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

Filing 253

Assented to MOTION to Seal Motion to Quash Subpoenas and Deposition Notices or for a Protective Order 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
PLAINTIFF’S MOTION TO QUASH SUBPOENAS AND
DEPOSITION NOTICES OR FOR A PROTECTIVE ORDER
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 a motion to quash two subpoenas and deposition notices or for
a protective order. SFFA’s motion will seek to quash the depositions of two of its standing
members. This motion will contain information that has been designated as Confidential and/or
Highly Confidential – Attorneys’ Eyes Only pursuant to the Stipulated Protective Order. SFFA
requests an order that allows the motion and all accompanying exhibits to be filed under seal in
their entirety. Pursuant to Local Rule 7.1(a)(2), Defendant was aware of this motion and assents
to it.
WHEREFORE, SFFA respectfully requests that the Court grant this motion and allow
SFFA’s motion to quash or for a protective order and all accompanying exhibits 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.

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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]

William S. Consovoy
Thomas R. McCarthy
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]
Michael H. Park
CONSOVOY MCCARTHY PARK PLLC
2 Columbus Circle, 15th Floor
New York, NY 10024
Tel.: [phone]
[e-mail]

Dated: March 13, 2017

Counsel for Plaintiff SFFA

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CERTIFICATE OF CONFERENCE
In accordance with Local Rule 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

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