DOCKET - Andrea Constand vs William H Cosby

SEALDC,CLOSED,LEAD,STANDARD
United States District Court
Eastern District of Pennsylvania (Philadelphia)
CIVIL DOCKET FOR CASE #: 2:05−cv−01099−ER
CONSTAND v. COSBY
Assigned to: HONORABLE EDUARDO C. ROBRENO
Cause: 28:1332 Diversity−Libel,Assault,Slander
Date Filed: 03/08/2005
Date Terminated: 11/08/2006
Jury Demand: Defendant
Nature of Suit: 320 P.I.: Assault Libel
&Slander
Jurisdiction: Diversity
Plaintiff
ANDREA CONSTAND represented by BEBE H. KIVITZ
JACOBS SINGER KIVITZ &HERMAN
LLC
1525 LOCUST ST 12TH FL
PHILADELPHIA, PA 19102
215−732−2656
Email: bkivitz@jskhlaw.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
ANN C. LEBOWITZ
200 SOUTH BROAD STREET
SUITE 600
215−893−4976
Fax: 215−790−0509
Email: acl@alebowitz.com
DOLORES M. TROIANI
TROIANI &GIBNEY LLP
131 LANCASTER AVE
DEVON, PA 19333
610−688−8400
Fax: MDL TERMINATED
Email: dmt@tglawoffice.com
V.
Defendant
WILLIAM H. COSBY, JR. represented by ANDREW D. SCHAU
COVINGTON &BURLING LLP
THE NEW YORK TIMES BLDG
620 EIGHTH AVE
NEW YORK, NY 10018
212−841−1007
Email: aschau@cov.com
LEAD ATTORNEY
PATRICK J. O'CONNOR
COZEN OCONNOR
1900 MARKET ST
215−665−2024
Fax: 215−665−3701
Email: poconnor@cozen.com
LEAD ATTORNEY
Case: 2:05-cv-01099 As of: 12/04/2014 03:21 PM EST 1 of 10

GEORGE M. GOWEN , III
COZEN O'CONNOR
1900 MARKET STREET
215−665−2000
Fax: 215−665−2013
Email: ggowen@cozen.com
V.
Respondent
NATIONAL INQUIRER represented by JENNIFER B. JORDAN
MORGAN LEWIS &BOCKIUS LLP
1701 MARKET ST
PHILADELPHIA, PA 19103−2921
215−963−5000
Email: jjordan@morganlewis.com
LEAD ATTORNEY
PAUL D. WELLER
MORGAN LEWIS &BOCKIUS LLP
1701 MARKET ST
215−963−5530
Email: pweller@morganlewis.com
LEAD ATTORNEY
V.
Movant
THE ASSOCIATED PRESS
TERMINATED: 01/13/2006
represented by GAYLE CHATILO SPROUL
LEVINE SULLIVAN KOCH &SCHULZ
LLP
1760 MARKET ST SUITE 1001
215−988−9778
Fax: 215−988−9750
Email: gsproul@lskslaw.com
LEAD ATTORNEY
MICHAEL BERRY
LEVINE SULLIVAN KOCH &SCHULZ
LLP
1760 MARKET ST STE 1001
215−988−9778
Email: mberry@lskslaw.com
Movant
JANE DOE WITNESSES represented by B. JOYCE THOMPSON DALE
204 SOUTH AVENUE
MEDIA, PA 19063−3121
LEAD ATTORNEY

Date Filed # Docket Text
03/08/2005 1 COMPLAINT against WILLIAM H. COSBY, JR ( Filing fee $ 250 receipt number
914383.), filed by ANDREA CONSTAND.(ss, ) (Entered: 03/08/2005)
03/08/2005 Summons Issued, One original mailed as to WILLIAM H. COSBY, JR. Forwarded
To: Counsel on 3/8/05 (ss, ) (Entered: 03/08/2005)
03/08/2005 DEMAND for Trial by Jury by ANDREA CONSTAND. (ss, ) (Entered:
03/08/2005)
03/08/2005 2 NOTICE of Appearance by DOLORES M. TROIANI on behalf of ANDREA
CONSTAND (TROIANI, DOLORES) (Entered: 03/08/2005)
03/23/2005 3 WAIVER OF SERVICE Returned Executed by ANDREA CONSTAND.
WILLIAM H. COSBY, JR waiver sent on 3/9/2005, answer due 5/9/2005. (afm, )
(as, ). (Entered: 03/23/2005)
03/31/2005 4 NOTICE of Appearance by GEORGE M. GOWEN, III on behalf of WILLIAM H.
COSBY, JR with Certificate of Service (GOWEN, GEORGE) (DOCKETED IN
ERROR ATTORNEY DELETED) Modified on 4/4/2005 (afm, ). (Entered:
03/31/2005)
04/04/2005 5 NOTICE of Appearance by PATRICK J. O'CONNOR on behalf of WILLIAM H.
COSBY, JR., Certificate of Service. (O'CONNOR, PATRICK) Modified on
4/5/2005 (np). (Entered: 04/04/2005)
04/04/2005 6 NOTICE of Appearance by GEORGE M. GOWEN, III on behalf of WILLIAM H.
