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)

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: [phone]
[e-mail]
/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: [phone]
[e-mail]
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

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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

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