{"@context":"https://schema.org","@type":"DigitalDocument","altText":"LETTER / CORRESPONDENCE TO JUDGE (Motion #002)","alternateName":"NYSCEF-Document-000066.pdf","caption":"NYSCEF document #66 | Filed: 2026-10-14 | Filed by: COHEN, ETHAN J Filed:  Received: | Docket status: Processed Confirmation Notice | Source: NYSCEF, New York County Supreme Court","contentUrl":"https://lucycraig.blog/media/418/raw","datePublished":"2026-10-15T18:45:43+00:00","description":"NYSCEF document #66 | Filed: 2026-10-14 | Filed by: COHEN, ETHAN J Filed:  Received: | Docket status: Processed Confirmation Notice | Source: NYSCEF, New York County Supreme Court","encodingFormat":"application/pdf","identifier":"418","isAccessibleForFree":true,"machineReadable":{"json":"https://lucycraig.blog/media/418/index.json","markdown":"https://lucycraig.blog/media/418/index.md"},"name":"LETTER / CORRESPONDENCE TO JUDGE (Motion #002)","ocrStatus":"ready","ocrText":"--- Page 1 ---\nRG1U&H\nRHBINGOLD GIUFPRA RUPPO\nPLOTKIN & HELLMANLLP\n551 FIFTH AVE | 29TH FLOOR | NEW YORK, NEW YORK 10176 \nPHONE (212) 684-1880 | FAX (212) 689-8156 | WWW.RHEINGOLDLAW.COM \n \n \n \nOctober 14, 2026 \n \nVia NYSCEF \nHon. Phaedra F. Perry-Bond, J.S.C. \nSupreme Court, New York County \nIAS Part 35  \n60 Centre Street, Courtroom 252  \nNew York, New York 10007 \n \n    Re:  Jane Doe v. Cornell University, Inc., et al. \nSupreme Court | New York County | Index No. 161704/2026  \n \nDear Judge Perry-Bond: \n \n \nPursuant to the court\u2019s email of October 12, 2026, Plaintiff submits the following letter in \nopposition to the signing of the proposed order to show cause, and its TRO request, filed by \nDefendant Diego Sarabia (NYSCEF 48, 49, 50). The proposed order to show cause is completely \nmisguided and must be denied.  \n \nStatement of Facts \n \n \n \nThis is a claim made for the rape of Jane Doe that occurred in the Chi Phi House at \nCornell University on October 19-20, 2024. I will not discuss the facts of the case as they have \nbeen widely reported in the media. On September 16, 2026, we filed a lawsuit against several \nindividuals and entities for claims related to the subject assault.   \n \n \nThis case was first reported in The Cornell Daily Sun on September 18, 2026.1 The case \nwas also first published in New York Post, a major market newspaper, on September 18, 2026. 2 \nMy name was not mentioned in either publication, nor was I interviewed by either outlet before \nthe stories were published. At the time the lawsuit was first reported in the media, I was \noverseas. Following the reporting about the case in the New York Post, media interest has been \nextraordinary, and it continues to be because the case involves a matter of significant \ninternational interest: sexual abuse of women on college campuses.  \n \n \n1 https://www.cornellsun.com/article/2026/09/tccsuykuvb4z \n2 https://nypost.com/2026/09/18/us-news/cornell-frat-bros-gang-rape-student-texting-free-p-y-during-sick-assault-\nshocking-lawsuit/ \nDAVID B. RHEINGOLD \u25ca \nTHOMAS P. GIUFFRA \u2666\u25cb \nEDWARD A. RUFFO \u2666 \nJEREMY A. HELLMAN \nETHAN J. COHEN \u2666 \n \nOf Counsel \nSHERRI L. PLOTKIN \u2666 \n                          \nPAUL D. RHEINGOLD (1933 - 2026) \n    Founding Partner   \nAlso Admitted In:  \nNew Jersey \u2666 \nUtah \u25cb \nVirginia \u25ca \n \nFILED: NEW YORK COUNTY CLERK 10/14/2026 05:57 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 66\nRECEIVED NYSCEF: 10/14/2026\n1 of 12\n\n--- Page 2 ---\nI have been previously involved in other high profile litigations including claims against \nHarvey Weinstein and Sean Combs among other matters. I am a lawyer who is known in New \nYork legal circles as an experienced, well-credentialed and ethical trial attorney. As a result, I \nhave had the opportunity to handle significant cases. However, I am by no means a \u201cmedia \nlawyer\u201d as is being argued.  \n \n \nI fully acknowledge that the media response far exceeded what I had expected as well as \nthe ramifications to my client, myself and both our families. However, my response to media \ninquiries has been reactive; reacting to leaks and developments in areas other than the civil \nlawsuit in which I am acting as an attorney.   \n \n \nMovant has argued that I have engaged in a meticulously planned \u201cmedia blitz\u201d that was \nin the works long before the filing of this case. This is not true. All my media responses have \nbeen reactive to questions posed about the criminal investigation and in response to evidentiary \nleaks perpetrated by the defendants to media outlets. There was no pre-planning for media prior \nto the filing of the case. In fact, all the media inquiries have been personally addressed by myself \nor my staff. We do not have a public relations company involved. This is simply a falsehood that \nthe movant is presenting as fact.  \n \n \nThroughout the past two weeks, I have received numerous requests from the media for \nthe Title IX records, including the exhibits, conclusions and testimony. I certainly do have these \nrecords in my possession as Ms. Doe\u2019s attorney. Similarly, other than Cornell, the only parties \nthat would have possession of the Title IX records would be Defendants and their attorneys. \nWhen media outlets have requested the Title IX documents, I have uniformly told them that I \nwould not be able give the records to them because we agreed that they would be kept \nconfidential at the time of the Title IX hearings. Certainly, much of what is contained in these \nrecords is favorable to my client. However, we made a confidentiality agreement, and we intend \nto honor it.  \n \nI am happy to provide the Court, for an in camera review, copies of multiple emails and \ntexts where these records were sought from me and I rejected the request. Based on what I know \nabout who had copies of the records and who it was released to, it is very clear to me that \nrepresentatives of the Defendants have leaked the Title IX records to the media to push a \nnarrative in favor of their clients to a certain media outlet with direct ties to one of the attorneys \nhandling the related criminal matter.  \n \nI will state exactly what I have provided for media outlets: \n \n1. The Second Page of the Group Chat included in the complaint; \n2. Copies of various threats received by Ms. Doe and me; \n3. Copies of the Police Reports regarding the swatting incidents at Ms. Doe\u2019s family \nhome.  \n \n \n \n \nFILED: NEW YORK COUNTY CLERK 10/14/2026 05:57 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 66\nRECEIVED NYSCEF: 10/14/2026\n2 of 12\n\n--- Page 3 ---\nIt is very clear to me that all the Title IX evidence and testimony that has been released to \nthe media has been released by attorneys representing the Defendants. I can state with certainty \nthat the Title IX leaks have not come from any representative of the Plaintiff. They have been \nleaked by the Defense to the media outlets of their choosing to attempt to create a perception that \nthe rapes and assaults were somehow consensual. Based on their conduct in releasing materials \nthat were supposed to be confidential, to do exactly what they are accusing me of, is certainly the \ndefinition of ironic.   \n \nFollowing the publicity of this case, extensive inquiry was directed at the actions of the \nlocal district attorney and the actions of the Cornell Police in investigating the criminal case. \nThis was extensively reported on and resulted in Governor Hochul appointing a special \nprosecutor based on the obvious failures of local law enforcement that came to light.  \n \nBased on my involvement with the Sean Combs litigation, I am very familiar with how \ndefense firms appoint a shadow member of the defense team to push its agenda in the national \nmedia. The same tactics are being utilized in this matter. Following the positive result of having \na Special Prosecutor appointed, Defendants counsel began making public statements in the \nmedia about the case.  \n \nAttorney Jeremy Saland appeared in the media numerous times and made statements \nabout evidence regarding witness statements, negative hair follicle drug testing done almost 90 \ndays after the assaults and also repeatedly highlighting the findings of the Title IX Board.3 I will \nnot burden the Court with summarizing all of Mr. Saland\u2019s appearances. But suffice to say, he \npublicly disseminated pertinent facts of the case, confidential Title IX findings and medical \ntesting results as well as advocating heavily for his client.  \n \nPerhaps the most repugnant statement that Mr. Saland gave was when he stated that Ms. \nDoe\u2019s claims were nothing more than a \u201cmoney grab.\u201d4 Mr. Saland\u2019s comments were not well \nreceived in the media. Nor were they well received by Ms. Doe.  \n \nNevertheless, shortly after this wrong-footed rebuttal of the case, selective parts of the \nTitle IX records began to be released. Following this, other Defense attorneys entered the fray \nand began discussing the case. Andrew Miltenberg appeared on CBS News and NewsNation \n(Cuomo & Pavlich) and extensively discussed the leaked texts and argued the facts of the case \nand questioned the credibility of Ms. Doe. \n \n \n3 https://www.youtube.com/watch?v=CRAMTzGuCi0; https://www.cbsnews.com/newyork/news/cornell-university-\nrape-allegation-chi-phi-snapchat-conversation/; https://www.nbcnews.com/news/us-news/investigative-records-\ngive-insight-accused-cornell-student-responded-a-rcna600987; \nhttps://www.facebook.com/NewsNationNow/videos/cornell-7-sexual-assault-case-reopened-accused-mans-attorney-\nspeaks-out/1389106529975871/; https://www.cnn.com/2026/09/29/us/video/cnn-sitroom-pamela-brown-jeremy-\nsaland-jane-doe-cornell-seven-client-sexual-assault-university-fraternity; \nhttps://www.youtube.com/watch?v=WHXMNh87f30; https://www.nytimes.com/2026/10/03/nyregion/cornell-men-\nuniversity-discipline.html; https://www.cornellsun.com/article/2026/10/records-reveal-cornell-s-punishments-for-\nseven-chi-phi-defendants \n4 https://nypost.com/2026/09/28/us-news/accused-cornell-frat-bros-lawyer-dismisses-heinous-rape-claims-as-\nmoney-grab/ \nFILED: NEW YORK COUNTY CLERK 10/14/2026 05:57 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 66\nRECEIVED NYSCEF: 10/14/2026\n3 of 12\n\n--- Page 4 ---\nThereafter another Defense lawyer, Tara Davis appeared on the Megyn Kelly Show and   \ndiscussed \u201cbombshell\u201d revelations about Ms. Doe\u2019s \u201cchanging account\u201d and the existence of \n\u201cfalse narratives.