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

Filing 265

Assented to MOTION for Leave to File Reply Memorandum in Support of SFFA's 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 FOR LEAVE TO FILE A REPLY
MEMORANDUM IN SUPPORT OF ITS MOTION TO QUASH SUBPOENAS AND
DEPOSITION NOTICES OR FOR A PROTECTIVE ORDER
Pursuant to Local Rule 7.1(b)(3), Plaintiff, Students for Fair Admissions, Inc. (“SFFA”),
respectfully moves for leave to submit a reply memorandum in support of SFFA’s Motion to
Quash Subpoenas and Deposition Notices or for a Protective Order (the “Motion”).1 The Motion
seeks to quash the depositions of two of SFFA’s standing members. A reply memorandum for
the Motion is warranted to address certain assertions and arguments in Defendant’s opposition
which require a response. Pursuant to Local Rule 7.1(a)(2), Defendant was made aware of this
motion and assents to it. If this motion is granted, SFFA shall submit its reply memorandum by
April 5, 2017.
WHEREFORE, SFFA respectfully requests that the Court grant its motion for leave to
file a reply memorandum in support of the Motion.

The Motion (including SFFA’s accompanying memorandum) was filed under seal on March 15, 2017,
per court order (Dkt. 254). Harvard’s opposition to the Motion was also filed under seal on March 29,
2017, per court order (Dkt. 264).
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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]

Dated: March 31, 2017

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 Rule 7.1(a)(2), 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 the registered participants as identified on the Notice of Electronic Filing.
/s/ Benjamin C. Caldwell

4831-3265-1334.1

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