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

Filing 201

Assented to MOTION to Seal Document (Opposition Memorandums and Supporting Materials) by Students for Fair Admissions, Inc..(Caldwell, Benjamin)

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 ASSENTED-TO MOTION TO FILE UNDER SEAL
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 assented-to motion
seeking an order to file under seal unredacted versions of the following documents which SFFA
will soon be filing: (1) Opposition to Defendant’s Motion for Judgment on the Pleadings on
Counts IV and VI (the “MJP Opposition”), (2) the exhibit to the Declaration of William S.
Consovoy in support of the MJP Opposition (“Consovoy MJP Declaration”), (3) Opposition to
Defendant’s Motion to Dismiss for Lack of Subject Matter Jurisdiction (the “MTD Opposition”),
and (4) the Declaration of Williams S. Consovoy in support of the MTD Opposition and certain
exhibits thereto (“Consovoy MTD Declaration”). These documents contain information that has
been designated by SFFA and/or Defendant as Confidential and/or Highly Confidential –
Attorneys’ Eyes Only pursuant to the Stipulated Protected Order. Pursuant to Local Rule
7.1(a)(2), Harvard was made aware of this motion and assents to it.
WHEREFORE, SFFA respectfully requests that the Court grant this motion and allow the
MJP Opposition, an exhibit to the Consovoy MJP Declaration, the MTD Opposition, as well as

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the Consovoy MTD Declaration and certain exhibits thereto, to be filed under seal until further
order of the Court and to be viewed only by the Judge, her clerk(s), and Court personnel.

Respectfully submitted,
By: /s/ 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: [phone]
Fax: [phone]
[e-mail]
[e-mail]

Dated: October 20, 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: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Patrick Strawbridge BBO #678274
CONSOVOY MCCARTHY PARK PLLC
Ten Post Office Square
8th Floor South PMB #706
Boston, MA 02109
Tel: [phone]
[e-mail]
Counsel for Plaintiff Students for Fair
Admissions, Inc.

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CERTIFICATE OF CONFERENCE
In accordance with Local Rules 7.1(a), I hereby certify that Defendant’s counsel was
made aware of this motion before it was filed and assents to the relief requested therein.

/s/ Benjamin C. Caldwell

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.
/s/ Benjamin C. Caldwell

4832-2356-4603.1

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