Latest / The Epstein Chronicles / Jane Doe And Her Allegations Against The Cornell 7 (Part 1) (10/7/26)

Transcript

Jane Doe And Her Allegations Against The Cornell 7 (Part 1) (10/7/26) · The Epstein Chronicles

• 0:00
  Speaker 1: What's up everyone and welcome back to the program. So
• 0:04
  Speaker 1: over the past few days, there's been a case that
• 0:07
  Speaker 1: has been brought to our attention where on the surface,
• 0:11
  Speaker 1: it appears to be just absolutely horrendous. However, one thing
• 0:15
  Speaker 1: that I will caution is that it's very early on
• 0:19
  Speaker 1: and we don't have all the facts. So I'm not
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  Speaker 1: going to sit here and fire off a bunch of
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  Speaker 1: opinions about what allegedly happened when it comes to the
• 0:27
  Speaker 1: Cornell 7. Instead, what we're going to do, at least
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  Speaker 1: to get things started, is we're going to dive right
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  Speaker 1: into the complaint itself. And we're going to read it
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  Speaker 1: line by line. And then we're going to continue taking
• 0:39
  Speaker 1: a look at whatever court documents become available. And we'll
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  Speaker 1: follow the evidence wherever it leads us. But I think
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  Speaker 1: there's a lot of people out there that are just
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  Speaker 1: firing from the hip without having all of the information
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  Speaker 1: that's needed. So... Let's just do away with all the bullshit,
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  Speaker 1: and let's dive right into this complaint that was filed
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  Speaker 1: by Jane Doe, and let's see what Jane Doe has
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  Speaker 1: to say. Case number 161704. Jane Doe, plaintiff. Against Cornell University, Inc.,
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  Speaker 1: Chi Phi Chapter House Association, Chi Phi Fraternity, Inc., Chi
• 1:20
  Speaker 1: Phi Education Trust, Alpha Beta University, House Corporation, or Delta
• 1:25
  Speaker 1: Delta Delta, Delta Delta Delta Sorority, Zerreen Enterprise LLC, DBA
• 1:30
  Speaker 1: Mooney's Bar and Nightclub, Matthew Ingalls, Jonathan Newell, Winston Lee,
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  Speaker 1: Jilio Lopez, Diego, Sarabia, Scott Norris, Scott Kretschmar, John Doe Faculty,
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  Speaker 1: John Doe Alumni, John Doe Executive Board, and Orazio Petito.
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  Speaker 1: Nature of the Action This complaint is based... on the negligent, willful,
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  Speaker 1: or intentional failure of the defendants Cornell University Incorporated and
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  Speaker 1: other defendants, their employees, agents, and or servants to protect
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  Speaker 1: Plaintiff Jane Doe from being sexually assaulted and raped by
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  Speaker 1: multiple members of the Z Chapter of Chi Phi Fraternity
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  Speaker 1: at Cornell University while at the Chi Phi Fraternity House
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  Speaker 1: on Cornell University's campus, as well against those individuals, defendants
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  Speaker 1: Matthew Ingalls, Jonathan Newell, Winston Lee, Julio Lopez, Diego Sarabia,
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  Speaker 1: Scott Norris, and Scott Kretschmar, who perpetrated such heinous criminal
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  Speaker 1: sexual acts against plaintiff therein. This complaint also contains allegations
• 2:33
  Speaker 1: against defendant Cornell University Incorporated for breach of contract. This
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  Speaker 1: complaint also contains allegations against defendants Alpha Beta House, Corporation
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  Speaker 1: of Delta Delta Delta, and Delta Delta Delta Sorority for
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  Speaker 1: breach of contract. This complaint also contains allegations against defendant
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  Speaker 1: Cornell University for violations of New York State Human Rights Law.
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  Speaker 1: Executive Chapter 18, Article 15, Section 296. This complaint also
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  Speaker 1: contains allegations against defendant Cornell University for violations of New
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  Speaker 1: York Education Law, Section 6440. This complaint also contains allegations...
