{"@context":"https://schema.org","@type":"DigitalDocument","altText":"Cornell Response","alternateName":"161704_2026_Jane_Doe_v_Cornell_University_Inc_et_al_LETTER___CORRESPOND_65.pdf","caption":"Cornell Response","contentUrl":"https://lucycraig.blog/media/342/raw","datePublished":"2026-10-14T22:46:05+00:00","description":"Cornell Response","encodingFormat":"application/pdf","identifier":"342","isAccessibleForFree":true,"machineReadable":{"json":"https://lucycraig.blog/media/342/index.json","markdown":"https://lucycraig.blog/media/342/index.md"},"name":"161704_2026_Jane_Doe_v_Cornell_University_Inc_et_al_LETTER___CORRESPOND_65","ocrStatus":"ready","ocrText":"--- Page 1 ---\nPatrick J. Hines \nPartner \nDirect Dial: 716.848.1679 \nPHines@hodgsonruss.com\nThe Guaranty Building, 140 Pearl Street, Suite 100   |   Buffalo, New York 14202   |   716.856.4000   |   hodgsonruss.com\nAlbany  \uf0be  Buffalo  \uf0be  Greensboro  \uf0be  New Jersey  \uf0be  New York  \uf0be  Palm Beach  \uf0be  Rochester  \uf0be  Saratoga Springs  \uf0be  Toronto\nOctober 14, 2026 \nVia NYSCEF \nHon. Phaedra F. Perry-Bond \nNew York Supreme Court \n60 Centre Street, Courtroom 252 \nNew York, New York 10007 \nDear Justice Perry-Bond: \nRe: \nJane Doe v. Cornell University, et al.\nIndex No. 161704/2026 \nOur firm represents Cornell University in the above-referenced matter, and we \nwrite regarding Jane Doe\u2019s pending application for permission to proceed by pseudonym, see\nNYSCEF Dkt. 2-5, and Defendant Diego Sarabia\u2019s application for an order restraining certain \nstatements and disclosures. See NYSCEF Dkt. 48-50. \nCornell does not oppose Plaintiff\u2019s application to proceed by pseudonym and \nsupports all reasonable measures to preserve her anonymity and privacy. We note that in \nPlaintiff\u2019s affirmation, she requests \u201ca partial Attorneys\u2019 Eyes Only (AEO) designation as to my \nsensitive personal information including my date of birth, SSN, residential address, phone \nnumber, and email address.\u201d Dkt. 4 \u00b6 10. Cornell also has no objection to that request, and we \nwelcome further discussion with all counsel regarding an appropriate protective order to govern \nthis litigation. \nIn fact, Cornell respectfully suggests that the relief requested by Jane Doe be \nbroadened to ensure it also protects the sensitive personal information of non-parties to this \naction, including their identities. To investigate complaints of sexual misconduct, universities \nrely on the willingness of reporting parties and witnesses to come forward, share what they know \nregarding highly sensitive events, and, ultimately, testify in Title IX hearings. Any future \nprotective order should include appropriate safeguards to protect the privacy of these witnesses \nas well. \nWith respect to Defendant Sarabia\u2019s application, Cornell fully supports efforts by \nthe Court and the parties to \u201cbring[] the temperature down\u201d as stated in Your Honor\u2019s October 9, \n2026 Order. NYSCEF Dkt. 44. For the most part, Cornell has no objection to the relief requested \nin the Order to Show Cause, but certain modifications to the order are necessary, given that \nCornell is not an individual but an institution with myriad current and future reporting and other \ndisclosure obligations. The relief currently requested in Sarabia\u2019s application could be \nFILED: NEW YORK COUNTY CLERK 10/14/2026 03:55 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 65\nRECEIVED NYSCEF: 10/14/2026\n1 of 2\n\n--- Page 2 ---\nHon. Phaedra F. Perry-Bond \nOctober 14, 2026 \nPage 2 \ninterpreted to prevent Cornell from satisfying these obligations or imposing upon the institution \nan obligation to restrict the speech of its various students, employees, and community members. \nThe exceptions set out in the proposed order are not sufficiently broad or sufficiently defined to \naddress these concerns. Cornell welcomes an opportunity to discuss the language of an \nappropriate order either stipulated by the parties or resolved by the Court but respectfully \nrequests that the Order to Show Cause as currently drafted not be entered by the Court until the \nlimitations and exceptions are clarified to permit Cornell to fulfill