Students for Fair Admissions, Inc. v. President and Fellows of Harvard College et al
Filing
157
MOTION to Seal Letter by President and Fellows of Harvard College.(Ellsworth, Felicia)
Case 1:14-cv-14176-ADB Document 157 Filed 07/08/16 Page 1 of 4
UNITED STATES DISTRICT COURT FOR
THE DISTRICT OF MASSACHUSETTS
BOSTON DIVISION
STUDENTS FOR FAIR ADMISSIONS, INC.,
Plaintiff,
v.
PRESIDENT AND FELLOWS OF HARVARD
COLLEGE (HARVARD CORPORATION),
Civil Action No. 1:14-cv-14176-ADB
Defendant.
DEFENDANT’S MOTION TO FILE UNDER SEAL
DEFENDANT’S UNREDACTED LETTER REGARDING
IMPLICATIONS OF FISHER II FOR THIS LITIGATION
Pursuant to Local Rule 7.2 and the Stipulated Protective Order (Dkt. 55), Defendant
President and Fellows of Harvard College (“Harvard”) hereby moves this Court for an order
sealing the unredacted version of Harvard’s letter regarding the implications of Fisher II for this
litigation (“Harvard’s Letter”). This letter includes admissions database information that Harvard
has designated as Highly Confidential – Attorneys’ Eyes Only pursuant to the Stipulated
Protective Order (Dkt. 55).
Harvard is delivering to the Court an unredacted courtesy copy of this letter in a sealed
envelope. Harvard requests that the document subject to this Motion be impounded until further
order of the Court. In the event the Court has not previously ordered otherwise, Harvard’s
submission should be returned to its undersigned counsel upon resolution of this matter. Pursuant
to Local Rule 7.1(a)(2), SFFA was made aware of this motion and assents to it.
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Case 1:14-cv-14176-ADB Document 157 Filed 07/08/16 Page 2 of 4
WHEREFORE, Harvard respectfully requests that the Court grant this motion and allow
Harvard’s unredacted Letter to be filed under seal and to be viewed only by the Judge, her clerk(s),
and Court personnel.
Respectfully submitted,
/s/ Felicia H. Ellsworth
Seth P. Waxman (pro hac vice)
Paul R.Q. Wolfson (pro hac vice)
WILMER CUTLER PICKERING
HALE AND DORR LLP
1875 Pennsylvania Ave. NW
Washington, D.C. 20006
Tel: (202) 663-6800
Fax: (202) 663-6363
seth.waxman@wilmerhale.com
paul.wolfson@wilmerhale.com
Debo P. Adegbile (pro hac vice)
WILMER CUTLER PICKERING
HALE AND DORR LLP
7 World Trade Center
250 Greenwich Street
New York, NY 10007
Tel: (212) 295-6717
Fax: (212) 230-8888
debo.adegbile@wilmerhale.com
Felicia H. Ellsworth (BBO #665232)
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, MA 02109
Tel: (617) 526-6687
Fax: (617) 526-5000
felicia.ellsworth@wilmerhale.com
Dated: July 8, 2016
Counsel for Defendant President and
Fellows of Harvard College
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Case 1:14-cv-14176-ADB Document 157 Filed 07/08/16 Page 3 of 4
CERTIFICATE OF CONFERENCE
In accordance with Local Rule 7.1(a), I hereby certify that Students for Fair Admissions’
counsel was made aware of this motion before it was filed and assents to Harvard’s request to file
its unredacted Letter under seal.
/s/ Felicia H. Ellsworth
Felicia H. Ellsworth
CERTIFICATE OF SERVICE
I hereby certify that this document filed through the CM/ECF system will be sent
electronically to all counsel of record via the CM/ECF system. The attachment to this motion was
delivered to the Court in a sealed envelope.
/s/ Felicia H. Ellsworth
Felicia H. Ellsworth
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Case 1:14-cv-14176-ADB Document 157 Filed 07/08/16 Page 4 of 4
EXHIBIT 1
Attachment To Be Filed Pending
Proposed Motion to File Under Seal
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