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)

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: [phone]
Fax: [phone]
[e-mail]

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: [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.

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