STIPULATION - CONFIDENTIALITY ( REQUEST TO SO ORDER )

--- Page 1 --- 1 STATE OF NEW YORK SUPREME COURT: TOMPKINS COUNTY _________________________________________ In the Matter of the Application of JOHN DOE, Petitioner, FOR A JUDGMENT PURSUANT TO ARTICLE 78 AND SECTION 3001 OF THE CPLR Index No. EF2026-0292 -AGAINST- CORNELL UNIVERSITY, Respondent. _________________________________________ STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER Petitioner John Doe and Respondent Cornell University (collectively, the “Parties”), through their counsel, hereby stipulate and agree that good cause exists to protect and treat as confidential the record to be produced by Cornell in this proceeding because the record contains non-public information of a sensitive, personal or private nature (including but not limited to information protected by state or federal statute limiting such disclosure); information revealing the identity of certain current and/or former students; and confidential, non-public student conduct investigations and proceedings. The Parties further stipulate and agree that, with the Court’s permission, the entire record to be produced by Cornell in this proceeding may be filed unredacted but under seal because of the sensitive nature of the underlying materials and the voluminous record that makes redaction of the entire record impracticable. The Parties further stipulate and agree that all information and documents produced by Cornell as part of the record shall be deemed “Confidential,” and the information contained CI2026-12453 Index # : EF2026-0292 --- Page 2 --- 2 therein shall be used solely for the purpose of this litigation and shall not be disclosed in any manner to any individual, except to those individuals directly participating in this litigation or assisting either Party in this litigation, all of whom shall be informed of this Confidentiality Agreement and Protective Order and shall agree to be bound by it prior to disclosure. The Parties further stipulate and agree that, to the extent any portions of the record are referenced in or attached to papers in this litigation, the names and other identifying information of any students and/or witnesses involved in the conduct investigation and proceedings shall be redacted. It will be the responsibility of the Party referencing or attaching portions of the record to their papers to identify and redact such information. NOW, THEREFORE, IT IS ORDERED, that this stipulated Confidentiality Agreement and Protective Order is “so ordered,” and Cornell may file under seal the entire record (unredacted) that is the subject matter of this proceeding. /s/ Adam G. Pence /s/ Alan E. Sash Adam G. Pence, Esq. Alan E. Sash, Esq. Cornell University Bushell, Sovak, Kane & Sash LLP Office of General Counsel 274 Madison Avenue 118 Sage Place Suite 1401 Ithaca, NY 14850 New York, NY 10016 (607) 255-5124 (212) 949-4700 [email protected] [email protected] SO ORDERED ______________________________ Honorable Mark G. Masler CI2026-12453 Index #: EF2026-0292