161704_2026_Jane_Doe_v_Cornell_University_Inc_et_al_DEMAND_FOR_CHANGE_O_32

--- Page 1 --- SUPREMECOURTOFTHESTATEOFNEWYORK COUNTYOFNEWYORK JANEDOE, DEFENDANT'S DEMANDFORCHANGE Plaintiff, OFVENUE -against- Index No. 161704/2026 CORNELLUNIVERSITY, INC., CHI PHI CHAPTERHOUSEASSOCIATION,CHI PHI FRATERNITY,INC., CHI PHI EDUCATIONALTRUST, ALPHABETA HOUSECORPORATIONOFDELTA DELTADELTA,DELTADELTADELTA SORORITY,ZAREENENTERPRISE, LLC, d/b/a MOONIESBARAND NIGHTCLUB,MATTHEW INGALLS, JOHNATHAN NEWELL,WINSTON LEE,GILLIO LOPES,DIETO SARABIA, SCOTTNORRIS, SCOTT KRETZSCHMAR,JOHNDOE (FACULTY), JOHNDOE(ALUMNI), JOHNDOES(EXECUTIVEBOARD), and ORAZIOPETITO, Defendants. S I RS : PLEASETAKENOTICE, that Defendant ZAREENENTERPRISE, LLC, d/b/a MOONIES BARANDNIGHTCLUB(hereinafter, "Zareen") hereby demands, pursuant to Section 503, Section 510, and Rule 511 of the NewYork Civil Practice Law and Rules (CPLR), that the place of trial of this action be changed from the County of NewYork to the County of Tompkins. The grounds for this Demand are that the County of NewYork designated by Plaintiff is an improper county for the place of trial, and that the County of Tompkins is the proper county because: FILED: NEW YORK COUNTY CLERK 10/06/2026 01:37 PM INDEX NO. 161704/2026 NYSCEF DOC. NO. 32 RECEIVED NYSCEF: 10/06/2026 1 of 3 --- Page 2 --- 1. Upon information and belief, none of the parties resided in NewYork County at the time of the commencementof this action pursuant to CPLR§ 503(a). 2. The targets of Plaintiffs claims, including defendants CORNELLUNIVERSITY, INC., CHI PHI CHAPTERHOUSEASSOCIATION,CHI PHI FRATERNITY, INC., CHI PHI EDUCATIONALTRUST,ALPHABETAHOUSECORPORATIONOF DELTADELTADELTA, DELTADELTADELTASORORITY,and ZAREEN ENTERPRISE, LLC, d/b/a MOONIESBARANDNIGHTCLUB, are all located, domiciled, or maintain their principal places of business and operations within the County of Tompkins. 3. All of the alleged occurrences, incidents, transactions, and acts complained of in Plaintiffs Second Amended Verified Complaint took place entirely within the City of Ithaca, NewYork, which is located within the County of Tompkins. 4. Virtually all material non-party witnesses, local law enforcement personnel, medical responders, and business records associated with the claims reside or are located in Tompkins County, meaning the convenience of material witnesses and the ends ofjustice will be promoted by changing the venue to Tompkins County pursuant to CPLR§ 510(3). PLEASETAKEFURTHERNOTICE, that pursuant to CPLRRule 511(b), you are required to serve your written consent to the change of venue within five (5) days after service of this Demand upon you. In the event that you fail to serve such consent, a motion will be made to the Court to change the place of trial as demandedherein, and Defendant will seek costs and disbursements associated with the motion. Dated: October 5, 2026 Ithaca, NewYork Yours, etc., THELAMALAWFIRM, LLP FILED: NEW YORK COUNTY CLERK 10/06/2026 01:37 PM INDEX NO. 161704/2026 NYSCEF DOC. NO. 32 RECEIVED NYSCEF: 10/06/2026 2 of 3 --- Page 3 --- o Lan , Esq. A eys for Defendant Zareen Enterprise, LLC, d/b/a Moonies Bar and Nightclub 2343 N. Triphammer Rd. Ithaca, NewYork 14850 (607) 275-3425 [email protected] TO: Thomas P. Giuffra, Esq. VIA NYSCEF FILED: NEW YORK COUNTY CLERK 10/06/2026 01:37 PM INDEX NO. 161704/2026 NYSCEF DOC. NO. 32 RECEIVED NYSCEF: 10/06/2026 3 of 3