{"@context":"https://schema.org","@type":"ImageObject","altText":"HTvyj-uWAAESiya","alternateName":"HTvyj-uWAAESiya.jpg","alternativeHeadline":"HTvyj-uWAAESiya","caption":"Page 1 Jane Doe Application","contentUrl":"https://lucycraig.blog/media/150/raw","datePublished":"2026-10-09T11:24:10+00:00","description":"Page 1 Jane Doe Application","encodingFormat":"image/jpeg","identifier":"150","isAccessibleForFree":true,"machineReadable":{"json":"https://lucycraig.blog/media/150/index.json","markdown":"https://lucycraig.blog/media/150/index.md"},"name":"HTvyj-uWAAESiya","ocrStatus":"ready","ocrText":"(FILED: NEW YORK COUNTY CLERK 09/16/2026 07:05 PM) ENDESENO.. LOUIOI/ 2026\n\nNYSCEF DOC. NO. 4 RECEIVED NYSCEF: 09/18/2026\n\nSUPREME COURT OF THE STATE OF NEW YORK\nCOUNTY OF NEW YORK\n\nJANE DOE,\n\nPlaintiff,\n\n-against-\nCORNELL UNIVERSITY, INC., CHI PHI CHAPTER\nHOUSE ASSOCIATION, CHI PHI FRATERNITY, INC.,\nCHI PHI EDUCATIONAL TRUST, ALPHA BETA\nHOUSE CORPORATION OF DELTA DELTA DELTA,\nDELTA DELTA DELTA SORORITY, ZAREEN\nENTERPRISE LLC d/b/a MOONIES BAR &\nNIGHTCLUB, MATTHEW INGALLS, JOHNATHAN\nNEWELL, WINSTON LEE, GILLIO LOPES, DIEGO\nSARABIA, SCOTT NORRIS, SCOTT KRETZSCHMAR,\nJOHN DOE (FACULTY), JOHN BOE (ALUMNI), JOHN\nDOES (EXECUTIVE BOARD), and ORAZIO PETITO,\nDefendant.\n\nPlaintiff .: JANE DOE, being duly sworn, affirms the contents of the\nfollowing to be true under penalty of perjury:\n\n1, I am the Plaintiff JANE DOE in this action. I am a victim of sexual abuse, sexual\nassault, and rape.\n\n2. I submit this Affirmation in support of Plaintiff's Order to Show Cause to Proceed via\nPseudonym pursuant to Civil Rights Law 50-b and other supporting authority and case law. I\nrespectfully request that I be permitted to proceed anonymously using the pseudonym in the\nabove-captioned matter and in all publicly filed documents, as well as to enjoin the Defendants\nand their agents from disclosing my name and/or identity to anyone other than their attorneys.\n\n3. I am seeking to proceed anonymously because I was drugged, sexually assault, and\nraped by Defendants MATTHEW INGALLS, JOHNATHAN NEWELL, WINSTON LEE,\nGILLIO LOPES, DIEGO SARABIA, SCOTT NORRIS, and SCOTT KRETZSCHMAR, in\nOctober 2024 within the Xi Chapter of Chi Phi Fraternity\u2019s house located on Cornell University\u2019s\ncampus.\n\n4.1 am seeking compensation from the individual defendants for the heinous sexual abuse\nI suffered, as well as against the institutional defendants for allowing, enabling, encouraging,\naiding, and abetting said abuses to occur.\n\n5. I am seeking to shield my identity from the stigma associated with the sexual assault\nand rape that I suffered. I strongly believe that proceeding in this matter henceforth via a\npseudonym is in my best interests.\n\n6, The risk of exposing my identity is particularly acute here as I was raped by multiple\ndefendants while attending Cormell University as a full-time undergraduate student. I have since\nstopped attending Cornell University because of the subject incident.\n\n7. What happened to me was devastating and humiliating. I fear that such details of the\nsubject assaults being made public would bring further shame to not only myself, but to my\nfamily as well.\n\n8. I fear that being identified by name in this lawsuit will hinder my social life and career.