Students for Fair Admissions, Inc. v. President and Fellows of Harvard College et al

Filing 119

MOTION to Seal Document (SFFA's Letter to Judge Burroughs) by Students for Fair Admissions, Inc..(Caldwell, Benjamin)

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS STUDENTS FOR FAIR ADMISSIONS, INC., Plaintiff, Civil Action No. 1:14-cv-14176-ADB v. PRESIDENT AND FELLOWS OF HARVARD COLLEGE (HARVARD CORPORATION), Defendant. ***The attached envelope contains a letter subject to a Protective Order of this Court and cannot be opened or its contents made available to anyone other than counsel of record for the parties or Court personnel.*** PLAINTIFF’S MOTION TO IMPOUND Pursuant to Local Rule 7.2 and this matter’s Stipulated Protective Order (Dkt. No. 55), Plaintiff, Students for Fair Admissions, Inc. (“SFFA”), hereby brings this motion to give this Honorable Court the option to impound the enclosed unredacted letter from Plaintiff’s counsel to Judge Burroughs dated January 27, 2016 (the “Letter”). The Letter contains the identity of database fields and other information which have been designated by Defendant, the President and Fellows of Harvard College (“Harvard”) as “protected material” under the Stipulated Protective Order. This motion is brought in reaction to Harvard’s designations. A redacted version of the Letter has been publicly filed in which discussion and references to the designated “protected material” that has not previously been disclosed by Harvard were redacted. WHEREFORE, SFFA respectfully submits this motion which gives the Court the option to allow the unredacted version of the Letter to be impounded and to be viewed only by the Judge, her clerk(s) and Court personnel. 1 Respectfully submitted, By: /s/ Patrick Strawbridge Patrick Strawbridge Paul M. Sanford BBO #566318 Benjamin C. Caldwell BBO #675061 BURNS & LEVINSON LLP One Citizens Plaza, Suite 1100 Providence, RI 02903 Tel: 617-345-3000 Fax: 617-345-3299 Dated: January 27, 2016 William S. Consovoy Thomas R. McCarthy Michael H. Park J. Michael Connolly CONSOVOY MCCARTHY PARK PLLC 3033 Wilson Boulevard, Suite 700 Arlington, Virginia 22201 Tel: 703-243-4923 Fax: 703.243.4923 Patrick Strawbridge BBO #678274 CONSOVOY MCCARTHY PARK PLLC Ten Post Office Square 8th Floor South PMB #706 Boston, MA 02109 Tel: 617-227-0548 Counsel for Plaintiff Students for Fair Admissions, Inc. 2 CERTIFICATE OF CONFERENCE In accordance with Local Rules 7.1(a), I hereby certify that this motion is brought in reaction to Harvard’s designation of certain database fields and other information as “protected material” under the Stipulated Protected Order. The issues presented in the Letter encompass areas of dispute which the parties have previously briefed or which they have reached an impasse after conferring as required by L.R. 7.1(a)(2). /s/ Patrick Strawbridge Patrick Strawbridge CERTIFICATE OF SERVICE In accordance with Local Rule 5.2(b), I hereby certify that this document was filed through the Court’s ECF system on January 27, 2016 and will be sent electronically to the registered participants identified on the Notice of Electronic Filing. The attachment to this motion was delivered to the Court in a sealed envelope. /s/ Benjamin C. Caldwell Benjamin C. Caldwell 4834-3739-8829.1 3

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