Case: The Louis D. Brandeis Center for Human Rights Under Law v. President and Fellows of Harvard College

The Louis D. Brandeis Center for Human Rights Under Law and Jewish Americans for Fairness in Education v. President and Fellows of Harvard College

COMPLAINT against President and Fellows of Harvard College Filing fee: $ 405, receipt number AMADC-10429356 (Fee Status: Filing Fee paid), filed by Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law. (Attachments: # 1 Exhibit A, # 2 Exhibit A-1, # 3 Exhibit A-2, # 4 Exhibit A-3, # 5 Exhibit A-4, # 6 Exhibit B, # 7 Exhibit C, # 8 Exhibit D, # 9 Exhibit E, # 10 Exhibit F, # 11 Exhibit G, # 12 Exhibit H, # 13 Exhibit I, # 14 Exhibit J, # 15 Exhibit K, # 16 Exhibit L, # 17 Exhibit M, # 18 Exhibit N, # 19 Exhibit O, # 20 Civil Cover Sheet, # 21 Category Form)(Sivitz, Rebecca) (Entered: 05/22/2024)

1 Exhibit A

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2 Exhibit A-1

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3 Exhibit A-2

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4 Exhibit A-3

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5 Exhibit A-4

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6 Exhibit B

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7 Exhibit C

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8 Exhibit D

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9 Exhibit E

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10 Exhibit F

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11 Exhibit G

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12 Exhibit H

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13 Exhibit I

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14 Exhibit J

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15 Exhibit K

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16 Exhibit L

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17 Exhibit M

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18 Exhibit N

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19 Exhibit O

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20 Civil Cover Sheet

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21 Category Form

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CORPORATE DISCLOSURE STATEMENT by Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law. (Sivitz, Rebecca) (Entered: 05/22/2024)

NOTICE by Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law re Local Rule 40.1(g)(5)(B) Certification of Relatedness (Sivitz, Rebecca) (Entered: 05/22/2024)

MOTION for Leave to Appear Pro Hac Vice for admission of Jonathan D. Polkes Filing fee: $ 125, receipt number AMADC-10429545 by Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law.(Sivitz, Rebecca) (Main Document 4 replaced on 5/23/2024) (McManus, Caetlin). (Additional attachment(s) added on 5/23/2024: # 1 Certification) (McManus, Caetlin). (Entered: 05/22/2024)

MOTION for Leave to Appear Pro Hac Vice for admission of Kenneth L. Marcus Filing fee: $ 125, receipt number AMADC-10429567 by Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law.(Sivitz, Rebecca) (Main Document 5 replaced on 5/23/2024) (McManus, Caetlin). (Additional attachment(s) added on 5/23/2024: # 1 Certification) (McManus, Caetlin). (Entered: 05/22/2024)

MOTION for Leave to Appear Pro Hac Vice for admission of Lora Rachel Lerman Filing fee: $ 125, receipt number AMADC-10429580 by Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law.(Sivitz, Rebecca) (Main Document 6 replaced on 5/23/2024) (McManus, Caetlin). (Additional attachment(s) added on 5/23/2024: # 1 Certification) (McManus, Caetlin). (Entered: 05/22/2024)

ELECTRONIC NOTICE of Case Assignment. Judge Richard G. Stearns assigned to case. If the trial Judge issues an Order of Reference of any matter in this case to a Magistrate Judge, the matter will be transmitted to Magistrate Judge M. Page Kelley. (Cook, Savannah) (Entered: 05/22/2024)

Notice of Case Assignment

Summons Issued as to All Defendants. Counsel receiving this notice electronically should download this summons, complete one for each defendant and serve it in accordance with Fed.R.Civ.P. 4 and LR 4.1. Summons will be mailed to plaintiff(s) not receiving notice electronically for completion of service. (Cowan, Nicole) (Entered: 05/23/2024)

