[ 132123
Lt9l7 Lzrilt2 L31l2O L2s/25 L3O/23 134/20 r38lrr Lltl't 773122 L?'|LO L78/3 tgo15
L33/L7 t3E/16 L{'OltA l$12 L38l2O L4O/2s t4715 L(LlLr 180/1s LgLllL L92|LL L83/L3
r5:-t8 LsLitS L62t1 L6413 L66/L5 trLl'{ 1{1/15 L47/L6 L42lt8 L83123 1S5/u L8613 L9L/18
r7o/22 rltlLo t7419 L17122 1'18/11 L5O/2s L5l/2 ts4lL6 L92/20 L92/2L t93120 L9u4
78o/1 Lgal2o L98lL7 199/4 L99lS 155/19 L59/L2 L64/L9 L6sl23 Ls6/6 te6l7 2OOl2s 2OLl4 2OL/t4
2LO/t6 2Li/5 ?LB|LL 2t8l20 L68l2O L74/24 t14l2r L1Sle 2}gllt 208118 20917 2O9l2O
2ts/L3 22i/L8 2271L7 238/22 17s/L4 L7813 L1el2 r8o/13 L9sl2 2LOl27 2L4/22 2LslLg 2L615
old t2l sq/8 62ltt LsTlLr 2o7lLL 2L3125 2L413 2L6/23 2L1/L\ 2r9/rr 22L/4
older [1] itzslzo 2L4122 2rs/ta 22L/6 2231t3 22lls 22L/L9 22L125 222178
acton [}l Le9/L2 223llr 22819 2351L8 23718 22316 2231L2 223/L5 225/2L
.'I
268
c rv€rYhelrllng [1] 2L619 peer [3] 22/L7 22/20 23/2L

