IMAGE · PUBLIC LIBRARY #344
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(FILED: NEW YORK COUNTY CLERK 10/14/2026 03:55 PM INDEX NO. 161704/2026
NYSCEF DOC. NO. 65 RECEIVED NYSCEF: 10/14/2026
Hon. Phaedra F. Perry-Bond HodgsonRuss..
October 14,2026 0 EEE RS
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interpreted to prevent Cornell from satisfying these obligations or imposing upon the institution
an obligation to restrict the speech of its various students, employees, and community members.
The exceptions set out in the proposed order are not sufficiently broad or sufficiently defined to
address these concerns. Cornell welcomes an opportunity to discuss the language of an
appropriate order either stipulated by the parties or resolved by the Court but respectfully
requests that the Order to Show Cause as currently drafted not be entered by the Court until the
limitations and exceptions are clarified to permit Cornell to fulfill its legitimate institutional and
legal obligations.
Respectfully submitted,
Patrick J. Hines
PJH
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PUBLIC DISCUSSION
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