Judge Richard G. Stearns: ELECTRONIC ORDER entered granting 4 Motion for Leave to Appear Pro Hac Vice Added Jonathan D. Polkes. Attorneys admitted Pro Hac Vice must have an individual upgraded PACER account, not a shared firm account, to electronically file in the District of Massachusetts. Counsel may need to link their CM/ECF account to their upgraded individual pacer account. Instructions on how to link CM/ECF accounts to upgraded pacer account can be found at https://www.mad.uscourts.gov/caseinfo/nextgen-current-pacer-accounts.htm#link-account. (McManus, Caetlin) (Entered: 05/23/2024)

Judge Richard G. Stearns: ELECTRONIC ORDER entered granting 5 Motion for Leave to Appear Pro Hac Vice Added Kenneth L. Marcus. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. To register for a PACER account, go the Pacer website at https://pacer.uscourts.gov/register-account. You must put the docket number under ADDITIONAL FILER INFORMATION on your form when registering or it will be rejected.Pro Hac Vice Admission Request Instructions https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by the newly admitted attorney. (McManus, Caetlin) (Entered: 05/23/2024)

Judge Richard G. Stearns: ELECTRONIC ORDER entered granting 6 Motion for Leave to Appear Pro Hac Vice Added Lora Rachel Lerman. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. To register for a PACER account, go the Pacer website at https://pacer.uscourts.gov/register-account. You must put the docket number under ADDITIONAL FILER INFORMATION on your form when registering or it will be rejected.Pro Hac Vice Admission Request Instructions https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by the newly admitted attorney. (McManus, Caetlin) (Entered: 05/23/2024)

MOTION for Leave to Appear Pro Hac Vice for admission of Jared R. Friedmann Filing fee: $ 125, receipt number AMADC-10432163 by Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law.(Sivitz, Rebecca) (Main Document 12 replaced on 5/28/2024) (McManus, Caetlin). (Additional attachment(s) added on 5/28/2024: # 1 Exhibit A - Certification) (McManus, Caetlin). (Entered: 05/23/2024)

MOTION for Leave to Appear Pro Hac Vice for admission of Mark Pinkert Filing fee: $ 125, receipt number AMADC-10432178 by Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law.(Sivitz, Rebecca) (Main Document 13 replaced on 5/28/2024) (McManus, Caetlin). (Additional attachment(s) added on 5/28/2024: # 1 Exhibit A - Certification) (McManus, Caetlin). (Entered: 05/23/2024)

Order on Motion for Leave to Appear

NOTICE of Appearance by Douglas S. Brooks on behalf of Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law (Brooks, Douglas) (Entered: 05/28/2024)

MOTION for Leave to Appear Pro Hac Vice for admission of Jason Torchinsky Filing fee: $ 125, receipt number AMADC-10436115 by Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law. (Attachments: # 1 Declaration ISO PHV)(Brooks, Douglas) (Attachment 1 replaced on 5/28/2024) (McManus, Caetlin). (Entered: 05/28/2024)

Judge Richard G. Stearns: ELECTRONIC ORDER entered granting 12 Motion for Leave to Appear Pro Hac Vice of Jared R. Friedmann. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. To register for a PACER account, go the Pacer website at https://pacer.uscourts.gov/register-account. You must put the docket number under ADDITIONAL FILER INFORMATION on your form when registering or it will be rejected.Pro Hac Vice Admission Request Instructions https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by the newly admitted attorney. (McManus, Caetlin) (Entered: 05/28/2024)

Judge Richard G. Stearns: ELECTRONIC ORDER entered granting 13 Motion for Leave to Appear Pro Hac Vice of Mark Pinkert. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. To register for a PACER account, go the Pacer website at https://pacer.uscourts.gov/register-account. You must put the docket number under ADDITIONAL FILER INFORMATION on your form when registering or it will be rejected.Pro Hac Vice Admission Request Instructions https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by the newly admitted attorney. (McManus, Caetlin) (Entered: 05/28/2024)

