atniteb s;tates 1JBistritt ctourt 

For Eastern District of Pennsylvania 

ANDREA CONSTAND, 

Plaintiff, 

v. 

WILLIAM H. COSBY, JR. 

Defendant. 

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CIVIL ACTION NO: 

05-cv-1099 

ORAL ARGUMENT 

REQUESTED 

MOTION TO INTERVENE 

M. EUGENE GIBBS-SQUIRES [Esq.] 

NOW COMES, M. Eugene Gibbs-Squires pursuant to FRCP, Rule 24(a)(2) and/or 

24(b)(l)(B) and moves this Honorable Court grant his motion to intervene. The reasons for said 

motion are more fully set forth below: 

1. I submit this motion to intervene; to address the invitation to do so; extended by 

Defendant William H. Cosby Jr. [Hereinafter Cosby]. On Friday, Nov. 21, 2014, Cosby gave a 

response to the sexual assault claims to Florida Today - stating, "I know people are tired of me 

not saying anything, but a guy doesn't have to answer to innuendos. People should fact-check." 

ADDITIONALLY, on Sunday, November 16, 2014 an attorney for Cosby, John P. Schmitt, 

called the allegations "decade-old" and "discredited," ... CNN Money. AND, Gibbs believes 

evidence pertaining to the "stolen art" is contained in the deposition the Associated Press 

petitioned this Honorable Court to release. This Court granted the petition to the extent the 

deposition was released in part. 

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2. I am a retired New York City police officer, and the attorney of record: in the 

litigation of the largest art conspiracy and racketeering corrupt organization (RICO) in America's 

history. The individuals listed, infra, are those alleging criminal conduct by the Defendant. I've 

used resources acquired as a police officer and attorney, print and video media, social media, 

reference materials and the internet. My through investigation cannot produce any evidence the 

"allegations" referenced were "old discredited allegations." Additionally, 

Innuendo - insinuation, suggestion, implication, intimation, allusion, hint or overtone. 

3. The Defendant, William H. Cosby, Jr. (Hereinafter Cosby), his Curator, Dr. David 

Driskell and the Smithsonian Institution, alleged Gibbs was "mentally ill" and Gibbs' claims as 

to stolen art was delusional. "They" threatened to sue a reporter and Channel 21 News of 

Montgomery County, Maryland for slander. 

a. Gibbs provided uncontroverted proof: Dr. David Driskell stole 100 works 

of art from Fisk University- $100 million. 

b. Dr. Driskell "formed" sexual relationships with Dr. Richard Powell and 

other curators in order to steal works of art valued at $300 million from Historical Black 

Colleges and Universities (HBCU). Dr. David Driskell facilitated the Smithsonian Institution's 

theft of Black art valued at $10 [B]illion. 

c. Cosby, Dr. Driskell and Julian Bond's theft of art from the Dr. Barnes Art 

Trust [$30 Billion], forced Lincoln University to accept a $50 million bribe to relinquish control 

of the Dr. Barnes Art Trust. 

4. In or about the spring of 2005, Gibbs provided Plaintiffs attorney with 

documented evidence of Cosby's criminal behavior: the same information Gibbs used to filed 15 

complaints with the FBI, Justice Department, and multiple RICO suits. 

Case 2:05-cv-01099-ER Document 121 Filed 07/29/15 Page 2 of 14
5. Gibbs has not uncovered a single instance whereby an innuendo has been used to 

describe the actions of Bill Cosby. The women have given very personal and detailed accounts of 

their encounters with Bill Cosby, to wit: 

February 10, 2005 

Tamara Green (Plaintiff), a California lawyer, appears on the Today Show and alleges that Cosby 

drugged and sexually assaulted her in the 1970s. Green tells Matt Lauer that Cosby, who had 

given her pills to combat a fever, drove her to her apartment and began " ... groping me and 

kissing me and touching me and handling me and ... taking off my clothes." According to Green, 

Cosby left two $100 bills on her coffee table afterwards. Cosby's lawyer issues a statement: 

"Miss Green's allegations are absolutely false. Mr. Cosby does not know the name Tamara 

Green or Tamara Lucier [her maiden name], and the incident she describes did not happen. The 

fact that she may have repeated this story to others is not corroboration." 

