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

Filing 424

Assented to MOTION to Seal Portions of SFFA's Opposition to Harvard's Motion to Seal by Students for Fair Admissions, Inc..(Strawbridge, Patrick)

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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 PORTIONS OF SFFA’S OPPOSITION TO HARVARD’S MOTION TO SEAL CERTAIN INFORMATION FILED IN CONNECTION WITH THE PARTIES’ SUMMARY JUDGMENT MOTIONS Pursuant to Local Rule 7.2 and this matter’s Stipulated Protective Order (Dkt. No. 55), and this Court’s recent order adopting the parties’ proposed briefing schedule for resolving disputes relating to confidentiality (Dkt. 409), Plaintiff, Students for Fair Admissions, Inc. (“SFFA”), hereby moves this Court for an order sealing portions of its Opposition to Harvard’s Motion to Seal Certain Information Filed in Connection with the Parties’ Summary Judgment Motions (the “Opposition”). This upcoming filing will contain substantial information that makes reference to Exhibits B and C to Defendant’s Memorandum in Support of its Motion for Summary Judgment (“Defendant’s Memorandum”), which have 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 portions of its Opposition that reference Exhibits B and C to Defendant’s Memorandum to be filed under seal. Pursuant to Local Rule 7.1(a)(2), Defendant was made aware of this motion and assents to it. 4844-1538-2636.1 1 WHEREFORE, SFFA respectfully requests that the Court grant this motion and allow the portions of its Opposition that reference Exhibits B and C to Defendant’s Memorandum to be filed under seal until further order of the Court such that it may be viewed only by the Judge, her clerk(s), and Court personnel in connection with SFFA’s Motion for Summary Judgment. Respectfully submitted, By: /s/ Patrick Strawbridge Paul M. Sanford BBO #566318 BURNS & LEVINSON LLP One Citizens Plaza, Suite 1100 Providence, RI 02903 Tel: 617-345-3000 Fax: 617-345-3299 Dated: June 27, 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: 703-243-4923 Fax: 703.243.4923 Patrick Strawbridge BBO #678274 CONSOVOY MCCARTHY PARK PLLC Ten Post Office Square 8th Floor South PMB #706 Boston, MA 02109 Tel: 617-227-0548 Counsel for Plaintiff Students for Fair Admissions, Inc. 4844-1538-2636.1 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/ 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 4844-1538-2636.1 3

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