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

Filing 299

Assented to MOTION to Seal 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 TO FILE UNDER SEAL PLAINTIFF’S REPLY MEMORANDA IN SUPPORT OF ITS TWO 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 moves this Court for an order sealing in their entirety (1) SFFA’s Reply Memorandum in Support of its Motion to Compel Production of Unredacted Documents (“Unredacted Documents Motion”) and (2) SFFA’s Reply Memorandum in Support of its Renewed Motion to Compel Production of Application Files (“Application Files Motion”).1 These upcoming filings will contain substantial 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 the reply memoranda, and all accompanying documentation, 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. The Court has previously granted SFFA’s assented-to motion for leave to file these replies. See Dkt. 298. 1 1 WHEREFORE, SFFA respectfully requests that the Court grant this motion and allow the reply memoranda and all accompanying documentation 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: 617-345-3000 Fax: 617-345-3299 Dated: April 27, 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 Rules 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 4821-8115-8727.1 3

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