March 8, 2005 

Andrea Constand files a civil complaint against Cosby. The five-count lawsuit charges Cosby 

with battery and assault. 

June 23, 2005 

Philadelphia Daily News, Jane Doe 5 goes public. Beth Ferrier claims she was in a relationship 

with Cosby in the mid-1980s, one that ended when he allegedly drugged her coffee and Ferrier 

woke in a car. Bill Cosby is "dubbed" Dr. Huxtable and Mr. Hvde. 

December 2006 

The following month, People Magazine publishes Barbara Bowman's account of several 

assaults: "It was in a hotel in Reno, claims Bowman, that Cosby assaulted her one night in 1986. 

February 2014 

Katie Baker of Newsweek - Whitaker's former employer - interviews both Green and 

Bowman about the alleged assaults. 

October 16, 2014 

Comedian Hannibal Buress does an extended bit about the rape charges in Cosby's home town of 

Philadelphia. 

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November 10, 2014 

To battle the bad press, Cosby's PR team launches an online meme generator. Twitter 1s 

immediately inundated with references to the rape claims. 

November 13, 2014 

Inspired by the reactions to Buress's bit, Bowman pens an op-ed in the Washington Post, titled 

"Bill Cosby raped me. Why did it take 30 years for people to believe my story?" 

November 15, 2014 

Cosby is asked about the various charges on NPR's "Weekend Edition" but stays silent. His 

lawyer later posts a statement saying Cosby "won't dignify these allegations with any response." 

November 16, 2014 

A new accuser, Joan Tarshis, alleges that Cosby drugged and assaulted her on two occasions in 

1969. 

November 17, 2014 

Linda Joy Traitz, a former waitress at Cosby's Cafe Figaro, writes a lengthy FaceBook post 

accusing the actor of trying to drug her in the early '70s. 

November 18, 2014 

On Entertainment Tonight, supermodel Janice Dickinson becomes the next woman to accuse 

Cosby of sexual abuse, saying the comedian drugged and raped her in 1982. Dickinson alluded 

to the event in her 2002 memoir, and later told Howard Stem she was asked to change the text to 

show Cosby in a better light. 

November 20, 2014 

Three more women accused the comedian of sexual assault on Thursday, while producers behind 

The Cosby Show claimed ignorance. Actress Louisa Moritz, who played Rose in One Flew Over 

the Cuckoo's Nest, told TMZ that Cosby forced her to engage in oral sex before a 1971 Tonight 

Show appearance; Carla Ferrigno (Lou Ferrigno's wife) told Rumorfix he attacked and grabbed 

her at a party in 1967; and Therese Serignese, a Florida nurse, told the Huffington Post that he 

drugged and raped her in 1976. 

November 21, 2014 

Three more accusers step forward. All tell similar stories: Kristina Ruehli says Cosby spiked her 

bourbon and forced her to perform oral sex in 1965; Picture Pages actress Renita Chaney Hill 

alleges Cosby drugged and assaulted her multiple times when she was a teenager; and model 

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Angela Leslie contends that Cosby invited her to his Las Vegas hotel room in 1992, got naked, 

then forced her to masturbate him. Renita Chaney Hill, who says she was just 15 and an 

aspiring actress when she met Bill Cosby after her modeling agency sent her on an audition 

(or "Picture Pages," a series of educational videos Cosby was producing in Pittsburgh in the 

mid-1980s. 

November 22, 2014 

The Washington Post publishes the results of a long investigation into the allegations, including 

an interview with a new accuser: former Playmate Victoria Valentino, who says Cosby drugged 

and assaulted her and a friend in 1970. 

November 23, 2014 

Former Cosby Show employee Frank Scotti says he was in charge of delivering payoffs to eight 

different women. In his words, "It was a coverup." Scotti also claims that he stood guard outside 

Cosby's dressing room while the comedian conducted "interviews" with young models, all 

supplied by an agency he had an "arrangement" with. 

