{"@context":"https://schema.org","@type":"DigitalDocument","altText":"LucyCraig.blog Motion For Vacatur","alternateName":"Motion_For_VACATUR_1.pdf","caption":"LucyCraig.blog Motion For Vacatur","contentUrl":"https://lucycraig.blog/media/285/raw","datePublished":"2026-10-12T18:05:41+00:00","description":"LucyCraig.blog Motion For Vacatur","encodingFormat":"application/pdf","identifier":"285","isAccessibleForFree":true,"machineReadable":{"json":"https://lucycraig.blog/media/285/index.json","markdown":"https://lucycraig.blog/media/285/index.md"},"name":"Motion_For_VACATUR_1","ocrStatus":"ready","ocrText":"--- Page 1 ---\nSUPREME COURT OF THE STATE OF NEW YORK\u200b\nCOUNTY OF NEW YORK \u2014 PART 35 \n \nJANE DOE,\u200b\nPlaintiff, \n-against- \nCORNELL UNIVERSITY, INC., CHI PHI \nCHAPTER HOUSE ASSOCIATION, CHI \nPHI FRATERNITY, INC., CHI PHI \nEDUCATIONAL TRUST, ALPHA BETA \nHOUSE CORPORATION OF DELTA \nDELTA DELTA, DELTA DELTA DELTA \nSORORITY, ZAREEN ENTERPRISE \nLLC, MATTHEW INGALLS, \nJOHNATHAN NEWELL, WINSTON \nLEE, GILLIO LOPES, DIEGO SARABIA, \nSCOTT NORRIS, SCOTT \nKRETZSCHMAR, JOHN DOE, JOHN \nDOE, JOHN DOES, and ORAZIO \nPETITO,\u200b\nDefendants. \nIndex No. 161704/2026\u200b\nHon. Phaedra F. Perry-Bond, J.S.C.\u200b\nPart 35 \nNONPARTY JANE DOE'S APPLICATION FOR LEAVE TO APPEAR \nPSEUDONYMOUSLY; MOTION FOR ACCESS TO JUDICIAL RECORDS, \nMODIFICATION OR PARTIAL VACATUR OF SUA SPONTE SEALING ORDER; AND \nLIMITED OBJECTION TO FIRST AMENDMENT IMPLICATIONS OF NYSCEF DOC. \nNO. 44 \nProposed Intervenor/Nonparty Movant: \n\u200b\nJane Doe, appearing under the public pseudonym \"JaneDoe1\", individually and in the capacity \nof an administrator of the public commentary website https://lucycraig.blog. \nPRELIMINARY STATEMENT\n\n--- Page 2 ---\n1.\u200b Nonparty Movant Jane Doe, publicly known as \"JaneDoe1,\" respectfully seeks limited \nleave to appear under a pseudonym, to be heard concerning the public's right of access to \njudicial records, and to object to the potentially speech-chilling implications of the \nCourt's October 9, 2026 sua sponte sealing order, NYSCEF Document No. 44. \n2.\u200b Movant is not a plaintiff, defendant, witness, or attorney in the underlying action. Movant \ndoes not seek to adjudicate the allegations between the litigants, interfere with discovery, \nor participate in the merits of the case. \n3.\u200b Movant instead appears as an independent speaker, administrator of a public forum, and \nmember of the public asserting rights protected by the First Amendment to the United \nStates Constitution, Article I, Section 8 of the New York Constitution, and the \nlongstanding presumption of public access to judicial proceedings and records. \n4.\u200b This litigation has become the subject of extraordinary public attention and vigorous \ndebate concerning sexual-assault allegations, the presumption of innocence, institutional \nresponsibility, prosecutorial judgment, media coverage, and the respective rights of \ncomplainants and accused persons. \n5.\u200b Movant administers https://lucycraig.blog, an independently operated website dedicated \nto public discussion of the litigation and related controversies. \n6.\u200b As of the preparation of this submission, according to the website's reported statistics, the \nplatform has accumulated more than 3,000,000 views, 3,000 comments, and 8,000 \nparticipant reactions. Those figures are provided to illustrate the scale of public \nengagement and do not represent a claim that three million distinct individuals have been \nindependently verified. \n7.\u200b The website permits anonymous participation and operates under a policy favoring the \nmaximum lawful freedom of expression. Comments ordinarily become publicly visible \nautomatically. Administrators generally remove spam and content determined to be \nplainly unlawful, rather than censoring contributions because they are unpopular, \noffensive, controversial, or critical of a particular party. \n8.\u200b Users and administrators may contribute records, images, commentary, documents, and \nother materials for public discussion. The platform's editorial policy favors publication \nand retention of lawful materials regardless of viewpoint. \n9.\u200b Movant expressly disputes any proposition that judicial disapproval of public \ncommentary, or concern about the intensity of public disagreement, supplies independent \nauthority to regulate the speech of persons who have never appeared before the Court. \n10.\u200bMovant does not contest that genuine threats, targeted harassment, or malicious \npublication of sensitive residential information may justify lawful intervention. Nor does \nMovant dispute the Court's legitimate interest in protecting an uninvolved family \nreportedly subjected to threats after an erroneous address appeared in a filing. \n11.\u200bThe dispute is instead whether a broadly worded judicial warning directed at unidentified \nnonparties, coupled with restrictions on access to judicial documents, may be understood \n________________________________ \nhttps://lucycraig.blog \nPage: 2 of 11\n\n--- Page 3 ---\nor applied to chill lawful public debate without notice, individualized findings, an \nopportunity to be heard, or constitutionally adequate procedural protections. \n12.\u200bMovant respectfully submits that it may not. \nI. FACTUAL AND PROCEDURAL BACKGROUND \n13.\u200bOn October 9, 2026, the Court entered NYSCEF Document No. 44, styled Sua Sponte \nDecision and Order Directing Sealing of Certain Documents. \n14.\u200bThe order directs the sealing of NYSCEF Documents 1, 6, 7, and 22 and directs the \nplaintiff to refile versions with purported addresses redacted. \n15.\u200bThe Court explains that certain filed documents included address information, including \nan allegedly erroneous residential address associated with an individual who was not \ninvolved in this lawsuit. \n16.\u200bThe Court reports that a former Marine and his family were subjected to threats after that \nerroneous association circulated online. \n17.\u200bMovant condemns genuine threats of violence and harassment against innocent persons \nand does not seek public dissemination of the erroneous residential address. \n18.\u200bHowever, the Court's order extends beyond discussing the mechanics of address \nredaction. It also criticizes the broader climate of online discussion and urges those \ninvolved, including the general public, to reduce the intensity of the controversy. \n19.\u200bOf particular concern is footnote 2, which states: \n\"The Court is mindful that this information is highly likely to \nalready be disseminated on the internet. However, the Court issues \nthis decision and order to do its part in mitigating the risk of harm \nand to caution all involved, whether parties or not, to act \naccordingly.\" \n20.