{"@context":"https://schema.org","@type":"DigitalDocument","altText":"AFFIDAVIT OR AFFIRMATION IN SUPPORT","alternateName":"NYSCEF-Document-000075.pdf","caption":"NYSCEF document #75 | Filed: 2026-10-19 | Filed by: COHEN, ETHAN J Filed:  Received: | Docket status: Processed Confirmation Notice | Source: NYSCEF, New York County Supreme Court","contentUrl":"https://lucycraig.blog/media/537/raw","datePublished":"2026-10-20T12:33:08+00:00","description":"NYSCEF document #75 | Filed: 2026-10-19 | Filed by: COHEN, ETHAN J Filed:  Received: | Docket status: Processed Confirmation Notice | Source: NYSCEF, New York County Supreme Court","encodingFormat":"application/pdf","identifier":"537","isAccessibleForFree":true,"machineReadable":{"json":"https://lucycraig.blog/media/537/index.json","markdown":"https://lucycraig.blog/media/537/index.md"},"name":"AFFIDAVIT OR AFFIRMATION IN SUPPORT","ocrStatus":"ready","ocrText":"--- Page 1 ---\n1 \nSUPREME COURT OF THE STATE OF NEW YORK \nCOUNTY OF NEW YORK \n \nJANE DOE,  \nIndex No. 161704/2026 \nMotion Seq. 003 \n \n \nMOTION FOR ADMISSION \nPRO HAC VICE OF W. \nWHITNEY SEALS, \nESQUIRE PURSUANT TO \n22 NYCRR 520.11 \n \n \nPlaintiff, \n-against-  \n \nCORNELL UNIVERSITY, INC., et al. \n \nDefendants. \n \n \nPlaintiff JANE DOE, by her counsel, the attorneys at Rheingold Giuffra Ruffo Plotkin & \nHellman, LLP, files this herein Motion, pursuant to 22 NYCRR 520.11, seeking the admission pro \nhac vice of W. Whitney Seals, Esquire. Plaintiff JANE DOE has included a Proposed Order \nattached hereto as Exhibit A for the Court\u2019s convenience.  \n \nIn support of this Motion, Plaintiff JANE DOE states as follows:  \n \n1. \nThis motion is made by Plaintiff JANE DOE, by and through counsel Thomas P. \nGiuffra, Esq., a partner of the law firm of Rheingold Giuffra Ruffo Plotkin & Hellman, LLP, a \nmember in good standing of the bar of the State of New York.  \n2. \nThe Affidavit of Thomas P. Giuffra, Esq., in support of Attorney Seals\u2019s admission \nis attached hereto as Exhibit B.  \n3. \nThe Affidavit of W. Whitney Seals, Esq., in support of this motion is attached \nhereto as Exhibit C.  \n4. \nCertificate of Good Standing issued by the Supreme Court of Alabama in support \nof this Motion is attached hereto as Exhibit D.  \n5. \nPlaintiff JANE DOE respectfully asserts that there is good cause for the admission \nof W. Whitney Seals, Esq., pro hac vice, given that Attorney Seals has significant experience \nFILED: NEW YORK COUNTY CLERK 10/19/2026 07:37 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 75\nRECEIVED NYSCEF: 10/19/2026\n1 of 3\n\n--- Page 2 ---\n2 \nhandling civil litigation matters in the State of Alabama. \n6. \nApplicant Attorney Seals is not admitted to the bar of the State of New York but is \nadmitted to the bar of and authorized to practice law in the State of Alabama. He has been admitted \nto practice law in the State of Alabama since 2004. There are no disciplinary proceedings pending \nagainst Applicant Attorney Seals in the State of Alabama or in any other jurisdiction, nor have \nthere been any such proceedings brought against him in any jurisdiction. \n7. \nApplicant Attorney Seals is familiar with and agrees to be bound by the standards \nof professional conduct imposed upon members of the New York Bar. He also acknowledges and \nagrees that he shall be subject to the jurisdiction of the courts of the State of New York with respect \nto any acts occurring over the course of his participation in this case.  \n8. \nPlaintiff JANE DOE respectfully requests this motion be granted so that Attorney \nSeals may attend and fully participate in all matters on her behalf and otherwise engage in pre-\ntrial, trial, and post-trial proceedings in connection with this action. \n \nWHEREFORE, Plaintiff JANE DOE, by and through her counsel and sponsor of Attorney \nSeals, Thomas P. Giuffra, Esq., respectfully requests that this application for admission pro hac \nvice of W. Whitney Seals, Esq., be granted and that the Court enter an order substantially similar \nto the proposed order attached hereto as Exhibit A. \nDated: New York, NY \n \nOctober 19, 2026 \n \n \n \n \n \n \n \n \n \n \nFILED: NEW YORK COUNTY CLERK 10/19/2026 07:37 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 75\nRECEIVED NYSCEF: 10/19/2026\n2 of 3\n\n--- Page 3 ---\n.\n3 \n \n \n \n \n \n \nRHEINGOLD GIUFFRA RUFFO  \n \n \n \n \n \n \nPLOTKIN & HELLMAN LLP \n \n \n \n \n \n \nAttorneys for Plaintiff  \n \n \n \n \n \n \n \n  \n \n      _____________________                                                         \n \n \n \n \n \n \nBy: Thomas P. Giuffra, Esq. \n \n \n \n \n \n \n551 Fifth Avenue, 29th Fl. \nNew York, NY 10176 \n \n \n \n \n \n \nTel: (212) 684-1880 \n \n \n \n \n \n \ntgiuffra@rheingoldlaw.com \n \n \n \n \n \n \n \n \n-AND- \n \n \n \n \n \n \n \n \nCOCHRUN & SEALS, LLC \n \n \n \n \n \n \nAttorneys for Plaintiff \n \n \n \n \n \n \n(Pro Hac Vice pending) \n \n \n \n \n \n \n \n/s/ W. Whitney Seals \n   _____________________                                                         \n \n \n \n \n \n \nBy: W. Whitney Seals, Esq. \n \n \n \n \n \n \nP.O. Box 10448 \n \n \n \n \n \n \nBirmingham, AL 35202-0448 \n \n \n \n \n \n \nTel: (202) 323-3900 \n \n \n \n \n \n \nwhitney@cochrunseals.com \n \nFILED: NEW YORK COUNTY CLERK 10/19/2026 07:37 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 75\nRECEIVED NYSCEF: 10/19/2026\n3 of 3","text":"--- Page 1 ---\n1 \nSUPREME COURT OF THE STATE OF NEW YORK \nCOUNTY OF NEW YORK \n \nJANE DOE,  \nIndex No. 161704/2026 \nMotion Seq. 003 \n \n \nMOTION FOR ADMISSION \nPRO HAC VICE OF W. \nWHITNEY SEALS, \nESQUIRE PURSUANT TO \n22 NYCRR 520.11 \n \n \nPlaintiff, \n-against-  \n \nCORNELL UNIVERSITY, INC., et al. \n \nDefendants. \n \n \nPlaintiff JANE DOE, by her counsel, the attorneys at Rheingold Giuffra Ruffo Plotkin & \nHellman, LLP, files this herein Motion, pursuant to 22 NYCRR 520.11, seeking the admission pro \nhac vice of W. Whitney Seals, Esquire. Plaintiff JANE DOE has included a Proposed Order \nattached hereto as Exhibit A for the Court\u2019s convenience.  \n \nIn support of this Motion, Plaintiff JANE DOE states as follows:  \n \n1. \nThis motion is made by Plaintiff JANE DOE, by and through counsel Thomas P. \nGiuffra, Esq., a partner of the law firm of Rheingold Giuffra Ruffo Plotkin & Hellman, LLP, a \nmember in good standing of the bar of the State of New York.  \n2. \nThe Affidavit of Thomas P. Giuffra, Esq., in support of Attorney Seals\u2019s admission \nis attached hereto as Exhibit B.  \n3. \nThe Affidavit of W. Whitney Seals, Esq., in support of this motion is attached \nhereto as Exhibit C.  \n4. \nCertificate of Good Standing issued by the Supreme Court of Alabama in support \nof this Motion is attached hereto as Exhibit D.  \n5. \nPlaintiff JANE DOE respectfully asserts that there is good cause for the admission \nof W. Whitney Seals, Esq., pro hac vice, given that Attorney Seals has significant experience \nFILED: NEW YORK COUNTY CLERK 10/19/2026 07:37 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 75\nRECEIVED NYSCEF: 10/19/2026\n1 of 3\n\n--- Page 2 ---\n2 \nhandling civil litigation matters in the State of Alabama. \n6. \nApplicant Attorney Seals is not admitted to the bar of the State of New York but is \nadmitted to the bar of and authorized to practice law in the State of Alabama. He has been admitted \nto practice law in the State of Alabama since 2004. There are no disciplinary proceedings pending \nagainst Applicant Attorney Seals in the State of Alabama or in any other jurisdiction, nor have \nthere been any such proceedings brought against him in any jurisdiction. \n7. \nApplicant Attorney Seals is familiar with and agrees to be bound by the standards \nof professional conduct imposed upon members of the New York Bar. He also acknowledges and \nagrees that he shall be subject to the jurisdiction of the courts of the State of New York with respect \nto any acts occurring over the course of his participation in this case.  \n8. \nPlaintiff JANE DOE respectfully requests this motion be granted so that Attorney \nSeals may attend and fully participate in all matters on her behalf and otherwise engage in pre-\ntrial, trial, and post-trial proceedings in connection with this action. \n \nWHEREFORE, Plaintiff JANE DOE, by and through her counsel and sponsor of Attorney \nSeals, Thomas P. Giuffra, Esq., respectfully requests that this application for admission pro hac \nvice of W. Whitney Seals, Esq., be granted and that the Court enter an order substantially similar \nto the proposed order attached hereto as Exhibit A. \nDated: New York, NY \n \nOctober 19, 2026 \n \n \n \n \n \n \n \n \n \n \nFILED: NEW YORK COUNTY CLERK 10/19/2026 07:37 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 75\nRECEIVED NYSCEF: 10/19/2026\n2 of 3\n\n--- Page 3 ---\n.\n3 \n \n \n \n \n \n \nRHEINGOLD GIUFFRA RUFFO  \n \n \n \n \n \n \nPLOTKIN & HELLMAN LLP \n \n \n \n \n \n \nAttorneys for Plaintiff  \n \n \n \n \n \n \n \n  \n \n      _____________________                                                         \n \n \n \n \n \n \nBy: Thomas P. Giuffra, Esq. \n \n \n \n \n \n \n551 Fifth Avenue, 29th Fl. \nNew York, NY 10176 \n \n \n \n \n \n \nTel: (212) 684-1880 \n \n \n \n \n \n \ntgiuffra@rheingoldlaw.com \n \n \n \n \n \n \n \n \n-AND- \n \n \n \n \n \n \n \n \nCOCHRUN & SEALS, LLC \n \n \n \n \n \n \nAttorneys for Plaintiff \n \n \n \n \n \n \n(Pro Hac Vice pending) \n \n \n \n \n \n \n \n/s/ W. Whitney Seals \n   _____________________                                                         \n \n \n \n \n \n \nBy: W. Whitney Seals, Esq. \n \n \n \n \n \n \nP.O. Box 10448 \n \n \n \n \n \n \nBirmingham, AL 35202-0448 \n \n \n \n \n \n \nTel: (202) 323-3900 \n \n \n \n \n \n \nwhitney@cochrunseals.com \n \nFILED: NEW YORK COUNTY CLERK 10/19/2026 07:37 PM\nINDEX NO. 161704/2026\nNYSCEF DOC. NO. 75\nRECEIVED NYSCEF: 10/19/2026\n3 of 3","thumbnailUrl":"https://lucycraig.blog/media/537/thumb.webp","transcriptStatus":"not_applicable","transcriptText":"","url":"https://lucycraig.blog/media/537"}