November 24, 2014 

Model Jewel Allison accuses Cosby of drugging and assaulting her in the late '80s. She recalls 

accepting a dinner invitation to Cosby's home, where he poured her a glass of wine. Allison says 

now she thinks the wine was drugged. "I looked at myself in the mirror and I didn't look good," 

she tells the New York Daily News. 

December 2, 2014 

Judy Huth accuses Cosby of assaulting her when she was 15. Huth claims that she and a friend 

met Cosby when they wandered onto a movie set in 1974. A week later, she says, the comedian 

took them to a party at the Playboy Mansion. There, Huth claims Cosby told her to lie about her 

age; then, when the two were alone, Cosby stuck his hand down her pants and forced her to 

masturbate him. 

December 11, 2014 

Model Beverly Johnson accuses Cosby of drugging her in the mid-'80s. Johnson tells Vanity Fair 

the comedian insisted she try a cappuccino from his home espresso machine; after two sips, she 

knew it was drugged. Before passing out, she remembers calling Cosby "a motherfucker," which 

annoyed him so much he dragged her out of his house and hailed her a cab. 

So far, 48 women have publicly accused Bill Cosby of assaulting them. 

Case 2:05-cv-01099-ER Document 121 Filed 07/29/15 Page 5 of 14
6. If, Bill Cosby denies each allegation under oath, fully and completely; Gibbs will 

dismiss this Motion to Intervene with prejudice. If, some allegations are denied and others are 

admitted: Gibbs will redact the allegations denied. 

7. Gibbs's letter [Edited] to NYC Mayor Bill de Blasio evidences Gibbs's 

qualifications and why Gibbs believes an attempt will be made to destroy Gibbs and any attorney 

discovering the TRUTH concerning the Racketeering Influence Corrupt Organization; the letter 

is included as follows: 

M. Eugene Gibbs,[Esq.] Retired NYC-PD 

XXXX XXXXXXXX Drive 

xxxxxxx, xxxxxx xxxx 

(XXX) XXX-XXXX 

E-Mail: mystolenart@aol.com 

December 5, 2014 

Hon. Mayor Bill de Blasio 

City Hall 

New York, NY 10007 

cc: Police Commissioner William J. Bratton, First Deputy Commissioner Benjamin Tucker and 

Charlie Beck, Chief of Police, LAPD 

Re: NYC-PD and RACE 

[William "Bill" Cosby: RAPE and Stolen Art] 

By way of introduction: 40 years ago Police Commissioner Michael Codd requested I participate 

in the conference on race at Major de Seversky; at the conclusion of the conference I co-wrote 

NYC-PD's "position paper" on race. I was assigned to the 69th Pct., but did not realize the police 

officer removed to create a space for me was: First Deputy Commissioner Benjamin Tucker .... 

My first encounter with Commissioner Codd - I was assigned to the 79th Pct. and Codd was 

Commander of Brooklyn North. Several White officers beat a student beyond recognition; at 

Boys High School (832 Marcy Avenue, B'klyn). The event caused a riot; trapping three officers 

in the school. When I arrived students were throwing items from the windows: chairs, trash cans, 

books and all that wasn't nailed down. I walked in the courtyard and yelled, "STOP". The school 

became silent and I motioned for the three officers to walk out of the school. My captain 

informed Codd I had stopped another riot; caused when two White cops arrested a nine month 

pregnant Black woman. They cuffed her hands behind her back; she struggled while asking, 

"Why are you arresting me and not the landlord?" The officers pushed her stomach first into the 

Case 2:05-cv-01099-ER Document 121 Filed 07/29/15 Page 6 of 14
rear side panel of the police car - Bed-Sty erupted. Codd asked me to accept Boys High as an 

assignment. I was assigned-BOYS HIGH SCHOOL is my alma mater .... 

I met Capt. Francis, Assistant Chief Inspector Eldridge Waith and Benjamin Ward, 45 years ago. 

They created a tutorial class with emphasis on math and math related problems, designed to 

recruit minorities. Benjamin Ward was selected to teach the math related sections. 

After assisting Ward with several math equations - they (including Ward) asked me to teach the 

math classes. We recruited more minorities than at any time in NYC-PD's history. 

