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

Filing 410

Joint MOTION to Seal Certain Information Filed in Connection with the Parties' Summary Judgment Motions 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 (HARVARD CORPORATION),

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

Defendant.

JOINT MOTION TO SEAL CERTAIN INFORMATION FILED IN
CONNECTION WITH THE PARTIES’ SUMMARY JUDGMENT MOTIONS
Pursuant to Local Rule 7.2, the Stipulated Protective Order (Dkt. 55), and this Court’s
recent order adopting the parties’ proposed briefing schedule for resolving disputes relating to
confidentiality (Dkt. 409), the parties jointly move this Court for an order sealing (1) portions of
the memoranda of law filed in support of their motions for summary judgment; (2) portions of
the statements of material fact filed in connection with their motions for summary judgment; and
(3) all or part of several of the exhibits filed in connection with their motions for summary
judgment. The parties request that any documents filed under seal on June 15 be impounded
until further order of the Court.
The parties have met and conferred and determined which materials must be subject to
this initial sealing order because one party has indicated the materials must be filed under seal.
In accordance with the schedule set by this Court (Dkts. 408, 409), the party seeking to seal
material that is the subject of this motion will file a Memorandum of Law in support of this
motion on June 22, 2018.

WHEREFORE, the parties respectfully request that the Court grant this motion and that
any documents filed under seal on June 15 be impounded until further order of the Court, such
that they may be viewed only by the Judge, her clerk(s), and Court personnel in conjunction with
the parties’ motion for summary judgment.
Respectfully submitted,
/s/ Felicia H. Ellsworth
Felicia H. Ellsworth (BBO #665232)
William F. Lee (BBO #291960)
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, MA 02109
Tel: [phone]
Fax: [phone]
[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]
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]
Counsel for Defendant President and
Fellows of Harvard College

/s/ Patrick Strawbridge
Patrick Strawbridge BBO #678274
CONSOVOY MCCARTHY PARK PLLC
Ten Post Office Square
8th Floor South PMB #706
Boston, MA 02109
Tel: [phone]
[e-mail]
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]
Paul M. Sanford BBO #566318
BURNS & LEVINSON LLP
125 Summer
One Citizens Plaza, Suite 1100
Providence, RI 02903
Tel: [phone]
Fax: [phone]
[e-mail]

Counsel for Plaintiff Students for Fair Admissions,
Inc.
Dated: June 13, 2018

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