KEVIN J. KENSIK, ESQ.

LAW OFFICES OF KEVIN J. KENSIK

6()9 Deep Valley Drive
Suite 31(1
Rolling Hills Estates, California 90274
(310) 891-2300
State Bar Number:
206585
SPENCER T. KEVIN, ESQ.
LAW OFFICES OF CRAIG GOLDENFARB, P.A.
1800 S. Australian Avenue
Suite 400
West Palm Beach, Florida, 33409
(561) 697-444()
Florida State Bar Number:
89737
Pro Hac Vice Application Pending
Attorneys for Plaintiff
Chloe Goins, An Individual
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
CENTRAL DISTRICT - UNLIMITED JURISDICTION
CASE NO.:
)
)
CHLOE GOINS, an individual,
)
)
)
)
)
Plaintiff,
)
)
and
)
)
WILLIAM HENRY COSI3Y, JR. aka
)
BILL COSI3Y, an individual,
)
HUGH MARSTON HEFNER, an individual,)
Does 1-5()
)
)

COMPLAINT FOR:
1. SEXUAL BATTERY;
2. GENDER VIOLENCE;
3. INTENTIONAL INFLICTION
OF EMOTIONAL DISTRESS;
4. NEGLIGENT INFLICTION
OF EMOTIONAL DISTRESS;
5. CONSPIRACY TO COMMIT
SEXUAL BATTERY;
DEMAND FOR .JURY TRIAL

Plaintiff CHLOE GOINS, alleges as follows:

SUMMARY OF ACTION
l) Plaintiff Chloe Goins, (hereinafter"CHI OE" or "GUNS") an individual, brings this action
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Complaint

against William Henry Cosby, JR, (hereinafter "BILL" or "COSBY") an individual, and Hugh

Marston Hefner, (hereinafter "HUGH" or "HEFNER")

2) In 200, Plaintiff GOINS and a friend were invited to the home of HEFNER, better known

as "The Playboy Mansion" (Hereinafter "Playboy Mansion", "Mansion" or "residence") for a

party or event.

in 2008.

the event and checked into a hotel;

3) After checking into the hotel, GOINS and the friend traveled to the Playboy Mansion

because the friend had been invited, and GOINS was with the friend as her "plus one" guest.

Plaintiff is unsure of the exact date of the visit to the residence, but it did occur

Plaintiff traveled with the friend from San Diego County to Los Angeles County for

Upon arriving to the Playboy Mansion, GOINS and her friend were introduced to

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4)

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HEFNER, who presumably owned the residence and who was the host of the party or event;

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5)

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COSBY asked GOINS and her friend if they wanted a drink. GOINS and her friend agreed to

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accept drinks, and COSI3Y went to get them the drinks;

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6)

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portion of the drink and began to feel ill.

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did not. look well.

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suggested GOINS go and "lie down" in a bedroom at the residence.

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believes that Defendant COSI3Y put some type of drug or narcotic in the drink. (hereinafter

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also "foreign substance");

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7)

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and lost consciousness and does not have any recollection cif what happened;

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8)

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awoke from feeling a sharp pain in one of her toes. When she awoke, she looked at her toes

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and witnessed Defendant COSBY with one her toes in his mouth.

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was naked and that she felt a wet and sticky substance on her breasts as though a person had

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been licking them;

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Upon meeting HEFNER, GOINS was introduced to Defendant COSBY by HEFNER.

COSBY returned to the girls with drinks and gave the girls the drinks. GOINS drank a
GOINS was also told by other party-goers that she

Both HEFNER and COSBY saw that GOINS was "woozy," and HEFNER

COSBY escorted GOINS to a private room.

GOINS is informed and

From that point, GOJNS "blacked-out,"

GOINS awakened some time later, but is unsure how long she was unconscious.

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Complaint

She

GOJNS also noticed she

9) As GOINS witnessed COSBY removing her toes from his mouth, she also saw him stand up
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and pull up his pants which were previously removed. COSBY then left the room.

Plaintiff

was scared, afraid, embarrassed and repulsed at what had just occurred. She immediately

gathered her clothes from the floor, dressed and left the residence;

10) Plaintiff was shocked, hurt, and psychologically impacted and damaged as a result of this

traumatic incident at such a young age and this psychological torment. has caused her serious

and life-long harm and injury.

touch, lick or molest. her, and Plaintiff was in fact unable to give such consent because she was

Plaintiff at no time gave any such consent for COSBY to

unconscious;
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11) Plaintiff recalls this chain of events from the time she arrived at the Playboy Mansion as

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the "incident" herein.

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dissuaded GOINS from telling anyone about the incident, reasoning that if GOINS told the

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police or anyone else, that they would never be invited to large celebrity filled parties such as

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1ITTNER's again.

