{"@context":"https://schema.org","@type":"DigitalDocument","altText":"ANSWER IN SPECIAL PROCEEDING Respondents' Verified Answer","alternateName":"NYSCEF-case-20f2fbf9d925-000018.pdf","caption":"NYSCEF document #18 | Filed: 2026-10-22 | Filed by: VIGARS, KAITLIN NORA Filed:  Received: | Docket status: Processed Confirmation Notice | Case: Lopes v. Hochul (Cornell 7 Lopes Against Special Prosecutor Assignment Tish James) Albany | Source: NYSCEF","contentUrl":"https://lucycraig.blog/media/592/raw","datePublished":"2026-10-22T21:41:43+00:00","description":"NYSCEF document #18 | Filed: 2026-10-22 | Filed by: VIGARS, KAITLIN NORA Filed:  Received: | Docket status: Processed Confirmation Notice | Case: Lopes v. Hochul (Cornell 7 Lopes Against Special Prosecutor Assignment Tish James) Albany | Source: NYSCEF","encodingFormat":"application/pdf","identifier":"592","isAccessibleForFree":true,"machineReadable":{"json":"https://lucycraig.blog/media/592/index.json","markdown":"https://lucycraig.blog/media/592/index.md"},"name":"ANSWER IN SPECIAL PROCEEDING Respondents' Verified Answer","ocrStatus":"ready","ocrText":"--- Page 1 ---\nSUPREME COURT OF THE STATE OF NEW YORK \nCOUNTY OF ALBANY \n \nIn the Matter of the Application of \nGILLIO LOPES, \nPetitioner, \n \nFor a Judgment Pursuant to Article 78 \nof the Civil Practice Law and Rules \n \n-against- \n \nKATHLEEN (\u201cKATHY\u201d) M. HOCHUL, in her official \ncapacity as Governor of the State of New York, and \nLETITIA JAMES, in her official capacity as Attorney \nGeneral of the State of New York, \n \nRespondents. \n \n \n \n \n \n \n \nVERIFIED ANSWER \n \nIndex No. 911974-26 \n \nOctober 29, 2026 \n \nFarrell, J. \n \n \nRespondents Kathy Hochul, Governor of the State of New York (Governor), and Letitia \nJames, Attorney General of the State of New York (AG and collectively with the Governor, \nRespondents), by their attorney, Letitia James, Attorney General of the State of New York, Kaitlin \nVigars of counsel, answer the petition as follows: \n1. \nAdmit the allegations contained in paragraph 1 of the verified petition insofar as \nsuch allegations tend to describe the nature of this proceeding and identify the administrative \ndetermination challenged in this proceeding and otherwise deny any allegations in paragraph 1 of \nthe verified petition that allege or tend to allege that the challenged action was in any way contrary \nto constitutional, statutory, regulatory or case law, and deny any wrongdoing whatsoever. \n2. \nAdmit the allegations contained in paragraph 2 of the verified petition insofar as \nsuch allegations identify the complaint filed in Index No. 161704/2026, Jane Doe v. Cornell \nUniversity, et al. (the Jane Doe Litigation), respectfully refer the Court to the complaint cited as \nthe best evidence and most accurate version of its contents, and deny the allegations in paragraph \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n1 of 20\n\n--- Page 2 ---\n2\n2 of the verified petition to the extent that such allegations are inconsistent with the document \ncited. \n3. \nAdmit the allegations contained in paragraph 3 of the verified petition insofar as \nsuch allegations identify subject matter of the complaint filed in the Jane Doe litigation, \nrespectfully refer the Court to the document cited as the best evidence and most accurate version \nof its contents, and deny the allegations in paragraph 3 of the verified petition to the extent that \nsuch allegations are inconsistent with the document cited. \n4. \nAdmit the allegations contained in paragraph 4 of the verified petition insofar as \nsuch allegations allege or tend to allege that the Jane Doe litigation made national headlines and \notherwise deny such allegations insofar as such allegations characterize the nature of the media \nattention. \n5. \nAdmit the allegations contained in paragraph 5 of the verified petition insofar as \nsuch allegations allege that, by Executive Order No. 64, dated October 1, 2026 and filed October \n2, 2026 (EO 64), the Governor appointed the AG to serve as a special prosecutor to investigate \nconduct arising out of the allegations made in the Jane Doe litigation, respectfully refer the Court \nto the copy of EO 64, which is appended to the accompanying affirmation of Kaitlin Vigars as \nExhibit A, as the best evidence and most accurate version of its contents, deny the allegations in \nparagraph 5 of the verified petition to the extent that such allegations are inconsistent with such \ndocument, deny the allegations in paragraph 5 of the verified petition that characterize or tend to \ncharacterize the Governor\u2019s action, deny that the that the challenged action was in any way \ncontrary to constitutional, statutory, regulatory or case law, and deny any wrongdoing whatsoever. \n6. \nDeny the allegations in paragraph 6 of the verified petition. \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n2 of 20\n\n--- Page 3 ---\n3\n7. \nAdmit the allegations in paragraph 7 of the verified petition insofar as such \nallegations identify remarks made by the AG on social media, respectfully refer the court to the \nsocial media post cited as the best evidence and most accurate version of its contents, and deny the \nallegations in paragraph 7 of the verified petition to the extent that such allegations are inconsistent \nwith the social media post cited. \n8. \nDeny the allegations in paragraph 8 of the verified petition. \n9. \nDeny the allegations in paragraph 9 of the verified petition. \n10. \nDeny the allegations in paragraph 10 of the verified petition. \n11. \nDeny knowledge of information sufficient to form a belief as to the truth of the \nallegations in paragraph 11 of the verified petition. \n12. \nAdmit the allegations in paragraph 12 of the verified petition insofar as such \nallegations identify the Governor in her official capacity as Governor of the State of New York. \n13. \nAdmit the allegations in paragraph 13 of the verified petition insofar as such \nallegations identify the AG in her official capacity as Attorney General of the State of New York. \n14. \nDeny the allegations in paragraph 14 of the verified petition insofar as such \nallegations allege or tend to allege that this Court has subject matter jurisdiction over this \nproceeding, respectfully refer the Court to the statutes cited as the best and most accurate version \nof their contents, deny the allegations in paragraph 14 of the verified petition to the extent that \nsuch allegations are inconsistent with the statute cited, and respectfully refer all questions of law \nto the Court. \n15. \nAdmit the allegations in paragraph 15 of the verified petition. \n16. \nAdmit the allegations contained in paragraph 16 of the verified petition insofar as \nsuch allegations identify the complaint filed in the Jane Doe Litigation and the subject matter of \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n3 of 20\n\n--- Page 4 ---\n4\nsame, respectfully refer the Court to the complaint cited as the best evidence and most accurate \nversion of its contents, and deny the allegations in paragraph 16 of the verified petition to the extent \nthat such allegations are inconsistent with the document cited. \n17. \nAdmit the allegations contained in paragraph 17 of the verified petition insofar as \nsuch allegations identify the complaint filed in the Jane Doe Litigation and the subject matter of \nsame, respectfully refer the Court to the complaint cited as the best evidence and most accurate \nversion of its contents, and deny the allegations in paragraph 17 of the verified petition to the extent \nthat such allegations are inconsistent with the document cited. \n18. \nAdmit the allegations contained in paragraph 18 of the verified petition insofar as \nsuch allegations allege or tend to allege that no criminal charges were filed in connection with the \nevents alleged in the Jane Doe litigation, and otherwise deny knowledge or information sufficient \nto form a belief as to the truth of the allegations in paragraph 18 of the verified petition pertaining \nto a report that the non-party plaintiff in the Jane Doe litigation made to non-party Cornell \nUniversity. \n19. \nDeny knowledge or information sufficient to form a belief as to the truth of the \nallegations in paragraph 19 of the verified petition. \n20. \nDeny knowledge or information sufficient to form a belief as to the truth of the \nallegations in paragraph 20 of the verified petition. \n21. \nDeny knowledge or information sufficient to form a belief as to the truth of the \nallegations in paragraph 21 of the verified petition. \n22. \nAdmit the allegations contained in paragraph 22 of the verified petition insofar as \nsuch allegations identify the Jane Doe Litigation and the subject matter of