COSBY, JR (GOWEN, GEORGE) (Entered: 04/04/2005)
04/06/2005 7 Report Of Plaintiff following Rule 26 Conference of Parties by ANDREA
CONSTAND, Certificate of Service. (Attachments: # 1 Preliminary Scheduling
Order) (KIVITZ, BEBE) Modified on 4/8/2005 (np). (Entered: 04/06/2005)
04/12/2005 8 NOTICE of Hearing: PRETRIAL CONFERENCE SET FOR 5/3/2005 12:30 PM
IN JUDGE'S CHAMBERS, Room 11614, BEFORE HONORABLE EDUARDO
C. ROBRENO. (to, ) (Entered: 04/12/2005)
04/12/2005 9 MOTION FOR ADMISSION PRO HAC VICE OF ANDREW D. SCHAU,
ESQUIRE FILED BY WILLIAM H. COSBY, JR.,APPLICATION,
CERTIFICATE OF SERVICE.(afm, ) (Entered: 04/13/2005)
04/15/2005 10 MOTION to Compel Plaintiff's Initial Disclosures filed by WILLIAM H. COSBY,
JR.Memorandum. (Attachments: # 1 Text of Proposed Order # 2
Memorandum)(O'CONNOR, PATRICK) (Entered: 04/15/2005)
04/18/2005 11 ORDER THAT DEFENDANT'S MOTION FOR LIMITED ADMISSION IS
GRANTED.. SIGNED BY JUDGE EDUARDO C. ROBRENO ON
4/18/05.4/18/05 ENTERED AND COPIES MAILED AND FAXED. (afm, ) (as, ).
(Entered: 04/18/2005)
04/19/2005 12 RESPONSE in Opposition re 10 MOTION to Compel Plaintiff's Initial Disclosures
, Memorandum of Law, Certificate of Service filed by ANDREA CONSTAND.
(KIVITZ, BEBE) (Entered: 04/19/2005)
04/19/2005 13 MOTION for Protective Order to Protect the Identity Rule 415 Jane Doe Witnesses
filed by ANDREA CONSTAND.Memorandum of Law, Certificate of
Service.(KIVITZ, BEBE) (Entered: 04/19/2005)
04/22/2005 14 MOTION for Leave to File Reply Memorandum filed by WILLIAM H. COSBY,
JR.. (Attachments: # 1 Exhibit A# 2 Exhibit B)(O'CONNOR, PATRICK) (Entered:
04/22/2005)
04/22/2005 15 ORDER THAT THE INITIAL PRETRIAL CONFERENCE IS RESCHEDULED
FOR 5/11/2005 AT 12:00 PM.. SIGNED BY JUDGE EDUARDO C. ROBRENO
ON 4/20/05. 4/22/05 ENTERED AND COPIES MAILED AND E−MAILED. XC
BY CHAMBERS 4/22/05.(afm, ) (Entered: 04/22/2005)

04/25/2005 16 RESPONSE to defendant's MOTION FOR LEAV TO FILE REPLY
MEMORANDUM IN SUPPORT OF HIS MOTION TO COMPEL PLAINTIFF'S
INITIAL DISCLOSURES filed by ANDREA CONSTAND, CERTIFICATE OF
SERVICE. (afm, ) (Entered: 04/25/2005)
04/27/2005 17 MOTION for Protective Order filed by WILLIAM H. COSBY, JR.Memorandum.
(Attachments: # 1 Text of Proposed Order # 2 Memorandum# 3
Exhibits)(O'CONNOR, PATRICK) (Entered: 04/27/2005)
04/27/2005 18 Memorandum in Support of 13 MOTION for Protective Order to Protect the
Identity Rule 415 Jane Doe Witnesses and in Opposition to PLAINTIFF'S
MOTION TO PRECT THE IDENTITY OF RULE 415 JANE DOE WITNESSES
FOR PROTECTIVE ORDER filed by WILLIAM H. COSBY, JR. (Attachments: #
1 Exhibits) (O'CONNOR, PATRICK) Modified on 4/29/2005 (np). (Entered:
04/27/2005)
05/09/2005 19 MOTION TO COMPEL DISCOVERY RESPONSES AND TO STRIKE
