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

Filing 363

Joint MOTION to Amend 335 Order on Motion to Amend,,, Scheduling Order by Students for Fair Admissions, Inc..(Strawbridge, Patrick)

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.
The Court recently ordered the production of additional materials by Harvard in this case.
Dkt. 362. To accommodate the production of materials responsive to that and prior orders of the
Court, the parties jointly seek an order revising portions of the expert discovery schedule—but not
the dispositive motion schedule—reflected in the Court’s prior order of June 27, 2017. Dkt. 335.:
1.

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

P. 26(a)(2) shall be disclosed by October 16, 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 15, 2017.
3.

Plaintiff’s rebuttal expert reports shall be disclosed by January 29, 2018.

4.

Defendant’s rebuttal expert reports shall be disclosed by March 15, 2018.

5.

All other deadlines shall remain the same as previously ordered by the Court:
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a. Expert discovery, including expert depositions, shall be completed by May 1,
2018.
b. All dispositive motions under Fed. R. Civ. P. 56 shall be filed by June 15, 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,
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: September 20, 2017

/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]
Counsel for Plaintiff Students for Fair
Admissions, Inc.

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/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]
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: September 20, 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 Harvard joins in this motion
and consents to the requested relief.
s/ Patrick Strawbridge
Patrick Strawbridge
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/ Patrick Strawbridge
Patrick Strawbridge

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