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

Filing 288

Letter/request (non-motion) from SFFA to Judge Burroughs Requesting Conference. (Strawbridge, Patrick)

Ten Post Office Square
8th Floor South PMB #706
Boston, MA 02109
617.227.0548
www.consovoymccarthy.com

April 12, 2017
VIA ECF
Hon. Allison D. Burroughs
U.S. District Court, District of Massachusetts
John Joseph Moakley U.S. Courthouse
1 Courthouse Way, Suite 2300
Boston, MA 02210
Re:

Students for Fair Admissions, Inc. v. President & Fellows of Harvard College,
No. 1:14-cv-14176-ADB

Dear Judge Burroughs,
Plaintiff Students for Fair Admissions, Inc. (“SFFA”) respectfully requests a
conference to resolve discovery motions it has pending before the Court. Without
prompt resolution of these discovery disputes, it will be impossible for the parties to
meet the June 20, 2017 deadline for the close of fact discovery. Listed below are the
matters currently pending before the Court:
Issue

Pending Since

Filings

SFFA’s letter challenging Harvard’s
confidentiality designations

Nov. 1, 2016

 SFFA’s letter describing disputed
documents and parties’ positions
(11/1/16)

SFFA’s motion to compel
production of reviewer comments

Feb. 3, 2017

 Parties ordered to submit proposals
on reviewer comments (1/12/17)
 SFFA’s and Harvard’s letters (2/3/17)

SFFA’s motion to quash
depositions of standing members

Apr. 5, 2017

 SFFA’s motion to quash (3/15/17)
 Harvard’s opposition (3/29/17)
 SFFA’s reply (4/5/17)

SFFA’s motion to quash
depositions of additional SFFA
officers

Apr. 11, 2017

 SFFA’s motion to quash (3/22/17)
 Harvard’s opposition (4/5/17)
 SFFA’s reply (4/11/17)

SFFA’s motion to compel
production of unredacted
documents

In progress

 SFFA’s motion to compel (4/10/17)
 Briefing to be completed by 5/1/17

SFFA’s renewed motion to compel
production of application files

In progress

 SFFA’s motion to compel (4/10/17)
 Briefing to be completed by 5/1/17

SFFA’s request for additional
depositions and custodians

In progress

 SFFA’s letter motion (4/12/17)
 Briefing to be completed by 5/1/17

Boston Latin High School’s motion
to quash third-party subpoena

In progress

 Boston Latin’s motion (4/10/17)
 Briefing to be completed by 5/1/17

Hon. Allison D. Burroughs
April 12, 2017
Page 2

Most urgently, SFFA requests relief from Harvard’s request to depose two of its
officers and two of its student members. The first of those depositions is scheduled
for May 9, 2017. Moreover, SFFA has recently submitted several motions to compel
the production of various categories of discovery that are obviously important to this
case. Finally, SFFA is unable to schedule several depositions until the Court rules on
its motion to expand the number of deponents.
Accordingly, SFFA requests a conference to facilitate the prompt resolution of these
pending matters once they have all been briefed. Counsel for SFFA is available for a
conference on the following dates: May 1, May 2, May 3, May 5, or May 8. Counsel for
SFFA also is amenable to a telephonic conference if it would be more convenient for
the Court.
Respectfully submitted,
/s/ Patrick Strawbridge
Patrick Strawbridge
cc:

ECF recipients

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