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

Filing 31

MEMORANDUM in Support re 30 MOTION to Intervene In Defense of Harvard's Admission Policy filed by M. B., K. C., Sarah Cole, Y. D., G. E., A. G., I. G., R. H., J. L., Fadhal Moore, Arjini Kumari Nawal, R. S., Itzel Vasquez-Rodriguez, Keyanna Wigglesworth. (Attachments: # 1 Exhibit Declarations of Proposed Defendant-Intervenors, # 2 Exhibit Proposed Answer)(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.

EXHIBITS IN SUPPORT OF PROPOSED DEFENDANT-INTERVENORS’
MOTION TO INTERVENE
Exhibit 1.1:

Declaration of M.B.

Exhibit 1.2:

Declaration of K.C.

Exhibit 1.3:

Declaration of Y.D.

Exhibit 1.4:

Declaration of G.E.

Exhibit 1.5:

Declaration of A.G.

Exhibit 1.6:

Declaration of I.G.

Exhibit 1.7:

Declaration of R.H.

Exhibit 1.8:

Declaration of J.L.

Exhibit 1.9:

Declaration of R.S.

Exhibit 1.10: Declaration of Sarah Cole
Exhibit 1.11: Declaration of Fadhal Moore
Exhibit 1.12: Declaration of Arjini Kumari Nawal
Exhibit 1.13: Declaration of Itzel Libertad Vasquez-Rodriguez
Exhibit 1.14: Declaration of Keyanna Wigglesworth

EXHIBIT 1.1

EXHIBIT 1.2

EXHIBIT 1.3

EXHIBIT 1.4

EXHIBIT 1.5

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),
Defendants.

Civil Action No. 1:14-cv-14176-DJC

DECLARATION OF A.G.

A.G., pursuant to 28 U.S.C. Section 1746, declares the following:
1. My name is A.G., I am under 18 years of age and I am fully competent to make
this Declaration.
2. I am in the 11th grade at a private high school.
3. I am of Hispanic heritage.
4. Hispanic students are in the minority in my school.
5. I have a very high GPA, and have taken the following advanced courses: AP
Chemistry; AP Computer Science (Java); AP Calculus; AP Statistics; College
Trig-Based Physics; Molecular Biology; and AP Spanish Language.

6. My extracurricular and volunteer experiences include: The Hispanic Student
Association (2013- present), Club Soccer Team Captain (State Championship
finalists, 2013); High School Soccer, Varsity starter 2012 to present (State
Champions, 2012; semi-finalists, 2013; finalists, 2014); High School Soccer –
Varsity Soccer Player of the Year 2014; Track and Field participant; Youth soccer
coach and referee; Summer High School Pre-Medical Institute, Washington
University in St. Louis (July 2014);
North Science Center volunteer; Project Share volunteer; Roadrunner Food Bank
volunteer; and, Read to Excel volunteer.

7. I am also of Filipino descent. My race and ethnicity are at the core of who I am,
how I view the world, and in many ways, how others view me. Culturally, my
beliefs and principles are grounded in my family and our history. In turn, this has
provided me a richer understanding and appreciation for my friends and
colleagues at school (both regardless of and in regard for their race, gender and
culture), a greater value in our differences and a deeper desire to encourage
participation by what each of us brings to the conversation.

8. I believe that because of my family, our history, our experiences and our beliefs, I
can contribute in much more meaningful, broader and important ways to not only
my education, but to the education and understanding of others around me.
9. In college I hope to be part of a highly diverse environment, including race,
ethnicity, gender, points of view, and other elements that create opportunities for
learning, growing and appreciating variety and understanding.

10. My plans include applyrng to Harvard University. I plan to apply for scholarships
and any other fomr of financial aid thar may be available to me.

I declare under penalty of perjury that the foregoing is true and correct.
Executed on this day,

April Zt

,2015.

A.G.

EXHIBIT 1.6

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),
Defendants.

Civil Action No. 1:14-cv-14176-DJC

DECLARATION OF I.G.

I.G., pursuant to 28 U.S.C. Section 1746, declares the following:
1. My name is I.G., I am under 18 years of age and I am fully competent to make
this Declaration.
2. I am in the 9th grade at an independent high school.
3. I am Hispanic.
4. My school is approximately 50% white and 50% minority.
5. My relevant coursework includes Math: Algebra I and II, Geometry,
Trigonometry, Pre-calculus; Science: Earth Science, Physics I, Chemistry I; and,
Spanish (IA, IIA), English, and History.
6. Award and Honors I’ve received:

a. The Follansbee Award (awarded for unusually distinguished academic and
athletic records at my school) – May 2012
b. The Robert Schroeder Memorial Award (awarded for best exemplifying
the ideals of my school through spirit, citizenship, and contribution to the
welfare of the school) – May 2014
c. My artwork was selected for a juried exhibition at an art gallery in a wellknown center for art, and I received the Alumni Award for unique vision
and creativity – April 2015
7. My relevant extracurricular activities are: USATF Cross Country Junior
Olympics National Championships 2012; Varsity Track and Field (State
Championship medalist, 2014); Competitive Soccer (2008-2015); Varsity High
School Soccer (2014), and Basketball.
8. My volunteer activities include cooking meals for families staying at the local
Ronald McDonald House, preparing and serving meals to low-income and
homeless people of my community through a local agency, and sorting produce at
a local food bank.
9. I’m proud of my heritage, being Hispanic and Filipino. Through my interactions
with my cousins, friends, and volunteer activities, I’ve come to appreciate
differences based on family, socio-economic status and alternative experiences. I
think that my own experiences and heritage give me a unique perspective that is
important to share with others.
10. The campus environment I would prefer is one that brings together people of
different races, ethnicities and perspectives. I believe that a variety of perspectives
ultimately results in better solutions.
11. Although my college applications are several years away, I want to apply to
Harvard University. I will also apply for financial aid.

I declare under penalty of perjury that the foregoing is true and correct.
Executed on this day,

April Lcl ,2015.

I.G.

EXHIBIT 1.7

EXHIBIT 1.8

EXHIBIT 1.9

EXHIBIT 1.10

EXHIBIT 1.11

EXHIBIT 1.12

EXHIBIT 1.13

EXHIBIT 1.14

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, BBO # 645369
LAWYERS’ COMMITTEE FOR CIVIL RIGHTS
AND ECONOMIC JUSTICE
294 Washington St., Suite 443
Boston, MA 02108
Tel: [phone]
[e-mail]
ATTORNEY FOR PROPOSED DEFENDANTINTERVENORS