DEFENDANTS' GENERAL OBJECTIONS TO PLAINTIFF'S FIRST SET OF
INTERROGATORIES FILED BY ANDREA CONSTAND,MEMORANDUM,
CERTIFICATE OF SERVICE.(afm, ) (Entered: 05/09/2005)
05/09/2005 20 RESPONSE to defendant's MOTION FOR PROTECTIVE ORDER filed by
ANDREA CONSTAND, MEMORANDUM, CERTIFICATE OF SERVICE. (afm,
) (Entered: 05/09/2005)
05/09/2005 21 ANSWER to Complaint by WILLIAM H. COSBY, JR.(O'CONNOR, PATRICK)
(Entered: 05/09/2005)
05/10/2005 22 MOTION for Leave to File Reply Brief in Support of Motion for Protective Order
filed by WILLIAM H. COSBY, JR.Brief. (Attachments: # 1 Reply
Brief)(O'CONNOR, PATRICK) (Entered: 05/10/2005)
05/11/2005 23 Response re 21 Answer to Complaint to Affirmative Defenses by ANDREA
CONSTAND, Certificate of Service. (KIVITZ, BEBE) Modified on 5/13/2005
(np). (Entered: 05/11/2005)
05/12/2005 24 RESPONSE in Opposition re 22 MOTION for Leave to File Reply Brief in Support
of Motion for Protective Order and Memorandum of Law filed by ANDREA
CONSTAND. (KIVITZ, BEBE) (Entered: 05/12/2005)
05/13/2005 25 TRANSCRIPT of Proceedings held on 5/11/05 before Judge HONORABLE
EDUARDO C. ROBRENO. Court Reporter: ESR. (afm, ) (Entered: 05/16/2005)
05/13/2005 26 MOTION TO INTERVENE AND TO FILE OPPOSITION TO DEFENDANT'S
MOTION FOR PROTECTIVE ORDER FILED BY THE ASSOCIATED
PRESS,MEMORANDUM, CERTIFICATE OF SERVICE. (Attachments: # 1
MEMO# 2 COS# 3 EXHIBIT A# 4 EXHIBIT B# 5 EXHIBIT C)(afm, ) (Entered:
05/16/2005)
05/24/2005 27 RESPONSE in Support re 26 MOTION to Intervene of the Associated Press filed
by ANDREA CONSTAND, Memorandum, Certificate of Service. (KIVITZ,
BEBE) Modified on 5/26/2005 (md, ). (Entered: 05/24/2005)
05/27/2005 28 RESPONSE in Opposition re 26 MOTION to Intervene filed by WILLIAM H.
COSBY, JR. (O'CONNOR, PATRICK) (Entered: 05/27/2005)
06/02/2005 29 MEMORANDUM AND ORDER THAT DEFENDANT'S MOTION TO
COMPEL INITIAL DISCLOSURES IS GRANTED; PLAINTIFF'S MOTION
FOR A PROTECTIVE ORDER TO PROTECT THE IDENTITY OF HER RULE
415 JANE DOE WITNESS IS DENIED; DEFENDANT'S MOTION FOR A
PROTECTIVE ORDER IS DENIED; DEFENDANT'S MOTION FOR LEAVE
TO FILE A REPLY MEMORANDUM IN SUPPORT OF MOTION TO COMPEL
PLAINTIFF'S INITIAL DISCLOSURE IS GRANTED; DEFENDANT'S
MOTION FOR LEAVE TO FILE A REPLY MEMORDEUM IN SUPPORT OF
MOTION FOR PROTECTIVE ORDER IS GRANTED; AND THE
ASSOCIATED PRESS'S MOTION TO INTERVENE IS DENIED AS MOOT..
SIGNED BY JUDGE EDUARDO C. ROBRENO ON 6/2/05.6/2/05 ENTERED
AND COPIES MAILED AND E−MAILED. (afm, ) (Entered: 06/02/2005)

06/02/2005 30 CASE MANAGEMENT ORDER 1 THAT PENNSYLVANIA RULE OF
PROFESSIONAL CONDUCT 3.6 SHALL BE ADOPTED GOVERNING THE
CONDUCT OF COUNSEL, THE VIOLATIONS OF THIS ORDER SHALL BE
SUBJECT TO SANCTIONS, ETC..... SIGNED BY JUDGE EDUARDO C.
