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

Filing 268

Assented to MOTION to Seal Document Harvard's Opposition to SFFA's Motion for a Protective Order and to Quash Deposition Notices 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 FOR
A PROTECTIVE ORDER AND TO QUASH DEPOSITION NOTICES
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 For a Protective Order and to
Quash Deposition Notices. This document includes information designated by Students for Fair
Admissions, Inc. (“SFFA”) as Confidential or Highly Confidential – Attorneys’ Eyes Only
pursuant to the Stipulated Protective Order (Dkt. 55). Harvard’s Opposition will be filed in
response to SFFA’s Motion For a Protective Order and to Quash Deposition Notices, which was
filed under seal (Dkt. 259). 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 For a Protective Order and to Quash Deposition
Notices, 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: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[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]
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Fax: [phone]
[e-mail]
Dated: April 3, 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 For a Protective Order and to Quash Deposition
Notices 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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