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

Filing 275

Assented to MOTION to Seal SFFA's Motions to Compel 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 MOTIONS TO COMPEL
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 two motions to compel. SFFA’s first motion to compel seeks
the production of specific documents in unredacted form which were previously produced by
Defendant in redacted form only (the “Unredacted Documents Motion”). SFFA’s second motion
to compel is a renewed motion to compel which seeks the production of Defendant’s application
files (“Application Files Motion”). These motions, and their respective supporting documents,
contain information that has been designated by Defendant as Confidential and/or Highly
Confidential – Attorneys’ Eyes Only pursuant to the Stipulated Protective Order. To comply
with Defendant’s designations, SFFA requests an order that allows these two motions, and all
documents in support, 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 Unredacted Documents Motion and Application Files Motion, along with all

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accompanying documents in support, 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.

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]

William S. Consovoy
Thomas R. McCarthy
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]
Michael H. Park
CONSOVOY MCCARTHY PARK PLLC
2 Columbus Circle, 15th Floor
New York, NY 10024
Tel.: [phone]
[e-mail]

Dated: April 7, 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

4811-7406-2918.1

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