ROBRENO ON 6/2/05. 6/3/05 ENTERED AND COPIES MAILED AND
E−MAILED.(afm, ) (Entered: 06/03/2005)
06/03/2005 31 ORDER THAT A CONFERENCE WILL BE HELD ON 6/22/2005 AT 02:00 PM
IN COURTROOM 11A.. SIGNED BY JUDGE EDUARDO C. ROBRENO ON
6/2/05. 6/3/05 ENTERED AND COPIES MAILED AND E−MAILED.(afm, )
(Entered: 06/03/2005)
06/10/2005 32 MOTION for Extension of Time to File Protective Order as to Jane Doe No. 8
filed by ANDREA CONSTAND.Certificate of Service.(KIVITZ, BEBE) (Entered:
06/10/2005)
06/13/2005 33 MOTION TO PROTECT DISCLOSURE OF THEIR NAMES OUTSIDE OF
THIS LITIGATION FILED BY JANE DOE WITNESSES,MEMORANDUM,
CERTIFICATE OF SERVICE..(afm, ) (Entered: 06/13/2005)
06/14/2005 34 ORDER THAT A HEARING TO ADDRESS PLAINTIFF'S MOTION TO
EXTEND SUSPENSION PERIOD OF COURT'S ORDER REGARDING THE
IDENTITY OF JANE DOE WITNESSES AND TO PROTECT DISCLOSURE
OF THEIR NAMES WILL BE HELD ON 6/22/05 AT 2:00P.M. IN
COURTROOM 11A. SIGNED BY JUDGE EDUARDO C. ROBRENO ON
6/14/05. 6/15/05 ENTERED AND COPIES E−MAILED. FAXED BY
CHAMBERS 6/14/05.(afm, ) (Entered: 06/15/2005)
06/21/2005 35 RESPONSE to Motion re 32 MOTION for Extension of Time to File Protective
Order as to Jane Doe No. 8, 33 MOTION for Protective Order by Jane Doe
Witnesses filed by WILLIAM H. COSBY, JR. (Attachments: # 1 Declaration of
Patrick J.O'Connor)(O'CONNOR, PATRICK) (Entered: 06/21/2005)
06/24/2005 36 ORDER THAT THE COURT'S MEMORANDUM DATED 6/2/05 IS
AMENDED SO THAT THE FOLLOWING SENTENCE ON PAGE 12 IS
DELETED AND INSERTED IN LIEU THEREOF SHALL BE THE
FOLLOWING LANGUAGE: RULE 3.6 OF THE PENNSYLVANIA RULES OF
PROFESSIONAL CONDUCT, IN ITS ORIGINAL INCARNATION,
INCLUDING WHAT IS NOW COMMENT 5, ETC....... SIGNED BY JUDGE
EDUARDO C. ROBRENO ON 6/24/05. 6/24/05 ENTERED AND COPIES
MAILED AND E−MAILED.(afm, ) (Entered: 06/24/2005)
07/07/2005 37 ORDER THAT THE MOTION OF JANE DOE WITNESSES TO PROTECT
DISCLOSURE OF THEIR NAMES OUTSIDE OF THIS LITIGATION IS
DENIED; AND PLAINTIFF'S MOTION TO EXTEND THE SUSPENSION
PERIOD OF THE COURT'S ORDER REGARDING THE IDENTITY OF JANE
DOE WITNESSES AS TO JANE DOE NO.8 IS DENIED. SIGNED BY JUDGE
MAILED AND E−MAILED. (fdc) (Entered: 07/07/2005)
07/11/2005 38 ORDER THAT PLAINTIFF'S MOTION TO COMPEL AND STRIKE
OBJECTIONS IS DENIED WITHOUT PREJUDICE; THE PARTIES SHALL
SUBMIT TO THE COURT A F.R.C.P. 26(f) REPORT BY 8/8/05.. SIGNED BY
JUDGE EDUARDO C. ROBRENO ON 7/8/05.7/12/05 ENTERED AND COPIES
MAILED AND E−MAILED. (afm, ) (Entered: 07/12/2005)
07/22/2005 39 TRANSCRIPT of Hearing held on 6/22/05 before Judge Robreno. (fdc) (Entered:
07/22/2005)
08/18/2005 40 SCHEDULING ORDER THAT PLAINTIFF SHALL FILE AN AMENDED
COMPLAINT ASSERTING THE CITIZENSHIP OF THE PARTIES BY 8/29/05;
PLAINTIFF SHALL JOIN ANY ADDITIONAL DEFENDANTS BY 11/17/05;
ALL DISCOVERY SHALL BE COMPLETED BY 6/30/06; ANY MOTIONS
FOR SUMMARY JUDGMENT SHALL BE FILED BY 6/30/06; PRETRIAL
MEMORANDA AND AMY MOTIONS IN LIMINE SHALL BE FILED BY
9/15/06; AND THE CASE SHALL BE PLACED IN THE TRIAL POOL ON
10/1/06, ETC.SIGNED BY JUDGE EDUARDO C. ROBRENO ON 8/17/05.
8/19/05 ENTERED AND COPIES MAILED AND FAXED.(cdd, ) Additional

attachment(s) added on 8/23/2005 (afm, ). (Entered: 08/19/2005)
08/24/2005 41 AMENDED COMPLAINT with JURY DEMAND against WILLIAM H. COSBY,
JR , filed by ANDREA CONSTAND, CERTIFICATE OF SERVICE.(afm, )
(Entered: 08/25/2005)
09/08/2005 42 ANSWER to Amended Complaint by WILLIAM H. COSBY, JR.(O'CONNOR,
PATRICK) (Entered: 09/08/2005)
09/12/2005 43 ORDER THAT A DISCOVERY CONFERENCE WILL BE HELD ON 9/23/2005
AT 09:00 AM IN COURTROOM 11A.. SIGNED BY JUDGE EDUARDO C.
E−MAILED.(afm, ) Additional attachment(s) added on 9/12/2005 (afm, ).
