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--- Page 1 ---
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
JANE DOE,
Index No. 161704/2026
PLAINTIFF’S
AFFIRMATION
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
DOE (ALUMNI), JOHN DOES (EXECUTIVE BOARD),
and ORAZIO PETITO,
Defendants.
STATE OF NEW YORK
)
):ss:
COUNTY OF NEW YORK
)
being duly sworn, affirms the contents of the
following to be true under penalties of perjury:
1. I am Plaintiff JANE DOE in the above-captioned matter.
2. This affidavit is made pursuant to CPLR §511(b) in
response to the demand for change of venue filed by Defendant
ZAREEN ENTERPRISE, LLC d/b/a MOONIES BAR &
NIGHTCLUB, on October 6, 2026.
3. Venue was properly made in the County of New York, as
same is the county in which I resided when this action
commenced. See CPLR §503(a).
4. On September 16, 2026, I was residing within an
i
N
Y k C
l
d
143 W 86 h S
FILED: NEW YORK COUNTY CLERK 10/09/2026 10:54 AM
INDEX NO. 161704/2026
NYSCEF DOC. NO. 42
RECEIVED NYSCEF: 10/09/2026
--- Page 2 ---
apartment m1New York County,
located
at
14.S w 80t11
estreet,
Apt.
3B, NewYork, NY10024.
5. OnSeptember
16, 2026, myattorneys
initiated
the herein
suit by filing
a Summons& Complaint
on NYSCEF.
6. Therefore,
because
I resided
in NewYork County
at the
time
this
action
was commenced,
the County of New York
is
a
properly
chosen venue.
I
affirm
this
8th day of
October,
2026,
under
the
penalties
of
perjury
under
the laws of New York,
which may include
a fine
or imprisonment,
that
the foregoing
is
true,
and I understand
that
this
document maybe filed
in an action
or proceeding
in a court
of law.
Dated:
NewYork, NY
October
8, 2026
s JANEDOE
2
FILED: NEW YORK COUNTY CLERK 10/09/2026 10:54 AM
INDEX NO. 161704/2026
NYSCEF DOC. NO. 42
RECEIVED NYSCEF: 10/09/2026
PUBLIC DISCUSSION
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