\u201d  \n \nThroughout this period, TMZ has reported and regurgitated the texts to undermine Ms. \nDoe\u2019s story. This has been a continuous process and has been a regular part of their reporting \npaired with regular interviews with attorney Mark Geragos. Mr. Geragos has also appeared \nnumerous times on NewsNation to opine on all the \u201cissues\u201d with Ms. Doe\u2019s case.  \n \nMr. Geragos\u2019s entry into the media fray with the goal of undermining a survivor\u2019s claim \nis one that I have seen before. When I was initially interviewed on the Cuomo Show in \nDecember 2024, regarding three cases that I had filed against Sean Combs, Mr. Geragos \nappeared as the \u201ccounterpoint\u201d and assumed the mantle of apologist for Mr. Combs.5 \nUnbeknownst to me at the time, his daughter, Teny Geragos, the current criminal attorney for \nDefendant Winston Lee in this matter, was the then-attorney for Mr. Combs. \n \nFollowing this appearance and thereafter, I closely followed the Combs case to monitor \nthe interplay between Mr. Geragos and the media and his influential role in the defense strategy \nand public messaging despite not being an official member of the trial team. This culminated in \nprosecutors objecting to his role as a \u201cspokesman\u201d for the defense.6 He was ultimately \nadmonished by the judge overseeing the case for his role as the \u201cunofficial\u201d member of the \ndefense team.7&8  \n \nBeing fully aware of the connection with Mr. Geragos and his daughter in this case, I \nhave been keeping a close eye on whether he would take on a repeat role of the one he took \nduring the Combs litigation as the public messaging point person for the defense. In due course, \nMr. Geragos has already made repeated appearances on TMZ continually attacking Ms. Doe\u2019s \ncredibility in the media. Unsurprisingly, leaks of the prior confidential proceedings in this case \nhave emanated through TMZ, in which Mr. Geragos has close ties. One can put the pieces \ntogether and understand what might be afoot. The role of Mr. Geragos and others has been to \nincrease the temperature surrounding this case not lower it. \n \nAs new limited details about the case were released, bigots online rushed to the defense \nof the alleged perpetrators and attacked Jane Doe and other survivors of sexual assault.9 This has \nlargely resulted from the selective reporting of materials related to the defense leak of Title IX \ndocuments. This resulted in a stampede of people trying to identify Ms. Doe and out her online. \n \n5 https://www.newsnationnow.com/cuomo-show/three-men-suing-sean-diddy-combs-rape/ \n6 https://www.hollywoodreporter.com/news/general-news/sean-diddy-combs-mark-geragos-prosecutors-letter-\n1236208857/ \n7 https://www.nbcnews.com/news/us-news/attorney-mark-geragos-calls-sean-diddy-combs-prosecutors-six-pack-\nwhit-rcna205355 \n8 https://www.foxnews.com/entertainment/celebrity-lawyer-mark-geragos-steals-diddy-trial-spotlight-runs-trouble-\njudge \n9 https://globalextremism.org/post/cornell-assault-case/ \nFILED: NEW YORK COUNTY CLERK 10/14/2026 05:57 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 66\nRECEIVED NYSCEF: 10/14/2026\n4 of 12\n\n--- Page 5 ---\nOther women have been misidentified as Ms. Doe. These individuals know that they are beyond \nthe power of this Court and are acting in an irresponsible and cruel manner.  \n \nWe acknowledge misidentifying a person as Mr. Ingalls. When we were appraised of this, \nwe immediately contacted the Court to correct this mistake, owned our error and apologized. We \ndid not realize at the time that Mr. Ingalls was from Dubai and his legal first name was Umar.10 \nWe acted in good faith because the individual identified fit the search criteria that we had.  \n \nI have made several appearances attempting to calm the situation down and to bring the \ntemperature down without avail. The threats continued and escalated so that Ms. Doe received \nseveral violent threats and a phone call threatening to kill her family. This culminated in a \nswatting incident at her family home where her father, brother and friends had weapons drawn \non them by police who were doing their job.11 The threats to Ms. Doe continued and the \nfollowing day threats were made on my wife\u2019s life and I was required to hire armed security to \nguard my home.  \n \nI said very clearly when interviewed that \u201cenough was enough\u201d and took a tone which \nwas geared to effectively calm the situation down. I also noted that certain minor and \nirresponsible members of the media were sowing hate and reaping what they sowed. This \nresulted in an outpouring of support from many for what Ms. Doe was being subjected to and \ncalmed things down. I believe that this was good use of the media by me to bring attention to \nwhat was going on and to try to stop it12. It certainly worked because the threats ended shortly \nthereafter.     \n \nI have been a member of this Court for over 30 years, and I know what limits there are on \nspeech related to trial publicity. I have repeatedly appeared in the media to state that this is not a \npolitical case and that the rancor was too much13. Most of what my interviews focused on are the \nthreats that Ms. Doe and I have received, responses to attacks regarding the Defense\u2019s leaked \ntext messages, abusive statements from minor podcasters, among other leaked evidence.  \n \nThe real motivation for movants attempts to effectively muzzle me is twofold.  Due to my \nvast experience in handling abuse cases, the extensive studies I have read and many \nconversations that I have had with experts in trauma, regarding the impact of trauma on \nsurvivors, I am able to rebut their efforts to undermine Ms. Doe\u2019s credibility by utilizing their \nown documents that they have leaked.  \n \nExcept for a few obscure or defense related media outlets, this has resulted in a positive \ndiscourse by people to learn more about the impact of trauma and the idea that responses to rape \nare not always as one would expect in the immediate aftermath. This has led to greater education \non this subject and experts in the field have weighed in to explain this. I believe that this has \n \n10 https://nypost.com/2026/10/10/us-news/sodomized-cornell-frat-bro-is-anti-us-son-of-dubai-islamic-studies-prof/ \n11 https://en.wikipedia.org/wiki/Swatting \n12 https://www.cnn.com/2026/10/07/us/cornell-lawsuit-student-protests-hnk \n13 https://www.youtube.com/watch?v=Fx-FAyChGQ0 \nFILED: NEW YORK COUNTY CLERK 10/14/2026 05:57 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 66\nRECEIVED NYSCEF: 10/14/2026\n5 of 12\n\n--- Page 6 ---\nbeen for the good. Movant does not care for this because it undermines the use of leaked \nmaterials to create a false narrative14.   \n \nThe second reason for this application is that they want to control the narrative and \ncontinue to leak confidential information to \u201cfriendly\u201d media outlets and push their version of the \nevents through surrogates. Clearly, this is what was done in the Combs case, and I believe this is \nwhat is happening here.  \n \nHowever, this is too important a case to permit the defendants to run rough shod with a \nsurrogate pushing their agenda while Ms. Doe must in effect \u201ctake it\u201d. That would be manifestly \nunfair and unjust. My media appearances have been focused on righting the ship in the face of \nintense attacks on Ms. Doe orchestrated by the defense and others, her credibility and the \ndangers that coming public have brought upon her and her family. I have done this without \nleaking any confidential documents.  \n \nPreventing me from speaking on her behalf effectively stifles Jane Doe and plays directly \nin the hands of the Defendants who do not want a level playing field in the public eye.  Aside \nfrom the unfairness of the relief sought, the application is in direct violation of the First \nAmendment. Certainly, courts are permitted to issue gag orders in appropriate circumstances, but \nas  described herein the instant application flouts all restrictions and there is no foundation for \nthe relief sought.  \nSummary of Legal Arguments \n \n \nThis order to show cause should not be signed as an inadequate showing has been \ndemonstrated for the extraordinary relief sought. As demonstrated in this letter, a prior restraint on \nspeech requires a finding that there is a clear and present danger to the administration of justice. \nEven then, if alternative remedies can be utilized to mitigate the prejudice and protect the right to \na fair trial, then the restraint is uncalled for.  \n \nFurthermore, even if a prior restraint on speech is appropriate, same must be as targeted as \npossible so only the bare minimum of speech is restricted. Similarly, any order must not be vague, \nas otherwise parties would need to overly restrict their speech to make sure they are complying. \nFinally, the ability to respond to bad press must be protected under all circumstances, otherwise \nthe court\u2019s protections would themselves be causing damage to those that abide. This letter \ndemonstrates that for all of the indicated reasons, there should be no restrictions imposed herein.  \n \nThe Clerk\u2019s Rejection & the Amended Filing \n \n \nThis proposed order to show cause was originally filed on October 9, 2026, but was rejected \nby the ex-parte clerk since the TRO request was non-existent. Originally, defendant merely asked \nthat the court place \u201cinterim restrictions\u201d, which was not a request for anything in specific. \nPaukman v. Uvaydov, 2024 NY Slip Op 51689(U) (Sup. Ct., Kings County 2024) (\u201cthe Court \n \n14 While I am loathe to waste this Court\u2019s time discussing Megyn Kelly and her statements that Ms. Doe was ugly \nand in effect \u201clooking to be raped\u201d. I believe my response to this trope was helpful to all survivors who are \nvictimized in such a mean-spirited way.  https://www.ms.now/opinion/megyn-kelly-cornell-jane-doe-hypocrite; \nhttps://www.thedailybeast.com/megyn-kelly-torched-by-alleged-cornell-rape-victims-lawyer-after-sick-attack. \nFILED: NEW YORK COUNTY CLERK 10/14/2026 05:57 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 66\nRECEIVED NYSCEF: 10/14/2026\n6 of 12\n\n--- Page 7 ---\nfinds that his order to show cause fails the most basic requirement of motion practice, that it specify \n\"the relief demanded and the grounds therefor\"\u201d). In their amended filing yesterday, defendant \nnow asks that the court issue a TRO granting all of the requests for relief made in the order to show \ncause. This was a material change. \n \nLegal Standard of Prior Restraints of Speech \n \nThe First Department in Ash v Board of Mgrs. of the 155 Condominium, 44 AD3d 324 \n(1st Dept. 2007) noted that: \n \nany imposition of prior restraint, whatever the form, bears a \"heavy \npresumption against its constitutional validity\" \u2026 and a party \nseeking to obtain such a restraint bears a correspondingly heavy \nburden of demonstrating justification for its imposition \u2026 It is also \nincumbent upon a trial court to insure that each of the parties \nreceives a fair trial and, to that end, possesses both the power and \nresponsibility to safeguard their rights \u2026 The trial court, in so doing, \nmust bear in mind the fact that prior restraints upon the rights of free \nspeech and publication \"may only be overcome upon a showing of \na 'clear and present danger' of a serious threat to the administration \nof justice\". \n \nThe case of Karantinidis v. Karantinidis, 186 A.D.3d 1502, 131 N.Y.S.3d 363 (2nd Dept. \n2020) includes an on-point rendition of the legal principles at issue:  \n \nThe defendant correctly contends that the portion of the order \ngranting that branch of the plaintiff's motion which was for an order \ndirecting the defendant not to discuss, demean, or disparage the \nplaintiff to any third parties, including but not limited to the \nplaintiff's patients, was an unconstitutional prior restraint on speech. \nA prior restraint on speech is a law, regulation  or judicial order that \nsuppresses speech on the basis of the speech's content and in \nadvance of its actual expression \u2026 Any imposition of prior restraint, \nwhatever the form, bears a \"heavy presumption against its \nconstitutional validity, and a party seeking to obtain such a restraint \nbears a correspondingly heavy burden of demonstrating justification \nfor its imposition\" \u2026 An injunctive order issued in the area of First \nAmendment rights must be couched in the narrowest terms that will \naccomplish the pin-pointed objective permitted by constitutional \nmandate and the essential needs of the public order \u2026 The order \nmust be tailored as precisely as possible to the exact needs of the \ncase. \n \n \n \n \nFILED: NEW YORK COUNTY CLERK 10/14/2026 05:57 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 66\nRECEIVED NYSCEF: 10/14/2026\n7 of 12\n\n--- Page 8 ---\nNo Showing of Any Clear and Present Danger \n \nThe speech that is curtailed must also be shown to represent \u201ca clear and present danger of \na serious substantive evil\u201d. Kassenoff v. Kassenoff, 213 A.D.3d 822, 183 N.Y.S.3d 533 (2nd Dept. \n2023) (\u201ca party must demonstrate that the speech sought to be restrained is \"'likely to produce a \nclear and present danger of a serious substantive evil that rises far above public inconvenience, \nannoyance, or unrest' \u2026 An order imposing a prior restraint on speech \"must be tailored as \nprecisely as possible to the exact needs of the case\"\u201d); United States v. Cutler, 58 F.3d 825 (2d \nCir. 1995) (\u201cspeech that fell within a proscribed category had to be reasonably likely to interfere \nwith a fair trial or otherwise prejudice the due administration of justice\u201d). Lowinger v. Lowinger, \n264 A.D.2d 763, 695 N.Y.S.2d 127 (2nd Dept. 1999) (\u201cOrders restraining extrajudicial comments \nby the parties or their attorneys are not generally permitted unless there is a reasonable likelihood \nof the existence of serious threat to the right to a fair trial\u201d).  \n \nI have spoken to the press. But my communications were limited to discussing what is \npublicly available through the complaint, and fair comment on what is already publicly available. \nThere is no showing that my statements are beyond what I would be able to say at trial. \nAccordingly, there is no possible showing that I have caused any unfair influence on potential \njurors. As such, there is no showing that any actual danger of misconduct is clearly expected, \nwhich was movant\u2019s burden to demonstrate.  \n \nNo Showing that Alternative Remedies Cannot Prevent Suspected Issues \n \n \nEven where prior restraints on free speech are otherwise indicated, they should still not be \nmade where alternative remedies can prevent the suspected abuse. For instance, in Cleveland v \nPerry, 175 AD3d 1017 (2nd Dept. 2019) it was found that even where \u201csuch statements present a \n'reasonable likelihood' of a serious threat to [defendants'] right to a fair trial\"\u201d, there still should \nnot have been any restrictions on what the attorneys could say where \u201cthere is no evidence in the \nrecord \"that less restrictive alternatives would not be just as effective in assuring the defendant[s] \na fair trial\"\u201d. The court in Cleveland found that \u201cInasmuch as alternative remedies such as a \n\"searching voir dire\" and \"emphatic jury instructions\" \u2026 would be sufficient to mitigate the \nprejudice to defendants and protect their right to a fair trial\u201d. Here, no such showing is made.  \n \nAlong these lines, Nat'l Broad. Co. v. Cooperman, 116 A.D.2d 287, 501 N.Y.S.2d 405 (2nd \nDept. 1986) describes in detail that even if statements were \u201creasonably likely to pose a serious \nthreat to the defendants' 6th Amendment right to a fair trial\u201d, a restraint on speech would still not \nbe permissible if \u201cthere is no indication in the record that less restrictive alternatives to the prior \nrestraint on counsel's extrajudicial statements would not have been just as effective in preserving \nthe police officers' right to a fair trial. Sequestration of the jury, postponement of the trial to allow \npublic attention to subside, a change of venue, a comprehensive and searching voir dire of potential \njurors and the use of emphatic instructions to the jurors regarding their sworn duty to decide the \ncase only on the evidence presented at trial, are all less restrictive alternatives to a prior restraint \nupon the free speech of the attorneys and other participants in the case\u201d. As such, the court summed \nup its holding that \u201ca trial court may not impose prior restraints upon attorneys and other \nparticipants in a trial without the requisite showing of a necessity for such restraint and a \nFILED: NEW YORK COUNTY CLERK 10/14/2026 05:57 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 66\nRECEIVED NYSCEF: 10/14/2026\n8 of 12\n\n--- Page 9 ---\ndetermination that less restrictive alternatives would not be just as effective in assuring the \ndefendant a fair trial\u201d. Id. \n \nInstead, in defendant\u2019s Memorandum of Law, defendant lodges an unsupported argument \nthat \u201cThose trial-stage measures do not fully address the present circumstances. This action is in \nits infancy, some parties have not appeared, and the publicity is ongoing. The harm includes not \nonly possible juror prejudice, but also the public dissemination of nonpublic personal information \nand the danger of threats, doxing, intimidation, and extrajudicial contact\u201d. This response to the \nalternative remedies argument primarily regards the doxing issue, which has primarily impacted \nMs. Doe, and the fact that currently the case is in the news. While defendant mentions that a trial \nis far away, this cuts the other way, diminishing the potential impact. Overall, there is no \nexplanation offered for why careful jury selection and specified instructions will not prevent the \nharm defendant seems to fear.  \n \nDefendant Merely Proposes a General Legal Standard as a Prohibition,  \nRendering the Requested Prohibitions Vague and Overly Broad \n \n \nThe proposed order to show cause should not be signed as the relief sought is so vague \nthat it would have a chilling effect on all related speech to make sure one does not transgress the \nambiguous order. \n \n \nDefendant asks that extrajudicial statements not be made to the media if they have \u201ca \nsubstantial likelihood of materially prejudicing the adjudicative process in this action\u201d. This is a \nmere regurgitation of a legal standard, and leaves it to the attorneys to guess as what may or may \nnot violate that standard. For instance, the court in People v. Buttafuoco, 158 Misc. 2d 174, 599 \nN.Y.S.2d 419 (Cnty. Ct. 1993) started with such a standard, but then went into detail to \ndemonstrate what precisely was included in such requirement. Without such delineations, the order \nwould bar more than necessary, which is legally inappropriate.  \n \nAdditionally, an order may be overbroad when it prevents parties from discussing the case \nwith witnesses or hinders investigation. Doe v. Eliyas, 241 A.D.3d 1271, 242 N.Y.S.3d 286 (2nd \nDept. 