My crusade to minimize police brutality and gain equality caused an irreconcilable difference 

and ended my police career. I never requested or accepted anything from Waith; and the only 

request I made of Codd was to be transferred from the 79th Pct. to the 73rd Pct. This was after 16 

cops beat a Black woman who died. I wasn't working the night it happened, but I sought justice 

for her family. When I sought assistance from outside the department, my connection to Codd 

was severed. In 1971 I wrote: 

(©1971) "Systematic Murder" 

Protect and guide my youth, so they may build a nation-strong 

There are many subtle pitfalls they must clear to avoid the systematic wrong 

To build a nation, we all must make a contribution before we die 

And when young life is wasted, we must demand of ourselves why 

Remember my young, Clifford Glover, Claude Reese 

Both so young, and now listed as decease 

Not shooting dope or in a far off comer smoking pot 

But, from a single racist bullet, ringing from a single systematic shot 

The system declare, the press write, what a tragic mistake 

I say to the system, give back the life you did take 

Black media and people, you say Officers Bosco and Shea have 

Committed murder by taking two of our youthful lives 

I say to you stop the rhetoric and non-sense, it is the same 

"System" that for years have raped our sisters and wives. 1 

Tears of a Cop 

I have been where you fear to go ... I have seen what you fear to see ... 

I have done what you fear to do ... All these things I've done for you. 

I am the one you lean upon ... The one you cast your scorn upon ... 

The one you bring your troubles to ... All these people I've been for you. 

The one you ask to stand apart ... The one you feel should have no heart ... 

The one you call the man in blue ... But I am human just like you. 

And through the years I've come to see ... That I'm not what you ask of me ... 

And when you watch a person die ... And hear a battered baby cry ... 

Then so you think that you can be ... All those things you ask of me ... ? 

So take this badge and take this gun ... Will you take it? Will anyone? 

©Unknown Cop 

" .. .I was born poor- and colored- and almost all the prettiest roses I have seen have been in rich people's 

yards, not in mine. That is why I cannot write exclusively about roses and moonlight - for sometimes in the 

moonlight my brothers see a fiery cross and a circle ofKlansmen's hoods. Sometimes in the moonlight a dark body 

swings from a lynching tree, but for his funeral there are no roses." Langston Hughes 

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Fast forward - 20 years ago my law firm (Gibbs, Scott & Redmond) was retained to represent 

the Estate of the late Black artist, William H. Johnson. It was my belief that a few works of art 

would be recovered valued at about $250,000. My investigation revealed the Harmon Foundation 

stole 2,000 works of art by Johnson - $10 Billion and 1,000 works of art belonging to 200 Black 

artists - $10 Billion and a connection to the Dr. Barnes Art Trust - $30 Billion: see, The Art of 

the Steal, by Don Argott. During my conversation with Dr. Johnnetta Cole (former President 

Spellman College), Dr. Cole stated, "I do not have any of the art, but you are about to open a 

'can of worms' that you have no idea." 

Dr. David Driskell "oversaw" the thefts by the Harmon Foundation. When Driskell resigned as 

Chairman Art Department, Fisk University to accept the same position at the University of 

Maryland - Driskell stole artwork valued at more than $100 million. Driskell became Curator of 

William "Bill" Cosby's art collection. Having teamed with Cosby - they gained control of$$$ 

billion [estimated to be $10 billion] of stolen Black art at the Smithsonian Institution, and stole 

art from the Dr. Barnes Trust [Valued at $30 Billion]. 

The stolen art was used to corrupt politicians, lawyers, judges and public figures. Bill Cosby is 

"protected" by a person or persons in the Justice Department. The political "system" we believe 

we have do not exist. Congress is controlled - "key" members are controlled by stolen art. I 

believed members of Congress were dedicated to serving their constituency. Wrong, there is a 

corrupt structure in place to serve the rich: below are the realities hidden from America: 

... while litigating the stolen art I appeared on CBS Sunday Morning, BET Television, ABC -

News (New York), NBC -News (Savannah, Georgia), NBC- News (Florence, SC), Channel 21 

News- Washington, DC area, Washington Post, etc .... 