\u200bMovant objects to the ambiguity of this admonition insofar as it could reasonably be \ninterpreted as a warning of judicial consequences against unidentified nonparties for their \nindependent publications, commentary, criticism, or republication of otherwise lawfully \nobtained information. \n21.\u200bThe order identifies no specific act by Movant, makes no factual finding that Movant \nthreatened \nanyone, \nand \ndoes \nnot \nidentify \nany \nparticular \npublication \nby \nhttps://lucycraig.blog or elsewhere as unlawful. \n22.\u200bMovant has not been served with process, joined as a party, provided notice of a proposed \nspeech restriction, or afforded an opportunity to oppose an order directly restricting \nMovant's expressive activities. \n23.\u200bNevertheless, a judicial caution explicitly addressed to nonparties may reasonably \nproduce uncertainty among speakers and publishers concerning whether their continuing \nactivities could expose them to sanctions or contempt proceedings. \n________________________________ \nhttps://lucycraig.blog \nPage: 3 of 11\n\n--- Page 4 ---\n24.\u200bThat uncertainty is particularly consequential where anonymous contributors participate \nin extensive debate about an ongoing judicial controversy. \nII. LEAVE TO APPEAR AS AN ANONYMOUS NONPARTY \n25.\u200bMovant seeks limited participation to challenge the sealing of judicial records and request \nclarification of the October 9 order's scope. \n26.\u200bMovant's interests differ from those of the existing litigants. The parties may be \nprincipally concerned with litigation strategy, personal privacy, potential liability, or \nreputational interests. Movant's concern is the public's independent right to observe, \nreport upon, criticize, and debate judicial proceedings. \n27.\u200bIn Mosallem v. Berenson, 76 A.D.3d 345 (1st Dept. 2010), the Appellate Division \naddressed a journalist's intervention to challenge sealing, recognizing the public's \nsubstantial interest in inspecting judicial records. \n28.\u200bMovant's status as an online publisher or forum administrator does not eliminate those \ninterests. Constitutional protections of speech and public commentary do not depend on \nmembership in an established newspaper, a traditional broadcasting organization, or an \ninstitution approved by litigants. \n29.\u200bMovant seeks permission to use the pseudonym Jane Doe, with \"JaneDoe1\" identifying \nMovant's public online role. \n30.\u200bAnonymous and pseudonymous expression enjoy substantial constitutional protection. \nSee McIntyre v. Ohio Elections Commission, 514 U.S. 334 (1995); Talley v. California, \n362 U.S. 60 (1960). \n31.\u200bMovant recognizes that the right to publish anonymously does not automatically confer a \nright to litigate anonymously. Judicial permission requires consideration of competing \ninterests, including transparency, potential prejudice, confidentiality, and the reasons for \nseeking anonymity. See Anonymous v. Lerner, 124 A.D.3d 487 (1st Dept. 2015). \n32.\u200bMovant requests anonymity because the controversy involves extraordinary public \nhostility, intense scrutiny of online publishers, and a demonstrated risk that individuals \nassociated with this litigation may face unwanted exposure or retaliatory attention. \n33.\u200bMovant's proposed participation presents primarily legal issues and does not require \nadjudication of Movant's personal conduct or credibility. \n34.\u200bPublic identification of Movant would add little to the legal analysis concerning public \naccess or the constitutional limits of court orders, while potentially exposing an \nindependent speaker to unnecessary personal risk. \n35.\u200bMovant is willing to comply with any lawful procedure the Court determines necessary \nfor confidential verification of identity, subject to an appropriate protective order and an \nopportunity to be heard concerning disclosure. \n36.\u200bAccordingly, Movant requests leave to appear pseudonymously for the limited purpose of \npursuing the relief described herein, or alternatively leave to submit a limited nonparty \nbrief under a pseudonym. \n________________________________ \nhttps://lucycraig.blog \nPage: 4 of 11\n\n--- Page 5 ---\nIII. THE PRESUMPTION OF PUBLIC ACCESS REQUIRES NARROWLY TAILORED \nSEALING \n37.\u200bNew York courts recognize a substantial presumption favoring public access to judicial \nrecords. \n38.\u200bUnder 22 NYCRR \u00a7 216.1(a), sealing requires a written finding of good cause identifying \nthe grounds for restricting access, with consideration of the interests of both the public \nand the parties. \n39.\u200bThe First Department has repeatedly emphasized that secrecy is exceptional rather than \nroutine. See Mosallem v. Berenson, 76 A.D.3d 345 (1st Dept. 2010); Danco Laboratories, \nLtd. v. Chemical Works of Gedeon Richter, Ltd., 274 A.D.2d 1 (1st Dept. 2000). \n40.\u200bHere, the Court identified a concrete concern: personal address information reportedly \nused to direct threats against innocent individuals. \n41.\u200bMovant does not ask the Court to disregard that concern. The protection of residential \naddresses and other genuinely sensitive identifying information may constitute good \ncause for limited restrictions. \n42.\u200bHowever, where legitimate privacy interests can be protected through targeted redactions, \nwholesale or continuing exclusion of otherwise public judicial documents warrants \nindependent scrutiny. \n43.\u200bThe Court has already ordered the preparation of redacted versions of the affected filings. \n44.\u200bThat remedy demonstrates the availability of a less restrictive alternative: preserve \nnecessary address redactions while restoring public access to the remaining, \nnonconfidential portions of the documents. \n45.\u200bTo the extent the redacted versions have not been publicly docketed, Movant asks that \nthey be made available promptly, subject to review for additional information whose \ndisclosure would create a demonstrable risk of harm. \n46.\u200bMovant further requests clarification of whether the original documents must remain \nsealed once complete, properly redacted substitutes are available and whether any \nnon-address information is independently asserted to warrant protection. \n47.\u200bMovant does not insist that the Court release erroneous residential information or \ninformation whose disclosure is independently prohibited by law. \n48.\u200bRather, the Court should apply a document-specific, narrowly tailored analysis so that the \npublic does not lose access to substantive court filings merely because discrete \ninformation within them requires protection. \n49.\u200bThe public interest is especially substantial where judicial proceedings have become \ncentral to a national conversation concerning alleged misconduct, institutional \naccountability, due process, reputational harm, and the presumption of innocence. \n50.