New York prosecutors on Tuesday charged Cuba Gooding Jr. with groping two separate women in the past two years. The 51-year-old actor was indicted on charges of forcible touching and third-degree sexual assault.

According to a court memorandum from the Manhattan DA’s office obtained by Variety, one of the incidents occurred at TAO nightclub in October 2018 and the other happened at Magic Hour Rooftop Bar in June 2019. Gooding has pled not guilty.

In addition to the two New York women, 12 additional women will testify that he has groped, bitten or licked them without their consent and after little or no prior interaction, according to the memo. Gooding is not being charged for these incidents, which took place in bars and clubs across the country. But prosecutors say this evidence establishes a pattern of sexually predatory behavior, proving that the two New York incidents aren’t innocent misunderstandings.

The litany of alleged incidents, the oldest of which dates back to 2001, proves “the defendant’s intent to gratify himself sexually...and lack of mistake or accident on his part,” Manhattan ADA Jenna Long wrote in the court memorandum, which details a total of 14 alleged incidents of sexual harassment or assault.

One of the witnesses said that in 2006, Gooding—having never spoken to her in his life— approached her from behind at a bar in Hollywood and bit her bare shoulder. Allegedly, she asked him if he’d bitten her, and he shrugged, then when she turned back away from him, he bit her again and thrust his pelvis against her leg.

In February 2011, Gooding allegedly grabbed a woman’s arm as she walked past him at a bar in Los Angeles—again, a total stranger—and reached inside her shirt to squeeze her bare breast. In November 2013, the memo states that he approached another total stranger who was at the Chatwal Hotel bar in New York for a work event and licked her neck. In 2003, another woman said she and Gooding were posing for a picture together at Yard House in Long Beach, CA, when he allegedly squeezed her buttocks and said something to the effect of “you’ve got a good piece of ass.”

Long wrote, “Looking at these incidents, it is clear...that he does not mistakenly believe the acts are consensual, and that they are done for the purpose of gratifying his own sexual desire, as well as for the purpose of degrading and abusing the women he has targeted.”

Gooding denied the veracity of all the claims through his lawyer, who told TMZ, “Cuba denies all of these allegations. This is a typical scenario in which random people come out of the woodwork to accuse a celebrity who has already been charged. They have no credibility because Cuba was not charged with any of those allegations.”

Gooding is due back in court December 13.