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

Filing 134

MOTION to Seal Document (SFFA's Reply to Harvard's February 5, 2016 Letter) by Students for Fair Admissions, Inc..(Caldwell, Benjamin) (Additional attachment(s) added on 2/10/2016: # 1 Exhibit) (Folan, Karen).

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS STUDENTS FOR FAIR ADMISSIONS, INC., Plaintiff, v. Civil Action No. 1:14-cv-14176-ADB PRESIDENT AND FELLOWS OF HARVARD COLLEGE (HARVARD CORPORATION), Defendant. PLAINTIFF’S MOTION TO IMPOUND REPLY TO HARVARD’S FEBRUARY 5, 2016 LETTER 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 SFFA’s February 10, 2016 letter to Judge Burroughs (“Letter”) which replies to the letter filed under seal by Defendant, the President and Fellows of Harvard College (“Harvard”) on February 5, 2016. The Letter contains information that has been designated by Harvard as “protected material” under the Stipulated Protective Order. This motion is brought in reaction to Harvard’s designations. SFFA is hand-delivering an unredacted courtesy copy of the Letter to Judge Burroughs in a sealed envelope. WHEREFORE, SFFA respectfully submits this motion, which gives the Court the option to allow the Letter to be impounded until further order of the Court and to be viewed only by the Judge, her clerk(s), and Court personnel. 1 Respectfully submitted, By: /s/ Benjamin C. Caldwell Benjamin C. Caldwell 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 psanford@burnslev.com bcaldwell@burnslev.com Dated: February 10, 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 will@consovoymccarthy.com tom@consovoymccarthy.com park@consovoymccarthy.com mike@consovoymccarthy.com Patrick Strawbridge BBO #678274 CONSOVOY MCCARTHY PARK PLLC Ten Post Office Square 8th Floor South PMB #706 Boston, MA 02109 Tel: 617-227-0548 patrick@consovoymccarthy.com 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. /s/ Benjamin C. Caldwell Benjamin C. Caldwell 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 February 10, 2016 and will be sent electronically to the registered participants identified on the Notice of Electronic Filing. A courtesy copy of the unredacted Letter referenced herein was hand-delivered to the Court; a copy is also being provided to opposing counsel. /s/ Benjamin C. Caldwell Benjamin C. Caldwell 4836-6708-5102.1 3

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