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

Filing 378

Assented to MOTION to Seal Reply Memorandum in Support of SFFA's Motion to Compel 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
PLAINTIFF’S REPLY MEMORANDUM IN SUPPORT OF MOTION TO COMPEL
THE PRODUCTION OF DOCUMENTS WITHHELD OR REDACTED
Pursuant to Local Rule 7.2 and this matter’s Stipulated Protective Order (Dkt. No. 55),
Plaintiff, Students for Fair Admissions, Inc. (“SFFA”), hereby moves this Court for an order
sealing in its entirety SFFA’s Reply Memorandum in support of its Motion to Compel the
Production of Documents Withheld or Redacted (the “Reply”). 1 This upcoming filing will
contain substantial 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 Defendant’s designations, SFFA requests an order that allows the Reply and all
accompanying documentation to be filed under seal.

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 and all accompanying documentation 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.

The Court has previously granted SFFA’s assented-to motion for leave to file the Reply.
See Dkt. 376.
1

1

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: January 25, 2018

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.

2

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

4841-9129-3018.1

3