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Case 1:20-cr-00330-PAE Document 310-1 Filed 07/02/21 Page 8 of 80
mother informed Cosby that Constand had filed a police report accusing him of sexual
assault.
Constand later telephoned Cosby again and, unbeknownst to Cosby, recorded the
conversation with a tape recorder that she had purchased. During this conversation,
Cosby offered to continue assisting Constand if she still desired to work in sports
broadcasting. He also indicated that he would pay for Constand to continue her
education. Cosby asked Constand to meet him in person to discuss these matters further,
and told her that he would have someone contact her to set up the meeting. As with the
previous call, Cosby again refused to identify the pills that he had provided to Constand
on the night of the alleged assault.
Within days of filing the police report, Constand received two telephone messages
from people associated with Cosby. The first message was from one of Cosby’s
assistants, calling on Cosby’s behalf to invite Constand and her mother to Cosby’s
upcoming performance in Miami, Florida. Constand called the representative back and
recorded the call. The representative asked for certain details about Constand and her
mother so that he could book flights and hotel rooms for them. Constand declined the
offer and did not provide the requested information. Constand then received a message
from one of Cosby’s attorneys, who stated that he was calling to discuss the creation of
a trust that Cosby wanted to set up in order to provide financial assistance for Constand’s
education. Constand never returned the attorney’s call.
In the meantime, the Durham Regional Police Department referred Constand’s
police report to the Philadelphia Police Department, which, in turn, referred it to the
Cheltenham Police Department in Montgomery County, where Cosby’s residence was
located. The case was assigned to Sergeant Richard Schaeffer, who worked in tandem
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