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

Filing 421

DECLARATION re 412 MOTION for Summary Judgment by Students for Fair Admissions, Inc.. (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, # 98 Exhibit 98, # 99 Exhibit 99, # 100 Exhibit 100, # 101 Exhibit 101, # 102 Exhibit 102, # 103 Exhibit 103, # 104 Exhibit 104, # 105 Exhibit 105, # 106 Exhibit 106, # 107 Exhibit 107, # 108 Exhibit 108, # 109 Exhibit 109, # 110 Exhibit 110, # 111 Exhibit 111, # 112 Exhibit 112, # 113 Exhibit 113, # 114 Exhibit 114, # 115 Exhibit 115, # 116 Exhibit 116, # 117 Exhibit 117, # 118 Exhibit 118, # 119 Exhibit 119, # 120 Exhibit 120, # 121 Exhibit 121, # 122 Exhibit 122, # 123 Exhibit 123, # 124 Exhibit 124, # 125 Exhibit 125, # 126 Exhibit 126, # 127 Exhibit 127, # 128 Exhibit 128, # 129 Exhibit 129, # 130 Exhibit 130, # 131 Exhibit 131, # 132 Exhibit 132, # 133 Exhibit 133, # 134 Exhibit 134, # 135 Exhibit 135, # 136 Exhibit 136, # 137 Exhibit 137, # 138 Exhibit 138, # 139 Exhibit 139, # 140 Exhibit 140, # 141 Exhibit 141, # 142 Exhibit 142, # 143 Exhibit 143, # 144 Exhibit 144, # 145 Exhibit 145, # 146 Exhibit 146, # 147 Exhibit 147, # 148 Exhibit 148, # 149 Exhibit 149, # 150 Exhibit 150, # 151 Exhibit 151, # 152 Exhibit 152, # 153 Exhibit 153, # 154 Exhibit 154, # 155 Exhibit 155, # 156 Exhibit 156, # 157 Exhibit 157, # 158 Exhibit 158, # 159 Exhibit 159, # 160 Exhibit 160, # 161 Exhibit 161, # 162 Exhibit 162, # 163 Exhibit 163, # 164 Exhibit 164, # 165 Exhibit 165, # 166 Exhibit 166, # 167 Exhibit 167, # 168 Exhibit 168, # 169 Exhibit 169, # 170 Exhibit 170, # 171 Exhibit 171, # 172 Exhibit 172, # 173 Exhibit 173, # 174 Exhibit 174, # 175 Exhibit 175, # 176 Exhibit 176, # 177 Exhibit 177, # 178 Exhibit 178, # 179 Exhibit 179, # 180 Exhibit 180, # 181 Exhibit 181, # 182 Exhibit 182, # 183 Exhibit 183, # 184 Exhibit 184, # 185 Exhibit 185, # 186 Exhibit 186, # 187 Exhibit 187, # 188 Exhibit 188, # 189 Exhibit 189, # 190 Exhibit 190, # 191 Exhibit 191, # 192 Exhibit 192, # 193 Exhibit 193, # 194 Exhibit 194, # 195 Exhibit 195, # 196 Exhibit 196, # 197 Exhibit 197, # 198 Exhibit 198, # 199 Exhibit 199, # 200 Exhibit 200, # 201 Exhibit 201, # 202 Exhibit 202, # 203 Exhibit 203, # 204 Exhibit 204, # 205 Exhibit 205, # 206 Exhibit 206, # 207 Exhibit 207, # 208 Exhibit 208, # 209 Exhibit 209, # 210 Exhibit 210, # 211 Exhibit 211, # 212 Exhibit 212, # 213 Exhibit 213, # 214 Exhibit 214, # 215 Exhibit 215, # 216 Exhibit 216, # 217 Exhibit 217, # 218 Exhibit 218, # 219 Exhibit 219, # 220 Exhibit 220, # 221 Exhibit 221, # 222 Exhibit 222, # 223 Exhibit 223, # 224 Exhibit 224, # 