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

Filing 295

Assented to MOTION for Leave to File Reply Memoranda in Support of SFFA's Two Pending Motions to Compel 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 REPLY MEMORANDA IN SUPPORT OF ITS TWO PENDING MOTIONS TO COMPEL Pursuant to Local Rule 7.1(b)(3), Plaintiff, Students for Fair Admissions, Inc. (“SFFA”), respectfully moves for leave to submit reply memoranda in support of (1) SFFA’s Motion to Compel Production of Unredacted Documents (“Unredacted Documents Motion”) and (2) SFFA’s Renewed Motion to Compel Production of Application Files (“Application Files Motion”).1 A reply memorandum for each of these pending motions is warranted to address certain assertions and arguments in Defendant’s oppositions 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 memoranda by May 1, 2017. WHEREFORE, SFFA respectfully requests that the Court grant its motion for leave to file reply memoranda in support of the Unredacted Documents Motion and Application Files Motion. Both underlying motions to compel (including SFFA’s accompanying memoranda) were filed under seal on April 10, 2017, per court order (Dkt. 279). Harvard’s oppositions to each motion were also filed under seal on April 24, 2017, per court order (Dkt. 293). 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 26, 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. 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 4842-7483-5015.1 3

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