MOTION for Leave to Appear Pro Hac Vice for admission of Jonathan Lienhard Filing fee: $ 125, receipt number AMADC-10436351 by Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law. (Attachments: # 1 Declaration ISO PHV)(Brooks, Douglas) (Entered: 05/28/2024)

MOTION for Leave to Appear Pro Hac Vice for admission of Jonathan Vogel Filing fee: $ 125, receipt number AMADC-10436393 by Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law. (Attachments: # 1 Declaration ISO PHV)(Brooks, Douglas) (Entered: 05/28/2024)

Judge Richard G. Stearns: ELECTRONIC ORDER entered granting 15 Motion for Leave to Appear Pro Hac Vice Added Jason Torchinsky. Attorneys admitted Pro Hac Vice must have an individual upgraded PACER account, not a shared firm account, to electronically file in the District of Massachusetts. Counsel may need to link their CM/ECF account to their upgraded individual pacer account. Instructions on how to link CM/ECF accounts to upgraded pacer account can be found at https://www.mad.uscourts.gov/caseinfo/nextgen-current-pacer-accounts.htm#link-account. (McManus, Caetlin) (Entered: 05/28/2024)

MOTION for Leave to Appear Pro Hac Vice for admission of John J. Cycon Filing fee: $ 125, receipt number AMADC-10436598 by Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law. (Attachments: # 1 Declaration ISO PHV)(Brooks, Douglas) (Entered: 05/28/2024)

Order on Motion for Leave to Appear

Judge Richard G. Stearns: ELECTRONIC ORDER entered granting 18 Motion for Leave to Appear Pro Hac Vice of Jonathan Lienhard. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. To register for a PACER account, go the Pacer website at https://pacer.uscourts.gov/register-account. You must put the docket number under ADDITIONAL FILER INFORMATION on your form when registering or it will be rejected.Pro Hac Vice Admission Request Instructions https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by the newly admitted attorney. (McManus, Caetlin) (Entered: 05/29/2024)

Judge Richard G. Stearns: ELECTRONIC ORDER entered granting 19 Motion for Leave to Appear Pro Hac Vice of Jonathan Vogel. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. To register for a PACER account, go the Pacer website at https://pacer.uscourts.gov/register-account. You must put the docket number under ADDITIONAL FILER INFORMATION on your form when registering or it will be rejected.Pro Hac Vice Admission Request Instructions https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by the newly admitted attorney. (McManus, Caetlin) (Entered: 05/29/2024)

Judge Richard G. Stearns: ELECTRONIC ORDER entered granting 21 Motion for Leave to Appear Pro Hac Vice of John J. Cycon. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. To register for a PACER account, go the Pacer website at https://pacer.uscourts.gov/register-account. You must put the docket number under ADDITIONAL FILER INFORMATION on your form when registering or it will be rejected.Pro Hac Vice Admission Request Instructions https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by the newly admitted attorney. (McManus, Caetlin) (Entered: 05/29/2024)

Order on Motion for Leave to Appear

NOTICE of Appearance by Jonathan D. Polkes on behalf of Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law (Polkes, Jonathan) (Entered: 05/30/2024)

WAIVER OF SERVICE Returned Executed by The Louis D. Brandeis Center for Human Rights Under Law, Jewish Americans for Fairness in Education. Jewish Americans for Fairness in Education waiver sent on 5/23/2024, answer due 7/22/2024. (Polkes, Jonathan) (Entered: 05/30/2024)

NOTICE of Appearance by Jared R. Friedmann on behalf of Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law (Friedmann, Jared) (Entered: 05/30/2024)

NOTICE of Appearance by Mark Pinkert on behalf of Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law (Pinkert, Mark) (Entered: 05/30/2024)

MOTION for Leave to Appear Pro Hac Vice for admission of Erielle Davidson Filing fee: $ 125, receipt number AMADC-10440955 by Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law. (Attachments: # 1 Declaration ISO PHV)(Brooks, Douglas) (Entered: 05/30/2024)

