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

Filing 30

MOTION to Intervene In Defense of Harvard's Admission Policy by Sarah Cole, Fadhal Moore, Arjini Kumari Nawal, Itzel Vasquez-Rodriguez, Keyanna Wigglesworth, M. B., K. C., Y. D., G. E., A. G., I. G., R. H., J. L., R. S..(Hall, Rahsaan)

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UNITED STATES DISTRICT COURT FOR THE DISTRICT COURT OF MASSACHUSETTS BOSTON DIVISION STUDENTS FOR FAIR ADMISSIONS, INC, Plaintiff, v. PRESIDENT AND FELLOWS OF HARVARD COLLEGE (HARVARD CORPORATION), Civil Action No. 1:14-cv-14176-ADB Defendant. MOTION TO INTERVENE IN DEFENSE OF HARVARD’S ADMISSIONS POLICY Movants and Proposed Intervenors, M.B., K.C., Y.D., G.E., A.G., I.G., R.H., J.L., and R.S., nine minority students intending to apply for Harvard College, as well as Sarah Cole, Fadhal Moore, Arjini Kumari Nawal, Itzel Libertad Vasquez-Rodriguez, and Keyanna Wigglesworth, five minority Harvard College students (collectively, “Movants”), respectfully move to intervene in this case, pursuant to Fed. R. Civ. P. 24, in defense of Harvard’s right to consider race or ethnicity in admissions. As detailed in the accompanying memorandum of reasons, Movants satisfy each of the requirements for intervention as of right under Fed. R. Civ. P. 24(a), but if the Court does not find that all of the Rule 24(a) elements have been met, Movants request in the alternative that they be allowed to intervene permissively under Fed. R. Civ. P. 24(b). In addition to the memorandum, Movants have filed two additional supporting documents: (1) pursuant to Local Rule 7.1(b)(1), a declaration from each Proposed Intervenor setting forth facts upon which this motion is based, see Ex. 1, and (2) pursuant to Fed. R. Civ. P. 24(c), a Proposed Answer. WHEREFORE, Movants respectfully request that this Court grant this Motion to Intervene. Dated: April 29, 2015 Respectfully submitted, /s/ Rahsaan D. Hall Rahsaan D. Hall, BBO # 645369 LAWYERS’ COMMITTEE FOR CIVIL RIGHTS AND ECONOMIC JUSTICE 294 Washington St. Suite 443 Boston, MA 02108 Tel: (617) 988-0608 /s/ Jon M. Greenbaum Jon M. Greenbaum, DC Bar # 489887 LAWYERS’ COMMITTEE FOR CIVIL RIGHTS UNDER LAW 1401 New York Avenue, NW, Suite 400 Washington, DC 20005 Tel: (202) 662-8600 ATTORNEYS FOR PROPOSED DEFENDANT INTERVENORS CERTIFICATE OF CONFERENCE In accordance with Local Rule 7.1(a), I hereby certify that I conferred with counsel for Plaintiff and counsel for Defendant. Neither Plaintiff SFFA nor Defendant Harvard has decided its position on this motion and both wish to respond to it in accordance with the timeframe established by local rule. /s/ Jon M. Greenbaum Jon M. Greenbaum 2 CERTIFICATE OF SERVICE In accordance with Local Rule 5.2(b), I hereby certify that this document filed through the ECF system on April 29, 2015 will be sent electronically to the registered participants as identified on the Notice of Electronic Filing. /s/ Rahsaan D. Hall Rahsaan D. Hall 3

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