same, respectfully refer \nthe Court to the complaint filed in the Jane Doe Litigation as the best evidence and most accurate \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n4 of 20\n\n--- Page 5 ---\n5\nversion of its contents, including any claims filed against Petitioner, and deny the allegations in \nparagraph 22 of the verified petition to the extent that such allegations are inconsistent with \ncomplaint filed in the Jane Doe Litigation. \n23. \nAdmit the allegations contained in paragraph 23 of the verified petition insofar as \nsuch allegations allege or tend to allege that the Jane Doe litigation made national headlines, deny \nsuch allegations insofar as such allegations characterize the nature of the media attention, \nrespectfully refer the Court to the document cited in paragraph 23 as the best evidence and most \naccurate version of its contents, and deny the allegations in paragraph 23 of the verified petition to \nthe extent that such allegations are inconsistent with the document cited. \n24. \nAdmit the allegations contained in paragraph 24 of the verified petition insofar as \nsuch allegations allege or tend to allege that the Governor became aware of the Jane Doe litigation \nand that the actions of local law enforcement handling of the investigation into the events alleged \nin the Jane Doe Litigation was subject to public scrutiny, and otherwise deny the allegations \ncontained in paragraph 24 of the verified petition that characterize the Governor\u2019s actions or \nawareness.    \n25. \nDeny knowledge or information sufficient to form a belief as to the truth of the \nallegations contained in paragraph 25 of the verified petition. \n26. \nDeny knowledge or information sufficient to form a belief as to the truth of the \nallegations contained in paragraph 26 of the verified petition, respectfully refer the court to the \ndocument cited as the best evidence and most accurate version of its contents, and deny the \nallegations in paragraph 26 of the verified petition to the extent that such allegations are \ninconsistent with the document cited. \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n5 of 20\n\n--- Page 6 ---\n6\n27. \nAdmit the allegations in paragraph 27 of the verified petition insofar as such \nallegations allege or tend to allege that, on October 1, 2026, the Governor made a public statement \nregarding the Jane Doe litigation, respectfully refer the court to the statement cited as the best \nevidence and most accurate version of its contents, deny the allegations in paragraph 27 of the \nverified petition to the extent that such allegations are inconsistent with the statement cited, and \notherwise deny the allegations in paragraph 27 of the verified petition that characterize the \nGovernor\u2019s actions. \n28. \nAdmit the allegations in paragraph 28 of the verified petition insofar as such \nallegations allege or tend to allege that, on October 1, 2026, the Governor made a public statement \nregarding the Jane Doe litigation, respectfully refer the court to the statement cited as the best \nevidence and most accurate version of its contents, deny the allegations in paragraph 28 of the \nverified petition to the extent that such allegations are inconsistent with the statement cited, and \notherwise deny the allegations in paragraph 28 of the verified petition that characterize the \nGovernor\u2019s actions. \n29. \nAdmit the allegations in paragraph 29 of the verified petition insofar as such \nallegations allege or tend to allege that, by EO 64, the Governor appointed the AG to serve as a \nspecial prosecutor to investigate conduct arising out of the allegations made in the Jane Doe \nlitigation, respectfully refer the Court to the copy of EO 64, which is appended to the \naccompanying affirmation of Kaitlin Vigars as Exhibit A, as the best evidence and most accurate \nversion of its contents, and deny the allegations in paragraph 29 of the verified petition to the extent \nthat such allegations are inconsistent with EO 64. \n30. \nAdmit the allegations in paragraph 30 of the verified petition insofar as such \nallegations allege or tend to allege that, by EO 64, the Governor appointed the AG to serve as a \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n6 of 20\n\n--- Page 7 ---\n7\nspecial prosecutor to investigate conduct arising out of the allegations made in the Jane Doe \nlitigation, respectfully refer the Court to the copy of EO 64, which is appended to the \naccompanying affirmation of Kaitlin Vigars as Exhibit A, as the best evidence and most accurate \nversion of its contents, and deny the allegations in paragraph 30 of the verified petition to the extent \nthat such allegations are inconsistent with EO 64. \n31. \nDeny the allegations in paragraph 31 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever. \n32. \nAdmit the allegations in paragraph 32 of the verified petition insofar as such \nallegations identify remarks made by the AG on social media prior to her appointment as special \nprosecutor, respectfully refer the court to the social media post cited as the best evidence and most \naccurate version of its contents, and deny the allegations in paragraph 32 of the verified petition to \nthe extent that such allegations are inconsistent with the social media post cited. \n33. \nDeny the allegations in paragraph 33 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever.  \n34. \nDeny the allegations in paragraph 34 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever. \n35. \nDeny the allegations in paragraph 35 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, and deny that Petitioner is entitled to the relief requested or any relief \nwhatsoever. \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n7 of 20\n\n--- Page 8 ---\n8\n36. \nDeny the allegations in the paragraph enumerated as \u201cI\u201d on page 7 of the verified \npetition, deny that the challenged action was in any way contrary to constitutional, statutory, \nregulatory or case law, deny any wrongdoing whatsoever, and deny that Petitioner is entitled to \nthe relief requested or any relief whatsoever, and respectfully refer all questions of law to the \nCourt. \n37. \nDeny the allegations in paragraph 36 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, respectfully refer all questions of law to the Court, respectfully refer \nthe Court to the copy of EO 64, which is appended to the accompanying affirmation of Kaitlin \nVigars as Exhibit A, as the best evidence and most accurate version of its contents, and deny the \nallegations in paragraph 36 of the verified petition to the extent that such allegations are \ninconsistent with EO 64; further, respectfully refer the court to the social media post cited as the \nbest evidence and most accurate version of its contents, and deny the allegations in paragraph 36 \nof the verified petition to the extent that such allegations are inconsistent with the social media \npost cited. \n38. \nDeny the allegations in paragraph 37 of the verified petition to the extent that such \nallegations are inconsistent with the statute and case law cited, respectfully refer the court to the \nstatute and case law cited as the best evidence and most accurate version of their contents, and \notherwise deny the allegations in paragraph 37 of the verified petition, deny that the challenged \naction was in any way contrary to constitutional, statutory, regulatory or case law, and deny any \nwrongdoing whatsoever. \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n8 of 20\n\n--- Page 9 ---\n9\n39. \nDeny the allegations in paragraph 38 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever. \n40. \nDeny the allegations in paragraph 39 of the verified petition to the extent that such \nallegations are inconsistent with the case law cited, respectfully refer the court to the case law cited \nas the best evidence and most accurate version of its contents, and otherwise deny the allegations \nin paragraph 39 of the verified petition, deny that the challenged action was in any way contrary \nto constitutional, statutory, regulatory or case law, and deny any wrongdoing whatsoever. \n41. \nDeny the allegations in paragraph 40 to the extent that such allegations are \ninconsistent with the case law cited, respectfully refer the court to the case law cited as the best \nevidence and most accurate version of its contents, and otherwise deny the allegations in paragraph \n40 of the verified petition, deny that the challenged action was in any way contrary to \nconstitutional, statutory, regulatory or case law, and deny any wrongdoing whatsoever. \n42. \nDeny the allegations in paragraph 41 of the verified petition to the extent that such \nallegations are inconsistent with the case law cited, respectfully refer the