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Case 1:20-cr-00330-PAE Document 310-1 Filed 07/02/21 Page 16 of 80 phone calls were being recorded. Although he did not believe that Constand was making these allegations in an attempt to get money from him, Cosby explained that, after Constand and her mother confronted him, he offered to pay for her education and asked his attorney to commence discussions regarding setting up a trust for that purpose. Cosby admitted that it would be in his best interests if the public believed that Constand had consented to the encounter, and that he believed he would suffer financial consequences if the public believed that he had drugged and assaulted her. Notably, during his depositions, Cosby confessed that, in the past, he had provided Quaaludes®*—not Benadrylto other women with whom he wanted to have sexual intercourse. Eventually, Constand settled her civil suit with Cosby for $3.38 million.’ Initially, the terms of the settlement and the records of the case, including Cosby’s depositions, were sealed. However, following a media request, the federal judge who presided over the civil suit unsealed the records in 2015. By that point, then-D.A. Castor had moved on from the district attorney's office and was serving as a Montgomery County Commissioner. He was succeeded as district attorney by his former first assistant, Risa Vetri Ferman, Esquire.‘° Despite her predecessor’s decision not to prosecute Cosby, upon release of the civil records, District Attorney Ferman reopened the criminal investigation of Constand’s allegations. Then- 8 “Quaalude” is a brand name for methaqualone, a central nervous system depressant that was a popular recreational drug from the 1960s through the 1980s, until the federal government classified methaqualone as a controlled substance. 9 Constand also received $20,000 from American Media, Inc., which was a party to the lawsuit as a result of an interview that Cosby gave to the National Enquirer about Constand’s allegations. 10 D.A Ferman, now Judge Ferman, was subsequently elected to a seat on the Court of Common Pleas of Montgomery County. [J-100-2020] - 15 DOJ-OGR-00004828