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

Filing 596

Assented to MOTION to Seal by Students for Fair Admissions, Inc..(Hacker, Katherine)

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS BOSTON DIVISION STUDENTS FOR FAIR ADMISSIONS, INC., Plaintiff, v. PRESIDENT AND FELLOWS OF HARVARD COLLEGE, Defendant. Civil Action No. 1:14-cv-14176-ADB MOTION TO SEAL EXHIBITS TO OFFER OF PROOF 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 exhibits to SFFA’s Offer of Proof. The documents that SFFA seeks to seal are designated Confidential or Highly Confidential-Attorneys’ Eyes Only pursuant to the Stipulated Protective Order (Dkt. 55). 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 exhibits to SFFA’s Offer of Proof be filed under seal on or before October 29 and to be viewed only by the Judge, her clerk(s), and Court personnel. Dated: October 27, 2018 Respectfully submitted, /s/ Katherine L.I. Hacker 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 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 William S. Consovoy Thomas R. McCarthy Michael H. Park J. Michael Connolly CONSOVOY MCCARTHY PARK PLLC 3033 Wilson Boulevard, Suite 700 Arlington, Virginia 22201 703.243.9423 Patrick Strawbridge BBO #678274 CONSOVOY MCCARTHY PARK PLLC Ten Post Office Square 8th Floor South PMB #706 Boston, MA 02109 617.227.0548 2 Paul M. Sanford BBO #566318 BURNS & LEVINSON LLP One Citizens Plaza, Suite 1100 Providence, RI 02903 617.345.3000 Attorneys for Plaintiff Students for Fair Admissions, Inc. 3 CERTIFICATE OF CONFERENCE Pursuant to Local Rule 7.1(a), the undersigned conferred with counsel for Defendant on October 26, 2018, and Defendant consents to this motion. /s/ Katherine L.I. Hacker 4 CERTIFICATE OF SERVICE I hereby certify that this document, filed through the ECF system will be sent electronically to the registered participants as identified in the Notice of Electronic Filing (NEF) and paper copies will be sent to those indicated as non-registered participants on this 27th day of October, 2018. /s/ Katherine L.I. Hacker 5

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