court to the case law cited \nas the best evidence and most accurate version of its contents, and otherwise deny the allegations \nin paragraph 41 of the verified petition, deny that the challenged action was in any way contrary \nto constitutional, statutory, regulatory or case law, and deny any wrongdoing whatsoever. \n43. \nDeny the allegations in paragraph 42 of the verified petition to the extent that such \nallegations are inconsistent with the case law cited, respectfully refer the court to the case law cited \nas the best evidence and most accurate version of its contents, and otherwise deny the allegations \nin paragraph 42 of the verified petition, deny that the challenged action was in any way contrary \nto constitutional, statutory, regulatory or case law, and deny any wrongdoing whatsoever. \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n9 of 20\n\n--- Page 10 ---\n10 \n44. \nDeny the allegations in paragraph 43 of the verified petition to the extent that such \nallegations are inconsistent with the case law cited, respectfully refer the court to the case law cited \nas the best evidence and most accurate version of its contents, and otherwise deny the allegations \nin paragraph 43 of the verified petition, deny that the challenged action was in any way contrary \nto constitutional, statutory, regulatory or case law, and deny any wrongdoing whatsoever. \n45. \nDeny the allegations in paragraph 44 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever. \n46. \nDeny the allegations in paragraph 45 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever. \n47. \nDeny the allegations in paragraph 46 of the verified petition insofar as such \nallegations characterize the authority that the Governor granted to the AG as articulated in EO 64, \nrespectfully refer the Court to the copy of EO 64, which is appended to the accompanying \naffirmation of Kaitlin Vigars as Exhibit A, as the best evidence and most accurate version of its \ncontents, deny the allegations in paragraph 46 of the verified petition to the extent that such \nallegations are inconsistent with EO 64, and deny that the that the challenged action was in any \nway contrary to constitutional, statutory, regulatory or case law, and deny any wrongdoing \nwhatsoever. \n48. \nDeny the allegations in paragraph 47 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, and deny that Petitioner is entitled to the relief requested or any relief \nwhatsoever. \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n10 of 20\n\n--- Page 11 ---\n11 \n49. \nDeny the allegations in paragraph 48 of the verified petition to the extent that they \nare inconsistent with the document cited, respectfully refer the court to the document cited as the \nbest evidence and most accurate version of its contents, and otherwise deny the allegations in \nparagraph 48 of the verified petition deny that the challenged action was in any way contrary to \nconstitutional, statutory, regulatory or case law, and deny any wrongdoing whatsoever. \n50. \nDeny the allegations in paragraph 49 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, deny that the opinion/commentary cited as Exhibit 8 is evidence of \nprejudice, and deny that Petitioner is entitled to the relief requested or any relief whatsoever. \n51. \nDeny the allegations in paragraph 50 of the verified petition to the extent that such \nallegations are inconsistent with the case law cited, respectfully refer the court to the case law cited \nas the best evidence and most accurate version of its contents, and otherwise deny the allegations \nin paragraph 50 of the verified petition, deny that the challenged action was in any way contrary \nto constitutional, statutory, regulatory or case law, and deny any wrongdoing whatsoever. \n52. \nAdmit the allegations in paragraph 51 of the verified petition insofar as such \nallegations allege or tend to allege that whether the writ of prohibition lies in a particular matter \nrequires consideration of certain threshold questions and discretionary factors, and otherwise deny \nthe allegations in paragraph 51 of the verified petition that allege or tend to allege that Petitioner \nis entitled to the writ of prohibition here, deny that the challenged action was in any way contrary \nto constitutional, statutory, regulatory or case law, and deny any wrongdoing whatsoever. \n53. \nDeny the allegations in the paragraph enumerated as \u201cII\u201d on page 10 of the verified \npetition, deny that the challenged action was in any way contrary to constitutional, statutory, \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n11 of 20\n\n--- Page 12 ---\n12 \nregulatory or case law, deny any wrongdoing whatsoever, and deny that Petitioner is entitled to \nthe relief requested or any relief whatsoever. \n54. \nDeny the allegations in paragraph 52 of the verified petition to the extent that such \nallegations are inconsistent with the statute and case law cited, respectfully refer the court to the \nstatute and case law cited as the best evidence and most accurate version of its contents, and \notherwise deny the allegations in paragraph 52 of the verified petition, deny that the challenged \naction was in any way contrary to constitutional, statutory, regulatory or case law, deny any \nwrongdoing whatsoever, and respectfully refer all questions of law to the Court. \n55. \nDeny knowledge or information sufficient to form a belief as to the allegations in \nparagraph 53 of the verified petition insofar as such allegations reference Petitioner\u2019s contentions, \nand otherwise deny the allegations in paragraph 53 of the verified petition, deny that the challenged \naction was in any way contrary to constitutional, statutory, regulatory or case law, and deny any \nwrongdoing whatsoever. \n56. \nDeny the allegations in paragraph 54 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever. \n57. \nDeny the allegations in paragraph 55 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever, and respectfully refer all questions of law to the Court. \n58. \nDeny the allegations in the paragraph enumerated as \u201cIII\u201d on page 11 of the verified \npetition, deny that the challenged action was in any way contrary to constitutional, statutory, \nregulatory or case law, deny any wrongdoing whatsoever, and deny that Petitioner is entitled to \nthe relief requested or any relief whatsoever. \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n12 of 20\n\n--- Page 13 ---\n13 \n59. \nAdmit the allegations in paragraph 56 insofar as such allegations allege or tend to \nallege that Petitioner\u2019s conduct may fall within the scope of the investigation authorized by EO \n64, respectfully refer the Court to the copy of EO 64, which is appended to the accompanying \naffirmation of Kaitlin Vigars as Exhibit A, as the best evidence and most accurate version of its \ncontents, and deny the allegations in paragraph 56 of the verified petition to the extent that such \nallegations are inconsistent with EO 64. \n60. \nDeny the allegations in paragraph 57 of the verified petition insofar as such \nallegations tend to characterize the authority that the Governor granted to the AG as articulated in \nEO 64, respectfully refer the Court to the copy of EO 64, which is appended to the accompanying \naffirmation of Kaitlin Vigars as Exhibit A, as the best evidence and most accurate version of its \ncontents, deny the allegations in paragraph 57 of the verified petition to the extent that such \nallegations are inconsistent with EO 64, and deny that the that the challenged action was in any \nway contrary to constitutional, statutory, regulatory or case law, and deny any wrongdoing \nwhatsoever.  \n61. \nDeny the allegations in paragraph 58 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, and deny that Petitioner is entitled to the relief requested or any relief \nwhatsoever. \n62. \nDeny the allegations in paragraph 59 of the verified petition to the extent that such \nallegations are inconsistent with the statute and case law cited, respectfully refer the court to the \nstatute and case law cited as the best evidence and most accurate version of their contents, and \notherwise deny the allegations in paragraph 59 of the verified petition, deny that the challenged \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n13 of 20\n\n--- Page 14 ---\n14 \naction was in any way contrary to constitutional, statutory, regulatory or case law, and deny any \nwrongdoing whatsoever. \n63. \nDeny the allegations in the paragraph enumerated as \u201cIV\u201d on page 12 of the verified \npetition, deny that the challenged action was in any way contrary to constitutional, statutory, \nregulatory or case law, deny any wrongdoing whatsoever, deny that Petitioner is entitled to the \nrelief requested or any relief whatsoever, and respectfully refer all questions of law to the Court. \n64. \nDeny the allegations in paragraph 60 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, deny that Petitioner is entitled to the relief requested or any relief \nwhatsoever, and respectfully refer all questions of law to the Court. \n65. \nDeny the allegations in paragraph 61 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, and deny that Petitioner is entitled to the relief requested or any relief \nwhatsoever. \n66. \nDeny the allegations in paragraph 62 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, and deny that Petitioner is entitled to the relief requested or any relief \nwhatsoever. \n67. \nDeny the allegations in paragraph 63 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, and deny that Petitioner is entitled to the relief requested or any relief \nwhatsoever. \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n14 of 20\n\n--- Page 15 ---\n15 \n68. \nDeny the allegations in the paragraph enumerated as \u201cV\u201d on page 13 of the verified \npetition to the extent that it is alleged that Petitioner has suffered harm, deny that the challenged \naction was in any way contrary to constitutional, statutory, regulatory or case law, and deny any \nwrongdoing whatsoever. \n69. \nAdmit the allegations in paragraph 64 insofar as such allegations allege or tend to \nallege that Petitioner\u2019s conduct may fall within the scope of the investigation authorized by EO \n64, respectfully refer the Court to the copy of EO 64, which is appended to the accompanying \naffirmation of Kaitlin Vigars as Exhibit A, as the best evidence and most accurate version of its \ncontents, and deny the allegations in paragraph 64 of the verified petition to the extent that such \nallegations are inconsistent with EO 64. \n70. \nAdmit the allegations in paragraph 65 of the verified petition. \n71. \nDeny the allegations in paragraph 66 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever. \n72. \nDeny the allegations in paragraph 67 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, and deny that Petitioner is entitled to the relief requested or any relief \nwhatsoever. \n73. \nDeny the allegations in paragraph 68 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, and deny that Petitioner is entitled to the relief requested or any relief \nwhatsoever. \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n15 of 20\n\n--- Page 16 ---\n16 \n74. \nDeny the allegations in paragraph 69 of the verified petition and respectfully refer \nto their answers to paragraphs 1 through 68 of the verified petition above. \n75. \nDeny the allegations in paragraph 70 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, and respectfully refer all questions of law to the Court. \n76. \nDeny the allegations in paragraph 71 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, and respectfully refer all questions of law to the Court. \n77. \nAdmit the allegations in paragraph 72 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever. \n78. \nAdmit the allegations in paragraph 73 of the verified petition insofar as such \nallegations allege or tend to allege that Petitioner\u2019s conduct may fall within the scope of the \ninvestigation authorized by EO 64, respectfully refer the Court to the copy of EO 64, which is \nappended to the accompanying affirmation of Kaitlin Vigars as Exhibit A, as the best evidence \nand most accurate version of its contents, and deny the allegations in paragraph 73 of the verified \npetition to the extent that such allegations are inconsistent with EO 64. \n79. \nDeny the allegations in paragraph 74 of the verified petition. \n80. \nDeny the allegations in paragraph 75 of the verified petition insofar as such \nallegations tend to characterize the authority that the Governor granted to the AG as articulated in \nEO 64, respectfully refer the Court to the copy of EO 64, which is appended to the accompanying \naffirmation of Kaitlin Vigars as Exhibit A, as the best evidence and most accurate version of its \ncontents, deny the allegations in paragraph 75 of the verified petition to the extent that such \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n16 of 20\n\n--- Page 17 ---\n17 \nallegations are inconsistent with EO 64, and deny that the that the challenged action was in any \nway contrary to constitutional, statutory, regulatory or case law, and deny any wrongdoing \nwhatsoever. \n81. \nDeny the allegations in paragraph 76 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever. \n82. \nDeny the allegations in paragraph 77 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever. \n83. \nDeny the allegations in paragraph 78 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever. \n84. \nDeny the allegations in paragraph 79 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever. \n85. \nDeny the allegations in paragraph 80 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, and deny that Petitioner is entitled to the relief requested or any relief \nwhatsoever. \n86. \nDeny knowledge or information sufficient to form a belief as to the truth of the \nallegations in paragraph 81 of the verified petition. \n87. \nDeny the allegations in the WHEREFORE clause, deny that Petitioner is entitled to \nthe relief requested, and deny that Petitioner is entitled to any relief whatsoever. \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n17 of 20\n\n--- Page 18 ---\n18 \n88. \nDeny each and every allegation of the verified petition not specifically responded \nto above.  \nOBJECTIONS IN POINT OF LAW \n89. \nPetitioner\u2019s claims raised in this proceeding are not justiciable.  CPLR 3211(a)(2), \nand (7). \n90. \nPetitioner lacks standing.  CPLR 3211(a)(2), and (7). \n91. \nPetitioner\u2019s claims raised in this proceeding raise a political question not suitable \nfor judicial review.  CPLR 3211(a)(2), and (7). \n92. \nPetitioner\u2019s claims raised in this proceeding are not ripe for judicial review.  CPLR \n3211(a)(2), and (7). \n93. \nThe verified petition fails to state a cause of action.  CPLR 3211(a)(7). \n94. \nThe actions challenged in this proceeding are not subject to judicial review as \narbitrary and capricious or an abuse of discretion.  CPLR 3211(a)(7). \nRECORD BEFORE THE AGENCY BELOW \n95. \nThe documents annexed to the Affirmation of Kaitlin Vigars, dated October 22, \n2026, as Exhibit A constitute the record before the administrative agency in this proceeding: \na. \nExecutive Order No. 64. \n96. \n Also submitted herewith is the following: \na. \nAffirmation of Kaitlin Vigars, dated October 22, 2026, with Exhibit A as \ndetailed in paragraph 95 above. \nWHEREFORE, Respondents respectfully request that the relief requested in the verified \npetition be denied, that the petition and this action be dismissed, and that Respondents be awarded \ncosts and disbursements or, in the event the Court grants the verified petition, that the Court remand \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n18 of 20\n\n--- Page 19 ---\nPrinted [Reproduced] on Recycled Paper \n \n19 \nthe matter for a rehearing at which the technical matters complained of by the petitioner may be \nremedied, together with such other relief as may be right and just. \nDated: Albany, New York \n \nOctober 22, 2026 \nLETITIA JAMES \nAttorney General of the State of New York \nAttorney for Respondents Kathy Hochul, \nGovernor of the State of New York, and \nLetitia James, Attorney General of the State \nof New York \nThe Capitol \nAlbany, New York  12224 \n \nBy: \n/s/ Kaitlin Vigars \nKaitlin Vigars \nAssistant Attorney General, of Counsel \nTelephone:  (518) 776-2036 \nFax: (518) 915-7738 (Not for service of papers) \n \n \nTO: \nAll counsel of record (via NYSCEF) \n \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n19 of 20\n\n--- Page 20 ---\nPrinted [Reproduced] on Recycled Paper \n \n \nVerification \n \n \n \nKaitlin Vigars, being a duly licensed attorney in the State of New York and an Assistant \nAttorney General of counsel in this matter to Letitia James, Attorney General of the State of New \nYork, affirms the following: \n \nI have been assigned to defend the within proceeding and I am acquainted therewith, and \nI have personally examined the exhibits annexed to the foregoing answer and records of \nRespondents provided herein. \n \nI have read the foregoing answer.  The same is true to my knowledge, except as to those \nmatters alleged on information and belief, and as to those matters, I believe them to be true. \n \nThis verification is made by me, pursuant to CPLR Section 3020(d)(2), because  \nRespondents are officers of the State of New York, and I am acquainted with the facts of this \nproceeding. \n \nI affirm this 22nd day of October, 2026, under the penalties of perjury under the laws of New \nYork, which may include a fine or imprisonment, that the foregoing is true, and I understand that \nthis document may be filed in an action or proceeding in a court of law.   \n \n \n/s/ Kaitlin Vigars \n  Kaitlin Vigars \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n20 of 20","text":"--- Page 1 ---\nSUPREME COURT OF THE STATE OF NEW YORK \nCOUNTY OF ALBANY \n \nIn the Matter of the Application of \nGILLIO LOPES, \nPetitioner, \n \nFor a Judgment Pursuant to Article 78 \nof the Civil Practice Law and Rules \n \n-against- \n \nKATHLEEN (\u201cKATHY\u201d) M. HOCHUL, in her official \ncapacity as Governor of the State of New York, and \nLETITIA JAMES, in her official capacity as Attorney \nGeneral of the State of New York, \n \nRespondents. \n \n \n \n \n \n \n \nVERIFIED ANSWER \n \nIndex No. 911974-26 \n \nOctober 29, 2026 \n \nFarrell, J. \n \n \nRespondents Kathy Hochul, Governor of the State of New York (Governor), and Letitia \nJames, Attorney General of the State of New York (AG and collectively with the Governor, \nRespondents), by their attorney, Letitia James, Attorney General of the State of New York, Kaitlin \nVigars of counsel, answer the petition as follows: \n1. \nAdmit the allegations contained in paragraph 1 of the verified petition insofar as \nsuch allegations tend to describe the nature of this proceeding and identify the administrative \ndetermination challenged in this proceeding and otherwise deny any allegations in paragraph 1 of \nthe verified petition that allege or tend to allege that the challenged action was in any way contrary \nto constitutional, statutory, regulatory or case law, and deny any wrongdoing whatsoever. \n2. \nAdmit the allegations contained in paragraph 2 of the verified petition insofar as \nsuch allegations identify the complaint filed in Index No. 161704/2026, Jane Doe v. Cornell \nUniversity, et al. (the Jane Doe Litigation), respectfully refer the Court to the complaint cited as \nthe best evidence and most accurate version of its contents, and deny the allegations in paragraph \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n1 of 20\n\n--- Page 2 ---\n2\n2 of the verified petition to the extent that such allegations are inconsistent with the document \ncited. \n3. \nAdmit the allegations contained in paragraph 3 of the verified petition insofar as \nsuch allegations identify subject matter of the complaint filed in the Jane Doe litigation, \nrespectfully refer the Court to the document cited as the best evidence and most accurate version \nof its contents, and deny the allegations in paragraph 3 of the verified petition to the extent that \nsuch allegations are inconsistent with the document cited. \n4. \nAdmit the allegations contained in paragraph 4 of the verified petition insofar as \nsuch allegations allege or tend to allege that the Jane Doe litigation made national headlines and \notherwise deny such allegations insofar as such allegations characterize the nature of the media \nattention. \n5. \nAdmit the allegations contained in paragraph 5 of the verified petition insofar as \nsuch allegations allege that, by Executive Order No. 64, dated October 1, 2026 and filed October \n2, 2026 (EO 64), the Governor appointed the AG to serve as a special prosecutor to investigate \nconduct arising out of the allegations made in the Jane Doe litigation, respectfully refer the Court \nto the copy of EO 64, which is appended to the accompanying affirmation of Kaitlin Vigars as \nExhibit A, as the best evidence and most accurate version of its contents, deny the allegations in \nparagraph 5 of the verified petition to the extent that such allegations are inconsistent with such \ndocument, deny the allegations in paragraph 5 of the verified petition that characterize or tend to \ncharacterize the Governor\u2019s action, deny that the that the challenged action was in any way \ncontrary to constitutional, statutory, regulatory or case law, and deny any wrongdoing whatsoever. \n6. \nDeny the allegations in paragraph 6 of the verified petition. \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n2 of 20\n\n--- Page 3 ---\n3\n7. \nAdmit the allegations in paragraph 7 of the verified petition insofar as such \nallegations identify remarks made by the AG on social media, respectfully refer the court to the \nsocial media post cited as the best evidence and most accurate version of its contents, and deny the \nallegations in paragraph 7 of the verified petition to the extent that such allegations are inconsistent \nwith the social media post cited. \n8. \nDeny the allegations in paragraph 8 of the verified petition. \n9. \nDeny the allegations in paragraph 9 of the verified petition. \n10. \nDeny the allegations in paragraph 10 of the verified petition. \n11. \nDeny knowledge of information sufficient to form a belief as to the truth of the \nallegations in paragraph 11 of the verified petition. \n12. \nAdmit the allegations in paragraph 12 of the verified petition insofar as such \nallegations identify the Governor in her official capacity as Governor of the State of New York. \n13. \nAdmit the allegations in paragraph 13 of the verified petition insofar as such \nallegations identify the AG in her official capacity as Attorney General of the State of New York. \n14. \nDeny the allegations in paragraph 14 of the verified petition insofar as such \nallegations allege or tend to allege that this Court has subject matter jurisdiction over this \nproceeding, respectfully refer the Court to the statutes cited as the best and most accurate version \nof their contents, deny the allegations in paragraph 14 of the verified petition to the extent that \nsuch allegations are inconsistent with the statute cited, and respectfully refer all questions of law \nto the Court. \n15. \nAdmit the allegations in paragraph 15 of the verified petition. \n16. \nAdmit the allegations contained in paragraph 16 of the verified petition insofar as \nsuch allegations identify the complaint filed in the Jane Doe Litigation and the subject matter of \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n3 of 20\n\n--- Page 4 ---\n4\nsame, respectfully refer the Court to the complaint cited as the best evidence and most accurate \nversion of its contents, and deny the allegations in paragraph 16 of the verified petition to the extent \nthat such allegations are inconsistent with the document cited. \n17. \nAdmit the allegations contained in paragraph 17 of the verified petition insofar as \nsuch allegations identify the complaint filed in the Jane Doe Litigation and the subject matter of \nsame, respectfully refer the Court to the complaint cited as the best evidence and most accurate \nversion of its contents, and deny the allegations in paragraph 17 of the verified petition to the extent \nthat such allegations are inconsistent with the document cited. \n18. \nAdmit the allegations contained in paragraph 18 of the verified petition insofar as \nsuch allegations allege or tend to allege that no criminal charges were filed in connection with the \nevents alleged in the Jane Doe litigation, and otherwise deny knowledge or information sufficient \nto form a belief as to the truth of the allegations in paragraph 18 of the verified petition pertaining \nto a report that the non-party plaintiff in the Jane Doe litigation made to non-party Cornell \nUniversity. \n19. \nDeny knowledge or information sufficient to form a belief as to the truth of the \nallegations in paragraph 19 of the verified petition. \n20. \nDeny knowledge or information sufficient to form a belief as to the truth of the \nallegations in paragraph 20 of the verified petition. \n21. \nDeny knowledge or information sufficient to form a belief as to the truth of the \nallegations in paragraph 21 of the verified petition. \n22. \nAdmit the allegations contained in paragraph 22 of the verified petition insofar as \nsuch allegations identify the Jane Doe Litigation and the subject matter of same, respectfully refer \nthe Court to the complaint filed in the Jane Doe Litigation as the best evidence and most accurate \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n4 of 20\n\n--- Page 5 ---\n5\nversion of its contents, including any claims filed against Petitioner, and deny the allegations in \nparagraph 22 of the verified petition to the extent that such allegations are inconsistent with \ncomplaint filed in the Jane Doe Litigation. \n23. \nAdmit the allegations contained in paragraph 23 of the verified petition insofar as \nsuch allegations allege or tend to allege that the Jane Doe litigation made national headlines, deny \nsuch allegations insofar as such allegations characterize the nature of the media attention, \nrespectfully refer the Court to the document cited in paragraph 23 as the best evidence and most \naccurate version of its contents, and deny the allegations in paragraph 23 of the verified petition to \nthe extent that such allegations are inconsistent with the document cited. \n24. \nAdmit the allegations contained in paragraph 24 of the verified petition insofar as \nsuch allegations allege or tend to allege that the Governor became aware of the Jane Doe litigation \nand that the actions of local law enforcement handling of the investigation into the events alleged \nin the Jane Doe Litigation was subject to public scrutiny, and otherwise deny the allegations \ncontained in paragraph 24 of the verified petition that characterize the Governor\u2019s actions or \nawareness.    \n25. \nDeny knowledge or information sufficient to form a belief as to the truth of the \nallegations contained in paragraph 25 of the verified petition. \n26. \nDeny knowledge or information sufficient to form a belief as to the truth of the \nallegations contained in paragraph 26 of the verified petition, respectfully refer the court to the \ndocument cited as the best evidence and most accurate version of its contents, and deny the \nallegations in paragraph 26 of the verified petition to the extent that such allegations are \ninconsistent with the document cited. \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n5 of 20\n\n--- Page 6 ---\n6\n27. \nAdmit the allegations in paragraph 27 of the verified petition insofar as such \nallegations allege or tend to allege that, on October 1, 2026, the Governor made a public statement \nregarding the Jane Doe litigation, respectfully refer the court to the statement cited as the best \nevidence and most accurate version of its contents, deny the allegations in paragraph 27 of the \nverified petition to the extent that such allegations are inconsistent with the statement cited, and \notherwise deny the allegations in paragraph 27 of the verified petition that characterize the \nGovernor\u2019s actions. \n28. \nAdmit the allegations in paragraph 28 of the verified petition insofar as such \nallegations allege or tend to allege that, on October 1, 2026, the Governor made a public statement \nregarding the Jane Doe litigation, respectfully refer the court to the statement cited as the best \nevidence and most accurate version of its contents, deny the allegations in paragraph 28 of the \nverified petition to the extent that such allegations are inconsistent with the statement cited, and \notherwise deny the allegations in paragraph 28 of the verified petition that characterize the \nGovernor\u2019s actions. \n29. \nAdmit the allegations in paragraph 29 of the verified petition insofar as such \nallegations allege or tend to allege that, by EO 64, the Governor appointed the AG to serve as a \nspecial prosecutor to investigate conduct arising out of the allegations made in the Jane Doe \nlitigation, respectfully refer the Court to the copy of EO 64, which is appended to the \naccompanying affirmation of Kaitlin Vigars as Exhibit A, as the best evidence and most accurate \nversion of its contents, and deny the allegations in paragraph 29 of the verified petition to the extent \nthat such allegations are inconsistent with EO 64. \n30. \nAdmit the allegations in paragraph 30 of the verified petition insofar as such \nallegations allege or tend to allege that, by EO 64, the Governor appointed the AG to serve as a \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n6 of 20\n\n--- Page 7 ---\n7\nspecial prosecutor to investigate conduct arising out of the allegations made in the Jane Doe \nlitigation, respectfully refer the Court to the copy of EO 64, which is appended to the \naccompanying affirmation of Kaitlin Vigars as Exhibit A, as the best evidence and most accurate \nversion of its contents, and deny the allegations in paragraph 30 of the verified petition to the extent \nthat such allegations are inconsistent with EO 64. \n31. \nDeny the allegations in paragraph 31 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever. \n32. \nAdmit the allegations in paragraph 32 of the verified petition insofar as such \nallegations identify remarks made by the AG on social media prior to her appointment as special \nprosecutor, respectfully refer the court to the social media post cited as the best evidence and most \naccurate version of its contents, and deny the allegations in paragraph 32 of the verified petition to \nthe extent that such allegations are inconsistent with the social media post cited. \n33. \nDeny the allegations in paragraph 33 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever.  \n34. \nDeny the allegations in paragraph 34 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever. \n35. \nDeny the allegations in paragraph 35 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, and deny that Petitioner is entitled to the relief requested or any relief \nwhatsoever. \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n7 of 20\n\n--- Page 8 ---\n8\n36. \nDeny the allegations in the paragraph enumerated as \u201cI\u201d on page 7 of the verified \npetition, deny that the challenged action was in any way contrary to constitutional, statutory, \nregulatory or case law, deny any wrongdoing whatsoever, and deny that Petitioner is entitled to \nthe relief requested or any relief whatsoever, and respectfully refer all questions of law to the \nCourt. \n37. \nDeny the allegations in paragraph 36 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, respectfully refer all questions of law to the Court, respectfully refer \nthe Court to the copy of EO 64, which is appended to the accompanying affirmation of Kaitlin \nVigars as Exhibit A, as the best evidence and most accurate version of its contents, and deny the \nallegations in paragraph 36 of the verified petition to the extent that such allegations are \ninconsistent with EO 64; further, respectfully refer the court to the social media post cited as the \nbest evidence and most accurate version of its contents, and deny the allegations in paragraph 36 \nof the verified petition to the extent that such allegations are inconsistent with the social media \npost cited. \n38. \nDeny the allegations in paragraph 37 of the verified petition to the extent that such \nallegations are inconsistent with the statute and case law cited, respectfully refer the court to the \nstatute and case law cited as the best evidence and most accurate version of their contents, and \notherwise deny the allegations in paragraph 37 of the verified petition, deny that the challenged \naction was in any way contrary to constitutional, statutory, regulatory or case law, and deny any \nwrongdoing whatsoever. \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n8 of 20\n\n--- Page 9 ---\n9\n39. \nDeny the allegations in paragraph 38 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever. \n40. \nDeny the allegations in paragraph 39 of the verified petition to the extent that such \nallegations are inconsistent with the case law cited, respectfully refer the court to the case law cited \nas the best evidence and most accurate version of its contents, and otherwise deny the allegations \nin paragraph 39 of the verified petition, deny that the challenged action was in any way contrary \nto constitutional, statutory, regulatory or case law, and deny any wrongdoing whatsoever. \n41. \nDeny the allegations in paragraph 40 to the extent that such allegations are \ninconsistent with the case law cited, respectfully refer the court to the case law cited as the best \nevidence and most accurate version of its contents, and otherwise deny the allegations in paragraph \n40 of the verified petition, deny that the challenged action was in any way contrary to \nconstitutional, statutory, regulatory or case law, and deny any wrongdoing whatsoever. \n42. \nDeny the allegations in paragraph 41 of the verified petition to the extent that such \nallegations are inconsistent with the case law cited, respectfully refer the court to the case law cited \nas the best evidence and most accurate version of its contents, and otherwise deny the allegations \nin paragraph 41 of the verified petition, deny that the challenged action was in any way contrary \nto constitutional, statutory, regulatory or case law, and deny any wrongdoing whatsoever. \n43. \nDeny the allegations in paragraph 42 of the verified petition to the extent that such \nallegations are inconsistent with the case law cited, respectfully refer the court to the case law cited \nas the best evidence and most accurate version of its contents, and otherwise deny the allegations \nin paragraph 42 of the verified petition, deny that the challenged action was in any way contrary \nto