The Cornell Complaint PDF: What the 2026 Lawsuit Filing Says
People searching for the Cornell complaint PDF are usually looking for one court file: Jane Doe v. Cornell University, Inc., et al., Index No. 161704/2026, in New York State Supreme Court, New York County. The New York County Clerk stamp on the circulated copy is September 16, 2026. The summons is dated September 14, 2026. The filing runs about 101 pages and demands a jury trial.
A complaint is the plaintiff’s opening account of the case and the relief she wants. It is one side of the record. Answers, evidence, and a judge or jury come later. Nothing in this guide is a finding of liability. If you need the file itself, use the official New York courts site, NYSCEF, and search the index number. Random “free download” copies of a sexual-assault filing are a poor place to start.
If you are in crisis or want confidential support, the National Sexual Assault Hotline is available at 800-656-4673 and at rainn.org.
What is in the file#
The PDF that news outlets posted is a summons plus a complaint. The summons tells each defendant to answer, usually within 20 days after personal service in New York, or 30 days if service is completed another way.
The plaintiff is listed as Jane Doe. The complaint says she was a 20-year-old adult woman and a full-time Cornell undergraduate living on campus. Her lawyers are Rheingold Giuffra Ruffo Plotkin & Hellman LLP in New York, and Cochrun & Seals, LLC, with a pro hac vice application pending.
The caption names a long list of defendants:
- Cornell University, Inc.
- Chi Phi Chapter House Association, Chi Phi Fraternity, Inc., and Chi Phi Educational Trust
- Alpha Beta House Corporation of Delta Delta Delta and Delta Delta Delta Sorority
- Zareen Enterprise LLC, doing business as Moonies Bar & Nightclub
- Matthew Ingalls, Johnathan Newell, Winston Lee, Gillio Lopes, Diego Sarabia, Scott Norris, and Scott Kretzschmar
- John Doe (faculty), John Doe (alumni), John Does (executive board), and Orazio Petito
Venue is New York County because that is where the complaint says the plaintiff lives. Cornell’s campus in the filing is in Ithaca.
What the complaint alleges#
The “nature of the action” says the university, the Chi Phi organizations, the Delta Delta Delta organizations, and others failed to protect Jane Doe from sexual assault and rape by members of the Xi Chapter of Chi Phi. It places that alleged assault at the chapter house at 107 Edgemoor Lane in Ithaca, on Cornell property. A later count dates the alleged abuse to the night of October 19, 2024, into the morning of October 20, 2024.
The filing says she was given alcohol and drugs until she was intoxicated. It also says Moonies, at 114 East State Street in Ithaca, served her alcohol even though she had an “X” on both hands marking her as under 21, and kept serving her past the point of visible intoxication. Those sentences are allegations. A civil complaint is the plaintiff’s pleading, and a court has not adopted it as fact.
The middle of the PDF describes the alleged assault in detail. The caption, the claim headings, and the prayer tell you who sued whom and which legal theories are on the page.
The legal claims on the page#
The opening pages sort the theories this way: negligence and related failures to protect her; breach of contract against Cornell; breach of contract against the Delta Delta Delta defendants; a New York Human Rights Law claim against Cornell under Executive Law § 296; a claim against Cornell under New York Education Law § 6440; civil claims against the named students for sexual assault, with a citation to CPLR 213-c; and Dram Shop and negligence claims against the bar under General Obligations Law §§ 11-100 and 11-101.
Education Law § 6440 sits in Article 129-B, New York’s campus sexual-assault statute. It is about the policies colleges must keep for prevention, reporting, and response. The complaint treats Cornell’s duties under that law as one basis for the suit.
The labeled counts in the circulated text use the court’s own numbers. There is a gap at five:
- Negligence
- Negligent retention, supervision, and direction
- Breach of contract
- Violation of the New York State Human Rights Law
- Sexual assault
- Sexual battery
- Intentional infliction of emotional distress
- Negligent infliction of emotional distress
- Violations of New York’s Dram Shop Act
The prayer for relief still asks for judgment on ten counts, including a fifth. The introduction pleads Education Law § 6440 as its own theory, which is the claim that lines up with that gap. If your copy prints a fifth heading, quote that heading.