rxed [1] 3l/23 P€er! [1] 23/L2
lor... aBl :225/23 229lLr 229/Lt )ren [1] 9/13 Peffall [1I 25/L4
| 23s/s 23u.Le 231120 23e14 rrn [6I sLlS 5213 8slLL 94/25 Pe,sw 12) L98/9 2Ol/7
I zt2/2L i 71-514 t57l1-t p€nalty [1] 59/11
p€ncils [1] L39/9
forder t23I'. S/LO 3/2L 6/1 9124 P
I ultc 4o/L7 s4/Ls 6els 69lLz pending l3l 6613 9sl2l 229ltt
| 98/25 101,/15 101/16 LLslLa p.u l3I LO2/L2 Lo2/L3 2Bl3 PENNSYT,ITAIIrA I{31 ll2 Ll4 L/LS
| 775/6 2o4l]^8 2Osl2O 2o9/6 23L/7 Pe [3] 3/6 176124 L7g/L7 3/8 7ls 9/9 2r/2 22125 2r/3
| 23L/Lo 23ih3 2s6/s 2rolzL pace [1] LO2/4 27121 5217 5619 s6lLe S7l4 57ls
| 2r2/e 7,
page [30] 75ls 7sll2 7'lt6
L49ls L49/e r5O/2
57/Lt 571L6 511L6 5712L s9ll6
59/24 631t4 63/tS 63/24 65/s
lorderly [1[ 3lL6 ,.341G L48/L3
ordera t2li 789/L5 231/20 L5516 LS9|L6 L59l2L r6o/s 65/Lr 7413 89/Ls 99lLO Lsrls
ordlnarilyi [3] t6lz 7L121 7L/22 L62/Lo 16316 L63|LO t63124 L?el7L L83/s L9L/2o 2O8/L5
original [3] 7l/15 9419 226/14 L63125 t6s/L6 167122 119/22 2L7l2s 2281L6 231/23 23418
orLginetedi [1] 2s/L9 791123 799/s Leel6 Le9/7 tge/e 233/4 2s5/L7 24O/Lr 24r/7 2.7/9
other [61] i 6/5 6/Lo e/5 Lolg 218/20 2L8/2L 2L8123 279/as penclon [1] 731l6
22/20 Xlq solzr s8lt5 sel22 2t9ll7 peopte t32l I7lL3 LSILG 2LlLg
60/2 60l'i62lLe 6slrs 7s/22 PaEe 1 t3t L3rl6 L67122 L99/6 29/L7 34/2L 37/t4 46/8 5r/7
7sl2L sOli OL/1 8Lt76 8LlL7 Page 2 [1] L9rl23 s6lt0 s6l2o s7lLs s8119 62ltL
821L1 8r/13 85122 87ls szl4 Pase 3 [5I L'glr' ts9/2\ 19917 621t9 79/5 80/t3 8415 84/s
9211 9219'tO6/6 t2OlS r23lL2 2|el20 2tal2L 84/16 LL4ILL Lr5llg L3514 tsrl3
L30/2 t34/2' 137/L7 L37/L8 Page { [3] t6316 L63l2r t63125 L5414 L72/L1 L72/2r r79ll8
Lr6lS L18lt2 rs}/8 L76/l L84l2O peger tl! 7514 t86120 208/L6 2t3lL6 229lLL
208/4 2L3'LS 220/20 22319 paper [12] 2ol9 2oll-o 37172 24L17
223123 22Q/23 22512 225/4 22s15 37 l2l 72/1L 140/10 1,00./10 People.coa [2] 317 L79/LO
22512L 225lZZ 225125 2281e 1321L7 L7614 L7615 L9O/2r 208/6 parcent [6f L96/Lg 2t313 2L318
22elt7 22tl2v 229121 23OlLo paperr [1I 3216 2L3ltO 2L3|LO zr3lLA
23:-lrt ?36113 23118 231123 peragraph [{3I 751L9 151L9 p€rcentag€ [1] Ll?14
23911 212'1.2! 7s/2L 7613 761L2 7712 77/8 p€rfect [1] 2316
others l4l ,2Sl2 6OlL3 S613 17124 1819 8Ol7 80123 8217 e218 perfactly [2] L2lL6 59123
L56lLe I 82/rL s3l3 8316 8316 A6l2L 8716 perhapc [5] s3l2 LLB|L2 t8l/L7
orheriso ill 20216 s7125 98lLO r3rlt7 118/L5 20617 2O9/2s
our [16! E/L3 3lL3 6lLo 712{ L58t2t 163/10 L6418 L6419 t8al8 period [5] s3/L7 s3125 5sl]-9
sn4 ell8i.9l2 2615 26lrL 32/20 tetll2 19r/2L t94122 ?L4lrO 5sl7 rLol2o
34/2L 3sl9 38l:-s 69/3 8319 2ls/lo 2L5123 215/23 2L6124 perJury [6t 220123 221ll8 2261r
t5al2 f 2LslL4 220/3 22013 22019 220/Lo 226/20 2271r 221lls
out [63] i!/6 3/9 23ls 2e122 2221L. 22u2O peraanently [1] 221/L3
rolg r6lL5 4118 1elr7 sole Paragraph 1 [ll 75/2L paaairrlble [1] L14/3
53/L2 7Ll6 1213 72lLO 72/L2 paragraph-\'-paragraPh [ 1l penJ.aaion (6! LLIB 7Ll5 96/70
721L7esle 86ltB 8712O s2lL4 751L9 14LlL2 23319 2341t5
9Ur9 gsll} LO3l6 t}el21 110/17 para.nount [1] 32120 petait [1] lr4l24
L2L/2 L37124 L?81L6 LlOlLg paraphreae [1] 82/9 peraitted ltll rL3/L6 l46l2L
t45/LL 1{6/1r t$lll 1s{/18 pardon [1t 49/a 746122 L74/2L
L62/LS L6413 L6417 L6elte parre [{I 1313 L2Ll2 zollLs perlt€ttator t2t LrglL3 L5212
L72l2s L7?/2 174/3 176123 2L2ltL perpetuity [1I L2412
L78lr6 L79lL2 180/17 181/10 parc [13] r5l:-8 38122 rtl]-e perrlatant [1] 36125
t87122 1e0/18 196/1s 2O0lLs 4rlt6 171L6 stlrr 7916 921t8 Irrson [21t L3/23 tilLl 2el7
2O4lL6 209/6 2LO|L3 2LOl23 r3sl6 L89lL6 2i2l2r 2tolL7 2817 28lLo 29/L5 4413 53/20
213/20 2L6/2L 220/23 2221L8 2L3lLO 6L123 6418 eo/s LLs/2 LL8ll?
223/6 225724 22slL7 229/1.8 Parrlelly [2] 3914 2t5122 L2619 L8317 r84l2g 181125
22912L 234120 23s17 partlcular [8] L8l4 5919 941L7 189/19 2|8lt5 233/14
outcoqe [2i 73/4 237120 LOs/s t:-8/2s L29lL3 r37/16 [1] 29ltl
p€lronrr'96121
ourllne l2i 7124 811-7 L99ls peraonal [1] 197/L1
ouceide [1] L36l2l partlsula!1y t1l 291L3 peraonally [7] 59lLS 1tlL1
ower [33] 2/L2 3/9 L2/L7 LSlLs prrticulare [1] 4L123 7L/re 7t122 LL'116 115/18 17{/8
22/L6 2elL6 {7/t3 53/2t s6l3 partier [15] 6612^ 67/L9 77/7 p€rsonn€l !21 53123 5ll\2
s7/2 6o/Lq 5elL2 76/23 791L4 78lLO 84125 86122 Lo:.lLT 13219 perrona [3! 8Ol9 8613 156,/19
87le LO3l'! 103/10 ro3lL4 tL2l3 L9u23 L92lr2 tg2ll.r 2L5lL3 tr€?rt€ctivo [{] tSl2L 33124
LL9|L2 LLal2L L3813 L38122 215124 2L6l? 2L6lt7 21113 11/20 Leo/s
13e/s 1soi17 LS2IS r6o/1e pertc [3t 56/15 t,2315 198123 PETITION I2I LI$ SI23
L6o/23 L79lr L1elr2 L19/L6 party [6] 3714 s7l7 s7l7 5718 ph lll 2L3l?L
rs4l23 2Lill 83lLo 23315 Philadelphia [12] 22lLS 2612
overall [1]- 33117 Pecs [3t 2/L4 t47114 L47l2l 2613 2617 311L8 43120 7414
overcooe [fI 621L7 LLslL4 pacsaEe [2] 2917 67lLl 76123 85/16 Lool2s l18l1s 21619
ouernight ['1) 10216 pacred [2] L3|LA s2l9 Phlrllpr [55f 5216 S2l9 52/L2
overrule []l 2715 Ll4l8 parr [9t 80125 t/1/L9 L3tl6 521t5 s3/L1 5412L 51123 s4/24
overnled [3] 351t2 42125 L56/2 L5615 L6Ol14 L72/!o sslLo sslt6 sgl4 61121 65110
7r6lLs i L86l2L 2O7lLg 6s/22 6618 661L9 6713 6'tlt6
ov€rsee [1] 2412L Patrick [1] L8418 67/22 851't 81/L7 9L/5 981t9
ovetsaeingi[1] 205124 paused lll LI[ll toa/6 to9/2 !09173 7L0123
overture Itl 111/13 pay t{t 11t2 s4lti 6Sltz 74114 1Ul10 L26|LL L2815 L28lL4
38/20 4\/7 43/t8 r4l5 44/7 retion tzl 12/2L L21/6
48/L2 4s/L3 4S/L8 sLl2O sLl22 re [1] 7s/20
Phtllipr..i t2l1 L28lt9 L29/7 531L9 34/L6 5r/L6 55/L2 35/2s t3l t60/L4 t60lL8
Lzglt' L74122 t8L/L6 L8Ll25 5613 s713 5919 6Lls 6L/L6 52/r L72/77
L82/6 L84/22 L84l2A tSsl23 62/L3 62/L8 62120 76/23 771L3 ror [1] 160/ls
L88/9 r88lL2 L88122 L8918 71/2s 77125 sLlLL Auts 8L/23 ring [11 72/tS
L89123 r92lL2 L92lL6 Lgrll2 84/e srl75 Lt4l22 tt4l23 7L912 r [91 5/6 47/2 69/24
232/t9 23i/3 236/L7 240/9 L76lL2 180/19 L8Ol25 tgL/rr to2l21 Lr9l5 L32lL7 L87lr2
240/Lr 24+/2 225l\s 226119 22812s 229/re 20312s 2A8/t7
'hilIIps'Ill 237121 229125 red [1] 25lLO
'htlty.cou)[{t 315 3lt3 L16122 11ce-{nltl.rtod [1! 5613 l1l 617
2Le/4 t uto [1] 2oolL6 ts t1l slt3
tl1tg s./10 551L7 58/6 t1l rolzt I te?l 3l2L s/9 5l7s 8/3
7s/2L 79/Q 79ltL 791L3 1elLs Pope'a [1] LB/tg 64122 68/t1 69/6 7ol6 7AlL4
LL0/2O LLgl22 t83122 Ill L4eI9 7L/L6 ?Ll2L 72/L6 73/11 73/22
copy [1t 7L/t6 t2l L8l7 Lgle 7r/t6 7313 76124 Tele 7elL4
e t1l i 73312s t12l 9llLl t23ll9 soltL s5/9 87/22 8e125 8e123
t5! izln zels nzlz L33124 L3u3 L47l2t 7s4125 101./1/t LOll22 LOgl4 LOBI6
154119 L67lLr L63ltO L85lr 2oLl4 206lLL 2LLl8 119/16 LzOl7 r2tl22 L2213 L2219
t1t 69/tO 2L2l16 L22lLt L2zllr L22lt6 l22ll8
l2l 13/7 L6Ol8 azl 9418 L26lL7 L22122 r23/L7 t23/24 t24lE
12l l4l1 4al5 t2t 8613 ts6lle L2419 L24/73 L25/9 L2e/L3
ttl,, a3l2s tion [13] TlLe 8n4 elLB L29lt8 L3A|L4 135/11 13s/1{
nt t{I t6LlL6 elz L3122 L./2 L6/r5 t8l3 281L5 13s/19 r37l2s L38/L7 L14ls
t6t Islr1 2LlrL 2sls 331t2 r9/2s s6ll9 Lr2lL3 20217 L48lL7 1{8/1e L48l2O L5rl23
ieja i6irli itlons [1] L6l2 L52lL3
L54lL2
t52l2o L52124 LsAlLL
LSAlLr L51123 Lsll24
trintiff [8] 88lts 88115 8sll7 eive t1l LOOI2O
L2218 2LO/6 2LLlr2 2LLlLe 2L215 ty t7l 6rlto 6L/t3 !s6l11 l56lL7 ts9/9 159/10
latnriff'{ l31l t'8l3 L89lt3 62122 67lLL tOOltT 22L|LO L6On6 t6]-l6 L6813 L7816 L7818
LsOlzO teLlz4
19olr,5 L9O|?O
190/3 190d15 Lgl-lzr 228120 L96122 L91lt3 2ool4 zooll3
L9212 t9244 L92lr4 L92lr8 t18l 316 3311 szlL5 2'Oltr zoolLs 2ool2o zool2L
rszl2r 195/3 195./9 L9S/11 s2/L8 8318 ].12125 L(S/s L47/r 2OLl8 20219 20319 2O3lL4 2o3IL5
208/25 aLL/LL 2rrl9 2LL|L6 11718 L47lLO L76/23 L78lr6 2O6lL4 209123 2L2/9 2L2lL1
2L2lt8 2L?/2o 2t3ls 2L3/6 ts4lL' 2L2/s 2L216 2tsll.r 2L614 2t2l2r 2L3lr 22011 22L19 2281L4
2L3/77 2Lil22 2L4lL3 2L4lt6 22tl2L 2301'.5
214124 23612 23'l2r 2321L8 $ry t3l Srltt 621t2 22613 t7l Llzr 5/5 47/2
233/s I9l 2/2O L65124 16618 69124 Lo2l2r L32lL7 Lelll2
Plainrtffr . a2l
[2I 2tol9
2LoI9 22glL3 L66/Lo L66lL2 L66lr1 L76/LO sunably [1I 134123
al t1l tgL12 L76lL7 LTelLo suBed (21 92124 L3514
r.an tsl lelL3 621L2 62123 t2l L{Oltg L0O/2O trial [2] L2lltg L2tl2O
141t3 L021.7 t31 r78l14 Lsol? r8Ll7 trirlg I1l L4122
ray tlt ietzt I1I LOls tty [1] ssl6
.+! ,^5!t7^ a. .< , t9f 77/LL 78120 83117 tzl L22/g Lsels
_1::*:?.
-pl,sAs
trt 'l,lz tala 951L8- L?L|2L LZll6 ts7lt,3 2oalt6 2o2l\3 lng I2l 98/U 98/rs
leage [15I en U6 L2l4 LZITO 2231L2 223/23 t t1l sle
38111 38/J6 6913 701L1 106120 r]'y t{l 421t1 57120 iour [2] 5L177 LOBl25
LO7/r LOAILI L2stL' L35ls r31ls L3Ll22 tll 3l2t e2124 $le
Lr6/23 zo\lts anarc [1] 140/3 8r12.
teared tli 2o6lLO ctotm [5] zlLt t3812 139/15 ila tll {0/18
Ieeroa [1] L34f24 L4Oll 1,4o17 inariry [3] 2217 2', 124 85/6
Iearure lfl Lt2l5 r I11l 6lLs 6s178 L\8/9 tnciples [1] 612l
led l1l 2tl2r 2O8lL6 2L912 23219 2341t2 rint I?! r38l2L 140/10 1tt0/10
t1t r8713 2341L3 235/s 2rLl8 241123 L1716 L7813 L78l2r 198/1s
I3l T|LO 7/r5 LL3l2s t1l L21l2L ntout [1] 14018
t{91' 13/18 L5l2 32/L8 tl.oner [2] 183/11 L83/L6 s t?l L3912 L4018
3sl].2 17125 4815 191L1 5LlL9 llt 75ltt or I8l 23124 43/20 591L3
5t/23 SSliS 6OlL2 5313 6512r ge [3I LS5/t6 1S0/18 s}lto t3glLr t48124 16214
681t7 741? 7ilL7 a3122 86122 t7slt7
8sl:,8 8g/i3 solt2 s4lLs e4/L9 ly t2l 76/20 2t2lL1 11l 59/21
LL'|LI L27lls L2912 t33124 uded t2l 22212t 22318 vately [1] 11613
L3617 t4oltg l'ls/s 74s123 tor [1] 9216 vlleEa [{l !9516 2ALILB
t48lL4 LrBlZt LS3l22 LS4l2 Ill 23/Lr 20218 240122
ivileges [1]
75516 L62it5 t6417 LSOI2L L8212 t?t t5l7 Lsle 201/17
Ls3l2O Ls!t/22 Lse/23' Leel I ns tll 5/t9 I1l e9l1s
2ltl25 2Ltiltl 223/3 232/t2 Judico [1] rDl3 te [1] 216/5
23slte i2 t3t 6017 621L5 tlll 2L125 86/t2 LLLIg
oinred J1l L36lrL 11{/11 L5ll74 L13|LO t82lL4
oinring tit L62/9 L9L|L0 ininarily [1] 261L3 t82l2t 18r/19 Lgrl2l 185111
t1l 18122 relluinary [4] e/$ t0ll0 ttve [4t 6011 521L6 SLILO
tssl LSIL2 2L/3 25/23 38112 L2Llr1 EtlrL
2s124 2613 2611 2619 26/LO ture [3] 7l$ elLS S/LB t1l t4113
zeno 2ell2 28/t4 3ol8 311L8 I1l 6712 tet 29t16 31n 3e/6
109,/16 L4612 L47lLL L54120 purposeg lrll 2oltB 38/Ls L6olL0
P !s7/L2 L81.13 L8213 t82/23 L8813 I t66/22
lproblaa. . ... [6] Lt4/L5 ll5/23 191,/10 L92lL0 L9319 222/L7 pursuant [1] 26la
| 741113 L7313 20L/L3 2L3/LL 222/20 223/5 2231e 225/4 2231e puraue [lt 799111
lproutear t3l s7 l3 L73/2 l-73/3 221lLO 23t17 232122 237/2O pursuit [1] 2L5/25
procedural! [1] 94/l prosecutiona [2] 55/23 85/Le push [2] 1,2/2{ L39/LO
procedure ,i8! 6/8 e/L6 :-olLL proaecrrtor [29] 2/17 2l2L 2t/4 pushed [1t 23918
L2/6 2Sl4- 2s/4 zslLL Le0lts 27/L7 2el3 37/s $/2 r8/9 49125 put t30l LzlLB Lsl25 L6lL4
proceed [5] sl2o 612 LO/6 t2l9 s5/2 631L4 63176 Lt6/9 rL6llo 28/L4 72lLt 12/L5 77/2 77ls
17/6 fr tL6/L3 LL64L8 Lt6l23 138/10 77lLO 78/Ls 8619 86lte 9tlt2
proceedl-ng{ [2] 5122 6l2L t52/7 tszlll, t 2lL8 L65/25 9613 7OOl27 101/1s L27lL4
proceedinsll [9t sl2 16123 661L3 L56/L8 236122 2371L7 2371r7 t4o/22 L72l2s L9Ol22 r90l24
6e/2r tozlL$ L32l1r ts1/9 243/3 238/L9 239122 2r2lL7 79o/2s Lgt/s 276/2r 2L9/tS
2t4/5 i prosecf,rtort r [1] t22125 2L9l2O 22O/9 22O/tL 2201L7
procear [5i 5lL6 6712r lL6l24 prorecutoriet t3! 2713 4918 234122
t24l2v 1e5/16 20sl2r outt:Lnq [1] 2L211
proaecutorr t3t 2712L 53/9
produce [1] L7ll78
produotion [1] 8O/2 t3412 I
profeerionaf t2l 68lLS 781L3 prospectlve [6] 7416 7418 8Ol4 queation [51] 27/8 3O/L4 33lLO
prolecrionqDy t1l 3ol2l e3ltL 2t6lLo 2!717 331t8 3slL9 4LlL2 43lLo r3lr3
progeny t1I 9lL3 proteat [2] 4o/L7 23311 r3/L6 4slLt 4sl2o 1s122 46/9
proJecr [1I t59lt7 protected [1] 913 47lLL 67/2 72lLS 92l2tt 92/25
projectod [2] La'Lll LSLILG protectlng [1I elln 9318 toTls LL3lr7 L2414 L24/s
prodae [lf L23l2o protoction [3] 9912 991L2 991t9 125/2 t2sl3 r25l2s L27ls t35124
pronired [Ql 90123 24OlL9 protocolc [2] 2618 zile t36/8 L36/9 L37/2 L37ls L37/7
prouoted [dt L5l6 L5lL4 L5lr9 prove [3] 881t7 LtrlLo 11{/13 L3719 L4413 L{rlt3 146/L9
L5/24 t proveable [lt LL3lLl L46/22 14612l tr1l7 t49/22
proooti.on f,lt LS/S proven [rlt Lo/L1 LOllS 60120 t5ol21 LsL/1 Ls1l22 L1Ll6
pronpr alli 261L5 27lLO rrl2 88120 t7LlL4 L8Ll8 209le 22r/7 23L19
76120 provide [5I s2ll2 60/25 66122 23u2s
prouptly tit 27/23 t97lto 2331s questioning [3] 7013 to2l24
proaulgate{ [1] 5lL3 provided t9l L8l2L 39124 1812L t2elLl
pronouttcoSnte [1] 73/22 L2Ol6 L22/lO L27lL6 135/18 quections [19] 351L3 38/7 38/9
proof [2] 8318 2L6la r37lLO L[elza r2l2s 93120 LLLI2O LL2/5 t6OlL5
prop€r 121, 3613 41-lL2 providing [1] 9Al6 t6ol2l t5sl8 La?llg 20213
properly tit Lg7ltL public [{91 SILG tglLo L8/20 223/L7 2231L9 230/2 23L14
property [il 2331L4 L8122 3719 10123 5ol8 57125 238123 2391L5 2391L6
proporitio{ [2] 183/6 a83lL9 65/2 66121 6915 73la 73122 gutck].y [{f 321t6 33/3 3517
progecute t69l 7l2s 8l2L gl22 solLl 8OlL9 s3lr7 83123 85/17 LO3l75
-2tlL6 s6l6 s6/L5 921L8 LOLILI t2ole quid tll 99lr,s
24lIO 3O/t6 30122 3rlt9 quiat t1l 203/17
33lLs 1Ol6 1'9120 so/73 6112 t2oltl L2616 L3slt3 L38/t5 qnite t8l 2rll4 3215 s3lzo 72lS
67t2O 9rt6 99120 ro8l1 LL6/2s L45/3 7r5l2r Lr6lrl- L47lLL
L4el25 L49l2O LsOlL[ Lsol1.6 L2212 L75122 2OLl3 2O7123
Lt6l2s t'-en Lt9lL? t2o/Le
L2Ol2r L2i/2 L23l2L t,2413 Lsol2z LsL/21 LsLlzL 15214 quo [1] 99lls
L2uL7 12t/11 L?tlL2 L1tlL1 15{/18 t5gl2 L88lr8 2L5l2O guotation [15] L3Ol3 L4U23
L74llg L7612 L8r/t8 L82ls t8616 23512L 235/L0 2311L2 2311r4 L4S|LI L6Ol7 L62/LO L62/L3
L88121 L94lL3 L9llL6 t96ll4 237/t9 231122 L61lt7 L57/t8 16712! L67/24
tsslts 2ol1l2t 202123 2O1l2O publ!,cationr [1t A7 121 16815 t68/5 L6817 199124 z1-sl'-r
2}sl2r 2L218 2L6123 2L7lLL pr*rr"ity lzl 581L7 621to eolt3 quotationr [2] 20LlL3 20619
220121 22113 22LlL4 22Ll2r 83lLr e4/7 2L618 2231L2 quore [33] L29122 L31lL7 t31122
222tL3 223lLr 224122 225lLA publicized t1l 2351L2 L33lt7 L36/LO L37lLO L37lL6
223116 2271L5 2271L9 22712L polrrcry tll 83/25 8a179 Ll2l22 t38/s trg/s 1{9/9 r49123 t33/3
221t2r ?36l'3 23Ll2O 234123 21716 1s3/10 1s3/16 tsrl2 L62lL1
236118 ?3lt?3 23714 2381L5 publish ttS) L9ILO 3612 36/L4 t63lL4 163/19 r'rlll t64lt6
24olL5 24Q120 361L8 36/20 3717 371t5 3814 L$ILA Lill24 165/9 165,/10
proaecute.[ [1] t67lto ssl7 s7l5 e?lg Lolltr t33ll,3 L65lL2 L65lL7 t6sl20 L61/5
prosocutadr [3ill 2L122 27 12 L(LILO L7913 1e9/15 ztslzr 2L9125 22016
ss/L4 se/*4 64l:-e 6slt6 66/8 pubriahed [22] 2/t'8 36/L7 40122 2201a4
67tt 67hA 68/7 e7l''e eolL\ 4217 14/20 1rl2r eTlto e7lr2 i+rotad tgl 1{9/10 L4glLs LsLlz4
solL3 so/44 gelro Loolr 100/6 Losls to'r177 r33ll7 t5el6 I teilzt L76lr2 L96ltL 196/1S
L}sl2s L2\122 2021s 201lLa 158./t5 159,/19 L7O/7 L73/2o | 2oLl2 2oll5
20516 z}si,,s 2osl23 2Ltl24 t8ot2 L81lL6 L99lL2 2O7l2L latoEas tzl l6ol?s 22019
aL2|LO 2tal2} 2L7114 2L7lr7 2091L2 2L518 lR.
2L7124 22QlL9 233lrs 237125 publisbing [5] 36/8 37/9 12/L3
21011 6 43ls LsLlg lradio t?l 5elL9 L7315 17317
progecrrtlng [8I 6lL2 2LlL2 pulr [1] L5016 I nzte L73lt6 t73123 L7r/2
231L8 23125 2412 6612L 2OLl9 pulled [1] 2L1lLt lrej.se [2I 23O16 23017
2L7123 | puniehed t,tl 1419 74lLr 2381s lraired [5] 5123 6/6 Lol4 t3ll4
crorecrrtioli [rt0! 5/25 9/7 919 2381t2 I L8sl22
241L5 26122 301L2 33/t3 4818 Purdonta t1t 23215 lraises [1] 4L12
sol22 63119 68lts 7312s 7817 purpose
- [8] 4LlL2 lLlL0 66lLL fraising t1t 92122
Tslls 8il+s s8l1 e1/B e8l2r 6s7a Lt7lls 1{s/s Ls3/L4 2oL/8 lran t1l l7/L9
g
Lr2/2 LL2/t6 Lt2l22 LLIl72 to6/8 tog/tt rrs/L6 L6e/24
LL1lL1 L1glL7 L26lL7 128/A L8O/t2 2201L5 222/2r
rapid [1] lr{s/{ L29/5 L29lt2 L3ol6 L31lL3
rapict trli 9216 L34/24 L3512 L35/L5 LAzILL 1.O717
rato [1] 29123 t4316 L43/73 t43/22 r46l2s refercencer [3] 75/22 IO7lll
tll 23/4 L47123 L47/25 L4el8 LlgltB 20818
thet [3] i 82/L7 L42l2L L70123 L48/2O r4el22 L48123 L5L/23 referancl.ng [9] 7,O5/LL 105/11
ring [2t' Zlls ZSla L54lLt L54lt2 L59/6 rS9/8 15919 105/13 tgols L88/23 189./5
tLonale [2t 39/LL 391L7 L62122 L62124 L62l2s L63/2 LezlL1 L98124 220/4
rrle [1t\ ttaltt L53/5 L64/L7 L6Sls L12lL3 erred [10] 2O/2L 26/3 2619
Ilet 3i/25 3u1 31/7 3e/t5 L72123 L7315 173/L1 L73/L2 26lLO 26/L2 21le 3rlLl 8el2
q1/9 e5l7!e5/9 L7s/L3 L7s/L8 L73122 L75124 L15l2S 176lLa 160./13 160/17
t7slzo L7'r.lLz t77/20 t80lL' L77/9 L8417 L84lr4 185/1s ferring I18l 341L9 3515
Laol2o 780/23 L83ltt 183/24 L85l2O 1s6/10 rs3lLg t95lL2 to7l23 L3olL6 L44/LO r44lL3
2L1|LL 22Lltt Lgslt3 2001L7 2o8/L3 2oelzl lso/l.9 t67lLg Lgo/L3 L99122
re-a8!tr.t!6nt [1] L83lt 2LLl22 2t313 2ool4 2L6lL2 2L6/22 2r7/6 2L913
rc-intervidred I11 5ll9 recalled [3] L26lL4 12112 1,2712 22L19 22L|LO 223/4
r€-lirlsatd !{l 33125 3rl4 3417 recrlling [1t 126121 s t]'l 22319
3elLs i rocalls [1] 2oglLz reflect [3] 5/18 4715 t53/3
re-open [1] 2L7ltt receiv€ lat 18/25 20122
2212 reflected [1] 142/8
re-orlened i12I 9517 9519 L73lL3 tLo/20 t{l t0ol25 to9l3 t09lL2
a75/t8 L73l2O L77/L2 L77l2o r€c61vad I8l \9119 22/L8 34/L5 LOg/20
18o/1s $o/2o L8Ol23 l83l2r LOrl23 tO7l8 7t8121 130/13 fregh [5! ALlg 42/20 161119
22LILL ; L$122 L68/2r L70ls
reaclr [{l t59/1 6'lt3 ,L2L|L3 recolYLng [1] 106/10 freshes [1] L13lLs
,,4sls i r€cently [1I 14211 fused [3] L8314 L83lr 1'8315
reached [2i L45/22 L8212 r€c€lr [?l 161L6 461L8 69116 tll tL1/2t
roachlng lil 6ol2L LO2|L? t3Ll5 t32lL2 L8717 t8l 27lr 3e118 113/10
reaction [1! t9714 e tl1l L9/22 7olt9 tLelLl 138/8 1s3/1s L17lL6
read [rr?t ie/g rolrs nl3 73/LO 7Llt3 96114 Lo4/2o t2Llr L77lr 209121
73lr| 73/L2 731L3 79/L1 SLI2O L|llS L86122 2L613 23113 rdins [?l 6ltr 47ls 60/2
81120 g3/4 831L2 esl3 87124 rocogmiz€d [1] 2LlLl te6/t7 224lls 236122 2r2lL1
8g/L2 e8l\2 eLla e2125 9rl6 recognlzer [1t 28/9 rdtese [2] l1L/3 tg4ll0
s5/8 sel2isgls tos/te Lo3l2s recogmizing [1] 83lL^ rds tzl 8l2o 1L6/2L
J:o6/1 to77,2 to|l2L rL5/t9 L2Ll4 recollact [1t 89/7
gter [1] 23/LL
t2713 L29122 L[9|LO L6sl22 recollected llt ],-08/25 y tll L3s/9
L66lts 11$lLt r7615 r7717 r.collection t18l 25/L7 2711,2 I11l 33114 5alJ-6 60/L9
L77/L8 r1b/1 L78/2L 179/8 A:.ls 42120 5712 L3O/4 r1814 66lL{ t29/Lt t61lL( L6S|L6
Le6/LO L96l2t 2L8le 2!8/L4 L6Ll!9 L68124 L70/5 L73lL5 L72/3 L87ltg 22L/4 22LlL4
2L8/L5 22611 $LlL3 LsTl23 203/3 2O5/6 20618 tsl 39lLe 7613 esl6
reader lLl, L19lI8 206/18 2O7//r L22120 t27lLS
roadlns [5J 371L9 ro1l9 L75l2r reconnence [2] L87lS 23913 rolationchlp [5] 241L2 2l.3lLl
2OOls 22414 reconnendation [1] 2r'19 2L31L9 21.3/25 2L4l2l
readc [?l ieo/z eslzs r52ll-5 r€considor [4] 8512 2LslLl relativc [1] zglL'.
L62lt7 L6ll1-r zLrlLL 2L5lL5 2t6/t7 2t714 relea€e [56t 3l2L 681L8 7016
raady t6l :10/16 1212 LoL/3 reconsiderins [1] 777125 7olL4 71/L6 7tl2L 7212 72116
to2/23 tr7/12 tl]-le reconvene l2l L3211 24217 74/L7 15/3 78/21 7919 SO/12
real [1] 3llLl reconvened [5t e6l2l 69122 87122 88125 89124 LO5l23 108/{
realizetlon [1I 891t9 LO?|L9 L3zlLs La1lLo LOe/6 Lt9lL6 t2vl7 L2219 a22/LL
reallze [{i 8Ll8 97/L5 L5ol6 record [1{] 5/r8 113 LOILS L22lt4 722/L6 L22122 L23124
32/L6 r'l\7 r2l4 421L1 47lr t2419 1.211t3 L25le trlfs 154/24
L7'' lr5 i
reatLzed [?] 8712t 22515 5317 s6l5 70315 t31lzL ts3l3 ts6ll2 1s6l18 L6O/L6 L6Ll6
reall'y tloi 2elt5 4o/2L 4tl2s L60/Lo L96122 te7/L4 2OOll 2o0lt4
recordings [2] 5413 L37122 2OO|2L 2OLl8 20219 20319 2o3/L.
los/ll t2216 LBLlr7 LezlLs 2o3lt5 209/23 2L219 2L2lL7
202/t8 233/2s 234123 rocords [12] 4ol2s 53122 5415
ro.In [1] i85/22 5116 s,{lLo s4l2s s5/8 ssllL 2t2127 2lsl4 22Ol{ 22L19 2281r4
realtlne li! gzlLg 18/5 7812L 7918 7'lLL 79ILA 230lls 2rLl24
reason [23i 26125 1ol6 s6ftc recounting [1t tlll2L tsl 71123 e3123 e4l7
TslLL srli sutl ro7l6 L35lL7 racorrer [3] ,r5l2o LA7l5 LS1|2O 941L2 21214
r36lLO L3it2 L37lLo L37lL3 racoverad [lt 1llto releaalng [1] 2all22
r31/78 L3il23 L42lL3 t7t.l8 recovery [5t 127/22 L4719 retevance [5] 261L9 26125 30lLO
15s/18 Ls?lt6 20611 351L2 381t2
t?rlt7 z}itL7 2t'l9 relevancy [1] 33/10
2t3lts 22L17 22L123 "L2lr8 Recr [1] 214
rerevant [17t 2rl4 30114 301L7
reasoneble [1Ol 60120 82/L6 recrosg [1] 24L/al
11s/1{ t2ol22 L25125 rod [1] t2l2A 30/24 30lzs 3Ll5 3Ll6 3LlLo
La4lL9 32lLL 33/L2 331L6 3rlL2 Sslta
161ls Le6(2L 2O3l2A 204/6 r t1l 2/4
49/L1 50/5 111./10
reuoning [1] 73121 r€direct [3] 2231L9 238124 4216
iarrilrty [1] 5lll-l
reasonr [6] 3gl2l 32/8 2L'r122 2391L2
rellable [3] 6ola L25123 L6111
22513 2321L5 2331L2 radress [2] 60125 87llt
Rec,d [{t lzlg stt 3lL6 els reelection [1] L1lLg iance [1] 42172
recell [?1] 48lLL l8l]-7 13123 er [2] L63l2L 209114 rerieal [{l a3125 99122 70O/s
er€nca [10] 4L122 42/LL 9812 24t15
}t-tLs s'.l2r e2/8 roolLe LLol2s
2
I
reprelsntatlve [7] 65/78 89/15 138/1s t39/7 L39/ts L40/2 r10/s
90/Lo 9s/16 L7A/L9 t82/s LgLlLg t1o/23 L42/L6 L43/24 L44/7
relief I1l. 10/9 repreaentinE [3] 66/2 67/6 t41ll7 L4r/2L L5Ol5 L51/t7
roly [5] Tltg sg/z 4217 43/24 1.82/LL rs4l2 LSAlr3 Ls5/74 7se/13
reputation [1] 861L2 1s9/1s L67/22 L6A/e 168/LL
ins ltl 8lL3 requerr [11] 818 9l2O L0/I2 L69l2L t7tl4 L1L/LL tlt/72
121J- el2t ts/Lo 45/n La4l9 L0u22 tO6/3 LLLlll L7llti L72l2L L7311 t74/r4
c t2i 6Lls 21218 L97/7O 2L2/LS 235120 L78le 778/L'l 180/1r L82/r7
t1l i 10/20 sted 12! 4716 L07/2O 78318t8rl3 192/7 L92/r3 792/2L
reuarks [1j 2ool:s reguiro [2] 55/LL 57/7 t9r/L7 L99/23 L99/25 2OOl3
reueober [l5t 22/3 22lLo 27le resrrired 16l 16/4 6s/L3 8817 2O7lti 2091L1 2L3/78 2trl4
A0lL6 431/5 t3/L5 55/2L 5512L 991L8 t58/3 20rlL9 2t512 2Lsl2L 2L8/23 22L/L7
551L6 59/7. e8lLg 8919 89lt]- regntres [3] 233/9 23616 23A/L4 2261L6 225/LO 22914 236/t5
LO8/20 Lt9l7 7211t2 L2Slt6 reaearch [1] t1zlLl 23814 24Dls 24016 24L/L1 242122
7281L7 72612t L29ls L29/6 resolution [1] 83lLG righta t16l LLIlLG tL9/12
t2gllt 729ltt t29l'.7 13s./11 resolve [3] 731L8 86122 t97lLL t22123 L23/2O L23/2s r24/t6
L3s/L6 Btl20 L36/22 L?71L6 resolvod [1] 91/15 t2'lLO L7lll6 L8Ll20 LS3/L1
L37lLs trllzs L16/L7 L4el3 b tl{t Tltr els L8/3 18619 2oo/2a 228/s 230/6 230/t?
L49/Ls L50lr2 Ls4l8 tsrl'' 22tt7 22119 231L4 23/24 35lLO 238/e
t51/L6 t94l23 7'9lr2 L50/2r s2/B s4l2o ssl's Lo3lL3 111/8 t15t 3123 3/25 417 4le
r6L/6 L5rit7 L6tlLB r6216 L60lLL 2sll3 e6l7 LOA/L2 to6lr{ 108/13
t62l\9 L6llr L63lL8 16{/15 t1l 3lL2 t85lA L87120 190/19 t90l25
t6rl2o L6ll2L L65lL2 y t1l 135/1s t9Llt3 rg'lL0 2221r
16s./16 L61lL7 165l'-9
'-64l2a L67lLL t5l s124, TOlLt 92fL9 rlak t1l 5ol9
t67lts L6il23 16812 16813 L68lS LO4l5 toul Lo'lLL road [2] 49/le 82lA
t68lL2 16g/rS L68lts L68lL8 responded [2] LS7l9 L1ll2L role [1] 34122
L68l2L $c125 t69t23 L7ol9 respon<ling [2t 105/13 106124 rolec [lt 236/22
LIO|LO L1O|L2 l7ol2o L12|LA reaponre [{t LolL4 Loll5 Lo4l9 tsl 2o4l2o 2o4/22 204125
L76/8 L76lL6 L76120 117123 LOlTLO 20513 20512t
L78lr9 18q/rs 181/6 18s/10 rerponal.bl.litira [1] 47lL1 root [1] 29122
i;;iio iiit'rii igoTrg2o6/L5
tso/2s ibr.e t1l 72lIO roughly [1] 29123
ts3l2 Ls67Ls 19817 2O715 vo t2t to1l23 t37ls routlnely llt 89/tO
2osl7l z72lzs 2tsl5 2tel24 I2t Ttlr e6l3 ror [3] Lslz0 L3gl[s rr2ll1
redl Irl L63lL7 result [10] 2419 29121 581L4 t2l sLl22 LeLlL6
rr lrt zo9lLo. 6O/2L ssl4 95/rr 9el]-7 Losl2r I2l tlL4 24119
tll | 8/3 LO6ILO 2L3l2L T2I 85/LL LL'II
I3t i 60lS selL2 2osl22 resulte llt 5Ll6 rule [{l 401L8 t26l2o 23elrB
l2r. 6/LL
12tr 6lLL 242/t7
2421t7 I3l1al3 ro2l2r ro3l2 23912L
lu 591L2
t2t[ 64lLs esl2s regurfaced [t] 2OLILG
t3l. 67/L2 671t3 eelLL reaurrected [1t 61/18 tl?l 618 714 7lL2 8lL5
c lll Lool7 Le3lLO retraction t3! L96l2l 2OO/2 LO/|L L2l6 3616 6?/S 63/8 63114
rs [1[ 83/9 20017 6slrs 8L/2s e2/L9 LLrlLl 236122
rlr i3e/u retreadlng [1] LO}/L4 237|L^ 2371L7
tlt s2l6 rn I2l toLltg 2Lsl3 ruling [?l 331L8 371L5 371L7
reopening [t] l81ll3 returrred [2t L59125 L9213 39/L9 42/t1 421L9 19122
repair Jrl, 6218 returning [3t l89lt2 790/11 ingt [1] L6O/LL
rcpeat t3l I 8/10 12415 L49/22 zLOllo t1l terl4
repeatedly|111 2tgl21 reverce [lI LTglLg IlOl 316 LTlts ts[l2o
rephra!€ [/l LlglLo reveraed [3] 591L2 s9ll6 59/24 r7Ll25 t7211 L72l2O L72122
replv tll i'-7Llta rewier [10I 22120 23/2L 521L6 t72/24 L76123 L78lL6
t"port lrsl 3l2o 35lLF 3SlL9 521L7 t27/6 L28l2L L3rlLL nnalng i{l 95l1-e LTOlLg L7O/2s
t27/
s4lL7 L20lL4 t2117 t27/7
4L/7 s4lL7. L3t/22 L32/2O 21912 LTtl20
L27t8 L27ILO 129/23 L3rlL8 reviewed [9! tln 3el2/ 78lli ruch l1l tl7l3
L3sl22 t61l2o L88lt6 t8e/e 8Ol8 8OlL6 t27/7 L27/t2 L27lL3 t18l rl2l 313 3OlL3 43lr
Le2l22 t9?14 L93lL1 236125 46124 69/22 to2llg t32l1s
reported [[1t 43118 1612L 5918 rcviering [2t 3O/2O 2O3l2O 13s/10 135/11 t4315 Ll{le
6slls 76113 eLl23 87123 e5l3 reviews [1] 221L1 Lr6lL6 1S3l15 L54lL3 L6sl2\
LO2l76 L8u22 195/11 ge [1t 56121
reporter lpt tlu eelt3 $612 ait t3I zLgl2L 22olt3
LOe/2 L96l2r 2!tl22 2OLl23 242116
rae"ty tll t8l4 LSILO t8l2o
20612L 2(rlLO reriad [1I 17112
reporterra, [3] 7316 7316 rs3llt to t2t 73/tg 86123 LBI22
relorters i11! 7319 9416 137/20 tu 2sll4 raid [117] 6115 LolLg 23124
2orl13 righr [101] 912 9123 9/2s a2ll8 rltL3 4417s 41/20 rsl1 491t2
1s9./11 z0t/L2 2g2l2o 4s/L5 sLl76 5417 5419 5S/t9
2o4lL7 2ohlq 2$lL2 206/6 z}ls 21/L9 2912 32/25 33/2
s7ltl 5€120 s8l2o 6L/2r 6sl2s
rePortlng l{t 53/L8 621L8 62/20 ssll3 3712L 38/Lo sr/Lg s3lLL
Ltslr2 i gLlT 53114 s(lte 581L4 6o/Lo 68/20 85/13 8s/1s 86124 921L3 9s/9
95/8 Loll2} 7O/2 7Ll8 721L4 72/L4 77lLe 97/23 7O2/e loTlLr LLL|73
reporte l?i 99/20 too/1 LL2|L3 tL3/9 r]-6le t2o/L1
L21/3 L42123 L45/8 L4619 e5123 88/2L 89/22
LoLls 7o3lg Lo8/to tt2/2 LL3/t4 L2O/2O r2o/23 L21lLe 729123
r€pre!6nt i{t 63112 L23124 L3O/t7 t3419 L31/LO 134/18
tssltl Ls?lL? Lt'lLO 119/11 t2tlL} L2Sl22
131/11 :.3216 t33l2L L3rl3 L34/2L 13s/19 13612 L38/S
taiionr [1] L2tl9
1s3/15 153/1s 7s3/2O t58125 2OolLO 2LO/5 2LL/LL 2L4lLo
t5el5 t66/22 166/23 180/9 2L5/L8 2LslLg 2t5122 2L7lLO
gaid... tTll t39lrA L42/7 te2l23 r99lt6 2371r7 238/L8 aentence-by-aentence [1] Ll9l25
L42l2O L(g/ZZ 1rrs/16 r49l]-7 le [1] 7',l2L aeparlte [1I 225/24
L'Olt2 lsg/18 lso/19 LSL|2t leg [3] 17/20 rLzlLs Ll2lzo tenb€r t{6t 3/5 3lLL 3122
Ls4l3 L5572s 1s5/5 Lse/tr tll 2t/s 3l2r 4/6 {18 Lrlt6 t5/23 93/L2
t59/L4 L63172 L53lL4 L6slLL I2l L9615 196/6 9616 tO4lLL 106/13 106/23
L6s/18 L67/4 L67/6 t67/6 L67/11 rcary [1] 28/9 L08lt2 LO8/23 L09/9 L71/2s
L6819 169/23 t7O/25 L7L/t5 acenarJ-o [1] 57112 L76/6 L76/23 t77/73 L77174
,.7rlt9 r74/2 L77/13 r78ll9 t1l e3l2o L77lL6 L77124 180/9 180/10
t8L/1r 18+/15 LS!|2L tgellg IU 2slrs L8O/L2 L8411 18416 18{/10
L8sl22 Lelltz L94lr7 rerlt( I3I el24 to7l7 Lo3le L87/2O Lgal2l t95/27 L9612
re6l22 L9?/t8 7OO|L3 2orll t3! tele L3tl25 L96/3 797122 798/L6 20117
20LlL2 20L/t4 20r/LS 20L/L7 229/L[ 206/25 207/L6 2L9122 220/Lr
20313 zo3ilg 201/e 2o5/s 2LL/8 echeue [3] 59173 621L2 62122 22215 222124 226/23 22e14
2t3lt8 2Li/L9 273121 2lrl2 rchool [5] lU6 t4l6 L4l9 6812 230116
276/6 2764L6 2L7/2 21718 2L7lr2 2L413 sept6nber 12th [{] 176/6 L77lL3
2L7/L6 2Lq/24 2te/3 22L12 rcr€on [18t :-L/17 LL/23 36/14 L8Ol9 78OlL2
222/aO 222/LS 222lte 22316 361L8 36/2L 371r9 3815 4rlt3 14rh t3l L77ltr
2z,ltr z2ilZZ 23tlle 236176 70124 88/24 88125 L33/2O L62/LL L77lL6 180/10
23713 i t80/5 teo/6 t92/7 L99lt4 2L5/LL 22rd t2l Lgrl6 La4lto
rctoening llt A8/L3 c 23td t5t Log/9 L7rl2S
saae t22l \ZZle ZStt sO/2 12/13 aeal [1] 40/24 t87/20 LA9|2L te6l3 20612s
4sl4 1sl8:921L8 Lo2lL3 LLl/L3 rearch [2] 5Ll4 L4O/7 9epteober 2{th t2l LeelL6 2Ou7
Ll}lg t45/2L 716/7 La6l9 L1915 loarch€d [3] 5Ll2 1elL9 L3912 Septerber 25th t6l Lo8l23
L5Ol2 t63/7 L63/8 19714 t99lL7 searche! [3] SOl2l 3tl6 5U24 Le'l2t L9612 2071t6 2221s
2l9lt4 2t9177 2rrl7 lBarching [1] L7313 222/24
saaplec Jlf 29ltg geatc [3] 691L2 L3217 LS7l5 riec [1] 5ll5
ganctlon lil 23s13 second [16J L8l8 2915 48116 rious [1] 74lll
aanccion: fll 6llla 7613 161t2 8217 ell23 9L121 rloucly [1] 34/2A
sARtas 17lj Ll2s sls 4712 69124 s3122 LO713 Lo1l4 L35/25 1{8/1{ rve [2] L7l8 L7lL3
ro2/2L L32fL7 La1ltz Lssl6 L6S/r3 188/s t6l L5lt5 L5l2r LOOlzr
ret [2] L7212 17112 recondary l2l 29/2 4tl6 toelz Loelrz 239119
rawvl' [lt i139/9 reconds [1] 70124 ice [3] L7lL6 L9l2 85llg
sav [8] ril6 s3lL4 87124 toolL6 cection [1I L63/8 tcec [1] 2219
13e/18 L1alU 2r0lzs 22L123 aee [{1t tlls Lllzo 26120 3619 I8l 27/2s 5416 64/3 681L4
say [7el 2/zz zlz el2 elLT 36/L2 37122 52/16 331L0 1t123 e'l6 L88l2s 202/2 2LOl24
2i/23 281t3 s2123 36/L5 36/20 LO8l5 L2!/75 r33/2L 13r/3 ns t2I LLl23 LLaILG
31lLs 31lIA, 4Ll1 46le 5u2L L36122 13916 L4OlLo 140/11 t3l 80/LL 88122 Selzo
6712o TOlis 12120 7e/22 8Ll2S L6Ol7 L62174 L52lL6 L63ltL 14l LO9/L4 t0elza
8217 8llt3 9Slr esllo
97124 L63/L3 16419 t68/2e n3/t2 LLOI2 LLOI6
tool2 L0o/L9 ].os/L2 togl2l Llslls 77513 179123 t8ol4 t87lr I3l 72/19 L26/L3 235ltt
rL6lL2 LLE/2O tLTltO LL7l25 Lg2/1 Lssl2s 19916 L99lL1 2OOls aeverely [1] 85114
Lr8/3 L?OtLg L25l2S L3sl23 2OO/8 zOAlLO 2L5lL2 2LelL6 cer [13] 2/L2 L3/22 L4/7 LslLT
ls7lts J3ll?3 l:'/e L3el21 2221L5 239lLA 271t6 29112 55123 LL6/Lo LL6/t2
LrLlzL L4alLs t44/2o Lr'lLo ceelng [6] L9l6 L23ltO L33l2O 115/16 LL6/22 L38/3 t3els
1s{/6 1s{}r3 1s8/18 153/9 L39124 Llolr 2o7l2r t.rurl [1{l 319 LSll 22/8 9216
L63lL5 L6gl2 L66lL9 t6715 aeek [3] 2351L3 239123 23912s t3s/22 L79lL2 202123 2L7ltt
LTLltO L72/6 L1619 L79ll9 aoened t2l 2l/L6 tosltg 22L176 22418 224lto 224/L6
L7sl?o L8i/2L rs.zlr' L8613 aeeng [3] l-3lL3 3OILA t6518 22u"3 240123
L86ls $el,LL t88/2o 189/3 l9Dl9 reen [1Ot lLlL2 23i12 LLol2 eerually [{l 55lLg 6L123 8413
Lsol2o Lsil3 LsLl22 20513 LLOII t37lL2 L37lL4 L4018 22s12
2OSl22 2L0ls ?LL|L3 2L2lL3 !65/2t 2L6l2o zLBlLe shalr [2] t24ls 237ftA
2L3124 2t4ll3 2L6l:L 2|9ll7 seea [2] tLl2O 361L3 che t88t 2518 25122 2811 38122
227/rs ,38l'-7 aeizures [1] 233lll 38123 43118 r3ll9 441L2 44113
aying [51] 33lS 4LlL9 l6lls aelected [2] 23122 t,2618 4rlLs ruzo s4lt6 ssl'-e 5819
8OlL4 8tlr7 86le e6lr6 to3lzr aerf [{l 9913 991L3 119/13 6712A 6112s 68/2 7616 76le
LL2lr6 rt2l22 lLel,3 L2L/5 Le3l8 761L2 9olL7 esltg 95121 9sl2s
t3el2l 142/23 L1811 7181L8 gelf-incriainetion [6] 99/3 s6/S LO4l8 10s/10 Las/L6 Lo6l8
Lrsl23 ,.1ilLo Lrs/Ls L49lL8 eslt3 tL9/L3 183/8 LO6l8 LOCl2r to1/8 to7l2o
1s4/8 15{ii1t t5sl22 LsI/9 renate lll L6123 Lo't/23 LO7l2s to9/7 LL3le
aend [1I L9716 LL4l22 LL4/21 LLrl2S
L51lz]- 7s7124 L6uLe L67lLL '.L4123Ll5l5 11s/13
t6e/24 172/2L L7612 L76lL2 eondlng [1] 72lLO Lt.l25 rLSl3
t'sl2L tsalt' L9sl7 aonse [3] L3Sl9 2lLl22 2L4l2s LL'|2O Ls6lt4 t57/5 15718
2OOlL7 202/77 2O2l2O 2L4/79
'-9911-9 sent [20! SL/r 88/L3 961L7 L51/LL L62/L9 163/1s \63/L5
2L612 22O(Lr 22L/8 22Ll2O 22rls s7lL3 91/r8 Lo3lL6 LOll3 LO4/8 163/16 L63lL7 !64/t2 L6slLg
22713 227(9 227lLA 2271L8 roslL2 7O3/2O LO6/25 LOe/24 L7Ol25 tlLlLe L76lL3 181/11
109/6 110/9 110/19 l-7s12 t87lLe LA4/2O 185./13 185/13 t8'lt6
22elr2 23!18 L9312 L93lL2 Lg3lrs Le3l2o
raya [28] [COlrs 57/23 631L6 190/19 L9tl2 2O7/L8
ailzt ficia t33ls t33lto t3417 aentence I21l 73lL{ 19125 79ll0 L95lL3 L96|LO 2o1lts 2oe17
13{/10 13$/21 L3el4 L4Olt9 8Ol7 Sslzs 86120 LLe/25 Lr9l23 z}glt} 2OS.LL 2o8ll2 2o8lL2
L35l2L 1/t8l15 L9216 L9718 2ool8 2OAlt| 209/5 209llo zL3lLe
t40l2a L4Il24 L52lt8 L52120
ling [1] eBl19 apecial [3J 21125 6318 237lt6
enoothly [1] 77/S specific [1ill 817 5L/6 66/LL
lhe... lTli 2L412 2L412 22s/8 ao [3061 LO1/23 t9L/22 L97/2s L92/9
225124 226/3 227ltr 2311r9 ao-called [2] 27lLl 76/L8 t92/73 198/23 205/2 206/6
ahers [3] 105/13 L93/6 196/9 rociat [3t L76/LO L78/Lo L78lL4 206/14 207/r4 23s14
ahoch [3] 2o7124 20813 208/9 eole [1] 23714 cpecif,ically t10l 98/23 LLL|1
c t{I lrlre 7L9120 186/16 eolely I1l 23613 Lr2lzL 168/18 L73/LL 182/L6
\e7/3 ! rolicitlng [1] 22519 190/11 LgLl9 2O7/5 22L/12
rpccificr [2] 5O/S SLltS
rhorthanded [1t 120/23 coae [56] 20/20 29lls 29/24
chortly [1]' 76/L4 34lLL 4S/t7 33120 57/6 5717 t3l L43lL2 L4712
rhould t23i 6/2 9/20 4}lt7 581t9 63120 6411 66123 68/L7 t49lt8
4OlLs 441t2 18/2 84/LL e5l2 17/18 80/73 83/16 891]-8 92/S ion l11l 9slt2 LO3/20
9sl2l t23l.t2 723123 L27lLr 92/5 92/21 9118 94/ts e6/4 t43lL9 L4513 773/t5 L75/25
L28/2r L6uS 2L'lLr 2L6lt8 s7/23 LL2/S Lr2/6 ttelts t2712 77717O t11lLL l77lLg L?O/U
2L7/r 2201,27 220/23 2271L4 72712 L28/5 L3Ol13 t3O/L4 lSO/22
23517 238120 24012 r3ol23 L33l2o r3sl3 t46ls ationr [1] 97/2
tr Ul s2l7 153/LL t6'l24 L6Ll3 t7tl8 apeeches [1] 13122
hor [10] 134123 36123 3712 t18125 L$Ol6 L9OIA L94/3 205/22 lp€nt [{] 32lll 92/LS 7L9/I5
l2lLO 4{.lir 59/L3 161L7 961L2 22L122 224/16 22512 22515 LLg/20
7O4/L8 2Lils 229124 23LlL2 23tl:-2 238/L2 spoke [{] 5212 52/LL l8r/t7
chored ILI' 20617 238/21 2391L1 242/13 L81l19
rhower [1I 29lLS aonebody [11] L9123 4616 64lLO apokan [5t 431t3 43lLg e1123
rhoving [3] 4t/L8 trllL{ 180/10 881L2 LLrltg 116/16 118/1tl ILLI3 LLLIg
shorn [2] i3613 l?0llg L72l2s 2L2122 229124 233/Ls Spring [1I L6l5
ahuc [2I g5lL7 lrLlLS couebody'c [2J 29120 6Lll ataff [1] 32/L2
side [11t iZe/S Ztltt 8712 8713 loneone [6] 6117 6llt2 LL7lLs rtage l25l r0ll LOle 26123
LOOIL? tttl2 LgslLs 2L315 2L316 LL1l2O t2rl22 L2916 3LlL5 33lLr 33120 3718 39lLL
2L3/L7 2|4l2s auething [52] L6/9 2817 lOlL3 rr/t3 4'.lte 46/1 4916 491t6
aide'a lll* 150/9 {0125 12/23 r3l8 1u25 4513 68174 58125 L2L/2O L44l2L L5617
cides [3] (85120 8613 tS6lL9 1716 6rlLt 6rlL2 731L5 8ol3 L7O/L1 22815 228/13 22elL7
rigD t2l $ele ztzlzo 86/L3 9L/2o 9/122 e2l6 ssle 23uta 238lt0 24712L
risaature t{t 75lLl g9/3 212123 93/10 93/14 931L6 9812 1oo/19 taad [2] 2317 23olL7
233/11 ; to2lto to3l20 L3213 tl'ltB tandard [2] 8318 2L6/3
slqried [19] 72/9 e9l2 89/7 89/9 t38l1} taol2r t43/L3 L44122 tandards [5] 2114 30/20 3Ol2L
e9lL2 8el?3 e6l2l LO1l25 108/{ L48/e Ls2l23 ls{/s rs6lr2 relL0 23712
rs6lL2 le9lrs 20014 200122 L6O|L7 L63lr5 t63/L7 LIO|?L tandtng [2] 7lr4 2618
2Lz/L7 2L2/22 2L316 2L3/6 $6123 18e/11 te3l3 Le[l4 L91lS tandpolnt [1] 2g16
2L4lL2 2L4lL9 20016 2tol8 274lte 234121 23517 start [1I 208122
cignif,icance [8I L6124 271L6 235122 23SlL4 23$lts tart [9] 3912L 471L3 69/L4
27lLs 28/9 2elr3 7sll2 7ell2 aouetiae [1] 2L9/8 LOt/2r t''2l6 L3Al24 L74124
8Ll5 tinec [3] 29ltg 55/23 L6414 Llrl2s 22312L
if i.ei"'"8a Iq 2LlLi 27/L7 t1] 2e/22 rarred [{] Lrltl ro3l2{ 139/8
321L2 $/2L LeLlT t9tl8 Ill 19'!/1{ 202/t9
irence tli Ltslt2 orry t16l dIt
[rbJ 3Ll7 79/tL
8/7 JLf, ttlLL LO3l2 tartiog [1] L1ILS
inij.ar [1I 5812L Lt2lL2 t3Ll8 LrolL6 tr9l4 atarts [1] 2OOl9
tnple [1I i 3LlL7 tle/L1 75A/$ t95/LO 2OSl4 atese [t1l 2UZ S7 18 S9l2S
rnply tgli erlzo LLslT 113116 2O9lL4 209/L8 2LO/L9 zL'-lLL 98/24 L28123 L9L|7O L9l/L2
L54/23 reiltz 2O8l2L .2r0lto tt2\ Lg/Lr 3417L 100/1s 19512 200125 2OLl3 229124
223114 232120 L09lzt tt?lL3 L28/r7 L2913 rtated [,ft L2O/L7 L75/LO 2$ll7
ince [{l Izats gzttz tgtlg L74/LO L9O|LA L92/4 zoglLe 23817
2oLlL6 i 22rlL6 stateoont [53] 4ol7 AOILG 47ls
ingle [1] I 206/19 t3l LLLIS LL8lLs LL8l2r 181L6 $lt6 6sl2 6SlL9 871L2
tngla-aoaf [1] 206119 t1l 2ool2 ss/g sslL6 LO7l23 LLOILa LL9/2
t l22t is/t tolts a7lt4 sol3 I3l L69lL9 L1Ll5 LltlLL LLg18 LL9|L1 119/13 tLelz2
5OlL4 74122 Lctls L'3ltt Lo8l22 t3l 46lto t7Lll r7L/L5 L27le L21lL2 t27123 L28lL2
L2s/2 L32lS 133/1s L3sle LIL/L7 rourcs [1] 34118 L2SlLr L29/24 L34/t9 134124
Lr4/7r ttiltg L86l2s ,esl23 theaet [{t 2/LG S2l7 L5216 13512 L35123 t36/2 LA2lLl L43lA
223/20 23i).16 21LlL3 242/23 t4316 L4317 tr3l22 L1416 t15lL8
7\Lo ee/3 172/e 206/16 t23l 63/2L 63123 14618 tsLlLB L'L|2L t5rl9
1:^l:l
zLslL4 i 63/25 6rlL7 6sls 651L8 65/L7 1s{/10 L62123 t6312 l8'-l4
citg I1l
19lLO L83lL4 tgo/1 r97ltg t99lL6
8glr3 891L6 9OILO 9slL6 L74lL'
ritting lrfl 62/6 LOLIs L4ol2 2OslLO 2t,l9 2L916 2LelLL 22016
tsLltl 191/18 L'L|2O 2agl22
202/3 220124 223122 22618 2261L3
23218 234/ro 234/73 2311L5
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lruation ")161 77120 92lLs 9s123 23613 23616 240120 2261L8 2261L9 226123 226125
101/11 LLrl3 t2118 spen [1] 59/19 2291L9 229125 23015
tlxth
r-...rL
[2t :L72lr4 2L9lL3
"î'.tiqatlt
al 6t1 a t9t 23/t7 4513 s3/2 86120 "a"a.."ngs [il3l 39117 441L2
skillg lLl: 2'8l2t 101/18 LLL/L4 L72ls Ls'lL3 441t9 4813 48/3 r8l6 {slLO
slorer tl]i 102/tl 2O7 /13 AslLL 48/12 48120 19125 6tl2g
alowly ttt{ 2L212 , [1] t6719 62lLL 18lLo eols 8o/t6 8]-/12
snall. [5] ''-ttl3 t33125 L7716 rnq 16l r3l2o 8616 8617 a]-lt4 aTla 941L2 911L3 lL2l7
L78l2t 1oo/11 L4815 L4el8 1.ttl24 L20/2 !20/7 L26/r3
'-1814 sP€aks [3] 7SlL7 80124 91122 L29lLg L29/19 L34lL4 L46/77
t72123 L83lL2 786/7 L97lte 756/75 L86l2t t87/2 L98/s
s 20L120 20615 207/t1 20712r L98/L2 204/22 2Os/t 2L7/L9
atat€nents'... tf3l U7/2 Ll1/7 22L13 2L8/L3 235/2
L58/23 L5916 L6215 L73/23 ruddenly t1l 2t0l25 taken [12] 74/72 3S/2O ille
L80/L9 206/71 2ts/2o 226/L4 sue [2] 155/13 202lLr ee/25 LOzlLs L2t/9 L28/tr
227/7 2271.t3 237/L8 cued [3] L7t/L9 L78/5 L78/9 2L6/20 226/A 8A/LL 234/L2
ctatoa agli 9/4 2t/7 2L/8 5716 suffer [1I L57/2O 244/6
6417 6r/8':651L2 19718 zt|ls guffl.oient [3I 4Ol5 Ll4ll9 takea [1] 29/Ls
8tatinE [{l 3LlL7 3t/Lg L6816 t25/22 taking [3] 29120 771t2 75/3
L96/8 auggeat [3] 39120 rL/tL 105/19 ralh [15] 4s/22 46/1.5 r6lLG
rtation [2! t13/7 L73/S auggected [1t t33/L9 LLL/I tL6/7 7381L7 L42lLs
atarute [?j s7123 23L124 232/4 auggeatlng [2] 3L/L3 L99125 1s1/13 L?(llo teolts t9tl2
233/8 2sr2s 235.13 23s/L7 suggestion [3] 3L/4 2L6l2L 79L/2s Le2lt3 2Lolr 2LSl3
aray [1] lr'lto 23Sl2L rrlked [5] 77125 891L7 2OL/23
srsELE l9l1 t/20 513 7/2 46124 cutt [12] 6518 6613 s7/2L 8712s 204ltr 20s/8 gle 29/t2 16/Ll
69122 L02ltg L32/t5 L84lL2 88ls S8/9 9r/L2 erlLo 98/L5 tarkins: [17]
L87lL0 ; !8O/L7 LSOlzr 2o5l2a 9313 Lt2lte 158/11 L58/12 L7rl4
lt€p tsl 3213 3213 3213 67lLg rnruarl.ze [{l 5813 6511 S3/2O Le2l3 L95|LL tesle L99h5 20116
24L/1A 107 lLg 2LL/L5 22olt6 22218 224lLt
rtepr-5t-"a"p-by-rteP [1] 3213 curaar:lsed [1] 8312 lalks l1l 2341s
arePa [rt] isals 66/22 6elL7 ruuoer [?] 9712L 92/25 9319 taap I1l L5l/L1
89/25 ; 93lLO 93/L4 e3/23 782122 tarping l1l L26/6
slElrEN lll1," tlLT rArBAcK l?l t/24 sl4 1612s
STEITTRT Tlf II2L sundry l1I 21819 69/23 L0zl2o 732/L6 tATltL
rttll [1rl ; 23/L7 2rl2 3616 Super [1] 2312 tearn [3] 321t3 B2lL2 Lltlll
5s/L2 A6l!2 92117 e2/L8 7t1ls Sul>erJ'or [2] S6ILL L8313 technical [1] L69lLz
L39/r7 Lr?/2O L5Ll22 2L719 eulrrvice [1] 251L3 rEcsNrcrl}r [1] 31lLO
2L7123 22112 rupenrlelon [1J LSlg tectrnologry l1l L39/LL
rtop [2] 4U6 73/2L cuPPorr [3] 2217 L57ll5 L57lL6 telePhone l?l 5312L 53122 5415
rtoppins [8] lr5l3 lulTtorteat [1] 5312a 5613 S6lLo s1l2 t84124
ctoriea l1I L65122 rullpotfed [8] 63lLL 77 lIS 81176 tetevlri.on [1t 58/Lg
rtory [2] /LO1/L2 L75lL4 L23tL7 r23ll8 t'21|s 22L16 te1l [4{t 2SlL7 28lLO 3ell5
atrenge [1]: 16l9 239123 4L124 4s123 s2l1 S3l4 s3ll6
etreet t1l r 197115 aqrpreraed [1] l2ll23 55112 66123 66/24 67/6 7oll8
rt!€tch [1] LOtl23 Suprene t3t 591t2 59lLS 59124 83/23 s5124 10s/16 LO6/2L
rtrtctly [1] 57112 gur [1] 10/15 LO8.|?O tl8l22 L47l\t LAglS
ltrike t2l,I.tzsltg
142120 2lO/13 sure [33] l2l1 601'.3 66/L2 t5o/22 LsLl6 L64/L2 t68l2s
srrip [8] L$tl]-g 186/8 68123 831L5 83/L7 861L2 gslLe L72/t6 L7slL6 L88ls L92/2o
2OL|L? 22614 2291e 23O/s 24Ol2L s1l2O to|/5 Lt3l2s L2t'17 t26/4 L92l2t 193/15 L9el6 L98lL3
rtripped t?I L74ll,5 795/5 L37lr L39/22 L4el23 t64125 2O3lL5 2O5lL2 2O6lL7 2O9lL5
ecripping i6t tL1lL' 122/23 L6gl8 L7Ll5 L7sl22 t9Ll8 tgrl24 2tsls 22slL6 23L/2O 2361e
123124 L2Bt70 200/23 2otlL' 1e6/18 2OLls 2L313 2t318 2l3lto 237/L2 237|L{ 237122
rtripr tLl. L2llLS 2r3/r5 224lr! z2rltL 226/13 teUlng t1?l 3ol2L 7516 77/24
Ituff [1] 1150/13 227lLa 23L122 8s/6 861L3 8717 9elL4 tl5/1
oubJect tf[ slLg 6rlL3 691L3 aurfaced [2] 2L9120 2201L2 L22ls tso/1-6 L57/L3 r57ltB
aurpriae [2t 16/2 LlOlLS L6elL5 189/11 20616
941L8 { 208112 '€6/10
rubuir a2li sl2o t6]-l1 rurprilod [3] rsl23 2O7lt2
rubElrr€d t2l 916 9lL2 207 lL1 relrs [2] 28/L2 2og/L2
$bsotrting( tll ggl22 curyiwe [1] 4O/2O leaplc [2] 2Sl2S 7617
rubordinaeEr [1] 18919 rurpect [3] LI?|LL lS3ll3 233/7 terporary [1] l5l7
arrrrpoena [i1 6ll'-0 641t4 9LlL2 suspected t2l 53124 L2819 tendr l1l 2917
24L124 surtrin [1] 204123 tenaa [1I 203125
aubpoenaed [3] 651L2 24L123 surtalned [6t l3l4 82lLS L2|lzt tera [?] 7el6 L8l7 l8/8 64/22
24212 : 2O3l2A 2041s 204lLL 79/2t L4A/Ll L8917
aubaequentg[?l 4t/L2 6318 661L3 rrorrl I3l LL|S t[l!s Llf9 rerna [12] L7/A5 28/23 37/t6
slllg LOL|20 t2719 202/17 75/rO 841L2 9212L 97123 161'123
T I L71lLr 208122 209/2 24L13
aulraequently [1] l{.slLt
substance i6t 26120 3OlLo 3LlLl r.v t3l 2Ol7 3617 168/L6 Itest I{t t2l2L 29/21 381L2 6017
7s/70 LgLl6 LsLle rrb tll 3714 Irecttfied tl{l LL/5 981L6 LOOI9
cubrtantial [1] t7l2 teble t1l 6217 100/10 lLL/r tLLlrL Ll3lS 20312
rubstanttv6 [1] 3LlL2 tacttcal [1] 2917 I zosltz 2osl24 2Ls/L1 222/L2
aucceod [19] Ll3l2 t{3lL0 taiat [3! 83lLL 2L6|LO 2L117 | 236/L6 23815
L5s/2L Ls'all L56lL4 LS6l23 tate ts?t TlLs t3/9 L3lL7 L6/L2 lceetify tlSl 64/Lo 65/L3 69/2
Ls|/6 L57l2L L37125 r93/9 2OlLs 241L9 34lrs 381L4 38121 I aelt BBILu 9tll3 99lro1s6/10
LrolLT
succeas [2i 77lLg 86179 rsll2 461L6 4e/9 5r/t9 58/L5 I tttlzt tsslll L55/24
aucceggfulj; [6] 19/L9 83116 64120 6sl7
66122 671L3 681t7 | figlz ts2l:-L L94lL3 20612 23Lle
851L8 L27720 r5s/10 1s6l3 68127 691L2 70/L7 721L5
6sl3 | 23tlrL
ruccesrfully [ll 155/13 lsls 76/L6 771L7 s3lls 8512r Itertisying I3l 110/15 1s6/6
ruch [261 613 7/6 2311 4Ll9 8sl2s LOL/3 to2/6 t|6l20 Lo1/3 | 220/5
65tLs 68ls 13/s 82/8 8816 LO7/1 t}'l]g 110/15 118/ls ltegtiaonial I1l 2421t9
L2sl25 t3.(rl2o t42/23 L49lLL L2Ll3 t3O/L4 t,3tlL? L69lL4 Itectinony [3{l 4212 4316 45/L7
rs:-l2r $116 L72lL'8 L12122 169/1s L74l2L L7517 17716 L82le I aatza B7lL6 94/e Lt2/24 Lt3/3
l
i
t
t
thenselveg [9] L8lL7 2818 281L4 22/LO 2e/2 sLl25 37121 38/11
64/9 LL6/t3 2LtlLg 2L2/6 275/25 6L|LO 63/8 03122 8413 8819
€rtbony.E. t25I r20/s 233/4 97/15 LOL/LL LO2/2 L20/23
r22/2L L26l7e L2716 '-L3/4
J,2813 then [119] LOltS L3/24 L4/L3 L33/2s L36/23 t4o/3 t4L/23
L2s/25 L2bl21 t3r/6 r34/L9 L6/2 L6l5 L6/5 L7/1.7 t8/L9 2s/r L65le L67lto t67/77 L69/LL
t35/22 tslr/15 L6L/2r tgL/L5 2s/9 28/1t 33/76 37/L4 37/77 204/2 2O4/2L 2L8/21 22e/L3
183/1 L84/2 t86/24 ta1/2s 2oL/6 42/t4 49/L8 5212 s2/8 23O/2O 237/LS 23s/L3 234/a
2LO/7 2L3lL9 2Lu4 2Le/2 224/2 'O/LL64179 65/20
58/3 S8lt7 6413 23512 23712 238/L3 2r2lL9
23LlL4 24?/t4 56/4 66122 69/3 72/9 73/2 73lls aftor l3l 1A4l5 104/7
Iesting [1]' L2122 76/22 77/2 7Sl5 7e120 80/L6 LS2/tO
texr [31 ]62lLO L63/8 t6319 80/23 euLT 8216 82/L1 82/20 therefore [16] 10/13 5?/17 8015
then [31t Gln to/g 44lto 55123 84/Le 84/21 8519 931L3 93122 89/L3 L22124 L23/2L L2516
86/4 ezl4l92/r ezllo 1oo/10 97/L3 e8/3 eel4 9e/7 98lt0 ts7lL6 L64lL8 165/10 193/10
702/4 70312s t2212 137/L7 9912L togl7 LO2/6 LOA/23 LO6/7 2oo/23 2ollLo 229/20 233/22
1ss/16 L56/20 L'e/LO LTLIS LO6ILL tOIlL4 108/10 115/19 23812
L76/4 1751L3 r78/t2 L78/L2 L7el24 L2O/L4 L2tlL3 L2214 therefrom [5] 222/2 223/7
180/18 LAO/25 t96/22 2AO|L{ L23lLO L2rl23 t2714 223las 22s17 22s/23
2L7/27 22O/2o 226/te 23LltL L36/22 1{0/rs uolL6
1211L3 ',23122 thereof [3] 2419 1315 991L7
23313
--ra 237123
- --.4.-r
tro/L1 L0Llg L4L/L6 L52lL7 thege [29] 2gl2| 321L9 43/25
hank 116l z 519 5lL4 7/7 7lL1 161/18 L63lL6 l7gl2r L72/L6 {{/19 50/10 56124 60/2 60lt,2
70123 201t5 14122 Lo2lzs 108,/10 L1313 t75/2 t18/23 L8216 L8317 63/24 7t/4 8Ll7 1.L3/s LIA/2L
732/27 ]'!qnS 2(tltL 24alL7 L$I|LO tg{lr]- 784/24 L8sl7 L26124 L21/L6 L2918 L37lL3
24Llr9 24i/2r 242125 18s/16 78713 t87lL9 193/1{ t37l2L L3912 L{sl2L L46lL7
I 1s8sl 19s/r0 795120 19618 2Orl2L Lrl/2 L6s/Le L65/2L L55/22
[111] slLL 8123 t2/t6
'r ;o/4i 2OS/25 2OSl3 2O9|LS 2rLl24 t72/24 t79/r 22r/4 225/2
L2tL6 2s/rG 3o/r8 3LlL3 216/8 2t6/LL 2L6lL6 2L7lL1 they [111] 8122 tolLs 2t/77
33/t7 35/+4 36125 3712 371L2 2|9l2r 22OlL2 22214 2221L9 22112 22/L4 221L4 2317 2417
38/6 r0lr+ Arlze 42lrs r7l2o 22317 223/L3 223lte 22s13 27t23 28/LO 3215 36lLt 361L2
4912r sz/to 661L8 73/5 7515 225/13 2271L2 22919 230/L6 36/L9 12/L7 421L4 1619 r6/e
75ls 85lLi 81/Ls 8sl3 ssle 23L/3 23tls 236120 5o/5 s2122 s2/2s s3ls 5315 s5/8
s8lt8 eel7 roLlz3 Lo3l79 to3l24 theory l1l L14123 5sla3 ss/14 s't13 5713 sgl0 6017
ltJ./1 rL4lL3 trs/23 116/11 thero [1??t S|LO 5124 715 L2/4 6L/5 6Ll6 62/21 64/LO 64172
LL7|LO Lr8/24 t20lLA L2'ltr 721L8 r2lre tslLL L6l3 t6lLe 6s/9 66/13 73lS 73lLO 7312r
L2S/L4 L3318 L3slL1 L36|LL L9l5 2416 2alL3 2s/21 27/9 3tl7 7516 771L2 191L6 80lLA 80/21
136/13 fi6/2r 13e/15 r[OlzL 32lr 3XlL3 36/6 37/22 4OlrO AL/Ls 8L/22 8L123 g2/3
r43lr4 t.\123 L4sllr 145l'.6 4416 r4l7D rsls 4616 4815 .eltl 'LILL
8214 85/7 e3l2o e4l2A 110/10
tl6ltl L$O|L7 1s0/18 Ls1./L6 r8/L9 48124 49120 SOl9 SOILI LL[/L3 11s/19 LL1/2s 118/13
1s3/3 153;3 LSBILL LSsts r6L18 30124 s7l4 srlLs 5tlL8 51125 LLS|L4 118/17 L2O/L1 L2rlto
L6tlt3 t6itL3 L62|LO 1-6513 3312t s.l4 s4123 Srl24 551L6 L24123 L25lt L2917 t3515 t37l2O
L66/22 168123 L67/9 L67/L2 ssl25 s7lrl 3817 59lLe 6o/L7 r31l2L L37122 LrLlL3 L43/2t
L67l2L 16Q/rr t6elL7 !7L/23 6LlL3 6312 63120 6el'-t 1sl5 L6Ll2 l6Ll3 r12/L4 L?21t5
t7719 119120 Lgll].z L8L/2L ?s122 16122 7119 77lLO 181L5 L72lts L72lt6 t72lt6 L72l2s
t82l2l 185/re t85l2[ ].85124 79123 8Ll9 87/LA 821L3 8313 L7312 L78/24 L8Ll2 1S3/16
L86lL7 18p/s 193/11 193/1{ 831t5 841L0 g616 861t8 ssl^ 206122 zloltr 2Lol24 2L2/1
Ls6l16 Lsiil2L 20016 202/25 s3/22 sslrL 9712 e8l2r 9ell5 2L219 aL2|LL 2L2122 2r4llg
2tol8 2L3ljl1 2L4l2O 2L514 lOO/3 100/17 LO3lt7 LO3/2O zL4llg 22Ll2o 223113 2231L3
2tslLs 2t1/8 22ile 22019 22213 105/19 L05125 ro7l24 109./1s 2231L4 22115 221125 22s13 22s/s
22212s 22212s 22slLL 22slL7 ros/22 LLSl2s LzO|L1 r2ol2o 22sls 226lLt 2291L9 229120
22713 22716 229/8 230122 233120 L2Lls lzLlLL LzLlt4 L25lt3 229123 22912s 231/5 23816
235/L8t xqlzo
23ql2i 24019 L25122 L26/2 r3rlL7 r3slte 238lLO 238lLL
llel i 2215 2el2L 3OlL8 L36125 L3712 L39/7 L39/Le they'd [1] 23819
30121 32/6 6117 63lLL 631L2 L39l2s Llo/2 L4olrg L.0/25 they'11 [2] LL/LG 6Ll8
7"178 77li sLls e,lro 861L7 LrLl2 LlLl23 Li2lt0 13413 theyfra [161 816 25124 27124
86/22 s4li2 srl25 rL1l:-5 1{8/11 L55lr2 162112 L62lL1 L63|LS 3212L 32/23 331L2 3Ol7 8415
2LLILS ii t65lg t5716 167123 L7uL3 r79le 841L4 94124 9112t 9512 rqtl9
eherq t??t .LLlg tr.lL6 L82/23 LS3ls 185/21 191/10 L6215 t6412 17516
Ltl1s LLtlz L2l3 '-llLo
L2l2L L3lrs Lszts t93/3 L9318 r96lt9 L96122 theyrve [{l 32/1 3218 3618
23/7 211t4 2rl:.6 2rlL7 26lLL L9716 L97lt7 z0}ls 20213 20412 L27 lL4
28/LO 281t2 3el2r r3l2o 44/11 z0rl8 20r/8 2o4l1s 2orl2o trring tl1l e/2 2219 121L3 91125
4slL5 rsti7 s3l5 s3122 5rlL5 2Or/24 20'l2t 2o7lLL 2LOl2 Loo/22 r25lL7 r9sl2 206lt3
54119 s'llt2 s6lLS S7 122 s7 125 2L3lL3 2L3lr5 2t514 2L6l2L 220122 22819 237/23
58/2L 6Llir 6tt2r 621t3 6rlLO 2t9lt5 2L9120 220te 220ltl thinsc 136l L8l'.3 tSlLG 2OlLg
73116 73/17 7rlLO s'lrO 8o/L7 22O/r7 2zLlle 223/22 2261e 23/2L 29lLL 43125 1s/22 5LlL6
8Ol2L 8lli1 8917 S9l9 rtl/6 226173 2261L7 2271t8 22112O 5Al2L sOlLO 6olL3 6slLr 83/3
LLLILS LrtlLT Lt2lLg L2ol9 227123 228lLO 2281L2 22s/L4 s6lto 86/rs 861L8 8elt6 8e/2L
L22ls L22lS L24173 L2rl2O L2sl4 228lLg 22s/L9 22912 2291a 97123 tOO/3 LLL/6 tL3lL2 71312
L2sll L3O/,23 L37122 L38lL5 2291L3 22e/L7 229/L8 22e120 126113 L26l2r L37l2t L43/L9
L47/3 1{8;r1 L54lL5 160/LL 229/2t 230173 23OlL7 23L/7 L6L/r1 158/10 L72lr5 L7519
t62/5 L68'j2O 18s./1'S 188/5 2321t7 232125 23!lLO 23417 L78125 L79lA 2O8t10 2oBl11
LgOl2L LgIl3 zl4lrtt 2o5le 234/20 234/22 23sl2s 23612 238t3
20s/t3 206123 2L413 22L122 236/2L 242/L2 2421L9 think l82l L2/23 L3/L2 L3/73
22416 23ti2o 23311 2331L1 23712 re.r [37] 6120 815 L2l1 tslL^ LflLT ttl4 20/19 22lto
i
It
32/tA $lLB 38/8 3e/7 40/L5 tosards [11] L33/24 LS4/4
a2l5 44/79 4r/2L 44/24 17/25 1{1./19 trglt 119/8 L53lr6
think... t74l 22/L2 22/21 2312L r8l5 Stl2s 52ls 52/LL 54/2 L53/22 t54/2 162/9 L79/2L
32/LO 32/+S 33120 34/L9 40lLz 54120 s5lt9 s7/5 Ss/1 58/ts 2L9/73
4O/r2 1L/t5 421L2 45/24 16/t2 s9l5 59/70 39/20 60/8 60/72 I1t 26le
49/t6 55/Lr 6L/t3 62/L4 68/L2 6rlLr 63/4 66lLS 66/L6 67/L2 trece [2] 29/9 29/L4
77/L2 791L6 7e124 84/LL 88/L3 671L3 68/L2 7L125 7212 72/8
921L2 e2/13 e4lr9 tOO/Lo 105/15 74120 75/13 7s120'r6/L1 76/71 tra:lned [lJ L2Ll2
LO7/2 Lt3lLL rL3lll LL4/7 rL4/9 83/L4 86/72 89/!8 89123 8s123 tsraining [1] 715,/8
11{/11 1U/13 L2313 r27/r\ 9rlL7 9L123 92/9 e3/22 e3/L7 trancactional [3] 232/9 23e18
L34lr2 130/13 L42l/7 Lt 3/7 Loo/Lz Lotlg torl22 Lo112 23612
t4r/2 L4614 L4glrL L3L/24 L59/2 LLOI2O 119/18 LL9/L' ttslzo tlanlcrilt€ [1] L37/22
!s9/3 76rlt2 L6u2 L6U6 t54/t8 LL9l2t tr9/24 L25120 L2S/22 transcript [1] 24117
L6719 r70l20 L1Ll8 r1LlL1 L27lL9 t28lL7 L29/2 !30/14 trenaniraion [1t 150/8
LTL|2L L7t/23 L?zlts L72/L6 L3Ll7 t3alLo :-3r/L6 r3213 tranlEit [2I 12/r-7 73/2
L7316 r?SlLg L75l2L L77l2S L33lL3 L34l2s L35/3 143/2s tread [1t 9S/2r
180/1e L8il3 L}rl2S L96l2L r{ele L(}lts 1sa/2s 1s5/e triar [5I 23122 2rlLs 48/23
2OOl5 2OLt22 2oll2s 209125 15s./11 t5612 LsalLt t7ol22 881L8 t2L/2o
277/25 223/2 229/6 L7219 L7517 176/23 L77l't L17123 t tsl Lrl23 ts/6 t5/8
thinklng tQt 32119 s5/22 88120 L78lL6 L82lL3 L86lr 7981L2 L5l11 t5124
szls t4u4 rrsls rr5l23 a7Ll6 L99lr1 2o:-lLs ?OL/L5 205/g tsl {31L3 1Ll5 73177 8Ll8
thtnka l2l'r 3ll7L L4116 20slL3 205113 20slL7 20slr9 L6Olt2
th1:l_t{t il{/s Telto L22/4 2osl2 208/Le 221/23 22e/6 t2, 37119 ]-8A16
188/8 ; 228lLO 2281L6 23017 231/e 2391s 12t L76lL4 L8Ll3
hir t382t l tinely [2t L[9/LZ LSL|?I Ilsl 20/25 52lLO 51122
ttlts 59
[2] i 1{/13
honrt J2l
fhorors sgltz cLaeg [19] 617 2312 23/2 23122 76124 8slt7 9712 t1-Lls LL6ILL
thorough tt! L2?llo 4rlLs 9tl2r t:-Lle LtslLs tL?19 LLS|?4 L2L|\O t3612 1-54/8
thoae [59] t6l8 t8/L6 22119 rL7l2O 118/5 118/8 L37lLz L54lt0 167l''z L7212 L97l2O
23/2 29lLr ralLs 4tlt3 r8l3 L37lL' r37lL' 14018 zgtlt2 220/25 230/22 236ltB
1813 48/6ia!/9 5L/6 5517 s6lLl 227120 232/22 sted [1] LOA|IO
s7llg s1/?O s812. sgl{ 6tl6 tlred [1I zOSlLl cruth tsl 66lLg 7t517 L16/3
62/s 6212q 65./t4 661L5 7117 ricle t3l 891L2 96122 L38l2S 2081L2 2081L3
TelLO 79118 8Ol2 8Ol2 8o/L6 today [26] 615 6/L4 7016 to/lQ try I19l 5120 32/78 35/7 4O/L7
8L/2L 56118 8717 88120 e^lrr 231L7 3Ll2 4Ll2r 7214 100/14 5OllL 5512s s6lt5 63/L3 92/20
tool3 L'.2I2o LLslz 11s/10 LO2I6 LIOIL' IL]'IA LLLILL LO2l9 LO3l6 L26/2L L31l2O
116/1s tt7l7} LL8/20 LL8l23 Lt2l24 72015 72212L L39lL1 L3'|LO r47/3 LsL/13 16LlL9
L2Ol2 L2OI7 t2tl3 L2L/22 L2Ll23 L44124 2O7/2r 2LO/7 2L2/72 L9414 220123
t22lL2 Lzilr7 L46ls L4717 L51'19 22|ls 2221L2 22312 23815 242lLl trying l2?t Lrl23 ?2lLs 33/r
15s/1a t7i/22 L92lt2 20619 todayfa [2] 5122 L26/22 4L123 461t3 s{/2L 57le 8713
23L18 238y2 239120 together [6] 121L6 86lLO 101/1s 931t5 L2'lLr L15/8 L45/2r
tlrough 121! 9L123 L25/23 ro9l3 tr5l3 23u22 L47lLt tso/L1 t5al22 L52ll
trrought t5!l 221r'5 29/21 33lts told t62t 38121 53117 33/23 L54lL7 2O3lL3 205/LL 20612
3r/20 3r/22 36114 571L5 60ls 5414 S4l2t ssl:-6 6u23 6514 224120 22slLo 228121 2321L2
6t122 6413 67lLO 58/rL 77123 5s/g 66/Le 67122 67122 6712s 233/25 234/19 234122
18/24 19/L7 srlr $tl6 81121 67125 15/L9 9416 togllr rtolz3 y lrl LltL
83123 S1/Z 9217 LOOI3 LOLILa tLr/s L2916 L2919 L3O13 Lr2l6 brortled [2t 77 12L LLZ|2O
LO2l4 t'6l,4 70717 LLO/5 110/13 t72123 L7u22 LTslra L73l2L turn [13] 371L4 95120 tL2lLo
L2Ll6 L2ril7 L2rl22 L22lL5 r76/L2 r76lt3 L78113 t'Olzs LLLILL L4Ll8 LeBlL3 1s9/16
L22lt6 L2ilr7 L23/r L2slLe 181/11 18216 L8217 rB(llr t79ll6 L86lL2 195lt9 t9916
L2S|TO L26l2L L29/7 L43/L3 L}ll2a L84122 LS1l21 L85/L2 22213 227lrr
t44ll6 LsilZe Ls'lL7 t77lL} rs'lr3 L85123 tE6l22 1,8912r turned [3t 76123 L59l2L L7914
flelg Lso/L6 LSLI9 L8217 L8ol22 ts2lts L93lt9 19s/13 20alr9 furnc [1] 531L2
L8s/22 L9l/7 ter/8 206/3 2t213 2oLl22 202/20 2llll3 2orlL7 treeted [1] 181/13
2trl2 22022L 220122 22LlL8 2\sl7 20517 2O5lL2 206/23 20911 tro [19] L3lLs t6/2 LllLs 34/1
22Ll2L 22!lLL 224t5 22513 2L2lL9 212122 zLrl2l 2L9122 s4l7 56ls s6l8 51/7 s7l8 s9122
23e123 | 24L/2 24t13 63/Lr 10/24 Tslr ta3lLz L3412
and [1] Lillti touorrov [8I 231L9 23125 24lle L6s/8 765/74 23417 23sl'-9
chouaanda !1t tflle LO2l3 703/7 239/3 2421A 2421t2 two-party I2l 5717 s7l8
threa! trti 6UL3 t57/2 Ls7ls too [?l 2rl8 24ltL 37/L9 6018 tt'P€ t3t L8l4 66123 ro7l2r
L57lL7 e 98/L2 L42/L1 L66lL7 tzJ 72/7 e5122
bhre6 [12] l$l:,l 1Ll2s 72121 took l1?! t7/25 271L3 211L3 tfP€! t3l stls LL6l22 23117
87122 e]-l24 e2lL4 931L5 L2O/8 2812s 28123 34120 3412L 7218 tlperritera [1] L39/9
r2oll2 L2ilt2 L22lt2 23s124 72llg 731L9 LL9/24 t28l2s
hrough [lPl 5lL3 slLS TLILO L6s/3 Le7/L6',L4l3
23615 238/L7
L3lt8 ]3llo 35/8 371L2 1313 top [11] 221L6 23/22 Lrtlzo s2ll'3 L25lL5
1SlL7 15/Le s7/e er/Lt 70213 LLLl2t Latl2L 160/1 76AlS it.ar. [ll 4312L
7O7/1 LL649 LL9lt6 L23117 L62/LO L63/9 167123 L99/s L26122
t23ll3 L56174 Toronto I2l 25123 25/24 tiaately I10l L4123 57lLO
throring t|,l l\l9 totally [1] ltel22 6013 60lr 6tl7 88/8 88/10 159/7
thus l1l P9l3 touched [2] 76/9 LLalE t96/S 205122
rrre t117tt 315 glLl L3/L4 L4lrs torard [{! L45125 Ll9l14 151/19 tzl 65120 LL8l22
251L6 2911 2elLO 3OILS 32112 L5213 unattainable [1I 82123
t
278
t lupon [20] 6/3 Le/g L1/L6 42/2 victins [6] 2218 84/L3 223/LO
u c I' se/n 6oli.s 62/s s2/14 9L/2s 223/L2 223124 2361L3
luncertain [1] 24113 eel22 tools t20l2L L25/22 victiaa' [2] 22/3 2214
lunder t35l? 5/18 6l2L 7l{ L0/LL L25/24 L[Ol6 76717 L93/e 203/23 vldgo [2] 2124 769/9
I nlu 24lil 4ell4 s7l2t 63/e 20414 2OAILO vLer [4] 35/9 351]-2 L58/4
64/t4 82/22 871L3 88/5 9L/1 urgea [2t 3/LL L97123 235120
9e/r Lotlis t32/9 tssl|T ug [21] 9lL9 2OlL9 23/ts 2rl2o vlgorously [1] 631L3
7s6lLO Ls7/2s
155/24 LS6l8',3218 25/L8 53/t6 s8/2O 621L9 6s/9 vl].ified [2] 83125 841L6
t6L/3 t6ur0 79rlL3 20213 67le 75119 8o/t4 9rlr8 9212t violating [1] 57/23
20r/L9 22U72 22618 226/L3 tl5l77 r[Ll2s L4216 164/L2 vl.olationa [1] 2z0lLg
226/18 226/24 230/3 23L/4 L67123 L97 lLo 199./15 violent [1] 2218
unaerrytnsi[?t 26120 golLl use [{{l 1/Lo 1/Ls gl3 8/6 2914 Virglnia [2] tlLA 2a419
stlLL 3Ll+2 39lrL 39/L5 18116 4L/L5 s6/2r 57/t6 57124 60/6 vlrtuelly [1] 74/5
unaerneathl[2] 152/78 L6Ol7 7215 LOL|2| tL3l24 LL3/2s Lrrl2 virtue [{l t6lt2 90/9 LLU2O
unaeratand)Ilo! 8/23 L]-l2L L3O/2L L30l2s 1s3/1{ 772lrr 20Al2l
281?2 39lLS 421t6 49122 5813 tSols 2o4lLL 22Ll2s 222/to vj.rit [2I L8lL3 76/9
63/22 67lL.O 7S/L4 751L4 7el5 2231L4 22s16 23217 232/7 232/9 volce [1] 12119
8313 841L1 8s/20 871L6 9414 232/LO 23r/8 234/9 23alL2 [{
LO1l2O Lti/L3 72019 L22|LO 234/L2 234/L4 234lLa 23513
L22lLs L2llt' r22lL7 L2zlts 23slL3 23slt1 23slL5 23slL6 rait [2] 33/9 L69lL4
L22/22 L2trlt1 7231L8 L2rl9 23s12s 235125 2361s 23615 raiting [1] 101/19
72rlL3 L25lr L2319 L3S|L6 used [22] lolS [olLo 4316 s7122 ralve [1] 20217
t43lLS 160/rr t6rl6 t78ls L9Ll3 59tL3 62112 6r/25 79ltL 79/20 rall [1] 6917L
234l's ?3ll24 8612 891L2 9alL2 Lzt.ltg t25lL1 erarry t1?l 8S/7 98/L9 IOOILL
underctand{ng [6] SllL L22lLl L3L/23 156/19 17214 L1113 L7416 Loo/14 Loo/16 Loo/L8 LO9/2
L26lLo L8Ol3 2251L3 22617 L91lt9 202/8 20312s L26ltO L7ll22 $819 L88/t2
und€rttat€qent t2l 72122 72123 uaing [l0l 3617 36/8 53124 L88/22 18911 L8e/22 L92/tt
underrrood'[7] t23123 L24125 62122 l3ol23 L5Ol7 L8917 222lLS L92/t6 23712a
t2513 L2sit6 t2615 L26l2O 24L14 223/6 225122 rralter [lt 5215
undue I3l lAelZt 2O2/L3 2t6lLa uaually [3] Ll2lL6 168/10 ranr [lo?l 5/9 7/lO 7/13 812.
unexpectedly [1] 93124 L72lL3 t2/s L8123 20lle 2ol2o 24/19
unfrlr tz)I 8412 t53/L2 utl.ltzrtion [1] 23318 2s123 32125 sslt,a 351L8 3Sl2O
unfortunataly tll L23lLi utilize [2] 281L2 {2120 36/16 36/L7 10124 42110 4619
unir t8t Ls/zz llla 15/10 1sl17 utillzed t3l 25lLL 232llg 3Ol9 61116 5812L 7Ll8 131L6
rslL7 rslis l,5t22 Lr6lL6 23612L 7{17 Trlto 141L2 7SlL6'r5lLg
united asli 914 2116 2Ll8 6417 uririzing [2] 40ll 235|L1 19122 79/2r eol3 8315 83123
6sl,.2 I uttcred [1] L35la 83/25 8416 861t7 8elt7 92/20
sniver.ityi[2t 2612 7618 93/tr 931L3 LOrlT LO2l7 Lo3l73
untees 14lt 281L5 3212L r6Ll3
v LO4lLe Lto/16 LLtlT LLI/LI
L9Sl23 i wacancier [1] 16119 LL2l6 Ll6l7 t22/6 t26ls t26l2L
unlthe a2l)" 62125 L6Ll5 vrcationr [1] l4l7 t26l2t t27125 t21l2S 130/13
unaecerrary [1] 232125 vacuur [1] L78l2O t36/1 L36/7 t36/23 138,/11
unrelated [1] 22519 vslLd [1I 5124 L43lL2 L4716 L5313 Ls3l22
unaoaled lil 9417 value [1{] 2916 2917 29/Lg 6017 rsrl24 LsSl6 r57l2L LSI/24
unrealinE t1t 95ll 521L6 78122 79122 80122 8Ll7 L5slL6 L64l2s L6sl23 L67lL3
unlure J2l1: 209/2 2|9ll 8tl8 sLltD sLlLt 8L122 19s/15 L67ltr t69lL3 L69lL4 L70lL4
untll [3ol { sltz 7/23 Ltl24 varl.ouc [?t 22/L8 441L9 l7ll8 L73/t4 L74l2l L74125 L83l2l
tsli? t7/s 27lLr 6tl'.s 4813 LL3le L2Ol6 L26lL3 LB6|L2 186/1s Ls1/24 L9318
']{lL2
62t20 681r.4 6sl2 70123 8e121 vartly [1] 65122 2O2lL2 zlolr 2Lo/L7 2L2/1 2L5/2
s2l9 e'/LQ t02l3 tozlt3 toxl1 tillre [1] 214 2t313 2L6/6 2L8/L2 zLAltA
rtT12 t2ttrLo L2tll3 L2912 t3615 veloric [1] 182122 zlal2o 222/L3 224/9 224lLt
t(Lls ]-71721 1?s/1r t86l7s varalon [1] 37112 22slt7 2291L2 23319 2331L6
Ls|l23 2261r 230/L4 v€rlur [61 7l2O 8/L1 9lL2 9lL3 2331L9 23312t 235121 2391L4
untEue ILI! L97/L2 5e/L7 6017 2r2lLt
unusuar [4i 4717 8918 135/13 very [23] 6120 L6l9 LAILT 2819 ranted [61f zlLs 712 34lLG
t5r/22 t 30/L7 rrl3 s2l6 62lLt 771L6 34lle s6/Ls 63120 5s/9 6818
uP t63l 27L5 tL/g LLl22 Ltl23 a4lt6 LO2l2 LL6l3 L2el9 L62l2O 7219 131L1 7rl9 17lLL 7915
r2l4 L2l4 L2l7 L2lL6 L2lL9 171./10 t77 16 19316 206lLo so/1s so/19 8L/6 8rl4 8414
l3l2o 211L3 3Ol2 37lLr 37122 2o1lLs 2tsl23 227/7 238123 9sll9 toolL6 100/18 to1l2s
rol2o 421?3 171L2 5OlL2 ssl4 2atlLe r2olL. 123/LL t21/2O L26le
6llb 1slL6 vetri [3I 3/25 1l4ll2 LA7/2o L2616 t27l2L L2A|2O LALI3
ssl22 6elLO 741L3
Ls5lL6 r5sl23 ts6lr3 LselT
7gl3 \il6't,8812r stlT 100/18 vla [1] 40123
rool22 roi./1o LorlLs LLlll-e vlarrlo [3t 6'a/L6 851L2 8814 L8Ll2 Lslls L93l2S 20012L zLOl6
L2L/LO L3212 t'rol23 victin [21] 2218 6813 LL2/L4 ztol9 2LLlLo 27rlt2 ztrlL4
t46 lzs LALlLl .Lrt I L6
t4o/25 '.2912 L2Blt' L3517 L16lL2 L8614 2ltl17 2t2l2o 2L2/22 2t316
L46/L2 7171t3 Lszlzt L9317 Le3/2L L93125 2l4/te 2L4/Ls 2Lsl2r 2t718
L4517 L45lr9 230/5 233/3 234125
2281r 229/e
L47l2t L4P/9 LsOl6 ts3l2o te(ls Lg(lLo L94lL6 1'9slL8
23s/25 231/23 238/s 2391t8
L62/L5 L61lLs L7zlLs L1'|LL 2L31L2 225/5 22512! 22s/22
22s125 236lLO 240/8
LS2l2 Legiir4 202/2 2LO|L4
2LOl2r 2LS/LL 2r9lL3 2231L9 victia,r [5] L2elLt L42122 lwanting [2] 73/4 LLS|L6
23311 23elL4 L4618 t93/24 209/6 wanrg [6] T|LO 37/2 191L4
updated [1] SGI2L vtctlnited [2: 2el8 29lll I tzsltg 225/L4 230/e
J
361L5 36120 3elt2 391L3 4L/2s L37/2t Lssl7 L68/LL L69122
ALl24 17/2L 49178 5LlL9 6912 L69/23 L72l2L L74/A n6/LL
arning [tl] 73/20 85/L9 85/20 72lLr 92/2 92/22 L,zln 10{/16 t78/L2 L79/4 L80/7 LeOlg L80/24
ettzs i 111/18 14o/L3 L43/24 L44/L5 L8717 L82/4 t84/s t84/e r85/s
arranted [1] L27/2O L[1 /L2 r50/rr 150,/17 L53/LO tas/L2 Lgslzr t8719 L88/5
t6e/L7 1e3/1{ 193/15 224/LL L88/L7 L89/16 7e2lL2 ts3/3
t6l 2l20 t65124 23r/2L 23e/2
,ve l8l 60170 7Ll3 LoLls
L9514 Le6/L1 198./8 r98/24 20tle
L66/S L66IL0 L66/12 166/1{ 209/s 2L3lt5 2L3lL6 2201t5
aanrt [16] LOlg 28/3 3OlL6 rsLlz Lsslts 186/Le 210122 22L15 22219 226/14 227/7 22A124
ssl2L 8Lli2 8s/6 ss/Ls t}strg 22Olt 229112 2291L3 229lre 229118
t3L/2r rrQlLg 17712L 2itl2 t8l 2lL7 L18lL7 L48124 229120 23rla 23L/6 234/20
225/8 22s1LL 23OlL4 2321L3 tlellg t5olL2 Ls2l8 752llr 234120 23512 23719 23812 238/9
satch lLl lL68l2S LSzlL9 240lro 2t313
ratchtnE [lt 20/6 I5I t3el1 73918 t3glLr ,r t2l L39122 Lg{lts
aterr ilt i. uttl L39/L3 t4ol3 r t3021
ey t{51 tzllj zaln 32/2s 33/2 rebaite [?l 3/78 3lL9 L9lL4 rtratte [15t 3Ll6 37/L3 37/20
47le 6312\6u75 72/8 .721L3 7318 2Ol2 7S/7 LrOl4 t4ll1 43/L7 7OlL1 e5lt2 971L2 e7123
17tzL sl-ll sLlLO 8sl2| e4l6 rltea [1] l40l9 LOUL9 tO6l2O Ls9l9 Lse/25
8512L 8s113 88/6 e4l'-7 981L3 11t 961L8 L69/L6 Lg0lzl zotltr
LtL/73 LL2l20 Ll1/r7 Lt1/L8 (31 L31/7 t12/3 rhatever l7l 7lL6 30121 40120
7r7/Le L2IlLs L22/2 L2612 L7o/21 L92178 2O5l'' 233/L9
L2e.lt} 73412L Lr4l20 tll 7l124 vhen t1orrl LLlg L3/9 73/2L L5/8
'l,612 16'.13 LeOlT 2O4lL5
155/23 L5813 reel [2] LllLo L8l2 L5lL4 L8123 231t5 2'ls 261L2
20s/22 2L9l7O 23L/L6 23LlL8 c t5l LAIL9 29lLB 87122 28/6 28173 29115 3O/5 32122
32125 23515 23e/2A
232/25 23Al2O 24212t
24212r L3rl2 L1tl23 3312s 3elLs rxl23 48125 stl2l
ys [1] tztttt I3I rrelLS L5L|L9 Ls2l3 s6l2l 5712s 591L2 6Li15 69/2
tls5t ll's slzo 6/Lo 7lL| I1t LsO/20 63/24 67/2O 92/s 93123 IOO/L6
i tig- iizal:siis- gis st6 sttL tghing [1] 77/20 Lo'lL2 LO6/4 LO714 LO1l7 Lo9l2
elLz elLe9ellg el2o Lols rl/e ght I3l 8U2t 2O2lL3 2L6lLr 110/1{ L12lt8 LL4/2L LL4/22
11/10 11/f3 LLIL3 Lele Lelg rd [1] 7tl2o Ltsl2t 115/23 Lt6lL6 t2L/L4
Lgln 231L1 26lLA 27/9 291L8 t62l L3/t2 L3/2L L7l3 L9l8 L24/22 L28/L7 1{0./1O tAO/LL
29lte 2e/?o 2e/2r 2e/22 29/23 2L/17 2L/L9 231L3 24/4 26123 L1'-/11 Lltl2L L12lL9 t42/2O
2s/24 2sl2s 3LlLs 3L/2A 34/20 211L9 3olr3 311L5 32124 341'-7 Lr2l2L L45/LB t4gl8 L49/6
34/22 3rl?3 3412s 36/2 38lr 3slLL 311t7 {tl' 4613 49/2 ssl6 L49lL7 150/19 rsO/20 1s1/r8
42/24 11/, 41lt0 4elL7 sll2 7rl2l Lools 1oo/15 Lo1l8 r09ltg LS4l22 L56lt7 150/13 161/s
$/22 SaIIO SrlL2 SSl23 5614 LO9/L9 rLLlT 7L3/L1. L26lL9 L63lL7 L10l2o LTtlLo L7t/L8
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7
EXHIBIT 3
IN AND FOR THE COUNTY OF MONTGOMERY, PENNSYLVANIA
CRIMINAL DIVTSION
vQ NO. MD-3 156-1 5
PETITION FOR WRIT OF HABEAS CORPUS/MOTION TO

