{"@context":"https://schema.org","@type":"DigitalDocument","altText":"Comment attachment by Anonymous","alternateName":"4_-_AFFIRMATION_Plaintiffs_Affirmation_Redacted.pdf","caption":"","contentUrl":"https://lucycraig.blog/media/579/raw","datePublished":"2026-10-21T23:31:02+00:00","description":"","encodingFormat":"application/pdf","identifier":"579","isAccessibleForFree":true,"machineReadable":{"json":"https://lucycraig.blog/media/579/index.json","markdown":"https://lucycraig.blog/media/579/index.md"},"name":"Comment attachment by Anonymous","ocrStatus":"ready","ocrText":"--- Page 1 ---\nCAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED\nNYSCEF DOC. NO. 4 RECEIVED NYSCEF: 09/16/2026\n\nSUPREME COURT OF THE STATE OF NEW YORK\nCOUNTY OF NEW YORK\nJANE DOE,\n\nIndex No.:\n\nPlaintiff,\n-against- PLAINTIFF\u2019S AFFIRMATION\nCORNELL UNIVERSITY, INC., CHI PHI CHAPTER\nHOUSE ASSOCIATION, CHI PHI FRATERNITY, INC.,\nCHI PHI EDUCATIONAL TRUST, ALPHA BETA\nHOUSE CORPORATION OF DELTA DELTA DELTA,\nDELTA DELTA DELTA SORORITY, ZAREEN\nENTERPRISE LLC d/b/a MOONIES BAR &\nNIGHTCLUB, MATTHEW INGALLS, JOHNATHAN\nNEWELL, WINSTON LEE, GILLIO LOPES, DIEGO\nSARABIA, SCOTT NORRIS, SCOTT KRETZSCHMAR,\nJOHN DOE (FACULTY), JOHN DOE (ALUMNI), JOHN\nDOES (EXECUTIVE BOARD), and ORAZIO PETITO,\n\nDefendant.\n\nPlaintiff {gas JANE DOE, being duly swom, affirms the contents of the\nfollowing to be true under penalty of perjury:\n\n1. I am the Plaintiff JANE DOE in this action. I am a victim of sexual abuse, sexual\nassault, and rape.\n\n2. I submit this Affirmation in support of Plaintiff\u2019s Order to Show Cause to Proceed via\nPseudonym pursuant to Civil Rights Law 50-b and other supporting authority and case law. I\nrespectfully request that I be permitted to proceed anonymously using the pseudonym in the\nabove-captioned matter and in all publicly filed documents, as well as to enjoin the Defendants\nand their agents from disclosing my name and/or identity to anyone other than their attorneys.\n\n3. I am seeking to proceed anonymously because I was drugged, sexually assault, and\nraped by Defendant MATTHEW INGALLS, JOHNATHAN NEWELL, WINSTON LEE,\nGILLIO LOPES, DIEGO SARABIA, SCOTT NORRIS, and SCOTT KRETZSCHMAR, in\nOctober 2024 within the Xi Chapter of Chi Phi Fraternity\u2019s house located on Cornell University\u2019s\ncampus.\n\n4. 1 am seeking compensation from the individual defendants for the heinous sexual abuse\nI suffered, as well as against the institutional defendants for allowing, enabling, encouraging,\naiding, and abetting said abuses to occur.\n\n5. I am seeking to shield my identity from the stigma associated with the sexual assault\nand rape that I suffered. I strongly believe that proceeding in this matter henceforth via a\npseudonym is in my best interests.\n\n6. The risk of exposing my identity is particularly acute here as I was raped by multiple\ndefendants while attending Cornell University as a full-time undergraduate student. I have since\nstopped attending Cornell University because of the subject incident.\n\n7. What happened to me was devastating and humiliating. I fear that such details of the\nsubject assaults being made public would bring further shame to not only myself, but to my\nfamily as well.\n\n8. I fear that being identified by name in this lawsuit will hinder my social life and career.\nExposing my identity will negatively affect my relationships, as these people will view me\ndifferently after discovering such personal information about me through a public filing.\nAttaching my name to this lawsuit may permanently tarnish my reputation, one that I have\n\nThis is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR \u00a7202.5-b(d) (3) (i))\nwhich, at the time of its printout from the court system's electronic website, had not yet been reviewed and\n\napproved by the County Clerk. Because court rules (22 NYCRR \u00a7202.5[d]) authorize the County Clerk to reject\n\nfilings for various reasons, readers should be aware that documents bearing this legend may not have been 1 of 2\naccepted for filing by the County Clerk.