My illegal arrest (2003), indictment and tortured confession were secured for the sole purpose of 

preventing me from exposing the art thefts .... AUSA James Trusty on behalf of the Justice 

Department ordered me to be tortured; to force me to confess to a crime that Trusty knew had not 

been committed. USA James Trusty conspired with an individual(s) to ensure I was denied bail: 

using a 16 year old nolle prosed, domestic charge. Trusty knew the charge arose from me being 

placed on steroids to save my life due to a lung disease: Sarcoidosis2 - I was taking 60 mg of 

Prednisone (Steroid) per day for months. My dosage was reduced to 20 mg a day over a few 

days, causing me to become mentally unstable - the dosage should have been reduced over 

several months. 

AUSA James Trusty stood before Judge Day and stated, "Well, these pleadings in terms - they 

probably will not generate counts by way of criminal conduct because it is my understanding that 

with the time stamp it shows they were hand delivered, and I'm not sure if there is any - they 

would not be covered by mailing or writing threatening communications. . .. During Mr. Gibbs, 

My wife testified, "I did not understand the effects of 'steroids' and when our doctor explained the 

causation, and my husband having been loving and caring for more than 30 years without incident, I dropped the 

charges. 

Case 2:05-cv-01099-ER Document 121 Filed 07/29/15 Page 8 of 14
60 years we cannot find so much as a speeding ticket." [sic] ... then I was "flagged" by the 

Justice Department. 

My TORTURE over 18 months included but was not limited as follow: 3 Forced to stay in a 

prison cell 23 hours a day where the temperature exceeded 105 degrees; Denied law library 

privileges, pen and pencil, legal documents not filed with the court; Forced to stand outside in 

30 degree weather in a tee-shirt; Transported in a steel cage to which there was no escape during 

a catastrophic accident, and the heat turned off in winter and the air conditioning turned off in the 

summer - I came very close to death; Flown thousands of miles over several days to travel less 

than 200 miles; Forced to undergo sleep deprivation prior to court appearances. 

The Chief Judge (Federal District Court) removed my case from the assigned judge and 

reassigned it to the Chief Judge of another state: illegal; I was not notified nor was a hearing 

held: illegal; "They" did not issue an order or cause an entry to be made on the DOCKET: 

both illegal. 

When "they" destroyed me and my law firm, in addition to litigating the largest art conspiracy in 

history, I was in the process of developing a means to quantify pain in personal injury cases: 

Expert reconstruction of the accident using a robotic "cadaver" while explaining the actual 

effects of pain - E=mgh, E=(Yi)kx/\2,x=sqrt(2mgh/k), f=kx=sqrt(2mghk). Investigating two 

innocent Black Men having been executed (1950s) in Florence, South Carolina. In one case, a 

White doctor on his "death bed" confessed to having killed his wife and "staged" the evidence to 

convict his Black gardener. The other case involved "covering up" two murders committed by a 

White politician's mentally challenged son - the son was in love with the female victim. Police 

women were relegated to clerical duties and jail matrons. Gibbs encouraged Hilda Hubbard and 

Iren Niles to seek equal patrol rights and supported every effort they undertook. .. .it was 

Contracts (class) that prevented me from completing law school in two years. Pursuant to ABA 

Guidelines, I would have been required to attend law school for two and one-half years. I 

"walked away" from law school for eight years prior to returning to graduate. 

"They" offered me $5 million to throw my clients under the bus; an offer I would never 

consider. But the o(fer was insulting based on the fact this would have been less than one-half 

of one per cent of the value ofthe art. 

Peter Stem, Esq., assisted by James Bogle, Sr. Ass AG, South Carolina, had me falsely arrested, 

tortured and convicted to conceal the largest art conspiracy in American history: assisted by 

A USA James Trusty - he rigged the grand jury: there was no crime, no victim or witness 

PRESENTED TO THE GRAND JURY. AND, AUSA Neil Corwin - he stopped the 

investigation by the FBI Art Theft Unit, Queens, New York. For additional information: see, 

mystolenart.com. 

I was illegally detained from August 2003 to September 2004, 13 months. The conditions were so atrocious 

at one facility- judges "gave" 2 days for every day served; thus I was imprisoned for 13 months. 

