# AFFIDAVIT Response to Demand for Change of Venue

Source: https://lucycraig.blog/media/393
File: NYSCEF-Document-000041.pdf
Format: application/pdf
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
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SUPREME COURT OF THE STATE OF NEW YORK 
COUNTY OF NEW YORK 
 
JANE DOE,  
Index No. 161704/2026 
 
 
 
AFFIDAVIT IN  
RESPONSE TO DEMAND  
FOR CHANGE OF VENUE 
 
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  
) 
 
Thomas P. Giuffra, Esq., being duly sworn, affirms the contents of the following to be 
true under penalties of perjury: 
1. 
I am an attorney duly licensed to practice law in the State of New York, and I am a 
partner of Rheingold Giuffra Ruffo Plotkin & Hellman, LLP, attorneys for Plaintiff in this 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 Plaintiff resided when this action was commenced. See CPLR §503(a). 
4. 
Furthermore, venue was properly made in the County of New York, as same is the 
county where Defendant CORNELL UNIVERSITY, INC. owns, controls, and maintains 
FILED: NEW YORK COUNTY CLERK 10/09/2026 10:54 AM
INDEX NO. 161704/2026
NYSCEF DOC. NO. 41
RECEIVED NYSCEF: 10/09/2026
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extensions of its Thompkins County undergraduate campus at 570 Lexington Avenue, New York, 
NY 10022. See CPLR §503(a). 
I affirm this 9th 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 may be filed in an action or proceeding in a court of law. 
 
 
Dated:  New York, NY 
 
 
October 9, 2026 
 
 
 
 
 
 
 
 
RHEINGOLD GIUFFRA RUFFO  
 
 
 
 
 
 
PLOTKIN & HELLMAN LLP 
 
 
 
 
 
 
Attorneys for Plaintiff  
 
 
 
 
 
 
 
  
 
      _____________________                                                         
 
 
 
 
 
 
By: Thomas P. Giuffra, Esq. 
 
 
 
 
 
 
551 Fifth Avenue, 29th Fl. 
New York, NY 10176 
 
 
 
 
 
 
Tel: (212) 684-1880 
 
 
 
 
 
 
tgiuffra@rheingoldlaw.com 
 
FILED: NEW YORK COUNTY CLERK 10/09/2026 10:54 AM
INDEX NO. 161704/2026
NYSCEF DOC. NO. 41
RECEIVED NYSCEF: 10/09/2026
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