\n\n\n--- Page 2 ---\nCAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED\nNYSCEF DOC. NO. 4 RECEIVED NYSCEF: 09/16/2026\nworked so hard to rebuild.\n\n9. I truly fear retribution and retaliation resulting from filing this lawsuit. Defendants have\nno regard for my health or safety. My assailants threatened my safety and wellbeing on numerous\noccasions, especially in plying me with copious amounts of drugs without any regard for the\nconsequences.\n\n10. Not only am I seeking to proceed anonymously as \u201cJANE DOE\u201d, but I am also kindly\nrequesting a partial Attorneys\u2019 Eyes Only (AEO) designation as to my sensitive personal\ninformation including my date of birth, SSN, residential address, phone number, and email\naddress.\n\n11. The worry of my identity being revealed in this lawsuit has caused me extreme\nanxiety, depression, and many sleepless nights.\n\n12. I do not believe that Defendants will be negatively affected and/or prejudiced by\nallowing me to use a pseudonym in legal proceedings or by granting any of the requested relief.\nDefendants and their attorneys will be made aware of my true identity upon the filing of this\nlawsuit.\n\n13. I believe that proceeding anonymously is within my best interests and will allow me to\nremain safe and maintain a sound sense of mind.\n\nI affirm this 14. day of Septem bor 2026, under the penalties of perjury under the law\n\nof New York which may include a fine or imprisonment, that the foregoing is true, and I\n\nunderstand that this document may be filed in an action or proceeding in a court of law.\n\nDated: Now ( fcr , New York\n\nSeplember /4 , 2026\nBy:\nas E DOE\n\n2\nThis is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR \u00a7202.5-b(d) (3) (i))\nwhich, at the time of its printout from the court system's electronic website, had not yet been reviewed and\napproved by the County Clerk. Because court rules (22 NYCRR \u00a7202.5[d]) authorize the County Clerk to reject\nfilings for various reasons, readers should be aware that documents bearing this legend may not have been 2 of 2\naccepted for filing by the County Clerk.\n","text":"--- Page 1 ---\nCAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED\nNYSCEF DOC. NO. 4 RECEIVED NYSCEF: 09/16/2026\n\nSUPREME COURT OF THE STATE OF NEW YORK\nCOUNTY OF NEW YORK\nJANE DOE,\n\nIndex No.:\n\nPlaintiff,\n-against- PLAINTIFF\u2019S AFFIRMATION\nCORNELL UNIVERSITY, INC., CHI PHI CHAPTER\nHOUSE ASSOCIATION, CHI PHI FRATERNITY, INC.,\nCHI PHI EDUCATIONAL TRUST, ALPHA BETA\nHOUSE CORPORATION OF DELTA DELTA DELTA,\nDELTA DELTA DELTA SORORITY, ZAREEN\nENTERPRISE LLC d/b/a MOONIES BAR &\nNIGHTCLUB, MATTHEW INGALLS, JOHNATHAN\nNEWELL, WINSTON LEE, GILLIO LOPES, DIEGO\nSARABIA, SCOTT NORRIS, SCOTT KRETZSCHMAR,\nJOHN DOE (FACULTY), JOHN DOE (ALUMNI), JOHN\nDOES (EXECUTIVE BOARD), and ORAZIO PETITO,\n\nDefendant.\n\nPlaintiff {gas JANE DOE, being duly swom, affirms the contents of the\nfollowing to be true under penalty of perjury:\n\n1. I am the Plaintiff JANE DOE in this action. I am a victim of sexual abuse, sexual\nassault, and rape.\n\n2. I submit this Affirmation in support of Plaintiff\u2019s Order to Show Cause to Proceed via\nPseudonym pursuant to Civil Rights Law 50-b and other supporting authority and case law. I\nrespectfully request that I be permitted to proceed anonymously using the pseudonym in the\nabove-captioned matter and in all publicly filed documents, as well as to enjoin the Defendants\nand their agents from disclosing my name and/or identity to anyone other than their attorneys.\n\n3. I am seeking to proceed anonymously because I was drugged, sexually assault, and\nraped by Defendant MATTHEW INGALLS, JOHNATHAN NEWELL, WINSTON LEE,\nGILLIO LOPES, DIEGO SARABIA, SCOTT NORRIS, and SCOTT KRETZSCHMAR, in\nOctober 2024 within the Xi Chapter of Chi Phi Fraternity\u2019s house located on Cornell University\u2019s\ncampus.\n\n4. 