(Entered: 09/12/2005)
09/21/2005 44 ORDER THAT THE DISCOVERY CONFERENCE SCHEDULED FOR 9/23/05
IS CONTINUED TO 9/26/05 AT 10:30 A.M. IN COURTROOM 11A.. SIGNED
BY JUDGE EDUARDO C. ROBRENO ON 9/21/05. 9/21/05 ENTERED AND
COPIES MAILED AND E−MAILED.(afm, ) (Entered: 09/21/2005)
09/27/2005 45 ORDER THAT AFTER A HEARING DISCUSSING DISCOVERY MATTERS
RAISED IN PLAINTIFF'S LETTERS DATED8/25/05 AND 9/8/05 AND
DEFENDANT'S LETTERS DATED 9/2/05 AND9/12/05 TO THE COURT, THE
MATTER HAVE BEEN RESOLVED IN ACCORDANCE WITH THE COURT'S
RULING ON RECORD.. SIGNED BY JUDGE EDUARDO C. ROBRENO ON
9/26/05. 9/27/05 ENTERED AND COPIES MAILED AND E−MAILED.(afm, )
(Entered: 09/27/2005)
11/03/2005 46 ORDER THAT A TELEPHONE STATUS CONFERENCE WILL BE HELD ON
11/4/2005 AT 09:00 AM, COUNSEL FOR PLAINTIFF AND DEFENDANT
SHALL CALL CHAMBERS.. SIGNED BY JUDGE EDUARDO C. ROBRENO
ON 11/2/05. 11/4/05 ENTERED AND COPIES MAILED AND E−MAILED.(afm,
) (Entered: 11/04/2005)
11/04/2005 47 CASE MANAGEMENT ORDER THAT EACH PARTY SHALL FILE ANY
REQUEST TO COMPEL BY 11/21/05, RESPONSES THERETO DUE 12/6/05.
ANY PARTY OPPOSING THE LIFTING OF THE SEAL SHALL SHOW
CAUSE WHY THE SEAL SHOULD NOT BE LIFTED BY 12/21/05. ANY
PARTY SUPPORTING THE LIFTING OF THE SEAL SHALL FILE A
MEMORANDUM BY 1/9/06. IT IS FURTHER ORDERED THAT ALL
REQUESTS FOR DISCOVERY, RESPONSES AND LEGAL MEMORANDA
FILED PURSUANT TO THIS ORDER SHALL BE FILED UNDER SEAL.
SIGNED BY JUDGE EDUARDO C. ROBRENO ON 11/4/05. 11/4/05 ENTERED
AND COPIES MAILED, E−MAILED AND FAXED BY CHAMBERS.(stb, )
(Entered: 11/04/2005)
11/21/2005 48 MOTION FOR SANCTIONS CONCERNING CONDUCT OF DEFENDANT AT
DEPOSITION AND MEMORANDUM OF LAW FILED BY ANDREA
CONSTAND (FILED UNDER SEAL)..(afm, ) (Entered: 11/21/2005)
11/21/2005 49 DEFENDANTS' REQUEST TO COMPEL AND MEMO CONCERNING
OVERARCHING ISSUES by WILLIAM H. COSBY, JR. (FILED UNDER
SEAL) (afm, ) (Entered: 11/22/2005)
11/21/2005 50 MOTION TO COMPEL DISCOVERY FILED BY ANDREA
CONSTAND,CERTIFICATE OF SERVICE.(afm, ) (FILED UNDER SEAL)
(Entered: 11/22/2005)
11/23/2005 51 Second MOTION to Intervene and to Unseal filed by THE ASSOCIATED
PRESS.Memorandum, Certificate of Service, Proposed Order. (Attachments: # 1
Memorandum of Law in Support of Motion to Intervene and Unseal# 2 Text of
Proposed Order Proposed Order# 3 Certificate of Service)(SPROUL, GAYLE)
(Entered: 11/23/2005)
11/28/2005 52 MOTION TO STRIKE PLAINTIFF'S MOTION CONCERNING CONDUCT OF
DEFENDANT'S DEPOSITION AND MOTION FOR SANCTIONS FILED BY
WILLIAM H. COSBY, JR.,MEMORANDUM, CERTIFICATE OF SERVICE
(FILED UNDER SEAL).(afm, ) (Entered: 11/28/2005)

12/02/2005 53 ORDER THE ORIGINAL TRANSCRIPT OF THE THELEPHONE
CONFERENCE HELD ON 11/4/05 SHALL BE FILED OF RECORD EXCEPT
LINES 9−10 OF PAGE 8 AND LINES 1−2 OF PAGE 9 SHALL BE
REDACTED; PAGES 8 AND 9 UNREDACTED SHALL BE FILED UNDER
SEAL; LEAVE IS GRANTED TO COUNSEL TO RECIEVE THE
UNREDACTED PARTS OF ORIGINAL TRANSCRIPT FILED UNDER SEAL..
