Assented to Motion for Leave to File Excess Pages by Massachusetts Institute of Technology.(Bhabha, Ishan)

Michel DeGraff,

Plaintiff, v. Massachusetts Institute of Technology; Tim Walberg in his official capacity as the Chairman of the House Committee on Education & Workforce; and The House Committee on Education & Workforce,

Defendants.

Defendant Massachusetts Institute of Technology (“MIT”) hereby requests leave to file an opening memorandum of no more than 25 pages in support of its forthcoming motion to dismiss Count I of Plaintiff’s Complaint. Counsel for MIT has conferred with counsel for the other parties, none of whom oppose this request. On May 7, 2026, this Court granted the Congressional Defendants’ request to file a 25-page memorandum in support of their anticipated motion to dismiss.

MIT respectfully submits that permitting a memorandum of up to 25 pages is warranted given the substantial number of allegations and issues the moving papers will need to address. The Complaint contains 170 paragraphs of factual allegations across approximately 55 pages, the vast majority of which relate to DeGraff’s First Amendment claim against MIT and the Committee (Count I). MIT intends to raise multiple distinct bases for dismissal of that claim. Under these circumstances, a modest expansion of the usual page limit, from 20 to 25 pages, is warranted to ensure that MIT can clearly and comprehensively present its arguments to this Court, so as to aid the Court in its resolution of the motion to dismiss.

WHEREFORE, MIT requests that the Court enter an order allowing MIT to submit a memorandum of up to 25 pages in support of its forthcoming motion to dismiss Count I of the Complaint. Date: June 2, 2026 Daniel J. Cloherty (BBO# 565772) Email: [email protected] Telephone: (617) 481-0610 Alexandra Arnold (BBO# 706208) Email: [email protected] Telephone: (617) 481-0610

One Financial Center, Suite 1120 Boston, MA 02111

Respectfully submitted, MASSACHUSETTS INSTITUTE OF TECHNOLOGY /s/ Ishan K. Bhabha Ishan K. Bhabha (pro hac vice) Email: [email protected] Telephone: (202) 637-6327 Lauren J. Hartz (pro hac vice) Email: [email protected] Telephone: (202) 637-6363 Elizabeth Henthorne (pro hac vice) Email: [email protected] Telephone: (202) 637-6367 JENNER & BLOCK LLP 1099 New York Avenue, N.W., Suite 900 Washington, DC 20001 CERTIFICATE OF COMPLIANCE

Pursuant to Local Rule 7.1(a), I hereby certify that counsel for MIT has conferred with counsel of record for all parties about the filing of this motion. As set forth above, counsel for Plaintiff and counsel for the Congressional Defendants indicated they do not oppose the relief sought.

/s/ Ishan K. Bhabha Ishan K. Bhabha CERTIFICATE OF SERVICE

I, Ishan Bhabha, hereby certify that a true copy of this document filed through the ECF system will be sent electronically to the registered participants as identified on the Notice of Electronic Filing (NEF) on June 2, 2026.

/s/ Ishan K. Bhabha Ishan K. Bhabha