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

Filing 345

Assented to MOTION to Seal SFFA's Reply in Support of its August 1, 2017 Request for Judicial Intervention and Relief by Students for Fair Admissions, Inc..(Caldwell, Benjamin)

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 PLAINTIFF’S
AUGUST 1, 2017 LETTER TO THE COURT
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 request filed under seal
on August 1, 2017, through which SFFA seeks authority to take one additional half-day
deposition of a newly discovered witness. This reply letter will address certain assertions and
arguments in Defendant’s response letter which was filed under seal on August 2, 2017. Like the
original letter request, this reply letter will contain information that has been designated by
Defendant 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 letter 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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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]

Dated: August 3, 2017

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]
Counsel for Plaintiff Students for Fair
Admissions, Inc.

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CERTIFICATE OF CONFERENCE
In accordance with Local Rules 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

4847-6190-3436.1

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