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

Filing 278

Assented to MOTION for Leave to File Reply Memorandum in Support of SFFA's Motion for a Protective Order and to Quash Deposition Notices 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 FOR LEAVE TO FILE A REPLY MEMORANDUM IN SUPPORT OF ITS MOTION FOR A PROTECTIVE ORDER AND TO QUASH DEPOSITION NOTICES 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 for a Protective Order and to Quash Deposition Notices (the “Motion”).1 The Motion seeks to quash the depositions of two of SFFA’s officers. 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 12, 2017. WHEREFORE, SFFA respectfully requests that the Court grant its motion for leave to file a reply memorandum in support of the Motion. 1 The Motion (including SFFA’s accompanying memorandum) was filed under seal on March 22, 2017, per court order (Dkt. 259). Harvard’s opposition to the Motion was also filed under seal on April 5, 2017, per court order (Dkt. 269). 4812-2374-8934.1 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 Dated: April 10, 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: 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 Counsel for Plaintiff Students for Fair Admissions, Inc. 4812-2374-8934.1 2 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 4812-2374-8934.1 3

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