Students for Fair Admissions, Inc. v. President and Fellows of Harvard College et al
Filing
419
DECLARATION re 417 MOTION for Summary Judgment by President and Fellows of Harvard College. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15, # 16 Exhibit 16, # 17 Exhibit 17, # 18 Exhibit 18, # 19 Exhibit 19, # 20 Exhibit 20, # 21 Exhibit 21, # 22 Exhibit 22, # 23 Exhibit 23, # 24 Exhibit 24, # 25 Exhibit 25, # 26 Exhibit 26, # 27 Exhibit 27, # 28 Exhibit 28, # 29 Exhibit 29, # 30 Exhibit 30, # 31 Exhibit 31, # 32 Exhibit 32, # 33 Exhibit 33, # 34 Exhibit 34, # 35 Exhibit 35, # 36 Exhibit 36, # 37 Exhibit 37, # 38 Exhibit 38, # 39 Exhibit 39, # 40 Exhibit 40, # 41 Exhibit 41, # 42 Exhibit 42, # 43 Exhibit 43, # 44 Exhibit 44, # 45 Exhibit 45, # 46 Exhibit 46, # 47 Exhibit 47, # 48 Exhibit 48, # 49 Exhibit 49, # 50 Exhibit 50, # 51 Exhibit 51, # 52 Exhibit 52, # 53 Exhibit 53, # 54 Exhibit 54, # 55 Exhibit 55, # 56 Exhibit 56, # 57 Exhibit 57, # 58 Exhibit 58, # 59 Exhibit 59, # 60 Exhibit 60, # 61 Exhibit 61, # 62 Exhibit 62, # 63 Exhibit 63, # 64 Exhibit 64, # 65 Exhibit 65, # 66 Exhibit 66, # 67 Exhibit 67, # 68 Exhibit 68, # 69 Exhibit 69, # 70 Exhibit 70, # 71 Exhibit 71, # 72 Exhibit 72, # 73 Exhibit 73, # 74 Exhibit 74, # 75 Exhibit 75, # 76 Exhibit 76, # 77 Exhibit 77, # 78 Exhibit 78, # 79 Exhibit 79, # 80 Exhibit 80, # 81 Exhibit 81, # 82 Exhibit 82, # 83 Exhibit 83, # 84 Exhibit 84, # 85 Exhibit 85, # 86 Exhibit 86, # 87 Exhibit 87, # 88 Exhibit 88, # 89 Exhibit 89, # 90 Exhibit 90, # 91 Exhibit 91, # 92 Exhibit 92, # 93 Exhibit 93, # 94 Exhibit 94, # 95 Exhibit 95, # 96 Exhibit 96, # 97 Exhibit 97)(Ellsworth, Felicia)
<![CDATA[
EXHIBIT 15
Page 1
1
IN THE UNITED STATES DISTRICT COURT
2
FOR THE DISTRICT OF MASSACHUSETTS
3
BOSTON DIVISION
4
5
Civil Action No. 1:14-cv-14176-ADB
______________________________________________________
6
DEPOSITION OF:
- June 16, 2017
7
______________________________________________________
8
STUDENTS FOR FAIR ADMISSIONS, INC.,
9
Plaintiff,
10
v.
11
PRESIDENT AND FELLOWS OF HARVARD COLLEGE
12
(HARVARD CORPORATION),
13
Defendant.
14
______________________________________________________
15
16
PURSUANT TO NOTICE AND SUBPOENA, the
17
deposition of
was taken on behalf of the
18
Defendant at 1225 17th Street, Suite 2600, Denver,
19
Colorado 80202, on June 16, 2017, at 8:54 a.m., before
20
Sherry Wallin, Certified Realtime Reporter, Registered
21
Merit Reporter and Notary Public within Colorado.
22
23
24
25
212-279-9424
Veritext Legal Solutions
www.veritext.com
212-490-3430
Page 37
1
offerings for upperclassmen?
2
A.
Not as thoroughly, but yes.
3
Q.
Are there any specific courses you are
4
thinking of taking at
5
A.
?
I have some in mind.
For example --
6
obviously the courses required for the computer
7
science major.
8
courses I'm thinking of.
9
major and minor than I have at specific courses.
10
11
Q.
I -- there aren't any very specific
Like I've looked more at the
Understood.
Are there any professors
you are looking forward to studying with at
?
12
A.
Not in particular.
13
Q.
Are there any extracurricular activities
14
you intend to participate in at
15
A.
Possibly.
?
Especially, like, the
16
Computer Science Club and
17
decided to basically make those decisions once I get
18
there, for the most part.
19
20
Q.
groups at
Quiz Bowl, but I have
That makes sense.
Are there any student
that you anticipate joining?
21
A.
Again, those same clubs.
22
Q.
Sitting here today, do you expect that
23
you will graduate from
in the spring of 2021?
24
A.
I hope so, yes.
25
Q.
Do you intend to apply to transfer from
212-279-9424
Veritext Legal Solutions
www.veritext.com
212-490-3430
Page 38
1
to any other college or university?
2
3
A.
no.
4
5
I don't anticipate that at the moment,
Q.
, has
offered
you any scholarship?
6
A.
No.
7
Q.
Has
8
offered you any merit-based
financial award?
9
A.
No.
I did win the National Merit
10
Scholarship, but that applies to any university.