1 am seeking compensation from the individual defendants for the heinous sexual abuse\nI suffered, as well as against the institutional defendants for allowing, enabling, encouraging,\naiding, and abetting said abuses to occur.\n\n5. I am seeking to shield my identity from the stigma associated with the sexual assault\nand rape that I suffered. I strongly believe that proceeding in this matter henceforth via a\npseudonym is in my best interests.\n\n6. The risk of exposing my identity is particularly acute here as I was raped by multiple\ndefendants while attending Cornell University as a full-time undergraduate student. I have since\nstopped attending Cornell University because of the subject incident.\n\n7. What happened to me was devastating and humiliating. I fear that such details of the\nsubject assaults being made public would bring further shame to not only myself, but to my\nfamily as well.\n\n8. I fear that being identified by name in this lawsuit will hinder my social life and career.\nExposing my identity will negatively affect my relationships, as these people will view me\ndifferently after discovering such personal information about me through a public filing.\nAttaching my name to this lawsuit may permanently tarnish my reputation, one that I have\n\nThis is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR \u00a7202.5-b(d) (3) (i))\nwhich, at the time of its printout from the court system's electronic website, had not yet been reviewed and\n\napproved by the County Clerk. Because court rules (22 NYCRR \u00a7202.5[d]) authorize the County Clerk to reject\n\nfilings for various reasons, readers should be aware that documents bearing this legend may not have been 1 of 2\naccepted for filing by the County Clerk.\n\n\n--- Page 2 ---\nCAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED\nNYSCEF DOC. NO. 4 RECEIVED NYSCEF: 09/16/2026\nworked so hard to rebuild.\n\n9. I truly fear retribution and retaliation resulting from filing this lawsuit. Defendants have\nno regard for my health or safety. My assailants threatened my safety and wellbeing on numerous\noccasions, especially in plying me with copious amounts of drugs without any regard for the\nconsequences.\n\n10. Not only am I seeking to proceed anonymously as \u201cJANE DOE\u201d, but I am also kindly\nrequesting a partial Attorneys\u2019 Eyes Only (AEO) designation as to my sensitive personal\ninformation including my date of birth, SSN, residential address, phone number, and email\naddress.\n\n11. The worry of my identity being revealed in this lawsuit has caused me extreme\nanxiety, depression, and many sleepless nights.\n\n12. I do not believe that Defendants will be negatively affected and/or prejudiced by\nallowing me to use a pseudonym in legal proceedings or by granting any of the requested relief.\nDefendants and their attorneys will be made aware of my true identity upon the filing of this\nlawsuit.\n\n13. I believe that proceeding anonymously is within my best interests and will allow me to\nremain safe and maintain a sound sense of mind.\n\nI affirm this 14. day of Septem bor 2026, under the penalties of perjury under the law\n\nof New York which may include a fine or imprisonment, that the foregoing is true, and I\n\nunderstand that this document may be filed in an action or proceeding in a court of law.\n\nDated: Now ( fcr , New York\n\nSeplember /4 , 2026\nBy:\nas E DOE\n\n2\nThis is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR \u00a7202.5-b(d) (3) (i))\nwhich, at the time of its printout from the court system's electronic website, had not yet been reviewed and\napproved by the County Clerk. Because court rules (22 NYCRR \u00a7202.5[d]) authorize the County Clerk to reject\nfilings for various reasons, readers should be aware that documents bearing this legend may not have been 2 of 2\naccepted for filing by the County Clerk.\n","thumbnailUrl":"https://lucycraig.blog/media/579/thumb.webp","transcriptStatus":"not_applicable","transcriptText":"","url":"https://lucycraig.blog/media/579"}