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

Filing 104

Emergency MOTION for Protective Order by President and Fellows of Harvard College. (Attachments: # 1 Declaration in Support of Motion, # 2 Exhibit Exhibit 1 to Ellsworth Declaration, # 3 Exhibit Exhibit 2 to Ellsworth Declaration, # 4 Exhibit Exhibit 3 to Ellsworth Declaration)(Ellsworth, Felicia) Modified on 10/1/2015 (Montes, Mariliz).

UNITED STATES DISTRICT COURT FOR
THE DISTRICT OF MASSACHUSETTS
BOSTON DIVISION

STUDENTS FOR FAIR ADMISSIONS, INC.,
Plaintiff,
Civil Action No. 1:14-cv-14176-ADB

v.
PRESIDENT AND FELLOWS OF HARVARD
COLLEGE,
Defendant.

DECLARATION OF FELICIA H. ELLSWORTH
IN SUPPORT OF EMERGENCY MOTION FOR PROTECTIVE ORDER AND A
TEMPORARY STAY OF DEPOSITIONS

I, Felicia H. Ellsworth, hereby state under oath:
1.

I am a member in good standing of the bar of the Commonwealth of

Massachusetts and this Court, and am a partner at the firm of Wilmer Cutler Pickering Hale and
Dorr LLP. I am one of the attorneys representing the Defendant President and Fellows of
Harvard College (“Harvard”) in the above-captioned matter. I submit this declaration in
connection with the Emergency Motion of Defendant President and Fellows of Harvard College
to Stay Depositions.
2.

Attached hereto as Exhibit 1 is a true and accurate copy of the amended

deposition notice for former Harvard employee Caroline Weaver.
3.

Attached hereto as Exhibit 2 is a true and accurate copy of the subpoena to testify

at a deposition for Ms. Weaver.
4.

Attached hereto as Exhibit 3 is a true and accurate copy of the deposition notice

for Harvard employee Tia Ray.
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I declare under penalty of perjury that the foregoing is true and correct.
Executed on this 30th day of September, 2015.

/s/ Felicia H. Ellsworth
Felicia H. Ellsworth (BBO #665232)
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, MA 02109
Tel: [phone]
Fax: [phone]
[e-mail]
Dated: September 30, 2015

Counsel for Defendant President and
Fellows of Harvard College and Former Employee
Caroline Weaver

2

CERTIFICATE OF SERVICE
I hereby certify that this document filed through the CM/ECF system will be sent
electronically to the registered participants as identified on the Notice of Electronic Filing and
that paper copies will be sent to those indicated as non-registered participants on September 30,
2015.
/s/ Felicia H. Ellsworth
Felicia H. Ellsworth

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