DISQUALIFY MONTGOMERY COUNTY DISTRICT ATTORNEY'S
OFF ICE
Courtroom A
Wednesday, FebruarY 3, 20L6
Commencing at 9 :33 a. m.
Vi-rginia M. Viomelsdorf , RPR

Officia.I Court RePorter
Montgomery CountY Courthouse
BEFORE: THE HONORABLE STEVEN T. OINEILL, JUDGE

KEVIN R. STEELE' ESQUIRE
District AttorneY
KRISTEN M. GIBBONS_FEDEN, ESQUIRE
Assistant District AttorneYs
for t.he Commonwealth
BRIAN J. MCMONAGLE' ESQUIRE
CHRISTOPHER TAYBACK, ESQUIRE
MONIQUE PRESSLEY, ESQUIRE
JOSEPH SARLES, ESQUIRE
for the Defendant
INDEX
DEFENDANT'S EVIDENCE
Wi-tness VDire Direct Cross Redir Recr

JOHN PATRICK SCHMITT 1s 59 65
COMMONWEALTH I S EVIDENCE
DOLORES TROIANI 135 198

BEBE KIVTTZ 233 238
EXHIB]TS
COMMONWEALTH I S
Number Description Marked Rec'd

C-l ABC News "New Developments in 254
Cosby Fondling Investigation"
C-2 Pottstown Mercury articl-e 254
"Cosby meets with authorities
over sex assault allegations"
C-3 Bloomberg. com article dated 254
November 26Lh, 20I4 "WhY Did
Bruce Castor Pass on a Chance
to Lock Up Bill CosbY?"
C-4 Southeast Missourian article 254
dated January 27, 2005
"Prosecutor cal1s case against
Bi1I Cosbv weak"
C-5 Daily MaiI article published 254
November 18, 201'4, "f wanted to
arrest BilI CosbYn
C-6 washington Post article dated 254
November 19, 2014 "Prosecutor
who declined to charge Bill
Cosby in 2005: rI didn't saY
that he didnft commit the
cr ime I rl
trYHTRTTq +19
COMMONWEALTH I S
Number Des--cription Marked Recrd
CNN video 254
c-B WNPV audio 254
c-9 PhiIIy.com article dated 254

September I4, 201-5 "Time hasnrt
run out on possible charges
against Cosby in Pa."
c- 10 People. corn article dat ed 254
t0-22-LS "Pennsylvania District
Attorney Candidates Battle it
Out Over the 2005 BiIt CosbY
Sexual Assault AlIegations il
c-11 The Intelligencer article dated 254
September 24, 20L5 "MontgomerY
DA candidate Castor urges delaY
n Cosby case until after
elections "
L_L4 PhiIIy. corn art,icle dat ed 254
1-31-16 "Castor could be keY
witness at CosbY hearing"
L-IJ Cheltenham TownshiP PoIice 19
Department Investigation
Interview RePort of Wil-liam H -
Co sby
c-]- 4 Packet t itl-ed ResPons ive, 2B
Non-Privif eged DocumenLs
Withheld from Production
Pending Agreement on
ConfidentialitY
c-1 5 Philadelphia DailY News article 42 251
dated 2-2-06
c- 16 Settl-ement Agreement 4-l
EXHIBITS
COMMONWEALTH' S
Number DescriPtion Marked Rec'd

C-17 Office of the District Attorney 64 259
Press Release dated JanuarY 24,
2005
C-l- B Oailv News dated February 18, 1'42

2005
C-19 Letter dated JuIy 10, 20]-5 to 185 lBB

Dolores Troiani from Risa Vetri-
Ferman
C-2A Letter dated September 22, 20L5 1B5 1B8

to Dolores Troiani and Patrick
O'Connor from Risa Vetri Eerman
C-2L Letter dated September 23, 2015 LB1 188
to Risa Vetri Ferman from
Dolores M. Troiani
C-22 Letter dated September 24, 20LS LB1 188
to Risa Vetri Ferman from
Patrick ,J. O'Connor
DEFENDANT I S
Number DescriP!'ion Marked Rec'd

Castor t s biograPhY from 20L6
a-
D-1
campaign website
D-2 Castor's biography from law 77
firm website
D-3 Canadian Incident RePort
D-4 Press Release dat,ed 2-]-'t-05 16
D-5 E-mail dated September 23, 2015 77

Castor
EXHIBITS
DEFENDANT I S
Number Description Marked Recld

D-6 Letter dated September 25, 201-5 77
to Bruce Castor from Risa Vetri
Ferrnan
D-7 E-mail dated September 25, 2015 77

Castor
D-B E-rnaiL dated September 25, 2015 77
Castor
Stipulation-1 Stipulation 75 259
Page
RULING OF COURT 306
RULTNG OF COURT 320

2 (The following proceedings were

"l
commenced with the Court, Mr. Steele' Mr. Ryan, Ms.
Gibbons-Feden, Mr. McMonagle, Mr. Tayback, Ms.
5 Pressley, Mr. Sarles, and the defendant being present:)
6
7 THE COURT: A11 riqht. We had a
I brief prehearing conference again for the sole purpose

9 of trying to understand how we will proceed this
t_0 mornJ-ng regarding witnesses, any motions' arguments
11 thereon, but we donrt have any firm plan on how that's
t2 going to work out. So we will take it one step at a
13 time here.
L4 We are stilI in the defendant's
L5 case since it is the defendantrs motion on habeas
r.6 corpus that the court is hearing evidence on. so at
l7 this stage you may call your next witness -
l_B MR. TAYBACK: Thank YOu, Your

19 Honor. The def ense cal-Is John P. Schmitt -
1A
2t JOHN PATRICK SCHMITT, having
22 been d.uly sworn, was examined and testified as
z5 fol lows :
24
25
I
I JOHN P. SCHMITT DIRECT
Z DIRECT EXAMINATION
3 BY MR. TAYBACK:
O Mr. Schmitt, you go by the firsL name Jack?
5 A I do.
6 0 What do you do for a living?
1 A I'm a lawyer.
B O Where are you a lawyer? Where do you practice?
Y A Patterson' BelktdP, Webb & Tyler in New York
10 Cit.y.
11 O How long have you been at the Patterson Belknap
l2 firm?
13 A Since 1983.
'J,4
O What are the positions that you've held while
1-5 you've been at Patterson BelknaP?
16 A I was an associate from 1983 through 1988' a
L7 partner from 1989 through December 20I5, became of
LB counsel January l- of this year. At various times f
19 also held the position of chair of the Corporate
ZU Department, chair of our cornmercial group and vice
21, chai-r f or them.
22 A Do you have a speciatty within your own practice?
ZJ A I'm a corPorate lawYer.
24 O Have you represented BilI Cosby in the past'?
25 A Since 1983.
1
I JOHN P. SCHMITT DIRECT B
Z 0 In what capacity or capacities have you

J represented Mr. Cosby?
a A When I first came to the firm as a junior
q
associate, f was assigned discreet matters for him.
6 Over time I became more involved in his .l-eqal af f airs.
7 And starting in the early l-990's I became his general
B counsel.
9 O Describe for me what the role of general counsel
t0 is.
11 A Any legal matters thaL affect Mr. Cosby would
L2 come to me. I woul-d either perf orm the legal services
13 or I would coordinate the IeqaI services of others.
T4 O At some point did you become aware in
1-5 approximately 2005 did you become aware of a criminal
L6 investigation of Mr. Cosby in Montgomery County?
L1 A I did, in January of 2005.
18 a And that was an investigatj-on regarding Andrea
1,9 Constand?
2t O When you became av,tare of that criminal
22 investigation, what did you do on behalf of Mr. Cosby?
23 A f retained criminal counseL. I spoke Lo t,he
24 chair of our firm who is also our senior litigator and
25 had been an Assistant U.S. Attorney to ask for

1 JOHN P. SCHMITT DIRECT 9
z recommendations. He reached out to a number of his

J forrner colleaguesr and every single one recommended
.l Walter Phillips who was a preerninent criminal lawyer
q
in the Philadelphia area.
6 O And does Walter also sometimes go by Wally? Did
7 he?
I A He did go by Wa1ly, Yes.

9 O And did you meet Mr. PhilliPs?
l-0 A r did.
11 O And did you uLtimately retain him?
T2 A r did.
1? 0 On behalf of Mr. CosbY?
t4 A I retained him on behalf of Mr. Cosby.
15 a What role did you serve for Mr. Cosby in
Lb connection with the criminal i-nvestigation where
t7 Mr. phillips was Mr. cosby's criminal defense lawyer?
IU A Well-, Mr. Phillips dealt directly with the
t9 prosecutor's office. He would report to me and
20 discuss all those rnat.ters. I would also discuss those
21, with Mr. Cosby to determine how we would proceed '
22 O Was the D.A. at the time in Montgomery County
23 Bruce Castor?
24 A IE was.
25 O Did Mr. Cosby with your advice, did Mr.
P. SCHMITT DIRECT 10
1 'JOHN
2 Cosby withdraw that.
3 Did Mr. Cosby cooperate with the
4 investigation?
5 A He did.
o 0 Did he participate in an j-nterview?
1 A He did. He WaS interviewed in a conference room
o at my firm by I believe it was by detectives from
9 the cheltenham Police Department and the District
10 Attorney's office. Mr. cosby was there, I was there,
11 Mr. PhilIips was there, and the detectives were there.
12 O At some point in time was the criminal
13 investigation resol-ved?
1.4 A ft was.
L5 O ApproximatelY when?
A Within a matter of weeks. I think it was
l7 mid-rebruary.
r.8 O And how was it resolved?
19 A The District Attorney determined that there was
20 insufficient evidence to charge Mr. cosby with a

2I cr ime .
22 O And did at the time that decision was made,

23 did you have an understanding as to whether the
z.t criminal investigation could be continued, could be
25 re-opened ?
P. SCHMITT DIRECT 11
I JOHN
2 A I had an understanding it could not be. I spoke

to Mr. Phillips who indicat.ed that, df though the
A District Attornev had determined there wasn't
5 sufficient evidence to charge Mr. cosby, that he did
o anticipate t,hat there would be a civil litigation.
1 And he wanted to ensure that Mr. Cosby could be
B compelted to testify in a civil litigation. And'
9 therefore, it waS an irrevocable

his d.ecision waS
10 commj.tment Lo us t.hat he was not going to prosecute.
11 o Is that how you understood the deterrnination of
12 the District AttorneY's Office?
-LJ A AbsoIutelY.
1-4 ( Defendant' s Exhibit D-A
15 published. )
16 BY MR. TAYBACK:
T7 o I'm going to show you a document that was marked
1B yesterday as Exhibit D-4. Mr. Schmitt, you have the
1-9 option of a pa';Per in f ront of you and the video
20 screen. It's a two-Page document.
2I Do You recognize that?
22 A It's a press refease released by the office of
23 the District. Attorney on February 17th, 2005'
24 O And do you remernber receiving that a copy of
25 that press release at or around the time it was
1 JOHN P. SCHMITT DIRECT I2
z i-ssued?
3 A I do.
4 0 Now, you said that it was anticipated that a
5 civil suit would be filed. Did you understand that a
6 civil- suit would tikely be filed by Ms. Constand

against Mr. Cosby even bef ore it was f il-ed?
H
A That was my expectation, Yeah.
9 O And in connection with that civil suit, once the
10 crimina] investigation was, as you said, irrevocably
L1 concluded, what did you do to assist Mr. Cosby in
I2 defending the civil suit that you anticipated would
L3 come ?
'tA
ta A We counsel in Philadelphia.
retained civil we
15 retained Pat.rick O'Connor, a partner Of Cozen O'Connor

tb to be the lead counsel along with our firm, but he was
t,
L' the lead counsel on the Iitigation -
1B 0 And was Mr. O'Connor retained af t,er the
19 conclusion of the criminal case?
20 A He was.
2T o at some point after the crirninal case
After
22 was concluded, was, in fact, a civi] suit filed?
23 A It was.
24 0 ApproximatelY when was that?
25 A I think it $tas in March of 2005.
1 JOHN P. SCHMITT DIRECT 13
2 O Pdrticipate in the defense

And did you, in fact,
of t.hat lawsuit on behalf of Mr. Cosby with Mr.
O'Connor ?
5 A r did.
6 O Did you rely upon the irrevocable commitment of
'l the District Attorney's Office not to reopen the
B criminal investigation in defending Mr. Cosby?
9 MR. STEELE: Objection to
r0 1 eadi ng .
11 THE COURT: Sure is. Donrt Iead
L2 the witnes s.
1_3 MR. STEELE: And it's
1,4 irrelevant.
15 BY MR. TAYBACK:
16 0 what did you do in defending the civil Iitigation

L7 brought by Miss Constand?
1B A We participated in the discovery. Mr. Cosby sat
19 for a deposition. We did that knowing that the
20 criminal titigation that the criminal matter had
2L been concluded and could not be reopened-

22 o And how many days of deposition did Mr. cosby sit
23 for ?
24 A He sat for four daYs.