11
it's not through
12
MR. DULBERG:
All right.
13
been going for a little under an hour.
14
So
take a quick break.
Why don't we
15
MR. PARK:
16
MR. DULBERG:
17
(Recess taken, 9:43 a.m. to 10:00 a.m.)
18
Q.
19
20
Yeah.
I think we've
That sounds good.
Thank you.
(BY MR. DULBERG)
During the break,
, did you discuss the deposition with your
attorney?
21
A.
Briefly.
22
Q.
And what did you discuss?
23
A.
I just asked him if I was doing well,
24
and he said yes, I should just slow down a little bit.
25
Q.
212-279-9424
Always good advice.
Veritext Legal Solutions
www.veritext.com
212-490-3430
Page 76
1
reimburse?
2
A.
No.
3
Q.
What's your understanding of the current
4
status of this case?
5
A.
6
So -MR. PARK:
Objection.
I just want to
7
warn you, like, not the contents of what we have
8
discussed about the case, but, you know, your
9
understanding without revealing, you can discuss.
10
A.
So as I mentioned, I've been following
11
the case on Justia dockets' website, and I understand
12
that the case is in discovery, so both sides are
13
asking for -- each side is asking for evidence from
14
the other side, including -- that's what this
15
deposition is part of, and I know that later next year
16
the judge will either decide the case or hold a trial.
17
Q.
(BY MR. DULBERG)
That information that
18
you just described is based on your review of publicly
19
available information in this case; is that correct?
20
A.
Yes.
21
Q.
Have you ever voted to elect anyone who
22
has any role with respect to SFFA?
23
MR. PARK:
Instructing the witness not
24
to answer the question, concerns SFFA's governance and
25
your rights as a member of SFFA.
212-279-9424
Veritext Legal Solutions
www.veritext.com
212-490-3430
Page 80
1
A.
I don't know of anyone who I know is a
2
member.
There may be people who I know who happen to
3
be members, but I don't know that they're members.
4
Q.
5
a meeting of SFFA?
6
7
MR. PARK:
10
Have you ever attended
You can answer that.
You can
answer.
8
9
(BY MR. DULBERG)
A.
revise that.
No, I have not.
Actually, I should
I was on a phone conference for SFFA
this past December.
11
Q.
(BY MR. DULBERG)
Is that a phone
12
conference that was open to all SFFA members, to the
13
best of your knowledge?
14
A.
It was.
All SFFA members received an
15
email a couple days before that stating there will be
16
this phone conference, dial in if you want to attend
17
it, and so I did.
18
Q.
Was that the only time you were invited
19
to participate in a phone conference that all SFFA
20
members were invited to?
21
A.
Yes.
22
Q.
Do you know whether there have been any
23
other phone conferences of SFFA members as a whole?
24
25
A.
I don't think there have been any
because, as I said, I have been a member since
212-279-9424
Veritext Legal Solutions
www.veritext.com
212-490-3430
Page 81
1
November 2014, with my email address on the list.
2
I should have been contacted if there were others.
3
Q.
So
Do you know if there has ever been a
4
meeting of all SFFA members that you could have
5
attended?
6
MR. PARK:
Objection.
7
A.
I don't know of any such meeting, no.
8
Q.
(BY MR. DULBERG)
9
knowledge, there have been no such meetings, correct?
10
MR. PARK:
11
12
A.
Objection.
To the best of my knowledge, yes, there
have not been.
13
14
To the best of your
MR. DULBERG:
Let's mark the next
exhibit.
15
(Deposition Exhibit 2 was marked.)
16
Q.
(BY MR. DULBERG)
Showing you what's
17
been marked as Exhibit 2, this is a document entitled
18
Re:
19
(SFFA) dated June 30, 2015.
20
document?
Annual Report of Students for Fair Admissions
Do you recognize this
21
A.
Vaguely, yes.
22
Q.
Have you seen it before?
23
A.
Yes.
24
Q.
When?
25
A.
I believe it was on June 30, 2015.
212-279-9424
I received it as an email.
Veritext Legal Solutions
www.veritext.com
212-490-3430
Page 127
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
REPORTER'S CERTIFICATE
STATE OF COLORADO
)
) ss.
CITY AND COUNTY OF DENVER )
I, SHERRY A. WALLIN, Certified Realtime
Reporter, Registered Merit Reporter and Notary Public
ID 19874212873, State of Colorado, do hereby certify
that previous to the commencement of the examination,
the said
was duly sworn by me to testify
to the truth in relation to the matters in controversy
between the parties hereto; that the said deposition
was taken in machine shorthand by me at the time and
place aforesaid and was thereafter reduced to
typewritten form; that the foregoing is a true
transcript of the questions asked, testimony given,
and proceedings had.
I further certify that I am not employed
by, related to, nor of counsel for any of the parties
herein, nor otherwise interested in the outcome of
this litigation.
IN WITNESS WHEREOF, I have affixed my
signature this 23rd day of June, 2017.
My commission expires May 14, 2019.
__X__ Reading and Signing was requested.
_____ Reading and Signing was waived.
_____ Reading and Signing is not required.
<%Signature%>
SHERRY A. WALLIN
Certified Realtime Reporter
Registered Merit Reporter
24
25
212-279-9424
Veritext Legal Solutions
www.veritext.com
212-490-3430
]]>
