{"@context":"https://schema.org","@type":"DigitalDocument","altText":"STIPULATION - CONFIDENTIALITY ( REQUEST TO SO ORDER )","alternateName":"NYSCEF-case-4c779433507a-000014.pdf","caption":"NYSCEF document #14 | Filed: 2026-06-02 | Filed by: PENCE, ADAM G Filed:  Received: | Docket status: Processed Confirmation Notice | Case: Jane Doe v. Cornell Univeristy (Tompkins County) | Source: NYSCEF","contentUrl":"https://lucycraig.blog/media/496/raw","datePublished":"2026-10-19T12:20:21+00:00","description":"NYSCEF document #14 | Filed: 2026-06-02 | Filed by: PENCE, ADAM G Filed:  Received: | Docket status: Processed Confirmation Notice | Case: Jane Doe v. Cornell Univeristy (Tompkins County) | Source: NYSCEF","encodingFormat":"application/pdf","identifier":"496","isAccessibleForFree":true,"machineReadable":{"json":"https://lucycraig.blog/media/496/index.json","markdown":"https://lucycraig.blog/media/496/index.md"},"name":"STIPULATION - CONFIDENTIALITY ( REQUEST TO SO ORDER )","ocrStatus":"ready","ocrText":"--- Page 1 ---\n1 \n \nSTATE OF NEW YORK \nSUPREME COURT: TOMPKINS COUNTY \n_________________________________________ \nIn the Matter of the Application of \n \n \n \n \n \n             \nJOHN DOE, \n \n \n \n \n \n \n \n \n             \n \n \n \n \nPetitioner, \n             \n \nFOR A JUDGMENT PURSUANT TO ARTICLE 78 \nAND SECTION 3001 OF THE CPLR \n \nIndex No. EF2026-0292 \n \n \n-AGAINST- \n \nCORNELL UNIVERSITY, \n \n \n \n \n \nRespondent. \n_________________________________________ \n \nSTIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER \n \n \nPetitioner John Doe and Respondent Cornell University (collectively, the \u201cParties\u201d), \nthrough their counsel, hereby stipulate and agree that good cause exists to protect and treat as \nconfidential the record to be produced by Cornell in this proceeding because the record contains \nnon-public information of a sensitive, personal or private nature (including but not limited to \ninformation protected by state or federal statute limiting such disclosure); information revealing \nthe identity of certain current and/or former students; and confidential, non-public student \nconduct investigations and proceedings. \n \nThe Parties further stipulate and agree that, with the Court\u2019s permission, the entire record to \nbe produced by Cornell in this proceeding may be filed unredacted but under seal because of the \nsensitive nature of the underlying materials and the voluminous record that makes redaction of \nthe entire record impracticable. \n \nThe Parties further stipulate and agree that all information and documents produced by \nCornell as part of the record shall be deemed \u201cConfidential,\u201d and the information contained \nCI2026-12453\nIndex # : EF2026-0292\n\n--- Page 2 ---\n2 \n \ntherein shall be used solely for the purpose of this litigation and shall not be disclosed in any \nmanner to any individual, except to those individuals directly participating in this litigation or \nassisting either Party in this litigation, all of whom shall be informed of this Confidentiality \nAgreement and Protective Order and shall agree to be bound by it prior to disclosure. \n \nThe Parties further stipulate and agree that, to the extent any portions of the record are \nreferenced in or attached to papers in this litigation, the names and other identifying information \nof any students and/or witnesses involved in the conduct investigation and proceedings shall be \nredacted.  It will be the responsibility of the Party referencing or attaching portions of the record \nto their papers to identify and redact such information. \n \nNOW, THEREFORE, IT IS ORDERED, that this stipulated Confidentiality Agreement and \nProtective Order is  \u201cso ordered,\u201d and Cornell may file under seal the entire record (unredacted) \nthat is the subject matter of this proceeding.\n \n/s/ Adam G. Pence \n \n \n \n/s/ Alan E. Sash \nAdam G. Pence, Esq.  \n \n \nAlan E. Sash, Esq.   \n \n \nCornell University \n \n \n \nBushell, Sovak, Kane & Sash LLP \nOffice of General Counsel  \n \n \n274 Madison Avenue \n118 Sage Place \n \n \n \nSuite 1401 \nIthaca, NY 14850 \n \n \n \nNew York, NY 10016 \n(607) 255-5124 \n \n \n \n(212) 949-4700 \napence@cornell.edu  \n \n \nasash@bushellsovak.com \n \nSO ORDERED \n \n \n______________________________ \nHonorable Mark G. Masler \nCI2026-12453\nIndex #: EF2026-0292","text":"--- Page 1 ---\n1 \n \nSTATE OF NEW YORK \nSUPREME COURT: TOMPKINS COUNTY \n_________________________________________ \nIn the Matter of the Application of \n \n \n \n \n \n             \nJOHN DOE, \n \n \n \n \n \n \n \n \n             \n \n \n \n \nPetitioner, \n             \n \nFOR A JUDGMENT PURSUANT TO ARTICLE 78 \nAND SECTION 3001 OF THE CPLR \n \nIndex No. EF2026-0292 \n \n \n-AGAINST- \n \nCORNELL UNIVERSITY, \n \n \n \n \n \nRespondent. \n_________________________________________ \n \nSTIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER \n \n \nPetitioner John Doe and Respondent Cornell University (collectively, the \u201cParties\u201d), \nthrough their counsel, hereby stipulate and agree that good cause exists to protect and treat as \nconfidential the record to be produced by Cornell in this proceeding because the record contains \nnon-public information of a sensitive, personal or private nature (including but not limited to \ninformation protected by state or federal statute limiting such disclosure); information revealing \nthe identity of certain current and/or former students; and confidential, non-public student \nconduct investigations and proceedings. \n \nThe Parties further stipulate and agree that, with the Court\u2019s permission, the entire record to \nbe produced by Cornell in this proceeding may be filed unredacted but under seal because of the \nsensitive nature of the underlying materials and the voluminous record that makes redaction of \nthe entire record impracticable. \n \nThe Parties further stipulate and agree that all information and documents produced by \nCornell as part of the record shall be deemed \u201cConfidential,\u201d and the information contained \nCI2026-12453\nIndex # : EF2026-0292\n\n--- Page 2 ---\n2 \n \ntherein shall be used solely for the purpose of this litigation and shall not be disclosed in any \nmanner to any individual, except to those individuals directly participating in this litigation or \nassisting either Party in this litigation, all of whom shall be informed of this Confidentiality \nAgreement and Protective Order and shall agree to be bound by it prior to disclosure. \n \nThe Parties further stipulate and agree that, to the extent any portions of the record are \nreferenced in or attached to papers in this litigation, the names and other identifying information \nof any students and/or witnesses involved in the conduct investigation and proceedings shall be \nredacted.  It will be the responsibility of the Party referencing or attaching portions of the record \nto their papers to identify and redact such information. \n \nNOW, THEREFORE, IT IS ORDERED, that this stipulated Confidentiality Agreement and \nProtective Order is  \u201cso ordered,\u201d and Cornell may file under seal the entire record (unredacted) \nthat is the subject matter of this proceeding.\n \n/s/ Adam G. Pence \n \n \n \n/s/ Alan E. Sash \nAdam G. Pence, Esq.  \n \n \nAlan E. Sash, Esq.   \n \n \nCornell University \n \n \n \nBushell, Sovak, Kane & Sash LLP \nOffice of General Counsel  \n \n \n274 Madison Avenue \n118 Sage Place \n \n \n \nSuite 1401 \nIthaca, NY 14850 \n \n \n \nNew York, NY 10016 \n(607) 255-5124 \n \n \n \n(212) 949-4700 \napence@cornell.edu  \n \n \nasash@bushellsovak.com \n \nSO ORDERED \n \n \n______________________________ \nHonorable Mark G. Masler \nCI2026-12453\nIndex #: EF2026-0292","thumbnailUrl":"https://lucycraig.blog/media/496/thumb.webp","transcriptStatus":"not_applicable","transcriptText":"","url":"https://lucycraig.blog/media/496"}