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

Filing 90

MOTION to Stay Proceedings Pending Appeal by M. B., K. C., Sarah Cole, Y. D., G. E., A. G., I. G., R. H., J. L., Fadhal Moore, Arjini Kumari Nawal, R. S., Itzel Vasquez-Rodriguez, Keyanna Wigglesworth.(Lane, Priya)

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.

PROPOSED DEFENDANT-INTERVENORS’
MOTION TO STAY PROCEEDINGS PENDING APPEAL
Consistent with the Notice of Appeal filed July 13, 2015 (Docket No. 60), and for the
reasons set forth more fully in the accompanying memorandum, Proposed Defendant-Intervenors
M.B., K.C., Y.D., G.E., A.G., I.G., R.H., J.L., R.S., Sarah Cole, Fadhal Moore, Arjini Kumari
Nawal, Itzel Libertad Vasquez-Rodriguez, and Keyanna Wigglesworth (“the Students”)
respectfully move to stay this litigation while the First Circuit resolves whether they have the
right to intervene as parties to this case. The Students additionally support Harvard’s Motion to
Stay proceedings while the Supreme Court decides Fisher v. University of Texas at Austin, No.
14-981(Fisher II ) (Docket No. 58) because that stay would largely overlap with a stay pending
appeal.
Respectfully submitted,
Dated: August 5, 2015

/s/ Priya A. Lane
Priya A. Lane, BBO # 688499

LAWYERS’ COMMITTEE FOR CIVIL
RIGHTS AND ECONOMIC JUSTICE
294 Washington St. Suite 443
Boston, MA 02108
Tel: [phone]
[e-mail]

Jon M. Greenbaum
LAWYERS’ COMMITTEE FOR CIVIL
RIGHTS UNDER LAW
1401 New York Avenue, NW, Suite 400
Washington, DC 20005
Tel: [phone]

Lawrence E. Culleen
Steven L. Mayer
Nancy L. Perkins
ARNOLD & PORTER, LLP
555 12th Street, NW
Washington, D.C. 20004
Tel: [phone]

ATTORNEYS FOR PROPOSED
DEFENDANT-INTERVENORS

2

CERTIFICATE OF CONFERENCE
In accordance with Local Rule 7.1(a), I hereby certify that I conferred in good faith with
counsel for Plaintiff and Defendant in connection with this motion and have been unable to
resolve or narrow the issues presented by this motion.

/s/ Jon M. Greenbaum
Jon M. Greenbaum

CERTIFICATE OF SERVICE
In accordance with Local Rule 5.2(b), I hereby certify that this document filed through
the ECF system on August 5, 2015 will be sent electronically to the registered participants as
identified on the Notice of Electronic Filing.
/s/ Priya A. Lane
Priya A. Lane