161704_2026_Jane_Doe_v_Cornell_University_Inc_et_al_AFFIRMATION_4

--- Page 1 --- SUPREMECOURTOFTHESTATEOFNEWYORK COUNTYOFNEWYORK JANEDOE, Index No.: Plaintiff, -against- PLAINTIFF'S AFFIRMATION CORNELLUNIVERSITY, INC., CHI PHI CHAPTER HOUSEASSOCIATION, CHI PHI FRATERNITY, INC., CHI PHI EDUCATIONALTRUST,ALPHABETA HOUSECORPORATION OFDELTADELTADELTA, DELTADELTADELTASORORITY,ZAREEN ENTERPRISELLC d/b/a MOONIESBAR& NIGHTCLUB,MATTHEW INGALLS, JOHNATHAN NEWELL,WINSTONLEE, GILLIO LOPES, DIEGO SARABIA, SCOTTNORRIS, SCOTTKRETZSCHMAR, JOHNDOE(FACULTY), JOHNBOE(ALUMNI), JOHN DOES(EXECUTIVEBOARD), and ORAZIOPETITO, Defendant. Plaintiff s JANE DOE, being duly sworn, affirms the contents of the following to be true under penalty of perjury: 1. I am the Plaintiff JANE DOEin 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 Pseudonympursuant 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 mynameand/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 MATTHEWINGALLS, JOHNATHANNEWELL, WINSTONLEE, GILLIO LOPES, DIEGO SARABIA, SCOTTNORRIS, and SCOTTKRETZSCHMAR, in October 2024 within the Xi Chapter of Chi Phi Fraternity's house located on Cornell University's campus. 4. I amseeking 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 mybest interests. 6. The risk of exposing my identity is particularly acute here as I was raped by multiple defendants while attending Cornell University as a full-time undergraduate student. I have since stopped attending Cornell University because of the subject incident. 7. What happened to mewas 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 namein 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 FILED: NEW YORK COUNTY CLERK 09/16/2026 07:05 PM INDEX NO. 161704/2026 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 09/18/2026 1 of 2 --- Page 2 --- worked so hard to rebuild. 9. I truly fear retribution and retaliation resulting from filing this lawsuit. Defendants have no regard for my health or safety. My assailants threatened my safety and wellbeing on numerous occasions, especially in plying me with copious amounts of drugs without any regard for the consequences. 10. Not only amI seeking to proceed anonymously as "JANE DOE", but I amalso kindly requesting a partial Attorneys' Eyes Only (AEO) designation as to my sensitive personal information including my date of birth, SSN, residential address, phone number, and email address. 11. The worry of my identity being revealed in this lawsuit has caused me extreme anxiety, depression, and manysleepless nights. 12. I do not believe that Defendants will be negatively affected and/or prejudiced by allowing meto use a pseudonym in legal proceedings or by granting any of the requested relief. Defendants and their attorneys will be made aware of my true identity upon the filing of this lawsuit. 13. I believe that proceeding anonymously is within my best interests and will allow meto remain safe and maintain a sound sense of mind. I affirm this _/N_ day of 6,c 2026, under the penalties of perjury under the law of New York which may include a fine or imprisonment, that the foregoing is true, and I understand that this document may be filed in an action or proceeding in a court of law. Dated: k, , NewYork e be,- /1 , 2026 By: FILED: NEW YORK COUNTY CLERK 09/16/2026 07:05 PM INDEX NO. 161704/2026 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 09/18/2026 2 of 2