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her mind;

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12)

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She was young and heeded the advice of the friend to "deal with it" by not going to the police.

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However, the passage of time has only caused more damage to Plaintiff. Plaintiff only came

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forward after receiving news of the nearly 40-60 women claiming Defendant COSBY had a

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propensity since the 1960's of drugging young women and taking advantage of them sexually

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while the victims were under the influence of alcohol or drugs;

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13) GOINS has a birth date of May 17,1990.

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took place in 2008, but GOINS is unsure of the specific event, party or date.

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informed and believes from various media outlets and stories that similar events and parties

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occur often throughout the year at the Playboy Mansion;

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//

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//

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GOINS told her party-going friend about the incident.

The friend

The friend basically told GOINS to simply "deal-with-it" and put it out of

COINS was hurt by the malicious and unwanted touching and molesting by COSBY.

The acts, events and incident. describer herein

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Complaint

GOINS is

JURISDICTION AND VENUE

14)

The acts, occurrences, omissions and commissions hereinafter set forth, took place

within the County of Los Angeles and State of California and thus within the jurisdiction of this
Court. Plaintiff COINS was a resident of San Diego County and a resident of the State of
California when the acts occurred;
15)

Defendant COSBY is an individual who was residing in or visiting the County of Los

Angeles when the acts occurred.

Defendant COSBY may now he a resident of the State of

California or another state;

16)

Plaintiff is informed and believes Defendant HEFNER is a resident of the County of Los

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Angeles and the State of California when the acts occurred.

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17)

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captioned court.

The sum total of all the claims meets and exceeds the jurisdictional limits of the above -

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14

COUNT ONE - (By Plaintiff for Sexual Battery against Defendant

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William Henry Cosby.)

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18)

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complaint;

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19)

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unwanted touching and contact of an intimate and sexual nature against Plaintiff;

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20)

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(for purposes of this complaint the term "foreign substances" shall refer to any alcohol, fluid,

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drug or other substance which is administered unknowingly and unwanted) to Plaintiff were

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malicious, fraudulent, deceitful and oppressive and performed to prevent Plaintiffs consent;

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21)

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by his greater age, and because of Defendant's act of providing alcohol and or a foreign

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substance to Plaintiff (possibly at the age of minority), and because of Plaintiffs resulting

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unconsciousness, Plaintiff was unable to and did not give meaningful consent to the

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Plaintiff incorporates by reference as fully set forth, Paragraphs I through 17 of this

The acts of Defendant COSBY were intentional and performed to cause an offensive and

Additionally, Defendant COSBY's acts of providing alcohol and or a foreign substance

Because of Defendant Cosby's status as a celebrity and position of authority as an adult

4
Complaint

or

aforementioned acts of Defendant COSBY;

22)

sustained serious and permanent injuries to her person, all to her damage in an amount to be

shown according to proof, and in an amount no less than the jurisdictional limits of this Court;

23)

compelled to employ the assistance of medical and or mental health professionals, facilities and

services, and Plaintiff is informed and believes that she will need continuing treatment in the

future for an indefinite period and will incur additional damages to be shown according to proof.

Additionally, Plaintiff is informed and believes as a result of the acts of the Defendant COSBY,

As a direct legal and proximate result of the acts of Defendant COSBY, Plaintiff has

As a direct legal and proximate result of the acts of Defendant COSBY, Plaintiff was

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Plaintiff's career, employment, reputation and future prospects have caused her additional

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damages to be shown according to proof;

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24) Plaintiff is informed and believes that the acts by Defendant COSBY against Plaintiff

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were carried out with a malicious and conscious disregard towards Plaintiff, and as such

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constitute oppression, fraud or malice pursuant to California Civil Code Section 3294, entitling

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Plaintiff in an appropriate amount to punish and set an example of Defendant COSBY;

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25)

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forthwith;

Plaintiff will provide the necessary certificates of merit pursuant to the code and her claim

COUNT TWO - (By Plaintiff for Gender Violence against Defendant

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William Henry Cosby.)

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20

26)

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complaint;

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27)

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under the code, the legislature has found that gender violence disproportionately harms women,

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such as Plaintiff;

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28)

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force and performed to cause a physical intrusion or invasion of a sexual nature under coercive

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conditions;

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Plaintiff incorporates by reference as fully set forth, Paragraphs 1 through 25 of this

Plaintiff has standing under Civil Code Section 52.4. Although all persons are protected

The acts of Defendant COSBY were forceful, intentional and criminal by use of physical

5
Complaint

29)

Additionally, Defendant. COSBY's acts of providing alcohol and or a foreign substance

to Plaintiff were coercive, malicious, fraudulent, deceitful and oppressive and performed to

prevent Plaintilrs consent;