AND COPIES MAILED AND E−MAILED.(afm, ) (Entered: 12/05/2005)
12/02/2005 54 REDACTED TRANSCRIPT of Proceedings held on 11/4/05 before Judge
HONORABLE EDUARDO C. ROBRENO. Court Reporter: ESR. (afm, )
(Entered: 12/05/2005)
12/02/2005 55 PAGES 8 AND 9 OF THE REDACTED TRANSCRIPT OF HEARING ON
TELEPHONE CONFERENCE DATED 11/4/05. (FILED UNDER SEAL) (afm, )
(Entered: 12/05/2005)
12/02/2005 56 ORDER THAT THE PARTIES SHALL FILE A RESPONSE TO THE MOTION
TO INTERVENE AND LIFT THE SEAL BY 12/19/2005. A HEARING IS SET
FOR 1/9/2006 AT 10:00 A.M. IN COURTROOM 11−A BEFORE HONORABLE
EDUARDO C. ROBRENO. SIGNED BY JUDGE EDUARDO C. ROBRENO ON
12/2/05. 12/5/05 ENTERED AND COPIES MAILED AND E−MAILED. (jpd)
(Entered: 12/05/2005)
12/05/2005 57 PLAINTIFF'S REPLY TO DEFENDANT'S REQUESTS TO COMPEL AND
MEMORANDUM CONCERNING OVERARCHING ISSUES by ANDREA
CONSTAND. (FILED UNDER SEAL) (afm, ) (Entered: 12/05/2005)
12/05/2005 59 RESPONSE TO THE MOTION OF THE ASSOCIATED PRESS TO
INTERVENE AND TO LIFT SEAL FILED BY ANDREA CONSTAND,
MEMORANDUM, CERTIFICATE OF SERVICE. (Attachments: # 1
MEMO)(afm, ) (Entered: 12/08/2005)
12/06/2005 58 RESPONSE TO PLAINTIFF'S MOTION TO COMPEL AND MEMORANDUM
CONCERNING OVERARCHING ISSUES filed by WILLIAM H. COSBY, JR.,
CERTIFICATE OF SERVICE. (afm, ) (FILED UNDER SEAL) (Entered:
12/07/2005)
12/08/2005 60 RESPONSE TO DEFENDANT'S MOTION TO STRIKE PLAINTIFF'S MOTION
CONCERNING CONDUCT OF DEFENDANT'S DEPOSITION AND MOTION
FOR SANCTIONS AND MEMORANDUM OF LAW FILE BY ANDREA
CONSTAND (FILE UNDER SEAL). (afm, ) (Entered: 12/08/2005)
12/08/2005 61 MOTION TO COMPEL THE NATIONAL ENQUIRER'S COMPLIANCE WITH
SUBPOENA FOR DOCUMENT AND REQUEST FOR EXPEDITED
RESOLUTION AND MEMORANDUM OF LAW FILED BY ANDREA
CONSTAND (FILED UNDER SEAL)..(afm, ) (Entered: 12/08/2005)
12/19/2005 62 RESPONSE in Opposition re 51 Second MOTION to Intervene and to Unseal filed
by WILLIAM H. COSBY, JR. (O'CONNOR, PATRICK) (Entered: 12/19/2005)
12/21/2005 63 MEMORANDUM OF LAW IN PARTIAL OPPOSITION TO THE LIFTING OF
THE SEAL ESTABLISHED BY CASE MANAGEMENT ORDER 2 by
WILLIAM H. COSBY, JR. (FILED UNDER SEAL) (afm, ) (Entered: 12/22/2005)
12/22/2005 64 DEFENDANT'S BRIEF IN OPPOSITION TO PLAINTIFF'S MOTION TO
COMPEL THE NATIONAL ENQUIRER'S COMPLIANCE WITH SUBPOENA
FOR DOCUMENT AND REQUEST FOR EXPEDITED RESOLUTION filed by
WILLIAM H. COSBY, JR. (FILED UNDER SEAL) (afm, ) Modified on
12/28/2005 (cdd, ). (Entered: 12/23/2005)
12/27/2005 65 MEMORANDUM OF LAW IN OPPOSITION TO PLAINTIFF'S MOTION TO
COMPEL filed by NATIONAL INQUIRER (FILED UNDER SEAL). (afm, )
(Entered: 01/03/2006)
01/04/2006 66 MOTION FOR LEAVE TO FILE REPLY MEMORANDUM OF LAW IN
RESPONSE TO DEFENDANT'S MEMO IN OPPOSITION TO PLAINTIFF'S
MOTION TO COMPEL THE NATIONAL ENQUIRER'S COMPLIANCE WITH

SUBPOENA FOR DOCUMENTS ANDREA CONSTAND, CERTIFICATE OF
SERVICE (FILED UNDER SEAL)..(afm, ) (Entered: 01/04/2006)
01/04/2006 67 MEMORANDUM OF LAW IN SUPPORT OF THE LIFTING OF THE SEAL
ESTABLISHED BY CASE MANAGEMENT ORDER 2 filed by ANDREA
CONSTAND, CERTIFICATE OF SERVICE (FILED UNDER SEAL). (afm, )
(Entered: 01/04/2006)
01/05/2006 68 MOTION FOR LEAVE TO FILE PLAINTIFF' SREPLY TO THE NATIONAL
ENQUIRER'S MEMORANDUM OF LAW IN OPPOSITION TO PLAINTIFF'W
MOTION TO COMPEL FILED BY ANDREA CONSTAND, CERTIFICATE OF
SERVICE (FILED UNDER SEAL)..(afm, ) (Entered: 01/05/2006)
01/05/2006 69 ORDER THAT A HEARING ON 1/9/2006 AT 10:00 AM IN COURTROOM 11A
WILL ADDRESS FOLLOWING MOTIONS FOR SANCTIONS #48, COMPEL
DISCOVERY #50, TO STRIKE #52, ASSOCIATED'S MOTION TO
INTERVENE #51, MOTION TO COMPEL NATIONAL #61.. SIGNED BY
JUDGE EDUARDO C. ROBRENO ON 1/4/06. 1/5/06 ENTERED. COPIES
FAXED BY CHAMBERS 1/5/06.(afm, ) (as, ). (Entered: 01/05/2006)
01/06/2006 70 NOTICE of Appearance by MICHAEL BERRY on behalf of THE ASSOCIATED
PRESS with Certificate of Service (BERRY, MICHAEL) (Entered: 01/06/2006)
01/10/2006 71 TRANSCRIPT of Proceedings held on 9/26/05 before Judge ROBRENO. Court
Reporter: J. MATKOWSKI. HEARING (jl, ) (Entered: 01/10/2006)
01/13/2006 72 MEMORANDUM AND ORDER THAT THE MOVANT ASSOCIATED
PRESS'S MOTION TO INTERVENE IS DENIED WITHOUT PREJUDICE..
