# Public administrative PDF — original entry #87 Source: https://lucycraig.blog/media/614 File: needs-review-f2fabf3239-161704_2026_Jane_Doe_v_Cornell_University_Inc_et_al_NOTICE_OF_MOTION_87.pdf Format: application/pdf Description: Alt text: ## OCR / extracted text --- Page 1 --- 1 SUPREME COURT STATE OF NEW YORK COUNTY OF NEW YORK JANE DOE, Petitioner, -against- CORNELL UNIVERSITY, INC., CHI PHI CHAPTER HOUSE ASSOCIATION, CHI PHI FRATERNITY, INC., CHI PHI EDUCATIONAL TRUST, ALPHA BETA HOUSE CORPORATION OF DELTA DELTA DELTA, DELTA DELTA DELTA SORORITY, ZAREEN ENTERPRISE LLC d/b/a MOONIES BAR & NIGHTCLUB, MATTHEW INGALLS, JOHNATHAN NEWELL, WINSTON LEE, GILLIO LOPES, DIEGO SARABIA, SCOTT NORRIS, SCOTT KRETZSCHMAR, JOHN DOE (FACULTY), JOHN DOE (ALUMNI), JOHN DOES (EXECUTIVE BOARD), and ORAZIO PETITO, Defendants. NOTICE OF MOTION Index No.: 161704/2026 PLEASE TAKE NOTICE that Defendant Diego Sarabia, by and through its undersigned attorneys, will move this Court for an Order granting the relief described below, at the time and place set forth below: Moving Party: Defendant Diego Sarabia. Return Date: November 16, 2026 at 9:30 a.m., at NYS Supreme Court, IAS Part 35 New York County, 60 Centre Street, Courtroom 252, New York, N.Y. 10007. Relief Sought: Dismissal, with prejudice, of Plaintiff’s Complaint, in its entirety, pursuant to CPLR 3211(a)(5) and (a)(7), together with such other relief in favor of the Defendant as the Court deems just and proper. Supporting Papers: The papers offered in support of the motion are: (i) the Attorney Affirmation of James C. Knox, dated October 23, 2026, with an Exhibit; (ii) the Memorandum of Law in Support dated October 23, 2026; and (iv) all prior papers and pleadings had herein, filed with the Court and made a part of the NYSCEF docket for this case. INDEX NO. 161704/2026 NYSCEF DOC. NO. 87 RECEIVED NYSCEF: 10/23/2026 1 of 2 --- Page 2 --- 2 PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR 2214(b), any party opposing the motion must serve its opposition papers (and any cross-motion) upon the undersigned at least seven (7) days prior to the above-listed Return Date. Defendant intends to serve and file reply papers. Dated: Albany, New York October 23, 2026 Respectfully submitted, HACKER MURPHY LLP By:_______________________________________ James C. Knox Attorneys for Defendant Diego Sarabia Office & P.O. Address 22 Corporate Woods Boulevard, Suite 404 Albany, NY 12211 Telephone: 518-274-5820 jknox@hackermurphy.com By:_______________________________________ Alishah Bhimani Attorneys for Defendant Diego Sarabia Office & P.O. Address 22 Corporate Woods Boulevard, Suite 404 Albany, NY 12211 Telephone: 518-274-5820 abhimani@hackermurphy.com INDEX NO. 161704/2026 NYSCEF DOC. NO. 87 RECEIVED NYSCEF: 10/23/2026 2 of 2 ## Transcript ## Machine-readable JSON https://lucycraig.blog/media/614/index.json