• 3:11
  Speaker 1: against defendant Matthew Ingalls, Jonathan Newell, Winston Lee, Julio Lopez,
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  Speaker 1: Diego Sarabia, Scott Norris, and Scott Kretschmar, and each of
• 3:22
  Speaker 1: them for their sexual assault and rape of plaintiff, pursuant
• 3:25
  Speaker 1: to the protections afforded by CPLR 213C. This complaint also
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  Speaker 1: contains allegations against defendant Zerreen Enterprise LLC, DBA Mooney's Bar
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  Speaker 1: and Nightclub, their employees, agents, and or servants, for causes
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  Speaker 1: of action pursuant to New York Dram Shop Act, General
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  Speaker 1: Obligations Law, Section 11-100, 11-101, as well as others, under
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  Speaker 1: the theory of negligence. Parties. All relevant times Plaintiff Jane Doe,
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  Speaker 1: here in Doe, was a 20-year-old adult female. At all
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  Speaker 1: relevant times, defendant Cornell University was and is a private
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  Speaker 1: institution of higher education with address in New York City
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  Speaker 1: and Ithaca, New York. That at all relevant times, Cornell maintained, operated,
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  Speaker 1: and controlled the private Ivy League University, known as Cornell University,
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  Speaker 1: in Ithaca, New York. That at all relevant times, Plaintiff
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  Speaker 1: was a full-time undergraduate student attending Cornell's Cornell University, located
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  Speaker 1: in Ithaca, New York. That at all relevant times, Plaintiff
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  Speaker 1: resided on Cornell's campus. That at all relevant times, Cornell
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  Speaker 1: maintained a private police department, known as Cornell University Police.
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  Speaker 1: with its primary office located at 117 Statler Drive, Ithaca,
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  Speaker 1: New York. That at all relevant times, Cornell maintained a
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  Speaker 1: division of public safety with its primary office located in Ithaca,
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  Speaker 1: New York. That at all relevant times, Cornell maintained the
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  Speaker 1: share office within the Skorton Center for health initiatives. That
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  Speaker 1: at all relevant times, Cornell held itself out of the
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  Speaker 1: public and more particularly to plaintiff herein as possessing the
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  Speaker 1: proper degree of safety measure to adequately protect its students
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  Speaker 1: and to use reasonable care and diligence in its monitoring
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  Speaker 1: and policing of campus and those utilizing said campus. That
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  Speaker 1: at all relevant times, while plaintiff was attending, lawfully located
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  Speaker 1: on Cornell's campus, of which Cornell had and has complete control,
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  Speaker 1: she was sexually assaulted and raped by fellow Cornell University
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  Speaker 1: students at the frat house known as Chi Phi, fraternity
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  Speaker 1: located in Ithaca, New York. That at all relevant times, Cornell...
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  Speaker 1: managed operated and or controlled the subject chi phi fraternity
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  Speaker 1: house and it was situated on cornell's property that at
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  Speaker 1: all relevant times chi phi chapter house association was and
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  Speaker 1: is a chapter of the international men's fraternity known as
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  Speaker 1: chi phi fraternity which is managed owned or controlled by
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  Speaker 1: defendants chi phi fraternity and chi phi educational trust that
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  Speaker 1: at all relevant times z chapter executive offices are located
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  Speaker 1: in hoboken At all relevant times, Z Chapter was and
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  Speaker 1: is a domestic not-for-profit corporation duly organized and existing under
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  Speaker 1: New York law. That at all times, the chapter owned, managed, operated,
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  Speaker 1: and or controlled the chapter of Chi Phi at Cornell
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  Speaker 1: University House located at 107 Edgemore. That at all relevant times,
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  Speaker 1: the chapter maintained and controlled a regional chapter of its
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  Speaker 1: parent organization of Chi Phi Fraternity at Cornell University. that
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  Speaker 1: at all relevant times the chapter maintained and controlled a
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  Speaker 1: residential house on Cornell University campus on the chapter's use
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  Speaker 1: located in New York, that at all relevant times the
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  Speaker 1: chapter held itself out of public, and more particularly to
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  Speaker 1: plaintiff herein. as possessing the proper degree of safety measure
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  Speaker 1: to adequately protect its invitees and her guests, and to
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  Speaker 1: use reasonable care and diligence in its monitoring and policing