\u200bThe intensity of that interest strengthens the need for access to reliable judicial records. \nPublicly available filings allow readers to evaluate competing accounts by reference to \nwhat litigants actually submitted rather than relying exclusively on selective media \ndescriptions. \n________________________________ \nhttps://lucycraig.blog \nPage: 5 of 11\n\n--- Page 6 ---\nIV. FOOTNOTE 2 MUST NOT BE CONSTRUED AS A RESTRICTION ON \nPROTECTED NONPARTY SPEECH \n51.\u200bMovant's central constitutional objection concerns footnote 2 and the possibility that its \ninstruction to nonparties to act \"accordingly\" could be interpreted more broadly than the \nactual relief ordered. \n52.\u200bThe First Amendment protects a broad range of public discussion, including criticism of \njudicial proceedings, attorneys, public officials, institutional actors, litigants, and subjects \nof public controversy. \n53.\u200bThat protection does not disappear because commentary is impolite, emotionally charged, \noffensive, or sharply critical. \n54.\u200bIn Snyder v. Phelps, 562 U.S. 443 (2011), the Supreme Court recognized particularly \nstrong protection for expression addressing matters of public concern, even where its \ncontent causes serious distress. \n55.\u200bIn Bridges v. California, 314 U.S. 252 (1941), the Supreme Court addressed the \nconstitutional limits of using contempt powers against publications concerning pending \njudicial proceedings. \n56.\u200bThe present order does not expressly direct Movant or the public to stop speaking. \nMovant acknowledges that limitation and does not characterize footnote 2 as an \nalready-issued injunction against the website. \n57.\u200bNonetheless, Movant respectfully objects to any interpretation under which the footnote \nis treated as a directive enforceable against persons who were not before the Court and \nwhose specific conduct has not been adjudicated. \n58.\u200bThe distinction is critical. A court may condemn threats and explain that existing law \nprohibits particular conduct. It does not follow that the same order may impose undefined \nduties of restraint upon every member of the public discussing the litigation. \n59.\u200bAny order purporting to bind nonparties must rest on an applicable legal basis and satisfy \nrelevant requirements of notice, scope, jurisdiction, and due process. \n60.\u200bMovant therefore requests an express clarification that footnote 2 is advisory rather than \ninjunctive and does not, by itself, create an enforceable restriction on independent \nnonparty speech. \n61.\u200bSpecifically, the Court should confirm that the October 9 order does not prohibit lawful \npublication of opinions, criticism of the proceedings, discussion of publicly available \nallegations, examination of evidence lawfully obtained, or public debate concerning the \nconduct of litigants and attorneys. \n62.\u200bThe Court should further clarify that independent speakers are not subject to contempt \nmerely because their editorial judgments conflict with a party's preferred narrative or \nbecause their commentary is considered inflammatory, distasteful, or one-sided. \n63.\u200bThis requested clarification would not immunize threats, harassment, unlawful disclosure, \ndefamatory statements, or other conduct that may independently give rise to legal \nliability. \n________________________________ \nhttps://lucycraig.blog \nPage: 6 of 11\n\n--- Page 7 ---\n64.\u200bIt would simply preserve the distinction between enforceable legal restrictions and \nconstitutionally protected expression. \nV. THE PUBLIC CONTROVERSY HAS BEEN INTENSIFIED BY EXTRAJUDICIAL \nADVOCACY \n65.\u200bThis dispute has not unfolded solely in court filings. \n66.\u200bMovant contends that counsel associated with the plaintiff's position have participated in \nsubstantial public-facing advocacy concerning the allegations, the litigation, and the \npublic narrative surrounding the case. \n67.\u200bMovant further asserts, based on information Movant seeks an opportunity to \nsubstantiate, that efforts have been made to persuade online platforms, media \norganizations, and media executives, reportedly including Harvey Levin of TMZ, to limit \nor alter unfavorable coverage. \n68.\u200bThese assertions are presented as Movant's allegations and concerns, not as established \njudicial findings. Movant does not suggest that an attorney's lawful media advocacy or a \nlawful request to remove genuinely unlawful material is itself prohibited. \n69.\u200bNevertheless, when litigation participants seek public support, encourage media \ncoverage, or press their accounts before a national audience, opposing viewpoints and \nindependent scrutiny become no less important. \n70.\u200bA litigant or attorney cannot fairly demand the benefits of public advocacy while \nasserting that competing narratives must be suppressed merely because they challenge the \npreferred account. \n71.\u200bThe proper response to disputed public claims generally lies in rebuttal, disclosure of \naccurate information, and adversarial examination\u2014not presumptive silencing of \nopposing speakers. \n72.\u200bThe First Amendment does not reserve public commentary on pending litigation to \nparties, attorneys, institutional newsrooms, or speakers supporting a particular viewpoint. \n73.\u200bMovant submits that online forums permitting competing opinions serve a legitimate \npublic function when they allow readers to examine inconsistent factual assertions, \ncriticize coverage, and assess the available judicial record. \n74.\u200bThat function may be uncomfortable for the participants. But public discomfort, standing \nalone, is not a constitutional basis for suppressing lawful speech. \nVI. ANONYMOUS PUBLIC PARTICIPATION IS NOT SYNONYMOUS WITH \nMISCONDUCT \n75.\u200bThe website operated by Movant permits anonymous comments, reactions, and \nuser-contributed media. \n________________________________ \nhttps://lucycraig.blog \nPage: 7 of 11\n\n--- Page 8 ---\n76.\u200bThe platform generally publishes comments without advance editorial screening and \nseeks to moderate on a content-neutral basis, addressing spam and plainly unlawful \nmaterial rather than disfavored viewpoints. \n77.\u200bMovant recognizes that a policy of immediate publication does not eliminate potential \nlegal duties arising from specific content or valid court orders lawfully applicable to \nparticular persons. \n78.\u200bNevertheless, the existence of anonymous comments or controversial submissions is not \nitself evidence that a website operator or visitors / commenters have threatened anyone, \nencouraged violence, or participated in unlawful harassment. \n79.\u200bThe use of anonymity can facilitate discussion by persons who reasonably fear \nprofessional retaliation, social ostracism, online targeting, or unwanted public attention. \n80.\u200bThe Supreme Court has recognized the historic relationship between anonymity and free \nexpression. McIntyre, 514 U.S. at 341\u2013342. \n81.