30)

by his greater age, and because of Defendant's act of providing alcohol and or a foreign

substance to Plaintiff (possibly at the age of minority), and because of Plaintiffs resulting

unconsciousness, Plaintiff was unable to and did not give meaningful consent to the

aforementioned acts of Defendant COSBY;

31)

Because of Defendant. Cosby's status as a celebrity and position of authority as an adult or

As a direct legal and proximate result of the acts of Defendant COSBY, Plaintiff has

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sustained serious and permanent injuries to her person, all to her damage in an aMOUnt to be

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shown according to proof, and in an amount no less than the jurisdictional limits of this Court;

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32)

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were carried out with a malicious and conscious disregard towards Plaintiff, and as such

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constitute oppression, fraud or malice pursuant to California Civil Code Section 3294, entitling

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Plaintiff in an appropriate amount to punish and set an example of Defendant COSBY;

Plaintiff is informed and believes that the acts by Defendant COSBY against Plaintiff

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COUNT THREE - (By Plaintiff for Intentional Infliction of

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Emotional Distress against Defendant William 1-lenry Cosby.),

Plaintiff incorporates by reference as fully set forth, Paragraphs] through 31 of this

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33)

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complaint;

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34)

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also touching and molesting Plaintiff were disgusting, despicable.

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touched and molested Plaintiff but removed her and his clothing without Plaintifrs consent and

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while known to him she was unconscious and incapable of consenting to such outrageous

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conduct. This conduct was so extreme it is beyond all bounds of decency tolerated by society;

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35)

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young age, and tlic fact that she was forcibly incapacitated by Defendant's act of providing the

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alcohol or substance causing Plaintiffs unconsciousness.

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Defendant COSBY's acts of providing alcohol and or a foreign substance or drug and
Defendant not only

Defendant COSBY knew or should have known Plaintiff was vulnerable because of her

6
Complaint

Defendant COSBY abused his

1 position as a celebrity and his greater age and wisdom over Plaintiff and intentionally or
2

recklessly knew or should of known these acts were outrageous and would cause severe harm to

Plaintiff;

36)

Plaintiff, Plaintiff has suffered severe stress, enduring emotional harm and loss of income;

37)

fraudulent and oppressive manner pursuant to California Civil Code Section 3294, entitling

Plaintiff in an appropriate amount to punish and set an example of Defendant COSBY;

Because of the result of Defendant's knowing and intentional outrageous acts against

Defendant's actions were reprehensible and were done in a malicious, deceitful,

COUNT FOUR - (By Plaintiff for Negligent Infliction of

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10

Emotional Distress against Defendants

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William Henry Cosby and Hugh Marston Hefner.)

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38)

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complaint;

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39)

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to their home to make sure that no foreseeable harm would come to her at this event or from

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conditions at the residence;

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40)

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or to have non-consensual sex or molestation with an adult. Defendant HEFNER had a duty to

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not provide alcohol or substances to minors or adults under age 21;

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41)

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possibly minor children to his residence, and providing alcoholic beverages and or foreign

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substances was negligent at the very least.

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introducing Defendant COSBY, the Defendant HEFNER knew or should have known had a

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history of severe and serial sexual battery and or possibly rape of women was negligent at the

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very least, and Defendant HEFNER knew or should have known such actions would lead to

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harm of his invitees and Plaintiff;

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42)

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Plaintiff incorporates by reference as fully set forth, Paragraphs l through 36 of this

Defendants HEFNER and COSBY and both of them had a duty to Plaintiff by inviting her

Furthermore, Defendant COSBY had a legal duty to not engage in sex or molest a minor

Defendant HEFNER's actions of inviting and hosting young and impressionable and

Additionally, his act of inviting or housing and

Defendant COSBY's acts of providing alcohol and or a foreign substance or drug and
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Complaint

also touching and molesting Plaintiff were disgusting, despicable.

COSBY knew or should have known such conduct was likely to harm Plaintiff;

43)

Defendant COSBY, providing a private bedroom for Plaintiff to be harmed and providing

alcohol and substances to Plaintiff under the age of 21 years, Defendant HEFNER caused harm

to Plaintiff;

44)

substance to Plaintiff and subsequently touching and molesting Plaintiff without her consent,

Additionally, Defendant.

As a direct and proximate result of Defendant HEFNER inviting, introducing Plaintiff to

As a direct and proximate result of Defendant COSBY proving alcohol and or a foreign

Defendant COSBY caused harm to Plaintiff;

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45)

Defendants HEFNER and COSI3Y knew or should have known Plaintiff was vulnerable

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because of her young age, and the fact that their negligence was likely to cause serve and

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enduring harm to her;

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46)

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Plaintiff, Plaintiff has suffered severe stress, enduring emotional harm and loss of income; ail to

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her damage in an amount to be shown according to proof, and in an amount no less than the

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jurisdictional limits of this Court;

Because of the result of Defendant's knowing and intentional outrageous acts against

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COUNT FIVE- (By Plaintiff for Conspiracy to commit Sexual

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Battery and Gender Violence against Defendants

William Henry Cosby and Hugh Marston Hefner.)