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  Speaker 1: of the chapter's house and those living in and utilizing
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  Speaker 1: said house, that at all relevant times while plaintiff was
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  Speaker 1: lawfully within the house of which the chapter had and
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  Speaker 1: has complete control, she was plied with alcohol and drugs
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  Speaker 1: to the point of intoxication by members of the chapter's
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  Speaker 1: fraternal organization. which resulted in plaintiff being sexually assaulted and
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  Speaker 1: raped by members of the chapter's regional fraternal organization at
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  Speaker 1: Cornell University, operating out of the fraternity house known as
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  Speaker 1: Chi Phi. That at all relevant times, Chi Phi Fraternity
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  Speaker 1: was and is a domestic business corporation duly organized and
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  Speaker 1: existing under Georgia law with its principal place of business
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  Speaker 1: in Roswell, Georgia. That at all relevant times, the Chi
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  Speaker 1: Phi Fraternity was owned, managed, operated, and or controlled by
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  Speaker 1: the chapter, a regional chapter of its fraternal organization operating
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  Speaker 1: out of the chapter of Chi Phi at Cornell University
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  Speaker 1: in New York. That at all relevant times, Chi Phi
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  Speaker 1: Educational Trust was and is a domestic, not-for-profit, corporation duly
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  Speaker 1: organized and existing under Georgia law with its principal place
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  Speaker 1: of business in Roswell, Georgia. That at all relevant times, Chi...
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  Speaker 1: Phi Educational Trust owned, managed, and operated by the chapter,
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  Speaker 1: a regional chapter of its fraternal organization operating out of
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  Speaker 1: Cornell University. That at all relevant times, Chi Phi Fraternity
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  Speaker 1: and Educational Trust operate jointly as one business entity known
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  Speaker 1: as Chi Phi Fraternity, hereinafter jointly referred to as Chi
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  Speaker 1: Phi National. That at all relevant times, Chi Phi National
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  Speaker 1: maintained and controlled a regional chapter of its parental organization
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  Speaker 1: known as the Chapter of Chi Phi Fraternity at Cornell University.
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  Speaker 1: That at all relevant times, Chi Phi National maintained and
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  Speaker 1: controlled a residential house on Cornell University's campus. To all
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  Speaker 1: relevant times, Chi Phi National held itself out of the public,
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  Speaker 1: and more particularly, to plaintiff herein, as possessing the proper
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  Speaker 1: degree of safety, measure to adequately protect its invitees and
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  Speaker 1: or guests, and to use reasonable care and diligence in
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  Speaker 1: its monitoring and policing of the Chapter's house. that at
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  Speaker 1: all relevant times, while plaintiff was lawfully within the National House,
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  Speaker 1: of which Chi Phi National had complete control, she was
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  Speaker 1: plied with alcohol and drugs to the point of intoxication
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  Speaker 1: by members of the fraternal organization, which resulted in plaintiff
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  Speaker 1: being sexually assaulted and raped by members of the fraternal
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  Speaker 1: organization at Cornell University, that at all relevant times, Alpha
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  Speaker 1: Beta House Corporation of Delta Delta Delta was and is
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  Speaker 1: a chapter of the International Women's Fraternal Organization, aka sorority,
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  Speaker 1: known as Delta Delta Delta, which is managed, owned, and
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  Speaker 1: controlled by defendant Delta Delta Delta sorority. That it all times,
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  Speaker 1: Alpha Beta Chapter was and is a domestic not-for-profit corporation
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  Speaker 1: duly organized and existing under New York law with its
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  Speaker 1: principal place of business in New York. That at all
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  Speaker 1: relevant times, Alpha Beta Chapter owned and operated the Alpha
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  Speaker 1: Beta Chapter of Tri-Delta at Cornell University House, located in
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  Speaker 1: New York. That at all relevant times, Alpha Beta Chapter
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  Speaker 1: maintained and controlled the regional chapter of Tri-Delta's fraternal organization.
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  Speaker 1: At all relevant times, Plaintiff was a member of Alphabet's
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  Speaker 1: chapter regional sorority chapter at Cornell University. All relevant times,
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  Speaker 1: Plaintiff resided in Alpha Beta Chapter's house at Cornell University campus.
