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

Filing 334

Joint MOTION to Amend September 1, 2016 Amended Scheduling 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,

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

Defendant.

JOINT MOTION FOR ENTRY OF AMENDED SCHEDULING ORDER
Plaintiff Students for Fair Admissions, Inc. (“SFFA”) and Defendant President and
Fellows of Harvard College (“Harvard”) hereby jointly move this Court for entry of an amended
scheduling order.
On September 1, 2016, the Court entered an Amended Scheduling Order governing fact
discovery, expert discovery, and dispositive motions. Dkt. 180. On June 6, 2017, the Court
extended the deadline for fact discovery from June 20, 2017, to August 4, 2017. To reflect that
extension, the parties jointly seek an order revising the expert discovery and dispositive motion
schedule as follows:
1.

Plaintiff’s experts shall be designated and the information required by Fed. R. Civ.

P. 26(a)(2) shall be disclosed by October 3, 2017.
2.

Defendant’s experts shall be designated and the information required by Fed. R.

Civ. P. 26(a)(2) shall be disclosed by December 2, 2017.
3.

Plaintiff’s rebuttal expert reports shall be disclosed by January 16, 2018.

4.

Defendant’s rebuttal expert reports shall be disclosed by February 26, 2018.
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5.

All expert discovery, including expert depositions, shall be completed by May 1,

6.

All dispositive motions under Fed. R. Civ. P. 56 shall be filed by June 15, 2018.

2018.

Opposition briefs shall be filed by July 30, 2018. Reply briefs shall be filed by August 30, 2018.
SFFA and Harvard respectfully request that the Court enter a revised scheduling order as
described above.
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
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250 Greenwich Street
New York, NY 10007
Tel: [phone]
Fax: [phone]
[e-mail]
Dated: June 27, 2017

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]

Counsel for Defendant President and
Fellows of Harvard College

/s/ Patrick Strawbridge
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: [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]

Dated: June 27, 2017

Counsel for Plaintiff Students for Fair
Admissions, Inc.

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CERTIFICATE OF CONFERENCE
In accordance with Local Rule 7.1(a)(2), I hereby certify that SFFA joins in this motion
and consents to the requested relief.

/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

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