\nExposing my identity will negatively affect my relationships, as these people will view me\ndifferently after discovering such personal information about me through a public filing.\nAttaching my name to this lawsuit may permanently tarnish my reputation, one that I have\n\n1, BE 2\n","text":"(FILED: NEW YORK COUNTY CLERK 09/16/2026 07:05 PM) ENDESENO.. LOUIOI/ 2026\n\nNYSCEF DOC. NO. 4 RECEIVED NYSCEF: 09/18/2026\n\nSUPREME COURT OF THE STATE OF NEW YORK\nCOUNTY OF NEW YORK\n\nJANE DOE,\n\nPlaintiff,\n\n-against-\nCORNELL UNIVERSITY, INC., CHI PHI CHAPTER\nHOUSE ASSOCIATION, CHI PHI FRATERNITY, INC.,\nCHI PHI EDUCATIONAL TRUST, ALPHA BETA\nHOUSE CORPORATION OF DELTA DELTA DELTA,\nDELTA DELTA DELTA SORORITY, ZAREEN\nENTERPRISE LLC d/b/a MOONIES BAR &\nNIGHTCLUB, MATTHEW INGALLS, JOHNATHAN\nNEWELL, WINSTON LEE, GILLIO LOPES, DIEGO\nSARABIA, SCOTT NORRIS, SCOTT KRETZSCHMAR,\nJOHN DOE (FACULTY), JOHN BOE (ALUMNI), JOHN\nDOES (EXECUTIVE BOARD), and ORAZIO PETITO,\nDefendant.\n\nPlaintiff .: JANE DOE, being duly sworn, affirms the contents of the\nfollowing to be true under penalty of perjury:\n\n1, I am the Plaintiff JANE DOE in this action. I am a victim of sexual abuse, sexual\nassault, and rape.\n\n2. I submit this Affirmation in support of Plaintiff's Order to Show Cause to Proceed via\nPseudonym pursuant to Civil Rights Law 50-b and other supporting authority and case law. I\nrespectfully request that I be permitted to proceed anonymously using the pseudonym in the\nabove-captioned matter and in all publicly filed documents, as well as to enjoin the Defendants\nand their agents from disclosing my name and/or identity to anyone other than their attorneys.\n\n3. I am seeking to proceed anonymously because I was drugged, sexually assault, and\nraped by Defendants MATTHEW INGALLS, JOHNATHAN NEWELL, WINSTON LEE,\nGILLIO LOPES, DIEGO SARABIA, SCOTT NORRIS, and SCOTT KRETZSCHMAR, in\nOctober 2024 within the Xi Chapter of Chi Phi Fraternity\u2019s house located on Cornell University\u2019s\ncampus.\n\n4.1 am seeking compensation from the individual defendants for the heinous sexual abuse\nI suffered, as well as against the institutional defendants for allowing, enabling, encouraging,\naiding, and abetting said abuses to occur.\n\n5. I am seeking to shield my identity from the stigma associated with the sexual assault\nand rape that I suffered. I strongly believe that proceeding in this matter henceforth via a\npseudonym is in my best interests.\n\n6, The risk of exposing my identity is particularly acute here as I was raped by multiple\ndefendants while attending Cormell University as a full-time undergraduate student. I have since\nstopped attending Cornell University because of the subject incident.\n\n7. What happened to me was devastating and humiliating. I fear that such details of the\nsubject assaults being made public would bring further shame to not only myself, but to my\nfamily as well.\n\n8. I fear that being identified by name in this lawsuit will hinder my social life and career.\nExposing my identity will negatively affect my relationships, as these people will view me\ndifferently after discovering such personal information about me through a public filing.\nAttaching my name to this lawsuit may permanently tarnish my reputation, one that I have\n\n1, BE 2\n","thumbnailUrl":"https://lucycraig.blog/media/150/raw","transcriptStatus":"not_applicable","transcriptText":"","url":"https://lucycraig.blog/media/150"}