2025) (\u201cthe Supreme Court's temporary restraining order was overbroad, such that it \nprevented the defendants from discussing the instant action with third-party witnesses or disclosing \nthe plaintiffs' names for investigative purposes\u201d); See N.Y. Times Co. v. Rothwax, 143 A.D.2d \n592, 533 N.Y.S.2d 73 (1st Dept. 1988) (\u201cThe sua sponte gag order \u2026 suffers from the further \nconstitutional infirmity of being overbroad, for \"assuming that the respondent had properly \nconcluded that prior restraint upon the extrajudicial statements of attorneys was necessary, the \nprior restraint should have been limited solely to information or statements which might be likely \nto impugn the fairness and integrity of the trial\"\u201d). \n \n \nHere, the only specifics included in defendant\u2019s proposal are found two demands later, \nwhen proposing a prohibition of \u201cpublicly disclosing, republishing, or disseminating the \nfollowing information \u2026\u201d, after which five categories are mentioned; each is flawed. Before \ngetting to those specifics, the first glaring problem with this formulation is that there is no \nindication of whether even court filings themselves can mention this information, as court filings \nare public, this formulation seems to bar the parties in terms of what they can even say to the court. \nFILED: NEW YORK COUNTY CLERK 10/14/2026 05:57 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 66\nRECEIVED NYSCEF: 10/14/2026\n9 of 12\n\n--- Page 10 ---\na. Any residential address or other nonpublic personal identifying  \ninformation concerning any party, witness, alleged victim, or nonparty; \n \n \nThis request would appear to bar an attorney from mentioning the name of any nonparty, \neven in court filings. There is no indication given anywhere for why nonparties require some sort \nof protection. All we have seen from defendant\u2019s offer is that parties (or persons believed to be \nparties) have been subject to internet scorn, not nonparties. The demand is entirely overbroad, \nmaking no distinctions or qualifications whatsoever. However, I take no issue if addresses of the \nparties are redacted in Court filings.   \n \nb. Materials produced in discovery that have not  \nbeen filed in a publicly accessible court record; \n \n \nThis formulation does not make it clear whether the materials can be filed in the first place. \nIt just says that if they have been, then they can be disseminated. In any event, the request is overly \nbroad since it bars all materials that have not been filed. There is no reason given why all discovery \nmust be kept secret. Surely, it should depend on the content of the specific document. This demand \nmakes no distinction and is therefore facially overbroad. In any event, Defendants have been the \nones leaking documents, not the Plaintiff.  \n \nc. Statements concerning the expected testimony, character, credibility, reputation,  \nor personal history of any party or witness, where such statements create a  \nsubstantial likelihood of materially prejudicing the adjudication of this action; \n \n \nThis demand again regurgitates a legal standard of \u201csubstantial likelihood of materially \nprejudicing the adjudication\u201d, while failing to indicate what sort of statements would violate that \nstandard. The demand further gives no indication of what these \u201ccharacter etc.\u201d types of statements \nwould refer to. Everything is left utterly vague. \n \nd. The contents or purported contents of any nonpublic statement,  \ncommunication, examination, test, investigative material, or physical evidence  \nthat may be offered in this action, where disclosure creates a substantial  \nlikelihood of materially prejudicing the adjudication of this action; \n \n \nThis demand again fails to indicate whether such materials can be filed with the court, and \nwhether the act of filing now makes such documents public. This demand also regurgitates a legal \nstandard of \u201csubstantial likelihood of materially prejudicing the adjudication\u201d, while failing to \nindicate what sort of materials would violate that standard. \n \ne. Any statement inviting, encouraging, or facilitating threats,  \nharassment, intimidation, doxing, or extrajudicial contact directed  \ntoward any party, witness, counsel, juror, prospective juror, or nonparty; \n \n \nThis formulation prohibits \u201cfacilitating\u201d, but it in no way qualifies what that term includes. \nWhile \u201cinviting\u201d and \u201cencouraging\u201d are active terms that can be defined, \u201cfacilitating\u201d is a general \nFILED: NEW YORK COUNTY CLERK 10/14/2026 05:57 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 66\nRECEIVED NYSCEF: 10/14/2026\n10 of 12\n\n--- Page 11 ---\nterm with many facets, and can even include an unwanted and unintended consequence of proper \nconduct. This demand is therefore not only vague, but entirely overbroad. \n \n \nGiven the substantial problems with defendants\u2019 formulation of prohibitions in their \nproposed order to show cause, a TRO that grants what defendant wants is highly problematic. \nThere are too many loose ends in defendant\u2019s chosen formulation, the terms are overbroad, and \nthere is no showing why any of this (aside from potential doxing materials) is needed in order to \nprevent abuse. Therefore, the requested prior restraint on free speech is uncalled for, especially as \ninterim relief, given the plethora of problems with the formulations at issue that are readily \nnoticeable even without a full briefing in opposition. \n \n \nI am quite confused by this application as the person who has been subjected to death \nthreats, harassment, intimidation (to withdraw her case or her family would be killed), doxing, \ndeath threats and swatting has been Ms. Doe. Not any of the defendants. I believe that much this \nhas been caused by the leaks and ensuing credibility attacks done by the defendants and their \nsurrogates. It was reasonable and a positive dialogue was going on until the counter arguments \nwere offered up due to the leaks.    \n \n \nThe Imbalance A TRO Would Create \n \n \nA TRO here would heavily hinder plaintiff\u2019s counsel, even as defendants\u2019 surrogates would \nbe able to say whatever they wanted. As materials from the Title IX hearing have improperly \nslowly trickled out, it is apparent that parties have been resourceful in having others \u2018find\u2019 \ninformation and disseminate it.  \n \nTo put a bar on the attorneys in this case, however, will leave the parties unable to counter \nwhatever soundbites are taken out of context from proceedings that were already supposed to be \nconfidential from surrogates. This would leave the Defendants with the upper hand, while tying \nthe hands of those that have a moral responsibility to act properly \u2013 even without the issuance of \na specific court order. Jane Doe No. 1 v. Zeder, 5 Misc. 3d 574 (Sup. Ct., Onondaga County 2004) \n(\u201cIt is worth pointing out that defendant Keating has made liberal and aggressive use of the press \nin advancement of his position in this action. In this regard, the court is mindful that DR 7-107 (a) \npermits a lawyer to make a statement that a reasonable lawyer would believe is required to protect \na client from the substantial prejudicial effect of recent publicity not initiated by the lawyer or the \nlawyer's client\u201d). \n \nIn fact, New York Rules of Professional Conduct, \u00a73.6(d) specifically allows lawyers to \nrespond to adverse publicity: \u201cA lawyer may make a limited statement reasonably necessary to \nprotect a client from substantial prejudice caused by recent adverse publicity not initiated by the \nlawyer or client\u201d Id. Defendant\u2019s proposed order to show cause serves to undercut this provision, \nwhich would unfairly punish those that follow the rule of law, while emboldening those that are \nnot subject to the court\u2019s jurisdiction. The rules specifically allow such replies to prevent this unfair \nimbalance, and this right should not be taken away. This is what I have done with respect to the \nleaks. Perhaps too well since movant is now seeking to silence me. Obviously, they want their \narguments presented without an alternate being offered.  \nFILED: NEW YORK COUNTY CLERK 10/14/2026 05:57 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 66\nRECEIVED NYSCEF: 10/14/2026\n11 of 12\n\n--- Page 12 ---\nCertainly, these \u2018proxy representation\u2019 and \u2018surrogacy\u2019 issues are becoming more apparent \nby the day, which reflects how a full record and briefing are necessary here. Indeed, where both \nsides are making public disclosures, a restraint on free speech is even less appropriate. Barker v \nVictorious Life Christian Church, 72 Misc 3d 898 (Sup Ct, Albany County 2021) (\u201cAlthough the \ndefendants have asserted, in conclusory fashion, that potential news/social media coverage might \ntaint the jury pool, they have not made a factual showing that the possibility of such coverage \npresents a \"clear and present danger\" to the administration of justice. It is worth pointing out that \ndefendant Brignola \u2026 has made use of the press to advance his own view of this action \u2026 In other \nwords, the plaintiff is not alone in making the type of statements to the press about which the \ndefendants now complain\u201d).  \n \nPrematurity \n \n \nFinally, it must be pointed out that this application is premature. This case is still brand \nnew, not all defendants have appeared, only one has answered, and I believe no defendants are \neven in default yet. Other parties may have their own take on these issues and should not be \nrestricted before they have even had a chance to comment. Furthermore, other defendants may \nwant to make their own motion. It would be imprudent to have one motion active, with its own \nschedule, while other similar motions have yet to be made. This problem would be compounded \nif there are potentially multiple TRO\u2019s that would end up being in place. All of these issues are \nbrought to the fore by the early filing of this application, rendering same premature.  \n \nConclusion \n \n \nGiven the many issues discussed herein, the proposed order to show cause should not be \nsigned, and certainly no TRO should be granted without a full briefing on the complex legal and \nfactual issues that defendant\u2019s overbroad, vague, legally unsupported, and legally unnecessary \nformulations proposals evince.  \n \nRespectfully submitted, \n \nThomas P. Giuffra \n \ncc: All defendants via email: \n \njknox@hackermurphy.com; abhimani@hackermurphy.com; ebernstein@nylegaljustice.com; \ntdavis@nmllplaw.com; nino@lamalaw.com; ehallak@harrisbeachmurtha.com; \nasash@bushellsovak.com; echohen@rheingoldlaw.com; sbernstein@nmllplaw.com; \nmcuccaro@shertremonte.com; rfriedman@shertremonte.com; rsweeney@mgmlaw.com \nFILED: NEW YORK COUNTY CLERK 10/14/2026 05:57 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 66\nRECEIVED NYSCEF: 10/14/2026\n12 of 12","text":"--- Page 1 ---\nRG1U&H\nRHBINGOLD GIUFPRA RUPPO\nPLOTKIN & HELLMANLLP\n551 FIFTH AVE | 29TH FLOOR | NEW YORK, NEW YORK 10176 \nPHONE (212) 684-1880 | FAX (212) 689-8156 | WWW.RHEINGOLDLAW.COM \n \n \n \nOctober 14, 2026 \n \nVia NYSCEF \nHon. Phaedra F. Perry-Bond, J.S.C. \nSupreme Court, New York County \nIAS Part 35  \n60 Centre Street, Courtroom 252  \nNew York, New York 10007 \n \n    Re:  Jane Doe v. Cornell University, Inc., et al. \nSupreme Court | New York County | Index No. 161704/2026  \n \nDear Judge Perry-Bond: \n \n \nPursuant to the court\u2019s email of October 12, 2026, Plaintiff submits the following letter in \nopposition to the signing of the proposed order to show cause, and its TRO request, filed by \nDefendant Diego Sarabia (NYSCEF 48, 49, 50). The proposed order to show cause is completely \nmisguided and must be denied.  \n \nStatement of Facts \n \n \n \nThis is a claim made for the rape of Jane Doe that occurred in the Chi Phi House at \nCornell University on October 19-20, 2024. I will not discuss the facts of the case as they have \nbeen widely reported in the media. On September 16, 2026, we filed a lawsuit against several \nindividuals and entities for claims related to the subject assault.   \n \n \nThis case was first reported in The Cornell Daily Sun on September 18, 2026.1 The case \nwas also first published in New York Post, a major market newspaper, on September 18, 2026. 2 \nMy name was not mentioned in either publication, nor was I interviewed by either outlet before \nthe stories were published. At the time the lawsuit was first reported in the media, I was \noverseas. Following the reporting about the case in the New York Post, media interest has been \nextraordinary, and it continues to be because the case involves a matter of significant \ninternational interest: sexual abuse of women on college campuses.  \n \n \n1 https://www.cornellsun.com/article/2026/09/tccsuykuvb4z \n2 https://nypost.com/2026/09/18/us-news/cornell-frat-bros-gang-rape-student-texting-free-p-y-during-sick-assault-\nshocking-lawsuit/ \nDAVID B. RHEINGOLD \u25ca \nTHOMAS P. GIUFFRA \u2666\u25cb \nEDWARD A. RUFFO \u2666 \nJEREMY A. HELLMAN \nETHAN J. COHEN \u2666 \n \nOf Counsel \nSHERRI L. PLOTKIN \u2666 \n                          \nPAUL D. RHEINGOLD (1933 - 2026) \n    Founding Partner   \nAlso Admitted In:  \nNew Jersey \u2666 \nUtah \u25cb \nVirginia \u25ca \n \nFILED: NEW YORK COUNTY CLERK 10/14/2026 05:57 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 66\nRECEIVED NYSCEF: 10/14/2026\n1 of 12\n\n--- Page 2 ---\nI have been previously involved in other high profile litigations including claims against \nHarvey Weinstein and Sean Combs among other matters. I am a lawyer who is known in New \nYork legal circles as an experienced, well-credentialed and ethical trial attorney. As a result, I \nhave had the opportunity to handle significant cases. However, I am by no means a \u201cmedia \nlawyer\u201d as is being argued.  \n \n \nI fully acknowledge that the media response far exceeded what I had expected as well as \nthe ramifications to my client, myself and both our families. However, my response to media \ninquiries has been reactive; reacting to leaks and developments in areas other than the civil \nlawsuit in which I am acting as an attorney.   \n \n \nMovant has argued that I have engaged in a meticulously planned \u201cmedia blitz\u201d that was \nin the works long before the filing of this case. This is not true. All my media responses have \nbeen reactive to questions posed about the criminal investigation and in response to evidentiary \nleaks perpetrated by the defendants to media outlets. There was no pre-planning for media prior \nto the filing of the case. In fact, all the media inquiries have been personally addressed by myself \nor my staff. We do not have a public relations company involved. This is simply a falsehood that \nthe movant is presenting as fact.  \n \n \nThroughout the past two weeks, I have received numerous requests from the media for \nthe Title IX records, including the exhibits, conclusions and testimony. I certainly do have these \nrecords in my possession as Ms. Doe\u2019s attorney. Similarly, other than Cornell, the only parties \nthat would have possession of the Title IX records would be Defendants and their attorneys. \nWhen media outlets have requested the Title IX documents, I have uniformly told them that I \nwould not be able give the records to them because we agreed that they would be kept \nconfidential at the time of the Title IX hearings. Certainly, much of what is contained in these \nrecords is favorable to my client. However, we made a confidentiality agreement, and we intend \nto honor it.  \n \nI am happy to provide the Court, for an in camera review, copies of multiple emails and \ntexts where these records were sought from me and I rejected the request. Based on what I know \nabout who had copies of the records and who it was released to, it is very clear to me that \nrepresentatives of the Defendants have leaked the Title IX records to the media to push a \nnarrative in favor of their clients to a certain media outlet with direct ties to one of the attorneys \nhandling the related criminal matter.  \n \nI will state exactly what I have provided for media outlets: \n \n1. The Second Page of the Group Chat included in the complaint; \n2. Copies of various threats received by Ms. Doe and me; \n3. Copies of the Police Reports regarding the swatting incidents at Ms. Doe\u2019s family \nhome.  \n \n \n \n \nFILED: NEW YORK COUNTY CLERK 10/14/2026 05:57 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 66\nRECEIVED NYSCEF: 10/14/2026\n2 of 12\n\n--- Page 3 ---\nIt is very clear to me that all the Title IX evidence and testimony that has been released to \nthe media has been released by attorneys representing the Defendants. I can state with certainty \nthat the Title IX leaks have not come from any representative of the Plaintiff. They have been \nleaked by the Defense to the media outlets of their choosing to attempt to create a perception that \nthe rapes and assaults were somehow consensual. Based on their conduct in releasing materials \nthat were supposed to be confidential, to do exactly what they are accusing me of, is certainly the \ndefinition of ironic.   \n \nFollowing the publicity of this case, extensive inquiry was directed at the actions of the \nlocal district attorney and the actions of the Cornell Police in investigating the criminal case. \nThis was extensively reported on and resulted in Governor Hochul appointing a special \nprosecutor based on the obvious failures of local law enforcement that came to light.  \n \nBased on my involvement with the Sean Combs litigation, I am very familiar with how \ndefense firms appoint a shadow member of the defense team to push its agenda in the national \nmedia. The same tactics are being utilized in this matter. Following the positive result of having \na Special Prosecutor appointed, Defendants counsel began making public statements in the \nmedia about the case.  \n \nAttorney Jeremy Saland appeared in the media numerous times and made statements \nabout evidence regarding witness statements, negative hair follicle drug testing done almost 90 \ndays after the assaults and also repeatedly highlighting the findings of the Title IX Board.3 I will \nnot burden the Court with summarizing all of Mr. Saland\u2019s appearances. But suffice to say, he \npublicly disseminated pertinent facts of the case, confidential Title IX findings and medical \ntesting results as well as advocating heavily for his client.  \n \nPerhaps the most repugnant statement that Mr. Saland gave was when he stated that Ms. \nDoe\u2019s claims were nothing more than a \u201cmoney grab.\u201d4 Mr. Saland\u2019s comments were not well \nreceived in the media. Nor were they well received by Ms. Doe.  \n \nNevertheless, shortly after this wrong-footed rebuttal of the case, selective parts of the \nTitle IX records began to be released. Following this, other Defense attorneys entered the fray \nand began discussing the case. Andrew Miltenberg appeared on CBS News and NewsNation \n(Cuomo & Pavlich) and extensively discussed the leaked texts and argued the facts of the case \nand questioned the credibility of Ms. Doe. \n \n \n3 https://www.youtube.com/watch?v=CRAMTzGuCi0; https://www.cbsnews.com/newyork/news/cornell-university-\nrape-allegation-chi-phi-snapchat-conversation/; https://www.nbcnews.com/news/us-news/investigative-records-\ngive-insight-accused-cornell-student-responded-a-rcna600987; \nhttps://www.facebook.com/NewsNationNow/videos/cornell-7-sexual-assault-case-reopened-accused-mans-attorney-\nspeaks-out/1389106529975871/; https://www.cnn.com/2026/09/29/us/video/cnn-sitroom-pamela-brown-jeremy-\nsaland-jane-doe-cornell-seven-client-sexual-assault-university-fraternity; \nhttps://www.youtube.com/watch?v=WHXMNh87f30; https://www.nytimes.com/2026/10/03/nyregion/cornell-men-\nuniversity-discipline.html; https://www.cornellsun.com/article/2026/10/records-reveal-cornell-s-punishments-for-\nseven-chi-phi-defendants \n4 https://nypost.com/2026/09/28/us-news/accused-cornell-frat-bros-lawyer-dismisses-heinous-rape-claims-as-\nmoney-grab/ \nFILED: NEW YORK COUNTY CLERK 10/14/2026 05:57 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 66\nRECEIVED NYSCEF: 10/14/2026\n3 of 12\n\n--- Page 4 ---\nThereafter another Defense lawyer, Tara Davis appeared on the Megyn Kelly Show and   \ndiscussed \u201cbombshell\u201d revelations about Ms. Doe\u2019s \u201cchanging account\u201d and the existence of \n\u201cfalse narratives.