Joint Motion for Leave to File Reply Briefs in Support of Motions to Dismiss 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,

Pursuant to Local Rule 7.1(b)(3), Defendants Massachusetts Institute of Technology; Tim Walberg in his official capacity as the Chairman of the House Committee on Education and Workforce; and the House Committee on Education and Workforce (collectively, “Defendants”) respectfully seek leave to submit separate 15-page reply briefs in support of their respective Motions to Dismiss Count I of Plaintiff’s Complaint (ECF Nos. 36, 38). Defendants are prepared to file their proposed reply briefs by July 24, 2026. Counsel for Defendants have conferred with counsel for Plaintiff Michel DeGraff, who does not oppose Defendants’ request.

Reply briefs are necessary because, in his opposition briefs (ECF Nos. 46, 47), Plaintiff raises legal and factual arguments against dismissal that were not addressed in Defendants’ opening briefs and warrant focused responses. Defendants respectfully submit that reply briefs succinctly addressing these points will assist the Court in its resolution of the pending motions. Granting Defendants’ motion will not cause delay in the consideration of these issues because Defendants will file their reply briefs within 22 days of the filing of Plaintiff’s opposition briefs, and no hearing on Defendants’ motions has yet been scheduled.

WHEREFORE, Defendants respectfully request that the Court grant their unopposed joint motion for leave to file separate 15-page reply briefs in support of their Motions to Dismiss Count I of the Complaint by July 24, 2026. Date: July 6, 2026

/s/ Matthew B. Berry Matthew B. Berry General Counsel Todd B. Tatelman Deputy General Counsel Andy T. Wang Associate General Counsel Alicia Garten Assistant General Counsel

5140 O’Neill House Office Building Washington, D.C. 20515 (202) 225-9700 [email protected] [email protected] [email protected] [email protected]

Respectfully submitted, MASSACHUSETTS INSTITUTE OF TECHNOLOGY /s/ Ishan K. Bhabha Ishan K. Bhabha (pro hac vice) Lauren J. Hartz (pro hac vice) Elizabeth Henthorne (pro hac vice) JENNER & BLOCK LLP 1099 New York Avenue, NW Suite 900 Washington, DC 20001 (202) 639-6000 [email protected] [email protected] [email protected] Daniel J. Cloherty (BBO# 565772) Alexandra Arnold (BBO# 706208) CLOHERTY & STEINBERG LLP One Financial Center Suite 1120 Boston, MA 02111 (617) 481-0610 [email protected] [email protected] CERTIFICATE OF SERVICE

I hereby certify that on this 6th day of July, 2026, I caused the foregoing to be electronically filed with the clerk of the court for the U.S. District Court for the District of Massachusetts, by using the CM/ECF system, which will send a notice of electronic filing to all counsel of record. Dated: July 6, 2026

/s/ Ishan K. Bhabha Ishan K. Bhabha (pro hac vice) JENNER & BLOCK LLP 1099 New York Avenue, NW Suite 900 Washington, DC 20001 (202) 639-6000 [email protected] CERTIFICATE OF COMPLIANCE

Pursuant to Local Rule 7.1(a), I hereby certify that counsel for Defendants have conferred with counsel of record for Plaintiff about the filing of this motion. Plaintiff does not oppose the relief Defendants seek. Dated: July 6, 2026

/s/ Ishan K. Bhabha Ishan K. Bhabha (pro hac vice) JENNER & BLOCK LLP 1099 New York Avenue, NW Suite 900 Washington, DC 20001 (202) 639-6000 [email protected]