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`UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF MASSACHUSETTS
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`NATIONAL ASSOCIATION OF THE DEAF,
`on behalf of its members, C. WAYNE DORE,
`CHRISTY SMITH, and LEE NETTLES, on
`behalf of themselves and a proposed class of
`similarly situated persons defined below,
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`Plaintiffs,
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`Civil Action No. 15-30024-KAR
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`MASSACHUSETTS INSTITUTE OF
`TECHNOLOGY,
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`v.
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`Defendant.
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`DEFENDANT MASSACHUSETTS INSTITUTE OF TECHNOLOGY’S
`MOTION FOR JUDGMENT ON THE PLEADINGS
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`Pursuant to Rule 12(c) of the Federal Rules of Civil Procedure, Defendant Massachusetts
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`Institute of Technology (“MIT”) hereby moves for judgment on the pleadings as to all claims
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`alleged in the Complaint filed by Plaintiffs National Association of the Deaf, C. Wayne Dore,
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`Christy Smith, and Lee Nettles (“Plaintiffs”). This Court should enter judgment in favor of MIT
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`and against Plaintiffs for the reasons stated in the accompanying memorandum of law.
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`REQUEST FOR ORAL ARGUMENT
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`Pursuant to Local Rule 7.1(d), MIT respectfully requests oral argument. MIT believes
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`that oral argument will assist the Court in deciding the issues presented in this Motion and the
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`accompanying memorandum.
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`Case 3:15-cv-30024-KAR Document 148 Filed 08/24/18 Page 2 of 3
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`Dated: August 24, 2018
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`Respectfully submitted,
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`/s/ Roberto M. Braceras
`Roberto M. Braceras (BBO# 566816)
`Jennifer B. Luz (BBO# 657739)
`GOODWIN PROCTER LLP
`100 Northern Avenue
`Boston, Massachusetts 02210
`Tel.: 617.570.1000
`Fax: 617.523.1231
`rbraceras@goodwinlaw.com
`jluz@goodwinlaw.com
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`William M. Jay (pro hac vice)
`Andrew Kim (pro hac vice)
`901 New York Avenue, N.W.
`Washington, DC 20001
`Tel.: 202.346.4000
`Fax: 202.346.4444
`wjay@goodwinlaw.com
`andrewkim@goodwinlaw.com
`
`Janet Grumer (pro hac vice)
`DAVIS WRIGHT TREMAINE LLP
`865 S. Figueroa Street, Suite 2400
`Los Angeles, CA 90017
`Tel.: 213.633.6866
`Fax: 213.633.4231
`janetgrumer@dwt.com
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`Attorneys for Defendant
`Massachusetts Institute of Technology
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`Case 3:15-cv-30024-KAR Document 148 Filed 08/24/18 Page 3 of 3
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` LOCAL RULE 7.1(A)(2) CERTIFICATION AND CERTIFICATE OF SERVICE
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`I hereby certify that counsel for Defendant conferred with opposing counsel in an effort
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`to resolve or narrow the issues presented in this Motion prior to filing.
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`I also certify that a copy of the foregoing document, filed through the CM/ECF system,
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`will be sent electronically to the registered participants as identified on the Notice of Electronic
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`Filing (NEF), and paper copies shall be served by first class mail, postage prepaid, on all counsel
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`who are not served through the CM/ECF system on August 24, 2018.
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`/s/ Roberto M. Braceras
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