MOTION for Leave to Appear Pro Hac Vice for admission of Mohammad O. Jazil Filing fee: $ 125, receipt number AMADC-10440963 by Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law. (Attachments: # 1 Declaration ISO PHV)(Brooks, Douglas) (Entered: 05/30/2024)

NOTICE of Appearance by Jonathan Vogel on behalf of Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law (Vogel, Jonathan) (Entered: 05/31/2024)

Judge Richard G. Stearns: ELECTRONIC ORDER entered granting 29 Motion for Leave to Appear Pro Hac Vice of Erielle Davidson. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. To register for a PACER account, go the Pacer website at https://pacer.uscourts.gov/register-account. You must put the docket number under ADDITIONAL FILER INFORMATION on your form when registering or it will be rejected.Pro Hac Vice Admission Request Instructions https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by the newly admitted attorney. (McManus, Caetlin) (Entered: 05/31/2024)

Judge Richard G. Stearns: ELECTRONIC ORDER entered granting 30 Motion for Leave to Appear Pro Hac Vice of Mohammad O. Jazil. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. To register for a PACER account, go the Pacer website at https://pacer.uscourts.gov/register-account. You must put the docket number under ADDITIONAL FILER INFORMATION on your form when registering or it will be rejected.Pro Hac Vice Admission Request Instructions https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by the newly admitted attorney. (McManus, Caetlin) (Entered: 05/31/2024)

Order on Motion for Leave to Appear

NOTICE of Appearance by Jonathan Lienhard on behalf of Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law (Lienhard, Jonathan) (Entered: 06/03/2024)

NOTICE of Appearance by Mohammad Omar Jazil on behalf of Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law (Jazil, Mohammad) (Entered: 06/04/2024)

NOTICE of Appearance by John Cycon on behalf of Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law (Cycon, John) (Entered: 06/06/2024)

NOTICE of Appearance by Jason Brett Torchinsky on behalf of Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law (Torchinsky, Jason) (Entered: 06/06/2024)

NOTICE of Appearance by Felicia H. Ellsworth on behalf of President and Fellows of Harvard College (Ellsworth, Felicia) (Entered: 06/10/2024)

CORPORATE DISCLOSURE STATEMENT by President and Fellows of Harvard College. (Ellsworth, Felicia) (Entered: 06/10/2024)

Filed in error Modified on 6/11/2024 (McManus, Caetlin). (Entered: 06/11/2024)

Consolidate Cases

NOTICE of Appearance by Erielle Davidson on behalf of Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law (Davidson, Erielle) (Entered: 06/13/2024)

MOTION for Leave to Appear Pro Hac Vice for admission of Bruce M. Berman Filing fee: $ 125, receipt number AMADC-10514799 by President and Fellows of Harvard College. (Attachments: # 1 Certification in Support)(Ellsworth, Felicia) (Entered: 07/19/2024)

MOTION for Leave to Appear Pro Hac Vice for admission of Jeremy W. Brinster Filing fee: $ 125, receipt number AMADC-10514828 by President and Fellows of Harvard College. (Attachments: # 1 Certification in Support)(Ellsworth, Felicia) (Entered: 07/19/2024)

MOTION for Leave to Appear Pro Hac Vice for admission of Seth P. Waxman Filing fee: $ 125, receipt number AMADC-10514866 by President and Fellows of Harvard College. (Attachments: # 1 Certification in Support)(Ellsworth, Felicia) (Entered: 07/19/2024)

MOTION for Leave to Appear Pro Hac Vice for admission of Mark A. Kirsch Filing fee: $ 125, receipt number AMADC-10514879 by President and Fellows of Harvard College. (Attachments: # 1 Certification in Support)(Ellsworth, Felicia) (Entered: 07/19/2024)

