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Armstrong Final Complaint 070912

Armstrong Final Complaint 070912

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Published by: Deadspin on Jul 09, 2012
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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 2150 Austin, Texas,is a citizen of Travis County, Texas. He resides in Austin, Texas.2.
 
Defendant United States Anti-
Doping Agency (―USADA‖) is a Colorado
Corporation with its principal place of business at 5555 Tech Center Drive, Suite 200,Colorado Springs, Colorado 80919. USADA is the national anti-doping organization forthe United States and manages
the United States‘ anti
-doping testing program forNational Governing Bodies for Olympic, Paralympic, and Pan-American Games Sports.3.
 
Defendant Travis Tygart is a resident of the state of Colorado. Mr. Tygartis named as a Defendant in his official capacity as the Chief Executive Officer
(―CEO‖)
 
 2of 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 and its CEO, TravisTygart, to prevent imminent violations of 
Mr. Armstrong‘s
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.
 
Defendants‘
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.
6.
 
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
(―DOJ‖)
, the
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
 
 3
engaging in ―unreasonable‖ tactics amounting to ―harassment.‖ One federal j
udge eveninquired of Agent Novitsky
‘s
efforts
, ―Whatever happened to the Fourth Amendment?Was it repealed somehow?‖
7.
 
Defendant Tygart shares with Agent Novitsky a well-publicized obsession
with ―getting‖
Mr. Armstrong. Defendant Tygart evidently believes that USADA needs
to bring a big case against a ―big fish‖ to justify its existence.
One of, if not the primary,goals of this effort is to convince the United States government to continue and increasethe tens of millions of dollars of unsupervised grants that the government alreadyprovides to USADA. In furtherance of this effort, Defendant Tygart and Agent Novitskyoffered other cyclists corrupt inducements
 — 
offers some cyclists could not refuse
 — 
toimplicate Mr. Armstrong in exchange for saving
the cyclists‘
careers. If they refused todo so, USADA would work to ruin their careers, just as it is now attempting to end
Mr. Armstrong‘s career.
 8.
 
Despite Agent Novitsky
‘s and
Defendant
Tygart‘s conduct, the
federalauthorities ultimately decided not to prosecute Mr. Armstrong. This is not surprising.After all, Mr. Armstrong has passed every drug test ever administered to him in hiscareer
 — 
a total of 500 to 600 tests. Those tests include a tremendous number of addi
tional tests by USADA over the past several years as part of its ―target testing‖
designed to determine if Mr. Armstrong was cheating or competing fairly. In its multi-
million dollar zeal to ―get‖ Mr. Armstrong, USADA has been
unable to turn up a singlepositive drug test from Mr. Armstrong. Given that Mr. Armstrong is believed to have
 been given more drug tests than any other athlete in history, it is a testament to USADA‘s

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