its legitimate institutional and \nlegal obligations. \nRespectfully submitted, \nPatrick J. Hines \nPJH \nFILED: NEW YORK COUNTY CLERK 10/14/2026 03:55 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 65\nRECEIVED NYSCEF: 10/14/2026\n2 of 2","text":"--- Page 1 ---\nPatrick J. Hines \nPartner \nDirect Dial: 716.848.1679 \nPHines@hodgsonruss.com\nThe Guaranty Building, 140 Pearl Street, Suite 100   |   Buffalo, New York 14202   |   716.856.4000   |   hodgsonruss.com\nAlbany  \uf0be  Buffalo  \uf0be  Greensboro  \uf0be  New Jersey  \uf0be  New York  \uf0be  Palm Beach  \uf0be  Rochester  \uf0be  Saratoga Springs  \uf0be  Toronto\nOctober 14, 2026 \nVia NYSCEF \nHon. Phaedra F. Perry-Bond \nNew York Supreme Court \n60 Centre Street, Courtroom 252 \nNew York, New York 10007 \nDear Justice Perry-Bond: \nRe: \nJane Doe v. Cornell University, et al.\nIndex No. 161704/2026 \nOur firm represents Cornell University in the above-referenced matter, and we \nwrite regarding Jane Doe\u2019s pending application for permission to proceed by pseudonym, see\nNYSCEF Dkt. 2-5, and Defendant Diego Sarabia\u2019s application for an order restraining certain \nstatements and disclosures. See NYSCEF Dkt. 48-50. \nCornell does not oppose Plaintiff\u2019s application to proceed by pseudonym and \nsupports all reasonable measures to preserve her anonymity and privacy. We note that in \nPlaintiff\u2019s affirmation, she requests \u201ca partial Attorneys\u2019 Eyes Only (AEO) designation as to my \nsensitive personal information including my date of birth, SSN, residential address, phone \nnumber, and email address.\u201d Dkt. 4 \u00b6 10. Cornell also has no objection to that request, and we \nwelcome further discussion with all counsel regarding an appropriate protective order to govern \nthis litigation. \nIn fact, Cornell respectfully suggests that the relief requested by Jane Doe be \nbroadened to ensure it also protects the sensitive personal information of non-parties to this \naction, including their identities. To investigate complaints of sexual misconduct, universities \nrely on the willingness of reporting parties and witnesses to come forward, share what they know \nregarding highly sensitive events, and, ultimately, testify in Title IX hearings. Any future \nprotective order should include appropriate safeguards to protect the privacy of these witnesses \nas well. \nWith respect to Defendant Sarabia\u2019s application, Cornell fully supports efforts by \nthe Court and the parties to \u201cbring[] the temperature down\u201d as stated in Your Honor\u2019s October 9, \n2026 Order. NYSCEF Dkt. 44. For the most part, Cornell has no objection to the relief requested \nin the Order to Show Cause, but certain modifications to the order are necessary, given that \nCornell is not an individual but an institution with myriad current and future reporting and other \ndisclosure obligations. The relief currently requested in Sarabia\u2019s application could be \nFILED: NEW YORK COUNTY CLERK 10/14/2026 03:55 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 65\nRECEIVED NYSCEF: 10/14/2026\n1 of 2\n\n--- Page 2 ---\nHon. Phaedra F. Perry-Bond \nOctober 14, 2026 \nPage 2 \ninterpreted to prevent Cornell from satisfying these obligations or imposing upon the institution \nan obligation to restrict the speech of its various students, employees, and community members. \nThe exceptions set out in the proposed order are not sufficiently broad or sufficiently defined to \naddress these concerns. Cornell welcomes an opportunity to discuss the language of an \nappropriate order either stipulated by the parties or resolved by the Court but respectfully \nrequests that the Order to Show Cause as currently drafted not be entered by the Court until the \nlimitations and exceptions are clarified to permit Cornell to fulfill its legitimate institutional and \nlegal obligations. \nRespectfully submitted, \nPatrick J. Hines \nPJH \nFILED: NEW YORK COUNTY CLERK 10/14/2026 03:55 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 65\nRECEIVED NYSCEF: 10/14/2026\n2 of 2","thumbnailUrl":"https://lucycraig.blog/media/342/thumb.webp","transcriptStatus":"not_applicable","transcriptText":"","url":"https://lucycraig.blog/media/342"}