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

Filing 331

Assented to MOTION to Seal Document Harvard's Letter to the Court regarding June 6, 2017 Discovery Order 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 LETTER TO THE COURT REGARDING
JUNE 6, 2017 DISCOVERY ORDER
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 Letter to the Court Regarding June 6, 2017 Discovery Order. This
document refers to and attaches 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 the Court’s June 6, 2017 sealed discovery order (Dkt. 326). 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 Letter to the Court Regarding June 6, 2017 Discovery Order to be filed under seal and to
be viewed only by the Judge, her clerk(s), and Court personnel.

1

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]
Dated: June 21, 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 Letter to the Court Regarding June 6, 2017 Discovery Order 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