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Janice Dickinson V. William H. Cosby, Jr. Case No. BC 580909 1 2 3 4 5 6

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Janice Dickinson V. William H. Cosby, Jr. Case No. BC 580909 1 2 3 4 5 6 1 Lisa Bloom, Esq. (SBN 158458) Jivaka Candappa, Esq. (SBN 225919) 2 Alan Goldstein, Esq. (SBN 296430) 3 THE BLOOM FIRM 20700 Ventura Blvd., Suite 301 4 Woodland Hills, CA 91364 Telephone: (818) 914-7314 5 Facsimile: (866) 852-5666 6 Email: [email protected] Jivaka@TheBloomFirm 7 [email protected] 8 Attorneys for Plaintiff JANICE DICKINSON 9 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 COUNTY OF LOS ANGELES, CENTRAL DISTRICT 12 13 Case Number: BC 580909 JANICE DICKINSON, an individual, [Case assigned to The Honorable 14 Plaintiff, Debre Weintraub – Department 47] 15 v. 16 PLAINTIFF JANICE DICKINSON’S WILLIAM H. COSBY, JR., an individual OPPOSITION TO DEFENDANT’S 17 Defendant. SPECIAL MOTION TO STRIKE 18 PLAINTIFF’S COMPLAINT 19 Date: February 29, 2016 20 Time: 8:30 A.M. 21 22 23 24 25 26 27 28 PLAINTIFF JANICE DICKINSON’S OPPOSITION Janice Dickinson v. William H. Cosby, Jr. Case No. BC 580909 THE BLOOM FIRM 1 TABLE OF CONTENTS 2 Page 3 I. INTRODUCTION.……………………………………………………………………………...1 4 II. FACTUAL BACKGROUND.………………………………………………………………….1 5 A. MR. COSBY DRUGGED AND RAPED MS. DICKINSON IN OR ABOUT 1982.……………1 6 B. MS. DICKINSON’S PRIOR DISCLOSURES OF THE RAPE, 1982-2010.………………….....1 7 C. MS. DICKINSON PUBLICLY DISCLOSES THE RAPE ………………………………………2 8 D. MR. COSBY QUICKLY RETALIATES BY DEFAMING MS. DICKINSON.………..............2 9 E. MR. COSBY REFUSES TO RETRACT THE FALSE STATEMENTS.…………………...........2 10 F. MR. COSBY ADMITS UNDER OATH TO DRUGGING WOMEN FOR SEX.………………..2 11 III. LEGAL ARGUMENT.…………………………………………………………………………3 12 A. DEFENDANT MUST SATISFY BOTH PRONGS OF THE ANTI-SLAPP STATUTE.……….3 B. DEFENDANT FAILS THE FIRST PRONG BECAUSE HIS PRESS STATEMENTS 13 ARE NOT “PROTECTED ACTIVITY” UNDER THE ANTI-SLAPP STATUTE.……………..4 14 1. The November 18 Press Statement was Not a Privileged Pre-Litigation Demand.……….4 15 2. A Cause of Action Containing a Mix of Unprotected and Protected Activity Should 16 Not be Stricken if Plaintiff Can Prevail on any Part of Her Claim………………………...4 17 3. Defendant has Alleged in Another Court that Rape Allegations are a Private Matter.……5 18 C. DEFENDANT FAILS THE SECOND PRONG BECAUSE MS. DICKINSON FAR 19 EXCEEDS THE “MINIMAL MERIT” TEST ON EACH ELEMENT OF HER CLAIMS.……..5 20 1. Plaintiff Need Only Establish “Minimal Merit” to Survive a SLAPP Motion.……………5 21 2. Plaintiff Can Establish “Minimal Merit” on Each Element of Her Defamation Claim.……5 22 a. The Press Statements Contain Multiple Provably False Statements ………………5 23 b. The Press Statements Were Unprivileged.………………………………………….7 24 i. The Litigation Privilege does not apply to the Press Statements.…………...7 25 ii. The Press Statements are not privileged as "predictable opinion" because 26 they were not issued in the context of pending or completed litigation.………7 27 iii. Defendant's Press Statements are not “indisputably true”…………………8 28 c. Ms. Dickinson was Harmed.………………………………………………………..8 THE BLOOM FIRM i 1 d. Mr. Cosby, As Principal, Is Liable For Media Statements Made By 2 His Attorney.