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

Filing 258

Assented to MOTION to Seal Motion for a Protective Order and to Quash Deposition Notices 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 FOR A PROTECTIVE ORDER AND TO QUASH DEPOSITION NOTICES
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 for a protective order and to quash two deposition
notices—a motion that SFFA soon will be filing. SFFA’s motion will seek to quash the noticed
depositions of two of its officers. The motion will contain information that has been designated
as Confidential and/or Highly Confidential – Attorneys’ Eyes Only under the Stipulated
Protective Order. SFFA requests an order that allows the motion, as well as all accompanying
filings in support (including 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 for a protective order and to quash deposition notices, as well as all
accompanying filings in support (including 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.

1

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 21, 2017

Counsel for Plaintiff SFFA

2

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

3