# STIPULATION - CONFIDENTIALITY ( REQUEST TO SO ORDER )

Source: https://lucycraig.blog/media/496
File: NYSCEF-case-4c779433507a-000014.pdf
Format: application/pdf
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
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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

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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 
apence@cornell.edu  
 
 
asash@bushellsovak.com 
 
SO ORDERED 
 
 
______________________________ 
Honorable Mark G. Masler 
CI2026-12453
Index #: EF2026-0292

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