{"@context":"https://schema.org","@type":"DigitalDocument","altText":"AFFIDAVIT Response to Demand for Change of Venue","alternateName":"NYSCEF-Document-000041.pdf","caption":"NYSCEF document #41 | Filed: 2026-10-09 | Filed by: COHEN, ETHAN J Filed:  Received: | Docket status: Processed Confirmation Notice | Source: NYSCEF, New York County Supreme Court","contentUrl":"https://lucycraig.blog/media/393/raw","datePublished":"2026-10-15T18:45:41+00:00","description":"NYSCEF document #41 | Filed: 2026-10-09 | Filed by: COHEN, ETHAN J Filed:  Received: | Docket status: Processed Confirmation Notice | Source: NYSCEF, New York County Supreme Court","encodingFormat":"application/pdf","identifier":"393","isAccessibleForFree":true,"machineReadable":{"json":"https://lucycraig.blog/media/393/index.json","markdown":"https://lucycraig.blog/media/393/index.md"},"name":"AFFIDAVIT Response to Demand for Change of Venue","ocrStatus":"ready","ocrText":"--- Page 1 ---\n1 \nSUPREME COURT OF THE STATE OF NEW YORK \nCOUNTY OF NEW YORK \n \nJANE DOE,  \nIndex No. 161704/2026 \n \n \n \nAFFIDAVIT IN  \nRESPONSE TO DEMAND  \nFOR CHANGE OF VENUE \n \nPlaintiff, \n-against-  \nCORNELL UNIVERSITY, INC., CHI PHI CHAPTER \nHOUSE ASSOCIATION, CHI PHI FRATERNITY, INC., \nCHI PHI EDUCATIONAL TRUST, ALPHA BETA \nHOUSE CORPORATION OF DELTA DELTA DELTA, \nDELTA DELTA DELTA SORORITY, ZAREEN \nENTERPRISE LLC d/b/a MOONIES BAR & \nNIGHTCLUB, MATTHEW INGALLS, JOHNATHAN \nNEWELL, WINSTON LEE, GILLIO LOPES, DIEGO \nSARABIA, SCOTT NORRIS, SCOTT KRETZSCHMAR, \nJOHN DOE (FACULTY), JOHN DOE (ALUMNI), JOHN \nDOES (EXECUTIVE BOARD), and ORAZIO PETITO, \n \nDefendants. \n \nSTATE OF NEW YORK \n \n) \n \n \n \n \n \n):ss: \nCOUNTY OF NEW YORK  \n) \n \nThomas P. Giuffra, Esq., being duly sworn, affirms the contents of the following to be \ntrue under penalties of perjury: \n1. \nI am an attorney duly licensed to practice law in the State of New York, and I am a \npartner of Rheingold Giuffra Ruffo Plotkin & Hellman, LLP, attorneys for Plaintiff in this matter. \n2. \nThis affidavit is made pursuant to CPLR \u00a7511(b) in response to the demand for \nchange of venue filed by Defendant ZAREEN ENTERPRISE, LLC d/b/a MOONIES BAR & \nNIGHTCLUB, on October 6, 2026. \n3. \nVenue was properly made in the County of New York, as same is the county in \nwhich Plaintiff resided when this action was commenced. See CPLR \u00a7503(a). \n4. \nFurthermore, venue was properly made in the County of New York, as same is the \ncounty where Defendant CORNELL UNIVERSITY, INC. owns, controls, and maintains \nFILED: NEW YORK COUNTY CLERK 10/09/2026 10:54 AM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 41\nRECEIVED NYSCEF: 10/09/2026\n1 of 2\n\n--- Page 2 ---\n.\n2 \nextensions of its Thompkins County undergraduate campus at 570 Lexington Avenue, New York, \nNY 10022. See CPLR \u00a7503(a). \nI affirm this 9th day of October, 2026, under the penalties of perjury under the laws of New York, \nwhich may include a fine or imprisonment, that the foregoing is true, and I understand that this \ndocument may be filed in an action or proceeding in a court of law. \n \n \nDated:  New York, NY \n \n \nOctober 9, 2026 \n \n \n \n \n \n \n \n \nRHEINGOLD GIUFFRA RUFFO  \n \n \n \n \n \n \nPLOTKIN & HELLMAN LLP \n \n \n \n \n \n \nAttorneys for Plaintiff  \n \n \n \n \n \n \n \n  \n \n      _____________________                                                         \n \n \n \n \n \n \nBy: Thomas P. Giuffra, Esq. \n \n \n \n \n \n \n551 Fifth Avenue, 29th Fl. \nNew York, NY 10176 \n \n \n \n \n \n \nTel: (212) 684-1880 \n \n \n \n \n \n \ntgiuffra@rheingoldlaw.com \n \nFILED: NEW YORK COUNTY CLERK 10/09/2026 10:54 AM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 41\nRECEIVED NYSCEF: 10/09/2026\n2 of 2","text":"--- Page 1 ---\n1 \nSUPREME COURT OF THE STATE OF NEW YORK \nCOUNTY OF NEW YORK \n \nJANE DOE,  \nIndex No. 161704/2026 \n \n \n \nAFFIDAVIT IN  \nRESPONSE TO DEMAND  \nFOR CHANGE OF VENUE \n \nPlaintiff, \n-against-  \nCORNELL UNIVERSITY, INC., CHI PHI CHAPTER \nHOUSE ASSOCIATION, CHI PHI FRATERNITY, INC., \nCHI PHI EDUCATIONAL TRUST, ALPHA BETA \nHOUSE CORPORATION OF DELTA DELTA DELTA, \nDELTA DELTA DELTA SORORITY, ZAREEN \nENTERPRISE LLC d/b/a MOONIES BAR & \nNIGHTCLUB, MATTHEW INGALLS, JOHNATHAN \nNEWELL, WINSTON LEE, GILLIO LOPES, DIEGO \nSARABIA, SCOTT NORRIS, SCOTT KRETZSCHMAR, \nJOHN DOE (FACULTY), JOHN DOE (ALUMNI), JOHN \nDOES (EXECUTIVE BOARD), and ORAZIO PETITO, \n \nDefendants. \n \nSTATE OF NEW YORK \n \n) \n \n \n \n \n \n):ss: \nCOUNTY OF NEW YORK  \n) \n \nThomas P. Giuffra, Esq., being duly sworn, affirms the contents of the following to be \ntrue under penalties of perjury: \n1. \nI am an attorney duly licensed to practice law in the State of New York, and I am a \npartner of Rheingold Giuffra Ruffo Plotkin & Hellman, LLP, attorneys for Plaintiff in this matter. \n2. \nThis affidavit is made pursuant to CPLR \u00a7511(b) in response to the demand for \nchange of venue filed by Defendant ZAREEN ENTERPRISE, LLC d/b/a MOONIES BAR & \nNIGHTCLUB, on October 6, 2026. \n3. \nVenue was properly made in the County of New York, as same is the county in \nwhich Plaintiff resided when this action was commenced. See CPLR \u00a7503(a). \n4. \nFurthermore, venue was properly made in the County of New York, as same is the \ncounty where Defendant CORNELL UNIVERSITY, INC. owns, controls, and maintains \nFILED: NEW YORK COUNTY CLERK 10/09/2026 10:54 AM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 41\nRECEIVED NYSCEF: 10/09/2026\n1 of 2\n\n--- Page 2 ---\n.\n2 \nextensions of its Thompkins County undergraduate campus at 570 Lexington Avenue, New York, \nNY 10022. See CPLR \u00a7503(a). \nI affirm this 9th day of October, 2026, under the penalties of perjury under the laws of New York, \nwhich may include a fine or imprisonment, that the foregoing is true, and I understand that this \ndocument may be filed in an action or proceeding in a court of law. \n \n \nDated:  New York, NY \n \n \nOctober 9, 2026 \n \n \n \n \n \n \n \n \nRHEINGOLD GIUFFRA RUFFO  \n \n \n \n \n \n \nPLOTKIN & HELLMAN LLP \n \n \n \n \n \n \nAttorneys for Plaintiff  \n \n \n \n \n \n \n \n  \n \n      _____________________                                                         \n \n \n \n \n \n \nBy: Thomas P. Giuffra, Esq. \n \n \n \n \n \n \n551 Fifth Avenue, 29th Fl. \nNew York, NY 10176 \n \n \n \n \n \n \nTel: (212) 684-1880 \n \n \n \n \n \n \ntgiuffra@rheingoldlaw.com \n \nFILED: NEW YORK COUNTY CLERK 10/09/2026 10:54 AM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 41\nRECEIVED NYSCEF: 10/09/2026\n2 of 2","thumbnailUrl":"https://lucycraig.blog/media/393/thumb.webp","transcriptStatus":"not_applicable","transcriptText":"","url":"https://lucycraig.blog/media/393"}