225 Exhibit 225, # 226 Exhibit 226, # 227 Exhibit 227, # 228 Exhibit 228, # 229 Exhibit 229, # 230 Exhibit 230, # 231 Exhibit 231, # 232 Exhibit 232, # 233 Exhibit 233, # 234 Exhibit 234, # 235 Exhibit 235, # 236 Exhibit 236, # 237 Exhibit 237, # 238 Exhibit 238, # 239 Exhibit 239, # 240 Exhibit 240, # 241 Exhibit 241, # 242 Exhibit 242, # 243 Exhibit 243, # 244 Exhibit 244, # 245 Exhibit 245, # 246 Exhibit 246, # 247 Exhibit 247, # 248 Exhibit 248, # 249 Exhibit 249, # 250 Exhibit 250, # 251 Exhibit 251, # 252 Exhibit 252, # 253 Exhibit 253, # 254 Exhibit 254, # 255 Exhibit 255, # 256 Exhibit 256, # 257 Exhibit 257, # 258 Exhibit 258, # 259 Exhibit 259, # 260 Exhibit 260, # 261 Exhibit 261)(Consovoy, William) (Additional attachment(s) added on 6/18/2018: # 262 Unredacted version of Declaration, # 263 Exhibit 1 (filed under seal), # 264 Exhibit 2 (filed under seal), # 265 Exhibit 5 (filed under seal), # 266 Exhibit 6 (filed under seal), # 267 Exhibit 7 (filed under seal), # 268 Exhibit 8 (filed under seal), # 269 Exhibit 9 (filed under seal), # 270 Exhibit 10 (filed under seal)) (Montes, Mariliz). (Additional attachment(s) added on 6/18/2018: # 271 Exhibit 11 (filed under seal), # 272 Exhibit 12(filed under seal), # 273 Exhibit 13 (filed under seal), # 274 Exhibit 14 (filed under seal), # 275 Exhibit 16 (filed under seal), # 276 Exhibit 17(filed under seal), # 277 Exhibit 18(filed under seal), # 278 Exhibit 19 (filed under seal), # 279 Exhibit 20 (filed under seal), # 280 Exhibit 22 (filed under seal), # 281 Exhibit 23 (filed under seal), # 282 Exhibit 24 (filed under seal), # 283 Exhibit 25(filed under seal), # 284 Exhibit 26 (filed under seal), # 285 Exhibit 28 (filed under seal), # 286 Exhibit 29 (filed under seal), # 287 Exhibit 31 (filed under seal), # 288 Exhibit 32 (filed under seal), # 289 Exhibit 33 (filed under seal), # 290 Exhibit 35 (filed under seal), # 291 Exhibit 36 (filed under seal), # 292 Exhibit 37 (filed under seal), # 293 Exhibit 38(filed under seal), # 294 Exhibit 39 (filed under seal), # 295 Exhibit 40 (filed under seal), # 296 Exhibit 41, # 297 Exhibit 42 (filed under seal), # 298 Exhibit 43 (filed under seal), # 299 Exhibit 44(filed under seal), # 300 Exhibit 45 (filed under seal), # 301 Exhibit 46 (filed under seal), # 302 Exhibit 47 (filed under seal), # 303 Exhibit 48 (filed under seal), # 304 Exhibit 51 (filed under seal)) (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 MICHAEL CONNOLLY IN SUPPORT OF
PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT
I, Michael Connolly, pursuant to 28 U.S.C. § 1746, declare the following:
1.

