AFFIDAVIT OR AFFIRMATION IN SUPPORT

--- Page 1 --- 1 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK JANE DOE, Index No. 161704/2026 Motion Seq. 003 MOTION FOR ADMISSION PRO HAC VICE OF W. WHITNEY SEALS, ESQUIRE PURSUANT TO 22 NYCRR 520.11 Plaintiff, -against- CORNELL UNIVERSITY, INC., et al. Defendants. Plaintiff JANE DOE, by her counsel, the attorneys at Rheingold Giuffra Ruffo Plotkin & Hellman, LLP, files this herein Motion, pursuant to 22 NYCRR 520.11, seeking the admission pro hac vice of W. Whitney Seals, Esquire. Plaintiff JANE DOE has included a Proposed Order attached hereto as Exhibit A for the Court’s convenience. In support of this Motion, Plaintiff JANE DOE states as follows: 1. This motion is made by Plaintiff JANE DOE, by and through counsel Thomas P. Giuffra, Esq., a partner of the law firm of Rheingold Giuffra Ruffo Plotkin & Hellman, LLP, a member in good standing of the bar of the State of New York. 2. The Affidavit of Thomas P. Giuffra, Esq., in support of Attorney Seals’s admission is attached hereto as Exhibit B. 3. The Affidavit of W. Whitney Seals, Esq., in support of this motion is attached hereto as Exhibit C. 4. Certificate of Good Standing issued by the Supreme Court of Alabama in support of this Motion is attached hereto as Exhibit D. 5. Plaintiff JANE DOE respectfully asserts that there is good cause for the admission of W. Whitney Seals, Esq., pro hac vice, given that Attorney Seals has significant experience FILED: NEW YORK COUNTY CLERK 10/19/2026 07:37 PM INDEX NO. 161704/2026 NYSCEF DOC. NO. 75 RECEIVED NYSCEF: 10/19/2026 1 of 3 --- Page 2 --- 2 handling civil litigation matters in the State of Alabama. 6. Applicant Attorney Seals is not admitted to the bar of the State of New York but is admitted to the bar of and authorized to practice law in the State of Alabama. He has been admitted to practice law in the State of Alabama since 2004. There are no disciplinary proceedings pending against Applicant Attorney Seals in the State of Alabama or in any other jurisdiction, nor have there been any such proceedings brought against him in any jurisdiction. 7. Applicant Attorney Seals is familiar with and agrees to be bound by the standards of professional conduct imposed upon members of the New York Bar. He also acknowledges and agrees that he shall be subject to the jurisdiction of the courts of the State of New York with respect to any acts occurring over the course of his participation in this case. 8. Plaintiff JANE DOE respectfully requests this motion be granted so that Attorney Seals may attend and fully participate in all matters on her behalf and otherwise engage in pre- trial, trial, and post-trial proceedings in connection with this action. WHEREFORE, Plaintiff JANE DOE, by and through her counsel and sponsor of Attorney Seals, Thomas P. Giuffra, Esq., respectfully requests that this application for admission pro hac vice of W. Whitney Seals, Esq., be granted and that the Court enter an order substantially similar to the proposed order attached hereto as Exhibit A. Dated: New York, NY October 19, 2026 FILED: NEW YORK COUNTY CLERK 10/19/2026 07:37 PM INDEX NO. 161704/2026 NYSCEF DOC. NO. 75 RECEIVED NYSCEF: 10/19/2026 2 of 3 --- Page 3 --- . 3 RHEINGOLD GIUFFRA RUFFO PLOTKIN & HELLMAN LLP Attorneys for Plaintiff _____________________ By: Thomas P. Giuffra, Esq. 551 Fifth Avenue, 29th Fl. New York, NY 10176 Tel: (212) 684-1880 [email protected] -AND- COCHRUN & SEALS, LLC Attorneys for Plaintiff (Pro Hac Vice pending) /s/ W. Whitney Seals _____________________ By: W. Whitney Seals, Esq. P.O. Box 10448 Birmingham, AL 35202-0448 Tel: (202) 323-3900 [email protected] FILED: NEW YORK COUNTY CLERK 10/19/2026 07:37 PM INDEX NO. 161704/2026 NYSCEF DOC. NO. 75 RECEIVED NYSCEF: 10/19/2026 3 of 3