Students for Fair Admissions, Inc. v. President and Fellows of Harvard College et al
Filing
263
Assented to MOTION to Seal Document Opposition to SFFA's Motion to Quash Subpoenas and Deposition Notices or For a Protective Order 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.
HARVARD’S ASSENTED-TO MOTION TO FILE UNDER SEAL
HARVARD’S OPPOSITION TO SFFA’S MOTION TO QUASH SUBPOENAS AND
DEPOSITION NOTICES OR FOR A PROTECTIVE ORDER
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 in its entirety Harvard’s Opposition to Plaintiff’s Motion to Quash Subpoenas and
Deposition Notices or for a Protective Order. This document includes information designated as
Confidential or Highly Confidential – Attorneys’ Eyes Only pursuant to the Stipulated Protective
Order (Dkt. 55), including information disclosing the identities of members of Students for Fair
Admissions, Inc. (“SFFA”). Harvard’s Opposition will be filed in response to SFFA’s Motion to
Quash Subpoenas and Deposition Notices or for a Protective Order, which was filed under seal
(Dkt. 254). Pursuant to Local Rule 7.1(a)(2), SFFA was made aware of this motion and assents to
it.
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.
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WHEREFORE, Harvard respectfully requests that the Court grant this motion and allow
Harvard’s Opposition to Plaintiff’s Motion to Quash Subpoenas and Deposition Notices or for a
Protective Order, 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
Felicia H. Ellsworth (BBO #665232)
William F. Lee (BBO #291960)
Andrew S. Dulberg (BBO #675405)
Elizabeth Mooney (BBO #679522)
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, MA 02109
Tel: (617) 526-6000
Fax: (617) 526-5000
william.lee@wilmerhale.com
felicia.ellsworth@wilmerhale.com
andrew.dulberg@wilmerhale.com
elizabeth.mooney@wilmerhale.com
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: (202) 663-6800
Fax: (202) 663-6363
seth.waxman@wilmerhale.com
paul.wolfson@wilmerhale.com
daniel.winik@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
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Fax: (212) 230-8888
debo.adegbile@wilmerhale.com
Dated: March 28, 2017
Counsel for Defendant President and
Fellows of Harvard College
CERTIFICATE OF CONFERENCE
In accordance with Local Rule 7.1(a)(2), 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 Opposition to Plaintiff’s Motion to Quash Subpoenas and Deposition Notices or
for a Protective Order 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.
/s/ Felicia H. Ellsworth
Felicia H. Ellsworth
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