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

Filing 311

Assented to MOTION to Seal SFFA's Reply in Support of its Letter Motion Regarding Depositions and Custodians by Students for Fair Admissions, Inc..(Caldwell, Benjamin)

Case 1:14-cv-14176-ADB Document 311 Filed 05/10/17 Page 1 of 3

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
REPLY LETTER IN SUPPORT OF LETTER MOTION
REGARDING DEPOSITIONS AND CUSTODIANS
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 its reply letter in support of its letter motion filed under seal on
April 12, 2017, concerning SFFA’s request for additional depositions and custodians. This reply
letter will address certain assertions and arguments in Defendant’s response letter which was
filed under seal on May 3, 2017. Like the original letter motion, this reply letter will contain
information that has been designated as Confidential and/or Highly Confidential – Attorneys’
Eyes Only pursuant to the Stipulated Protective Order. To comply with those designations,
SFFA requests an order that allows the reply letter to be filed under seal in its 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 the
reply and all accompany exhibits 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.

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Case 1:14-cv-14176-ADB Document 311 Filed 05/10/17 Page 2 of 3

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: May 10, 2017

Counsel for Plaintiff SFFA

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Case 1:14-cv-14176-ADB Document 311 Filed 05/10/17 Page 3 of 3

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

4848-2749-7288.1

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