\u200bAccordingly, Movant requests that the Court avoid any inference that unidentified online \nspeakers constitute a collective group responsible for the misconduct of particular \nindividuals. \n82.\u200bFindings concerning unlawful conduct should be individualized and supported by \nappropriate evidence, rather than inferred from disagreement, controversial speech, \nanonymous participation, or mere association with a public discussion forum. \n \nStatistics dashboard of lucycraig.blog at 12:53pm on October 12, 2026 which demonstrate the significant public \ninterest in this matter..1 \nVII. DUE PROCESS AND LIMITS ON ENFORCEMENT AGAINST NONPARTIES \n1 It should be noted that these statistics were only started on October 6th, 2026 and do not represent the full duration of the blog\u2019s \nhistory. \n________________________________ \nhttps://lucycraig.blog \nPage: 8 of 11\n\n--- Page 9 ---\n83.\u200bThe Fourteenth Amendment prohibits deprivation of protected interests without \nconstitutionally adequate process. \n84.\u200bMovant has not been made a party, notified of any accusation of unlawful conduct, or \nafforded an evidentiary proceeding concerning the website. \n85.\u200bThe October 9 order makes no finding that Movant has engaged in threats, intimidation, \nor unlawful publication of personal information. \n86.\u200bA generalized public warning cannot substitute for particularized findings when an \nenforceable restriction on an individual's conduct is sought. \n87.\u200bNor may contempt sanctions be based solely upon the fact that a nonparty continues to \nexpress views contrary to a court's preference for less heated public discourse. \n88.\u200bMovant respectfully asks the Court to clarify that any future attempt to impose direct \nobligations on Movant must satisfy the applicable jurisdictional, substantive, notice, and \nprocedural requirements. \n89.\u200bSuch clarification would protect constitutional rights without diminishing the Court's \nauthority to enforce lawful orders against persons properly subject to them. \nVIII. THE REQUESTED RELIEF PRESERVES BOTH PUBLIC SAFETY AND PUBLIC \nACCESS \n90.\u200bMovant does not argue that judicial transparency requires indiscriminate publication of \nevery residential address, telephone number, or other sensitive detail found in a court \nfiling. \n91.\u200bNor does Movant assert that the First Amendment immunizes credible threats or targeted \nharassment. \n92.\u200bInstead, Movant proposes a narrower resolution that respects both the Court's identified \nsafety concerns and the public's constitutional and common-law interests. \n93.\u200bThe original documents may remain protected to the extent necessary to prevent \ndisclosure of genuinely sensitive personal information, while appropriately redacted \nversions are made accessible. \n94.\u200bThe public may continue to discuss the litigation, criticize the conduct of the parties and \ntheir lawyers, and examine lawfully accessible records without the sealing order being \nconstrued as a general speech prohibition. \n95.\u200bAnd unidentified persons may be held accountable for actual unlawful conduct through \nlawful procedures, rather than through ambiguous warnings to the public as a whole. \n96.\u200bThese principles are complementary, not contradictory. \nIX. PRAYER FOR RELIEF \nWHEREFORE, Nonparty Movant Jane Doe, publicly identified as \"JaneDoe1,\" respectfully \nrequests that the Court: \n________________________________ \nhttps://lucycraig.blog \nPage: 9 of 11\n\n--- Page 10 ---\nA. Grant limited leave for Movant to be heard as an interested nonparty concerning the October \n9, 2026 sealing order, NYSCEF Document No. 44, or alternatively accept this submission as a \nlimited nonparty brief; \nB. Grant Movant permission to proceed pseudonymously for purposes of the limited application, \nsubject to any appropriate confidential identity-verification procedure the Court may require; \nC. Reconsider, modify, or partially vacate the sealing directives insofar as they restrict access to \ninformation that may be released without exposing genuinely sensitive personal information; \nD. Direct that appropriately redacted versions of NYSCEF Documents 1, 6, 7, and 22 be made \npublicly accessible promptly, to the extent not already available; \nE. Make or supplement document-specific findings identifying any information requiring \ncontinued sealing and explaining why narrower redaction would be insufficient; \nF. Clarify that footnote 2 of NYSCEF Document No. 44 is advisory and is not a gag order, \ninjunction, or independently enforceable command directed at unidentified members of the \npublic; \nG. Declare or otherwise clarify that the October 9 order, by itself, does not prohibit Movant or \nother independent nonparties from engaging in lawful public commentary, criticism, journalism, \nanonymous discussion, or publication of lawfully obtained material; \nH. Confirm that no nonparty may be subjected to contempt or other sanctions solely for \nconstitutionally protected expression, without an applicable legal basis and the process required \nby law; \nI. Permit Movant to supplement the record with a sworn factual statement and appropriate \ndocumentary exhibits concerning the website's operation, public participation, and alleged \nextrajudicial efforts to suppress competing viewpoints; and \nJ. Grant such other and further relief as the Court deems just and proper. \nCONCLUSION \nThe judiciary's legitimacy depends not only upon its capacity to protect litigants and innocent \nthird persons, but also upon its willingness to permit public examination and criticism of the \njudicial process. \nThe October 9 order identifies a legitimate concern involving threats against an uninvolved \nfamily. That concern deserves careful judicial attention. \n________________________________ \nhttps://lucycraig.blog \nPage: 10 of 11\n\n--- Page 11 ---\nBut legitimate protection against threats must not be transformed\u2014whether intentionally or \nthrough ambiguity\u2014into a broader warning that discourages independent speakers from \nparticipating in a controversial public debate. \nThis litigation has entered the national conversation. Its allegations, the responses of the accused, \ninstitutional actions, prosecutorial decisions, and the conduct of counsel are matters that \nmembers of the public may lawfully discuss and criticize. \nNeither the plaintiff nor the defendants possess an exclusive right to define the public narrative. \nNor should any participant's desire to control media coverage displace the rights of independent \nspeakers. \nThe law protects the judicial process from genuine intimidation. It does not protect a \npreferred narrative from public disagreement. \nMovant accordingly requests narrowly tailored access to judicial records, leave to participate \nunder a pseudonym, and clarification that the Court's October 9 order does not restrict lawful \nnonparty expression. \nRespectfully submitted, \nJane Doe\u200b\nPublic pseudonym: JaneDoe1\u200b\nNonparty Movant, appearing individually\u200b\nAdministrator, https://lucycraig.blog \nDate: October 12, 2026 \n \n________________________________ \nhttps://lucycraig.blog \nPage: 11 of 11","text":"--- Page 1 ---\nSUPREME COURT OF THE STATE OF NEW YORK\u200b\nCOUNTY OF NEW YORK \u2014 PART 35 \n \nJANE DOE,\u200b\nPlaintiff, \n-against- \nCORNELL UNIVERSITY, INC., CHI PHI \nCHAPTER HOUSE ASSOCIATION, CHI \nPHI FRATERNITY, INC., CHI PHI \nEDUCATIONAL TRUST, ALPHA BETA \nHOUSE CORPORATION OF DELTA \nDELTA DELTA, DELTA DELTA DELTA \nSORORITY, ZAREEN ENTERPRISE \nLLC, MATTHEW INGALLS, \nJOHNATHAN NEWELL, WINSTON \nLEE, GILLIO LOPES, DIEGO SARABIA, \nSCOTT NORRIS, SCOTT \nKRETZSCHMAR, JOHN DOE, JOHN \nDOE, JOHN DOES, and ORAZIO \nPETITO,\u200b\nDefendants. \nIndex No. 161704/2026\u200b\nHon. Phaedra F. Perry-Bond, J.S.C.