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

Filing 540

Assented to MOTION to Seal Portions of Pre-Trial Motions by Students for Fair Admissions, Inc..(Strawbridge, Patrick)

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.

CONSENTED-TO MOTION TO SEAL CERTAIN INFORMATION FILED IN
CONNECTION WITH PRE-TRIAL MOTIONS
Pursuant to Local Rule 7.2 and the Stipulated Protective Order (Dkt. 55), Plaintiff Students
for Fair Admissions, Inc. (“SFFA”) hereby moves this Court for an order sealing (1) limited portions
of pre-trial motions that will be filed on September 17 and (2) parts of certain exhibits filed in support
of those motions. The materials that the parties seek to seal include information designated by both
SFFA and Harvard as Confidential or Highly Confidential–Attorneys’ Eyes Only pursuant to the
Stipulated Protective Order (Dkt. 55), and for which the Court has yet to rule on the parties’ dispute
over the scope of information that can be permissibly withheld from the public. See Dkt. 410, 427.
Harvard has consented to this motion.
SFFA 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, the parties’ submissions
should be returned to their undersigned counsel upon resolution of this matter.

WHEREFORE, SFFA respectfully requests that the Court grant this motion and allow
portions of its pre-trial motions and parts of its supporting exhibits to be filed under seal on or
before September 17 and to be viewed only by the Judge, her clerk(s), and Court personnel.
Respectfully submitted,
/s/ Patrick Strawbridge
Patrick Strawbridge BBO #678274
CONSOVOY MCCARTHY PARK PLLC
Ten Post Office Square
8th Floor South PMB #706
Boston, MA 02109
Tel: [phone]
[e-mail]
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]
Adam K. Mortara
J. Scott McBride
Krista J. Perry
Bartlit Beck Herman Palenchar & Scott LLP
54 West Hubbard Street, Suite 300
Chicago, IL 60654
312.494.4400
[e-mail]
[e-mail]
[e-mail]
John M. Hughes
Katherine L.I. Hacker
Meg E. Fasulo
Bartlit Beck Herman Palenchar & Scott LLP
1801 Wewatta Street, Suite 1200
Denver, CO 80202

303.592.3100
[e-mail]
[e-mail]
[e-mail]
Paul M. Sanford BBO #566318
BURNS & LEVINSON LLP
125 Summer
One Citizens Plaza, Suite 1100
Providence, RI 02903
Tel: [phone]
Fax: [phone]
[e-mail]
Counsel for Plaintiff Students for Fair Admissions,
Inc.

Dated: September 14, 2018

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
Patrick Strawbridge