\u201d  \n \nThroughout this period, TMZ has reported and regurgitated the texts to undermine Ms. \nDoe\u2019s story. This has been a continuous process and has been a regular part of their reporting \npaired with regular interviews with attorney Mark Geragos. Mr. Geragos has also appeared \nnumerous times on NewsNation to opine on all the \u201cissues\u201d with Ms. Doe\u2019s case.  \n \nMr. Geragos\u2019s entry into the media fray with the goal of undermining a survivor\u2019s claim \nis one that I have seen before. When I was initially interviewed on the Cuomo Show in \nDecember 2024, regarding three cases that I had filed against Sean Combs, Mr. Geragos \nappeared as the \u201ccounterpoint\u201d and assumed the mantle of apologist for Mr. Combs.5 \nUnbeknownst to me at the time, his daughter, Teny Geragos, the current criminal attorney for \nDefendant Winston Lee in this matter, was the then-attorney for Mr. Combs. \n \nFollowing this appearance and thereafter, I closely followed the Combs case to monitor \nthe interplay between Mr. Geragos and the media and his influential role in the defense strategy \nand public messaging despite not being an official member of the trial team. This culminated in \nprosecutors objecting to his role as a \u201cspokesman\u201d for the defense.6 He was ultimately \nadmonished by the judge overseeing the case for his role as the \u201cunofficial\u201d member of the \ndefense team.7&8  \n \nBeing fully aware of the connection with Mr. Geragos and his daughter in this case, I \nhave been keeping a close eye on whether he would take on a repeat role of the one he took \nduring the Combs litigation as the public messaging point person for the defense. In due course, \nMr. Geragos has already made repeated appearances on TMZ continually attacking Ms. Doe\u2019s \ncredibility in the media. Unsurprisingly, leaks of the prior confidential proceedings in this case \nhave emanated through TMZ, in which Mr. Geragos has close ties. One can put the pieces \ntogether and understand what might be afoot. The role of Mr. Geragos and others has been to \nincrease the temperature surrounding this case not lower it. \n \nAs new limited details about the case were released, bigots online rushed to the defense \nof the alleged perpetrators and attacked Jane Doe and other survivors of sexual assault.9 This has \nlargely resulted from the selective reporting of materials related to the defense leak of Title IX \ndocuments. This resulted in a stampede of people trying to identify Ms. Doe and out her online. \n \n5 https://www.newsnationnow.com/cuomo-show/three-men-suing-sean-diddy-combs-rape/ \n6 https://www.hollywoodreporter.com/news/general-news/sean-diddy-combs-mark-geragos-prosecutors-letter-\n1236208857/ \n7 https://www.nbcnews.com/news/us-news/attorney-mark-geragos-calls-sean-diddy-combs-prosecutors-six-pack-\nwhit-rcna205355 \n8 https://www.foxnews.com/entertainment/celebrity-lawyer-mark-geragos-steals-diddy-trial-spotlight-runs-trouble-\njudge \n9 https://globalextremism.org/post/cornell-assault-case/ \nFILED: NEW YORK COUNTY CLERK 10/14/2026 05:57 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 66\nRECEIVED NYSCEF: 10/14/2026\n4 of 12\n\n--- Page 5 ---\nOther women have been misidentified as Ms. Doe. These individuals know that they are beyond \nthe power of this Court and are acting in an irresponsible and cruel manner.  \n \nWe acknowledge misidentifying a person as Mr. Ingalls. When we were appraised of this, \nwe immediately contacted the Court to correct this mistake, owned our error and apologized. We \ndid not realize at the time that Mr. Ingalls was from Dubai and his legal first name was Umar.10 \nWe acted in good faith because the individual identified fit the search criteria that we had.  \n \nI have made several appearances attempting to calm the situation down and to bring the \ntemperature down without avail. The threats continued and escalated so that Ms. Doe received \nseveral violent threats and a phone call threatening to kill her family. This culminated in a \nswatting incident at her family home where her father, brother and friends had weapons drawn \non them by police who were doing their job.11 The threats to Ms. Doe continued and the \nfollowing day threats were made on my wife\u2019s life and I was required to hire armed security to \nguard my home.  \n \nI said very clearly when interviewed that \u201cenough was enough\u201d and took a tone which \nwas geared to effectively calm the situation down. I also noted that certain minor and \nirresponsible members of the media were sowing hate and reaping what they sowed. This \nresulted in an outpouring of support from many for what Ms. Doe was being subjected to and \ncalmed things down. I believe that this was good use of the media by me to bring attention to \nwhat was going on and to try to stop it12. It certainly worked because the threats ended shortly \nthereafter.     \n \nI have been a member of this Court for over 30 years, and I know what limits there are on \nspeech related to trial publicity. I have repeatedly appeared in the media to state that this is not a \npolitical case and that the rancor was too much13. Most of what my interviews focused on are the \nthreats that Ms. Doe and I have received, responses to attacks regarding the Defense\u2019s leaked \ntext messages, abusive statements from minor podcasters, among other leaked evidence.  \n \nThe real motivation for movants attempts to effectively muzzle me is twofold.  Due to my \nvast experience in handling abuse cases, the extensive studies I have read and many \nconversations that I have had with experts in trauma, regarding the impact of trauma on \nsurvivors, I am able to rebut their efforts to undermine Ms. Doe\u2019s credibility by utilizing their \nown documents that they have leaked.  \n \nExcept for a few obscure or defense related media outlets, this has resulted in a positive \ndiscourse by people to learn more about the impact of trauma and the idea that responses to rape \nare not always as one would expect in the immediate aftermath. This has led to greater education \non this subject and experts in the field have weighed in to explain this. I believe that this has \n \n10 https://nypost.com/2026/10/10/us-news/sodomized-cornell-frat-bro-is-anti-us-son-of-dubai-islamic-studies-prof/ \n11 https://en.wikipedia.org/wiki/Swatting \n12 https://www.cnn.com/2026/10/07/us/cornell-lawsuit-student-protests-hnk \n13 https://www.youtube.com/watch?v=Fx-FAyChGQ0 \nFILED: NEW YORK COUNTY CLERK 10/14/2026 05:57 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 66\nRECEIVED NYSCEF: 10/14/2026\n5 of 12\n\n--- Page 6 ---\nbeen for the good. Movant does not care for this because it undermines the use of leaked \nmaterials to create a false narrative14.   \n \nThe second reason for this application is that they want to control the narrative and \ncontinue to leak confidential information to \u201cfriendly\u201d media outlets and push their version of the \nevents through surrogates. Clearly, this is what was done in the Combs case, and I believe this is \nwhat is happening here.  \n \nHowever, this is too important a case to permit the defendants to run rough shod with a \nsurrogate pushing their agenda while Ms. Doe must in effect \u201ctake it\u201d. That would be manifestly \nunfair and unjust. My media appearances have been focused on righting the ship in the face of \nintense attacks on Ms. Doe orchestrated by the defense and others, her credibility and the \ndangers that coming public have brought upon her and her family. I have done this without \nleaking any confidential documents.  \n \nPreventing me from speaking on her behalf effectively stifles Jane Doe and plays directly \nin the hands of the Defendants who do not want a level playing field in the public eye.  Aside \nfrom the unfairness of the relief sought, the application is in direct violation of the First \nAmendment. Certainly, courts are permitted to issue gag orders in appropriate circumstances, but \nas  described herein the instant application flouts all restrictions and there is no foundation for \nthe relief sought.  \nSummary of Legal Arguments \n \n \nThis order to show cause should not be signed as an inadequate showing has been \ndemonstrated for the extraordinary relief sought. As demonstrated in this letter, a prior restraint on \nspeech requires a finding that there is a clear and present danger to the administration of justice. \nEven then, if alternative remedies can be utilized to mitigate the prejudice and protect the right to \na fair trial, then the restraint is uncalled for.  \n \nFurthermore, even if a prior restraint on speech is appropriate, same must be as targeted as \npossible so only the bare minimum of speech is restricted. Similarly, any order must not be vague, \nas otherwise parties would need to overly restrict their speech to make sure they are complying. \nFinally, the ability to respond to bad press must be protected under all circumstances, otherwise \nthe court\u2019s protections would themselves be causing damage to those that abide. This letter \ndemonstrates that for all of the indicated reasons, there should be no restrictions imposed herein.  \n \nThe Clerk\u2019s Rejection & the Amended Filing \n \n \nThis proposed order to show cause was originally filed on October 9, 2026, but was rejected \nby the ex-parte clerk since the TRO request was non-existent. Originally, defendant merely asked \nthat the court place \u201cinterim restrictions\u201d, which was not a request for anything in specific. \nPaukman v. Uvaydov, 2024 NY Slip Op 51689(U) (Sup. Ct., Kings County 2024) (\u201cthe Court \n \n14 While I am loathe to waste this Court\u2019s time discussing Megyn Kelly and her statements that Ms. Doe was ugly \nand in effect \u201clooking to be raped\u201d. I believe my response to this trope was helpful to all survivors who are \nvictimized in such a mean-spirited way.  https://www.ms.now/opinion/megyn-kelly-cornell-jane-doe-hypocrite; \nhttps://www.thedailybeast.com/megyn-kelly-torched-by-alleged-cornell-rape-victims-lawyer-after-sick-attack. \nFILED: NEW YORK COUNTY CLERK 10/14/2026 05:57 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 66\nRECEIVED NYSCEF: 10/14/2026\n6 of 12\n\n--- Page 7 ---\nfinds that his order to show cause fails the most basic requirement of motion practice, that it specify \n\"the relief demanded and the grounds therefor\"\u201d). In their amended filing yesterday, defendant \nnow asks that the court issue a TRO granting all of the requests for relief made in the order to show \ncause. This was a material change. \n \nLegal Standard of Prior Restraints of Speech \n \nThe First Department in Ash v Board of Mgrs. of the 155 Condominium, 44 AD3d 324 \n(1st Dept. 2007) noted that: \n \nany imposition of prior restraint, whatever the form, bears a \"heavy \npresumption against its constitutional validity\" \u2026 and a party \nseeking to obtain such a restraint bears a correspondingly heavy \nburden of demonstrating justification for its imposition \u2026 It is also \nincumbent upon a trial court to insure that each of the parties \nreceives a fair trial and, to that end, possesses both the power and \nresponsibility to safeguard their rights \u2026 The trial court, in so doing, \nmust bear in mind the fact that prior restraints upon the rights of free \nspeech and publication \"may only be overcome upon a showing of \na 'clear and present danger' of a serious threat to the administration \nof justice\". \n \nThe case of Karantinidis v. Karantinidis, 186 A.D.3d 1502, 131 N.Y.S.3d 363 (2nd Dept. \n2020) includes an on-point rendition of the legal principles at issue:  \n \nThe defendant correctly contends that the portion of the order \ngranting that branch of the plaintiff's motion which was for an order \ndirecting the defendant not to discuss, demean, or disparage the \nplaintiff to any third parties, including but not limited to the \nplaintiff's patients, was an unconstitutional prior restraint on speech. \nA prior restraint on speech is a law, regulation  or judicial order that \nsuppresses speech on the basis of the speech's content and in \nadvance of its actual expression \u2026 Any imposition of prior restraint, \nwhatever the form, bears a \"heavy presumption against its \nconstitutional validity, and a party seeking to obtain such a restraint \nbears a correspondingly heavy burden of demonstrating justification \nfor its imposition\" \u2026 An injunctive order issued in the area of First \nAmendment rights must be couched in the narrowest terms that will \naccomplish the pin-pointed objective permitted by constitutional \nmandate and the essential needs of the public order \u2026 The order \nmust be tailored as precisely as possible to the exact needs of the \ncase. \n \n \n \n \nFILED: NEW YORK COUNTY CLERK 10/14/2026 05:57 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 66\nRECEIVED NYSCEF: 10/14/2026\n7 of 12\n\n--- Page 8 ---\nNo Showing of Any Clear and Present Danger \n \nThe speech that is curtailed must also be shown to represent \u201ca clear and present danger of \na serious substantive evil\u201d. Kassenoff v. Kassenoff, 213 A.D.3d 822, 183 N.Y.S.3d 533 (2nd Dept. \n2023) (\u201ca party must demonstrate that the speech sought to be restrained is \"'likely to produce a \nclear and present danger of a serious substantive evil that rises far above public inconvenience, \nannoyance, or unrest' \u2026 An order imposing a prior restraint on speech \"must be tailored as \nprecisely as possible to the exact needs of the case\"\u201d); United States v. Cutler, 58 F.3d 825 (2d \nCir. 1995) (\u201cspeech that fell within a proscribed category had to be reasonably likely to interfere \nwith a fair trial or otherwise prejudice the due administration of justice\u201d). Lowinger v. Lowinger, \n264 A.D.2d 763, 695 N.Y.S.2d 127 (2nd Dept. 1999) (\u201cOrders restraining extrajudicial comments \nby the parties or their attorneys are not generally permitted unless there is a reasonable likelihood \nof the existence of serious threat to the right to a fair trial\u201d).  \n \nI have spoken to the press. But my communications were limited to discussing what is \npublicly available through the complaint, and fair comment on what is already publicly available. \nThere is no showing that my statements are beyond what I would be able to say at trial. \nAccordingly, there is no possible showing that I have caused any unfair influence on potential \njurors. As such, there is no showing that any actual danger of misconduct is clearly expected, \nwhich was movant\u2019s burden to demonstrate.  \n \nNo Showing that Alternative Remedies Cannot Prevent Suspected Issues \n \n \nEven where prior restraints on free speech are otherwise indicated, they should still not be \nmade where alternative remedies can prevent the suspected abuse. For instance, in Cleveland v \nPerry, 175 AD3d 1017 (2nd Dept. 2019) it was found that even where \u201csuch statements present a \n'reasonable likelihood' of a serious threat to [defendants'] right to a fair trial\"\u201d, there still should \nnot have been any restrictions on what the attorneys could say where \u201cthere is no evidence in the \nrecord \"that less restrictive alternatives would not be just as effective in assuring the defendant[s] \na fair trial\"\u201d. The court in Cleveland found that \u201cInasmuch as alternative remedies such as a \n\"searching voir dire\" and \"emphatic jury instructions\" \u2026 would be sufficient to mitigate the \nprejudice to defendants and protect their right to a fair trial\u201d. Here, no such showing is made.  \n \nAlong these lines, Nat'l Broad. Co. v. Cooperman, 116 A.D.2d 287, 501 N.Y.S.2d 405 (2nd \nDept. 1986) describes in detail that even if statements were \u201creasonably likely to pose a serious \nthreat to the defendants' 6th Amendment right to a fair trial\u201d, a restraint on speech would still not \nbe permissible if \u201cthere is no indication in the record that less restrictive alternatives to the prior \nrestraint on counsel's extrajudicial statements would not have been just as effective in preserving \nthe police officers' right to a fair trial. Sequestration of the jury, postponement of the trial to allow \npublic attention to subside, a change of venue, a comprehensive and searching voir dire of potential \njurors and the use of emphatic instructions to the jurors regarding their sworn duty to decide the \ncase only on the evidence presented at trial, are all less restrictive alternatives to a prior restraint \nupon the free speech of the attorneys and other participants in the case\u201d. As such, the court summed \nup its holding that \u201ca trial court may not impose prior restraints upon attorneys and other \nparticipants in a trial without the requisite showing of a necessity for such restraint and a \nFILED: NEW YORK COUNTY CLERK 10/14/2026 05:57 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 66\nRECEIVED NYSCEF: 10/14/2026\n8 of 12\n\n--- Page 9 ---\ndetermination that less restrictive alternatives would not be just as effective in assuring the \ndefendant a fair trial\u201d. Id. \n \nInstead, in defendant\u2019s Memorandum of Law, defendant lodges an unsupported argument \nthat \u201cThose trial-stage measures do not fully address the present circumstances. This action is in \nits infancy, some parties have not appeared, and the publicity is ongoing. The harm includes not \nonly possible juror prejudice, but also the public dissemination of nonpublic personal information \nand the danger of threats, doxing, intimidation, and extrajudicial contact\u201d. This response to the \nalternative remedies argument primarily regards the doxing issue, which has primarily impacted \nMs. Doe, and the fact that currently the case is in the news. While defendant mentions that a trial \nis far away, this cuts the other way, diminishing the potential impact. Overall, there is no \nexplanation offered for why careful jury selection and specified instructions will not prevent the \nharm defendant seems to fear.  \n \nDefendant Merely Proposes a General Legal Standard as a Prohibition,  \nRendering the Requested Prohibitions Vague and Overly Broad \n \n \nThe proposed order to show cause should not be signed as the relief sought is so vague \nthat it would have a chilling effect on all related speech to make sure one does not transgress the \nambiguous order. \n \n \nDefendant asks that extrajudicial statements not be made to the media if they have \u201ca \nsubstantial likelihood of materially prejudicing the adjudicative process in this action\u201d. This is a \nmere regurgitation of a legal standard, and leaves it to the attorneys to guess as what may or may \nnot violate that standard. For instance, the court in People v. Buttafuoco, 158 Misc. 2d 174, 599 \nN.Y.S.2d 419 (Cnty. Ct. 1993) started with such a standard, but then went into detail to \ndemonstrate what precisely was included in such requirement. Without such delineations, the order \nwould bar more than necessary, which is legally inappropriate.  \n \nAdditionally, an order may be overbroad when it prevents parties from discussing the case \nwith witnesses or hinders investigation. Doe v. Eliyas, 241 A.D.3d 1271, 242 N.Y.S.3d 286 (2nd \nDept. 