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20

47)

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complaint;

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48)

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conspired to host parties, invite minors or young adults under the age of 21 years, provide them

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with alcohol and or foreign substances.

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have known that Defendant COSI3Y over the years had a propensity for intoxicating and or

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drugging young women and taking advantage of them sexually and against their will or while

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they were unconscious;

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Plaintiff incorporates by reference as fully set forth, Paragraphs 1 through 46 of this

In 2008 Defendants HEFNER and COSBY and both knowingly and willfully agreed and

Additionally, Defendant. HEFNER knew or should

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Complaint

Similarly, Defendant COSBY is currently being sued or has had claims made against

1
2

him for hosting parties and or drugging young ladies in the 1970's such as Charlotte Fox, Judith

Huth, and Marcella Tate at the Playboy Mansion. Accordingly, Defendant HEFNER was

familiar with Defendant COSBY's habit and act of intoxicating young women and spending the

night with them while at his residence;

49)

agreement, whether explicit or implicit, and the conspiracy.

arrived at the Playboy Mansion, Defendant HEFNER introduced them to Defendant COSBY

and COSBY suggested that they have alcoholic drinks.

Defendants and each of them did acts and things herein alleged, in furtherance of the
When Plaintiff and her friend first

COSBY then retrieved, made or had

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the drinks prepared in anticipation and preparation for the sexual battery or molestation.

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Defendant HEFNER then suggested Plaintiff use a bedroom which would allow Defendant

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COSBY to secret away Plaintiff and molest her;

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50)

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with alcohol, introducing them Defendant COSBY and allowing Defendant COSBY to remove

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Plaintiff in a semi-conscious state to a bedroom, encouraged, aided, ratified and adopted the acts

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of Defendant COSBY;

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51)

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sustained serious and permanent injuries to her person, all to her damage in an amount to be

19

shown according to proof, and in an amount no less than the jurisdictional limits of this Court;

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52) Plaintiff is informed and believes that the acts by Defendant COSBY against Plaintiff

21

were carried out with a malicious and conscious disregard towards Plaintiff, and as such

22

constitute oppression, fraud or malice pursuant to California Civil Code Section 3294, entitling

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Plaintiff in an appropriate amount to punish and set an example of Defendant COSBY.

Defendant HEFNER, by inviting young, underage ladies to his home, providing them

As a direct legal and proximate result of the acts of Defendant COSBY, Plaintiff has

ALLEGATION OF DAMAGES

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25

53)

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have directly damaged Plaintiff in the amount no less than the jurisdictional limits of the Court

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and to be shown by proof;

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Defendants failure to perform their obligations and or their intentional and reckless acts

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Complaint

54)

injuries to her person. These acts were carried out with a malicious and conscious disregard

towards Plaintiff and as such constitute oppression, fraud or malice, entitling her to punitive

damages to be shown by proof;

Defendants' acts and both of them has caused Plaintiff sustained serious and permanent

PRAYER FOR RELIEF- ALL COUNTS

55)

fully set forth below;

56)

Defendants in favor of Plaintiff in an amount according to proof at trial, but not less than the

WHEREFORE, Plaintiff prays for judgment against Defendants and each of them, as more

(Damages for Actual Loss)

That this Court award damages for actual loss against

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jurisdictional amount of the Court;

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57)

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of plaintiff in the sum of unspecified amounts by reason of Defendants' oppression, fraud or

13

malice to be proved at time of trial (Counts 1,2,3 and 5 only);

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58)

For interest, if any, be awarded to Plaintiff;

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59)

That costs of this action be awarded to Plaintiff;

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60)

That this Court grant such other and further relief as it shall deem just.

(Punitive Damages)

That this Court award punitive damages against defendant in favor

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Dated:

By:
Kevin J. Kensik, Esq.
Law Office of Kevin J. Kensik
609 Deep Valley Drive
Suite 31()
Rolling Hills Estates, CA. 90274
SI3N 206585
310-891-2300
Local Counsel for Plaintiff
Chloe Goins

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//
//

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Complaint

Dated:

By:

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2)
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2 .7

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Complaint

Sp, nce . Kuvin, Esq.

Law Ofc. of Craig Goldenfarb, PA.
1800 S. Australian Ave.
Suite 400
West Palm Beach, CA. 33409
FIa. SBN. 89737
(561) 697-4440
Attorney for Plaintiff
Chloe Goins
Pro flac Vice Appl. Pending