AND COPIES MAILED AND E−MAILED. FAXED BY CHAMBERS 1/13/06.
(afm, ) (Entered: 01/13/2006)
01/13/2006 73 TRANSCRIPT of Proceedings held on 1/9/06 before Judge ROBRENO. Court
Reporter: JOSEPH MATKOWSKI. HEARING (jl, ) (Entered: 01/13/2006)
01/16/2006 74 MOTION for Leave to File Reply Brief in Support of Partial Opposition to the
Lifting of the Seal Established by Case Management Order 2 filed by WILLIAM
H. COSBY, JR.. (Attachments: # 1 Proposed Reply Brief)(O'CONNOR,
01/19/2006 75 ORDER THAT PLAINTIFF'S MOTION FOR LEAVE TO FILE A REPLY
BRIEF IN RESPONSE TO DEFENDANT'S MEMORANDUM IN OPPOSITION
TO PLAINTIFF'S MOTION TO COMPEL THE NATIONAL INQUIRER IS
GRANTED; PLAINTIFF'S MOTION FOR LEAVE TO FILE A REPLY BRIEF
IN RESPONSE TO NATIONAL INQUIRER'S MEMORANDUM IN
OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL THE NATIONAL
INQUIRER IS GRANTED; DEFENDANT'S MOTION FOR LEAVE TO FILE
REPLY BRIEF IN SUPPORT OF PARTIAL OPPOSITION TO THE LIFTING
OF THE SEAL IS GRANTED IN PART, DENIED IN PART AS MOOT..
01/31/2006 76 MEMORANDUM AND ORDER THAT PLAINTIFF'S MOTION TO COMPEL
IS GRANTED IN PART AND DENIED IN PART, ETC. PLAINTIFF'S MOTION
TO COMPEL THE NATIONAL ENQUIRER IS DENIED WITHOUT
PREJUDICE. SIGNED BY JUDGE EDUARDO C. ROBRENO ON 01/31/06.
(Attachments: # 1 Order)01/31/06 ENTERED AND COPIES MAILED AND
E−MAILED. (ac, ) (Entered: 01/31/2006)
02/28/2006 77 MOTION to Consolidate Cases Motion of Plaintiff Andrea Constand To
Consolidate along with Memorandum Of Law In Support Of Plaintiff's Motion to
Consolidate filed by ANDREA CONSTAND.Memorandum and Certificate of
Service. (Attachments: # 1)(TROIANI, DOLORES) (Entered: 02/28/2006)
03/14/2006 78 RESPONSE to Motion re 77 MOTION to Consolidate Cases Motion of Plaintiff
Andrea Constand To Consolidate along with Memorandum Of Law In Support Of
Plaintiff's Motion to Consolidate filed by WILLIAM H. COSBY, JR.
(O'CONNOR, PATRICK) (Entered: 03/14/2006)

04/12/2006 79 MOTION to Issue International Letters of Request filed by WILLIAM H. COSBY,
JR.Memorandum. (Attachments: # 1 Memorandum# 2 Text of Proposed Order # 3
Exhibit A# 4 Exhibit B# 5 Exhibit C# 6 Exhibit D# 7 Exhibit E# 8 Exhibit F# 9
Exhibit G# 10 Exhibit H# 11 Exhibit I# 12 Exhibit J# 13 Exhibit K)(O'CONNOR,
04/26/2006 80 RESPONSE TO DEFENDANT'S MOTION FOR THE ISSUANCE OF
INTERNATIONAL LETTERS OF REQUEST filed by ANDREA CONSTAND,
CERTIFICATE OF SERVICE. (afm, ) Additional attachment(s) added on 5/1/2006
(afm, ). (Entered: 04/26/2006)
05/02/2006 81 MOTION for Leave to File Reply Brief in Support of His Motion for the Issuance
of International Letters of Request filed by WILLIAM H. COSBY, JR.Brief.
