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)

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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. 1 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: 617-345-3000 Fax: 617-345-3299 William S. Consovoy Thomas R. McCarthy 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 Michael H. Park CONSOVOY MCCARTHY PARK PLLC 2 Columbus Circle, 15th Floor New York, NY 10024 Tel.: 212.247.8006 Dated: May 10, 2017 Counsel for Plaintiff SFFA 2 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 3

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