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  Speaker 1: That at all relevant times, Alpha Beta Chapter held itself
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  Speaker 1: out to the public and more particularly to plaintiff herein,
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  Speaker 1: as possessing the proper degree of safety measure to adequately
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  Speaker 1: protect its members and to use reasonable care and diligence
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  Speaker 1: in its monitoring and policing of the Alpha Beta Chapter's
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  Speaker 1: house and those living in and utilizing the house. All
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  Speaker 1: relevant times, while plaintiff was a member of Alpha Beta
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  Speaker 1: Chapter and while plaintiff was residing in Alpha Beta Chapter house,
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  Speaker 1: of which Alpha Beta Chapter had and has complete control.
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  Speaker 1: plaintiff became intoxicated and the house mother employed by Alpha
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  Speaker 1: Beta Chapter observed plaintiff in the intoxicated state and nevertheless
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  Speaker 1: took plaintiff to Mooney's in downtown Ithaca, which resulted in
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  Speaker 1: plaintiff being sexually assaulted and raped by fellow Cornell University
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  Speaker 1: students at the fraternity house known as Chi Phi Fraternity
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  Speaker 1: located in New York. That at all times, Tri-Delta National
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  Speaker 1: was and is a domestic business corporation duly organized and
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  Speaker 1: existing under Texas law. with its principal place of business
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  Speaker 1: in Texas. That at all relevant times, Tri-Delta National owned
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  Speaker 1: and operated the Alpha Beta chapter of Tri-Delta at Cornell University.
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  Speaker 1: That at all relevant times, Tri-Delta National maintained and controlled
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  Speaker 1: the regional chapter of Tri-Delta's fraternal organization known as the
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  Speaker 1: Alpha Beta chapter of Tri-Delta at Cornell University. That at
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  Speaker 1: all times, Tri-Delta National maintained and controlled a residential house
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  Speaker 1: on Cornell University's campus. for the Alpha Beta Chapter's house.
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  Speaker 1: That at all relevant times, Plaintiff was a member of
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  Speaker 1: Tri-Delta's National Alpha Beta Chapter at Cornell University. That at
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  Speaker 1: all relevant times, Plaintiff resided in Tri-Delta National Alpha Beta
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  Speaker 1: Chapter's house on Cornell University's campus, located at 118 Trip
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  Speaker 1: Hammer Road, Ithaca, New York. That at all relevant times,
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  Speaker 1: Tri-Delta National held itself out to the public and more
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  Speaker 1: particularly to a plaintiff herein as possessing the proper degree
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  Speaker 1: of safety measure to adequately protect its members and to
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  Speaker 1: use reasonable care and diligence in its monitoring and policing
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  Speaker 1: of the Alpha Beta Chapter's house and those living and
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  Speaker 1: utilizing said house. That at all relevant times, while plaintiff
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  Speaker 1: was a member of the Tri-Delta National, Alpha Beta Chapter,
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  Speaker 1: and while Plaintiff was residing in Tri-Delta National's Alpha Beta
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  Speaker 1: Chapter house, of which Tri-Delta National had and has complete control,
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  Speaker 1: Plaintiff had become intoxicated, and the house mother employed by
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  Speaker 1: Tri-Delta National observed Plaintiff in that intoxicated state, and nevertheless
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  Speaker 1: took Plaintiff to Mooney's in downtown Ithaca, which resulted in
• 13:23
  Speaker 1: Plaintiff being sexually assaulted and raped by fellow Cornell University
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  Speaker 1: students at the fraternity house known as Chi Phi Fraternity.
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  Speaker 1: that at all times relevant John Doe faculty was and
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  Speaker 1: is the designated faculty advisor appointed by Cornell as the
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  Speaker 1: official liaison between the chapter and Cornell University, that at
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  Speaker 1: all relevant times faculty as faculty advisor was and is
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  Speaker 1: assigned by Cornell to oversee the chapter to Cornell University
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  Speaker 1: Regional Chapter and its international fraternal organization, that at all
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  Speaker 1: relevant times faculty as faculty advisor, was and is a
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  Speaker 1: university employee employed directly by Cornell as a professor, lecturer, administrator,
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  Speaker 1: and or faculty member. That at all relevant times, Cornell
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  Speaker 1: was and is vicariously liable under Respondent Superior for the
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  Speaker 1: negligent acts and omission of faculty. That at all relevant times,
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  Speaker 1: faculty advisor was responsible for supervising and maintaining in a
• 14:24
  Speaker 1: safe condition the chapter's fraternity house and its members' threat.