\u200b\nPart 35 \nNONPARTY JANE DOE'S APPLICATION FOR LEAVE TO APPEAR \nPSEUDONYMOUSLY; MOTION FOR ACCESS TO JUDICIAL RECORDS, \nMODIFICATION OR PARTIAL VACATUR OF SUA SPONTE SEALING ORDER; AND \nLIMITED OBJECTION TO FIRST AMENDMENT IMPLICATIONS OF NYSCEF DOC. \nNO. 44 \nProposed Intervenor/Nonparty Movant: \n\u200b\nJane Doe, appearing under the public pseudonym \"JaneDoe1\", individually and in the capacity \nof an administrator of the public commentary website https://lucycraig.blog. \nPRELIMINARY STATEMENT\n\n--- Page 2 ---\n1.\u200b Nonparty Movant Jane Doe, publicly known as \"JaneDoe1,\" respectfully seeks limited \nleave to appear under a pseudonym, to be heard concerning the public's right of access to \njudicial records, and to object to the potentially speech-chilling implications of the \nCourt's October 9, 2026 sua sponte sealing order, NYSCEF Document No. 44. \n2.\u200b Movant is not a plaintiff, defendant, witness, or attorney in the underlying action. Movant \ndoes not seek to adjudicate the allegations between the litigants, interfere with discovery, \nor participate in the merits of the case. \n3.\u200b Movant instead appears as an independent speaker, administrator of a public forum, and \nmember of the public asserting rights protected by the First Amendment to the United \nStates Constitution, Article I, Section 8 of the New York Constitution, and the \nlongstanding presumption of public access to judicial proceedings and records. \n4.\u200b This litigation has become the subject of extraordinary public attention and vigorous \ndebate concerning sexual-assault allegations, the presumption of innocence, institutional \nresponsibility, prosecutorial judgment, media coverage, and the respective rights of \ncomplainants and accused persons. \n5.\u200b Movant administers https://lucycraig.blog, an independently operated website dedicated \nto public discussion of the litigation and related controversies. \n6.\u200b As of the preparation of this submission, according to the website's reported statistics, the \nplatform has accumulated more than 3,000,000 views, 3,000 comments, and 8,000 \nparticipant reactions. Those figures are provided to illustrate the scale of public \nengagement and do not represent a claim that three million distinct individuals have been \nindependently verified. \n7.\u200b The website permits anonymous participation and operates under a policy favoring the \nmaximum lawful freedom of expression. Comments ordinarily become publicly visible \nautomatically. Administrators generally remove spam and content determined to be \nplainly unlawful, rather than censoring contributions because they are unpopular, \noffensive, controversial, or critical of a particular party. \n8.\u200b Users and administrators may contribute records, images, commentary, documents, and \nother materials for public discussion. The platform's editorial policy favors publication \nand retention of lawful materials regardless of viewpoint. \n9.\u200b Movant expressly disputes any proposition that judicial disapproval of public \ncommentary, or concern about the intensity of public disagreement, supplies independent \nauthority to regulate the speech of persons who have never appeared before the Court. \n10.\u200bMovant does not contest that genuine threats, targeted harassment, or malicious \npublication of sensitive residential information may justify lawful intervention. Nor does \nMovant dispute the Court's legitimate interest in protecting an uninvolved family \nreportedly subjected to threats after an erroneous address appeared in a filing. \n11.\u200bThe dispute is instead whether a broadly worded judicial warning directed at unidentified \nnonparties, coupled with restrictions on access to judicial documents, may be understood \n________________________________ \nhttps://lucycraig.blog \nPage: 2 of 11\n\n--- Page 3 ---\nor applied to chill lawful public debate without notice, individualized findings, an \nopportunity to be heard, or constitutionally adequate procedural protections. \n12.\u200bMovant respectfully submits that it may not. \nI. FACTUAL AND PROCEDURAL BACKGROUND \n13.\u200bOn October 9, 2026, the Court entered NYSCEF Document No. 44, styled Sua Sponte \nDecision and Order Directing Sealing of Certain Documents. \n14.\u200bThe order directs the sealing of NYSCEF Documents 1, 6, 7, and 22 and directs the \nplaintiff to refile versions with purported addresses redacted. \n15.\u200bThe Court explains that certain filed documents included address information, including \nan allegedly erroneous residential address associated with an individual who was not \ninvolved in this lawsuit. \n16.\u200bThe Court reports that a former Marine and his family were subjected to threats after that \nerroneous association circulated online. \n17.\u200bMovant condemns genuine threats of violence and harassment against innocent persons \nand does not seek public dissemination of the erroneous residential address. \n18.\u200bHowever, the Court's order extends beyond discussing the mechanics of address \nredaction. It also criticizes the broader climate of online discussion and urges those \ninvolved, including the general public, to reduce the intensity of the controversy. \n19.\u200bOf particular concern is footnote 2, which states: \n\"The Court is mindful that this information is highly likely to \nalready be disseminated on the internet. However, the Court issues \nthis decision and order to do its part in mitigating the risk of harm \nand to caution all involved, whether parties or not, to act \naccordingly.\" \n20.\u200bMovant objects to the ambiguity of this admonition insofar as it could reasonably be \ninterpreted as a warning of judicial consequences against unidentified nonparties for their \nindependent publications, commentary, criticism, or republication of otherwise lawfully \nobtained information. \n21.\u200bThe order identifies no specific act by Movant, makes no factual finding that Movant \nthreatened \nanyone, \nand \ndoes \nnot \nidentify \nany \nparticular \npublication \nby \nhttps://lucycraig.blog or elsewhere as unlawful. \n22.