DOJ-OGR-00004827.pdf

--- Page 1 --- The extracted text is: **Case 1:20-cr-00330-PAE** **Document 310-1** **Filed 07/02/21** **Page 15 of 80** At deposition, Cosby testified that he developed a romantic interest in Constand as soon as he met her, but did not reveal his feelings. He acknowledged that he always initiated the in-person meetings and visits to his home. He also stated that he engaged in consensual sexual activity with Constand on three occasions, including the January 2004 incident. Throughout the depositions, Cosby identified the pills that he provided to Constand in 2004 as Benadryl. Cosby claimed to know the effects of Benadryl well, as he frequently took two of the pills to help himself fall asleep. Thus, when Constand arrived at his house on the night in question stressed, tense, and having difficulty sleeping, Cosby decided to give her three half-pills of Benadryl to help her relax. According to Cosby, Constand took the pills without asking what they were, and he did not volunteer that information to her. Cosby explained that, after fifteen or twenty minutes, he suggested that they move from the kitchen to the living room, where Constand met him after going to the restroom. Cosby testified that Constand sat next to him on the couch and they began kissing and touching each other. According to Cosby, they laid together on the couch while he touched her breasts and inserted his fingers into her vagina. Afterwards, Cosby told her to try to get some sleep, and then he went upstairs to his bedroom. He came back downstairs two hours later to find Constand awake. He then escorted her to the kitchen where they had a muffin and tea. Cosby was questioned about his telephone conversations with Constand's mother. Cosby admitted that he told Constand and her mother that he would write down the name of the pills that he gave her and then send it to them, but that he failed to do so. He further explained that he would not admit what the pills were over the phone with Constand and her mother because he did not want Constand's mother to think that he was a perverted old man who had drugged her daughter. He also noted that he had suspected that the pills would not affect her as they had affected him. **[J-100-2020] - 14** **DOJ-OGR-00004827**