2025) (\u201cthe Supreme Court's temporary restraining order was overbroad, such that it \nprevented the defendants from discussing the instant action with third-party witnesses or disclosing \nthe plaintiffs' names for investigative purposes\u201d); See N.Y. Times Co. v. Rothwax, 143 A.D.2d \n592, 533 N.Y.S.2d 73 (1st Dept. 1988) (\u201cThe sua sponte gag order \u2026 suffers from the further \nconstitutional infirmity of being overbroad, for \"assuming that the respondent had properly \nconcluded that prior restraint upon the extrajudicial statements of attorneys was necessary, the \nprior restraint should have been limited solely to information or statements which might be likely \nto impugn the fairness and integrity of the trial\"\u201d). \n \n \nHere, the only specifics included in defendant\u2019s proposal are found two demands later, \nwhen proposing a prohibition of \u201cpublicly disclosing, republishing, or disseminating the \nfollowing information \u2026\u201d, after which five categories are mentioned; each is flawed. Before \ngetting to those specifics, the first glaring problem with this formulation is that there is no \nindication of whether even court filings themselves can mention this information, as court filings \nare public, this formulation seems to bar the parties in terms of what they can even say to the court. \nFILED: NEW YORK COUNTY CLERK 10/14/2026 05:57 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 66\nRECEIVED NYSCEF: 10/14/2026\n9 of 12\n\n--- Page 10 ---\na. Any residential address or other nonpublic personal identifying  \ninformation concerning any party, witness, alleged victim, or nonparty; \n \n \nThis request would appear to bar an attorney from mentioning the name of any nonparty, \neven in court filings. There is no indication given anywhere for why nonparties require some sort \nof protection. All we have seen from defendant\u2019s offer is that parties (or persons believed to be \nparties) have been subject to internet scorn, not nonparties. The demand is entirely overbroad, \nmaking no distinctions or qualifications whatsoever. However, I take no issue if addresses of the \nparties are redacted in Court filings.   \n \nb. Materials produced in discovery that have not  \nbeen filed in a publicly accessible court record; \n \n \nThis formulation does not make it clear whether the materials can be filed in the first place. \nIt just says that if they have been, then they can be disseminated. In any event, the request is overly \nbroad since it bars all materials that have not been filed. There is no reason given why all discovery \nmust be kept secret. Surely, it should depend on the content of the specific document. This demand \nmakes no distinction and is therefore facially overbroad. In any event, Defendants have been the \nones leaking documents, not the Plaintiff.  \n \nc. Statements concerning the expected testimony, character, credibility, reputation,  \nor personal history of any party or witness, where such statements create a  \nsubstantial likelihood of materially prejudicing the adjudication of this action; \n \n \nThis demand again regurgitates a legal standard of \u201csubstantial likelihood of materially \nprejudicing the adjudication\u201d, while failing to indicate what sort of statements would violate that \nstandard. The demand further gives no indication of what these \u201ccharacter etc.\u201d types of statements \nwould refer to. Everything is left utterly vague. \n \nd. The contents or purported contents of any nonpublic statement,  \ncommunication, examination, test, investigative material, or physical evidence  \nthat may be offered in this action, where disclosure creates a substantial  \nlikelihood of materially prejudicing the adjudication of this action; \n \n \nThis demand again fails to indicate whether such materials can be filed with the court, and \nwhether the act of filing now makes such documents public. This demand also regurgitates a legal \nstandard of \u201csubstantial likelihood of materially prejudicing the adjudication\u201d, while failing to \nindicate what sort of materials would violate that standard. \n \ne. Any statement inviting, encouraging, or facilitating threats,  \nharassment, intimidation, doxing, or extrajudicial contact directed  \ntoward any party, witness, counsel, juror, prospective juror, or nonparty; \n \n \nThis formulation prohibits \u201cfacilitating\u201d, but it in no way qualifies what that term includes. \nWhile \u201cinviting\u201d and \u201cencouraging\u201d are active terms that can be defined, \u201cfacilitating\u201d is a general \nFILED: NEW YORK COUNTY CLERK 10/14/2026 05:57 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 66\nRECEIVED NYSCEF: 10/14/2026\n10 of 12\n\n--- Page 11 ---\nterm with many facets, and can even include an unwanted and unintended consequence of proper \nconduct. This demand is therefore not only vague, but entirely overbroad. \n \n \nGiven the substantial problems with defendants\u2019 formulation of prohibitions in their \nproposed order to show cause, a TRO that grants what defendant wants is highly problematic. \nThere are too many loose ends in defendant\u2019s chosen formulation, the terms are overbroad, and \nthere is no showing why any of this (aside from potential doxing materials) is needed in order to \nprevent abuse. Therefore, the requested prior restraint on free speech is uncalled for, especially as \ninterim relief, given the plethora of problems with the formulations at issue that are readily \nnoticeable even without a full briefing in opposition. \n \n \nI am quite confused by this application as the person who has been subjected to death \nthreats, harassment, intimidation (to withdraw her case or her family would be killed), doxing, \ndeath threats and swatting has been Ms. Doe. Not any of the defendants. I believe that much this \nhas been caused by the leaks and ensuing credibility attacks done by the defendants and their \nsurrogates. It was reasonable and a positive dialogue was going on until the counter arguments \nwere offered up due to the leaks.    \n \n \nThe Imbalance A TRO Would Create \n \n \nA TRO here would heavily hinder plaintiff\u2019s counsel, even as defendants\u2019 surrogates would \nbe able to say whatever they wanted. As materials from the Title IX hearing have improperly \nslowly trickled out, it is apparent that parties have been resourceful in having others \u2018find\u2019 \ninformation and disseminate it.  \n \nTo put a bar on the attorneys in this case, however, will leave the parties unable to counter \nwhatever soundbites are taken out of context from proceedings that were already supposed to be \nconfidential from surrogates. This would leave the Defendants with the upper hand, while tying \nthe hands of those that have a moral responsibility to act properly \u2013 even without the issuance of \na specific court order. Jane Doe No. 1 v. Zeder, 5 Misc. 3d 574 (Sup. Ct., Onondaga County 2004) \n(\u201cIt is worth pointing out that defendant Keating has made liberal and aggressive use of the press \nin advancement of his position in this action. In this regard, the court is mindful that DR 7-107 (a) \npermits a lawyer to make a statement that a reasonable lawyer would believe is required to protect \na client from the substantial prejudicial effect of recent publicity not initiated by the lawyer or the \nlawyer's client\u201d). \n \nIn fact, New York Rules of Professional Conduct, \u00a73.6(d) specifically allows lawyers to \nrespond to adverse publicity: \u201cA lawyer may make a limited statement reasonably necessary to \nprotect a client from substantial prejudice caused by recent adverse publicity not initiated by the \nlawyer or client\u201d Id. Defendant\u2019s proposed order to show cause serves to undercut this provision, \nwhich would unfairly punish those that follow the rule of law, while emboldening those that are \nnot subject to the court\u2019s jurisdiction. The rules specifically allow such replies to prevent this unfair \nimbalance, and this right should not be taken away. This is what I have done with respect to the \nleaks. Perhaps too well since movant is now seeking to silence me. Obviously, they want their \narguments presented without an alternate being offered.  \nFILED: NEW YORK COUNTY CLERK 10/14/2026 05:57 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 66\nRECEIVED NYSCEF: 10/14/2026\n11 of 12\n\n--- Page 12 ---\nCertainly, these \u2018proxy representation\u2019 and \u2018surrogacy\u2019 issues are becoming more apparent \nby the day, which reflects how a full record and briefing are necessary here. Indeed, where both \nsides are making public disclosures, a restraint on free speech is even less appropriate. Barker v \nVictorious Life Christian Church, 72 Misc 3d 898 (Sup Ct, Albany County 2021) (\u201cAlthough the \ndefendants have asserted, in conclusory fashion, that potential news/social media coverage might \ntaint the jury pool, they have not made a factual showing that the possibility of such coverage \npresents a \"clear and present danger\" to the administration of justice. It is worth pointing out that \ndefendant Brignola \u2026 has made use of the press to advance his own view of this action \u2026 In other \nwords, the plaintiff is not alone in making the type of statements to the press about which the \ndefendants now complain\u201d).  \n \nPrematurity \n \n \nFinally, it must be pointed out that this application is premature. This case is still brand \nnew, not all defendants have appeared, only one has answered, and I believe no defendants are \neven in default yet. Other parties may have their own take on these issues and should not be \nrestricted before they have even had a chance to comment. Furthermore, other defendants may \nwant to make their own motion. It would be imprudent to have one motion active, with its own \nschedule, while other similar motions have yet to be made. This problem would be compounded \nif there are potentially multiple TRO\u2019s that would end up being in place. All of these issues are \nbrought to the fore by the early filing of this application, rendering same premature.  \n \nConclusion \n \n \nGiven the many issues discussed herein, the proposed order to show cause should not be \nsigned, and certainly no TRO should be granted without a full briefing on the complex legal and \nfactual issues that defendant\u2019s overbroad, vague, legally unsupported, and legally unnecessary \nformulations proposals evince.  \n \nRespectfully submitted, \n \nThomas P. Giuffra \n \ncc: All defendants via email: \n \njknox@hackermurphy.com; abhimani@hackermurphy.com; ebernstein@nylegaljustice.com; \ntdavis@nmllplaw.com; nino@lamalaw.com; ehallak@harrisbeachmurtha.com; \nasash@bushellsovak.com; echohen@rheingoldlaw.com; sbernstein@nmllplaw.com; \nmcuccaro@shertremonte.com; rfriedman@shertremonte.com; rsweeney@mgmlaw.com \nFILED: NEW YORK COUNTY CLERK 10/14/2026 05:57 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 66\nRECEIVED NYSCEF: 10/14/2026\n12 of 12","thumbnailUrl":"https://lucycraig.blog/media/418/thumb.webp","transcriptStatus":"not_applicable","transcriptText":"","url":"https://lucycraig.blog/media/418"}