25 0 Did he invoke the Fifth?
1A
r.l
1 JOHN P. SCHMITT DIRECT
2 A No.
J O Did you participate in other asPects of

4 di s covery ?
5 A Yes.
6 0 If you had known that the criminal- investigation
7 in Montgomery county could be re-opened, how wou.Id it
R have affected your representation, if at a1l?
9 A We certainly wouldn't have let him sit for a
10 deposition.
11 O Did that civil case eventually resolve?
L2 A rt did.
13 a ApproximatelY when?
I4 A About a year after it was initiated-
15 O Was it a settlement?
t6 A It was a settlement, Yeah.
t'1 O Are the terms confidential?
1B A They are.
19 O Did you ever, after February of 20L5 (sic),
20 receive any requests from the Montgomery County
2L District Attorney's office on behal-f of Mr. cosby?
22 A 2005?
23 O I'm sorr!r 2005.
24 A NO.
25 o Did you receive any requests for the deposition

1 JOHN P. SCHMITT DIRECT IJ
2 transcripts or any port ion of thern?

J A No.
aA a Did you ever receive any inquires about how the

5 matter had been resolved?
A NO.
7 O Did you recej-ve any inquires regarding how the

I matter bras litigated?
9 A No.
l-u 0 was that true from the date of that press release
11 until --
L2 A Until f aI I or winter of last year , of 201'5 .
13 0 Do you know whether Mr. Phillips is alive?
I4 A He died last Year.
L5 0 Do you know when?
t6 A I think almost exactly a year d9o, I believe.
I7 I 'm not certain.
t-u MR. TAYBACK: No further
1-9 questions.
20 THE COURT: Cross-examlne
2'J, MR. STEELE: Thank You-
22 CROSS_EXAMINAT ION
23 BY MR. STEELE:
24 0 Mr. Schmitt, we went through some of Your
25 background in this in your direct testimonY. And,
SCHMITT CROSS 16
1 JOHN PATRICK
z you know, how many years have you been practicing law
at this point?
A Thirty-six Years.
5 O Thirty-six. And in your practice, it's pretty
6 wide specialties; correct? Like transactional and
'7 d.eaIs and all kinds of stuf f Iike that; riqht ?
Transactional, yeah. I don't know what I'a11

a A
I kinds of stuff likerr -- Yes.
10 o Agreement s that you make on di f f erent th j-ngs and
1L you work through those?

12 A Thatrs right.
LJ O Risht?
L4 A That's right.
15 O And you're integrally involved j-n as qeneral
16 counsel to the def endant ? You've been acti-ve in
1.'7 agreements that he's been involved with; correct?
1B A CorrecL.
L> aOkay.Nowrwouldyouagreewithmethatit'isa
20 good practice in any of your work to get things in
2I writing?
22 A As a general matter we try to get it in wrj-titg'
23 I do agree.
24 0 A11 right. And aqain, dealing with, You know,
25 Mr. Cosby, you try to get matters in writing when
1 JOHN PATRICK SCHMITT CROSS 1-7
2 you I re making agreements i correct ?
3 A Correct,
4 0 So I want to go through, you know, kind of a
5 timel-ine here with you. You are f amiliar that an
6 investJ-gation is going on reqarding your client, Mr.

1I Cosby; correct ?
o A Yes.
9 O And, you know, in JanudrY, former District
10 Attorney, Mr. Castor, had put out a press release, you
11" know, in that regard, that there was an investigation
72 going on. He talked about. asking you or aski-ng Mr.
13 cosby t s lega.L team to meet wit h detecti-ves, which you
1A.i
-t- ended up doing; correct?
15 A I'm sorry? Are you you're talking about
16 ,January of 200 5; correct ?
1,7 O Yes.
1B A Yes.
L9 A Okay. And you fotlow through and you do that'
.)i
t,hat request with your cl-ient to meet with detectives;
2t right?
22 A YES.
23 O Okay. And when that meeting goes on in your

L'a offices in New York
25 A Uh-huh.
1_ JOHN PATRICK SCHMITT CROSS 1B
2 0 you have Mr. Cosby there? You have

3 Mr. PhiIlips t.here?
q A Uh-huh.
5 0 There's detectives there' and theyrre doing a
6 written statement or lead into a written statement

'7 with the defend.ant?
R A They're taking notes as they go along.
9 0 Okay. But then, You know, eventually it's signed
10 off on; right?
1t A Correct.
1,2 O And at no time during that, that statement where
t1 he's being investigated, do you teIl your client to
T4 take the Fifth or not answer questions?
15 A That I s correct. He answered all the questions.
16 O And with counsef there, you and he, you and
1,7 Mr. PhiIlips there and maybe other lawyers; correct?
18 A As I said' yes.
LJ O Okay. And while that statemenL is going on
20 and I can
21. THE COURT: WhaL statement are
22 you referring to?
23 MR. STEELE: Mr. CosbY's
24 statemenl.
25 THE COURT: Of the date of?
1_ ,JOHN PATRICK SCH}4ITT CROSS 19
2 MR. STEELE: One-26-05 .
THE COURT: Okav.

4 (Cheltenham Township Pol-ice
5 Department Investigation Interview Report of William
6 H. Cosby dated I-26-05 marked Commonwealthrs Exhibit
C-13 for identification. )
THE COURT: Just to clarify

9 while they're doing that I had missed it this
10 statement is of -2005. You and Mr. Phil-lips were
1,-26
1_L present in whatever room or where this statement was

1a
.t- z beinq taken?
r_3 THE WITNESS: ThAt'S COTTCCI.
L4 THE COURT: Okay. Thank You.

15 BY MR. STEELE:
16 O I just stuck it next to You there'
),'7 Commonwealthrs-13. And I'd just ask you if you
1B recognize a question and answer statement that waS
19 given by Mr. CosbY?
20 A Yes, I do.
2I O Okay. And I think therers a number of signatures
22 on the .Ia st page as witnesses and counseL and things
ZJ Iike that.
24 Do you recognize any of those
25 si-gnatures ?
1 JOHN PATRICK SCHMITT - CROSS 20
2 A I do.
J 0 Which ones ?
4 A WeIl-, there' s Mr . Cosby' s signature.

5 O Uh-huh.
6 A Signature of f think it was I think that's
7 John Norris.
B O Correct, t.he chief .
9 A Yep. And then therers my signature as counsel.

10 O Okay.
1L A On the right, I think that's Peffall' I think he
l2 was one of the detectives.

13 O And Schaffer, I believe, another detective?
l4 A I don'L remember him. I don't know him.
15 O Okay. But the counsel signature is yours?
16 A Yes, that's mY signature.
t7 0 Okay. Al-I right. Now, it's 1et I s see, an
1B 1--page statement that i s gJ-ven I correct ?
B
19 A That's correct.
20 O And during that statement, I'11 refer you to a
21. couple dif f erent Point.s here.

22 MR. TAYBACK: Your Honor' mdY I
23 pose an objection to reading from a document on a
24 couple different grounds? One, itrs hearsay. But
25 two, it I s irrelevant fOr the Same reaSonS Your Honor
1 JOHN PATRICK SCHMITT CROSS 2I
a
a did not a1low the reports into evidence or recitation
3 of the various points regarding Ms. Constandrs
4 different statements.
J THE COURT: We]1, my ruling
6 regarding Mr. Castor was that he was aware of the
I statements and whether theyrre very relevant to his
a decision that he made. So my ruling was limited
9 there. And al-so balancing putting out material that
10 is not yet out into the public. But at that stage it
11 was very relevant to what Mr. Castor decided.
I2 I donrt. know why hers asking
13 these questions. If you would like to have, you know,
T4 a side bar so I can at l-east understand where these
l5 questions are going
16 MR. TAYBACK: I would.
r'7 THE COURT: -- because the
1B concerns of having all everything out in the
1"9 public, f donft want to do that.
2Q
2T (A conference was held at side

22 bar, not reported. )
23
z.t THE COURT: Okay. Now, there is

25 an objection. I did not have the court reporter
JOHN PATRICK SCHMITT CROSS 22
1
2 because at this stage I didn't feel the necessity to

3 have the court reporter to rule on an objection.
4 I'm going to hold the objection
5 open and see if we can qo about the purpose of the
6 questioning. And if we donft, we'11 come back to it.
I BY MR. STEELE:
B O Sir, you have the statement before you; correct?
9 A I do have the statement before me -
L0 O And vle're in agreernent that you sat through that
11 statement, you signed off as a witness to t.hat
I2 statement ?
1,4 O Okay. Can you assume from that that you were
r-5 there through the ent j-rety of the statement ?
16 A f was -- I was.
t7 O Okay. During that time, a number of questions
l_B were asked that coufd lead to criminal charges on your
1y clienti correct?
20 A Depending on the ansvter ' not the quest ion .
2I O Okay, conceded. Okay. That depending upon his
22 ansvrer, it couLd be the basis for a criminal charge?
23 A Right.
z.! O Okay. And at no time while he's giving t'hose
25 answers and I want to get into the specifics of it,
2 but things that cou.l-d potentially lead to him being

crirninally charged, you never stopped that interview
:
A
and said we're taking the Fifth; correct?
5 A Correct. He gave answers that did not lead to
6 criminal charges.
7 O That's not my question.
a A I'm sorry. Then I misunderstood your question-
9 0 They could have led to criminal charges and you
10 were concerned about them Ieading to criminal charges;
11 correct ?
T2 A I -- I had interviewed Mr. Cosby previously

13 was not concerned that his answers -*
1.4 MR. TAYBACK: I would just
15 admonish the witness not to remind the witness
16 I 'd ask the Court to remind the witness not to
I7 disclose privileged communications inadvertent.Iy in
18 his accounting of
3.9 THE COURT: You think a man with
20 36 years of experience needs you to remind him of

2)" that ?
22 THE WITNESS: We coul-d al-l- use a
23 littIe heIp.
24 THE COURT: Irm not going to
25 tell* anybodY what to testify. Tf this is what he's

1 JOHN PATRICK SCHMITT CROSS 24
') going to testify lo, that's up to him. He's under

J oath, and I'd ask you not to give him cues as to what
4 he should or shouldn't do.
5 Answer the suestion.
6 BY MR. STEELE:
7 O So let's foLlow up on this. So you had talked to
B him and you were confident at that poj-nt that you
9 wanted him to talk because it's not going to lead to
10 criminal charges ?
t2 O And you cooperated with this, You know,
1J j-nvestigation. You al-l-owed police to search his
1A
]Y residence; correct?
16 O And then there was a deposition that goes orlr you
L7 know, in this case. And you're confident in your
1B position at that point, too; weren't you?
19 A The deposition was not in this case - It was in
20 the civil matter.
21" O fn the civil matter. You were confident that
22 he's going to be fine. You had talked to him. You
23 knew what was going on in the case; right?

24 A Yes, I did.
25 O Let's go to the writing aspects of things for a
z moment, sir. You would agree with me that you never

3 obtained a written agreement from the Commonwealth,
4 f rom Mr, Castor, that your cIi.ent, the def endantt
5 would not be prosecuted?
6 A I have a signed statement from him, from the
1 prosecutor.
B O You have a press release in that regard; right?
9 A That he signed.
10 O That he signed?
11 A Right.
L2 O And that also says that that decision can be
13 reopened ?
L4 A No, it doesnrt.
r.5 O Let rne see it.
1A A You want this?
1,1 O Yes. I'd like you to look at a line here. I
1B don't have my glasses, so you're going to have to help
1-9 me here. That indicates -- and I'm pointing to the
2Q Iine there, "District Attorney Castor. " Just read
2t that for me.
22 A It says:"District Attorney Castor cautions all
23 parties of this matter that he will reconsider this
24 decision should the need arise. "
25 O Okay. AII right. So your testimony is that that
2 refease was the written agreement that you got from

3 the Commonwealth that they wouldn't proceed on
4 charges? Yes or no?
5 A Yes, it is.
6 O Okay. And you obtained no oLher document
1 regarding this written agreement?
B A That is correct.
9 O Okay. Now, I know most of your work is civiJ-
10 work. I ran across a blog talking about Thomas J-
11 Farrell's excel-Ient criminal defense' tools and
L2 technigues.
1? Let me read something to You.
LA 'rIf a judge or a Prosecutor makes any assurance,
t_5 either make sure that they are mernorialized in a
I6 writing that becomes an exhibit at a plea or repeat
L7 them for the record at a time of the p1ea. Courts
LB wilI not enforce unarticulated agreements or side
1_9 agireements not f ound in a written agreement. "
20 Does that make sense to You?
2t A ffm not a criminal lawyer. I'm not famlliar'
22 O Wel-I, let me see here. When you get this
23 assurance in writing in this press release, do you
24 memorialize that in any other waY, in any document to
25 plaintiff's counsel or anybody else? Is this brought
.JOHN PATRICK SCHMITT CROSS 27
L
up any time in something in writing?

3 A WeIl, there was no plainLiff's counsel there-
4 The this is the writing I got. we also got oral-
5 assurances. Mr. PhiIlips got oral assuranceS from Mr.
6 Castor that this was an irrevocabl-e decision that he
had made.
o O So letts move then to to what's going on kind
9 of rnidstream with this. AlI right. You're general
10 counsel to Mr. CosbY; right?
11 A Right.
1,2 o so you have to worry about his other matters that
t{ are going on and public matters that he's dealinq with
_L .t over this issue?
15 A That's correct.
_Lb 0 So one of those issues was a matter with the
1_7 National- Enquirer; correct?
18 A Correct.
19 0 okay. And you were involved in negotiations with
20 the National fnquirer?
2L A That is correct.
22 O Okay. And when Irm talking about when I asked
23 you before about, Iiker dgreements and things like
24 t.hat., you knOw, in an agreement that you t re making'
ZJ typically one side is giving sornething up and getting
2 something in return for that. And that t s contract

1 principles; correct?
A Okay.
5 0 And with this ag,reement with the NationaL
6 Enquirer, vou were giving up things, they were getting
7 things. You know, it's back and forth; right?
I A Correct.
9 O And that is all artj-culated in wrj-tings that are
10 going back and forth between, you know, counsel- and
11 you before he's ever going to do this interview with
t2 the National Enquirer?
13 A I don I t recaLJ how much back and forth. It's a
1"4 long time ago.

15 (Packet titled Responsive,
L6 Non-Privileged Documents Withhel-d from Production
77 Pending Agreement on Confidenti-a1ity marked
1B Commonweal-thrs Exhibit. C-l-4 for identification. )
I9 BY MR. STEELE:
20 0 I'm going to approach you and f'm going to show
21. you what frll mark as C-14 and if you could take a
22 look at that packet of documents and see if that
23 refreshes your recoll-ection as to some of the back and
24 forth that goes on in regard to this negotiation and
25 this written nesotiati-on.
.JOHN PATRICK SCHMITT CROS S 29
1
2 A WeIl, the first page, dll it has is Wally

1 phirlips' name, and then it. has the name of somebody
4 from the Enquirer and a telephone number.
5 O Yeah. If you want me to point you to
6 A WeIl, I'ft just
7 O Okay.
B A The second page has nothing to do with it ' It

9 just notes WalIy Phillips' narne again -
10 The third Page Iooks like it's

11 the beginning of my notes on the I don't know. No,
t2 it ' s Some it mentions Barry Levine. Hers with the
13 Enquirer . I this ot'her name i s '
don I t know who
L4 MR. TAYBACK: Your Honor, itrs a
l_5 narrative at t.his point. There's not a question

T6 pending. I bel-ieve it ' s just a narrative '
J-7 THE WITNESS: I 'm sorry. I
1B thought he asked me
L9 THE COURT: f don't think the
2A questionrs we really intend to let him answer. I

21, think what he really wanLs you to do is stop reading.
22 MR. TAYBACK : He was reacllng -
23 THE COURT: Tell him to stoP
24 reading.
25 MR. TAYBACK: NonresPonsive.
?n
a
I JOHN PATRICK SCHMITT CROSS
2 THE COURT: Just wait for a
question to be pending.
4 BY MR. STEELE:
5 0 AII ri.ght. So have you had a chance to look aL
6 those documents?
7 A Yeah. Yes, I have.
I O Alt right. So it appears from somebody who was
9 not invol-ved in this negotiation that this goes
10 this goes back and forth somewhat, You know, with
11 different different letters and changes in the
t2 letter.
13 If you look about' I guess/
1,4 halfway through the documents, it looks like therets
r.5 an e-mail with your byline on the top, John Schmitt,
I6 John P. Schrnitt.
I7 A I see it. Is that your question?
1B a Yeah. So if you go through, you know then
19 there I s another document that. is that is numbered,
20 you know, kind of breaks up the paragraphs in that
21, same Lett.er f orm. I think the date on the top of it
22 is February l1th. I'11 show it to you if you want.
23 A I mean, there are a number of documents dated
29. February 1 lth.
25 0 I ' l-1 show you. I rm just trying to get the one
'1
!
2 that starts with the nurnbers. I think you have 1t

there.
4 A Okay.
5 O The numbers.
6 A I've got it.
7 O Okay. So it appears from these documents that
I you guys go back and forth a little bit and you have a
9 negotiat.ion in writing in regard to what your client's

L0 going to do and then what and then what you're
11 going to do.
I2 If you want me to go through the
IJ paragraphs, I can do that along those Iines. If you
1A
_L't go t.o that
15 A OkaY.
l_o O If you go to that letter that we were just

L1 talking about, you know, Mr- Cosby is going to do an
18 exclusive interview with the Enquirer, the National
1_9 Enquirer; correct ?
20 A Yes.
2L 0 And in it You define what he's going to do. He's
22 going to apologize to his wj-f e if he's done anYthing
23 to hurt her?
24 MR. TAYBACK: Objectlon. The
25 document is not in evidence. It's hearsay'

2 THE COURT: WeJ-I, you know,

3 again, we're trying to use these extrajudicial
4 documents for purposes of decisj-ons and how decisions
5 were reached. Now, can you ref er to someth j-ng, ask
6 him to read it, ask him if he's read it without you
7 reading it
I MR. STEELE: I CAN.
9 THE COURT: -- to see if that

10 can help your question? Again, t,he Court has to deal
1l_ head on with this information at a most preliminary
l2 stage from there I s been a Prel-iminary Hearing or
-LJ therers been any fact finding, any jury decisions on
1A
r.i anything. I just don't want this stuff out there.
l-J See what we can do.
th MR. STEELE: Okay. And Irm
l7 not
1B THE COURT: f f You can rt, then
t9 I'.1-l have to rule.
20 MR. STEELE: And I'm not
27 offering it. for the truth of the matter aSSerLed. I'm
22 simply asking it, to show that there were definitive
23 terms that he went through when he's negotiating this
24 because this is what he does.
25 THE COURT: Ask him those
t_
) questions in that reqard then.

MR. STEELE: Okav.
4 BY MR. STEELE:
q
O Look at five, six, seven, eight, nine and 10.
6 You did?
I A I rve read them.
B O So can you ag'ree f or me based upon the reading of
9 those provisions t.hat are being lined up here that '
10 you know, while the criminal investigation is going
1l- orrr you are working through this the confines of
).2 Mr. Cosby, the defendant, doing an interview with the
National Enquirer ?
T4 A Yes.
15 O Okay. And during that period of timer Yau are
IO a"l"1owed if criminal charges are f iled, we're not
1,1 going to d.o this or we'Il- work something else out. If
1B they aren't filed, then werre going to proceed in this
19 fashion and do t.his interview, this exclusive
20 interview; right.?
2I A That's what the document saysr Y€s.
22 O Okay. And then with that you are negotiat ing al-l-
23 of the terms of that?

24 A Uh-huh.
25 O Correct ?
1
a A Correct.
1 O And they're verY specific; right?
: A Yes. Yes. Excuse me.
5 O And then you end up doing the interview

6 afterwards; correct.? And you go to Houston with him
7 and do this interview with the National Enquirer?
B A That's correct.
9 0 okay. under t.he conf ines of aIl of these written
10 terms; right ?
11 A Right.
1,2 O And would you agree with me that in your
1? business, those written terms are very important to
1-4 how you operate?
15 A It was irnportant in this case to have these
1G. written terms. Is that the question?
1,7 O It is.
1B A Okay.
19 o okay. so letrs f ast. f orward a lit,tle bit here to
20 the time period of t.he civil suit being filed and
2I depositions being taken. Correct?
22 A Correct what?
23 O That was done, sirr wdsn't it? There was a civil
24 suit filed? Didn,t you go and sit at depositions?
25 MR. McMONAGLE: Objection.
?q
1 JOHN PATRICK SCHMITT CROSS
2 Compound.
THE COURT: Okav. There's
4 the
5 THE WITNESS: Yourre saYing fast
6 forward to a time when depositions are bej-ng taken and
-, you didn't ask me a question. I didn't mean to offend
I you.
9 BY MR. STEELE:
10 0 I 'm not offended.
l_1 A Okay.
1,2 a can you agree with me that a civil suit htas fil-ed
13 and that you were the defendant's counsel at those
1-4 depositions along with other people?
16 O Okay. And you had Mr. O'Connor and, you know, a
T7 number of other attorneys with you on that?

r.8 A That's correct.
19 O Okay. So and in those depositions and
20 to help me with this because I haven I t

you I 11 have
2I done civiL work, but in t.hose depositions, is there a
22 procedure that's followed before a deposition is

23 taken, meaningr do you go over the rules of the of
24 whatrs going to haPPen?
25 A No. You set a time.

SCHMITT CROSS 36
1 JOHN PATRICK
a
0 OkaY.
J A You set a Place.

1 O Uh-huh.
5 A And you agree to sit for the deposition.
6 0 Okay. Then and you have a court reporter
7 t,here, somebody to type down what t s said in the
B deposition; right?
9 A Sure.
l_0 O Okay. And in this case there were four times
Is
t_1 that you sat f or a deposit.ion with Andrea constand
1-2 lawyers,' correct ?
t{ A Mr. Cosby sat on four occasions, yes.
).4 O On g-28-05,9-29-05,3-28-06 and 3-29-06?
15 THE COURT: Can You give them to
16 me again?
1,1 MR. STEELE: On 9-28-05,
1B 9-29-05, 3-28-06 and 3-29-06.
L9 BY MR. STEELE:
20 O Do we agree on those dates?
2t A That sounds around the time. I don't know the
22 specific dates.
23 0 And you were there for all four i correct?
z.+ A I was there or al"1 f our -
f
25 o Now, I want to direct you to the one on Thursday'

1
2 March 2Bth, '06. At the beginning of that, it talks

t
J about st.ipulations and agreements on sealing, filinq
4 of certifications, and then it. goes into agreements
q that are being made regarding that National Enquirer
o interview and what happened with that -
I WouId I be cor'rect in saYing,
B like, dt the beginning of a deposition you put the
q rules on on where you can go on certain things and
10 where you can't go on certain things?
1_1 MR. TAYBACK: Object to the form
L2 of the question. Vag'ue and conf using -
IJ THE COURT: If You don't

L4 understand, you can ask him to define it for You, but
15 I understood it.
J-O Do vou understand it?
1-7 THE WITNESS: We1l, I think I
1B understand it. Let me say I am a corporate lawyer.
BY MR. STEELE:
20 O okay.
21 A I bring in c j-vi-1 litigators f or civil litigat.ion.
22 At the beginning of depositions, there are phrases
thrown out tike, "Wer1I use the usual stipulationsr"
2., for example.
25 O Uh-huh.
3B
t
I JOHN PATRICK SCHMITT CROSS
2 A I have no idea what that means -
3 0 okay.
.I A on Patrick O'Connor of Cozen OrConnor.
I relied
5 I felt quite comfortable that whatever stipulations he
6 thought were appropriat.e would be appropriate, but I
7 can t t tell- you what those are or what they rnean.
a O Okay, fair. But can we agree that that's at
9 Ieast done at the beginning of a deposition?
10 A Whatever that is is done at the beginning of the
11 deposition, Yes.
1.2 O Okay. Kind of the rufes of the road, for
13 whatever it's worth?
I4 MR. TAYBACK: Objection. Vague
1q and relevance.
1,6 THE COURT: Rules of the road.
t'7 He said the usual stipulations. Again, they do appear
1B in most depositions, those words. And a corporate

t9 lawyer and a criminal lawyer don't know what they aret
20 so let's move to another question.

2t MR. STEELE: OkaY.
22 BY MR. STEELE:
23 O So in this you knew what the Fifth was; right?
24 A I know what the Fifth is, Yes.

25 0 You know what it was?
.JOHN PATRI CK SCHMI TT CROS S
39
1
a A Yes.
{ O And f think you said before you would never let
4 him sit for a deposition, you know, rf you hadn't
tr gotten this agreement; right?
6 A That's correct.
7 O Because, you know, it wouldnrt Iook good for Your
B you knowr oD that; right? I mean, is that l-ike

9 malpractice if you do something along those lines?
10 A I don't rnake decisions because of whether it
L1 makes me look good or not.
I2 O Okay. Well, can you tell me if, you know, if
tl this was so important, having this agreement, why
1A
_La there I s no place in any of those stipulations
LJ beforehand or anything during any of those depositions
L6 that refers to the Fifth, this agreement?
t7 A The agreement was with the prosecutor t s office in
1Q a matter
19 O On whose behalf?
20 A f 'rn sorry.
2L THE COURT: Let him answer the
22 question
23 THE WITNESS: And I can hear
24 you. You don I t have to yell at me.
25 THE COURT: Donrt teII him what

1 JOHN PATRTCK SCHMITT CROSS 40
2 he can and can I t do.

3 THE WTTNESS: I apologize, Your
4 Honor
5 THE COURT: He's answer the
6 quest j-on and then he can ask another one.
1 THE VIITNESS: The agreement that
B was made was made with Mr. Castor, the District
9 Attorney. That matter was concluded. We had our
10 agreement with him. We had his assurances. The civil

11 case is filed subsequent to that.
12 t need to worry about the
I don I
_t_ J Fifth Amendment because there is no risk of jeopardy

74 to Mr. Cosby because the District Attorney has agreed
15 irrevocably that Lhere would be no criminal
I6 prosecut ion .
I1 BY MR. STEELE:
1B O And you relied on t,hat. press release as that
r.9 irrevocable aqreement?
ZV A No. I relied on the combination of the press
2T release signed by Mr. Castor and the aSsurances that
22 were given to wally PhitIips, the criminal lawyer who
23 I retained, who assured me that it was sufficient to
24 the purpose.
25 O AII right So you never spoke to Mr. Castor?
z A f never spoke to Mr. Castor.

1
0 And you never, again and f'm repeating myself,
4 but. you never got a written agreement other than the
5 release?
6 A There is no other written asreernent.
0 Okay. So with this is it the civil attorneys
R that are for Ms. Constand that are benefitinq from
9 your client taking a deposition?
t_0 A lrm not sure how what that means, an attorney
11 is benefiting from a deposition. I mean, they want
I2 discovery. They're getting the discovery they want.
13 A And doing that and throughout the deposition,
L4 there were times where you didn't wantr or Mr.
15 O'Connor, I guess, because he' s Iead in it, doesn't
1,6 want, you know, the defendant to answer certain
r'l questions?
18 A He rnade objections to what he thought when he
L9 thought questions were inappropriate.
2A a Okay. And questions about Andrea Constand were
27 objected to during the deposition?
22 A I don't have the transcript in front of me.
23 There were nurnerous object.ions, objections as to the

24 form of the guestion, objections as to whatever other
25 evidentiary objections there were.
42
1 JOHN PATRICK SCHMITT - CROSS
2 O And didn't you have to go and do weren't
3 those, I guess' objections involving Miss Constand,
didn't you have to go to the Court and have the Court
5 decide what can be answered and what couldn't and set
6 rules up?
7 A WeIl, I I -- I know that during the deposition

a there were a number of times where Constand'S Iawyer
9 said, we'I1 take that to the court. I donrt recall-
10 what the motion practice that came out of that was.
11 They may have filed motions - I don I t recall '
72 (PhiIadeIphia Daily News articl-e

t3 dated 2-2-06 marked commonweal-th's Exhibit c-15 f or
15 BY MR. STEELE:
16 O I'm going to show you what It11 mark as
Sir,
L7 Commonwea.l-th's-15 f or identif ication. And itr s realIy
r8 just to refresh your recollection. Thatrs an article
19 that was written in the Philadelphia DaiIy News.
20 A Okay.
21" 0 And then it goes through and I think itrs
22 more on the second hal-f it talks about those
23 conf ines . I don I t want you to read it out .l-oud. r
z'r just want to see if that refreshes your recollection
ZJ to the Point I was trying to make '
1
2 A I don't have an independent recollection of this.

3 I see that there's the report of it, but f donrt
4 recall the motion practice.
J O Okay. So when you let me back up then. If
6 you recall, as we spoke before, about objections to
7 certain things being put on the record and how t'he
B questions were being asked.
9 A I do recall that.
10 0 And at l-east according to that, there was some
1L time that was spent with a judge to figure out, you

L2 know, which well, I won't use rules of the road
1? ag'ain, but to figure out what's going to be able to be
1"4 asked.
15 A It appears he overruled some of the objections'
Lo yes.
t'7 0 And then Mr. Cosby had to go forward and answer
1B things about the incident or about Ms - Constand
L9 instead of just reading the police statement in?
20 A That's what it says. Again, T don't recaIl that
2t independentlY.
22 0 Okay. So you work t.hrough. And I hope we agree
z5 t,hat f rom your statement bef ore that. you say we didn't
z.l need the Fifth, so it was never brought up in the
25 depositions.
z A Correct.
3 O Okay. You then rnove to what was ref erred to
4 earlier as a settlement of that matter, the civil
5 rnatter ?
6 A The matter settled, Yes.

1 0 Okay. And with that, simj-lar to, I guess ' some
o of the other things t,hat we I ve Iooked dt, t.he
9 documents with the National- Enquirer back and forth,
1nTJ
-L you have a very specif ic Set,tl-ement Agreement;
11 correct ?
L2 A There was a Settlement Agreement, yes.

t1 0 And you go through and there's provisions that
1A
r= get negotiated with that?
l-5 A That is correct.
I6 0 Do you recalI in those settlement ag'reements that
77 you requested a release of crirninal Iiability?
io
-LO MR. TAYBACK: frm going to
I9 object to the terms of the Settlement Agreement being
2i discussed. I believe they were protected by a
2! separate ConfidentialitY Order.
22 THE COURT: What's it have to do
23 with this case? T mean, Lf he
ztt MR. TAYBACK: And I would al-so

25 say it' s hearsaY.
45
2 THE COURT: rt's

J cross-examination. re wel-1 down the road about
We t
4 this document. It's an intent in this proceeding, you

5 know, to define hearsay now trying to shut the door
6 versus well down the road, but the confidentiality
1 part what's t.he basis of a conf identiality'
8 ag.reement between plaintiff and the defendant in a
9 civi-1 case ?
10 Hers now asking about that term'
11 Not about the terms of it, but the term of
L2 confidentiality. f'm assuming along the lines of how
t_J that was negotiated vis-a-vis an agreement '
t4 I mean, if that' s the lirnitat ion
IJ of where you I re going, then we're within a context
IO without going into the details of the agreernent.
1,1 That's what you're trying to prevent.
1B MR. TAYBACK: If he's onIY
L9 asking about the faet that it was negotiated and that
20 it was confidential-, then I wouldn't have an objection
2t to that.
22 THE COURT: Can I see counsel-
23 before I call in the court reporter? This may be

24 another one I can answer the question. It's still a
25 Iittle early for a morning breakr so we're coming

t- JOHN PATRTCK SCHM]TT CROSS 46
2 back.
3
4 (A conference was held in

5 chambers, not reported. )
1
THE COURT: PJ-ease, when we walk
B back in the room, that means wetre ready to start. I
9 would ask that you al-1 cease your communications.
10 Alt rlght. There was an
1t objectj-on based upon a question of which the Court

T2 does not have that document there. And apparently
J-J therers a paragraph in the Settlement Agreement
1"4 regarding criminal- charges.
15 And f don't know what it is, but
16 the Court has deterrnined that its present purpose is
I7 being used for cross-examination, not the truth of the
LB matter asserted. And I make no other rulinqs in that
l_9 regard, but I t m going to overrule t,he ob jection,
20 permit hlm to ask the question, and the witness can
2I answer it.
22 MR. STEELE: So Irm going to Lry
23 to pick up where f was.
24 BY MR. STEELE:
25 O So and I rm getting into the negotiat j-ons a
A1
.tI
littIe bit here on this. So originally there's a
request to basically absolve him from criminal

4 liability, and then there's a push back on that that
5 ends up in the Setllement Agreement along the language
o of that Andrea Constand cannot initiate a criminal
'7
act ion .
B Do vou recal-l- that ?
9 A that the Settlernent Agreement makes

f recall
10 reference to criminal matters. I don't reca11 the
ia
l- l- specifics of it.
T2 0 AII right.
r_3 Settlernent Agreement marked
1A
IA commonweal-th's Exhibit c-16 for identification. )
15 BY MR. STEELE:
16 O Sir, I just want You to take a look at
L't CommonweaLth ' s-16 to see if that refreshes your
1B recollection. And I just point yOU tOwards the "c'

t-9 paragraph and then what's on excuse me and then
20 on the next page, just the top few lines of that and
2T see if that refreshes your recollection -
22 A Okay.
23 o so does that help refresh your recollection in
24 terms of those portions of the Settlement Agreement?
25 A It it I now recall what the Settlement
1 JOHN PATRICK SCHMITT CROSS 4B
Agreement saysr Y€s.

3 O Okay, gteat. Now, with that, I'm reaIly just
A focused on those portions of it, you know. It
5 indicates that she will not initiate a criminal
6 complaint against CosbYi correct?
A Correct.
8 O Okay. And it also goes on to indicate if an
9 agency, Iaw enforcement, is subpoenainq or making, you
10 know, a document request, that they have to comply
11 with that.
t2 A It says theY may comPIY with it -
l3 O OkaY.
1-4 A UnIess there,s a valid and timely objection filed

15 in court.
16 O And there's a.l-so a no notice provision in there
[l if requested by the law enforcement agency?
to A Yeah. Yeah.
19 O Okay. Now, sir, you had more about a civil
20 background on things as opposed to the criminal
2L background.
22 Are you familiar with the
23 principle that if your client. not necessarily Mr.
z9 cosby, but any client would take the Fifth during a
25 deposition, potentially there would be an adverse

a
Z inference that. could be drawn on him?
A f n a civi J- matter, Ye s .
= 0 In a civil matter.
5 A r am familiar with that.
6 0 Okay.
I MR. STEELE: No other questions,
B Your Honor.
9 THE COURT: The Court has a
10 couple of questions and I will permit both sides any

l_ t- redirect and recross examination.
L2 So that I 'rn c1ear, You are the
IJ personal/corporate counsel for Mr. Cosby; is t'hat
74 right?
15 THE WITNESS: I am, Your Honor.
16 THE COURT: And that has been at
I7 least for 21" years prior to the January 2005 events
1B that we are here for todaY?
J_v THE WITNESS: YCS.
20 THE COURT: You said You started

2I in 1-983?
22 THE WITNESS: ' B3 as a junior

ZJ Iawyer. I became his principal lawyer in the early
24 '90s.
25 THE COURT: So let me first
z start with when did vou first hear that Chel-tenham

3 Pol-ice Depart.ment or Montgomery County Detectives
.t wanted to talk to Mr. Cosby? When did you first learn
5 of that ?
6 THE WITNESS: I believe it was
I just several days bef ore he act,ua1ly met .with them.

I THE COURT: So assuming that the
9 date that, he met with them was January 26Lh, is

1n that so you woul-d think a few days would be four or
11 five days before that?
L2 THE WITNESS: I believe that's
-LJ sor yes.
t4 THE COURT: At any time Prior to
It that date, four or five, had you consulted with
L6 Mr. Phitlips ?
L1 THE WITNESS: No. I had never

IB rnet Mr. Phil1ips.
l-9 THE COURT: So the reason to
)n consu.l-t Mr. Phitlips was the contact that you had
2l about the criminal case?
22 THE WfTNESS: That is correct -
23 THE COURT: How long before the

24 deposition did you -- wel1, Let me ask you first, did
25 you reta j-n Walter PhiI l iPs ?
1
f COMMONWEALTH vs. WILLIAM H. COSBY' JR. 51
z THE WITNESS: We did. We
retained Walter PhiIl1Ps, Y€s.

4 THE COURT: And You had en
5 agreement with Mr. Phillips that he would act as
6 Pennsylvania counsel in regards to any crimj-naI

.1
matters for Mr. CosbY?
8 THE WITNESS: He was retained
9 for that purpose. I don I t think there was a written

10 retainer agreement.
1L THE COURT: There was not - You
1,2 simply communicated what you needed to communicate so
13 that he would be able to represent Mr. Cosby for

1"4 anything regarding this criminal investiqation?
1_5 THE WITNESS: YCS, hC WAS
16 reLained for that PurPose-

t7 THE COURT: And who was
1B contacted about the statement on January 26Eh? Viho?

19 you or Mr. Phillips? How was the conLact made about
20 wanting to corne have the Cheltenham Police Department

2T and Montgomery County Detectives take a staternent?
22 Who was told that?
23 THE WITNESS: It must have been
24 Mr. phillips. He cerLainly I know that he called

25 and said yes. Exactly how that conversation was
1 COMMONWEALTH vs. WILLIAM H cosBY, JR. 52
2 initiated, I donrt recaIl.

3 THE COURT: In any event --
I THE WITNESS: It WASNIT MC.
5 THE COURTI -- it was not You?

6 THE WTTNESS: No -
1 THE COURT: So did You. come to
a Iearn that the purpose of the statement was criminal
9 investigators taking a staternent about an alleged
10 criminal incident?
11 THE WITNESS: I understood that,
L2 yes.
13 THE COURT: You understood that?
1,4 THE WITNESS: AbsoluteIY.
t-5 THE COURT: And if You
16 understood that, would it be fair to assume that

I7 Mr. Phillips understood that?
18 THE WITNESS: Yes, he did-
L9 THE COURT: And when the
20 statement was taken, YoD were present there?

