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)

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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. 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: 617-345-3000 Fax: 617-345-3299 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 Patrick Strawbridge BBO #678274 CONSOVOY MCCARTHY PARK PLLC Ten Post Office Square 8th Floor South PMB #706 Boston, MA 02109 Tel: 617-227-0548 Michael H. Park CONSOVOY MCCARTHY PARK PLLC 2 Columbus Circle, 15th Floor New York, NY 10024 Tel.: 212.247.8006 Dated: April 3, 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

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