(Attachments: # 1 Reply Brief)(O'CONNOR, PATRICK) (Entered: 05/02/2006)
05/15/2006 82 ORDER THAT A HEARING ON PLAINTIFF'S MOTION FOR SANCTIONS,
TO CONSOLIDATE AND DEFENDANT'S MOTIONS TO STRIKE AND FOR
INTERNATIONAL LETTER OF REQUEST WILL BE HELD ON 6/9/2006 AT
09:00 AM IN COURTROOM 11A.. SIGNED BY JUDGE EDUARDO C.
E−MAILED.(afm, ) (Entered: 05/16/2006)
05/22/2006 83 MOTION TO COMPEL SPECIFIC RESPONSES AND TO STRIKE
OBJECTIONS TO PLAINTIFF'S SECOND SET OF INTERROGATORIES
FILED BY ANDREA CONSTAND,CERTIFICATE OF SERVICE..(afm, ) (as, ).
(Entered: 05/23/2006)
05/24/2006 84 ORDER THAT PLAINTIFF'S MOTION TO COMPEL SPECIFIC RESPONSES
SHALL BE ADDRESSED AT THE HEARING ON 6/9/06; DEFENDANT
SHALL FILE A RESPONSE TO PLAINTIFF'S MOTION COMPEL BY 6/7/06..
AND COPIES MAILED AND E−MAILED.(afm, ) (Entered: 05/24/2006)
05/24/2006 85 MOTION TO COMPEL SPECIFIC RESPONSES AND TO STRIKE
OBJECTIONS TO PLAINTIFF'S SECOND SET OF INTERROGATORIES
FILED BY ANDREA CONSTAND,CERTIFICATE OF SERVICE.(afm, )
(Entered: 05/24/2006)
06/06/2006 86 ORDER THAT THE REQUEST TO CONTINUE MOTION HEARING IS
DENIED; HEARING WILL BEGIN AT 8:30 A.M.. SIGNED BY JUDGE
MAILED. FAXED BY CHAMBERS 6/5/06(afm, ) (as, ). (Entered: 06/06/2006)
06/07/2006 87 RESPONSE in Opposition re 83 MOTION to Compel, 85 MOTION to Compel
Specific Responses and to Strike Objections to Plaintiff's Second Set of
Interrogatories filed by WILLIAM H. COSBY, JR. (Attachments: # 1 Exhibit A
and B)(O'CONNOR, PATRICK) (Entered: 06/07/2006)
06/08/2006 88 NOTICE of Appearance by ANN C. LEBOWITZ on behalf of ANDREA
CONSTAND with Certificate of Service (LEBOWITZ, ANN) (Entered:
06/08/2006)
06/09/2006 89 ORDER THAT PLAINTIFF'S MOTION FOR SANCTIONS IS DENIED AS
MOOT; DEFENDANT'S MOTION TO STRIKE IS DENIED AS MOOT;
PLAINTIFF'S MOTION TO CONSOLIDATE IS DENIED AS MOOT, ETC....
06/20/2006 90 MOTION for Extension of Time to File Answer filed by NATIONAL
INQUIRER.Certificate of Service.(JORDAN, JENNIFER) (Entered: 06/20/2006)
06/21/2006 91 STIPULATION AND ORDER THAT NATIONAL ENQUIRER'S MOTION FOR
AN EXTENSION OF TIME TO FILE AN ANSWER IS GRANTED. THE
NATIONAL ENQUIRER SHALL HAVE UNTIL 7/7/06 TO FILE AN ANSWER
TO THE COMPLAINT. SIGNED BY JUDGE EDUARDO C. ROBRENO ON
6/20/06. 6/21/06 ENTERED AND COPIES MAILED.(fdc) (as, ). (Entered:
06/21/2006)

06/23/2006 92 ANSWER to Complaint with Jury Demand and Certificate of Service (Complaint
filed in Civil Action No. 06−483 and consolidated for pretrial purposes with Civil
Action 05−1099) by MARTIN D. SINGER.(GELLMAN, NANCY) (Entered:
06/23/2006)
07/07/2006 93 ANSWER to Complaint with Certificate of Service by NATIONAL
INQUIRER.(JORDAN, JENNIFER) (Entered: 07/07/2006)
07/13/2006 94 STIPULATION OF CONFIDENTIALITY. SIGNED BY JUDGE EDUARDO C.
ROBRENO ON 7/13/06. 7/14/06 ENTERED AND COPIES MAILED. (jpd) (as, ).
(Entered: 07/14/2006)
07/20/2006 95 Response to National Enquirer's Affirmative Defenses by ANDREA CONSTAND.
(TROIANI, DOLORES) (Entered: 07/20/2006)
11/08/2006 96 STIPULATION AND ORDER THAT THIS CASE IS DISMISSED
WITHPREJUDICE AND WITHOUT COSTS. SIGNED BY JUDGE EDUARDO
C. ROBRENO ON 11/8/06. 11/8/06 ENTERED AND COPIES MAILED AND
FAXED.(afm, ) (as, ). (Entered: 11/08/2006)

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