2t THE WITNESS: I was.
22 THE COURT: And Mr. PhilliPs was
23 present there?
24 THE WITNESS: HC WAS.
25 THE COURT: And were there any

COMMONWEALTH vs. WILLIAM H. COSBY' JR- 53
1
z other attorneys representing lt{r. Cosby present at that

3 stage?
4 THE WITNESS: I think that my
5 partner, my then partner Andrew Shaw who was a

6 litigator, I believe he was present. frm not entirely
sure. He became verv involved in the civil matter-
a He may have been present there, but I'm not. entirely
v cllra
l_u THE COURT: A.l-I right. And then

11 for the the investigators' there was the Cheltenham
t2 Police Department. You remember that?
13 THE WITNESS: Chief Norris'
t4 yeah.
.LJ THE COURT: And there was a
-Lb detect j-ve f or the Montgomery Count y Detect ives ?
t'7 THE WITNESS: Mr. Peffall was
1B with Montgomery CountY -

19 THE COURT: Do You recall
2n anybody else that. vtas there?
2t THE WITNESS: I saw there was a
22 Mr. Schaffer. I donrt recall him specifically' I

23 recal1 PeffalI and Norris -
24 THE COURT: All right- Now, at

25 this stage it was clear that there was a statement
I COMMONWEALTH vs. WILLIAM H. COSBY, JR . 54
2 being taken and there were quesLions being answered by

3 your client about alleged criminal involvement. Is
4 that. fair to assume? Did you know that was why he was
q
t here ?
6 THE WITNESS : YES, I did.

1T THE COURT: And f o1l-owing that
B statement., people signed that statement, did they not?
9 THE WITNESS: That is correct.
l-0 THE COURT: And You had
1l- indicated you think that Chief Norris signed it.

L2 THE WITNESS: That aPPeared to
l-3 be his signature on iL, Yes.
t4 THE COURT: Do You glve him the
tl ? The document is not to be admitted, but
d.ocument
-Lb there were questions I just needed clarification on.
I7 MR. STEELE: I think it stiIl

1B rnay be up there.
1,9 THE COURT: Since it's not being
20 admitted. int,o evidence, I don't want to see it because
21 r don't want to at this stage put it out, but it was
22 used for cross-examination.
23 THE WITNESS: Yes, it is signed
.A
L= by Mr. Cosby. It is signed I believe that
25 signature is John Norris who I understood to be the
1 COMMONWEALTH vs. WILLfAM H. COSBY, JR. 55
za chief of police. f t is signed by rne as counsel . Itrs

3 signed by Detective Peffall. And it's signed by
4 Richard Schaffer CTPD, so I guess that !'ras Cheltenham
5 as weLl-.
6 THE COURT: Let me see it . AI
7 this point I just want to make sure that what you' re
B s aying
9 ( Handing document . )
10 THE COURT: So it was
11 Schaffer f want to make sure from you that you're

1,2 reading. So it ' s Scha f fer
l_J THE WITNESS Thatrs Pef f al-1.
-L? THE COURT: Pef f al-1.
1q THE WITNESS ThatIs me-
.to THE COURT: That's you.

T7 THE WITNESS That's Norris.
1B THE COURT: That r s Norris,
t9 THE WITNESS Thatrs Mr. CosbY
20 THE COURT: And thatrs Mr.

2L Cosby. Can you exPlain to me why his retained
22 criminal counsel didn't sign that agreement ?
23 THE WITNESS Meaning the
24 t r ans cr ipt
25 THE COURT: Excuse ltte, that
2 statement.
THE WITNESS: It was produced
obviously af ter the conclusion. It carne to rne I
5 don't recall why Wally didn't sign iL, but it I
6 donrt recall why his signature is not on it.
7 THE COURT: Let rne see it one
B rnore time.
9 THE WfTNESS: Sure.
r0 (Handing document. )
11 THE COURT: And did Mr. Cosby
L2 gj-ve any other statements to Iaw enforcement

13 aut hori t ie s ?
I4 THE WITNESS: NO.
15 THE COURT: At that statement or

16 before that statement, do you recall- any law
II enforcement authorities saying that Mr. Cosby would
1B not be prosecuted?
I9 THE WITNESS: NO '
.)n THE COURT: Mr. Stee1e asked You
2L questions regarding what will or I'1l- refer to it

22 as the National Enquirer document. Was that document
23 being negotiated during the period of January 22nd up

24 through and including February 17th?
25 THE WfTNESS: I don't know that
COMMONWEALTH vs. WILLIAM H. COSBY' JR. 57
1
z it started that earlv. I think it I think that

J negotiation started in February. I
4 THE COURT: Was the negotiation
q underway completed for any reason prior to
6 Mr. Cast.or's press release of February 17th?
1 THE WITNESS: Yes.
B THE COURT: At the time of the
9 depositions which you stated were september 29t}],

1n september 29th, March 28th and March 29th, vtere you or
11 anybody representing him at that deposition, if you
L2 know, aware of any claims in other states? whether
1"3 taken to the police or notl just aware of cl-aims of a
III similar nature ?
THE WITNESS: We were made aware
1,6 through the deposition. The plaintiff was alleging

I1 that there were ot.her women.
1B THE COURT: Thatrs the first You
1,9 learned?
20 THE WITNESS: YCS.
2L THE COURT: And were there
22 any
23 THE WITNESS : Excuse ttl€ r Your
24 Honor. In the course of making their claims, not
25 necessarilY at the dePosition.

vs. WILLIAM H. COSBY, JR- 58
1 COMMONWEALTH
z THE COURT: So it coul-d have

been before.
.1 THE WITNESS: WelI, theY filed
papers and they indicated that they had
6 THE COURT: TheY filed the civil
7 suit.
B THE WITNESS: TheY had Jane Doe
9 witnesses.
10 THE COURT: OkaY. The civil
11 suit I have being filed on March Bth; is that correct?
1,2 THE WITNESS: ThAt I S COTTECt.
13 THE COURT: And as his corPorate

'tA and personal counsel, you worked with Mr. o'connor
15 regarding that suit; is that correct? You didn't
l-o directlyr you know, administer it, but you clearly had
17 discussions regarding it?

1A THE WITNESS: I was involved in
LY the civil suit, Yes.

20 THE COURT: And were You at the
21 depo s it ion ?
22 THE WITNESS: I was.
23 THE COURT: So You were at the
24 depositions. And, againr wds the Fifth Amendment at
25 any time interposed for any questions?
l_ COMMONWEALTH VS. WILLIAM H. COSBY, JR. 59
z THE WITNESS: In the dePosition?

J THE COURT: Yes.
4 THE WITNESS: NO.
5 THE COURT: So even guestions

6 regarding non-Constand matters, there was no r'ifth
Amendrnent objection?
B THE WITNESS: NO.
9 THE COURT: And did You believe

t_0 that Mr. Castorrs press release would cover, if they
11 started to ask questions about other states or other
T2 people, that his press release would cover that?
1-3 THE WITNESS: I don't think we
14 formed an opinion one way or the other -
r_5 THE COURT: AII right. Thank
lo you very much. Now, that allows each side to have

77 another round.
1-B RED-IRECT EXAMINATTON
t_9 BY MR. TAYBACK:

ZV 0 Mr. Schmitt, could you take a look at what was
2L placed in front of You and marked as
22 Commonwealthrs-16, C-16. It's the excerpt of the
23 Settlernent Agreement .
z+ A f have it.
page there, there I s
25 0 That on the first a
1 JOHN PATRICK SCHMITT REDIRECT 60
z Paragraph C which you were asked questions about.

Do vou see that?
4 A I do.
5 O The actual words, I believer saY that "Constand
6 agrees she will not initiate any crimj-naI complaint -'r
7 Do vou see that?
o A I do.
9 0 At the time l-et me ask you this. why was
10 that in your understanding, whY was that inserted

11 in this agreernent in light of the understanding you
I2 had with the District AttorneY?
1-3 A We were Lrying to have a comprehensive agreement,
l't cover all bases.
1_5 a And "any criminal compl-a.int" would include any
16 complaint in any jurisdiction where she might go?
t7 A Yes.
1B O By the wdY, did you know whet.her Miss Constand
I9 was a United States citizen or a ci-tizen of another
20 dnrlnlttt2 e- J .
27 A f believe shers a Canadian-

22 0 Let me ask you this. You were asked
some
23 questions about how you negotiate commercial contracts

aA
LA like the specific contract with the National Enquirer
25 about a particular interview. I want to revisit that
1 JOHN PATR]CK SCHMITT REDIRECT 61
2 topic.
J A Okay.
4 0 Why didnrt you negotiate the contract like the
5 National- Enquirer agreement you were asked about with
6 the District AtCorney from Montgomery County?
I
A The District Attorney was not interested in doing
a that sort of agreement. He sort of dictated how that
9 was going to be handl-ed.
10 0 In your experience negotiating contracts, are the
l_1 parties to that contract usually voluntarily in the
T2 room toget.her; that is to sdy, the National Enquirer
l-J wants to do a deal and Mr. Cosby wants to do a deal,
1A
and you're talking to each other?
l-J A Sure.
t_6 O Mr. Cosby didnrt voluntarily engage with the
L'7 District Attorney with respect to the criminal
L8 investigation?
1,9 A He did not.
20 0 You were asked questions about the interview that
2L Mr. Cosby qave to investigators in January of 2005.
22 At the time he save that
23 interview, was it your hope that it would result in no
24 charges being flled?

25 A Sure r y€s .
1 JOHN PATRICK SCHMITT - REDTRECT oz
2 O fs it your experience as a lawyer that sometimes

your adversaries don't see the facts the same way you
I do?
5 A That is my experience.
6 a And so did you recognize that it was a
7 possibility, theoretical or otherwise, Lhat the
B District Attorney might disagree?
o A It was a possibility. It. wasn't my expectation.
10 0 it had been the other u/ay and the District
And it
t- 1- Attorney had disagreed and continued to investigate or
L2 brought charges, did you understand that you had the
t< right or Mr. Cosby would have the right to assert the
1,4 Fifth beyond that date of that interview?
l_J A Absolutelv.
t_6 0 Let me ask you about Exhibit 4 which is the press
1"1 release itself. Itrs a two-page press releasei
1B correct ?
19 A It is.
20 O And when Mr. Steele asked you questions about
2'J" this press release, you recal1 he asked you about one
22 specific sentence.
z5 Do vou remember that?
24 A I do.
ZJ 0 Now, if you look at the first page of the press
1 JOHN PATRTCK SCHMITT - REDIRECT 63
a
L release/ there are multiple paragraphs that describe
3 the Office of the Montgomery County District Attorney
.) and the nature of the investiqation and what.
5 investigat j-ve steps were taken.
6 Do vou see that?
I A I. do.
I 0 Now, j-n the second page there's another couple
9 longer paraqraphs. The first fuII paragraph that
t-0 starts "After reviewing the above" and you see it ends
11 with the phrase "District Attorney Castor declines to
1-2 authorize the filing of criminal charges j-n connection
1_3 with this matter. "
t4 Do vou see that?

15 A I do.
L6 0 In that paragraphr wds it significant to you he
II rl'i rlnrt- e>\' that he reServed his right tO re-Open the

1B investigation should other evidence come forward?
1,9 A Yep. I understood this to be a f inal decis j-on.
20 0 Now, the sentence that you were directed to
21" that page, go to the next paragraph was a sentence
22 in the middle of this last paragraph. Do you remember
23 it? It was the sentence that says:
"District
24 Attorney Castor cautions aIl parties to this matter
z3 that he wilI reconsider this decision shoul-d the need
1 L]OHN PATRI CK SCHMITT REDI RECT oq
2 arise. tt
J Do you see that?

4 fl r do.
5 0 What did you understand that. to be referring to?
6 nn Well-, it's referring to the decision not to
I expound publicly further on the case.
a
O So itrs referring
to the decision that is
9 described in the sentences in this paragraph just
10 above t.he one that Mr. SteeIe showed vou?
11 A Riqht. He I s yes.
T2 0 And not to a decision to re-open the
13 invest.igation at some point in t.he future?
14 A Right. I mean, he's telling us not to make
1q public statements that could poison the juror poo1,
T6 but Lf we were to engage in what he refers to as
11 rhetoric, that he wouLd revisj-t his decision not to

r_B speak further about the case.
19 MR. TAYBACK: No further
20 questions.
2), THE COURT: Recross examination.
22 (Office of the District Attorney
23 Press Refease dated January 24, 2005 marked
24 Commonwealthrs Exhibit C-I7 for identification.)
25
1 JOHN PATRICK SCHMITT RECROSS 65
z RECROSS_EXAMINATION
J BY MR. STEELE:
4 0 There's one thing I wanted to clarify. I'm going
to show you Commonwealth Exhibit I7 which I would ask
6 to admit. Ir11 show it to you. f was referring to a
7 press release from Mr. castor on January 24th of I 05.
I And in that, therers a Portion
v down towards the bottom that discussed, You know, his
10 request to have Mr. cosby meet with detectives and
11 give a statement.
L2 A I see thatr Y€s.
13 o Yes?
1lt A Yes.
15 O And you were aware of that request through this;
1-6 right?
L'7 A I was aware of the request. I dontt know that it
l8 was through the Press release that I became aware of
19 that request.
20 O You learned it through Mr - PhilIips?
2T A Yeah. I mean yes. This indicates that he had
22 asked Mr. Phi]lips for permission to interview Mr.
23 Cosby.
24 O Okay. I just wanted to clarif y t'hat because I
25 brought that up earlier about the press release that
1 JOHN PATRICK SCHI\4ITT RECROSS 66
2 had been done on the 24Lh. I want to go back to a
3 couple things that you just said.

I The judge asked you if you knew
5 about any other allegations at the time. And you said

6 fror you just learned that through the deposition. I
I want to focus vou
B A I said through the discovery.
9 O The discovery' okay. I want to focus you back on
10 your agreement with the National- Enquirer thatrs up

11 there.
L2 Wasn't that whole thing about
13 those allegations from somebody else about things that
I4 the defendant had done? And that was what the
15 negotiation was about with the National Enquirer, that
16 they werenrt going to print an article about that and
t7 then your client was going to testify or

1B A You r re correct. And I st,and corrected. We had
19 heard through the National Enquirer that they were

20 going to publish a story about another woman, thaL is
2t absolutely correct. And that was about a month before
22 the discovery, two months before the discovery
23 started.
z4 O So you were asked about the press release that
25 r,ras given to your the one where you're indicating that
1 JOHN PATRICK SCHMITT RECROSS
2 that's your declaration that he's not going forward on
ir.
qA You would aqree with me that the
5 Iine about potentially re-opening something coul-d be
6 somewhat a matter of interpretatj-on?
1 MR. TAYBACK: Objection to the
o use of the word re-openingr dctually'
9 MR. STEELE: f don't have it in
L0 front of me.
11 THE COURT: WeIl, get it in

1,2 front of you because if you use a word that's not
tl there, you're going to get an objection'
r.t MR. STEELE: OkaY -
-LJ BY MR. STEELE:

to o so I'1I be specific on this. District Attorney
L1 castor cautions aIl parties to this matter that he
1Q wilI reconsider this decision should the need arise'
t9 A No, I dOnft think it's ambiguous, because in the
20 context it starts out because he's talking about a
21, civil action. Burden of proof is different'
22 He exoecLs that there's going to
23 be he does not want to speak further because he
24 doesn't want to contribute to publicity and tai'nt
25 prospective jurors.
I JOHN PATRICK SCHMITT RECROSS 68
z He doesnrt intend Lo expound

{ publicly on the details, it appears/ for fear that his
4 opinj-ons will affect jurors, cautions us not to engage
5 in rhetorj-c such that we would potentially taint
b jurors, that there is much in here that could portray
7 both sides in a Iess than flat!ering 1ight.
o But if, in factr w€ go ahead and
9 proceed to make statements, he's going to reconsider
r_0 his decision not to make statements.
11 0 On cross-exarnj-nation yesterday, he said something
12 different.
13 A We1l, I donft. know what he said, but I can tell
I4 you what I understood.
15 0 fs there any interpretation
16 THE COURT: Hold on. Statements
T7 by counsel I'm not going to consider. You'l-1 argue
1B what he did or d j-dnrt say. Just ask him a question.
19 BY MR. STEELE:
20 0 So with all of this writing that you do in
2t negotiating specific terms, that didn't cause you any
22 hesitation in going forward with depositions and other
23 things that you did in this case?
24 A Ifm did this language
25 O Yeah.
.JOHN PATRICK SCHMI TT RECROS S
69
1
2 A give rne caution going forward?

3 o Yes.
4 A No, because T understood that we had this and I
5 had the assurances given to our crirninal counsel.
6 O You've said that.
1 A You asked me again.
U O So you never and in terms of this, You know,
9 the deposit.ions and everything you did, you never, you
10 know, said that, YoD know, ?s part of, you know,
11 stipulat.ions or getting on the record, you never took
I2 it to the judge, you never catled and clarified
J-J anything with Mr. Castor; correct?
I4 MR. TAYBACK: Objection.
t-5 Compound and, I believe, asked and answered'
Ib THE COURT: OkaY. Put that into
L7 EngIish. Did you understand the question?

18 THE WITNESS: I'm not sure f
t9 understand the question.

20 THE COURT: TrY to ask it so the
21" witness understands.
22 MR. STEELE: I'11 break it down
23 here.
24 BY MR. STEELE:
25 0soatnopointinthesedepositionsandwhen
1 JOHN PATRICK SCHMITT RECROSS 70
z you're having your client sit for thern do you clarify

J that in any of the preambles or anything like that?
: A Clarify
5 a That language.
6 A This language
7 0 That there's nothing that can happen to' your
a client over this.
9 A This is referring to a criminal matter- That
1_0 criminal matter was closed. There was no reaSon for
11 me to be referring back to the criminal maLter in this
L2 civil context. Therers no I donrt thatrs my
13 answer.
l4 O WeII, You refer to it throughout. There's a
L5 statement that's referred to in the deposition. That'
T6 was part of the criminal matter; right?

L'7 A f don't know what statement you're referring to.
1B O Mr . Cosby I s stat.emenL, the one you sat through.
L9 MR. TAYBACK: Objection.

20 Argument at ive .
2L THE WITNESS: T MCAN
22 THE COURT: He said statement.
23 He I s clarifying.
24 THE WITNESS: f'm sorrY? What' s
25 the questj-on now?
t JOHN PATRICK SCHM]TT RECROSS 71-
z BY MR. STEELE:
1
a Mr. Cosby's statement that you sat through, was
4 that involved in the criminal rnatter?

5 A In the criminal matter?
6 O Yes.
A Yes, it was.
B O And then that was referred to within the
9 deposition; right ?
10 A Wel], the civil case was rnaking the same
1t_ al- Iegat.ions that. she had brought' to
I2 O Yes.
A Ri ght, .
1_4 O That t s correct; right?

lo 0 okay. And at no point during this do you clarify
L7 Mr. Castor,s press release or the things with t.he
1B with Mr. Phillips, the things that were supposedly
19 said to Mr. Phillips with a federal judge that was
20 overseeing this case?
2t A It wasnrt at issue.
22 O I asked whether You did it or not '
ZJ A We11, no.
24 O OkaY,
25 A OkaY.
I JOHN PATRICK SCHMITT RECROSS IL
0 Is that simple enough? Yes or no?

THE COURT: A1l right . Just ^ ^ t-
crDj\
4 him the questions.

q BY MR. STEELE:
6 O A11 right. Now, you heard about us re-oPening
7 this case; correct?
B A Yes, I did.
9 O Okay. And at no point did you come forward and
r_0 say anything about this agreement that was that you
11 understood had occurred back in '05, did you?
).2 A Did I come forward?
13 O Yeah.
t4 A NO.
t\ MR. STEELE: I have no other
16 questions ' Your Honor

I rm
T7 THE COURT: AnY further
1B ready to cut it off . If it's important, I'11 a1low
I9 reredirect.
zv MR. TAYBACK: No, I have no
2T questions.
22 THE COURT: A11 right- Then
23 that woul-d conclude the testimony of Mr. Schmj-tt -
24 Thank you very much.

25 THE WITNESS: Thank You, Your
Z as f ar as we can tel-1.
3 There is
4 THE COURT: Let me if You're
5 going to relate to it aqain, I mean, again, was
6 your premise is here that I now am takj-ng everything
.7
that Mr. Castor said as an absolut.e f act in terms of
B promise. What you're arguing now is this is now a
9 promise and that's what your c1j-ent took it dsr a
10 promise, and your client was never a defendant in this

11 case.
L2 So if vou have those cases --
13 and, again, I arn assuming the Dunn case, this was a
L4 defendant who they .sought to have testify and, if he
15 testified, they would nol-pros his case which is
L6 different. than not prosecutLng, but sounds the same'
L1 non-pros the case.
1B But so that I'm sure, wds there
19 any writing in the Dunn case? Was it subject to a
20 writing?
2I MR. TAYBACK: The Dunn case r^ras
22 an oral agreement. It was on the record.

ZJ THE COURT: On the record in
24 front of a j udqe ?
25 MR. TAYBACK: fn front of a

I COMMONI{EALTH VS . WILLIAM H . COSBY, JR 269
L judge.
THE COURT: Again, I donrt mean
.tA to be showing my hand, but if you have those cases

5 that are, you know, more close to here where you don't
6 have a j udge invoLved and it was not. t.o a def endant
1 who was charged and, you know, there was/ you know,
8 there was no recording of it, just Iet me know.
9 t'lR. TAYBACK : I wi l- 1
1-0 THE COURT: Other than that, I 'm
l1 golng to assume
l2 MR. TAYBACK: I will say that

13 there is no case that we have found that Lurns on it
1i
being a writing, that turns on it being transcribed,
1-5 that says if only you had had it transcrj"bed, that
l-6 would be the magic of having a court reporter there or
L7 have it in writing otherwise. It's not a statute of
1B frauds kind of case.
L9 THE COURT: Aqreed' but, again,
ZV your whole argument is Premised that this Court
2I believes everything that Mr. Castor said because he's
22 the only one testifying as to a promise- He's the
t? only one, It's not. Mr. Phillips isn't here ' Mr '
24 cosby t in the roorn. You weren't in the room.

wasn t
25 Mr. McMonagle. There's no other witness to the

1 COMMONWEALTH vs W]LLIAM H. COSBY, JR 2'7 0
z promt_se.
So what Irm trying to say is

4 you've kind of you know, the rabbit is in the hat.
5 And you want me at this stage to assume that, hey, the
6 prornise was made, Judge. Just accept that. And nolt
everything eJse doesn't reaIly and I just wanted to
B rnake sure that if there's cases in which there's
9 like thls where one person said they made the promise
L0 or a potential defendant claims a prosecutor made the
11 promise, that might he1p, too, you know. But f just
1,2 wanted to rnake sure that by the fact yourre arguing it
13 doesn I t make the promise enforceable.
L4 MR. TAYBACK: And I understand.
15 And Irm certainly not assuming that you have to make
lo that determination. You are the finder of fact on

l'1 this issue and I intend to persuade you why that is
1B true.
19 THE COURT: I appreciate it.
20 MR. TAYBACK: But my point is
2T t.hat if that is true, their arguments that have been
22 framed now by the Commonwealth that are independent of
23 that credibility determination, theyrre legal
24 arguments. And those legal arguments should be flatly
25 rejected based on the facts as they have come out.
EXHIBIT 4
AFFIDAVIT OF BRUCE.L. CASTOR. JR.. ESQUIRE
l, Bruce L. Castor, Jr., Esquire, provide this Affidavit to Attorneys Brian W. Perry
and Kristen L. Weisenberger, in lieu of giving a compelled deposition, and with the
knowledge that instead of my compelled deposition, this Affidavit will be attached as an
Exhibit to a Petition for Review Pursuant to Pennsylvania Rule of Appellate Procedure
1762(b)(2), related to the criminal conviction of William H. Cosby, Jr., at docket CP46-
cR-3932-2016.
1. In 1998 and 1999, as Montgomery County First Assistant District Attomey, I
campaigned for the Republican nomination for the position of Montgomery
County District Attorney against Attomey Steven T. O'Neill, a private
practitioner in Norristown, Pennsylvania.
2. In or about January or February of 1999, at the Upper Moreland Township
Building in \Mllow Grove, Pennsylvania, l engaged in a debate against Steven
T. O'Neill. At that point, lwas not aware that Judge O'Neillwas or had been
engaged in an extramarital affair with a female Assistant District Attorney
employed by the Montgomery County District Attorney. At the election debate
at Upper Moreland Township Building in \Mllow Grove, Pennsylvania, the
female Assistant District Attorney was present. Attorney O'Neill oddly
seemed distracted, unfocused, and nervous in that debate, despite the fact
that as a trial lawyer, he was an accomplished public speaker.
3. The next morning, I received a callfrom Montgomery County Republican
Party Chairman Frank Bartle, who indicated that he had just received a call
from Bill Donnelly, a key supporter of Steven O'Neill's campaign for District
Attorney of Montgomery County and the political leader of the Party that
encompassed Upper Moreland Township. Mr. Donnelly informed Mr. Bartle
who relayed it to me that he, Donnelly, thought placing the female Assistant
District Attorney in the front of the debate to distract Steven O'Neill was
playing dirty politics.
4. I responded to Mr. Bartle that no one on the campaign had anything to do
with the female's attendance at the debate and that was the first time I
learned Attorney O'Neill was having, or had, an affair with the female
Assistant District Attorney who worked in my office.
5. In approximately February or March of 1999, I anived at a political event at
the Bay Pony Inn in Harleysville, Pennsylvania. Around 11:30 a.m. (l
believe), I exited the political event with a number of individuals, including my
wife, Frank Bartle, the Montgomery County Republican Party Chairman, his
wife, and State Representative Bob Godshall. Our group encountered Steven
O'Neill as he anived to the event with a woman that I later learned was his
wife. I specifically recall Bob Godshall asking Mr. O'Neill if the woman with
him was his wife. This caused Mr. O'Neill to angrily accuse me, and the
entire group, of running a smear campaign and trying to ruin his maniage and
life. I remember Mr. O'Neill's wife saying similar things at that time. They
both reacted with what I thought were overly dramatic gestures and language.
6. I eventually won the Republican Party endorsement for District Attomey of
Montgomery County, causing Mr. O'Neill to withdraw his name from
consideration from the election.
7. ln the spring of 1999, I was nominated by the Republican Party to be its
candidate for District Attorney of Montgomery County, Pennsylvania. In the
fall of 1999, I was elected as District Attorney of Montgomery County.
8. There is no question in my mind that Mr. O'Neill blamed me and my political
supporters for raising his marital infideli$ in a "smear campaign" to defeat him
in the election for Montgomery County District Attorney. lt is my belief that
Mr. O'Neill has never forgiven me for this.
9. I would describe my relationship with Mr. O'Neill over the next sixteen years
as strained and tense. I would not describe the relationship as overtly hostile,
however, since I seldom came in contact with him while serving two terms as
District Attorney and two terms as Montgomery County Commissioner. Our
paths rarely crossed.
10. Steven O'Neillwas appointed to the Montgomery County bench in April 2OO2
by then Governor Mark S. Schweiker. He was later elected to a ten year term
in2OA4 and retained for another ten year term in 2014.
11. From 2OO2 until 2008, while I served as District Attomey of Montgomery
County, I do not recall ever personally appearing in front of Judge O'Neill. I
can say with certainty that I never handled a contested case of any
significance before him because as District Attorney, I only personally

prosecuted a handful of cases each year year, and I would remember trying a
contested matter of import before him. ln fact, as I had the authority to assign
prosecutors to cases, lwould have assigned another prosecutor to any
significant contested matter scheduled to occur before Judge O'Neill so as to
avoid being put in a position where Judge O'Neill could embarrass or
humiliate me and potentially damage a prosecution.
12. After I left the Office of the District Attomey and entered private practice, I do
not recall appearing in front of Judge O'Neill as an attorney in any capacity.
Again, I can say with certainty that I never represented a client in a contested
matter before Judge O'Neill. But I don't think I ever handled any matter
before him either as DA or in private practice. I suppose some matters are so
routine that I might forget appearing before him, but I never appeared before
him for anything contested that I can think of.
13. However, I do recall Judge O'Neill approaching me in my capacity as
Montgomery County District Attorney seeking my support for a project known
as drug court. Although I did not think at the time this program made good
prosecutorial sense for the County, after repeated requests for my support, I
relented. My approval was dispositive of drug court coming into being. lf the
DA would not agree to the institution of the program, it could not get off the
ground. I believe that Judge O'Neill resented the fact that he had to ask me
to support this program for it to be initiated.

14. I was elected Montgomery County Commissioner in 2OO7 and later reelected
in2A11. In my capacity as Commissioner, I recall Judge O'Neill coming to
see me in an attempt to gain my continued support for funding drug court
program, which he strongly supported and had oversight of. I had made clear
publicly that I thought drug court cost too much money for the limited number
of people Judge O'Neill claimed as success stories. As a Commissioner
coming from a prosecution background, I had serious misgivings concerning
whether the continuation of drug court made prosecutorial and economical
sense. Again, I relented. But, it is my belief that Judge O'Neill resented the
fact that he needed to ask for my support for his drug court program.
15. Regarding the case of Commonwealth of Pennsylvania v. \Mlliam H. Cosby,
Jr., docket number CP-46-CR-3932-2016, I believe that Judge O'Neill
assigned himself to this case in part because he knew that I made the
decision not to prosecute Mr. Cosby in 2005 and I would be at the center of
whether this case could proceed to trial.
16. On September 4,2018, preceding defense counsel sent an investigator to
interview me about whether Judge O'Neill has a personal animosity against
me because he has never forgiven me, or my campaign, for thinking we used
his extramarital affair during the campaign of 1999 for political gain when we
both sought the post of District Attorney of Montgomery County. The
investigator contacted me. I did not reach out to the Cosby defense team.
17. lwas subpoenaed as a defense witness in a Petition for Writ of Habeas
Corpus/Motion to Disqualify Montgomery County District Attorney's Office in
front of Judge O'Neill on February 3,2016. In that February 3,2016
proceeding, it was evident to me there existed in the courtroom tremendous
animosity from Judge O'Neill toward me from the moment that I took the
stand. lt was obvious from his tone and line of questioning that Judge O'Neill
felt very negatively towards me. In fact, at one point during my testimony, I
suggested that I not answer a particular question in public but instead rn
camera or at sidebar because I thought my answer would be inflammatory
and affect future jurors in the case if publicly reported. In response, I
perceived Judge O'Neill's facial expression towards me as one of disgust. He
also made statements that he thought it was ridiculous that I would make
such a statement. We went in camera and Judge O'Neill later ruled that I was
to testify more vaguely than the full truth for the precise reason I stated was
my reason for believing he should hear my answer in camera or a sidebar in
the first place.
18. I believe that by finding that a non-prosecution promise did not exist, and by
finding me "incredible," Judge O'Neill attempted to hurt me publicly and
professionally as a political payback. At the time we ran against each other,
Judge O'Neill was a heavyweight political operative from Lower Merion
Township which had the most money and the largest single voting block of
delegates to the nominating convention. I was a career civil servant who

entered politics only to run for DA. I believed that, and I still do, that Judge
O'Neill felt he was "entitled" to the nomination for DA and that I had not
"eamed" my chance to run by working in the political trenches, my record of
successes to that point as a prosecutor notwithstanding.
19. Regardless of innocence or guilt in this case, I believe that what happened to
Mr. Wlliam Cosby should never happen to any American citizen in any
American courtroom. I have been in and around government and the justice
system for 37 years. In many ways I am a product of the system: completely
beholden to the rule of law, the presumption of innocence, the burden of proof
being on the government in criminal cases, and the Exclusionary Rule as a
remedy for govemmental constitutional violations. I am also absolutely a man
of my word, and when I said to Cosby through his counsel the
Commonwealth was not going to prosecute him, I meant just that: he could
never take the Fifth Amendment because it was impossible for him to
incriminate himself criminally, but he could incriminate himself civilly as
occurred. As the chief law enforcement officer of Montgomery County, I
intended to forever bind the Commonwealth of Pennsylvania from a future
prosecution of Mr. Cosby related to the facts and circumstances of the case
involving Andrea Constand. I believed at the time that the allegation was
made that there was insufficient evidence to convict Mr. Cosby on the facts as
presented to me, something that time has shown was an accurate
assessment. My goalwas to obtain some measure of justice by assisting a

civil resolution and forcing Mr. Cosby to testify and give evidence in a civil
case that I knew would be filed. Because l, as the District Attorney of
Montgomery County, decided that Mr. Cosby would not be prosecuted for
these alleged crimes, he would not have been able to assert his Fifth
Amendment protection in any civil proceeding related to the anticipated civil
suit. Had he tried, I would have certified to the presiding judge that Cosby
was not going to be prosecuted ever, thus ensuring that nothing Cosby said
could prove incriminating and opening him up to having his testimony
compelled.
20. I clearly communicated my intention to Mr. Cosby's attorney at the time,
Walter Phillips who, as a former high level prosecutor himself and long time
criminal defense lawyer, immediately understood the ramifications to Cosby
civilly. There is no question that Mr. Cosby relied upon my representation
when he submitted to depositions in the civil case related to the allegations
made by Ms. Constand. Indeed, it strains credulity that given Cosby's
resources and access to able counsel, there is any other reason but for my
representation that Cosby would fail to invoke his Fifth Amendment
protections. Indeed, Constand's civil counsel, who took Cosby's deposition
and knew what he had said that was incriminating for a criminal case, never
asked me to review it with an eye toward re-opening the Cosby investigation.

I swear and affirm that these facts are true and correct to the best of my
knowledge.
toltolt(
CourrorxDcAt-r tt O F Qeor-:sg tuAutA

Qhopr1 oF NrdJrcou.eeq -
Swom to and subscribed
before me this dOry
Q. Q-o45,
My commission expires: -\.t
ronwealth of Pennsylvanla - Notary Seal
MelanieAltemus, Notary Public
MonlgomeryCounty
My commission expires April 2, 2022
Commission n umber 1 255 1 42
EXHIBIT 5
ill
rill
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il:l IN THE COURT OF COMMON PLEAS OF MONTGOMERY COUNTY, PENNSYLVANIA
ttl I
CRIMINAL DIVISION
iti!
ft, COMMONWEALTH OF PENNSYLVANIA No. MD-3156-15
{ill
l:r I
V.
t\{, WILLIAM H. COSBY, JR.

Ril
t"r
lltl
ORDER
AND NOW, this Y . aay of February,2A16, it is hereby ORDERDD as follows:
based upon review of all the pleadings and filings, the exhibits admitted at this
hearing, and all testimony of witnesses, with a credibility determination being an
inherent part of this Court's ruling, the Court finds that there is no basis to grant the
relief requested in paragraph 3b of the Defendant's Petition for a Writ Habeas Corpus
and, therefore, the Habeas Corpus Petition seeking dismissal of the charges is hereby
DENIED.
BY THE COURT:
Cooies of this Order

maired_o.n 4: l:l=
I lQ
to the following:
Brian J, McMonagle, Esq.
Kevin R. Steele, Bsq.
I{onorable Elizabeth A. Mcl{ugh
Honorable William J. Furber, Jr., President Judge
EXHIBIT 6
fosnPn P. GnnnN, Jn. Attorney for Defendant
Atry L D. No. 32604
I38 West Gay Street
West Chester, PA 19380
Telephone: (6 I 0) 692-0500
COMMONWEALTH OF PENNSYLVANIA IN THE MONTGOMERY COUNTY
COURT OF COMMON PLEAS

vs. l*..:
CRIMINAL DIVISION (:;::) -': I
-:l
WILLIAM H, COSBY, JR. No. CP.46-CR-00039 32-20L8 -fl
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MOTION FON DISCLOSIJNE, NECASAL T.
'=
AND FON NECONSIDERATION OFNECUSE.T, :ct\

Defendant Moves this Honorable Court for Disclosure, Recusal and For
Reconsideration of RecusaL, In support of that Motion, defense counsel sets forth the
following:
1. Defendant was charged on or about December 30, 2015, with various
offenses alleged to have occurred in or around January of.2004. After a mistrial
resulted.from a deadlocked jury, defendantwas found guilty on April 26, 2018, on 3
Counts of Aggravated Indecent Assault in violation of 18 Pa.C.S. S 3125.
2. On January 11, 2016, prior defense counsel filed a Petition for Writ of
Habeas Corpus and Motion to Disqualifr the Montgomery Cou:rty District Attorney
(herei:rafter', "the Petition"). On or about January 13, 2016, the case was assigned to
the Honorable Steven T. O'Neill. Judge O'NeiIl entered an Order. on that date
directing that the District Attorney file a response to the Petition within 14 days.
The District Attorney filed a response on January 2A,20L6.