………………………………………………………………………….9 3 i. An Attorney’s Actions Bind the Principal…………………………………..9 4 ii. A Principal's Silence to an Agent's Action is a Form of Ratification……...9 5 e. Mr. Singer, on Mr. Cosby’s Behalf, Acted with Malice…………………………..10 6 f. Mr. Cosby Acted With Actual Malice in Authorizing and Ratifying 7 the Statements………………………………………………………………………..13 8 3. Plaintiff’s False Light Claim is Not Duplicative, But Should Be Decided on Demurrer…14 9 4. Ms. Dickinson Sets Forth a Prima Facie Showing of Facts to Sustain a Favorable 10 Judgment on her Claim of Intentional Infliction of Emotional Distress (“IIED”)…………..14 11 D. MS. DICKINSON IS ENTITLED TO ATTORNEYS’ FEES…………………………………...15 12 IV. CONCLUSION…………………………………………………………………………………15 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 THE BLOOM FIRM ii 1 TABLE OF AUTHORITIES 2 Cases Page 3 Action Apartment Ass'n, Inc. v. City of Santa Monica, 41 Cal. 4th 1232 (2007)……………………..4 4 AIG Property Casualty Co. v William H. Cosby and Janice Dickinson, 5 Case No. 2:15-CV-04842-BRO-RAO………………………………………………………………15 6 American Society of Mechanical Engineers v. Hydro Level Corporation, 456 U.S. 556 (1982)…….9 7 Blanton v. Womancare, Inc., 38 Cal.3d 396 (1985)…………………………………………………..9 8 Bridge C.A.T. Scan Associates v. Ohio-Nuclear Inc., 608 F.Supp. 1187 (S.D.N.Y. 1985)…………..9 9 Constand v. Cosby, Case No: 2:05-cv-01099-ER………………………………………………….3, 6 10 Dreamstone Entertainment, Ltd. v. Maysalward, Inc., 2014 WL 4181026, *6 (C.D. Cal. 2014)……7 11 Ferlauto v. Hamsher, 74 Cal.App.4th 1394 (1999)………………………………………………..7, 8 12 Finke v. Walt Disney Co., 2 Cal. Rptr.3d 436 (2003)…………………………………………………7 Garrison v. Louisiana, 379 U.S. 64 (1964)………………………………………………………….10 13 Get Fugu, Inc. v. Patton Boggs LLP, 74 Cal.App.4th 141 (2013)…………………………………7, 8 14 Green v. Cosby, 2015 WL 5923553 (D. Mass. 2015)……………………………………………...6, 8 15 Grenier v. Taylor, 234 Cal. App. 4th 471 (2015)……………………………………………………..5 16 Haight Ashbury Free Clinics, Inc. v. Happening House Ventures, 184 Cal.App.4th 1539 (2010)…...5 17 Harte-Hanks Commc'ns, Inc. v. Connaughton, 491 U.S. 657 (1989)………………………..10, 11, 13 18 Heck v. Heck, 63 Cal. App. 2d 470 (1944)…………………………………………………………...10 19 HMS Capital, Inc. v. Lawyers Title Co., 118 Cal.App.4th 204 (2004)………………………………..5 20 Hustler Magazine v. Falwell, 485 U.S. 46 (1988)…………………………………………………...15 21 Jarrow Formulas, Inc. v. LaMarche, 31 Cal.4th 728 (2003)………………………………………….5 22 Khawar v. Globe Int’l, Inc., 19 Cal. 4th 254 (1998)…………………………………………………11 23 Lin v. City of Pleasanton, 176 Cal. App. 4th 408 (2009)…………………………………………….15 24 Mann v. Quality Old Time Service, Inc., 120 Cal.App.4th 90 (2004)…………………………………5 25 Martinez v. Metabolife Intl., Inc., 113 Cal.App.4th 181 (2003)………………………………………5 26 Navellier v. Sletten, 29 Cal.4th 82 (2002)……………………………………………………………..3 27 New York Times Co. v. Sullivan, 376 U.S. 254 (1964)………………………………………………10 28 NORCAL Mut. Ins. Co. v. Newton, 84 Cal. App. 4th 64 (2000)………………………………………9 THE BLOOM FIRM iii 1 Oasis West Realty, LLC v. Goldman, 51 Cal. 4th 811 (2011)………………………………………...4 2 Reader's Digest Assn. v. Superior Court, 37 Cal. 3d 244 (1984)………………………………..10, 13 3 Rothman v. Jackson, 49 Cal.App.4th 1134 (1996)…………………………………………………7, 8 4 Sanders v. Walsh, 219 Cal. App. 4th 855 (2013)…………………………………………………….10 5 Silberg v. Anderson, 50 Cal. 3d 205 (1990)…………………………………………………………...4 6 Soukup v. Law Offices of Herbert Hafif, 39 Cal.4th 260 (2006)……………………………………....5 7 St. Amant v. Thompson, 390 U.S. 727 (1968)………………………………………………………..10 8 Toal v. Tardif, 178 Cal. App. 4th 1208 (2009)……………………………………………………….10 9 Trerice v. Blue Cross of California, 209 Cal.App.3d 878 (1989)……………………………………14 10 11 Statutes 12 Cal. Civ. Proc. Code § 425.16 ……………….