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  Speaker 1: located 118 in New York. That at all relevant times, faculty,
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  Speaker 1: his faculty advisor, held himself out of the public, and
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  Speaker 1: more particularly to plaintiff herein, as possessing the proper degree
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  Speaker 1: of knowledge and training to adequately protect Cornell students, including
• 14:46
  Speaker 1: plaintiff herein, and to use reasonable care and diligence monitoring
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  Speaker 1: and policing the chapter's fraternity house and those members living
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  Speaker 1: and utilizing said house. That at all relevant times, while
• 14:58
  Speaker 1: plaintiff was lawfully within the chapter's house, of which faculty
• 15:01
  Speaker 1: as faculty advisor breached their duty to supervise and maintain
• 15:05
  Speaker 1: the chapter's fraternity house in a safe condition, as plaintiff
• 15:08
  Speaker 1: was plied with alcohol and drugs to the point of
• 15:11
  Speaker 1: intoxication by members of the chapter's fraternal organization, which resulted
• 15:16
  Speaker 1: in plaintiff being sexually assaulted and raped by members of
• 15:19
  Speaker 1: the chapter. That at all relevant times, John Doe, alumni
• 15:23
  Speaker 1: here and after alumni, was in his designated alumni advisor
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  Speaker 1: appointed by Chi Phi National as the official liaison between
• 15:31
  Speaker 1: the chapter and the national. That at all relevant times, alumni,
• 15:35
  Speaker 1: as alumni advisor, was and is assigned by the national
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  Speaker 1: to oversee the chapter, the Cornell University regional chapter, international
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  Speaker 1: fraternal organization. That at all relevant times, exec was and
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  Speaker 1: is comprised of officers with titles such as president, vice president, treasurer, secretary,
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  Speaker 1: risk manager, recruitment chair, social chair, among other executive titles.
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  Speaker 1: That at all relevant times, Exec was and is subject
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  Speaker 1: to Chi Phi's national constitution and bylaws, as well as
• 16:04
  Speaker 1: the chapter's regional constitution and bylaws. That at all relevant times,
• 16:09
  Speaker 1: Exec was and is subject to Cornell's constitution bylaws, code
• 16:13
  Speaker 1: of conduct, and student organizational rules and regulations. That at
• 16:17
  Speaker 1: all relevant times, Exec was responsible for supervising and maintaining
• 16:21
  Speaker 1: in a safe condition the chapter's fraternity house and its
• 16:25
  Speaker 1: members thereat. that at all relevant times the exec held
• 16:29
  Speaker 1: himself out to the public, and more particularly the plaintiff herein,
• 16:33
  Speaker 1: as possessing the proper degree of knowledge and training to
• 16:36
  Speaker 1: adequately protect Cornell students, including plaintiff herein, and to use
• 16:40
  Speaker 1: reasonable care and diligence in its monitoring and policing of
• 16:44
  Speaker 1: the chapter's fraternity house and those fraternity members living in
• 16:47
  Speaker 1: and utilizing said house, that at all relevant times, while
• 16:52
  Speaker 1: plaintiff was lawfully within the chapter's house, of which exec
• 16:56
  Speaker 1: breached their duty to supervise and maintain Fraternity House in
• 16:59
  Speaker 1: a safe condition as plaintiff was plied with alcohol and
• 17:02
  Speaker 1: drugs to the point of intoxication by members of the
• 17:05
  Speaker 1: chapter's fraternal organization, which resulted in plaintiff being sexually assaulted
• 17:10
  Speaker 1: and raped by members of the chapter's regional fraternal organization
• 17:15
  Speaker 1: at Cornell University, operating out of the fraternity house known
• 17:18
  Speaker 1: as Chi Phi Fraternity. All right, we're going to wrap
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  Speaker 1: up the first episode here And in the next episode,
• 17:24
  Speaker 1: we're going to pick up where we left off. All
• 17:26
  Speaker 1: the information that goes with this episode can be found
• 17:29
  Speaker 1: in the description box.