3. On January 22,2016, Judge O'Neill entered an Order scheduling a
hearing on the Petition for February 2,2016. That Order provided, in relevant part,
that the hearing would be 'limited to the issues regarding a non'prosecution
agreement."
4. At the time of the filing of the Petition, and certainly by the time the
Response wag filed on January 20,2016, and the Ord.er was entered on January
22"d, it was manifestly apparent that the credibility of Bruce L. Castor, Jr., would
be a primary issue ia the resolution of the Petition.
5. On February 4,2018, aft,er a hearing, the Court entered a:a Order
denying the Petition, stating that"a credibility determination" was "an inherent
part" of the Court's ruling. That credibility determination was an express finding
that the testimony of the former District Attorney, Mr, Castor, was not credible.
I. MONON FOR DISCLOSURE
6. The Court made no disclosures, at any time before, during or after the
hearing, that the Court had long been embroiled in a personal conflict with Mr,
Castor that can only be deseribed as nasty, including conduct by Mr, Castor directed
at Judge O'Neill, that would cause any reasonable person, i:rcluding any reasonable
Judge, and "a signifisa.t minority of the lay commuoity," to conclude that the Court
could not possibly be impartial regarding Mr. Castor's credibility.
7. On or about March 28,20L8,an article was published by Radar
Online, an Internet gossip site owned by American Media, Inc., the publisher of,
inter alia, The National Enguirer, with the headline " BilI Cosby Judge Steven T.
O'NeilI Kept Relationship Secret, Used As Grudge Against l{ey Wtness: Sources," A
, copy of this article is attached hereto as Exhibit A, This article may be accessed at
https://radaronline.com/exclusives/2018/03/bill-cosby-judge'steven't'oneill-relations
hip'secret' used' grudge'witness/.
8. Neither the defendant, the defendant's original counsel, Brian J.
McMonagle, nor his subsequent trial counsel, Thomas A. Mesereau, &., had any
knowledge of these subjects at the time of the original Due Process hearing in 20LG
or the trials 1n 2077 or 2018. This pre'sentence filing is the defendant's first
opportunity to raise the issues asserted herein,
9. Facts uncovered by subsequent investigation by undersigned counsel,
and others, has led undersigned counsel to the following conclusions:
A. The most-lilely source of the Radar Online article was Bruce L.
Castor, Jr., himself. NIr. Castor has denied to an investigator retainsfl fy

undersig:red counsel that he is the source of the article. The source of the
article appears to have painted the circumstances in the light most favorable
to I\4r'. Castor.
B. Mr. Castor was serving as Filst Assistant District Attorney in
Montgomery County in 1998 and 1999 i.n the run'up to the 1999 election
campaign for District Attorney. Mr. Castor was a candidate for the
Republican nomination for that office. Steven T. O'Neill was also a candidate
for that nomination, In that era, the endorsed Republican candidate was
highly likely to be the eventual winner of the general election for any
Montgomery County office, inclurl'ing the office of the District Attorney.
C. Prior to 1998, Judge O'Neill was sepa-rated fi'om his wife and
dating a single woman who was an employee of the District Attorney's Office.
That relationship ended well before the.1998-1999 campaign.
D. During the 1999 endorsement campaign, Castor and O'NeiIl
both appeared at various County Republican Committee meetings and
debates.
E. During the Spring of 1999, before the Republican Committee
met to award its endorsement, Castor ordered the female member of his staff
to appear at the next impend-ing debate between he and O'Neill. The staff
member was upset by this order and reported it to her supervisor at the DA's
Office. Illtimately she followed Castor's order and appeared at the debate
accompanied by two other attorneys from the District Attorney's staff. This
order was manifestly unlawfirl (as a form of "macing," cf.25 P.S. SS 2374-
2375), and served no legitimate purpose. Rather, it appeared only to be a
petty attempt to rattle or distract Mr. Castor's opponent,
F. When Judge O'Neill learned that the female staffer had been
ordered to appear at the debate, O'Nei1l was angry and confronted Castor,
who O'Neill believed had unfairly and. underhandedly abused. his posif,ion as
First Assistant Distrief Attorney. The relationship between Castor and
O'Neill became increasingly acri''"onious, and has remained so to this date.
G. Ultimately Castor secured the Republican nomi-nation. Jud.ge
O'Neillat first attempted to organize a Primary Election campaign opposing
Castor for the Republican nomination to run for the Office of District
Attorney, but eventually decided to abandon that effort,

H. Judge O'NeiIl subsequently received a Gubernatorial
nomination to, and was later elected to, the office of Judge of the Court of
Common Pleas. Throughout his terms on the bench, Judge O'Nei1l's
relationship with Castor, serving as District Attorney and later as a County
Commissioner. has remained hosti-Ie and acrimonious.
10. As applied to the assessment of Castor's credibility made by Judge
O'NeiiI in resolving defendanf,s Due Process claims in 2016, these facts constitute
information that "the parties or their lawyers might reasonably eonsider relevant to
a possible motion for disqualification or recusal, even if the judge believes there is
no proper basis for disqualification or recusal." See, Comment (g), Rule 2.7, Code of
Judicial Conduct. See also, Comment (5), Rute 2,1I-, Code of Judicial Conduct (A
judge should disclose on the record information that the judge believes the parties
or their lawyers might reasonably consider relevant to a possible motion for
disqualifieation, even if the judge believes there is no basis for d"isqualification.)
L1. The Court was requiled, and is now required, to state on the record the
true facts of his interactions with Mr. Castor beginnipg with the 1998 prelude to the
1999 election campaign for District Attorney.
WHEREFORE, defendant respectfully requests that this Honorable Court
disclose, on the record, the true facts of his interaetions with Mr. Castor beginning
with the 1998 prelude to the 1999 election campaign for District Attorney,
N, MOTION FON RECUSAL,
AND FON NEW IIEANING ON DUE PROCESS MOTION
L2. At the time that the Coult denied defendant's Motion To Dismiss, and
made an adverse ffedibility determination regarding Mr. Castor, the Court should
lrave disqualified itself sua spontebecause the Judge's impartiality might
reasonably be questioned due to the Judge's personal knowledge of and bias against
Mr. Castor. See, RuIe 2.11G0(f) (Oisqualification),
13. The Comment to the Rule suggests that the Court should have
exercised its discretion to recuse itself because the "prevailing facts and
circumstances could engender a substantial question in reasonable minds as to
whether disqualification nonetheless should. be required." See, Comment (Z), Rule
2.7L.
14, Defendant respectfully requests that the Cowt vacate its Order of
February 4,2076, denying the defendant's Habeas Corpus Petition, because that
Order necessarily relied upon an assessment of the credibility of Mr. Castor ("with a
credibility determination being an inherent part of this Court's ruling").
WHEREFORE, defendant respectfully requests that this Honorable Coult
Vacate its prior Order denying the defendant's Habeas Corpus Petition, and its
credibility determirnation, and Recuse itself from further proceedings herein,
III, MOTION FOE RECONSIDERATION
OF DENTET, OF MOTION FOR NECUSE-T-,
16. The Court has previously denied the defendant's Motion For Recusal
on the basis that the Court would be presid.ilg over a jury trial, and that the jury
would conduct the fact fi:rding, See, Order dated February 4,2016, (stating that the
Order denying the Petition was entered "with a credibility determination being an
inherent part of this Court's ruling")i see also N.T. March29,20t8, at 67 ("So as f
engage in this conscientious self-examination as to whether I cari assess this case
and preside over ihis jury trial where I am not the fact find.er, can I d.o so fairly and
impartially? Again, I note that actual bias is not alleged. It is the bias conneeted
with the appearance of implopriety that counsel has advanced in its argument.")
16. The Commonwealth has requested that the Court act at sentencing as
the fact fi.nder regarding the veracity of unidentifi.ed claims of uneharged
misconduct. See, Motion to Admit Euidence of [Jncharged Crimina] Acts Committed
by Defendanr (fiIed September 4, 20LB).
L7, Under these changed, circumstanees, the Judge's impartiality might
reasonably be questioned because of the Judge's personal knowledge derived fi'om
the work of his wife, who has expressed strong views regarrl'ing the believability of
disputed claims of abuse. See, Rule 2.116X1) (Disqualification). Defendant seeks to
incorporate herein the evidence arid arguments adduced on March 29, 20'1"8, as if set
out here at length.
18. The Comment to the RuIe suggests that the Court should exercise its
discretion to recuse itself here because the "prevaiJing facts and circumstances could
engender a substantial question in reasonable ninds as to whether disqualification
nonetheless should be required.." See, CommentQ), Rule Z.tt.

WHEREFORE, defendant respectfully requests that this Honorable Court
enter an Order granting the Motion For Recusal from further proceedings herein.
Re sp ectfully submitted,
of
Jaw offices
Josnpv P. GREEN, fR.
Dated:
TryNIFTCATION
COUNSEL HEREBY CERTIFIES that the facts set forth in the foregoing
Motion are true and correct to the best of counsel's knowledge, information and
belief This veri-fi.cation is made subject to the penalties for unsworn falsification set
forth in Section 49}4of the Crimes Code, 18 Pa.C.S. S 4904 (Unsworn falsifieation
to authorities).
CENTTTT CATE O F C OMPLIANC E
I certify that this fiIing complies with the provisionsof the Public Access
Policy of the Unified Judicial System of Pennsylvania: Case Records of the
Appellate and Trial Courts that require filjag confidential information and
documents differently than non'confidential i
Attorney ID No. 32604

Bill Cosby Jutlge Steven T. O'Neill I(ept Relationship Secret, Used As G... https://radaronline.com,/exclusives/2018/03/bill-cosby-judge-steven-t-onei.,.
l f rch...
Exhibit A
co$tsY TRTAL C|{A0S

Bill Cosby Judge Steven T. 0'Neill Kept Refationship Secret,
Used As Grudgt Against Key Witnessi Sources
Trial rocked on eve amid calls for Judge Steven T. O'Neillto be recused.
'15
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By Dylan Howard
Posted on Mar 28,20'18 @ 16:26PM
SHANE
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The sex assault retrlal of Bill €osby has been rocked on lts eve wlth accusatlons the presldlngJudge, Steven T,
O'Neill, had a blow out fight wlth a key witness arlslng from allegatlons of a close relationshlp he had wlth that
wltness's employee,
I of 9 6/2112018,12:55 PM
Bill Cosby Judge Steven T. ONeill IGpt Relationship Secret, Used As G.., https://radaronline.com,/exclusives/2018/03/bill-cqsby.judge-steven-t-onei...
Cogglns, who is now also a Judge for the Montgomery County Maglsterial Dlstrict ln Pennsylvanla, was an assistant
dlstrlct atorney worklng under Bruce L. CastorJr., the former district attorney who notorlously decllned to press
charges agalnst Cosby In 2005.
TreDdlng Arlicles
e MORE SCOOPS FROM RADAR ONTINE
Click to vlew the story in a new tab
Why is this lmportant? Prosecutors wantJudge o'Neill to exclude castor as a wltness rrJ;;oJ;ln. jurv*hy n"
".o
decllned to prosecute the astor in 2005, clting a lack of "reliable and admlsslble" evidence.
Dlsfrict Attorney, Kevln R, Steele, argued In recent court papers that the opinlon of Castor is not relevant and should
not be presented to ajury by the defense team,
"There is slmply no legltlmate, relevant Purpose to presentlng evldence of Castor's publicly-stated reasons for
decllning prosecutlon, which centered on hls alleged opinions about the admlsslbillty and credibllity of the evldence,
His opinions on those subJects are not remotely relevant " Steele wrote In couft papers.
"Such evldence and argument can only be used to confuse the lssues and mlslead the Jury as the defense attempted
to do at the flrst trial," Steele added.
PIJOTOS: 'Cosby'Actress Secretly Told Cops About Unwanted Sexual Contact'With Bill Read The Shocking Police
-
Report
Staggeringly, the man who must make the declslon on whether to keep Castort opinion out of the trlal isjudge
' O'Neill.
Judge O'Neill could be forced to rnake that call as early as tomorrow (Thursday) when the flnal round of pretrlal
hearlngs before juryselectlon begins on Aprll 2,
But Cosbyk defense team, headed by hlgh-profile lawyer Thomas Mesereau, who won an acquittal for Michael
Jackson during his 2005 chlld-molestation trial, are almost certain to ask Judge O'Nelll to recuse himself permanently
from the trial, a request thatwould also requlre a newJudge to make a decision on the admlsslblllty of Bruce Castor,
sources told Radar.
2 of9 612712018,12:55 PM
Bill Cosby Judge Steven T, O'Neill l(ept Relationship Secret, Used As G... https://radaronline.oom/exclusives/2018/03/bill-cosby-judge-steven-t-onei...
lll!rlv!\llesrleLltlllu!llrJrulLJ!lvJvtfqltrrvlrJrLrrrrr9rltutvgqtulavutlrgt p9o!r!u.esllt!rlyru!rtJuvSsv,ysrtt
and Castor over who would become Montgomery County Dlstrlct Attorney in ,|999.
It was a fight Castor ultlmately won - but not before bltterness was sewn.
PHOTOS: 'We Want To Seek.lustice!' Philly DA Vows To Reveal Truth,About Cosby Sex Assault
Sources on the ground In Montgomery County told Radar that Castor deliberatety sat Coggins dlrectly in front of
O'Neill at the podiurn, where she wore a "Castor for DA bunon,
At the event, both Castor and O'Neil were scheduled to give three'to-five minute talks to their fellow county GOp
members to Introduce themselves and explaln why they were running,
Wlth Cogglns front-and-center, O'Nelll was "absolutely terrible that night," said a source who was there. "Nervous,
sweating, stammering no focus.Just really bad."
According to Radar's well-placed sources, Blll Donnelly, who was O'Nelll's campalgn manager during the run, later
called the then GOP party chalr, Frank Bartlg to ask hlm who had put Cogglns ln front of O'Nelll to throw him off the
game at the debate.
€astor later Inslsted to Bartle he hadn't and, in fact, Cogglns'arrlval at candidate nlght was how he first learned of
-
O'Nelll and Cogglns' relatlonshlp,
But the damage to O'Neill was done. He lost the election shortly thereafter.
Castor and Coggins did not respond to a request for commentwhen contacted by Radar.
PHOTOS:Latest st'atement Gloria Allred Deposed Bill Cosby For Seven Hours In Playboy Mansion Sexual Assault Case,
Reveals Plans To Release Transcriptl
'Judge O'Nelll has a motlve to get back at Castor for his humiliatlon," a source who knows Castor told Radar,
In another blzarre twlst ln the protracted Cosby case, lt was Judge O'Neill who tossed Cosby's clalm that the flrst trial
should never have proceeded ln the first place, based on Castor! non-prosecution agreement wlth the comedlanb
lararyer more than a decade ago,
On the stand, Castor defended hls declslon not to bring charges, citing among other thlng vlctim Andrea Constand's
year-long delay In gglng to pollce, her continued contact wlth Cosby, and suggestions that she and her mother mlght
have trled to e)dort the cornlc.
O'Neill did not elaborate on how he came to the ruling, but he appeared to doubt Castort credlbllity regarding the
exlstence of the oral agreement from 2005,
'Thereb no other witness to the promise," he said at the time, 'The rabblt is In the hat and you want me at this point
to assume, 'Hey, the promise was made, Judge, accept that."'
However,Judge O'Nelll failed to dlsclose hls earlier run-in with Castor to the defense team - or put it on the record
when decldlng Castor3 credlblllty.
PHOTOS: Bill Cosby Sexual Assault Case: Smiling Wife Camille Arrives For Deposition
Some legal experts told Radaronllne,com rhatJudge o'Nelll should have dlsquallfled hlmself in the first trial and
3 of 9 612112018,12:55 PM
Bill Cosby Judge Steven T. O'Neill l(ept Relationship Secret Used As G... https://radaronline.com./exclusives/2018/03/bill-cosby-judge-steven-t-onei...
nll lgul ! vtrrurqrJ st l uutr6qLsq urJlrurL, I rvr vr r., ur rJ uur rrtrur vr tt arLr LJL| pu! qt U lJg(lt tlrqt Lvt trlr!! vt trtrLr Lr!,
renowned New York Clty lawyer, Peter Gleason, told Radar,
Whafs more, Gleason added that O'NelllS failure to disclosg'lives Cosby's defense team tie opportunlty to use this
to Cosby's advantage and enables them to say, 'how can he get a fair u'ial if all this inside baseball is golng on?'
'At a minlmum, he should have revealed it. To err on the slde of caution he should have recused hlmself,"
-
The bombshell Radar revelation ts eerily slmllar to that ofJudge Lance lto In the 1995 oJ. Simpson murder trlal, who
failed to dlsclose hls wifg Margaret York had been detectlve Mark Fuhrman's superior offlcer in the past,
Fuhrman had been called to testifl by the prosecution regarding his discovery of evldence ln the case.
Sources connected to Castor have told Radar he would verifl7 the grudge lf questioned in the trial about lt.
A spokesman for Cosby, Andrew Wyatt, told Radar: "lfs very Interestlng lfs my first time hearing about it,"
-
Additlonal reporting by MlkeJaccarinoJen Heger & Doug Montero
-
We pay forJuicy infol Do you have a story for Radaronline.com? Email us at tips@radaronline,com, or calt us
at 800-34&9598 any tlme, day or nlght.
Inside Shameless Bill Cosby's Reality TV Cash Grab
AROUND THE WEB
Bill cosby Steven T O'l'lelll
COMMENTS
4 of 9 612112018,12:55 PM
Josnpru P. Gnnnw, Jn Attorneyfor Defendant
Atty L D. No. 32604
I38 Vlest Gay Street
West Chester, PA 19380
Telephone: (610) 692-0500
COMMONW EAITH OF PENNSYLVANIA IN THE MONTGOMERY COUNTY
COURT OF COMMON PLEAS

vs.
CRIMINAI, DIWSION
WILLIAM H. COSBY, JR. No. CP-46-CR-00039 32-2076
CENTIFICATE OF SERWCE
This is to certi-fii that in this case, a true and correct copy of the within
document has been served upon the following persons, by the following means
and on the date stated:
Name: Means of Service: Date of Service:
Kevin R. Steele, Esquire

/{,*- o7t*vt?=T
--EirstClass mail &
u/,,,/at y
District Atforney's Office Electronic seEi
PO Box 311
Norristown, PA 19404-0311
Resp ectfully submitted,

of
law ffices
fosnpu P. GREEN, JR,

a profess ional corpor ation
.i r /Z,r{
Dated: '/ t ts /
EXHIBIT 7
IN THE COURT OF COMMON PLEAS OF MONTGOMERY COUNTY, PENNSYLVANIA
CRIMINAL DIVISION
COMMONWEALTH OF PENNSYLVANIA No. 3932-16

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WILLIAM H. COSBY, JR. \-o
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MpMORANDUM OPINION AND ORDER SUR RECUSAI{

-D i;:''
l\) :
o'NEILL, J. September $r 2Ofg

On September 11, 2018, the Defendant filed a "Motion for Disclosure, Recusal
and for Reconsideration of Recusal ("Motion") and supporting Memorandum of Law.
The Commonwealth fiied a "Response to the Motion for Disclosure, Recusal, and For
Reconsideration of Recusal," ("Response"), on September 13, 2018.
In his Motion, the Defendant asks the Court to: 1) make a disclosure related to a
witness; 2) vacate the February 4,2OL6 Order denying his Petition for a Writ of Habeas
Corpus,r and recuse itself from further proceedings; and 3) reconsider the denial of his
prior recusal motion. 2
"A motion for disqualification is directed to and decided by the jurist whose
impartiality is questioned." Lg_qg3re of Womglr Vptefs of Penns)rlvania_v.
Commonwealth, I79 A.3d 1080 (Pa. 2018) (citing Commonwealth v. 'fravaglia,661
A2.d 352,37O (Pa. 1995)).
1 On January 1I,2OL6, the Defendant filed a "Petition for a Writ of Habeas Corpus
and Motion to Disqualify the Montgomery County District Attorney's Office,"
("Petition") and supporting Memorandum of Law, seeking, inter alia, to have the
charges dismissed on the basis of a non-prosecution agreement. A hearing on this
issue was held on February 2 and 3, 201.6,
z "Defendant's Motion for Recusal of The Honorable Steven T. O'Neill and Request for
Reassignment" was filed on March 21,2018 and denied March 29,2OI8.

It is well settled that,
[t]here is a presumption t]rat judges of this Commonwealth are

honorable, fair and competent, and, when confronted with a recusal
demand, are able to determine whether they can rule in an impartial
manner, free of personal bias or interest in the outcome. If the .iudge
determines he or she can be impartial, the judge must then decide
whether his or her continued involvement in the case creates an
appearance of improprietv and/or would tend to undermine public
confidence in the judiciary. This is a personal and unreviewable decision
that only the .jurist can make. A iudge's decision to deny a recusal
motion will not be disturbed absent an abuse of discretion.
Loma$ v..KfgStq, 130 A.3d LO7,I22 (Pa. Super. 2015), affd. 170 A.3d 380 (Pa.
2OI7l (citations and internal quotations omitted).
Furthermore, courts have consistently held that, "[i]n this Commonwealth, a
party must seek recusal of a jurist at the earliest possible moment, f.e., when the party
knows of the facts that form the basis for a motion to recuse. If the party fails to
present a motion to recuse at that time, then the part5r's recusal issue is time-barred
oNotably,
and waived.'Lonaq V.. KqeViXz,ITA A.3d 380, 390 (Pa.2OI7l. [the
Pennsylvania Supreme Court] has held that, in addition to actual knowledge of the
facts underlying the application, facts that'should have been known'are to be
consideredindeterminingtimeliness.,'@,l79A.3dat1087
(citation omitted). Courts conduct a waiver analysis because,
lllitigants cannot be permitted to hedge against the possibility of losing a

case on the merits bv delaying the production of arguable grounds for
disqualification, or, worse, by digging up such grounds only after
learning of an adverse order. To hold otherwise would encourage iudge-
shopping, would undermine the interests in the finality of iudicial
decisions, and would countenance extensive and unnecessary
expenditures of iudicial resources, which are avoidable by mere timely
advancement of the challenge. The courts of this Commonwealth cannot
and do not approve of such gamesmanship.
2
Id. at 1086; Reilly by Reilly v. Southeastern Pennsylvania Transp. Authoriw, 489 A.2d
I29I, 1300 (Pa. 1985) (citation omitted) (stating, "[o]nce the trial is completed with the
entry of a verdict, a part5r is deemed to have waived his right to have a judge
disqualified, and if he has waived that issue, he cannot be heard to complain following
an unfavorable result"). Where a recusal motion is based upon purportedly after-
discovered evidence, the Pennsylvania Supreme Court has held that, "'as in other
cases involving after discovered evidence, there must be a showing that... the evidence
could not have been brought to the attention of the ... court in the exercise of due
diligence.'' Leazue o_f Woulgn Vot$rp, I79 A.sd at 1087 (quoting lqilh, 489 A.2d at
1301). Defendant's post-verdict,3 presentence Motion is both time-barred and

meritless.
First, the Motion is untimely and, thus, waived. This case commenced with the
filing of a Criminal Complaint on December 30, 2015. Numerous pretrial hearings
were held, beginning with the first hearings on February 2 and 3,2016. The
Defendant was represented by a total of 7 attorneys at various times, through the
commencement of jury selection on May 22,2017. The first trial ended in a mistriai
on June 77,2OI7. Thereafter, Defendant repiaced his entire Defense team with 8 new
lawyers who represented Defendant at various times through commencement of the
s The Rules of Criminal Procedure provide for an oral Motion for Extraordinary Relief
prior to sentencing seeking an arrest of judgment, judgment of acquittal, or a new
trial. Pa. R. Crim. P. 704 (B). The Motion does not comport with that rule and is,
therefore, procedurally improper as well. Appellate courts have repeatediy stated "this
Rule was not intended to provide a substitute vehicle for convicted defendant to raise
matters which could otherwise be raised via post sentence motions." C__gJnmonwealth v.
Howe, 842 A.2d 436, 441, (Pa. Super. 2OO4) (citations omitted). The Defendant seeks
to revisit a pretrial ruling, under the guise of a motion to recuse; he may challenge
that ruling via the appropriate post-sentence procedures.
second trial, and vigorously pursued many additional pre-trial motions on Defendant's
behalf. As noted above, the Defendant filed a recusal motion on March 21,2OI8,
which was denied following a hearing on March29,2018.
The second trial commenced with jury selection on April 2,2OI8. On April 26,
2OI8, the jury found the Defendant guilty of three counts of Aggravated Indecent
Assault (18 Pa. C.S.A. S 3125). By Order of May 15, 2018, this Court set sentencing
for September 24 and 25, 2018. Defendant's current counsel entered his appearance
on June L4,2OLg and did not file the within Motion until September 1,1., 2OL8.
The sum and substance of the Motion is based on a March 28, 2018, unsourced
tabloid article posted by "Radar Online," a website described by the Defendant as an
"internet gossip site." (Motion t[ 7). The article was posted the day before this Court
held a hearing on the Defendant's prior recusal motion, and four days before the start
of his second trial. The Defendant's spokesperson is quoted in the article. (Motion,
Exhibit "A" at 4). As noted in the Commonwealth's Response, the Defendant's
spokesperson accompanied the Defendant to every court appearance, observed the
proceedings, and frequently spoke on the Defendant's behalf to the media. (Response
at 5). Clearly, the Defendant was aware, or should have been aware, of the basis for
the instant motion in March of 2018 at the latest, prior ta the commencement of his
retrial. Furthermore, the fact that this Court sought a party nomination for the Office
of District Attorney nearly twent5r years ago is a fact of public record that could easily
be uncovered in the exercise of due diligence by no less than 15 attorneys ( and their
private investigators) acting in the capacity of Defendant's legal counsel. Therefore,
the Motion is untimely as a matter of Pennsylvania law.

Even assuming, arguendo, the Court had a duty to disclose that a witness was a
political opponent nearly twenty years ago, basing the Motion on the Court's duty to
disclose does not overcome the failure to file the Motion at the earliest possible date.
See l$Agl-re ol*lVolnen Voters, I79 A.3d at 1088 (quoting Reilly, 489 A.2d at 1301)
('[S]imply because a judge does not raise sua sponte the issue of his impartiality,
however, does not entitle a party to question a judge's partiality after the case has
ended without substantiation in the record that the complaining party did not receive
a full, fair, and impartial trial").
Even if this unsubstantiated claim, raised on the eve of sentencing, is not
waived, it is facially meritless. Accordingly, a hearing is neither required nor

necessary. (See Pa. R. Crim. P. 577 and 704). "The party who asserts that a trial judge
must be disqualified must produce evidence establishing bias, prejudice, or unfairness
which raises a substantial doubt as to the jurist's ability to preside impartially."
Lo:nas v. K{avitq, 130 A.3d IO7,l22 (Pa. Super.2O15), affd. 170 A.3d 380 (Pa. 2OI7l
(citations and internal quotations omitted). The Motion and supporting memorandum
of law do nothing more than assert that this Court should have a bias, based on the
campaign tactics of a witness twenty years ago, that somehow precluded the Court
from making credibility determinations at a hearing in this case 31 months ago. This
claim is wholly without merit.
The undersigned has served on the Montgomery County Court of Common Pleas
since July, 2OO2. For the first six years of this Court's tenure, 2OO2-2OO8, Mr. Castor
served as the District Attorney of Montgomery County. Not once during his tenure as
District Attorney was Mr. Castor, or anyone else, heard to ascribe some sort of
"grudge" or prejudice against Mr. Castor in any criminal matter that came before this
Court. Likewise, since 2OQ9, Mr. Castor has, on occasion, appeared before this Court
as a criminal defense attorney and has never sought disclosure or disqualification of
the Court because of some perceived bias or "grudge' against him. No ogrudge,"
animus, bias or prejudice can be claimed because it simply does not exist.
Defense counsel's conclusory statement that any credibility determinations
made by the Court as to [a11] witnesses who testified "was an express finding that the
testimony of the former District Attorney, Mr. Castor, was not credible" is simply false,
with no basis in fact. (Motion tf 5). The Court carefully weighed the testimony of each
of the witnessesa at the February 2 and 3,2016 hearing on the Petition for a Writ of
Habeas Corpus, and applied the applicable law, in denying the portion of the Petition
seeking dismissal of the charges. This Court's ruling on the Petition, as stated on the
record and memorialized in the order of February 4,2O16, and its subsequent
"Findings of Fact, Conclusions of Law and Order Sur: Defendant's Motion to Suppresss
Evidence Pursuant to Pa. R. Crim. P. 581 (I)," docketed December 5, 2016, were not
based solely on the Court's credibility assessment of any individual witness, but rather
+ In addition to Mr. Castor, John P. Schmitt, Esq, testified on behalf of the Defendant.
Dolores Troiani, Esq., and Bebe Kivitz, Esq., were called by the Commonwealth.
s Defendant's "Motion to Suppress The Contents Of His Deposition Testimony and Any
Evidence Derived Therefrom on the Basis that the District Attorney's Promise Not to
Prosecute Him Induced Him to Waive His Fifth Amendment Right Against Self-
Incrimination" was filed on August L2,2016. A hearing was held on November 1,
2016. No new evidence was presented at the hearing. Rather, the Notes of Testimony
from the February 2 and 3,2016 hearing on the Defendant's "Petition for Writ of
Habeas Corpus and Motion to Disqualify the Montgomery County District Attorney's
Oflice," and a series of stipulations were admitted as evidence sufficient to dispose of
the Motion to Suppress.
on the testimony of all witnesses and ultimately rested on the legal insufficiency of the
evidence presented by the defendant in support of his motions.

In regards to Section III of the Motion, seeking a reconsideration of this Court's
ruling on the Defendant's prior Motion to Recuse filed March 2L, 2018, and denied
March 29, 2OI8, the Court's findings, statements and reasons for said denial which
were placed on the record on March 29, 2OI8 are incorporated herein by reference,
Nothing raised by the Defendant warrants reconsideration of the Court's previous
denial.
Finally, even though this Court believes the claim to be waived, the Court
nevertheless undertook conscientious reflection on claims raised in the Motion.
Throughout the pendency of this matter, and in every matter over which this Court
presides, this Court is sensitive to its obligations under the Code of Judicial Conduct
and takes these obligations very seriously. This Court is confident that it has and can
continue to assess this case in an impartial manner, free of personal bias or interest in
the outcome, This Court simply has no bias against any witness called by the defense
or the Defendant himself. This Court finds no merit in any of the bases alleged by the
Defendant and the Court will not recuse itself. Based on the foregoing, the Court
issues the following:
7
ORDER
And now this 19u" day of September,2OIS, upon consideration of the Defendant's
Motion for Disclosure, Recusal and For Reconsideration of Recusal, and supporting
Memorandum of Law, filed September 11, 2018, and the Commonwealth's Response
thereto, filed September L3,2018, it is hereby ORDERED and DECREED that the
Motion is DENIED in its entirety.
BY THE COURT:
STEVEN T. O',NpILL, J.
^l t
Copies of this order mailed on g/lg //fto the following:
Joseph P. Green, Esq.
8
EXHIBIT 8
IN THE COURT OF COMMON PLEAS Or. MONTGOMERY COUNTY.
PENNSYLVANIA g -t!
CRIMINAL DIVISION g
rrl
zp'
:: FN
-t Yl e)
-rJHAfK
COMMONWEALTH OF PENNSYLVANIA : No. 3932-16 ..L
.?
E*tq
I':i'ig
V.:-
of Y.n
WILLIAM H. COSBY, JR. : $l
G' =d
FINDINGS OF FACT. CONCLUSIONS OF LAW ANp ORDER SUR DEFENpANTS'
MOTION TO SUPPRESS DVIDENCE PURSUANT TO pA. R. CRrM. p,_5_8_1 (Il
I. Findings of F'act
1. The Defendant seeks to suppress the contents of his civil deposition testimony,
and any evidence derived therefrom, on the basis that he expressly relied upon
former District Attorney Bruce L, Castor, Jr.'s alleged promise not to prosecute
him as the basis for not invoking his Fifth Amendment right against self-
incrimination at his civil depositions in 2005 and 2006. (Defendant's Motion to
S-]lppq-ess the Contents of His Peposition Testimony and Aqy Evidq.frce D_grived
Therefrom On the Ba.[iF that the Dist{ict Attornev's P{omise Not to Prosecute
Him lldu.ced Him to Waive his Fifth A4nendment Rieht Against Self-
Incrirninatiorl at 1.)
2. A hearing was held before the undersigned on November L, 2016. No new
evidence was presented at the hearing. Rather, the Notes of Testimony from
the February 2 and 3, 2076 hearing on the Defendant's "Petition for Writ of
Habeas Corpus and Motion to Disqualify the Montgomery County District
Attorney's Office," (Commonwealth's Suppression Exhibit 1 (CS-1)) t and a
series of stipulations (CS-2) were admitted as evidence sufficient to dispose of
the instant Motion to Suppress which was filed August 12, 2016. (N.T.
11lI I 16 at 7-81. This Court considered no other evidence in making its
findings and conclusions.
3. On January 24, 2OO5, then Montgomery County District Attorney Bruce L.
Castor, Jr., Esq. issued a signed press release indicating that an investigation
had commenced following the victim's January 13, 2005, report to authorities
in Canada that she was allegedly sexually assaulted by the Defendant at his
home in Pennsylvania. Ultimately, the case was referred to Cheltenham
Township Police Department. (N.T. 213116 at 65; C-17).
4. On January 26, 2005, the Defendant gave a written, question and answer
staternent to law enforcement. The Defendant was accompanied by counsel,
both his criminal defense attorney Walter M. Phillips2, Esq,, and his longtirne
t A1l other exhibits referenced herein are cited by the exhibit number assigned at the
Februar5r 2 and 3,20L6 hearing.
z Mr, Phillips passed away in early 2015.
general counsel John P. Schmitt, Esq., when he provided his statement to
police. (N.r.213116 at 19, S2-5S).
5, At no time during the statement to police did the Defendant invoke his Fifth
Amendment privilege. (ld, at 18).
6. Mr. Schmitt testified that he interviewed the Defendant prior to both his
statement to police and to his civil depositions and did not believe that he was
going to incriminate himself. (N.T. 2/3/ l6 at 22-24ll.
7. An February 17,2OO5, then District Attorney, Bruce L. Castor, Jr., issued a
signed press released stating that he had decided not to prosecute William H.
Cosby, Jr. (N.T.2l2l16 atTL-72, 89); Defendant's Exhibit 4 (D-4)).
B. Mr. Castor testified that it was his intention to strip the Defendant of his Fifth
Amendment right to force him to sit for a deposition in an unfiled civil case and
that Mr. Phillips, the Defendant's criminal attorney, agreed with his legal
assessment. N.f . 212116 at 63-68). He also testified that he relayed this
intention to then First Assistant District Attorney Risa V, Ferman, [d. at 67).
9. The press release cautions that the decision could be reconsidered. (N.T.
212/16 at 215; D-a).
10. There was no agreement not to prosecute and no "quid pro quo." (N.T,2/2116
at99,2271.
1 1. The decision not to prosecute was not the result of any agreement with, or
request from, the victim's attorneys, Dolores Troiani, Esq. and Bebe Kivitz, Esq.
(N.f . 2/3/16 at 175, 238, 2+7-2481,
L2,In fact, Ms. Troiani had no contact with the District Attorney's Office during the
investigation. (N,T. 2/3116 at 139-140). Ms. Kivitz had limited contact with
then-First Assistant Risa V. Ferman. (ld. at 236,247l'.
13. Further, Ms, Troiani had no discussions with anyone involved in the
investigation regarding a possible civil case against the Defendant. (Id. at 140).
14. Additionally, Ms. Troiani testified that if the Defendant had invoked the Fifth
Amendment at his depositions, it would have benefitted their civil case in the
event of a jury trial, because she would have requested an adverse inference
jury instruction. N.f . 2/3/16 at 1761,
15. At no time was the purported prornise not to prosecute reduced to writing.
(N,T.2l3l16 at 26, 47]r. Likewise, there was no Court approval of any promise
or agreement not to prosecute.
16. Neither of the victim's attorneys was aware of the purported promise until
2015. (Id. at 184,237-238).
L7.In fact, Ms. Troiani only learned of Mr. Castor's decision not to prosecute when
a reporter came to her office to obtain acomment on the decision. (Id. at 141-
1421.
18. During the 2005 criminal investigation, the Defendant's attorneys were
negotiating, in writing, with the National Enquirer for the defendant to give an
interview regarding the instant allegations, which he gave following the
conclusion of the criminal investigation. (N,T. 213116 at 33-34).
19. On March 8, 2005, the victim filed a civil lawsuit against the Defendant in the
Eastern District of Pennsylvania.
20. On four dates, September 28-29,2005 and March 28-29, 2006, the Defendant
sat for depositions in the civil matter. (N.T. 2/3/ 16 at 36).
2r. He was accompanied by counsel, including Mr. schmitt. (N.T. 2/3/16 at 13,
36). Mr. Schmitt testified that Mr. Phillips had informed him of Mr. Castor's
promise not to prosecute. (ld. at 1l).
22. The Defendant did not invoke the Fifth Amendment during the depositions,
however, counsel did advise him not to answer questions pertaining to the
victim in the instant case and her attorneys had to file motions to compel his
testimony. (N,T. 2/3/16 at 4L-42, 181-184, 248-2491.
23. The Defendant did not invoke the Fifth Amendment when asked about other
alleged victims. (1g!. at 5S-59).
24, At no time during the civil litigation did any of the attorneys for the Defendant
indicate on the record that the Defendant could not be prosecuted. (N.T.
2 / 3 / 16 at 177, 184, 247 -248).
25. There was no attempt to confirrn the purported promise before the depositions,
even though Mr, Castor was still the District Attorney; it was never referenced
in the stipulations at the outset of the civil depositions. (N.T. 2/3 l16 at7l,
178-r79, 247-2481.
26. In the late summer of 20O6, the victim and the Defendant settled the civil case.
As part of the settiement agreement defendant's attorneys initially attempted to
negotiate a provision whereby the victim would absolve the Defendant of
criminal responsibility and not cooperate with law enforcement. Additionally,
the defendant's attorney requested that Ms. Troiani agree to destroy her file.
N.r,213116 at 47-48, 19O-193).
27. Th'e settlement agreement contains a provision that Ms. Constand would not
initiate a criminal complaint against the Defendant based on the instant
allegations. (N.T.213116 at a8; C-221,
28. On July 6, 2015, in response to a request by the Associated Press, a federal
judge unsealed previously sealed portions of the record in the civil case, which
included portions of the defendant's 2005 depositions. (Dqfendantls Motion tq
Fuppress The Contents Of His Deposition Testirqonlr an4_Any Evidence Derived
Therefrom on the Basis that the District Altornelr'S Promise Not to Prosecute
Him Induced Him to Waive His F.'ifth Ar4gndment Right Against__Selt-
Incrimination at 41.
29. Around this time, the District Attorney's Office reopened the investigation. (C-
19, C-20).
30. On September 22, 2OI5, at 10:30 am, Brian McMonagle, Esq. and Patrick
O'Connor, Esq., met with then District Attorney Risa Vetri Ferman and then
First Assistant District Attorney Kevin Steele at the Montgomery County
District Attorney's Office for a discussion regarding William H. Cosby, Jr., who
Mr, McMonagle and Mr. O'Connor represented. (Defendant's . Motio4 to
Suppress the Conte+ts of His Deposition: Stipulations #1).
31. On September 23,2015, at 1:30 pm, Bruce L, Castor, Jr., Esq. sent an email to
then District Attorney Ferman. This email was marked and admitted as
Defendant's Exhibit 5 at the February 2016 Habeas Corpus hearing held in this
matter. (Defendant's Motion to Suppress thg Con_tsnts of His Deposilion:
Stipulations #2).
32. On September 23,2015, at 1:47 pm, Mr. Castor forwarded the email identified
above as Defendant's Exhibit 5 to Mr. McMonagle. (Oetenaant's tvtotion rc
Sgppress the Contents of His Dgposi.tion: Stipulations #S).
33. On September 25, 2015, then District Attorney Ferman sent a letter to Mr.
Castor by way of hand delivery. This letter was marked and admitted as the
Defendant's Exhibit 6 at the February 2OL6 Habeas Corpus hearing held in
this matter. At. 3:02 pm that same day, Mr. Castor's secretary forwarded a
scanned copy of the letter to him by way of email. (Defe.ndant's Motion.to
Supp.rqsq.the. 9onte{rts o{ His Depositigfr: Stipulatio+s #4).
34. In her letter Ms. Ferman stated, "[t]he first I heard. of such a binding agreement
was your email sent this past Wednesday." (D-6)
35. On September 25, 2075, at 3:59 pffi, Mr. Castor forwarded the letter
identified above as Defendant's Exhibit 6 to Mr. McMonagle. (Dqfendan_tlg
Motion to Suppress the Contents of His Dqposition: Stipulatiqns #5).
36. On September25,2015, at3:41 pm, Mr. Castor sent an email to then District
Attorney Ferman. This email was marked and admitted as Defendant's Exhibit
7 at the February 201"6 Habeas Corpus hearing in this matter. (Defendaqt's
Motion.to Supp{qss the Co0!9qts of His Deposition: $tipulations #.6),
37. On September 25,2015, at4:I9 pm, Mr. Castor forwarded the email identified
above as Defendant's Exhibit 7 to Mr. McMonagle along with the message
olatest," (Defendant's Moljon to Supp{e.ss the Contents of
-His Deposition:
Stiputeliops #7).
38. On December 31,2O15, the instant charges were filed.
39. The Defendant principally relies on the testimony and writings of Mr. Castor to
support his motion.
40. In that regard, the Court finds that there were numerous inconsistencies in the
testimony and writings of Mr. Castor and has previously ruled that credibility
determinations were an inherent part of this Court's denial of the Defendant's
initial "Petition for Writ of Habeas Corpus." (Court Order 2l 4 I L6l.
41. There were multiple inconsistencies between Mr. Castor's communications with
the District Attorney's Office in September of 2015 and with his testimony on
February 2,2016,
42. For example, in his Septembe r 23,2015 email, he indicated that the decision
not to prosecute was an attempt to force the Defendant to sit for depositions in
an unfiled civil case and that the decision was made with the "agreement" of
defense counsel and plaintilfs counsel. (D-5). However, in his testimony, he
indicated that there was no agreement and no quid pro quo.
43. The correspondence further states, "I signed the press release for precisely this
reason, at the request of the Plaintiffs counsel, and with the acquiescence of
Cosby's counsel, with full and complete intent to bind the Commonwealth that
anything Cosby said in the civil case would not be used against him, thereby
forcing him to be deposed and perhaps testify in a civil trial without him having
the ability to 'take the Sth'"' (D-5). "[B]ut one thing is fact: the Commonwealth,
defense and civil plaintiff's lawyers were all in agreement that the attached
decision [February 17, 2OOS press release] from me stripped Cosby of his Fifth
Amendment privilege, forcing him to be deposed." (N.T. 2/3/ 76 at 195; D-5).
44, This Court credits the testimony of Ms. Kivitz and Ms. Troiani, whose relevant
testimony regarding such agreement is outlined in paragraphs 11-17 above.
45. Mr, Castor's testimony about who was in agreement with his decision, as well
as what he purportedly promised, was equivocal. (N.T. 212116 at 185-195).
46.1n his final email to Ms. Ferman on the subject Mr. Castor states, "I never said
we would not prosecute Cosby." (D-B)
47. Additionally, there were multiple inconsistencies between Mr. Castor's
accounts to the press and his testimony on Februar! 2, 2016. (E.g., N.T.
212/16 at 2IB-22O, C-121.
48. There is no basis in the record to support the contention that there was ever arr
agreement or a promise not to prosecute the Defendant.
49. There is no basis in the record to support justifiable reliance on the part of the
Defendant,'
II. Conclusions of law
l.lnstantly, this Court concludes that there was neither an agreement nor a
promise not to prosecute, only an exercise of prosecutorial discretion,
memorialized by the February 17 ,2005 press release.
2.In til'e absence of an enforceable agreement, the Defendant relies on a theory of
promissory estoppel and the principles of due process and fundamental fairness
to support his motion to suppress.
3.Where there is no enforceable agreement between parties because the agreement
lacked consideration, the agreement may still be enforceable on a theory of
promissory estoppel to avoid injustice, C{ouse v. Clrclops Indus., 745 A.2d 606
(Pa. 2000).
4.The party who asserts promissory estoppel must show (1) the promisor made a
promise that he should have reasonably expected would induce action or
forbearance on the part of the promisee; (2) the promisee actually took action or
refrained from taking action in reliance on the promise; and (3) injustice can be
avoided only by enforcing the promise. Id. (citing Restatement (Second) of
Contracts S 90). Satisfaction of the third requirement may depend, inter alia, on
the reasonableness of the promisee's reliance and the formality with which the
promise was made, Thatq.hgr's Drug Stofe of__W. Goshen. Inc.. v. Consol,
Supermarkets, Inc. , 636 A.2d 156, 160 (Pa, I99$ (citing Restatement (Second) of
Contracts S 90, comment b).
5. Because there was no promise, there can be no reliance on the part of .the
Defendant and principles of fundamental fairness and due process have not been
violated.
6.This Court finds that there is no Constitutional barrier to the use of the
Defendant's civil deposition testimony.
Based on the foregoing, the Court issues the following:

ORDER
-- +\
And now, this o day of December, 2016, upon consideration of the
"Defendant's Motion to Suppress The Contents Of His Deposition Testimony and Any
Evidence Derived Therefrom on the Basis that the District Attorney's Promise Not to
Prosecute Him Induced Him to Waive His Fifth Amendment Right Against Self-
Incrimination," filed August 12, 2016, the Commonwealth's Response thereto, filed
September 2,2O16, and after hearing before the undersigned on November 1, 2016,
based upon the arguments of counsel and the evidence adduced, the Defendant's
Motion to Suppress is hereby DENIED in its entirety,
BY THE COURT:
)u;-r_"y*,t
T. O'NEILL,
STEVEN J.
Copv of the above Order
maiiea on S2JSlbto the following:
Kevin R. Steele, Esq. (District Attorney's Office)
I(risten Gibbons Feden, Esq.
Brian J. McMonagle, Esq.
Angela C. Agrusa, Esq.
Court Administration
AuaNr4 b'rntuArt-l
Secretary
EXHIBIT 9
IN AND FOR THE COUNTY .OF MONTGOMERY, PENNSYLVANIA
cRTMTNAL_olur s roN
vs. NO. 3932-16
PRETRIAL CONFERENCE/MOTION TO SUPPRESS TELEPHONE

RECORDING
Courtroom A
Tuesday, September 6, 20L6
Commencing at 1-:00 P.m.
Virginia M. Womelsdorf' RPR

Official Court RePorter
Montgomery CountY Courthouse
BEI'ORE : THE HONORABLE STEVEN T. O'NEILL ' JUDGE
KEVIN R. STEELE, ESOUIRE

District AttorneY
M. STEVIART RYAN, ESQUIRE
KRISTEN GIBBONS_FEDEN, ESQUIRE
Assistant District AttorneYs
for the Commonwealth
BRIAN J. MCMONAGLE, ESQUIRE
ANGELA AGRUSA, ESQUIRE
for the Defendant
l_ COMMONWEALTH vs. WILLIAM H. COSBY, JR . 2
'\2 (The following proceedings were

3 commenced with the Court, Mr. Steele, Mr. Ryan, Ms.
4 Gibbons-Feden, Mr. McMonagfe, Ms. Agrusa, and the
5 defendant being present: )
7 THE COURT: We had a brief

a pre-conference conference, but nothing was discussed
9 at this stage t.hat's not going to be discussed out
l_0 here. It I s qroing to be a litt]e unwieldy to try to
11 begin to bring this case within a trial track that we
t2 can begin to get resolution.