…………………………………………………….3, 4 Cal. Civ. Code § 2330.…………………………………….…………………………………………..9 13 14 Restatements 15 Restatement of Agency 254 (2d) ……………………………………………………………………..9 16 17 18 19 20 21 22 23 24 25 26 27 28 THE BLOOM FIRM iv 1 MEMORANDUM OF POINTS AND AUTHORITIES 2 I. INTRODUCTION 3 Janice Dickinson’s allegations that Bill Cosby drugged and raped her must be accepted as true 4 on this motion, because Ms. Dickinson has submitted a sworn declaration on those facts and 5 remarkably, Mr. Cosby has submitted no declaration denying them. 6 Press statements made on his behalf calling Ms. Dickinson a liar are therefore provably false, 7 not opinion. Either the rape happened, or it did not happen. Since on this motion the Court must take 8 as true that it did happen, Mr. Cosby’s calling Ms. Dickinson a liar was a false statement made with 9 malice, i.e. knowledge that it was false, as Mr. Cosby was present when he raped Ms. Dickinson. 10 Ms. Dickinson easily meets the “minimal merit” standard on each element of her claims. 11 II. FACTUAL BACKGROUND 12 A. MR. COSBY DRUGGED AND RAPED MS. DICKINSON IN OR ABOUT 1982 In or about 1982 in Lake Tahoe, Mr. Cosby drugged and raped Ms. Dickinson (the “Rape”). 13 (Dickinson Decl. ¶ 2.) 14 B. MS. DICKINSON’S PRIOR DISCLOSURES OF THE RAPE, 1982-2010 15 Ms. Dickinson disclosed the Rape to the following individuals: 16 (a) In 1982, to her friend Edward Tricomi. (Dickinson Decl. ¶ 4; Tricomi Decl. ¶ 3.) 17 (b) Shortly thereafter, to her friend Sandy Linter. (Dickinson Decl. ¶ 5; Linter Decl., ¶ 3.) 18 (c) In or about 2001, to Pablo Fenjves, the ghostwriter of her 2002 autobiography No 19 Lifeguard on Duty (“No Lifeguard”). (Dickinson Decl. ¶ 6; Fenjves Decl. ¶ 7.) 20 (d) In or about 2002, to Judith Regan, the president and publisher of Regan Books, an imprint 21 of HarperCollins and the publisher of No Lifeguard. (Dickinson Decl. ¶ 7; Regan Decl. ¶ 5.) 22 Ms. Regan and Mr. Fenjves would not allow Ms. Dickinson to disclose the Rape in No 23 Lifeguard because they were concerned that Mr. Cosby would sue or otherwise retaliate against 24 HarperCollins. (Fenjves Decl. ¶ 9 and Regan Decl. ¶ 6, respectively.) Although Ms. Dickinson 25 begged them to include her Rape in the book, they would only allow a milder negative story about 26 Mr. Cosby. (Fenjves Decl. ¶ 11; Regan Decl. ¶¶ 7-9; Dickinson Decl. ¶ 8.) Notably, HarperCollins’ 27 refusal to include the Rape came shortly before HarperCollins completed publication of two Cosby 28 books, Friends of a Feather and I Am What I Ate. (Bloom Decl. Exh. 1.) 1 THE BLOOM FIRM PLAINTIFF JANICE DICKINSON’S OPPOSITION JANICE DICKINSON V. WILLIAM H. COSBY, JR. TO DEFENDANT’S ANTI-SLAPP MOTION Case No.: BC 580909 1 (e) In 2010, Ms. Dickinson disclosed to Dr. Drew Pinsky that she had been raped by a 2 prominent celebrity, whose name she feared to say.
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