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PROFFERThe FBI falsely arrested Gibbs and confiscated (never returned) Gibbs' case file - Gibbs 

v. Smithsonian Institution. The file was protected by attorney client privilege; yet AUSA Jim 

Trusty distorted facts in the file to effect Gibbs' prosecution. 

Gibbs highlighted his prosecution strategy of the stolen art case in a manner to convict 

the perpetrators and secure damages, to wit: 

I dismissed Ms. Oprah Wirifi-ey from the litigation in February 2001. Ms. Winfrey signed 

an affidavit attesting to the fact she did not possess stolen art. The suit provided Ms. Winfrey 

each and every detail concerning the stolen art. Yet, August 2001, Ms. Wirifi-ey had Bill Cosby 

appear on her show to promote his stolen art .... (Accessory after the fact at a minimum) 

Michael Rosenfeld (Gallery) used a bogus purchase from the Mary Beatie Brady Estate 

to provide cover for art stolen from Historical Black Colleges and Universities (HBCUs): Fisk, 

Howard, Hampton, Tuskegee, Morgan State and Clark Atlanta Universities - Chiefly, the 

William H. Johnson painting "Sarah" was stolen from Tuskegee University. Mary Beatie Brady 

as President of the Harmon Foundation was responsible for the theft of 2,000 works of art by 

William H. Johnson, and 1,000 works of art by 200 Black artist. OBSERVATION: Michael 

Rosenfeld is the weak link in the corrupt organization and will "rat" on his mother to avoid jail 

time, 

Dr. Richard Powell, as a young art student, was coerced into a love affair with an older 

professor, Dr. David Driskell. When Driskell departed Fisk University as Chairman of the Art 

Department to take the same position at the University of Maryland - Driskell stole more than 

100 paintings from Fisk University: those paintings are valued at more than $100 million. Dr. 

Driskell became curator of Bill Cosby's art collection and Driskell and Cosby extended their 

thefts to the Dr. Barnes Art Trust [$30 Billion] .... Dr. Powell is weak and cannot withstand 

interrogation as to the facts of the case: he will reveal - who, when, where and how ... the why is 

tied to great financial gain, 

The Smithsonian Institution discovered they are in possession of stolen Black art having 

a value of more than $10 Billion. In order to cover-up the theft, the Smithsonian joined with Dr. 

Driskell to have Dr. Powell to create a false provenance for the stolen art work. 

Why would the Justice Department "protect" William "Bill" Cosby and Rep. John Lewis 

(D-GA)? It would be at the request of "powerful" people or Cosby and Lewis were used as 

informants - spying on Dr. King and the Civil Rights Movement. Bill Cosby can be compared to 

Vito Corleone (God-Father). If I was an investigator on the Ennis Cosby murder case, I would 

re-open the case.... There are several books in the conspiracy: Dr. Richard Powell, 

Homecoming - The Art and Life of William H. Johnson; Dr. David Cl. Driskell, The other 

Side of Color - African American Art in the Collection of Camille 0. and William H. 

Cosby Jr.; NOVAE: William H. Johnson. And exposing the conspiracy: Steve Turner & 

Victoria Dailey, William H. Johnson -Truth Be Told. Film: The Art of the Seal, Don Argott, 

and more than 300 documents retrieved from the Library of Congress (Madison Building), 

Inspector General (Smithsonian Institution) and the National Achieves. ADDITIONALLY, I've 

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written: M.E. (Melvin Eugene) The Last Angry Cop!. .. first pinned (2011) as "I Am No 

Ordinary Negro! - taken from a letter written by William H. Johnson in 1938. 

What happened to me is an example of the fate th,at awaited the women "drug" raped 

... had thev come forward 20, 30 or 40 years ago. 

In the event of my death or incapacity any and all investigations must begin and end 

HERE! 

If there exist any doubts concerning these stated facts, invite Al Sharpton, the NAACP and 

members of the Black Caucus to a meeting and reveal the contents of the art thefts and request 

their opinions as to what should be done. Jointly request the opinion of the three senators and 

three representatives on the Smithsonian's board of regents and those in power at the 

Smithsonian; particularly the Museum of American Art. 