13 Now, we are here today, Counsel,
t4 as we've discussed, for a pretrj.al conference that was
15 scheduled by my order of June 14th. And my order of

16 June 1"4th setting the trial pretrial conference
1"7 under the Rul-es of Criminal Procedure for today
L8 envisioned that there would be another order regarding
L9 the filing of motions prior to the pretrial motion of
20 September 6th.
27 ft was envisi-oned that motions
22 would be f iled. An inter-l-ocutory appeal was taken
23 from my habeas corpus decision, and at, that stage f
24 did not send out the order. However, it was obvious
t2s to the Court that counsel heard me and began to file
1 COMMONWEALTH vs. WILLIAM H. COSBy, JR.
I motions and began to undertake discovery.
a I note that the District
4 Attorney in todayrs filing indicated t,hat it has
provided in what it believes j-n its opinion
6 provided both mandatory and discretionary
7 discovery, at least what it believes it has to.
I And, in fact, the defense has
9 f iled t,wo pretrial motions today. And just today the
10 District Attorney's Office filed a 404(b) motion which
L1 obviously is very large in scope and size.
t2 So counsel was at least
1.3 following the formal agreements that we had made at
74 the pretrial conference, the scheduling conference,
L5 back in June. And f appreciate counsel for doing
16 that, but really today would mark now beginning to
T7 formaJ-ize dates, the types of filings that we should
18 expect, deadlines for those, any further discovery,
t9 and really beginning to set hearing dates for the
2A various motions that are going to be filed.
2J- Now, f do know one thing, Mr.
22 McMonagle, in one of the it was actual-ly a letter
23 prior to this requesting whether the defendant wouJ-d
24 have to appear. And you did indicate at this stage in

ZJ an affirmative fashion that he was blind.
L COMMONWEALTH vs. WILLIAM H. COSBY, JR . 4
z Now, if that is the case, then

3 I -- you need to know, you know, dt l-east through your
4 client and his doctors, what ramifications that is for
5 being able to accommodate t.he defendant through our
6 court procedures.
7 We I ve endeavored through our
B decorum orders and we do the best we can, but anything
9 that is personal and private to your client in regards
1_0 to his medical condition you're going to need to let
L1 the Court and the decorum officer, our Court
I
L2 Administrator, Michael Kehs, know so that we can

13 provide all accommodations that are necessary.
15 THE COURT: Okay. So in the
16 future, please be able to do that. He would be
I7 required to be present at these hearings.
18 Now, I do note from the outset,
19 Counsel, that this case is now 252 days from the
20 filing of Criminal Complaint. And I do envj-sion that,
2t as you've indicated, that there will be a motion from
22 the defense regarding pre-arrest delay, and that could
23 be envisioned by at Ieast the t.wo hearings that we I ve
24 already had in this, the both of them with the Court

25 having made decisions.
1 COMMONWEALTH vs. WfLLIAM H. COSBY, ,JR. 5
2 But clearly it raised the issue

3 of incidences that occurred in 2A04, from the
4 disclosure of the Commonwealth, and 2005, and a
q Criminal Complaint being filed in 20L5. I could

6 envision that they will be there.
7 But, nonetheless, a Criminal
B Complaint was filed and, therefore, there is a right
9 to a speedy tria1. And I recognize with a trial and
t0 some of the pretrial motions that have been filed just
1L to date, this is a large scope. But, nonetheless,
L2 your client has speedy trial rights.
1_3 . Now, the only delay that has
I4 actually occurred in the case was when the Superior
15 Court did stay this matter, I believe just. from March
L6 l-st through April 25th. Now, that was an actual stay
I7 where this Court was divested of jurisdiction to do
18 anything.
3,9 Under Rule 600, each side could
20 make claims as to, well, the filing of a certain thing
2L or having a certain hearing delayed the actuaL trial.
22 And I fm not trying to, you knowr encourage anyone. I
23 just don't know. But rights are ri-ghts, and in this
24 Commonwealth you have a right to be tried within 365
25 days from the date that the Commonwealth filed a

1 COMMONWEALTH vS. 9OILLIAM H. COSBY, JR . 6
z Criminal Complaint. So a mechanical run dat,e r ds we
call it in this business, would be December 29Lh,

4 2016.
5 Now, I don't think anyone who is
6 associated with this case believes that this case wil-1
7 be tried before that date, but' so far the only actual
8 excludable t.ime is when the Superior Court divested
9 this Court.
10 Again, there have been two
l_1 appeals to the Super j-or Court, tl. f irst one
T2 interlocutory in which they granted a stay, and the
13 second one being the current interlocutory appeal
T4 which this Court denied permission for such an
L5 interlocutory appeal.
1.6 And there I s now an application
J.7 to the Superior Court to hear that appeal in regards
1B to this Court I s ruling in regards to hearsay being
19 util ized in the form of prima facie evidence at a
20 PreIi-minary Hearing.
2L So that is on appeal. To my
22 knowledger Do stay has been granted. I think all are

23 in agreement that the rules permit this Court to
24 proceed with all trial procedures, aIl trial matters,
25 and I intend to do so.
l_ COMMONIÎEALTH vs. WILLIAI\4 H. COSBY. JR.
2 So I just put that as a backdrop
? so that everybody is sensitive to it, that this Court
4 wiII endeavor with everything within its power to give
q this defendant his right to a speedy trial, no matter
6 how large the scope and no matter how much underlying
7 procedural matters have to be undertaken.
I So with that said, the Court
9 notes that there was procedural anomaly that, in fact,
10 your cJ-ient had waived arraignment via your entry of
1L appearance back on June 3rd and, in fact, had pled not
I2 guilty. That actually came prior to Bills of
r.3 f nf orrnation being f iled.
14 So just for clarity of the
I) record, Bills of Information were, in fact, filed on
16 July 13th of 20LG charging WiIliam Henry Cosby with

L7 three counts, these j-nvolving incidences alleged to
18 have occurred between January of 2004 and
t9 February 2004, CounL 1 being aggravated indecent
20 assault, a felony of the second degree.
2T And heari.ng again, trying to
22 extrapolate your entry of appearance of not guilty, I
23 will enter a plea of not guilty on that matter.
25 THE COURT: He's charged with
. WILLIAM H . ' .JR.
8
L COMMONWEALTH VS COSBY
2 Count 2, aggravated indecent assault, a felony of the

3 second degree, the alleged victirn being Andrea
4 Const.and f or al1 t,hree of these.
5 Again, I will enter a not guiltY
6 on that one; is that correct?
I THE COURT: And then, finallY,
9 count 3, aggravated indecent assault, a felony of the
10 second degree.
l_ 1_ I wiII also enter a Plea of not
T2 gui lty .
13 MR. McMONAGLE: Thank You' Your

L4 Honor.
15 THE COURT: AIl right. So Pleas
15 of not guilty have werve now kind of caught up the
L7 BilIs of Information and the waivers of arraignment.
t8 That then triggers certain rules of our
19 Pennsylvania RuIes of Criminal Procedure have certain
20 deadlines.
2L Now, most Courts are somewhat
22 loose. They want to make sure we guarantee the rights
ZJ to trial'of all parties in being able to have a trial
24 where all of the pretrial issues have been heard and
25 resolved.
1 COMMONWEALTH vs - WILLIAM H. COSBY, JR . 9
2 So although I am not a stickler

3 to the rules, werre going to have to be setting our
4 own rules, even though they may be outside of the
5 Rul-es of Criminal Procedure, but we will stitl
6 endeavor to trv to follow that.
7 With that saidr w€ are having,
B you knowr dD official preLrial conference under Rule
9 570, and there are a number of things that we should
10 at Least cover and make sure that we handl-e.
1l_ So far in this case the
I2 f ol-lowing mot j-ons have been f iled. They've been
13 calIed pretrial motions. That $ras of August 3rd of
14 2016 by the defense, and that was to suppress the
phone call that the Commonwealth claims it's going to
J-O intend to use in evidence.
L'l Now, we've talked about that. I
1B believe that that is one hearing that i-s basically a
r-9 great deaL of legal argument orr if not, it may be

20 incorporation of pr j-or testimony, I don't know, but I
2L don't think it would. be. And $re wilL hear that tod.ay.
22 Tbere's no reason we couldn't hear that argument-
23 There is a second motion t,hat
24 was filed again, the phone call- suppression, the
25 Commonwealth filed its answer on September 1st Eo
2 that. So in all respects, that's ready to go in that

3 there has been a motion and an answer.
4 The next being a Motion to
5 Suppress Deposition Testimony of the defendant given
6 at. a deposition following at least the I guess
7 sometirne in 2005, a deposition testimony. And the
I answer was filed by the Commonwealth in that on
9 September 2nd.
1_0 Now, that being the later in
11 time and al-so the later Commonwealth answer, I tm
L2 willing to, as much as it may require just lega1

13 argument, to do that. But I don't have to hear that
t9 one if the parties do not feel that they are ready to
15 proceed on that one. But the Court is prepared to
hear those.
L7 And those are the only two
1B motions that were outstanding up to about an hour ago
1_9 at which time the Commonwealth filed a rather weighty
20 motion under Pennsylvania Rule of Evidence 404 (b)
2t which there is an indication there that you intend to

22 present the testimony of 13 alleged prior incidences
23 that you believe will meet the requirements of
24 Pennsylvania Rule of Evidence 404 (b) .
25 Now, that's obviously weighty
1 COMMONWEALTH vs. WfLLIAM H. COSBY, JR. 11
2 because there's a lot of information contained in that

? mot.ion and a hearing thereon will take some tirne. So,
4 as we discussed in the conference in the robing room,
5 that wil] need to be set out for a date certain. And
6 obviously there I s cerLain investigation that you may
7 need to undertake.
B Now, the only thing I would
9 comment. on that, the Court has not read it except for
10 to skim it because it was just filed today, but it
l-L appears to have the accounts of there I s reference
T2 to originally 50 possible, but you have chosen L3 that
13 you wish to have this Court consider as to whether
L4 they woul-d be permitted to testify under what is known
15 as the common plan, scheme or design exception. And
16 therefore, it did not appear that any names were

I7 placed in there and they are not attached to it.
1B I donrt know how that I s qoinq to
l_9 be handled in terms of the Commonwealth and. th"
20 defense. f would note that up until this, all 2OO
2t some days that werve had so far, that counsel in this

22 case has conducted themselves with the highest
23 integrity and allegiance to their ethical obligations
24 and rules, but we're talking about individuals here.
z5 And I just don't know nobody's asked for anything
2 as far as disclosure of names of these individuals.

3 I rrn going to eave it to counsel
f
4 at this st,age. I would not I just don't

5 nobody's asked me to do anything in that regard. f
6 would just note that there are no names attached to
7 those 13 accounts that you intend to use. fs that
I correct ?
9 MR. STEELE: That I s correct,

L0 Your Honor.
1_1 THE COURT: Okay. So we're
1.2 going to deal with that at the end of today as to how
13 we're going to schedule that out.

14 One other motion that was filed
15 vras the Comrnonwealth I s Motion f or Pretrial Discoverv
t6 and Reciprocal Discovery that is commonly filed. It's
17 a prophyLactic rnotion filed by the Commonwealth to
LB ensure that if the defense has any kind of discovery,
79 that they are essentially asking for it.
20 However, f note, Mr. McMonagle,
21 in that motion t.hey make a claim that they, in their
22 own determination, have provided you with aIl of their
23 obligations under the discovery rules of our Rules of
24 Criminal Procedure.
2s That may or may not be the case
1- COMMON!{EALTH vs. WILLTAM H cosBY, JR. L3
2 because, again, good lawyers and good Iawyering i-s

3 exactly what I guess they I re claiming and what
4 everybody has dernonstrated so far; that you don't need
q
to involve the Court or you don't have to have filings
6 and everything else for everything, meaning they
7 recognize their obligations.
I So yourre going to have to
9 review. Obviously discovery is always going to be
10 ongoing in this courtroom. and I will be sensitive to

LL the needs of both parties, but I ask you to be
t2 expeditious so that $re do not have delays in this

13 trial because of discovery motions.
L4 I can look at where the case is
15 now by reviewJ-ng an Af f idavit of Probable Cause f rom
16 some of the testimony I've heard so far. With the
'1,7 404(b) motion asider there doesntt seem Iike there's
1B going to be a great deal of other discovery. There
).9 doesnrt appear to be a lot of scientific, a lot of DNA
20 or other kind of testimony, but f just don't know.

2L So you're going to have to let
22 me know where you think you are in regards to
23 discovery. So you haven't had a chance to look at
24 that one either?
25 MR. McMONAGLE: No, Judge. Both
vs. WILLIAM H. COSBY' JR . 1'4
1 COMMONWEALTH
2 those motions were filed as we walked in today.

3 THE COURT: Right. So I would
4 ask you if you believe because I wiII be a sLickler
5 on the discovery motions' meaninq to keep you tight on
6 that if there is something that you don't think you
I got. And when was this discovery provided? over time
B or was it one, two discs and that's it? Does anybody
9 know ?
10 MR. RYAN: Your Honor, there was

1_1 a large batch j-n the beginning. I know that vte handed
L2 over some related to the prior bad acts motion today'
13 but I would say it's occurred over time. And we have
L4 a standing, you know, date'with counsel. If he wants
15 to come look at our file, he can.
16 THE COURT: OkaY. So Ifm going
L7 to leave that to counsel at this stage -

1_8 Now, there are certain
r.9 requirements that I should be going over with you and
20 your client here, Mr. McMonagle- And the first
2T obviously is any terms, Procedures for pretrial
22 discovery and inspection. we covered that. unless
23 this court hears that there's any problems with it,
24 I'm going to assume that that is proceeding in
25 accordance with the ruIes.
2 Now, there's some general stuff

3 under the requirements of a pretrial conference- They
4 talk about the stipuLation of factual issues,
5 admissibility of evidence and the like.
6 f don't know whether we're there
7 at that stage because a lot, of it has been but I
8 always ask counsel to keep that in mind, that
9 everything werre doing is still ultimately in a
L0 direction of triaI.
11 So that if these stipuJ.ations do
L2 come along and admissibility of evidence, think in

13 terms of being able to keep a list of it so it's not
I4 something $te have to do at the end at the l-ast moment
L5 to try and work these out. I know that good counsel

r_6 generally fol-1ow those kinds of rules. And they talk
L7 about exhibits and evidence so as to avoid the
t_B unnecessary delay.
L9 Again, the number of witnesses
20 that are going to be of a cumulative nature, you're
2I not goi.ng to begin to know that until you know the
22 identities of their proposed 404 (b) and whether r
23 would even permit one or all to testify. So that,
24 obviously is going to be sensitive on further hearings
25 on that motion.
1 COMMONWEALTH vs. WILLIAM H cosBY, JR. L6
2 But there are certain things

3 that would fall into your obligations now, and that
4 would be the defenses of alibi and mental infirrnity or
5 anything in that regard. The rules are pretty cfear
6 on that, but that I s something we should get groing on
7 soon.
B So f can set down a date. If
9 yourre going to be exploring that, it's certainly
10 within 15 to 30 days if that is going to be an issue.
11. Make sure yourre capturing this. That's something
L2 that $re have in 15 f I 11 decide when f look at that .
L3 So I have not. seen any motion

T4 for BilI of Particulars. Now, that's something that
15 is in our discovery rules, in my opinion often
16 underutilized, but I I rn not inviting it if it doesn t t
I7 have to be there. But, it is in our rules and it is
r8 out there. And I certainly arn a f an of it because
r_9 sometimes it begins to limit j.ssues of what we I re
20 doing here at trial.

2t So, again, f donrt know whether
22 this is archaic, but they talk about establishing the
23 time and place of the offense charge and the corpus
24 delicti. I don't it has generally beenr you know,
-25 pled j-n this case that it's between January and
1 COMMON9IEALTH vs. WILLIAPI H. COSBY, JR . L1
2 February as to an exact date. Obviously, any charge

J to a jury does not, require an exact date of an
4 of fense .
5 You're proceeding with the

6 qualifying and labeling of any of the discovery and
7 the exh j-bits and that, and I 'rn sure you' Il all f ollow
I along with it.
9 Admissions of fact hte tal-ked
10 about.
11 I doubt there I s going to be any
L2 pleas to a various count in there.
13 There doesn't aPPear to be any
L4 nol pros.
15 But then we're starting to get
l_6 to regarding determination of the suppress and return
t7 of evidence. we will spend some time on scheduling
18 t.hat out. We will hear the f irst motion on that
1_9 today.
20 Any severance, it doesn't
2t apPear.
22 Again, the number of counsel
23 Now, today you have counsel that will be moving
24 towards a pro hac vice admissioni is that correct?
25 MR. McMONAGLE: That is correct,
1B
1 COMMONWEALTH vs. WILLIAM H. COSBY' JR.
2 Your Honor.
3 THE COURT: And that is name?
I MR. McMONAGLE: Judge, Angela

5 Agrusa.
6 THE COURT: And, aga.i-nr I
7 permitted yoUr clearly, to be able to sit at counsel

B table, but Pennsylvania is kind of a stickler on the
9 pro hac vice motj.ons. And all counsel that were
10 involved j-n previous hearings have now officially
11 withdrawn, sor as of everything thatts out there, you
T2 are the only counsel of record, Mr - McMonagle.
13 },1R. MCMONAGLE: YES, YOUT HONOT.
1"4 THE COURT: So I would address

r.5 you and I look forward to any rnotions in regards to
16 Ms. Agrusa -
L7 MS. AGRUSA: Thank You for

1B allowing me to stay.
19 THE COURT: Again, I am limited
20 as to what you would be able to do in terms of any
2t actual court procedure. so that involves I don't
22 know what this says the }ength and number of
23 addresses of counsel, whatever that means. I don't
24 know about the }ength.
25 But then the number of
1 COMMONWEALTH vs. WILLIAM H. COSBY, JR . J'g
2 challenges of jurors and procedure for voir dire and

3 the 1ike. Now, obviously that is going to be
4 important in this case. I mean, it hangs over this
5 case, which are pretrial publicity.
6 And, again, the Court is
7 operating under what is called a Decorum Order and it
B is only necessitated because this is a case of public
9 interest. Andr a9ain, it is scheduled for the same
L0 day that I was calling trial- and pretrial matters in

11 my regular courtroom, but by the very nature of this
1,2 case, what appears to be large public interest, w€
L3 have scheduled and f see that we will conti-nue to

t4 schedul-e matters via separate schedulinq.
15 ,;" defendant tilI be present
L6 and it wil-1 be in this courtroorn subject to Decorum
t1 Orders, so heads up on that,, both to the press or any
1B interested parties t,hat are here and the attorneys, so
L9 be mindful of that.
20 But we wil-l eventual ly then have
2L to begin to address at some stage any motions as to if
22 there is a change of venue or anything having to do
23 with what procedures r,re would do to try to select

24 jurors in this case if and when we get to that time.
25 All right. So that I s kind of
1 COMMONWEALTII vs. WILLIAM H. COSBY, ,JR. 20
2 what, you know, the ruLes suggest. Let me make sure

3 of my checklist as to anything else. I think that's
4 pretty much at least what the rules envision.
5 Now, how about counsel? What,
6 if anything, right now do you want that the Court can
7 do or anything that. you're unsure of?
8 MR. STEELE: Your Honor, in
o terms of dates and things that you're going to be
10 picking, the Commonwealth is ready to proceed. Werre

t1 ready to proceed in this matter. We're ready to go to
I2 trial, so at the Court t s earl-iest convenience we are
r_3 prepared to do so -
L4 THE COURT: A11 right. Now,
15 that becomes i-mportant whether they really are or not.

16 They will, under Rule 600, always be in a posture of
L7 saying theyrre ready.
1B MR. STEELE: We I re ready.
19 .. THE COURT: You are ready to
20 proceed, but we're not goinq to call this case for
21_ trial . And f don't see that there is any unreasonabl-e
22 delay of the defense in this case.
23 Again, I fully understand the
24 defense's posture in its filing of its original habeas
25 corpus. This case is of a unique nature in how it
L COMMONWEALTH vs. WILLIAM H. COSBY, JR. 2I
2 arrived at this court. So I don't see that as an
3 unreasonbbLe delay. And pursuing cases of a unique

4 legaL ruling as far as they're concerned.
5 And whether we call it
6 interlocutory or not, that is rea1ly for the Superior
7 or Supreme Court to decide whether to accept appeals
I like that. I'11 make my judgment as to whether they
9 are, in fact, interlocutory.
10 So I don't want to get into
1L but the Commonwealth, .ld I do say this, will probably
T2 always maintain it's ready to proceed to tria1, Mr.
13 Mclt{onagle. And t,hat's important because I want your
I4 client to be able to feel thatr you know, however much
15 delay there has been leading up to the arrest, that
r.6 this Court stands ready, willing and able to afford
L1 both partj.es a speedy trial.
18 But I recognize that it is
19 within the bounds of. your ethical duty to be a zealous
20 advocat,e and to be an advocate that is fully prepared
2t and ready to present what,ever you feel in your
22 client t s interests, that are j-n his best interests. I
23 understand that,. So I will need to hear from you in
24 that regard if you are not thinking that your speedy
25 trial rights are being foIIowed.
I COMMONWEALTH vs. WILLfAM H. COSBY, JR . 22
2 Now, that does present you're

3 going to do the argument on the one pretrial, and then
4 we might retire again to get the calendars out and
5 then look long and hard at what we have to deal with
6 in terms of existing pretrial motions and presumed
7 pretrial motions or anticipated ones which you have
B indicated you will file. And I donrt want to leave
9 here again without setting deadlines for you to file
10 them and deadlines for the Commonwealth to file them,
1L But f do note this as a
L2 backdrop. But we did talk and I want you to think

13 about it as we do this. You are probably one of the
t4 most. preeminent trial- lawyers in this region, and you
r_5 alerted to me that you might not be available until
1_6 June. That's something we have to work on. It. Is
L7 probably a long, hard l-ook at your calendar.

18 And I don't want Eo, you know,
19 manage your business for you or anything like that,
2Q but by being a preeminent trial }awyer, you get a lot
2t of trials, some of which go to trj.a], some of which
22 don't, but we need to deal with that because I
23 wouldn't want your trial status to deny your client at
24 Ieast the ability to get an expeditious trial- as long
25 as the Commonwealth is always going to be rising and
2 saying they're ready to go.

3 So, with that said
4 MR. McMONAGLE: I did IooK
5 around when you said preeminent, Judge.
6 THE COURT: I consider you that,
7 f f ll put it that wdy, Mr. McMonagle, considerj-ng f rve
8 worked with the Commonwealth team here and I consider
9 them preeminent, but theyrre closed in to this county
10 here. That I s where they do their work.
L1 But you are a regional attorney
L2 and hence a very, very large inventory of cases
13 awaiting trial, and that sometimes in itself is a
14 difficult, procedural matter to deal with.

15 MR. McMONAGLE: Yes, Your Honor.
16 THE COURT: A11 riqhL. I think
t7 my checklist I think I went over most of it.
L8 So let I s t,alk about you know,
L9 I don't have to make my ruling today, but I believe
20 that the motion fiLed by the defense this was a
2L motion that was filed on August 3rd of 20L6

22 supplemented on August 12th of 20L6. It is entitled
23 Defendant I s Motion to Suppress the Recording of a
24 Telephone Call Obtained in Violation of Pennsylvania's

25 Wiretapping and Electronic Surveillance Control Act.
vs. WILLIAM H. COSBY' - 24
t COMMONWEALTH JR
2 And that was suPPlemented on

3 August L2Lh of 201'6 with a Cornmonwealth response
4 containing the actual, I believe, Ltanscript of the
5 alleged recording. And that was fiLed September l-st.
6 So Iet me start, first, with
7 have you heard the phone call, Mr- McMonagle?
I MR. McMONAGLE: Have f heard it,
9 Judge ?
r.0 THE COURT: Yes.

1L MR. McMONAGLE: No.
t2 THE COURT: OkaY. So I have to
13 deal first if I don't think that the Court's

Irm
14 determination is going t,o revoJ.ve around the actuaJ-
.LJ wording of the phone call. That could be subject of
t_6 another motion.
17 But theY have taken the
LB liberty I arn assumi-ng this is a one-sided
I9 transcription of a phone call that you have disclosed
20 in discovery?
2L MR. STEELE: Correct, Your
22 Honor.
23 THE COURT: So the Phone caII
24 exists. a matter for you to listen.

It's ff you have
25 assistance or experts to make sure that it's an
2 accurate transcribtion if and. when it was ever to be

used, that's on you. They claim they have an accurate
4 transcript.
q MR. McMONAGLE: I donrt
6 antic j-pate a problem with that, Your Honor .
7 MR. STEELE: And, Your Honor,
8 with that, my understanding on this was that we are
9 going to incorporate t,he exhibits, Cornmonwealth
1_0 exhibits, for this hearing.
L1_ THE COURT: Right. That's what
I2 I rm doing here. I have Exhibit A and I have Exhibit
13 B.
L4 Now, Exhibit A Exhibit B
J_5 appears to be an official court reporter transcribed

I6 deposition. And it was the purpose the
T7 Commonwealth seemed to add to it was to bolster an
1_B argument that they made regarding knowledge of being

r"9 recorded, f 'm assuming.
20 But thatrs a litt1e different
2L than I don r t see how the legal argurnent on what
22 statets wiretapping statute applies, if it applies.
23 They have kind of a dual argument in that regard. But
24 right now v/e can hold that open as to whether it was
ZJ an accurate transcription pending you l-istenj-ng to it,

1 COMMONWEALTH vs. WILTIAM H. COSBY, JR. 26
2 but I don't think it looks like an i-ssue either.

3 So with that said, your motion.
( THE COURT: You may address it.
6 MR. McMONAGLE: Your Honorr ds
7 the Court t s correctly stated, Mr. Cosby comes before
I the Court today requesting that he be entitled to the
9 protections of Pennsylvania's Wiretapping and
10 Electronic Surveillance Act 1aws.
1l- Tbis Court is well aware that in
t2 the State of Pennsylvania, the State of Pennsylvania
13 criminalizes the interception and discJosure of phone
1.4 conversations without the consent of both parties. fn
15 Pennsylvania we choose to protect our citizens from
16 such invasions. We're pretty vigilant, quite frankly,
T7 in the way we protect our citizens from such an
18 j-nvasion of privacy.
r-9 In 2005, a citizen of a foreign
20 country, Gianna Constand, while on foreign soil
2L recorded a phone conversat.ion with Mr. Cosby while he
22 was in the United States. And she did so without his

23 consent.
24 Despite the fact that
25 Pennsylvania criminal-izes use of such evidence, the
z District Attorney's Office seeks to do just that, use

3 it. The District Attorney has argued that this Court
4 shouJ-d ignore Pennsylvania law and, instead, apply the
5 Iaw of another country, that being Canada, wh j-ch
6 permits such intrusion of one's privacy.

7 We submit that to do so would
8 violate Mr. Cosbyrs rights. This Court is aware that
9 any time that there is a collision like we have here
10 of Iaws or a conflict of laws, the Court has to begin
l_1 as a threshold matter to decide whether or not that
t2 Iaw that is at issue is procedural or substantive.
r_3 And I think the Court's aware that in our legal papers
74 we have argued that this is a procedural rule.
l_5 If it is a procedural rule, then
16 it makes it really easy in terms of the Court's input.
L7 If it's deemed procedural, then this Court must apply
18 the Iaw of forum, and in that particular instance that
L9 would be Pennsvlvania.
2A We argue consistent with the
2I pronouncements of Commonwealth versus Dennis in its
22 holding. The questions that involve the admissibility
23 of evidence are procedural and must therefore be
24 analyzed under Pennsylvania 1aw.

25 However, even if this Court were
2 to come to a conclusion different than Dennis and

3 det,ermine that the guestion of the admissj-bility of an
4 oral communication like this one is, in fact,

5 substantive, the result is the same. Pennsylvania law
6 applies. And here's why.
7 If a conflict involves a
8 substantive law, the Court must analyze which forum

9 has the greater interest. And I think vre're aII in
10 aqreement on that. The level of inquiry this Court
11 must now embrace is if itrs substantive, which
t2 jurisdiction, whether it be Pennsylvania or Canada,
13 has the greater interest?
T4 I'd invite the Court to what
15 transpired in Cornmonwealth versus Rebert. There' the
16 Superior Court was charged with the task of analyzing
L7 a conflict of law question in a Pennsylvania rnurder
t_B case. In that particular instance, tragically, James
19 and Victoria Shugar urere murdered here in

20 Penn sylvania .
2I fn that case the defendant,

22 Mr. Rebert, tried to argue tbat the Pennsylvania court
23 should apply New York law in analyzLng the
24 admj-ssibility of what IAtas a jailhouse conf ession. And
25 he argued that the confession occurred in New York and

2 that, it was obtained in a New York prison and it was
J orchestrated by New York prison guards.

4 Itrs the typical scenario that
5 this Court has obviously seen time and time again
6 where law enforcement officers, whether they be in a
7 prison or sone other locale, decide that theyfre going

8 to send in somebody to the prison to try and obtain a
9 conf ession. WeIl, they did j-n New York and they were
10 successful.
1-1 And the defendant said, not so
t2 fast. You got to apply New York law. And New York
13 1aw, he said, would require evidence suppression.
1_4 And then the Superior Court said
15 in deciding this, not so fast, Mr. Rebert. You hold
L6 on. We're going to look hard t,o deterrnine which
t7 state, New York or Pennsylvania, has the greater
L8 interest. And they did. And herers what they wrote.
r-9 And I rrn coming right out of that opinion.
20 The Shugars, James and Victoria,
2T they said, llere Pennsylvania residents. The
22 defendant, Mr. Rebert, was a Pennsylvania resident.

23 The crime occurred in the Commonwealth of
24 Pennsylvania. The Pennsylvania State Police
25 invest,igrated the murder . A Pennsylvania D. A.
2 prosecuted the rnurder. And many of the wj-tnesses, the

3 Court. said, were from the State of Pennsylvania. The
4 Court then came to the inescapabl-e conclusion that New

5 York really had no j-nterest in the outcome of the case
6 and thev so ruled.
7 I now ask you to apply that test
I to the facts of this case step by step. In 2004, Mr.
9 Cosby was a resident of the State of Pennsylvania. In
10 2004, Miss ConsLand was a resident of the State of
l_ l_ Pennsylvania. It j-s alleged in this case that this
t2 incident happened in the State of Pennsylvania at Mr.
13 Cosby I s house. The case was investigated, without
L4 quest.ion , by the Montgomery County District Attorneyrs
-LJ Of f j.ce which is here in Pennsylvania. And the
16 Montgomery County District Attorney's Office has now
77 prosecuted the case with criminal charges.

18 Stated simply, Canada has
19 absotutely no interest on this issue as it no$t sits
20 here before you in Pennsylvania. end any interest, r
2l subrnit, that Canada might have paLes in comparison to
22 the interest of our state and our jurisdiction, and
z3 f'd ask you to apply the law of the Commonwealth of
24 Pennsylvania. And if I do, then there can be no
25 question that the evidence has to be suppressed.

.L COMMONWEALTH vs. WILLIAM H. COSBY' JR. 31
2 THE COURT: But obviouslv the

3 WireLap Act criminalizes the behavior.
4 MR. McMONAGLE: Yes, sj-r.
5 THE COURT: So there 's certain,
6 you know, venue of where it occurred. This is not
7 where anybody is being charged with a crime. This is
I an evidentiary rnatter. whether they can use it.
9 MR. McMONAGLE: No questi.on.
THE COURT: You're saYing it Is
10
1L stiIl proceduratly fact that he is a Pennsylvania

I2 resident, they cantt use it. But the act,
1_3 Pennsylvania's act is about charging someoner isnrt
14 it, not about whether you're using it in evidence?
-LJ MR. McMONAGLE: Well, it is.
16 about a prohibition of conduct that we're not goi-ng to
1'1 tolerate invasions of privacy here in Pennsylvania set
18 out that way without dual Party consent -
19 And what we are arguing and I
20 think what. is allowed under the statute is if someone
2T tries to use it in the state of Pennsylvania, it can
22 be illegal. And if someone tries to use it in a
23 criminal prosecution in Pennsylvania, it can be

24 suppressed. Well, someone's trying to do that.
25 IronicaIly, it's law enforcement in this particular
1 COMMONWEALTH vs. WILLIAM H. COSBY, ,JR - 32
2 case.
The only question before You, I
.tA submit to the Court, is what law you're going to
5 apply? They want you to apply Canada's law, a foreign
6 country. think about that for a second. I
And let's
7 mean, it's all nice and warm and fuzzy because it I s
U Canad.a, but don't make it Canada f or a second. Make
9 it rraq, make it North Korea, make it' sorne
10 jurisdiction that intends to use subterfuge or
LL trickery or a lie like in this case to get somebody on
L2 the phone and record them.

t_3 Do we want them Courts like
L4 Pennsytvania to apply the law of some foreign country?
15 And the answer is no.
Ib THE COURT: Right. So tell me
17 whether it changes it at all that it apPears that the

l_B phone caLl that was recorded, that your client was j-n
19 California.
2L THE COURT: And is that a
22 stipulation that everybody agrees' to?

23 MR. McMONAGLE: I believe it is'
24 And I would say to the court and it's the same
25 argument if for some reason this Court found that

2 California had any interesL and f don't believe

3 they do. Like Canada, Cal-ifornia has absolutely no
4 interest. in this, has no dog in this fight- But if
5 you applied California law, it would be the same.
6 THE COURT: rf r applied
7 California 1aw.
B MR. McMONAGLE: Sure.
9 THE COURT: I'm trying to
10 piggyback on the reasons t,hat you tell me that I have
1l_ to apply Pennsylvania Law. You call hirn a resident of
't"2 Pennsylvania. Is that a factual thing that we have to
L3 establish?
t4 If you're going to move along
15 and cl-aim, well, essentially this j-s the statute when
15 you're not prosecut j-ng somebody under it and you're
I7 really utilizing it t.o say that it's a prohibition,
1B therefore we want to protect Pennsylvania residents,
L9 is he a resident of Pennsylvania? fs he a resident of
20 California making a phone call from California? But
2T you're arguing because he's being prosecuted for an
22 related crime j-n Pennsylvania, he should get the

23 procedural prot.ection?
24 That's kind of what Ifm hearing
25 you say
2 MR. McMONAGLE: Unfortunately,

3 because of the 12-year delay we have to go back in
4 time to the event. Norrnallv it's a little bit more
5 timely. But at the time of incident, the time that
6, brings us here, Mr. Cosby was a resident of
7 Pennsylvania. That I s not in dispute. I rm sure Mr.
8 Steele is not taking that position. He l-ived in
9 Cheltenham. And the house that was in question in
l-0 this case, his house
11_ THE COURT: But he also mav have
L2 lived in CaLifornia.
13 MR. McMONAGLE 90eII, that 's
:
t4 certainly possible, too. And people can have dual
1-5 residences and live in different countries.
L6 THE COURT: f keep asking. If
L'l the Commonwealth is noL going to raise it, theyrre not
LB going to be again, this is not whether he is being
19 prosecuted for i1legaIly wiretapping somebody eIse.
20 MR. McMONAGLE: Of course.
2). THE COURT: You are trying to
22 prohibit its use because it woul-d seem wrong if we
ZJ have a statute'that makes it iIIegaI if it's only one
24 party consent, it certainly would seem wrong to admit

25 it into evidence in a case. Thatrs kind of what your
vs. WILLIAM H- COSBY' JR- 35
L COMMONWEALTH
2 argument is.
3 MR. McMONAGLE: It would be
4 iIleqal.
THE COURT: Right . And the
6 argument is vre protect our res j-dents r' right?
7 MR. McMONAGLE: Yes.
8 THE COURT: If You want to
9 record, you better have two. And if you're being
i_0 recorded, you better be in this state'
11 MR. McMONAGLE: That's correct .
I2 THE COURT: OkaY. But he wasn't
13 in this state.
t4 MR. McMONAGLE: No.
_1 3 THE COURT: And his onlY
L6 connection to this state is he happened to be a

l7 resident, but he made the callfrom california.
18 MR. McMONAGLE: Well, that's not
'connections to
1_9 the only connection to this state. The
20 this state are enormous in terms of your analysis ' I
2L mean, what this Court is required to do under conflict
22 of law principles in deciding whether it's
23 pennsylvania's Iaw or Canada's law is look at the
24 whole case. Look at it.
25 Mr. Cosby res j-ded in
2 Pennsylvania. Miss constand resided in pennsvlvania.