\u200bMovant has not been served with process, joined as a party, provided notice of a proposed \nspeech restriction, or afforded an opportunity to oppose an order directly restricting \nMovant's expressive activities. \n23.\u200bNevertheless, a judicial caution explicitly addressed to nonparties may reasonably \nproduce uncertainty among speakers and publishers concerning whether their continuing \nactivities could expose them to sanctions or contempt proceedings. \n________________________________ \nhttps://lucycraig.blog \nPage: 3 of 11\n\n--- Page 4 ---\n24.\u200bThat uncertainty is particularly consequential where anonymous contributors participate \nin extensive debate about an ongoing judicial controversy. \nII. LEAVE TO APPEAR AS AN ANONYMOUS NONPARTY \n25.\u200bMovant seeks limited participation to challenge the sealing of judicial records and request \nclarification of the October 9 order's scope. \n26.\u200bMovant's interests differ from those of the existing litigants. The parties may be \nprincipally concerned with litigation strategy, personal privacy, potential liability, or \nreputational interests. Movant's concern is the public's independent right to observe, \nreport upon, criticize, and debate judicial proceedings. \n27.\u200bIn Mosallem v. Berenson, 76 A.D.3d 345 (1st Dept. 2010), the Appellate Division \naddressed a journalist's intervention to challenge sealing, recognizing the public's \nsubstantial interest in inspecting judicial records. \n28.\u200bMovant's status as an online publisher or forum administrator does not eliminate those \ninterests. Constitutional protections of speech and public commentary do not depend on \nmembership in an established newspaper, a traditional broadcasting organization, or an \ninstitution approved by litigants. \n29.\u200bMovant seeks permission to use the pseudonym Jane Doe, with \"JaneDoe1\" identifying \nMovant's public online role. \n30.\u200bAnonymous and pseudonymous expression enjoy substantial constitutional protection. \nSee McIntyre v. Ohio Elections Commission, 514 U.S. 334 (1995); Talley v. California, \n362 U.S. 60 (1960). \n31.\u200bMovant recognizes that the right to publish anonymously does not automatically confer a \nright to litigate anonymously. Judicial permission requires consideration of competing \ninterests, including transparency, potential prejudice, confidentiality, and the reasons for \nseeking anonymity. See Anonymous v. Lerner, 124 A.D.3d 487 (1st Dept. 2015). \n32.\u200bMovant requests anonymity because the controversy involves extraordinary public \nhostility, intense scrutiny of online publishers, and a demonstrated risk that individuals \nassociated with this litigation may face unwanted exposure or retaliatory attention. \n33.\u200bMovant's proposed participation presents primarily legal issues and does not require \nadjudication of Movant's personal conduct or credibility. \n34.\u200bPublic identification of Movant would add little to the legal analysis concerning public \naccess or the constitutional limits of court orders, while potentially exposing an \nindependent speaker to unnecessary personal risk. \n35.\u200bMovant is willing to comply with any lawful procedure the Court determines necessary \nfor confidential verification of identity, subject to an appropriate protective order and an \nopportunity to be heard concerning disclosure. \n36.\u200bAccordingly, Movant requests leave to appear pseudonymously for the limited purpose of \npursuing the relief described herein, or alternatively leave to submit a limited nonparty \nbrief under a pseudonym. \n________________________________ \nhttps://lucycraig.blog \nPage: 4 of 11\n\n--- Page 5 ---\nIII. THE PRESUMPTION OF PUBLIC ACCESS REQUIRES NARROWLY TAILORED \nSEALING \n37.\u200bNew York courts recognize a substantial presumption favoring public access to judicial \nrecords. \n38.\u200bUnder 22 NYCRR \u00a7 216.1(a), sealing requires a written finding of good cause identifying \nthe grounds for restricting access, with consideration of the interests of both the public \nand the parties. \n39.\u200bThe First Department has repeatedly emphasized that secrecy is exceptional rather than \nroutine. See Mosallem v. Berenson, 76 A.D.3d 345 (1st Dept. 2010); Danco Laboratories, \nLtd. v. Chemical Works of Gedeon Richter, Ltd., 274 A.D.2d 1 (1st Dept. 2000). \n40.\u200bHere, the Court identified a concrete concern: personal address information reportedly \nused to direct threats against innocent individuals. \n41.\u200bMovant does not ask the Court to disregard that concern. The protection of residential \naddresses and other genuinely sensitive identifying information may constitute good \ncause for limited restrictions. \n42.\u200bHowever, where legitimate privacy interests can be protected through targeted redactions, \nwholesale or continuing exclusion of otherwise public judicial documents warrants \nindependent scrutiny. \n43.\u200bThe Court has already ordered the preparation of redacted versions of the affected filings. \n44.\u200bThat remedy demonstrates the availability of a less restrictive alternative: preserve \nnecessary address redactions while restoring public access to the remaining, \nnonconfidential portions of the documents. \n45.\u200bTo the extent the redacted versions have not been publicly docketed, Movant asks that \nthey be made available promptly, subject to review for additional information whose \ndisclosure would create a demonstrable risk of harm. \n46.\u200bMovant further requests clarification of whether the original documents must remain \nsealed once complete, properly redacted substitutes are available and whether any \nnon-address information is independently asserted to warrant protection. \n47.\u200bMovant does not insist that the Court release erroneous residential information or \ninformation whose disclosure is independently prohibited by law. \n48.\u200bRather, the Court should apply a document-specific, narrowly tailored analysis so that the \npublic does not lose access to substantive court filings merely because discrete \ninformation within them requires protection. \n49.\u200bThe public interest is especially substantial where judicial proceedings have become \ncentral to a national conversation concerning alleged misconduct, institutional \naccountability, due process, reputational harm, and the presumption of innocence. \n50.\u200bThe intensity of that interest strengthens the need for access to reliable judicial records. \nPublicly available filings allow readers to evaluate competing accounts by reference to \nwhat litigants actually submitted rather than relying exclusively on selective media \ndescriptions. \n________________________________ \nhttps://lucycraig.blog \nPage: 5 of 11\n\n--- Page 6 ---\nIV. FOOTNOTE 2 MUST NOT BE CONSTRUED AS A RESTRICTION ON \nPROTECTED NONPARTY SPEECH \n51.