Judge Richard G. Stearns: ELECTRONIC ORDER entered granting 42, 43, 44, and 45, Motions for Leave to Appear Pro Hac Vice of Bruce M. Berman, Jeremy W. Brinster, Seth P. Waxman, and Mark A. Kirsch. Attorneys admitted Pro Hac Vice must have an individual upgraded PACER account, not a shared firm account, to electronically file in the District of Massachusetts. Counsel may need to link their CM/ECF account to their upgraded individual pacer account. Instructions on how to link CM/ECF accounts to upgraded pacer account can be found at https://www.mad.uscourts.gov/caseinfo/nextgen-current-pacer-accounts.htm#link-account. (McManus, Caetlin) (Entered: 07/22/2024)

MOTION to Dismiss by President and Fellows of Harvard College.(Ellsworth, Felicia) (Entered: 07/22/2024)

MEMORANDUM in Support re 47 MOTION to Dismiss filed by President and Fellows of Harvard College. (Ellsworth, Felicia) (Entered: 07/22/2024)

DECLARATION re 47 MOTION to Dismiss of Meredith Weenick in Support by President and Fellows of Harvard College. (Ellsworth, Felicia) (Entered: 07/22/2024)

DECLARATION re 47 MOTION to Dismiss of Felicia Ellsworth in Support by President and Fellows of Harvard College. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13)(Ellsworth, Felicia) (Entered: 07/22/2024)

Order on Motion for Leave to Appear AND Order on Motion for Leave to Appear AND Order on Motion for Leave to Appear AND Order on Motion for Leave to Appear

Assented to MOTION for Extension of Time to August 30, 2024 to File Response to Defendant's Motion to Dismiss by Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law.(Polkes, Jonathan) Modified on 7/25/2024 (McManus, Caetlin). (Entered: 07/24/2024)

Judge Richard G. Stearns: ELECTRONIC ORDER entered granting 51 MOTION for Extension of Time to File Response/Reply to 47 MOTION to Dismiss. Response due by 8/30/2024. (McManus, Caetlin) (Entered: 07/25/2024)

Order on Motion for Extension of Time to File Response/Reply

MEMORANDUM in Opposition re 47 MOTION to Dismiss filed by Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law. (Polkes, Jonathan) (Entered: 08/30/2024)

MOTION for Leave to File a Reply Memorandum in Support of Motion to Dismiss by President and Fellows of Harvard College.(Ellsworth, Felicia) (Entered: 09/03/2024)

Judge Richard G. Stearns: ELECTRONIC ORDER entered granting 54 Motion for Leave to File Document. Defendant may file a reply brief of no more than 10 pages by September 10, 2024. (RGS, law3) (Entered: 09/04/2024)

Order on Motion for Leave to File Document

ELECTRONIC NOTICE Setting Hearing on Motion 47 MOTION to Dismiss : Motion Hearing set for 10/23/2024 10:00 AM in Courtroom 21 (In person only) before Judge Richard G. Stearns. (Maynard, Timothy) (Entered: 09/10/2024)

ENTRY DELETED - FILED IN ERROR. Modified on 9/10/2024 (Maynard, Timothy). (Entered: 09/10/2024)

REPLY to Response to 47 MOTION to Dismiss filed by President and Fellows of Harvard College. (Ellsworth, Felicia) (Entered: 09/10/2024)

Notice of Hearing

Notice Setting or Resetting Hearing on Motion

MOTION for Leave to File Request for Judicial Notice in Support of Plaintiffs' Opposition to Defendant's Motion to Dismiss the Complaint by Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law. (Attachments: # 1 Proposed Request for Judicial Notice, # 2 Exhibit A (Audio file, lodged with the Court))(Polkes, Jonathan) (Entered: 10/11/2024)

1 Proposed Request for Judicial Notice

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2 Exhibit A (Audio file, lodged with the Court)

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MOTION for Leave to Appear Pro Hac Vice for admission of Milana Bretgoltz Filing fee: $ 125, receipt number AMADC-10646736 by Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law. (Attachments: # 1 Exhibit A - Declaration of Milana Bretgoltz)(Sivitz, Rebecca) (Entered: 10/11/2024)

