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

Filing 483

MOTION to Seal Certain Information Filed in Connection with Harvard's Reply in Support of its Motion for Summary Judgment by President and Fellows of Harvard College.(Ellsworth, Felicia)

Case 1:14-cv-14176-ADB Document 483 Filed 08/27/18 Page 1 of 4

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.

MOTION TO SEAL CERTAIN INFORMATION FILED IN
CONNECTION WITH HARVARD’S REPLY MEMORANDUM
IN SUPPORT OF ITS MOTION FOR SUMMARY JUDGMENT
Pursuant to Local Rule 7.2 and the Stipulated Protective Order (Dkt. 55), Defendant
President and Fellows of Harvard College (Harvard Corporation) (“Harvard”) hereby moves this
Court for an order sealing (1) portions of Harvard’s reply memorandum in support of its motion
for summary judgment on all remaining counts; and (2) parts of the attorney declaration and
parts of certain exhibits filed in support of Harvard’s reply memorandum in support of its motion
for summary judgment. The materials that Harvard seeks to seal include information designated
by SFFA as Confidential or Highly Confidential–Attorneys’ Eyes Only pursuant to the
Stipulated Protective Order (Dkt. 55).
Harvard requests that the documents subject to this Motion be impounded until further
order of the Court. In the event the Court has not previously ordered otherwise, Harvard’s
submissions should be returned to its undersigned counsel upon resolution of this matter.

Case 1:14-cv-14176-ADB Document 483 Filed 08/27/18 Page 2 of 4

WHEREFORE, Harvard respectfully requests that the Court grant this motion and allow
portions of Harvard’s reply memorandum in support of its motion for summary judgment and
parts of the attorney declaration and parts of certain exhibits filed in connection with Harvard’s
reply memorandum in support of its motion for summary judgment to be filed under seal on or
before August 30 and to be viewed only by the Judge, her clerk(s), and Court personnel.

Respectfully submitted,

/s/ Felicia H. Ellsworth
Felicia H. Ellsworth (BBO #665232)
William F. Lee (BBO #291960)
Andrew S. Dulberg (BBO #675405)
Elizabeth Mooney (BBO #679522)
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, MA 02109
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
[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]
[e-mail]

Case 1:14-cv-14176-ADB Document 483 Filed 08/27/18 Page 3 of 4

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]
Dated: August 27, 2018

Case 1:14-cv-14176-ADB Document 483 Filed 08/27/18 Page 4 of 4

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

CERTIFICATE OF CONFERENCE
In accordance with Local Rule 7.1(a)(2), I hereby certify that Students for Fair
Admissions, Inc.’s counsel was made aware of this motion before it was filed.

/s/ Felicia H. Ellsworth
Felicia H. Ellsworth