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

Filing 433

Assented to 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.
SFFA’S MOTION TO FILE UNDER SEAL CERTAIN INFORMATION
FILED IN CONNECTION WITH SFFA’S OPPOSITION TO HARVARD’S
MOTION FOR SUMMARY JUDGMENT
Pursuant to Local Rule 7.2 and the Stipulated Protective Order (Dkt. 55), Plaintiff
Students for Fair Admissions (“SFFA”) hereby moves this Court for an order sealing (1) portions
of SFFA’s memorandum of law filed in opposition to Harvard’s motion for summary judgment;
(2) portions of SFFA’s response to Harvard’s Rule 56.1 statement; and (3) all or part of certain
of the declarations and exhibits filed in support of SFFA’s opposition to Harvard’s motion for
summary judgment.
The Court has yet to rule on the pending dispute between the parties regarding materials
that Harvard demanded be sealed in the initial summary judgment filings. See Dkt. Nos. 410,
427. The materials that SFFA seeks to seal include information currently designated as
Confidential or Highly Confidential–Attorneys’ Eyes Only pursuant to the Stipulated Protective
Order (Dkt. 55), and therefore must be filed under seal. Pursuant to Local Rule 7.1(a)(2),
Defendant was made aware of this motion and assents to it.
WHEREFORE, SFFA respectfully requests that the Court grant this motion and allow
portions of SFFA’s memorandum in opposition to Harvard’s summary judgment motion,

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portions of SFFA’s response to Harvard’s Rule 56.1 statement, and all or part of certain of the
declarations and exhibits filed in connection with SFFA’s opposition to Harvard’s motion for
summary judgment 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.

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: July 26, 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.

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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

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