# EXHIBIT(S) - 1 Notice of Charges against Doe Redacted per 22 NYCRR
						  §202.5(e)

Source: https://lucycraig.blog/media/489
File: NYSCEF-case-4c779433507a-000004.pdf
Format: application/pdf
Description: NYSCEF document #4 | Filed: 2026-03-30 | Filed by: SASH, ALAN EDWARD Filed:  Received: | Docket status: Processed Confirmation Notice | Case: Jane Doe v. Cornell Univeristy (Tompkins County) | Source: NYSCEF
Alt text: 

## OCR / extracted text

--- Page 1 ---
CornellUniversity
Office of Institutional Equity and Title IX
500 Day Hall
Ithaca, NY 14853
t. 607.255.2242
e. titleix@cornell.edu
www.titleix.cornell.edu
To:
Respondent
From: Lauren Branchini, Title IX Coordinator
Date:
January 16, 2025
Re.:
NOTICE TO PARTIES UPON THE ISSUANCE OF A FORMAL COMPLAINT
Personal – Private
Dear Complainant and Respondent,
This letter serves as “Notice to the Parties Upon the Issuance of a Formal Complaint.” Attached 
to this cover letter, you will find a copy of the signed Formal Complaint (94428) and the Policy 
6.4 Informational Letter with detailed information about your rights and options under both that 
Policy and the Procedures for Resolution of Reports Against Students Under Policy 6.4.1
The Investigator assigned to this matter is Samantha Freeburn. 
Jurisdiction
The University is exercising jurisdiction over this Formal Complaint pursuant to the Procedures 
for Resolution of Reports Against Students Under Cornell University Policy 6.4 because: (1) the 
Respondent is a student; and (2) the conduct is alleged to have occurred on any campus of the 
University, on any other property or facility used by it for educational purposes, or on property
owned or controlled by a University-related residential organization, student organization, 
sorority, or fraternity that is officially recognized by or registered with the University; and/or (3) 
I have determined that the alleged prohibited conduct has occurred in the context of a University 
program or activity; and/or (4) the alleged prohibited conduct poses a substantial threat to the
University’s educational mission, such as an allegation of serious misconduct by a Cornell 
student against a non-Cornell community member, or to the health or safety of University 
community members, including potentially contributing to or creating a hostile environment on 
any campus of the University.
Preliminary Determination of Hearing Process A or Hearing Process B and Whether Title 
IX Applies to the Formal Complaint
1 This Formal Complaint is being investigated and adjudicated under the August 5, 2024 Procedures for Resolution 
of Reports Against Students Under Policy 6.4. All Formal Complaints signed on or after August 5, 2024, will be 
investigated and adjudicated under those Procedures, regardless of the date of the incident. However, in evaluating 
the Formal Complaint, the adjudicator will use the definition of Prohibited Conduct in effect at the time of the 
reported incident.
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1
Formal Complaint 
(94428) 
Distributed 01/16/2025
1 of 6
Private 
Distribution Not Permitted, See Policy 6.4
CI2026-07228
Index # : EF2026-0292
FILED: TOMPKINS COUNTY CLERK 03/30/2026 01:47 PM
INDEX NO. EF2026-0292
NYSCEF DOC. NO. 4
RECEIVED NYSCEF: 03/30/2026

--- Page 2 ---
If the Formal Complaint is to be resolved through Hearing, such Hearing will be conducted in 
accordance with Hearing Process A.
Pursuant to Section 20 of the August 5, 2024, Procedures for Resolution of Reports Against 
Students Under Cornell University Policy 6.4, I have determined that Title IX applies to the 
Formal Complaint because (1) the alleged prohibited conduct meets at least one of the definitions 
for sexual harassment and sex/gender-based harassment, sexual assault, dating and domestic 
violence, or stalking, (2) the alleged prohibited conduct occurred in the University’s education 
program or activity, (3) the alleged prohibited conduct occurred against a complainant in the 
United States; and (4) at the time of filing the Formal Complaint, the complainant is participating 
in or attempting to participate in the University’s program or activity.
Thank you,
Lauren Branchini
Title IX Coordinator
Privacy. Please note that, pursuant to Cornell Policy 6.4, and the applicable Procedures:  The University 
encourages parties not to reveal any information they learn in the course of their participation in processes set forth 
in the applicable procedures, other than for the purpose of consulting with advisors and attorneys, and incidental to 
seeking support and advice from family, clergy, health professionals, and others playing a similar role.  Parties may 
choose whether to disclose or discuss with others the outcome of a complaint under this policy.  Students are 
prohibited from distributing documents obtained in the course of their participation in processes set forth in the
applicable procedures other than for the purpose of consulting with an advisor; incidental to seeking support and 
advice from family, clergy, health professionals, and others playing a similar role; or as part of a civil, criminal, or 
administrative legal proceeding.  By accepting the role of advisor, all advisors agree to comply with the rules and 
processes set forth in Policy 6.4 and these procedures, including rules regarding privacy.  As appropriate, in a 
given case, a university official, such as the Title IX Coordinator, may issue an order restricting the parties from 
disclosing specific information.  Members of the Cornell community who fail to follow an order of a university 
official may be found to have violated Cornell University’s Campus Code of Conduct. Additionally, sharing private 
information in a manner that harms another individual may constitute retaliation prohibited under this policy.
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Formal Complaint 
(94428) 
Distributed 01/16/2025
2 of 6
Private 
Distribution Not Permitted, See Policy 6.4
CI2026-07228
Index #: EF2026-0292
FILED: TOMPKINS COUNTY CLERK 03/30/2026 01:47 PM
INDEX NO. EF2026-0292
NYSCEF DOC. NO. 4
RECEIVED NYSCEF: 03/30/2026

