2of USADA, with his principal place of business at 5555 Tech Center Drive, Suite 200,Colorado Springs, Colorado 80919.
Nature of Action
Mr. Armstrong brings this Complaint against USADA and its CEO, TravisTygart, to prevent imminent violations of
Constitutional and commonlaw 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 hisworld-renowned cycling career.5.
actions demonstrate their belief that USADA is above theUnited States Constitution, above the law, above court review, free from supervisionfrom any person or organization, and even above its own rules. Defendants will no doubttell this Court it has no power or authority either to review their conduct or force USADAto obey the law, obey the Constitution or even obey its own rules. Contrary to
Defendants‘ belief that
USADA answers to no one outside of an arbitration regime it hascreated and has populated with arbitrators who predictably
find in USADA‘s favor, this
Court does indeed
have the power to review USADA‘s conduct.
Over a period of more than two years, and at a cost of millions of dollarsto the American taxpayer, Defendants have targeted Mr. Armstrong in a wide-ranginginvestigation, in concert with the United States Department of Justice
Federal Bureau of Investigation (―FBI‖)
and other federal law enforcement agencies.Among other things, Defendants have relied upon information gathered improperly andcoerced in concert with a Federal Agent, Jeff Novitzsky, who has been described by a
variety of federal courts as having ―callous disregard for the rights of third parties‖ and