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Case 1:20-cr-00330-PAE Document 310-1 Filed 07/02/21 Page 35 of 80 she voluntarily consumed both the alcohol and the pill. Cosby then gave her a second shot and led her to a couch. Lasha began to feel intoxicated. Lasha was unable to move on her own, and Cosby helped her to the bed. Cosby laid next to her, pinched her breasts, and rubbed his genitals against her leg until she felt something warm on her leg. Lasha woke up the next day wearing only a robe. Maud Lise-Lotte Lublin. When Cosby met Lublin in 1989, he was fifty-two years old, and she was twenty-three. Lublin also was an aspiring model and actress. Lublin’s agent informed her that Cosby wanted to meet her. Soon after, Lublin met with Cosby, who told her that he would refer her to a modeling agency in New York City. Cosby then started to call her regularly. Lublin considered Cosby to be a mentor and a father figure. Once, Cosby invited her to his hotel, where they talked about improvisation. Cosby poured her a shot of liquor and told her to drink it. Not normally a drinker, Lublin initially declined the shot. When Cosby insisted, she drank it. He poured her another shot, and again strongly encouraged her to drink it. Because she trusted him, Lublin drank the second shot as well. She quickly felt dizzy and unstable, and was unable to stand on her own. Cosby asked her to sit between his legs and lean against his chest. He stroked her hair and talked, but she could not hear his words. She could not move or get up. She awoke two days later at her home, with no idea how she got there. The trial court rejected Cosby’s arguments that the introduction of testimonies from the five prior bad acts witnesses violated his due process rights, and that the incidents were too remote in time and too dissimilar to have probative value, let alone probative value sufficient to overcome the unduly prejudicial impact of such evidence. The court noted that prior bad acts evidence generally cannot be used to establish a criminal propensity or to prove that the defendant acted in conformity with the past acts, but that such evidence can be used to show motive, opportunity, intent, preparation, plan, [J-100-2020] - 34 DOJ-OGR-00004847