\u200bMovant's central constitutional objection concerns footnote 2 and the possibility that its \ninstruction to nonparties to act \"accordingly\" could be interpreted more broadly than the \nactual relief ordered. \n52.\u200bThe First Amendment protects a broad range of public discussion, including criticism of \njudicial proceedings, attorneys, public officials, institutional actors, litigants, and subjects \nof public controversy. \n53.\u200bThat protection does not disappear because commentary is impolite, emotionally charged, \noffensive, or sharply critical. \n54.\u200bIn Snyder v. Phelps, 562 U.S. 443 (2011), the Supreme Court recognized particularly \nstrong protection for expression addressing matters of public concern, even where its \ncontent causes serious distress. \n55.\u200bIn Bridges v. California, 314 U.S. 252 (1941), the Supreme Court addressed the \nconstitutional limits of using contempt powers against publications concerning pending \njudicial proceedings. \n56.\u200bThe present order does not expressly direct Movant or the public to stop speaking. \nMovant acknowledges that limitation and does not characterize footnote 2 as an \nalready-issued injunction against the website. \n57.\u200bNonetheless, Movant respectfully objects to any interpretation under which the footnote \nis treated as a directive enforceable against persons who were not before the Court and \nwhose specific conduct has not been adjudicated. \n58.\u200bThe distinction is critical. A court may condemn threats and explain that existing law \nprohibits particular conduct. It does not follow that the same order may impose undefined \nduties of restraint upon every member of the public discussing the litigation. \n59.\u200bAny order purporting to bind nonparties must rest on an applicable legal basis and satisfy \nrelevant requirements of notice, scope, jurisdiction, and due process. \n60.\u200bMovant therefore requests an express clarification that footnote 2 is advisory rather than \ninjunctive and does not, by itself, create an enforceable restriction on independent \nnonparty speech. \n61.\u200bSpecifically, the Court should confirm that the October 9 order does not prohibit lawful \npublication of opinions, criticism of the proceedings, discussion of publicly available \nallegations, examination of evidence lawfully obtained, or public debate concerning the \nconduct of litigants and attorneys. \n62.\u200bThe Court should further clarify that independent speakers are not subject to contempt \nmerely because their editorial judgments conflict with a party's preferred narrative or \nbecause their commentary is considered inflammatory, distasteful, or one-sided. \n63.\u200bThis requested clarification would not immunize threats, harassment, unlawful disclosure, \ndefamatory statements, or other conduct that may independently give rise to legal \nliability. \n________________________________ \nhttps://lucycraig.blog \nPage: 6 of 11\n\n--- Page 7 ---\n64.\u200bIt would simply preserve the distinction between enforceable legal restrictions and \nconstitutionally protected expression. \nV. THE PUBLIC CONTROVERSY HAS BEEN INTENSIFIED BY EXTRAJUDICIAL \nADVOCACY \n65.\u200bThis dispute has not unfolded solely in court filings. \n66.\u200bMovant contends that counsel associated with the plaintiff's position have participated in \nsubstantial public-facing advocacy concerning the allegations, the litigation, and the \npublic narrative surrounding the case. \n67.\u200bMovant further asserts, based on information Movant seeks an opportunity to \nsubstantiate, that efforts have been made to persuade online platforms, media \norganizations, and media executives, reportedly including Harvey Levin of TMZ, to limit \nor alter unfavorable coverage. \n68.\u200bThese assertions are presented as Movant's allegations and concerns, not as established \njudicial findings. Movant does not suggest that an attorney's lawful media advocacy or a \nlawful request to remove genuinely unlawful material is itself prohibited. \n69.\u200bNevertheless, when litigation participants seek public support, encourage media \ncoverage, or press their accounts before a national audience, opposing viewpoints and \nindependent scrutiny become no less important. \n70.\u200bA litigant or attorney cannot fairly demand the benefits of public advocacy while \nasserting that competing narratives must be suppressed merely because they challenge the \npreferred account. \n71.\u200bThe proper response to disputed public claims generally lies in rebuttal, disclosure of \naccurate information, and adversarial examination\u2014not presumptive silencing of \nopposing speakers. \n72.\u200bThe First Amendment does not reserve public commentary on pending litigation to \nparties, attorneys, institutional newsrooms, or speakers supporting a particular viewpoint. \n73.\u200bMovant submits that online forums permitting competing opinions serve a legitimate \npublic function when they allow readers to examine inconsistent factual assertions, \ncriticize coverage, and assess the available judicial record. \n74.\u200bThat function may be uncomfortable for the participants. But public discomfort, standing \nalone, is not a constitutional basis for suppressing lawful speech. \nVI. ANONYMOUS PUBLIC PARTICIPATION IS NOT SYNONYMOUS WITH \nMISCONDUCT \n75.\u200bThe website operated by Movant permits anonymous comments, reactions, and \nuser-contributed media. \n________________________________ \nhttps://lucycraig.blog \nPage: 7 of 11\n\n--- Page 8 ---\n76.\u200bThe platform generally publishes comments without advance editorial screening and \nseeks to moderate on a content-neutral basis, addressing spam and plainly unlawful \nmaterial rather than disfavored viewpoints. \n77.\u200bMovant recognizes that a policy of immediate publication does not eliminate potential \nlegal duties arising from specific content or valid court orders lawfully applicable to \nparticular persons. \n78.\u200bNevertheless, the existence of anonymous comments or controversial submissions is not \nitself evidence that a website operator or visitors / commenters have threatened anyone, \nencouraged violence, or participated in unlawful harassment. \n79.\u200bThe use of anonymity can facilitate discussion by persons who reasonably fear \nprofessional retaliation, social ostracism, online targeting, or unwanted public attention. \n80.\u200bThe Supreme Court has recognized the historic relationship between anonymity and free \nexpression. McIntyre, 514 U.S. at 341\u2013342. \n81.\u200bAccordingly, Movant requests that the Court avoid any inference that unidentified online \nspeakers constitute a collective group responsible for the misconduct of particular \nindividuals. \n82.