MOTION for Leave to Appear Pro Hac Vice for admission of Shai Berman Filing fee: $ 125, receipt number AMADC-10646804 by Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law. (Attachments: # 1 Exhibit A - Declaration of Shai Berman)(Sivitz, Rebecca) (Entered: 10/11/2024)

MOTION for Leave to Appear Pro Hac Vice for admission of Daniel Lifton Filing fee: $ 125, receipt number AMADC-10646825 by Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law. (Attachments: # 1 Exhibit A - Declaration of Daniel Lifton)(Sivitz, Rebecca) (Entered: 10/11/2024)

MOTION for Leave to Appear Pro Hac Vice for admission of Alli G. Katzen Filing fee: $ 125, receipt number AMADC-10646841 by Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law. (Attachments: # 1 Exhibit A - Declaration of Alli G. Katzen)(Sivitz, Rebecca) (Entered: 10/11/2024)

Judge Richard G. Stearns: ELECTRONIC ORDER entered granting 60 Motion for Leave to Appear Pro Hac Vice Added Milana Bretgoltz. granting 61 Motion for Leave to Appear Pro Hac Vice Added Shai Berman. granting 62 Motion for Leave to Appear Pro Hac Vice Added Daniel Lifton. granting 63 Motion for Leave to Appear Pro Hac Vice Added Alli G. Katzen. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. To register for a PACER account, go the Pacer website at https://pacer.uscourts.gov/register-account. You must put the docket number under ADDITIONAL FILER INFORMATION on your form when registering or it will be rejected.Pro Hac Vice Admission Request Instructions https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by the newly admitted attorney. (Martin, Jacqueline) (Entered: 10/15/2024)

Order on Motion for Leave to Appear AND Order on Motion for Leave to Appear AND Order on Motion for Leave to Appear AND Order on Motion for Leave to Appear

Opposition re 59 MOTION for Leave to File Request for Judicial Notice in Support of Plaintiffs' Opposition to Defendant's Motion to Dismiss the Complaint filed by President and Fellows of Harvard College. (Ellsworth, Felicia) (Entered: 10/16/2024)

NOTICE of Appearance by Milana Bretgoltz on behalf of Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law (Bretgoltz, Milana) (Entered: 10/17/2024)

NOTICE of Appearance by Shai Berman on behalf of Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law (Berman, Shai) (Entered: 10/17/2024)

NOTICE of Appearance by Daniel Lifton on behalf of Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law (Lifton, Daniel) (Entered: 10/17/2024)

NOTICE of Appearance by Alli Katzen on behalf of Jewish Americans for Fairness in Education, The Louis D. Brandeis Center for Human Rights Under Law (Katzen, Alli) (Entered: 10/17/2024)

Judge Richard G. Stearns: ELECTRONIC ORDER entered denying 59 Motion for Leave to File Document. Although the incident may have some relevance to the litigation at some point in the future, it is not the proper subject matter for judicial notice at this stage. See United States v. Bello, 194 F.3d 18, 23 (1st Cir. 1999) ("A high degree of indisputability is the essential prerequisite.") (emphasis in original), quoting Fed. R. Evid. 201, advisory committee's note. (RGS, law3) (Entered: 10/17/2024)

Order on Motion for Leave to File Document

Electronic Clerk's Notes for proceedings held before Judge Richard G. Stearns: Motion Hearing held on 10/23/2024 re 47 MOTION to Dismiss filed by President and Fellows of Harvard College. Court hears argument from the parties; The court takes the matter under advisement. (Court Reporter: Robert Paschal at rwp.reporter@gmail.com.)(Attorneys present: Polkes, Waxman) (Maynard, Timothy) (Entered: 10/23/2024)

NOTICE of Change of Address or Firm Name by Mark Pinkert (Pinkert, Mark) (Entered: 10/23/2024)

