Students for Fair Admissions, Inc. v. President and Fellows of Harvard College et al
Filing
270
Assented to MOTION to Seal Document SFFA's Reply in Support of its 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 REPLY IN SUPPORT OF ITS 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 its reply in support of its motion to quash the depositions of two
of its standing members—a reply that SFFA soon will be filing. This Court granted SFFA leave to
file its reply on April 3, 2017 (Dkt. No. 267). Like the original motion, the reply 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 reply 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 reply 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: 617-345-3000
Fax: 617-345-3299
psanford@burnslev.com
bcaldwell@burnslev.com
William S. Consovoy
Thomas R. McCarthy
J. Michael Connolly
CONSOVOY MCCARTHY PARK PLLC
3033 Wilson Boulevard, Suite 700
Arlington, Virginia 22201
Tel: 703-243-4923
Fax: 703.243.4923
will@consovoymccarthy.com
tom@consovoymccarthy.com
park@consovoymccarthy.com
mike@consovoymccarthy.com
Patrick Strawbridge BBO #678274
CONSOVOY MCCARTHY PARK PLLC
Ten Post Office Square
8th Floor South PMB #706
Boston, MA 02109
Tel: 617-227-0548
patrick@consovoymccarthy.com
Michael H. Park
CONSOVOY MCCARTHY PARK PLLC
2 Columbus Circle, 15th Floor
New York, NY 10024
Tel.: 212.247.8006
park@consovoymccarthy.com
Dated: April 3, 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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