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

Filing 371

Assented to MOTION to Seal Document Harvard's Opposition to SFFA's Motion to Compel Production of Documents Withheld or Redacted by President and Fellows of Harvard College.(Ellsworth, Felicia)

UNITED STATES DISTRICT COURT FOR
THE DISTRICT OF MASSACHUSETTS

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 OPPOSITION TO SFFA’S MOTION TO
COMPEL THE PRODUCTION OF DOCUMENTS WITHHELD OR REDACTED
Pursuant to Local Rule 7.2 and the Stipulated Protective Order (Dkt. 55), Defendant
President and Fellows of Harvard College (Harvard Corporation) (“Harvard”) hereby moves this
Court for an order sealing in its entirety Harvard’s Opposition to Students for Fair Admissions,
Inc.’s (“SFFA”) Motion to Compel the Production of Documents Withheld or Redacted. This
document refers to information designated as Confidential or Highly Confidential–Attorneys’
Eyes Only pursuant to the Stipulated Protective Order (Dkt. 55). Harvard’s Opposition will be
filed in response to SFFA’s Motion to Compel the Production of Documents Withheld or
Redacted, which was filed under seal (Dkt. 366). Pursuant to Local Rule 7.1(a)(2), SFFA was
made aware of this motion before it was filed, and it assents to this motion.
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.

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WHEREFORE, Harvard respectfully requests that the Court grant this motion and allow
Harvard’s Opposition to SFFA’s Motion to Compel the Production of Documents Withheld or
Redacted 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]
2

Fax: [phone]
[e-mail]
Dated: January 17, 2018

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.

/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