Motion Hearing

Judge Richard G. Stearns: ORDER entered granting in part and denying in part 47 Motion to Dismiss. Counts I and III are dismissed. Count II shall proceed to discovery. (RGS, law3)

Judge Richard G. Stearns: ELECTRONIC ORDER entered granting (68) Motion to Consolidate. The court will allow the unopposed portion of Harvard's motion and consolidate case numbers 24-cv-10092 and 24-cv-11354 for discovery purposes. The Clerk will issue a new/revised scheduling order establishing joint discovery deadlines. The court reserves ruling on the partially opposed portion of the motion given the nascency of the cases. Harvard may renew its motion to consolidate the cases for the purposes of motions practice at the close of fact discovery. (RGS, law3) (Entered: 11/05/2024)

Order on Motion to Consolidate Cases

Judge Richard G. Stearns: ELECTRONIC ORDER entered. The court having allowed the unopposed portion of Harvard's motion and consolidated case numbers 24-cv-10092 and 24-cv-11354 for discovery purposes, the court enters the following pretrial schedule in both cases.Initial disclosures required by Fed. R. Civ. P. 26(a)(1) (already completed in 24-10092) must be completed in 24-11354 by 11/27/24. All amendments to the pleadings and/or joinder of additional parties shall be completed by 12/6/24. The court will permit 30 interrogatories, 30 requests for admissions and 30 document requests without leave of court and expects those requests to be filed with the opposing counsel within 30 days of the initial disclosures (no later than 12/27/24). If the parties would like to participate in the court's mediation program, they must notify our docket clerk Jacqueline Martin (617-748-4647) by 5/10/25 (it may take several weeks to get a mediation date). All fact discovery must be completed no later than 5/23/25.Dispositive motions (if any) are due no later than 6/19/25, with Oppositions due no later than 7/10/25; a Reply may be filed only with leave of court.If a party intends to utilize an expert, they must file a notice on the docket no later than 5/14/25, in order for the court to consider whether an expert is appropriate (party must offer basic Fed. R. Evid. 702 and 703 information) and, if so, to alter the existing schedule. Associated Cases: 1:24-cv-11354-RGS, 1:24-cv-10092-RGS(Zierk, Marsha) (Entered: 11/06/2024)

Transcript of Motion Hearing held on October 23, 2024, before Judge Richard G. Stearns. The Transcript may be purchased through the Court Reporter, viewed at the public terminal, or viewed through PACER after it is released. Court Reporter Name and Contact Information: Robert Paschal at rwp.reporter@gmail.com. Redaction Request due 11/27/2024. Redacted Transcript Deadline set for 12/9/2024. Release of Transcript Restriction set for 2/4/2025. (Kelly, Danielle) (Entered: 11/07/2024)

NOTICE is hereby given that an official transcript of a proceeding has been filed by the court reporter in the above-captioned matter. Counsel are referred to the Court's Transcript Redaction Policy, available on the court website at https://www.mad.uscourts.gov/caseinfo/transcripts.htm (Kelly, Danielle) (Entered: 11/07/2024)

Order

Notice of Filing of Official Transcript

Assented to MOTION for Extension of Time to December 10, 2024 to File Answer re 1 Complaint,, by President and Fellows of Harvard College.(Ellsworth, Felicia) (Entered: 11/11/2024)

Judge Richard G. Stearns: ELECTRONIC ORDER entered granting 78 Motion for Extension of Time. Harvard's Answer is due December 10, 2024. (RGS, law3) (Entered: 11/12/2024)

Order on Motion for Extension of Time to Answer

ANSWER to 1 Complaint,, by President and Fellows of Harvard College.(Ellsworth, Felicia) (Entered: 12/10/2024)

STIPULATION of Dismissal with Prejudice by President and Fellows of Harvard College. (Attachments: # 1 Exhibit)(Ellsworth, Felicia) (Entered: 01/21/2025)

1 Exhibit

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