constitutional, statutory, regulatory or case law, and deny any wrongdoing whatsoever. \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n9 of 20\n\n--- Page 10 ---\n10 \n44. \nDeny the allegations in paragraph 43 of the verified petition to the extent that such \nallegations are inconsistent with the case law cited, respectfully refer the court to the case law cited \nas the best evidence and most accurate version of its contents, and otherwise deny the allegations \nin paragraph 43 of the verified petition, deny that the challenged action was in any way contrary \nto constitutional, statutory, regulatory or case law, and deny any wrongdoing whatsoever. \n45. \nDeny the allegations in paragraph 44 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever. \n46. \nDeny the allegations in paragraph 45 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever. \n47. \nDeny the allegations in paragraph 46 of the verified petition insofar as such \nallegations characterize the authority that the Governor granted to the AG as articulated in EO 64, \nrespectfully refer the Court to the copy of EO 64, which is appended to the accompanying \naffirmation of Kaitlin Vigars as Exhibit A, as the best evidence and most accurate version of its \ncontents, deny the allegations in paragraph 46 of the verified petition to the extent that such \nallegations are inconsistent with EO 64, and deny that the that the challenged action was in any \nway contrary to constitutional, statutory, regulatory or case law, and deny any wrongdoing \nwhatsoever. \n48. \nDeny the allegations in paragraph 47 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, and deny that Petitioner is entitled to the relief requested or any relief \nwhatsoever. \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n10 of 20\n\n--- Page 11 ---\n11 \n49. \nDeny the allegations in paragraph 48 of the verified petition to the extent that they \nare inconsistent with the document cited, respectfully refer the court to the document cited as the \nbest evidence and most accurate version of its contents, and otherwise deny the allegations in \nparagraph 48 of the verified petition deny that the challenged action was in any way contrary to \nconstitutional, statutory, regulatory or case law, and deny any wrongdoing whatsoever. \n50. \nDeny the allegations in paragraph 49 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, deny that the opinion/commentary cited as Exhibit 8 is evidence of \nprejudice, and deny that Petitioner is entitled to the relief requested or any relief whatsoever. \n51. \nDeny the allegations in paragraph 50 of the verified petition to the extent that such \nallegations are inconsistent with the case law cited, respectfully refer the court to the case law cited \nas the best evidence and most accurate version of its contents, and otherwise deny the allegations \nin paragraph 50 of the verified petition, deny that the challenged action was in any way contrary \nto constitutional, statutory, regulatory or case law, and deny any wrongdoing whatsoever. \n52. \nAdmit the allegations in paragraph 51 of the verified petition insofar as such \nallegations allege or tend to allege that whether the writ of prohibition lies in a particular matter \nrequires consideration of certain threshold questions and discretionary factors, and otherwise deny \nthe allegations in paragraph 51 of the verified petition that allege or tend to allege that Petitioner \nis entitled to the writ of prohibition here, deny that the challenged action was in any way contrary \nto constitutional, statutory, regulatory or case law, and deny any wrongdoing whatsoever. \n53. \nDeny the allegations in the paragraph enumerated as \u201cII\u201d on page 10 of the verified \npetition, deny that the challenged action was in any way contrary to constitutional, statutory, \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n11 of 20\n\n--- Page 12 ---\n12 \nregulatory or case law, deny any wrongdoing whatsoever, and deny that Petitioner is entitled to \nthe relief requested or any relief whatsoever. \n54. \nDeny the allegations in paragraph 52 of the verified petition to the extent that such \nallegations are inconsistent with the statute and case law cited, respectfully refer the court to the \nstatute and case law cited as the best evidence and most accurate version of its contents, and \notherwise deny the allegations in paragraph 52 of the verified petition, deny that the challenged \naction was in any way contrary to constitutional, statutory, regulatory or case law, deny any \nwrongdoing whatsoever, and respectfully refer all questions of law to the Court. \n55. \nDeny knowledge or information sufficient to form a belief as to the allegations in \nparagraph 53 of the verified petition insofar as such allegations reference Petitioner\u2019s contentions, \nand otherwise deny the allegations in paragraph 53 of the verified petition, deny that the challenged \naction was in any way contrary to constitutional, statutory, regulatory or case law, and deny any \nwrongdoing whatsoever. \n56. \nDeny the allegations in paragraph 54 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever. \n57. \nDeny the allegations in paragraph 55 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever, and respectfully refer all questions of law to the Court. \n58. \nDeny the allegations in the paragraph enumerated as \u201cIII\u201d on page 11 of the verified \npetition, deny that the challenged action was in any way contrary to constitutional, statutory, \nregulatory or case law, deny any wrongdoing whatsoever, and deny that Petitioner is entitled to \nthe relief requested or any relief whatsoever. \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n12 of 20\n\n--- Page 13 ---\n13 \n59. \nAdmit the allegations in paragraph 56 insofar as such allegations allege or tend to \nallege that Petitioner\u2019s conduct may fall within the scope of the investigation authorized by EO \n64, respectfully refer the Court to the copy of EO 64, which is appended to the accompanying \naffirmation of Kaitlin Vigars as Exhibit A, as the best evidence and most accurate version of its \ncontents, and deny the allegations in paragraph 56 of the verified petition to the extent that such \nallegations are inconsistent with EO 64. \n60. \nDeny the allegations in paragraph 57 of the verified petition insofar as such \nallegations tend to characterize the authority that the Governor granted to the AG as articulated in \nEO 64, respectfully refer the Court to the copy of EO 64, which is appended to the accompanying \naffirmation of Kaitlin Vigars as Exhibit A, as the best evidence and most accurate version of its \ncontents, deny the allegations in paragraph 57 of the verified petition to the extent that such \nallegations are inconsistent with EO 64, and deny that the that the challenged action was in any \nway contrary to constitutional, statutory, regulatory or case law, and deny any wrongdoing \nwhatsoever.  \n61. \nDeny the allegations in paragraph 58 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, and deny that Petitioner is entitled to the relief requested or any relief \nwhatsoever. \n62. \nDeny the allegations in paragraph 59 of the verified petition to the extent that such \nallegations are inconsistent with the statute and case law cited, respectfully refer the court to the \nstatute and case law cited as the best evidence and most accurate version of their contents, and \notherwise deny the allegations in paragraph 59 of the verified petition, deny that the challenged \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n13 of 20\n\n--- Page 14 ---\n14 \naction was in any way contrary to constitutional, statutory, regulatory or case law, and deny any \nwrongdoing whatsoever. \n63. \nDeny the allegations in the paragraph enumerated as \u201cIV\u201d on page 12 of the verified \npetition, deny that the challenged action was in any way contrary to constitutional, statutory, \nregulatory or case law, deny any wrongdoing whatsoever, deny that Petitioner is entitled to the \nrelief requested or any relief whatsoever, and respectfully refer all questions of law to the Court. \n64. \nDeny the allegations in paragraph 60 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, deny that Petitioner is entitled to the relief requested or any relief \nwhatsoever, and respectfully refer all questions of law to the Court. \n65. \nDeny the allegations in paragraph 61 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, and deny that Petitioner is entitled to the relief requested or any relief \nwhatsoever. \n66. \nDeny the allegations in paragraph 62 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, and deny that Petitioner is entitled to the relief requested or any relief \nwhatsoever. \n67. \nDeny