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

Filing 416

DECLARATION re 412 MOTION for Summary Judgment by Students for Fair Admissions, Inc.. (Attachments: # 1 Exhibit Expert Report, # 2 Exhibit Rebuttal Expert Report, # 3 Exhibit Supplemental Report)(Consovoy, William) (Additional attachment(s) added on 6/18/2018: # 5 Exhibit A- unredacted version) (Montes, Mariliz).

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS

STUDENTS FOR FAIR ADMISSIONS, INC.,
Plaintiff,
v.

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

PRESIDENT AND FELLOWS OF
HARVARD COLLEGE (HARVARD
CORPORATION),
Defendant.
DECLARATION OF RICHARD KAHLENBERG
I, Richard Kahlenberg, pursuant to 28 U.S.C. § 1746, declare the following:
1.

I make this declaration at the request of counsel for Plaintiff Students for Fair

Admissions, Inc. (“SFFA”), and if called upon to testify as to the contents of this declaration
would testify competently thereto.
2.

Attached as Exhibit A to this declaration is a true and correct copy of my expert

report signed October 16, 2017 and served on Harvard on the same day.
3.

I have personal knowledge of the contents of the expert report attached as

Exhibit A.
4.

I hereby verify that the contents of my expert report attached as Exhibit A are true

and accurate.
5.

Attached as Exhibit B to this declaration is a true and correct copy of my rebuttal

expert report signed January 29, 2018 and served on Harvard on the same day.
6.

I have personal knowledge of the contents of the rebuttal expert report attached as

Exhibit B.

1

7.

I hereby verify that the contents of my rebuttal expert report attached as Exhibit B

are true and accurate.
8.

Attached as Exhibit C to this declaration is a true and correct copy of my

supplemental expert report signed on April 26, 2018 and served on Harvard on the same day.
9.

I have personal knowledge of the contents of my supplemental expert report

attached as Exhibit C.
10.

I hereby verify that the contents of my supplemental expert report attached as

Exhibit C are true and accurate.

I declare under penalty of perjury, under the laws of the United States, that the foregoing
is true and correct to the best of my knowledge.

Executed on this day, June 14, 2018.
/s/ Richard Kahlenberg
Richard Kahlenberg

2