\u200bFindings concerning unlawful conduct should be individualized and supported by \nappropriate evidence, rather than inferred from disagreement, controversial speech, \nanonymous participation, or mere association with a public discussion forum. \n \nStatistics dashboard of lucycraig.blog at 12:53pm on October 12, 2026 which demonstrate the significant public \ninterest in this matter..1 \nVII. DUE PROCESS AND LIMITS ON ENFORCEMENT AGAINST NONPARTIES \n1 It should be noted that these statistics were only started on October 6th, 2026 and do not represent the full duration of the blog\u2019s \nhistory. \n________________________________ \nhttps://lucycraig.blog \nPage: 8 of 11\n\n--- Page 9 ---\n83.\u200bThe Fourteenth Amendment prohibits deprivation of protected interests without \nconstitutionally adequate process. \n84.\u200bMovant has not been made a party, notified of any accusation of unlawful conduct, or \nafforded an evidentiary proceeding concerning the website. \n85.\u200bThe October 9 order makes no finding that Movant has engaged in threats, intimidation, \nor unlawful publication of personal information. \n86.\u200bA generalized public warning cannot substitute for particularized findings when an \nenforceable restriction on an individual's conduct is sought. \n87.\u200bNor may contempt sanctions be based solely upon the fact that a nonparty continues to \nexpress views contrary to a court's preference for less heated public discourse. \n88.\u200bMovant respectfully asks the Court to clarify that any future attempt to impose direct \nobligations on Movant must satisfy the applicable jurisdictional, substantive, notice, and \nprocedural requirements. \n89.\u200bSuch clarification would protect constitutional rights without diminishing the Court's \nauthority to enforce lawful orders against persons properly subject to them. \nVIII. THE REQUESTED RELIEF PRESERVES BOTH PUBLIC SAFETY AND PUBLIC \nACCESS \n90.\u200bMovant does not argue that judicial transparency requires indiscriminate publication of \nevery residential address, telephone number, or other sensitive detail found in a court \nfiling. \n91.\u200bNor does Movant assert that the First Amendment immunizes credible threats or targeted \nharassment. \n92.\u200bInstead, Movant proposes a narrower resolution that respects both the Court's identified \nsafety concerns and the public's constitutional and common-law interests. \n93.\u200bThe original documents may remain protected to the extent necessary to prevent \ndisclosure of genuinely sensitive personal information, while appropriately redacted \nversions are made accessible. \n94.\u200bThe public may continue to discuss the litigation, criticize the conduct of the parties and \ntheir lawyers, and examine lawfully accessible records without the sealing order being \nconstrued as a general speech prohibition. \n95.\u200bAnd unidentified persons may be held accountable for actual unlawful conduct through \nlawful procedures, rather than through ambiguous warnings to the public as a whole. \n96.\u200bThese principles are complementary, not contradictory. \nIX. PRAYER FOR RELIEF \nWHEREFORE, Nonparty Movant Jane Doe, publicly identified as \"JaneDoe1,\" respectfully \nrequests that the Court: \n________________________________ \nhttps://lucycraig.blog \nPage: 9 of 11\n\n--- Page 10 ---\nA. Grant limited leave for Movant to be heard as an interested nonparty concerning the October \n9, 2026 sealing order, NYSCEF Document No. 44, or alternatively accept this submission as a \nlimited nonparty brief; \nB. Grant Movant permission to proceed pseudonymously for purposes of the limited application, \nsubject to any appropriate confidential identity-verification procedure the Court may require; \nC. Reconsider, modify, or partially vacate the sealing directives insofar as they restrict access to \ninformation that may be released without exposing genuinely sensitive personal information; \nD. Direct that appropriately redacted versions of NYSCEF Documents 1, 6, 7, and 22 be made \npublicly accessible promptly, to the extent not already available; \nE. Make or supplement document-specific findings identifying any information requiring \ncontinued sealing and explaining why narrower redaction would be insufficient; \nF. Clarify that footnote 2 of NYSCEF Document No. 44 is advisory and is not a gag order, \ninjunction, or independently enforceable command directed at unidentified members of the \npublic; \nG. Declare or otherwise clarify that the October 9 order, by itself, does not prohibit Movant or \nother independent nonparties from engaging in lawful public commentary, criticism, journalism, \nanonymous discussion, or publication of lawfully obtained material; \nH. Confirm that no nonparty may be subjected to contempt or other sanctions solely for \nconstitutionally protected expression, without an applicable legal basis and the process required \nby law; \nI. Permit Movant to supplement the record with a sworn factual statement and appropriate \ndocumentary exhibits concerning the website's operation, public participation, and alleged \nextrajudicial efforts to suppress competing viewpoints; and \nJ. Grant such other and further relief as the Court deems just and proper. \nCONCLUSION \nThe judiciary's legitimacy depends not only upon its capacity to protect litigants and innocent \nthird persons, but also upon its willingness to permit public examination and criticism of the \njudicial process. \nThe October 9 order identifies a legitimate concern involving threats against an uninvolved \nfamily. That concern deserves careful judicial attention. \n________________________________ \nhttps://lucycraig.blog \nPage: 10 of 11\n\n--- Page 11 ---\nBut legitimate protection against threats must not be transformed\u2014whether intentionally or \nthrough ambiguity\u2014into a broader warning that discourages independent speakers from \nparticipating in a controversial public debate. \nThis litigation has entered the national conversation. Its allegations, the responses of the accused, \ninstitutional actions, prosecutorial decisions, and the conduct of counsel are matters that \nmembers of the public may lawfully discuss and criticize. \nNeither the plaintiff nor the defendants possess an exclusive right to define the public narrative. \nNor should any participant's desire to control media coverage displace the rights of independent \nspeakers. \nThe law protects the judicial process from genuine intimidation. It does not protect a \npreferred narrative from public disagreement. \nMovant accordingly requests narrowly tailored access to judicial records, leave to participate \nunder a pseudonym, and clarification that the Court's October 9 order does not restrict lawful \nnonparty expression. \nRespectfully submitted, \nJane Doe\u200b\nPublic pseudonym: JaneDoe1\u200b\nNonparty Movant, appearing individually\u200b\nAdministrator, https://lucycraig.blog \nDate: October 12, 2026 \n \n________________________________ \nhttps://lucycraig.blog \nPage: 11 of 11","thumbnailUrl":"https://lucycraig.blog/media/285/thumb.webp","transcriptStatus":"not_applicable","transcriptText":"","url":"https://lucycraig.blog/media/285"}