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

Filing 150

Letter/request (non-motion) from Students for Fair Admissions . (Attachments: # 1 Affidavit Ex A, # 2 Exhibit Ex B, # 3 Affidavit Ex C, # 4 Affidavit Ex D, # 5 Affidavit Ex E)(Consovoy, William)

EXHIBIT
 E

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS

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

v.

PRESIDENT AND FELLOWS OF HARV ARD COLLEGE
(HARVARD CORPORATION),
Defendant.

DECLARATION OF JOHN DOE

I, pursuant to 28 U.S.C. § 1746, declare the following:
1.

I am an individual over eighteen years old and of sound mind, who has never been

convicted of a felony, is capable of making this declaration, and is fully competent to declare as
to matters stated herein.
2.

I work in New York and am the father of one child who is almost six years old.

My family lives in the New York area. I hope that as my son applies to schools in the future, he
will not be subjected to the same discriminatory standards that Asian Americans face today.
3.

I joined Students for Fair Admissions ("SFFA") because I believe that Harvard

College and many other colleges and universities wrongly discriminate against Asian-American
students. In my view, colleges and universities require Asian-American students to have much
higher test scores and grade point averages to gain admission than other students. I view this
requirement to be unfair.

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4.

I am a member of SFFA, and I actively follow its activities. Last year, I worked

with Edward Blum to arrange a meeting with the Long Island Chinese Community. In the past
year, I have contributed a total of$120 to support SFFA's mission.
5.

I participate as an SFFA member because I support its work in defeating

affirmative action policies that unlawfully discriminate against Asian-American students.
6.

I am aware that SFFA advocates positions that are adverse to Harvard and are also

disfavored by many people, including some of my professional colleagues.
7.

When I joined SFFA, I expected that my identity and involvement in SFFA would

remain confidential. The website on which I registered stated that my membership would not be
disclosed, which was important to my decision to join. Thus, despite its unpopularity, I felt safe
participating in SFFA only because I believed that my identity would remain confidential.
8.

I do not want the public to know about my involvement in SFFA. If it becomes

public that I am a member of SFFA, I fear that it could damage my reputation and cause
colleagues at work to view me in a negative light.
9.

I also do not want anyone at Harvard to know that I am a member of SFFA. I

hope that my son can someday attend Harvard and fear that if Harvard knew that I opposed its
undergraduate admissions policies, then it might later retaliate against me by denying admission
to my son.
10.

Although I support SFFA's litigation against Harvard, I do not want to have any

personal involvement in it. I am making this declaration with the understanding that it will
remain anonymous and that my identity will not be disclosed.
11.

For these reasons, if my identity as a member of SFFA is disclosed to Harvard

and its attorneys in this litigation, then it will deter me from participating in SFFA, contributing

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money to it or paying membership dues, interacting with other members, or communicating with
the group's leadership. I would not have joined as a member of SFFA if I knew that my name
would be disclosed to Harvard.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on this day, April~2016.

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