I was recruited to play Basketball by legendary Boys High School Coach Mickey Fisher, who 

informed me, "If you don't know the players, you can't keep score." 

Thanking you in advance for your considerations .... 

With warm regards, I remain 

/s/ 

M. "Mel" Eugene Gibbs 

8. Defendant cannot be allowed to usurp the "Scales of Justice" which has become 

part of our shared cultural fabric. The public and attorneys in general and Gibbs in particular 

have a right of discourse through litigation without fear of intimidation and/or bodily harm. 

Bill Cosby: Rape and Stolen Art $50 [B]illion - Cosby has can be prosecuted: 

CRIMINAL and CIVIL LITIGATION under conspiracy and racketeering (RICO) [18 

USC § 1961 et seq. (§ 1964) .... William Morris Agency, J.F. Images, Denver's top 

agency at the time; Bill Cosby's "right hand" men and body guards; Bill Cosby's staff 

- Manhattan Brownstone and Pennsylvania Home, those who watched the "door" so 

Cosby would not be interrupted, etc ... Bill Cosby maintained and advanced rape against 

women and men when Cosby hired Dr. David Driskell. Cosby and Driskell were able to 

convince judges and politicians to turn a "blind eye" to their rapes by dolling out stolen 

art. Every woman: all 48 of them and a prosecutor can file under RICO: Racketeering 

Influence Corrupt Organization .... 

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NOW, the "well oiled" Bill Cosby "spin doctors" are embedding a lie in the public 

domain: "The statutes of limitations have expired and the aggrieved women do not have 

a cause of action at law." Talent agencies and others joined with Bill Cosby and 

conspired to procure young girls to satisfy Cosby's criminal enterprise. These acts are in 

violation of causes of action for conspiracy, racketeering, commerce clause and the laws 

of the states in which the crimes occurred. AND, Bm Cosby's legal team and public 

relation agency have become part and partial to the racketeering and pursuant to law 

must be severed: 

The court sided with the prosecutors, contending that Cutler [John Gotti's Attorney] was the 

"in-house counsel" for the Gambino family and must be severed, U.S. v. GOTT!, 9 F.Supp.2d 

320 (1998). 

CONCLUSION: 

For the foregoing reasons, Gibbs must be provided a litigation environment free from 

intimidation and corruption: this Honorable Court must order the full and complete transcript 

released, and deny any and all attempts to sanction Plaintiff and/her attorneys. 

RELIEF: 

WHEREFORE, Gibbs prays this Honorable Court will grant the Motion to Intervene, 

deny any and all relief requested by Defendant, and such other and further relief as this Court 

deems just and proper. 

Dated: July 25, 2015 

Florence, South Carolina 

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CERTIFICATE OF SERVICE 

I, Melvin E. Gibbs, hereby certify that a copy of this motion to intervene was 

electronically transmitted via Email and/or placed with USPS, postage prepaid, this 25th day of 

July 2015, addressed to: 

Bill Cosby's Attorney 

Patrick J. O'Connor 

Cozen O'Connor 

One Liberty Place 

1650 Market Street 

Philadelphia, PA 19103 

Melvin E. Gffihs 

4257 Monterey Drive 

Florence, SC 29501 

Dolores M. Troiani, Esq 

131 Lancaster Ave 

Devon, PA 19333-1503 

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Case 2:05-cv-01099-ER Document 121 Filed 07/29/15 Page 13 of 14
aliniteb a;tates il!listtitt Qeourt 

For Eastern District of Pennsylvania 

ANDREA CONSTAND, 

Plaintiff, 

v. 

WILLIAM H. COSBY, JR., 

Defendant. 

I, M. Eugene Gibbs, hereby declare: 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

CIVIL ACTION NO: 

05-cv-1099 

ORAL ARGUMENT 

REQUESTED 

I am a retired New York City police officer, and attorney of record in the largest art 

conspiracy and racketeering case in American history. 

I submit this Declaration in support of my Motion to Intervene, attached hereto. 

Pursuant to 28 U.S.C. § 1746, I certify under penalty of perjury that the foregoing is true and 

correct. 

Executed on: 

July 24, 2015 

Florence, South Carolina 

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