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(FILED: NEW YORK COUNTY CLERK 09/16/2026 07:05 PM) ENDESENO.. LOUIOI/ 2026 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 09/18/2026 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK JANE DOE, Plaintiff, -against- CORNELL UNIVERSITY, INC., CHI PHI CHAPTER HOUSE ASSOCIATION, CHI PHI FRATERNITY, INC., CHI PHI EDUCATIONAL TRUST, ALPHA BETA HOUSE CORPORATION OF DELTA DELTA DELTA, DELTA DELTA DELTA SORORITY, ZAREEN ENTERPRISE LLC d/b/a MOONIES BAR & NIGHTCLUB, MATTHEW INGALLS, JOHNATHAN NEWELL, WINSTON LEE, GILLIO LOPES, DIEGO SARABIA, SCOTT NORRIS, SCOTT KRETZSCHMAR, JOHN DOE (FACULTY), JOHN BOE (ALUMNI), JOHN DOES (EXECUTIVE BOARD), and ORAZIO PETITO, Defendant. Plaintiff .: JANE DOE, being duly sworn, affirms the contents of the following to be true under penalty of perjury: 1, I am the Plaintiff JANE DOE in this action. I am a victim of sexual abuse, sexual assault, and rape. 2. I submit this Affirmation in support of Plaintiff's Order to Show Cause to Proceed via Pseudonym pursuant to Civil Rights Law 50-b and other supporting authority and case law. I respectfully request that I be permitted to proceed anonymously using the pseudonym in the above-captioned matter and in all publicly filed documents, as well as to enjoin the Defendants and their agents from disclosing my name and/or identity to anyone other than their attorneys. 3. I am seeking to proceed anonymously because I was drugged, sexually assault, and raped by Defendants MATTHEW INGALLS, JOHNATHAN NEWELL, WINSTON LEE, GILLIO LOPES, DIEGO SARABIA, SCOTT NORRIS, and SCOTT KRETZSCHMAR, in October 2024 within the Xi Chapter of Chi Phi Fraternity’s house located on Cornell University’s campus. 4.1 am seeking compensation from the individual defendants for the heinous sexual abuse I suffered, as well as against the institutional defendants for allowing, enabling, encouraging, aiding, and abetting said abuses to occur. 5. I am seeking to shield my identity from the stigma associated with the sexual assault and rape that I suffered. I strongly believe that proceeding in this matter henceforth via a pseudonym is in my best interests. 6, The risk of exposing my identity is particularly acute here as I was raped by multiple defendants while attending Cormell University as a full-time undergraduate student. I have since stopped attending Cornell University because of the subject incident. 7. What happened to me was devastating and humiliating. I fear that such details of the subject assaults being made public would bring further shame to not only myself, but to my family as well. 8. I fear that being identified by name in this lawsuit will hinder my social life and career. Exposing my identity will negatively affect my relationships, as these people will view me differently after discovering such personal information about me through a public filing. Attaching my name to this lawsuit may permanently tarnish my reputation, one that I have 1, BE 2