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

Filing 245

Joint MOTION to Seal Letters Regarding Production Of Reviewer Comments by President and Fellows of Harvard College.(Ellsworth, Felicia)

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.

JOINT MOTION TO FILE UNDER SEAL LETTERS REGARDING
PRODUCTION OF REVIEWER COMMENTS
Pursuant to Local Rule 7.2 and the Stipulated Protective Order (Dkt. 55), Plaintiff Students
for Fair Admissions, Inc. (“SFFA”) and Defendant President and Fellows of Harvard College
(“Harvard”) hereby jointly move this Court for an order sealing in their entirety the letters each
side plans to submit in response to the Court’s invitation in its sealed January 12, 2017 Order to
provide proposals regarding the production of reviewer comments (Dkt. 243). The parties are
filing their letters pursuant to that sealed order, and the letters contain references to information
designated as confidential by Harvard relating to Harvard’s admissions process.
The parties request that the documents subject to this motion be impounded until further
order of the Court. In the event the Court has not previously ordered otherwise, the parties’
submissions should be returned to the undersigned counsel upon resolution of this matter.
WHEREFORE, SFFA and Harvard respectfully request that the Court grant this motion
and allow each party to file under seal in their entirety the letters regarding the production of
reviewer comments, which will be viewed only by the Judge, her clerk(s), and Court personnel.

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Respectfully submitted,
/s/ Felicia H. Ellsworth
Felicia H. Ellsworth (BBO #665232)
William F. Lee (BBO #291960)
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, MA 02109
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Seth P. Waxman (pro hac vice)
Paul R.Q. Wolfson (pro hac vice)
Daniel Winik (pro hac vice)
WILMER CUTLER PICKERING
HALE AND DORR LLP
1875 Pennsylvania Ave. NW
Washington, D.C. 20006
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
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: [phone]
Fax: [phone]
[e-mail]
Dated: February 2, 2017

Counsel for Defendant President and
Fellows of Harvard College

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By: /s/ Patrick Strawbridge

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]

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]

Dated: February 2, 2017

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 Rule 7.1(a)(2), I hereby certify that SFFA joins in this motion
and consents to the requested relief.

/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.

/s/ Felicia H. Ellsworth
Felicia H. Ellsworth

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