--- Page 3 ---
Cornell
University
ntle
IX
Ithaca, NY I4853
t. 607.255.2242
e. titleix(corncil.edu
www.titleix.cornell.edu
FORMALCOMPLAINTOFA POLICY 6.4 VIOLATION
This Formal Complaint provides
notice
of allegation(s)
of Prohibited
Conduct in violation
of
Cornell
University
Policy
6.4 (Prohibited
Bias,
Discrimination,
Harassment,
and Sexual and
Related Misconduct).
The purpose of this
Formal Complaint
is to advise the parties
of the dates,
times, and locations
of alleged prohibited
conduct,
to the extent known at the time this Formal Complaint
is signed
Pursuant
to Policy
6.4,
and the corresponding
Procedures,
retaliation
against
individuals
for
engaging in pmtected activities
is prohibited.
Protected
activities
include
making good-faith
reports
of Prohibited
Conduct or participating
in any investigation
or proceeding
under the
Policy
6.4 Pmcedures.
This Formal Complaint
is alleging
Sexual Assault and Sexual Exploitation
by multiple
undergraduate
students
at Cornell,
against
another
student.
This Formal Complaint
will
be
investigated
pursuant
to the August 5, 2024,
Procedures for
Resolution
of Reports Against
Students
Under Cornell
University
Policy
6.4.
The University
mayhold the Respondents accounta+e for
violations
of Policy
6.4 and other
policies
that are not referenced
in the Formal Complaint
but are learned about from evidence,
testimony,
or admissions
during
the investigation
and adjudication
process.
(the "Complainant")
is an undergraduate
student
at Cornell
University.
2. The Complainant
is signing
this
statement
because she believes
the following
individuals
violated
Cornell
University
Policy
6.4's
prohibition
against
Sexual Assault
and Sexual
Exploitation
on or about the night
of October
19, 2024, and/or the early
morning of October
20,
2024,
at the Chi Phi
Fraternity
House (107 Edgemoor Lane, Ithaca, NY14850).
3. Alleged
Misconduct:
Formal Complaint 
(94428) 
Distributed 01/16/2025
3 of 6
Private 
Distribution Not Permitted, See Policy 6.4
CI2026-07228
Index #: EF2026-0292
FILED: TOMPKINS COUNTY CLERK 03/30/2026 01:47 PM
INDEX NO. EF2026-0292
NYSCEF DOC. NO. 4
RECEIVED NYSCEF: 03/30/2026

--- Page 4 ---
Formal Complaint 
(94428) 
Distributed 01/16/2025
4 of 6
Private 
Distribution Not Permitted, See Policy 6.4
CI2026-07228
Index #: EF2026-0292
FILED: TOMPKINS COUNTY CLERK 03/30/2026 01:47 PM
INDEX NO. EF2026-0292
NYSCEF DOC. NO. 4
RECEIVED NYSCEF: 03/30/2026

--- Page 5 ---
g)
is accused of
v iolating
Cornell
University's
Policy
.
pro n
ition
agamst
exua
xp oitati
sault.
Specifically,
it
is alleged
that
at the above date,
time,
and location,
i. Intentionally
viewed the Complainant
in a state
of undress without
her permission;
and
ii. Touched his nose to the Complainant's
naked body and inhaled
powdered
substance
off her body without
affirmative
consent,
including
lack of affirmative
consent
due to incapacitation.
Complainant
Signature(s)
By signing
below,
I agree
the above information
is accurate,
to the best of my knowledge:
Complainant
Nam
Signature
Date:
ot-
144- 35
By signing
below,
I am indicating
I wish
to proceed
with
a formal
investigation
under Cornell
University
Policy
6.4:
Complainant
Name:
Signature:
Date:
g..m.
ast
By signing
below,
I am indicating
I am open resolving
this
matter
through
Alternate
Resolution:
Complainant
Name:
Signature
Date:
ot-
t s4- 25
Please
indicate:
Restorative
"Informal"
Resolution
Formal Complaint 
(94428) 
Distributed 01/16/2025
5 of 6
Private 
Distribution Not Permitted, See Policy 6.4
CI2026-07228
Index #: EF2026-0292
FILED: TOMPKINS COUNTY CLERK 03/30/2026 01:47 PM
INDEX NO. EF2026-0292
NYSCEF DOC. NO. 4
RECEIVED NYSCEF: 03/30/2026

--- Page 6 ---
Negotiated
"Formal"
Resolution
Unsure/Undecided
Formal Complaint
on behalf
of the University:
Pursuant to the Procedures
for the Resolution
of Reports Against
Students
Under Policy
6.4:
"Where the Title
IX Coordinator
determines
that
the University
cannot honor a complainant's
request
that no Formal Complaint
be pursued under
these procedures,
the Title
IX Coordinator
will
promptly
initiate
the resolution
process under
these procedures by making a signed,
written
Formal Complaint
on behalf of the University."
Title
IX Coordinator:
Signature:
Date:
2
Formal Complaint 
(94428) 
Distributed 01/16/2025
6 of 6
Private 
Distribution Not Permitted, See Policy 6.4
CI2026-07228
Index #: EF2026-0292
FILED: TOMPKINS COUNTY CLERK 03/30/2026 01:47 PM
INDEX NO. EF2026-0292
NYSCEF DOC. NO. 4
RECEIVED NYSCEF: 03/30/2026

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