UNITED STATES DISTRICT COURTWESTERN DISTRICT OF TEXASAUSTIN DIVISION
Lance Armstrong
Plaintiff
,
v
.United States Anti-Doping Agencyand Travis Tygart, in his official capacity asChief Executive Officer of theUnited States Anti-Doping Agency
Defendants
.Civ. Action No. ______.
COMPLAINT AND JURY DEMAND
Comes now, Plaintiff Lance Armstrong, by his undersigned counsel, and statesand alleges as follows:
Parties
1.Plaintiff Lance Armstrong, 300 West 6th Street, Suite 2150Austin, Texas, is a citizen of Travis County, Texas. He resides inAustin, Texas.2.Defendant United States Anti-Doping Agency (“USADA”)is a Colorado Corporation with its principal place of business at5555 Tech Center Drive, Suite 200, Colorado Springs, Colorado80919. USADA is the national anti-doping organization for theUnited States and manages the United States’ anti-doping testing
program for National Governing Bodies for Olympic,Paralympic, and Pan-American Games Sports.3.Defendant Travis Tygart is a resident of the state of Colorado. Mr. Tygart is named as a Defendant in his officialcapacity as the Chief Executive Officer (“CEO”) of USADA,with his principal place of business at 5555 Tech Center Drive,Suite 200, Colorado Springs, Colorado 80919.
Nature of Action
4.Mr. Armstrong brings this Complaint against USADA andits CEO, Travis Tygart, to prevent imminent violations of Mr.Armstrong’s Constitutional and common law due process rights, by which the Defendants would strip Mr. Armstrong of hislivelihood, his seven
Tour de France
titles, and the many other honors he has won in his world-renowned cycling career.5.Defendants’ actions demonstrate their belief that USADA isabove the United States Constitution, above the law, above courtreview, free from supervision from any person or organization,and even above its own rules. Defendants will no doubt tell thisCourt it has no power or authority either to review their conductor force USADA to obey the law, obey the Constitution or evenobey its own rules. Contrary to Defendants’ belief that USADAanswers to no one outside of an arbitration regime it has created2
and has populated with arbitrators who predictably find inUSADA’s favor, this Court does indeed have the power to reviewUSADA’s conduct.6.Over a period of more than two years, and at a cost of millions of dollars to the American taxpayer, Defendants havetargeted Mr. Armstrong in a wide-ranging investigation, inconcert with the United States Department of Justice (“DOJ”),the Federal Bureau of Investigation (“FBI”) and other federal lawenforcement agencies. Among other things, Defendants haverelied upon information gathered improperly and coerced inconcert with a Federal Agent, Jeff Novitzsky, who has beendescribed by a variety of federal courts as having “callousdisregard for the rights of third parties” and engaging in“unreasonable” tactics amounting to “harassment.” One federal judge even inquired of Agent Novitsky’s efforts, “Whatever happened to the Fourth Amendment? Was it repealedsomehow?”7.Defendant Tygart shares with Agent Novitsky a well- publicized obsession with “getting” Mr. Armstrong. DefendantTygart evidently believes that USADA needs to bring a big caseagainst a “big fish” to justify its existence. One of, if not the primary, goals of this effort is to convince the United States3
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