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

Filing 64

MOTION to Compel Production by Students for Fair Admissions, Inc..(Caldwell, Benjamin)

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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), REQUEST FOR ORAL ARGUMENT Defendant. PLAINTIFF’S MOTION TO COMPEL PRODUCTION Pursuant to Local Rules 7.1(b) and 37.1, Plaintiff, Students for Fair Admissions, Inc. (“SFFA”), hereby moves this Honorable Court for an order compelling Defendant, the President and Fellows of Harvard College (“Harvard”), to comply with certain Requests for Production of Documents SFFA served on Harvard (“Requests”). Specifically, SFFA seeks an order requiring Harvard to provide (a) a preliminary sample of 6,400 application files consistent with Request No. 24, (b) the names of a subset of alumni interviewers as set forth in Request No. 19, and (c) documents regarding Harvard’s transfer admissions process on the same terms Harvard produces information regarding its freshman admission process. In support thereof, SFFA relies upon the accompanying Memorandum of Law (including exhibits appended to the declaration from SFFA’s counsel). WHEREFORE, SFFA respectfully requests that the Court enter a 20-day order compelling Harvard to: (a) comply fully with Requests Nos. 19 and 24; (b) to produce documents regarding its transfer admissions process on the same terms it produces 1 information regarding its freshman admission process in response to the Requests; and (c) grant such other and further relief as the Court sees fit. Respectfully submitted, By: /s/ William S. Consovoy William S. Consovoy Paul M. Sanford BBO #566318 Benjamin C. Caldwell BBO #675061 BURNS & LEVINSON LLP One Citizens Plaza, Suite 1100 Providence, RI 02903 Tel: 617-345-3000 Fax: 617-345-3299 William S. Consovoy Thomas R. McCarthy J. Michael Connolly CONSOVOY MCCARTHY PARK PLLC 3033 Wilson Boulevard, Suite 700 Arlington, Virginia 22201 Tel: 703-243-4923 Fax: 703.243.4923 Dated: July 16, 2015 Patrick Strawbridge BBO #678274 CONSOVOY MCCARTHY PARK PLLC Ten Post Office Square 8th Floor South PMB #706 Boston, MA 02109 Tel: 617-227-0548 Counsel for Plaintiff Students for Fair Admissions, Inc. 2 CERTIFICATE OF CONFERENCE In accordance with Local Rules 7.1(a) and 37.1, I hereby certify that I conferred and attempted in good faith to resolve or narrow the issues set forth in this motion with Defendant’s counsel, including via telephone on June 23, 2015, and subsequent e-mail correspondence. /s/ Patrick Strawbridge Patrick Strawbridge CERTIFICATE OF SERVICE In accordance with Local Rule 5.2(b), I hereby certify that this document was filed through the Court’s ECF system on July 16, 2015 will be sent electronically to the registered participants identified on the Notice of Electronic Filing. /s/ Patrick Strawbridge Patrick Strawbridge 4845-8904-1189.1 3

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