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

Filing 493

MOTION for Leave to Appear Pro Hac Vice for admission of Earl A. Kirkland III Filing fee: $ 100, receipt number 0101-7296869 by Coalition for a Diverse Harvard, First Generation Harvard Alumni, Fuerza Latina of Harvard, Harvard Asian American Brotherhood, Harvard Islamic Society, Harvard Japan Society, Harvard Korean Association, Harvard Latino Alumni Alliance, Harvard Minority Association of Pre-Medical Students, Harvard Phillips Brooks House Association, Harvard South Asian Association, Harvard University Muslim Alumni, Harvard Vietnamese Association, Harvard-Radcliffe Asian American Association, Harvard-Radcliffe Asian American Women's Association, Harvard-Radcliffe Black Students Association, Harvard-Radcliffe Chinese Students Association, Kuumba Singers of Harvard College, Native American Alumni of Harvard University, Native Americans At Harvard College, Task Force on Asian and Pacific American Studies at Harvard College. (Attachments: # 1 Exhibit Certification of Attorney Kirkland)(Thayer, Kenneth)

UNITED STATES DISTRICT COURT FOR
THE DISTRICT OF MASSACHUSETTS
BOSTON DIVISION

STUDENTS FOR FAIR ADMISSIONS, INC.,
Plaintiff,
v.
Civil Action No. 1:14-cv-14176-ADB

PRESIDENT AND FELLOWS OF
HARVARD COLLEGE (HARVARD
CORPORATION),

Defendant.

MOTION FOR ADMISSION PRO HAC VICE
OF NAACP LEGAL DEFENSE AND EDUCATIONAL FUND, INC.
Pursuant to Local Rule 83.5.3, attorneys Kate R. Cook and Kenneth N. Thayer,
members in good standing of the bar of the Commonwealth of Massachusetts and this Court
and attorneys at the law firm Sugarman, Rogers, Barshak & Cohen, P.C., respectfully move this
Court to grant permission to the NAACP Legal Defense and Educational Fund, Inc. (“LDF”),
by and through its attorney Earl A. Kirkland III, to appear and practice pro hac vice in this
matter as counsel for amici curiae 21 Colorful Crimson, Harvard Black Alumni Society,
Association for Black Harvard Women, Harvard-Radcliffe Black Students Association,
Kuumba Singers of Harvard College, Fuerza Latina of Harvard, Harvard Asian American
Alumni Alliance, Native Americans at Harvard College, Harvard-Radcliffe Asian American
Association, Harvard-Radcliffe Asian American Women’s Association, Harvard Asian
American Brotherhood, Harvard Vietnamese Association, Harvard-Radcliffe Chinese Students
Association, Harvard Korean Association, Harvard Japan Society, Harvard South Asian
Association, Harvard Islamic Society, Task Force on Asian and Pacific American Studies at
Harvard College, Harvard Phillips Brooks House Association, Harvard Minority Association of
1

Pre-Medical Students, Coalition for a Diverse Harvard, First Generation Harvard Alumni,
Native American Alumni of Harvard University, Harvard University Muslim Alumni, and
Harvard Latino Alumni Alliance (collectively, “Amici”).
1.

Earl A. Kirkland III is an attorney at NAACP Legal Defense and Educational

Fund, Inc., located at 40 Rector Street, 5th Floor, New York, NY 10006. He is a member in good
standing of the bars of the State of Michigan and the United States Courts of Appeals for the
Sixth Circuit. There are no disciplinary proceedings pending against Mr. Kirkland in any
jurisdiction. Mr. Kirkland is familiar with the issues of this case and the Local Rules of this Court.
2.

Kate R. Cook and Kenneth N. Thayer, members in good standing of the Bar of the

Commonwealth of Massachusetts and the United States District Court for the District of
Massachusetts, will continue to represent the Amici as local counsel if this motion is granted.
3.

In support of this Motion, Amici submit the Certification of Mr. Kirkland.

WHEREFORE, Amici, by their attorneys Kate R. Cook and Kenneth N. Thayer,
respectfully request that this Court grant permission to Earl A. Kirkland III, to appear and
practice pro hac vice on behalf of Amici.
Dated: August 29, 2018

Respectfully submitted,
/s/ Kenneth N. Thayer
Kate R. Cook BBO #650698
[e-mail]
Kenneth N. Thayer, BBO #671029
[e-mail]
Sugarman, Rogers, Barshak & Cohen, P.C.
101 Merrimac Street (9th floor)
Boston, MA 02114-4737
[phone]

2

CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1
I hereby certify that on August 28, 2018, counsel for the above-listed amici curiae
conferred with counsel for the plaintiff, Students for Fair Admissions, Inc., and with counsel for
the defendant, President and Fellows of Harvard College, and both parties indicated their assent
to this motion.

/s/ Kenneth N. Thayer
Kenneth N. Thayer, Esq.

3

CERTIFICATE OF SERVICE
I hereby certify that on August 29, 2018, a copy of the foregoing MOTION FOR
ADMISSION PRO HAC VICE OF NAACP LEGAL DEFENSE AND EDUCATIONAL
FUND, INC. was filed through the Court’s ECF system, which provided notice of this filing to
all counsel of record via the CM/ECF system.

/s/ Kenneth N. Thayer
Kenneth N. Thayer, Esq.

4