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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
JANE DOE,
Plaintiff,
-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.
Index No: 161704/2026
AFFIRMATION OF
GILLIAN A. FISHER, ESQ. IN SUPPORT
OF MOTION FOR ADMISSION PRO
HAC VICE
I, GILLIAN A. FISHER Esq., an attorney duly admitted to practice law before the Courts
of the State of New York, affirms the following under penalties of perjury:
1.
I am Counsel at the law firm of Schenck, Price, Smith & King, LLP, attorneys for
Chi Phi Fraternity and Chi Phi Educational Trust in the above-captioned action.
2.
I submit this Affirmation seeking the admission pro hac vice of Jennifer
Coatsworth, Esq. Enclosed is a proposed order for the Court’s convenience, Exhibit C.
3.
This motion is made by Chi Phi Fraternity and Chi Phi Educational Trust, by and
through counsel Gillian A. Fisher, Esq., a member in good standing of the bar of the State of New
FILED: NEW YORK COUNTY CLERK 11/04/2026 01:28 PM
INDEX NO. 161704/2026
NYSCEF DOC. NO. 97
RECEIVED NYSCEF: 11/04/2026
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York and am admitted to practice law in the State per order of the Appellate Division, Second
Judicial Department, New York State Supreme Court, at its February 1996 Term.
4.
I am also admitted to practice law in the United States District Court for the Eastern
District of New York in 1996 and the Southern District of New York in 1996 as well.
5.
The Affidavit of Jennifer Coatsworth, Esq. is annexed as Exhibit A in support of
the attached motion.
6.
The Certificates of Good Standing issued by the States of New Jersey and
Pennsylvania for Jennifer Coatsworth, Esq. are annexed as Exhibit B.
7.
Chi Phi Fraternity and Chi Phi Educational Trust respectfully assert that there is
good cause for the admission of Jennifer Coatsworth, Esq. given that she has significant experience
with these entities and this area of law, and they have selected her to serve as their lead counsel.
8.
Applicant Jennifer Coatsworth, Esq. is not admitted to the bar of the State of New
York, but she has been admitted to the bars of New Jersey and Pennsylvania since 2003. There
are no disciplinary proceedings pending against Ms. Coatsworth in any jurisdiction.
9.
Applicant Jennifer Coatsworth, Esq. is familiar with and agrees to be bound by the
standards of professional conduct imposed upon members of the New York State Bar. She
acknowledges and agrees that she shall be subject to the jurisdiction of the courts of the State of
New York with respect to any acts occurring over the course of her participation in this case.
10.
Chi Phi Fraternity and Chi Phi Educational Trust respectfully request that this
motion be granted so that Jennifer Coatsworth, Esq. may attend and fully participate in all matters
on their behalf and otherwise engage in pre-trial, trial and post-trial proceedings in connection with
this action.
FILED: NEW YORK COUNTY CLERK 11/04/2026 01:28 PM
INDEX NO. 161704/2026
NYSCEF DOC. NO. 97
RECEIVED NYSCEF: 11/04/2026
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WHEREFORE, it is respectfully requested that this Court grant the within motion for pro
hac vice admission of Jennifer Coatsworth, Esq. be granted and that the Court enter an Order
granting the motion, and for such other and further relief as this Court deems just and proper.
Dated: New York, New York
November 4, 2026
Respectfully submitted,
SCHENCK, PRICE, SMITH & KING, LLP
Gillian A. Fisher, Esq.
By:
______________
_
Gillian A. Fisher, Esq.
805 Third Avenue | 10th Floor
New York, New York 10022
Attorneys for Chi Phi Fraternity and Chi Phi
Educational Trust
FILED: NEW YORK COUNTY CLERK 11/04/2026 01:28 PM
INDEX NO. 161704/2026
NYSCEF DOC. NO. 97
RECEIVED NYSCEF: 11/04/2026
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PUBLIC DISCUSSION
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