3 The alleged incident occurred j_n pennsylvania. It's
4 the same inquiry in Rebert.
5 The Courts are going to go step
6 by step and soy, wait a second. What state has the
-t greatest interest? We're trying this case in
8 Pennsylvania. He I s going on trial in Pennsylvania.
9 God forbid if he's convicted, he's going to be
10 punished under Pennsylvania Iaw. No other

11_ jurisdiction in this country or anywhere in the world
T2 has a greater interest in the outcome of this ruling
13 than the State of Pennsylvania.
1A
.t't And for all those reasons,
15 .)udge, i f you look at the analys i s provided by the
t6 Superior Court in other cases, you're going to have to
t7 come down somewhere on this.
18 And I know that Your Honor is
19 asking about the statute itself, but time and time
20 again the case law has permitted suppression.
2T THE COURT: I am not talking
22 about but, again, the analysis that gets you there,
23 you're falling back because f get all the
24 connections that the alleged crime occurred here; that
25 at, the time the alleged crime occurred, both parties
) were here; whether she was a technical resident of the

J Cornmonwealth with,whether he was a resident of the
4 Commonwealth, nobody's established yet. f can just
5 say maybe Mr. Cosby has res j-dences in other states.
6 And coming back about protecting
7 our citizens, not protecting the transientr
$ou know,
I people that will- come through our state and they get
9 our protections here, your basic claim is everybody
L0 was a resident. That locks us into Pennsylvania when
11 the crirne occurred.
t2 And then a year later nobodyrs
13 in Pennsylvania when the alleged discretion, you know,
L4 the alleged indiscretion under a wiretap occurred.
r_5 Nobody was in Pennsylvania then. One was in Canada;
L6 one was in CaLifornia.
l7 What you're saying is pay no
18 attention to that because now we're back here aqain
19 for sornething t,hat allegedly happened a year before
20 and a trial that's happening now in Pennsylvania with
21. a PennsyJ.vania prosecution.
22 I I m just. not maybe you're
23 correct, but you see I 'm getting a littl-e attenuaLed
24 when they didn't commit the alleged violation at the
25 time anybody was in Pennsylvania.
L COMMONWEALTH vs. WILLIAM H. COSBy, JR. 38
2 Can you argue, h"y, ure've got to

3 protect, our residents because that is one of the
4 foundations ?
5 MR. McMONAGLE: Yeah. The
6 di stinctions are made by distinct j-ons . I think
7 theytre distinctions without a difference. And the
I reason that I say that is you have to look, again, at
9 the totality of the circumstances in real time. Look
1_0 at Rebert.
L1 THE COURT: I have.
t2 MR. MCMONAGLE: fn Rebert,
13 everything happened in New York in terms of the
14 intrusion, for lack of a better descriptionr Lhe
15 evidence that was being suppressed.
16 So when you look at conflict
1,7 purposes and conflicts Iaws and what I s being protected
1B here, I submit to the Court that step by step by step
19 there is no other forum that has any interest in the
20 outcome of this particular issue and no other forum
2I that could even make a complaint.
22 Let me give you another example.
23 When Miss Constand went and made her complaint a ybar
24 after the fact, she had relocated to Canada. She
25 actually went to Canadj-an authorities. And you know

1 COI4MONWEALTH vs. WILLIAM H COSBY, JR. 39
z what they said? Not our problem. Call Pennsylvanj-a.

3 fn f act, t.hey took no steps to investigate the case.
4 They took a page interview and they called
5 Pennsylvania as fast as they could and they said, this
6 is your problem. This is your interest. We have no
7 interest. Of course, theY don'L.

B Of course, California has no
9 interest. ,Just the f act that a nationally recognized

10 entertainer happens to be in California on business
l_1 and own a home in California doesn't change the fact
t2 that everything that has to do with this case is right
13 here in your county in Pennsylvania -
l4 THE COURT: WelI, does it change
15 the fact that the alleged victim in this case didn't
16 record anybody?
I7 MR. McMONAGLE : That the victirn
1B didn't record anybodY?
19 THE COURT: That 's not the
20 claim. I haven't read any claim that the a11e9ed

2J- victim recorded anYbodY.
22 MR. McMONAGLE: I never
23 suggested that she did.
24 THE COURT: OkaY, but You
25 MR. McMONAGLE: Are You asking

L COMMONWEALTH vs. WILLIAM H. COSBY' JR . 40
2 me whether t,hat matters ?
3 THE COURT: V{eLJ., you I re saYing'

4 Iook
5' MR. McMONAGLE: WelL, her rnother
6 did.
7 THE COURT: I understand who
8 they allege did it, but she's not a subject of
9 anything here. Clearly the mother couldn't be
r.0 prosecuted in Canadai correct?

11 MR. McMONAGLE: Thatrs correct -
L2 THE COURT: The rnother undertook
13 an individual decision to record this conversation in

t4 canada where she was perfectly permitted to do so.
15 You keeP talking about Miss
L6 Constand being a resident of Pennsylvania at the time
77 of the crime.
18 MR. McMONAGLE: She's the
1-9 complainant.
2A THE COURT: I know who she is,
2t but not the person who recorded the conversation
22 MR. I'IcMONAGLE: Yes.
23 THE coURT: -- which is a little
24 different than some of the other cases, meaning the

25 actual case participant, she didn't record anything.
1 COMMONV{EALTH vs . WILL IAM H . COSBY, JR . 41-
z They jusE have they I re clairning they have a piece

3 of evidence
4 MR. McMONAGLE: Yeah.
tr
J THE COURT: -- that, $Ias
6 perfectly permitted. I mean, there was something, I
7 also believe, in one of the earlier hearings regarding
I whether, in fact, Miss Constand would be prosecuted
9 for recording phone calls. I believe there was
10 testimony by was it t'liss Troiani or Miss Kivitz

l-1 that that I s why they went to their office, that there
t2 lrere but nobody ever got prosecuted for recording
13 it; correct?
l4 MR. McMONAGIE: Not to my
15 knowledge.
16 THE COURT: And the onIY
L7 recording that was made was made by the victim's
t_8 the alleged victimrs mother.
L9 MR. McMONAGLE: That's correct -
20 THE COURT: And You're saYing it

2T just doesn't make a difference.
22 MR. McMONAGLE: No. The law'
t.he wiretap law doesn t t say it t s got to be a
23
24 THE COURT: The wiretaP law

25 doesn't taLk about
2 MR. McMONAGLE: Right.

J THE COURT: -- adrnitting
4 evidence.
5 MR. McMONAGLE: So I don't think
6 whoever the party is that engages in the, what I'11-
7 ca11, conduct that,'s in Pennsylvania, it doesnrt
B matter who it is, you just canrt use it in
9 Pennsylvania. That I s it. Unless you record from
L0 another jurisdiction that has greater interest.
11 In this case, the PartY who
1.2 recorded it recorded it in canada. canada has no
1? interest in the outcome of this issue. And for that
L4 reason, the only law you can apply is Pennsylvania.
LJ And when you apply that law, whet'her it be Miss
l6 Constand, her mother or the rnan in the moon, YoU can't
L7 admit the evidence.
1B THE COURT: Got You. All right-
19 Who would like to argue from the Commonwealth? Come
20 on over to the podium.

21. MR. STEELE: Do I need to go
22 there ?
23 THE COURT: Argue where You
24 want, but there's a nice microphone here. The

25 collective mernbers of the audience would like to hear
2 you loud and clear.

3 MR. STEELE: I'm focused on you.
4 THE COURT: I hear your but the
J microphone will project your focus back to them.
6 MR. STEELE: All right. So I
7 think it's helpful to look at this from a fact of
8 standpoint. The original motion that was filed by the
9 defense indicated that the defendant was in
L0 Pennsylvania at the time. Then there was the
1-1 supplernental that he l.ras in CaIif ornia.
t2 And I think also important to
13 this and to the assessment is he is making the call.
t4 It is a phone caLl that he makes to Canada, a phone
15 caIl between the defendant and Mrs. Constand.
16 Now, looking at the
t7 circurnstances of the call, one of the evaluations that
18 should be looked at on this is: fs there an
19 expectation of privacy? Do you have an expectation of

20 privacy that you're not being recorded at the time?
2I And when you look at this from a
22 factual basis of the circumstances around the call,

23 simiLar to Your Honor calling and somebody saying that
24 this is being recorded, we11, that's not a violation
25 of the Wiretap Act. That's you giving up your
vs. WILLIAM H. COSBY, JR . 44
1_ COMMONV{EALTH
2 expectation of privacy and engaging in this call-

? So in this call- there is a
4 beeping sound. And thatrs outlined in the factual

5 basis that vre presented, but also in the transcript
6 itself . And there's back and f ort,h on whether this
7 was a parrot or something else.
8 THE COURT: lrleII, Iet me ask
9 you. Obviously you have two responses to their
10 motion.
1t_ MR. STEELE: Uh-huh.
1-2 THE COURT: One is that he has
1_3 waived his expectation of privacy.

L4 MR. STEELE: Correct.
l_5 THE COURT: Now, PrettY much
r6 most of that can be made out. The recording is the

I7 recording where there $tas a claim that there is beeps.
- 18 Now, I have not heard it. I dOn't know whether you're
l-9 able to play it.
20 But is it determinative of rne or
2t someone else to listen and say that's not a parrot,
22 that I s beeping? so then when he says is that beeping
23 and she keeps saying, oor it's a parrot, that in order
24 for me to determine his exPectation of privacy' I've
25 got to make a determinatj-on is it an el-ectronic beep
COMMONWEATTH vs. WILLIAM H. COSBY, JR. 45
t-
2 or is it a really good parrot?

? MR. STEELE: No.
4 THE COURT: I don't have to do
5 that ?
6 MR. STEELE: You don't.

7 THE COURT: But Yori're claiming
I that. You're saying he knew what he was doing. He
9 said, I think you're recording me. so that works for
10 your argument. Hers saying, I'ook so you keep
11 telling fr€r ,Judge, whatever that lady was saying on
t2 there, that ainrt a parrot. That's an electronic
l_3 recording and he knew it. And he said you can say
L4 what you wantr Pafrot, no parrotr and you move on'
Part of Your evidence is that he
16 definitely makes a humorous remark about it to say

L"t that he knew it wasn't a parrot, right, in his
1,8 deposition?
t-9 l4R. STEELE: . OkaY. So that' s
20 where you get to the second point on it, which is t'he

2l evaluation that we just talked about, is, Y€s, he
22 believes that he is being recorded at the tj-me' which
23 it is important for the analYsis.
24 end we corroborate that' not just
25 from what he says in the transcript on the call and
2 asking about this beeping noise, but what he says in

3 the deposition when he is asked about it and he said
4 yeah, I thought I was being recorded. And you have
5 the transcript on it.
6 THE COURT: Do we have the
7 recording? Because if your whoLe argument, is well,
I st,op with the parrot. Even if that's what
9 Mrs. Constand said, you hear this recording and you
10 know somebody is recording it.
tl- And then your position is he
t2 just kept going, he knew what that beeping was. And
13 in f act, he let, us know n j-ne, 10 months later he knew
L4 exactly what the beeping was. But maybe he says I

15 didnrt say anything incriminating, I didn t t do
15 anythirg, I just had a conversation.

).7 That turns around you now want
18 to use it, but I don't know whether it was a beeping
19 or whether it sounded like a parrot and whether it vtas
20 plausible, and if it was plausible that it was a
2I parrot at the time and he said no harm there, there's

22 a parrot in the background, Itm going to keep saying
23 things.
24 I think that goes to my
25 determination, doesn t t it ?
.,1
COMMONWEALTH vs. WILLTAM H. COSBY, JR . 47
2 MR . STEELE : Wel l-, then we I L I
3 qet you the recording, but I don I t think it does.

4 THE COURT: AlI right. KeeP
5 gol-ng.
5 MR. STEETE: Because it is his
7 expectation of privacy, what he thinks, you know, dt
I the time. And the assessment, hers given it. He says
9 that he thought he was being recorded. So that in and
10 of itself
11, THE COURT: He said he thought
!2 he was being recorded until she kept saying, Dor it's

13 a parrot. Maybe it was a really good parrot that was
T4 able to mimick back beeps. I don't know that. I just

15 don't know it.
16 Your argument, that
But thatts
'17 it was ludicrous that it stas a parrot - It's
18 ridiculous t,hat it was a parrot. And he knew right in
19 there that it wasn't a parrot. Maybe he thought he
20 going to say anything that he thought anybody
wasn ' t
2T was ever golng to use against him and he just kept
22 going.
23 But I'd hate to see the
24 determination of being that you're arguing
25 sornething and I don't know whether it was a parrot or
2 a beep. Because people know el-ectronic beeps of

? recording, donrt they? Have you heard it? you
4 haven't heard it either?

5 MR. McMONAGLE: No.
6 MR. STEELE: We can get it and
7 bring it down here if you | 11 give us a couple minutes
B to do that.
9 THE COURT: Ask sornebody to do
10 it because if he hears it his response right now is
l-1 he had no clue he was being recorded. Zero clue.
72 That's got to be his position.
13 MR. STEETE: He didn I t say that.
T4 MR. McI4ONAGLE : .Tudge
15 THE COURT: Stop. He had no

16 clue because had he had a c.l-ue I rm going to ask him
L7 to come back in rebuttal to rebut your your main
LB piece is before f even get to which law applies and
1.9 how it applies is his expectation of privacy. He
20 never addressed that once with me. He never said

2L anything. He'said, Judger his interest is in this
22 Commonwealth procedurally. You got to suppress it.
23 So now you're making the
24 argument that this man knew he was being recorded and
25 he never had a chance to respond to it. ThatIs aII
1 COMMONWEALTH vs. WILLIAM H COSBY, JR 49
2 I 'm saying.
3 MR. McMONAGLE : It I s actual" 1Y a
4 Iittle slmpler than that.

5 MR. STEELE: Here, You can have
6 the mj-crophone.
7 MR. McMONAGLE: Judge, he's Iied
I to in that conversat ion . She tel l- s hirn she I s not
9 recording. And getting back to your first question,
10 she calIed hirn, left a phone messaqe with him in New
13- York, and then he calLed her back.

t2 . So to both Points that have been
13 raised, it doesntt matter that at some point in time
t4 he may or may not have heard beeping. By the time
15 hets deposed however many months later, Someone told
t6 him, oh, he got wiretapped. What matters is she lied
T7 to hirn in that conversation and didn't have his
1B consent to record it.
T9 THE COURT: Their whole Premise
20 is whether she said it or not, he knew he was being
2t recorded.. Now, there's not many cases on this, but f
22 don'l want this to qo down his position is Y€sr his
23 main that was the f j_rst thrust of your arg'ument,
24 Mr. SteeJ"e He waived it.
25 Now he's arguing, weII, You
vs. WILLIAM H- COSBY' JR. 50
L COMMONWEALTH
2 can't waive it because a lie is a lie- Even though

3 everything in the background could be saying you are
4 being recorded, beep, beep, beep, that indicated
5 MR. McMONAGLE: That's not the
6 case.
7 THE COURT: I don't know. You
B haven't heard it. You didn't hear any background.

9 Nobody's heard this thing.
10 MR. McMONAGLE: I can tell You
11 that's not the case.

t2 THE COURT: WelI, I just think I
13 would need to hear it because your argument is it j-s
T4 not a reasonable expectation of privacy' And
15 reasonable sounds Iike somebody has to make a

l-b determination of reasonable- Yourve made it'
t7 MR. STEELE: He made it, not me.
18 THE COURT: He argues somebodY
r_9 told him later on it wasn't a parrot.

20 MR. McI'IONAGLE : She l ied to him
21. in the conversation. Why are we having this
22 conver s at ion ?
23 THE COURT: MY fault. I didn't

24 mean to break this down. I need to hear the
25 record.ing. That's all. Not very long ' It sounds
COMMONWEALTH vs . L{ILLTAM H. COSBY' JR. 51
1
2 Iike you'd have to hear it in terms of your position-

? MR. STEELE: NO.
4 THE COURT: I don't?

5 MR. STEELE: We'11 PlaY it for
A you, but no, because that's the point here is
the
7 you don't have an expectation of privacy - And just
I because youfre being recorded, you talk and you say
9 things and he decides to be somewhat cagey and not do
10 certain things on the phone because he thinks he I s

t_1 being recorded
I2 THE COURT: Their clairn is he
13 did not know he was being recorded. That's what Mr.

L4 McMonagle is now saying. And he didntt know it
15 because he asked the direct question, and she said I
16 am not recording you. He relied upon it and continued
T7 to speak.
18 MR. STEELE: That's not what he
19 says in the dePosition -
20 THE COURT: OkaY. Let's leave

2t the deposltion out of it because their claim t'here is
22 he could have been told later on you were recording it
23 when he did.n't think he's being prosecuted '
24 So, the Court again, if itrs
25 going to be part of this, I think we need to hear the
1
2 background of this recording, and he hasnrt even heard

3 it, because it's your main argument. Your other
4 argument might be
5 MR. STEELE: You haven't let me
6 get to the rest of the argument. okay? T have a Iist

7 and f'm
B THE COURT: f 'm going to l-isten
9 t,o all of them. Relent with that one .

10 MR. STEELE: Sure. That's how
11 we're going through it.

t2 THE COURT: AIl right. Let's
IJ go.
t4 MR. STEELE: A1I right. So no
15 expectation of pri.vacy, simil-ar to what we dea] with.

16 in calls, you know, from the prison, from anyplace
1.7 elsewhere you have, hey yourre being recorded and
1B people talk anyway on them. He believed he was being
L9 recorded and he still talked anyway and made
20 admissi_ons that should come i-n. And then that
2L deposition and that transcript of the deposit.ion
22 support that.
23 Now, we get to the second
24 aspects.
25 THE COURT: Are You going Past
2 the expectation of privacy?

MR. STEELE: I am.
4 THE COURT: Let's just finish

5 that because, whether I hear it or not, the reason
6 that you no$t allege that that you can tell from the
7 recording, both the transcript and if I Iisten to it
B in real time, that right then and there he knew he r^tas
9 being recorded. Becaqse it's not important

10 MR. STEELE: I don't think that
11" that's that is integral to the decision making.
t2 THE COURT: OkaY. WeIl, then
1_3 point to me what was the deposition testimony that
l4 indicates to you the deposition appeared to be
15 taken when? Anybody know when this was taken?
16 MR. STEELE: So if you turn
L7 to
LB THB COURT: Turning to Your
1,9 Exhibit B?
20 MR. STEELE: Right .
2L THE COURT: And therers no date

22 on my deposition.
23 MR. STEELE: YEAh. ThAt'S --
24 it's indicated in the motion. March 29Lh, 2Q06.
25 THE COURT: So what are the
l_ COMMONWEALTHvs. WILLIAM H. COSBY, JR . 54
'2 parts in there t,hat .you're saying nowr over a year

3 later, that he now says he knew he was being recorded?
4 MR. STEELE: A11 right. So if
5 you go to the top of 2tL.
5 THE COURT: 21L, got it.
n
I MR. STEELE: Therers a question.
I Part of the question: rrDo you have a beeping going on
9 on your phone?"
10 THE COURT: This is Miss
11 Troiani I s questions to Mr. CosbY?
t2 MR. STEELE: Correct. "WhY did

13 you say that? I don't trust anybody. Do you believe
t4 that you were being tape-recorded in that
15 conversation? I believed there is a possibility-"
16 MR. McMONAGLE: Can You read
].'t that in its entiretY?
r.8 THE COURT: 'I believed there is
T9 a possibility. f think she said something Like, wait
20 a minute, I have to get away f rorn phone " Dor 'r f rom
2I some people or do someLhing like that - "
22 MR. MCMONAGLE: YES.
23 THE COURT: That I s his answer.
24 MR. STEELE: Uh-huh.
25 THE COURT: Then the next is a
q5
L COMMONWEALTH vs. WILLIAM H. COSBY, JR.
z question. She says, 'rShe said ilo, Do, not at all. r
J have a parrot. rl
4 MR. STEELE: Do You want me to

q read through that to get to where we are?
6 THE COURT: That ' s where You're
I talking.
8 MR. STEELE: No. We got to keeP
9 gol-ng.
r_0 THE COURT: You take me to the
LL place. You said the f irst is his answer f' f believed
)_2 there is a possibilitY. "
13 MR. STEELE: Right.

1"4 THE COURT: What I s the next one
15 that indicates ?
t-6 MR. STEETE: All right. So, and

I7 then the discussion here is about why, like, he's not
LB giving her certain inf or.mation. And it relates to the
L9 piece of paper that he said he was going to send her,
20 you know, with the drugs on it.
2L So then at the bottom of the
22 page, the question is: "Why didn't you want to tell
23 her at that Point, ?
24 nAnswer: The Parrot.

2s "Question: Because You believe
1 COMMONWEALTH vs . WI LL IAM H . COSBY, ,JR. 56
z you were being taped? Is that what you are saying?

3 ttYes. rr
.t Unequivoca-L in terms of he
5 believed at the time he was being taped and that's why
6 he didn't say certain things on the phone.

I Now, he says other things that
B we submit are admissions that we want to use in this
9 case. But he believed he was being recorded at the
l_0 time and says so uneguivocallyr so there I s no
11 expectation of privacy that he has. Therefore, it's
L2 admissible.
1_3 THE COURT: So you're saying at
l-4 this stage when he said "Why didn't you want to
I3 tell her at that point " and he said, rrThe parrot, rl
L6 that that is his recoll-ection of the conversation?
I7 So he knew he was being recorded
1_8 at the time, said the parrot obviously to be humorous
19 in terms of t,hat parrot was really the recording, he
20 knew it was recordi-ng and he just wasn't going to say
21 anything that he thought could be used against him or
22 could be incriminating or something he just didn I t
23 vJant recorded?
24 l4R. STEELE: I believe that's a
25 fair assessment.
l- COMMONWEALTH vs. WILLIAM H. COSBY, JR . 51
2 THE COURT: That I can

3 understand. I'm going to give you a chance to rebut
4 that, but they raise it as to why it's an exception to
5 your whole arg'urnenL.
A MR. McMONAGLE: Yes, sir.
7 THE COURT: Go ahead.
8 MR. STEELE: So, I mean, that
9 goes to the aspects of no reasonable expectati.on of
10 privacy.
l_ l_ So then vou deal with the second
l2 part of this under more of the wiretap laws and what
13 we're dealing with in Pennsylvania's Wiretap Act,
14 California I s Wiretap Act and Canada's Wiretap Act.
15 Our suggestion on this point is
15 the def endant f rom Cal i f orn j-a caI-l- s Canada . When you
T7 do that, you are allowing yourself to fall under their
18 rules. You know, when you leave a message on
L9 someoners on somebody's tape, when you do things
20 along t,hose lines , you are f al l ing under lhat
2T jurisdiction's rules with this -
22 So Miss Constand violated no
23 rules from Canada. It's a one-party consent. She's

24 permitted to tape record somebody who is calling in.
25 And she did that in this case.
1
.L COMMONWEALTH vs. WILLIAM H. COSBY, JR. 58
i2 So when you look at the laws and

? how this is to be resolved, if you look at and I'I1
'.t A
spell it. S-I-N-H-A versus Sinha which talks about
5 stating the flexible conflict of law approach.in
6 Pennsylvania and then finding a similar
7 interest-oriented approach is appropriate for
B resolution of confl-icts between the law of the states
9 of the United States and the law of another country.
10 That is in cases where that do have an
11 international dimension.
L2 So what you're looking at here
L3 is, you know, Canadian law which permits this to go
L4 on. And if you look at the cases in support of this,

15 like Housman, like Larrison, they, I believe, are on
L6 point with this issue. Rebert is not.

T7 And, as we footnoted in Rebert,
1B it did not involve a conflict. analysis regarding
t9 wiretap laws. It instead j-nvolved statements made by
20 a New York prisoner to a jailhouse informant about
2L Pennsylvania murders.
22 When it cornes to conflicts of
23 aII the wiretap statutes, Housman and Larrison are the
24 controlling cases in this regard and, under both, that
25 this is admissible based upon those circumstances.
vs. WILLIAM H. COSBY, JR- 59
1 COMMONWEALTH
2 And Pennsylvaniars wiretap 1aw does not aPPIY' you

3 know, to this. canada's does. And it was lawfully
4 recorded in Canada and should be used in this case.
5 THE COURT: All right'- Is that
6 ir?
7 MR. STEELE: And before f steP
8 aside, the opinion that is being relied on for this is
9 an unpublished opini-on that is not persuasive.
10 THE COURT: You wouldn't ask me
Ll, to rely on an unpublished opinion, would You' Mr'

I2 McMonagle ?
13 MR. McMONAGLE r w€ set'

: 'Judge
t4 forth the specific nature of it in our moving paPers
15 t,hat it was unpublished and I think I even said that
16 to you.
1.7 THE COURT: !\lhat I s our SuPerior
l"B Court oPerating procedure say about that?

19 MR. McMONAGLE: We set that out
20 in our brief, too.
2L THE COURT: What did theY say
22 about it? You just took up a tot of time and asked me
23 to rely upon a case that the Superior Court's

24 operating procedure say Irm not allowed to'
z) MR. McMONAGLE: WeI1, Judge, it
2 act ua 1 Iy
3 THE COURT: It's not a holding.
4 MR. McMONAGLE: It's not a
5 holding, but this Court can certainly consider the

6 legaI analysis offered by the'superior Court.. f think
7 to do otherwise would be ridicufous. And I think
B coun se J.
9 THE COURT: Well, if they wanted

t-0 me to, they wouldn't have made it a non-published
t_ 1_ opinion.
T2 MR. McMONAGLE: Well, they
13 certainly made the ruling they did in that case and it,
r_4 certainly affected Mr. Rebert and it should affect us.
15 Let me just kind of address a couple points.
16 One of the issues that Is
I7 problematic in Housman as you read Rebert is what do

1"8 you do here and what do you do now when it's not
19 Virginia and Pennsylvania where both states within the
20 United States have made a conscious choice about how
2J, they're going to provide for expectation of privacy,

22 both authored by the same federal Constitution, our
23 Constitution.
24 What do we do now when it is
25 another governrnent's laws that we're trying to get
t" COMMONWEALTH vs . WILL f AM H . COSBY, JR . 6l-
2 used and relied upon like in this case? They want us

3 nor^r, you now to use canadar s l_aw. we1-1., would
4 Canada I s laws survive constitutional muster in
5 Pennsylvania or in the United Stat.es as written? We
6 have no idea. And thatrs a slippery slope in terms of

7 relying on Housrnan. Look at the analysis and you
I never get there.
9 On the issue of this parrot, for
10 lack of a better description, I want you to just think
1L about what they're saying to you. What theyrre saying
1.2 to you is you can get a phone call from somebody,
13 return the call no matter where they are. They can
L4 illegally, or in their. country Iegally, record you.
15 You don't know it. You ask them if they're iIlegal}y
't6 recording you. They lie to you and they tell" you no.
l7 And at some point in time during the conversation you
1B get a littLe suspicious.
L9 Are you saying now that under
20 those facts this whole conversation comes in when you
21, are recorded from the beginning without being told,
22 without your consent, when you are lied to when asked
23 about whether or not you're being recorded' and at
24 some point in time you may figure it out?
25 Do vou then redact what it is
1 COMMONWEALTH vs. WILLIAM H. COSBY, tJR . 62
2 you were supposed to figure out, the parrot is not a

3 parrot and you're being lied to? I submit to the
4 Court the whole thing stinks and you ought to throw it
5 ouc.
6 THE COURT: A11 right. Wel1,
7 what do you want to do about I can take it under
B advisement. Yourve made the argument that he waived
9 it. And to do that, I'd have to hear the actual
10 context in which your argument would rnake sense, you
1L know. Ird just have to hear it because yourre both
L2 arguing.
13 His posit,ion is you never
1,4 ever
15 MR. STEELE: lTust give us a
1.6 couple-minute recess. We' 11 bring it in and present

77 it to you. Okay?
1B THE COURT: Okay. Let I s deal
19 with, before we would retj-re, to at Least try to come
2Q up with some dates. How are we going to approach them

2T in terms of importance? So far I have two outstanding
22 motions that would have to have hearings. T have his
23 original one to suppress the deposition as a
24 constitutional right violation and the Commonwealthrs

25 404(b) motion. I leave the discovery motion out there
t_ COMMONWEALTH vs . 9IILLIAM H. COSBY, JR. 63
2 because it doesn't require any immediate action.

3 So what else do you is there
4 anything that you know today that you wiLl- be filing?
6 Judge, dt least at this point we are working on a due
7 process,/pre-arrest delay motion. One was
B preliminarily filed pre-Preliminary Hearing which was
9 tabled. And we are supplementing that now and that

10 will be filed.
11 Addit j-ona11Y, it's anticiPated
t2 that we'lI be filing a motion
1-3 THE COURT: How long do You
t4 think it would take to do the pre-arrest delay motion?
L5 I mean, to finish it?
r_6 MR. McMONAGLE: I would ask for
t7 50 days if possible.
t_8 THE COURT: SixtY daYs?
19 MR. McMONAGLE: The onlY reason

20 I'd ask is we're accumulating now a lot of evidence
2I and discovery, et cetera, that go to the heart of the
22 issue, Partj-cularIy Irm trying to locate witnesses.
23 Are there witnesses that we no longer have access to
24 for purposes of pre-arrest delay? Perhaps they I re up
25 in Canada.
L COMMONWEALTH vs. WILLIAM H. COSBY, JR- 64
2 So wefre working on that now. I

J just want. to try and give myself as much time as I can
:t to make a complete argument. But I obviously defer to
5 the Court. I'11 get it done as fast as you want me
6 co.
7 THE COURT: ThirtY daYs. Next.
B MR. MCMONAGLE: WEITE A1SO,
9 Judge, going to be working on a Motion for Change of

10 Venue.
1l_ THE COURT: Of jurors or
T2 Iocat ion?
L3 MR. McMONAGLE: ProbabIY both.
14 And then the Court will decide which one, if atrY'
15 we I Il get.
16 THE COURT: !{here should we go?
t7 MR. I'IcMONAGLE: You want me to
1B tell you now?
1-9 THE COURT: Where would You
20 f ind. t,his is a case of national interest '

2t MR. McMONAGLE: Yes.
22 THE COURT: This isn't a
23 regional-type It would at least follow alongr

case.
24 the cases that have addressed this issue' In
25 Pennsylvania, a Philadelphia case of public interest
1 COMMONWEALTH vs. WTLLIAM H. COSBY, ,JR. 65
2 general ly where woul-d you go? Canrt go outside the

3 bounds of the Commonweal- t-h
I MR. McMONAGLE: No. And I

5 certainly was never going to file a motion that
6 requested that. I think what we'd like to do, what
7 werre trying to do with expert testimony is determine
8 where there would be'a big enough county where perhaps
9 the pool itself wouldn't have been saturated.
10 We I re concerned., quite f rankly,
l-1 about Montgomery County for one very important reason
L2 which werve previously argued, which is, unfortunately
13 and regretfully, while Mr. Cosby was awaiting and
T4 being investigated in this case, there was an
r_5 election.
15 And in that election Mr. Cosby
T7 for a significant news period was being referred to
18 before he was ever charged with a crime as a sexual
19 predator. Unfortunately, those references were made
20 by the nord District Attorney, then First Assistant

2t District At,torney's campaign.
22 We are trying to develop as much
23 as we can, and why I I ve asked f or the time on t.his j-s
24 to see just how much went out there.

25 THE COURT: Those pools the
t COMMONWEALTH vs. WILLIAM H. COSBY' JR. '66
2 only yourre saying a pool large enough seeinqr that

3 rire are the third largesL pool , ri9ht, this county?
4 MR. McMONAGLE: I take Your word
q f or that, .Tudge .
6 THE COURT: The onlY other two
7 would be Philadelphia and Allegheny. You're saying

I another pooI, either Philadelphia, Allegheny or
9 another large countY not
1n MR. McMONAGLE: Sure. We'11
11 have a big enough

t2 THE COURT: I understand. Look,
13 Itm not putting you to the test here, but again

14 MR. McMONAGLE: Irm haPPY to
15 answer your questions.
L6 THE2 -- I want to think
COURT
L-l about, it. I think r understand what you're saying.

18 MR. McMONAGLE: Yes.
L9 THE COURT: So how long for
20 that ?
2t MR. McMONAGLE : .Tudge, that is

22 requiring us to do a lot of due ditigence in terms of
23 Iooking at things like population, looking at the
24 pretrial publicity that occurred here. we I re trying
25 to accumulate aIl that happened during that campaign
EXHIBIT 1O
I}E THO COI'RT OF CONfiMOlY FI,PAS OF MO}T?GOMPRY CO['I![TY,
PS$$SYT"VA$IA
CKINfiINAL DIVISIO}I f'-'':
COMM*NWEALTH OF PENNSYLVANIA No.393?-'t6 :;

-;i
T
WILLIAfuI H. COSBY, JR.
t\)
(,rl
ORT}OR
, /n'L.k
AI{D ttOW, this i O' 'day of March, 2018, upon consideration cf the
Commonwealthr's "IMr:ticn to Introduce Svidence of 19 Priar 3ad Acts of the
Defendant," th€ Defendant's response thereto, the Commonr.vcatrth's oflers of
proof, argument of Counsel on }rlarch 5 and 5, 2018, the post hraring briefs
submitted by Counsel, and this Court's r:omprehensive review of Fa, R. E, 404
ib), reported appellate authority, an analysis of the proposed evidence under

lhe "common plan, scheme and design" and "absence af mistake" excepticns,
and a balancing of the probative value of the other acts evidence versus the
risk of unfair prejudice to the Defendant, it is hereby ORDEREII and
DECREED that the Commonwealth's Motion is GR.A,I{TED in part and
IISNIED, in part, subject to furthrr examination and evidentiary rullngs in the
context cf trial.
The Commonwealth shali be permitted to present evidence, pursuant tn
Pa" R. E. 404 {b}, regarding five prior bad acts of its choosing lrom CPBA 2-12
through CPBA 2-19. See, ilnm;nr:t"rw-q&llh v. trli*kx, 91 A.3d 47,55 {Pa. 201a}
{"Hjgkil"i {stating that "[trial ccurt] rvould have the authoriqy tc dictate ho',v
many cumulative witnesses may testify, br-rt it cannot dictate which of those
witnesses the Commonwealth may call to prove its caseu); Commonwealth v.
Hicks, 156 A.3d 1114 (Pa. 2OL7) (plurality) ("Hicks II"); Cqmmon:g"galtb U
Gordon, 652 A.zd317,324 (Pa. Super. L9941; Csmmsnpeeltb : Frank, 577

A.2d 609 (Pa. Super. 1990) {enumerating balancing test f,actors};
om:nrorgqslth v.j$npith,825 A,2d 1086 (Pa. Super. 1993); Commonwgalth y,
Donshu€, 549 A.2d 121 {Pa. 1988).
The balance of the CommonwealtJr's Motion is DEMED.
The Commonwealth shall identiff to the undersigned and to Defense
counsel which witnesses it intends to call by March 19, 2OlB.

BY THE COIIRT:
fI
STEVEN T. O1NIILL J.
Copies of t]lis order mailed on rtlrSf $'to the following:

Lane Vines, Esq.
Thomas A. Mesereau, Jr., Esq.
Kathleen Bliss, Esq.
Jason Hicks, Esq.
Becky S. James, Esq.
Kristen Gibbons Feden, Esq.
, Esq. {Court Administrator}
/j
PROOF OF SERVICE
I hereby certify that this 23'd day of October,2018, I have served the
attached Petition for Review, including its Exhibits, on the persons and on
the dates and manners set forth below, which satisfies the requirements of
Pa. R.A. P. 121 .
VIA PACFILE AND UNITED STATES POSTAL SERVICE

Kevin Steele, District Attorney
Montgomery County District Attorney's Office
Montgomery County Courthouse
4th Floor
P.O. Box 311
Norristown, PA 19404-031 1
VIA UNITED STATES POSTAL SERVICE

Judge Steven T. O'Neill
Montgomery County Court House
P.O. Box 311
Norristown, PA 19404-031 1
Brian W. Perry, Esquire

35

Bill Cosby Appeal Petition For Review - 007363

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Bill Cosby Appeal Petition For Review - 007363

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Received 10/23/2018 1:16:54 PM Superior Court Eastern District

Filed 10/23/2018 1:16:00 PM Superior Court Eastern District

IN THE SUPERIOR COURT OF PENNSYLVANIA

WILLIAM H. COSBY, JR., :

PETITION FOR REVIEW PURSUANT TO Pa.R.A.P. 1762(bX2)

The Petitioner, William H. Cosby, Jr. (the "Petitioner" or "Mr. Cosby"),

by and through his attorneys, Brian W. Perry and Kristen L. Weisenberger,

Pursuant to Pennsylvania Rule of Appellate Procedure 1762(b), from the

denying Mr. Cosby's request for bail post-sentencing and, in support

hereof, states as follows:

1. This Court has authority to hear this Petition pursuant to

September 25,2018, Mr. Cosby was sentenced to a term of incarceration

SVP/Sentencing Hearing dated September 25,2018, p. 120. Relevant

portions of the Notes of Sentencing Hearing are attached hereto at

131-133. The Order denying bail was entered on September 27,2018. A

On October 2,2018, pursuant to Pa. R. Crim. P.720(8) and 720(C), a

timely Post-Sentence Motion to Reconsider and Modify Sentence and for a

hear this Petition pursuant to Pa.R.A.P. 1762(b).

3. The Petitioner is William H. Cosby, Jr., who is currently

incarcerated at the State Correctional Institution at Phoenix.

by and through the District Attorney of Montgomery County.

DETERMINATION SOUGHT TO BE REVIEWED

5. Mr. Cosby seeks review of the determination and Order of

Judge Steven T. O'Neill of the Court of Common Pleas of Montgomery

the lower court immediately subsequent to sentencing. The lower court

hearing on September 25,2018. The Order denying bail, which was

6. In addressing Mr. Cosby's request for bail, the lower court

could quite possibly be a danger to the community." ld.

his contentious relationship with a material witness on the critical issue of

circumstances of which should have compelled Judge O'Neill's recusal

have been prosecuted was a clear abuse of discretion.

8. Additionally, there are other significant appellate issues that

should result in a reversal of the conviction. Specifically, the lower court

wrongly admitted deposition testimony Mr. Cosby gave pursuant to District

Attorney Castor's promise not to prosecute, allowed the prosecution to

proceed despite a prejudicial twelve-year delay in filing charges, and

allowed five women offered by the prosecution to testify regarding

uncharged conduct. These errors denied Mr. Cosby his constitutional

rights and warrant reversal of the conviction.

L Moreover, there is absolutely nothing in the record that would

blind, is a danger to the community.

10. On December 30,2015, Montgomery County District Attorney

purported conduct alleged to have occurred "on or about mid-January to

mid-February 2004" at a residence Mr. Cosby owns in Cheltenham,

Pennsylvania. The complainant had lodged the allegations against

the allegations and thereafter determined and promised, on behalf of the

Commonwealth, that Mr. Cosby would never be prosecuted for them.

purpose of compelling Mr. Cosby to testify in an anticipated deposition in

Amendment privilege against self-incrimination.

11. On December 30, 2015, bail was set in the amount of

based on the binding promise not to prosecute made by District Attorney

12. According to a sworn and notarized affidavit of Mr. Castor,

Judge O'Neill chose to assign this particular criminal case to himself.

Attached hereto as Exhibil"4'is the Affidavit of Bruce Castor. dated

questioned Mr. Castor and, in Mr. Castor's words, proceeded to treat

held for court.

14. On July 13,2016, a three-count Criminal lnformation was filed