The contract count says Cornell’s enrollment papers, handbooks, and conduct codes promised a reasonably safe campus, and that Jane Doe paid tuition and stayed in good standing. The Human Rights Law count says she was harmed because she is a woman. The assault and battery counts name the seven students. The emotional-distress counts name those students and, on the negligent count, Cornell and the Chi Phi organizations. The Dram Shop count names Moonies.
The prayer asks for compensatory damages in an amount to be proved at trial, above the limit of the lower courts, plus punitive damages, costs, attorneys’ fees where the law allows them, and prejudgment interest. It does not put a dollar figure in the “wherefore” clause.
What Cornell has said in public#
On September 21, 2026, Vice President for University Relations Kyle Kimball posted a statement. Cornell said it knew about a lawsuit over sexual-assault allegations from 2024. It said the Office of Civil Rights and the Office of Student Conduct and Community Standards investigated and adjudicated the allegations under university policy. It said the Xi chapter of Chi Phi remains barred from campus. It said federal privacy law blocks public comment on individual student discipline, and that it would answer in detail in court. The same note points to the Presidential Task Force on Campus Sexual Assault, launched after the incident, and to that task force’s report in March 2026.
On September 28, 2026, a second statement said Cornell supports the Tompkins County District Attorney’s decision to give the complainant’s account a chance to be heard by a criminal grand jury. Cornell described a Title IX investigation, temporary suspensions, and a multi-day hearing before faculty and staff. It said the panel’s sanctions included expulsions and suspensions, and that no one charged was given essay-writing as the only consequence. It said the chapter was closed in 2024 and remains barred. It called claims of minimal punishment false.
Those sentences are the university’s account. They are a public statement, and the court in Index No. 161704/2026 has its own record. A Title IX hearing, this civil case, and any grand-jury process each follow their own rules, and they can move on different clocks.
A different PDF with a similar name#
An older file, sometimes saved as cornell-complaint.pdf, is John Doe v. Cornell University in the U.S. District Court for the Northern District of New York. That complaint, from about 2017, challenges how Cornell investigated a December 2014 report under its Policy 6.4. The plaintiff there is a male student suing over the disciplinary process. Match the caption, the court, and the year before you quote either file.
How to read a 101-page court PDF#
Start with the caption, the nature of the action, and the prayer for relief. Those pages give you the court, the parties, the date, and the remedies. Then read each “cause of action” heading. Paragraphs under a heading repeat earlier allegations and then state one legal theory.
When you download from NYSCEF, keep the index number in the file name, for example 161704-2026-jane-doe-cornell-complaint.pdf. Pull the caption and the counts with the split PDF tool. Shrink a section you need to email with compress PDF. Combine Cornell’s September statements with the task-force report, if you downloaded those yourself, with merge PDF.
- Save the clerk-stamped copy with the index number and filing time in the file name.
- Search for “cause of action” and “wherefore.”
- Read factual paragraphs as allegations until an answer or a decision says otherwise.
- Leave the graphic pages out of slides, group chats, and class handouts.
PDF Gozar does not host this complaint. Court files change when answers, motions, and orders are added. Search NYSCEF again before you rely on a copy saved from a news site.
FAQ#
Is this a criminal case?#
The PDF is a civil complaint in New York Supreme Court. Cornell’s September 28 statement says the Tompkins County District Attorney was giving the matter a path to a criminal grand jury. Civil damages and criminal charges are separate.
Have the defendants been found liable?#
As of this writing, the public record described here is the complaint and Cornell’s statements. A filed complaint does not decide fault.
Why is the plaintiff called Jane Doe?#
The caption uses Jane Doe. Courts sometimes allow that in sexual-violence cases so the plaintiff’s name stays off the public docket. The complaint still pleads facts and names the defendants.
Where should I get the PDF?#
Use NYSCEF case search and Index No. 161704/2026. For the university’s response, use the two September 2026 statements linked above. Skip unofficial reposts.
What to do next#
Read the first pages and the cause-of-action headings, then read Cornell’s September 21 and September 28 statements beside them. Save a NYSCEF copy under the index number, and split or compress only the pages you need. Check the docket again before you describe the case, because answers and orders land in later PDFs.