# AFFIDAVIT OR AFFIRMATION IN SUPPORT

Source: https://lucycraig.blog/media/537
File: NYSCEF-Document-000075.pdf
Format: application/pdf
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
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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
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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
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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 
 
 
 
 
 
 
tgiuffra@rheingoldlaw.com 
 
 
 
 
 
 
 
 
-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 
 
 
 
 
 
 
whitney@cochrunseals.com 
 
FILED: NEW YORK COUNTY CLERK 10/19/2026 07:37 PM
INDEX NO. 161704/2026
NYSCEF DOC. NO. 75
RECEIVED NYSCEF: 10/19/2026
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