the allegations in paragraph 63 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, and deny that Petitioner is entitled to the relief requested or any relief \nwhatsoever. \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n14 of 20\n\n--- Page 15 ---\n15 \n68. \nDeny the allegations in the paragraph enumerated as \u201cV\u201d on page 13 of the verified \npetition to the extent that it is alleged that Petitioner has suffered harm, deny that the challenged \naction was in any way contrary to constitutional, statutory, regulatory or case law, and deny any \nwrongdoing whatsoever. \n69. \nAdmit the allegations in paragraph 64 insofar as such allegations allege or tend to \nallege that Petitioner\u2019s conduct may fall within the scope of the investigation authorized by EO \n64, respectfully refer the Court to the copy of EO 64, which is appended to the accompanying \naffirmation of Kaitlin Vigars as Exhibit A, as the best evidence and most accurate version of its \ncontents, and deny the allegations in paragraph 64 of the verified petition to the extent that such \nallegations are inconsistent with EO 64. \n70. \nAdmit the allegations in paragraph 65 of the verified petition. \n71. \nDeny the allegations in paragraph 66 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever. \n72. \nDeny the allegations in paragraph 67 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, and deny that Petitioner is entitled to the relief requested or any relief \nwhatsoever. \n73. \nDeny the allegations in paragraph 68 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, and deny that Petitioner is entitled to the relief requested or any relief \nwhatsoever. \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n15 of 20\n\n--- Page 16 ---\n16 \n74. \nDeny the allegations in paragraph 69 of the verified petition and respectfully refer \nto their answers to paragraphs 1 through 68 of the verified petition above. \n75. \nDeny the allegations in paragraph 70 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, and respectfully refer all questions of law to the Court. \n76. \nDeny the allegations in paragraph 71 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, and respectfully refer all questions of law to the Court. \n77. \nAdmit the allegations in paragraph 72 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever. \n78. \nAdmit the allegations in paragraph 73 of the verified petition insofar as such \nallegations allege or tend to allege that Petitioner\u2019s conduct may fall within the scope of the \ninvestigation authorized by EO 64, respectfully refer the Court to the copy of EO 64, which is \nappended to the accompanying affirmation of Kaitlin Vigars as Exhibit A, as the best evidence \nand most accurate version of its contents, and deny the allegations in paragraph 73 of the verified \npetition to the extent that such allegations are inconsistent with EO 64. \n79. \nDeny the allegations in paragraph 74 of the verified petition. \n80. \nDeny the allegations in paragraph 75 of the verified petition insofar as such \nallegations tend to characterize the authority that the Governor granted to the AG as articulated in \nEO 64, respectfully refer the Court to the copy of EO 64, which is appended to the accompanying \naffirmation of Kaitlin Vigars as Exhibit A, as the best evidence and most accurate version of its \ncontents, deny the allegations in paragraph 75 of the verified petition to the extent that such \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n16 of 20\n\n--- Page 17 ---\n17 \nallegations are inconsistent with EO 64, and deny that the that the challenged action was in any \nway contrary to constitutional, statutory, regulatory or case law, and deny any wrongdoing \nwhatsoever. \n81. \nDeny the allegations in paragraph 76 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever. \n82. \nDeny the allegations in paragraph 77 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever. \n83. \nDeny the allegations in paragraph 78 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever. \n84. \nDeny the allegations in paragraph 79 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, and \ndeny any wrongdoing whatsoever. \n85. \nDeny the allegations in paragraph 80 of the verified petition, deny that the \nchallenged action was in any way contrary to constitutional, statutory, regulatory or case law, deny \nany wrongdoing whatsoever, and deny that Petitioner is entitled to the relief requested or any relief \nwhatsoever. \n86. \nDeny knowledge or information sufficient to form a belief as to the truth of the \nallegations in paragraph 81 of the verified petition. \n87. \nDeny the allegations in the WHEREFORE clause, deny that Petitioner is entitled to \nthe relief requested, and deny that Petitioner is entitled to any relief whatsoever. \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n17 of 20\n\n--- Page 18 ---\n18 \n88. \nDeny each and every allegation of the verified petition not specifically responded \nto above.  \nOBJECTIONS IN POINT OF LAW \n89. \nPetitioner\u2019s claims raised in this proceeding are not justiciable.  CPLR 3211(a)(2), \nand (7). \n90. \nPetitioner lacks standing.  CPLR 3211(a)(2), and (7). \n91. \nPetitioner\u2019s claims raised in this proceeding raise a political question not suitable \nfor judicial review.  CPLR 3211(a)(2), and (7). \n92. \nPetitioner\u2019s claims raised in this proceeding are not ripe for judicial review.  CPLR \n3211(a)(2), and (7). \n93. \nThe verified petition fails to state a cause of action.  CPLR 3211(a)(7). \n94. \nThe actions challenged in this proceeding are not subject to judicial review as \narbitrary and capricious or an abuse of discretion.  CPLR 3211(a)(7). \nRECORD BEFORE THE AGENCY BELOW \n95. \nThe documents annexed to the Affirmation of Kaitlin Vigars, dated October 22, \n2026, as Exhibit A constitute the record before the administrative agency in this proceeding: \na. \nExecutive Order No. 64. \n96. \n Also submitted herewith is the following: \na. \nAffirmation of Kaitlin Vigars, dated October 22, 2026, with Exhibit A as \ndetailed in paragraph 95 above. \nWHEREFORE, Respondents respectfully request that the relief requested in the verified \npetition be denied, that the petition and this action be dismissed, and that Respondents be awarded \ncosts and disbursements or, in the event the Court grants the verified petition, that the Court remand \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n18 of 20\n\n--- Page 19 ---\nPrinted [Reproduced] on Recycled Paper \n \n19 \nthe matter for a rehearing at which the technical matters complained of by the petitioner may be \nremedied, together with such other relief as may be right and just. \nDated: Albany, New York \n \nOctober 22, 2026 \nLETITIA JAMES \nAttorney General of the State of New York \nAttorney for Respondents Kathy Hochul, \nGovernor of the State of New York, and \nLetitia James, Attorney General of the State \nof New York \nThe Capitol \nAlbany, New York  12224 \n \nBy: \n/s/ Kaitlin Vigars \nKaitlin Vigars \nAssistant Attorney General, of Counsel \nTelephone:  (518) 776-2036 \nFax: (518) 915-7738 (Not for service of papers) \n \n \nTO: \nAll counsel of record (via NYSCEF) \n \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n19 of 20\n\n--- Page 20 ---\nPrinted [Reproduced] on Recycled Paper \n \n \nVerification \n \n \n \nKaitlin Vigars, being a duly licensed attorney in the State of New York and an Assistant \nAttorney General of counsel in this matter to Letitia James, Attorney General of the State of New \nYork, affirms the following: \n \nI have been assigned to defend the within proceeding and I am acquainted therewith, and \nI have personally examined the exhibits annexed to the foregoing answer and records of \nRespondents provided herein. \n \nI have read the foregoing answer.  The same is true to my knowledge, except as to those \nmatters alleged on information and belief, and as to those matters, I believe them to be true. \n \nThis verification is made by me, pursuant to CPLR Section 3020(d)(2), because  \nRespondents are officers of the State of New York, and I am acquainted with the facts of this \nproceeding. \n \nI affirm this 22nd day of October, 2026, under the penalties of perjury under the laws of New \nYork, which may include a fine or imprisonment, that the foregoing is true, and I understand that \nthis document may be filed in an action or proceeding in a court of law.   \n \n \n/s/ Kaitlin Vigars \n  Kaitlin Vigars \nFILED: ALBANY COUNTY CLERK 10/22/2026 05:24 PM\nINDEX NO. 911974-26\nNYSCEF DOC. NO. 18\nRECEIVED NYSCEF: 10/22/2026\n20 of 20","thumbnailUrl":"https://lucycraig.blog/media/592/thumb.webp","transcriptStatus":"not_applicable","transcriptText":"","url":"https://lucycraig.blog/media/592"}