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

Filing 322

Assented to MOTION to Seal Document Harvard's Response Letter to SFFA's Letter Motion regarding Performance Reports by President and Fellows of Harvard College.(Ellsworth, Felicia)

UNITED STATES DISTRICT COURT FOR
THE DISTRICT OF MASSACHUSETTS
BOSTON DIVISION
STUDENTS FOR FAIR ADMISSIONS, INC.,
Plaintiff,
v.
PRESIDENT AND FELLOWS OF HARVARD
COLLEGE (HARVARD CORPORATION),

Civil Action No. 1:14-cv-14176-ADB

Defendant.
HARVARD’S ASSENTED-TO MOTION TO FILE UNDER SEAL
HARVARD’S RESPONSE LETTER TO SFFA’S MAY 22, 2017
LETTER MOTION REGARDING PERFORMANCE REPORTS
Pursuant to Local Rule 7.2 and the Stipulated Protective Order (Dkt. 55), Defendant
President and Fellows of Harvard College (“Harvard”) hereby moves this Court for an order
sealing in its entirety Harvard’s Response Letter to SFFA’s May 22, 2017 Letter Motion
Regarding Performance Reports. This document refers to information designated as Confidential
or Highly Confidential – Attorneys’ Eyes Only pursuant to the Stipulated Protective Order (Dkt.
55). Harvard’s Letter will be filed in response to SFFA’s May 22, 2017 Letter, which was filed
under seal (Dkt. 316). Pursuant to Local Rule 7.1(a)(2), SFFA was made aware of this motion and
assents to it.
Harvard requests that the document subject to this Motion be impounded until further order
of the Court. In the event the Court has not previously ordered otherwise, Harvard’s submission
should be returned to its undersigned counsel upon resolution of this matter.
WHEREFORE, Harvard respectfully requests that the Court grant this motion and allow
Harvard’s Response Letter to SFFA’s May 22, 2017 Letter Motion Regarding Performance

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Reports to be filed under seal and to be viewed only by the Judge, her clerk(s), and Court
personnel.
Respectfully submitted,
/s/ Felicia H. Ellsworth
Felicia H. Ellsworth (BBO #665232)
William F. Lee (BBO #291960)
Andrew S. Dulberg (BBO #675405)
Elizabeth Mooney (BBO #679522)
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, MA 02109
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Seth P. Waxman (pro hac vice)
Paul R.Q. Wolfson (pro hac vice)
Daniel Winik (pro hac vice)
WILMER CUTLER PICKERING
HALE AND DORR LLP
1875 Pennsylvania Ave. NW
Washington, D.C. 20006
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
Debo P. Adegbile (pro hac vice)
WILMER CUTLER PICKERING
HALE AND DORR LLP
7 World Trade Center
250 Greenwich Street
New York, NY 10007
Tel: [phone]
Fax: [phone]
[e-mail]

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Dated: May 31, 2017

Counsel for Defendant President and
Fellows of Harvard College

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CERTIFICATE OF CONFERENCE
In accordance with Local Rule 7.1(a)(2), I hereby certify that Students for Fair
Admissions, Inc.’s counsel was made aware of this motion before it was filed and assents to
Harvard’s request to file its Response Letter to SFFA’s May 22, 2017 Letter Motion Regarding
Performance Reports under seal.

/s/ Felicia H. Ellsworth
Felicia H. Ellsworth

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/ Felicia H. Ellsworth
Felicia H. Ellsworth