I am over eighteen years of age, have personal knowledge of the facts stated

herein, and if called upon to do so, could and would testify competently thereto.
2.

I am an attorney at Consovoy McCarthy Park PLLC and represent Plaintiff

Students for Fair Admissions, Inc. (“SFFA”) in the above-styled action.
3.

I provide this declaration in support of SFFA’s motion for summary judgment.

4.

Attached hereto as Exhibit 1 is a true and correct copy of excerpts of the May 4,

2017 deposition of Roger Banks.
5.

Attached hereto as Exhibit 2 is a true and correct copy of excerpts of the July 13,

2017 deposition of Erica Bever.
6.

Attached hereto as Exhibit 3 is a true and correct copy of excerpts of the April 27,

2018 deposition of David Card.
7.

Attached hereto as Exhibit 4 is a true and correct copy of excerpts of the July 27,

2017 deposition of Michael Contompasis.

1

8.

Attached hereto as Exhibit 5 is a true and correct copy of excerpts of the April 7,

2017 deposition of
9.

Attached hereto as Exhibit 6 is a true and correct copy of excerpts of the June 6,

2017 deposition of Sally Donahue.
10.

Attached hereto as Exhibit 7 is a true and correct copy of excerpts of the July 27,

2017 deposition of Erin Driver-Linn.
11.

Attached hereto as Exhibit 8 is a true and correct copy of excerpts of the March

10, 2017 deposition of Drew Faust.
12.

Attached hereto as Exhibit 9 is a true and correct copy of excerpts of the August

3, 2017 deposition of William Fitzsimmons.
13.

Attached hereto as Exhibit 10 is a true and correct copy of excerpts of the July 19,

2017 deposition of Mark Hansen.
14.

Attached hereto as Exhibit 11 is a true and correct copy of excerpts of the June

20, 2017 deposition of
15.

Attached hereto as Exhibit 12 is a true and correct copy of excerpts of the May 1,

2018 deposition of Richard Kahlenberg.
16.

Attached hereto as Exhibit 13 is a true and correct copy of excerpts of the April

27, 2017 deposition of Rakesh Khurana.
17.

Attached hereto as Exhibit 14 is a true and correct copy of excerpts of the June

30, 2017 deposition of
18.

Attached hereto as Exhibit 15 is a true and correct copy of excerpts of the May

22, 2017, 2017 deposition of Christina Lopez.

2

19.

Attached hereto as Exhibit 16 is a true and correct copy of excerpts of the June

18, 2015 deposition of Marlyn McGrath.
20.

Attached hereto as Exhibit 17 is a true and correct copy of excerpts of the August

1, 2017 deposition of Marlyn McGrath.
21.

Attached hereto as Exhibit 18 is a true and correct copy of excerpts of the June

14, 2017 deposition of
22.

Attached hereto as Exhibit 19 is a true and correct copy of excerpts of the July 17,

2017 deposition of Casey Pedrick.
23.

Attached hereto as Exhibit 20 is a true and correct copy of excerpts of the June 7,

2017 deposition of
24.

Attached hereto as Exhibit 21 is a true and correct copy of excerpts of the April

11, 2018 deposition of Ruth Simmons.
25.

Attached hereto as Exhibit 22 is a true and correct copy of excerpts of the April

11, 2017 deposition of Michael Smith.
26.

Attached hereto as Exhibit 23 is a true and correct copy of excerpts of the April

23, 2018 deposition of Michael Smith.
27.

Attached hereto as Exhibit 24 is a true and correct copy of excerpts of the June

28, 2017 deposition of
28.

Attached hereto as Exhibit 25 is a true and correct copy of excerpts of the October

9, 2015 and March 6, 2017 depositions of
29.

Attached hereto as Exhibit 26 is a true and correct copy of excerpts of the March

24, 2017 deposition of Elizabeth Yong.

3

30.

Attached hereto as Exhibit 27 is a true and correct copy of excerpts of the July 19,

2017 deposition of Fabio Zuluaga.
31.

Attached hereto as Exhibit 28 is a true and correct copy of a document bearing

bates number HARV000000008-15 that was produced by Harvard in this litigation.
32.

Attached hereto as Exhibit 29 is a true and correct copy of a document bearing

bates number HARV000001439-1454 that was produced by Harvard in this litigation.
33.

Attached hereto as Exhibit 30 is a true and correct copy of document excerpts

bearing bates number HARV00001478-1497 that were produced by Harvard in this litigation.
34.

Attached hereto as Exhibit 31 is a true and correct copy of document excerpts

bearing bates number HARV00001730-1749 that were produced by Harvard in this litigation.
35.

Attached hereto as Exhibit 32 is a true and correct copy of a document bearing

bates number HARV00001859-1860 that was produced by Harvard in this litigation.
36.

Attached hereto as Exhibit 33 is a true and correct copy of a document bearing

bates number HARV00001887 that was produced by Harvard in this litigation.
37.

Attached hereto as Exhibit 34 is a true and correct copy of a document bearing

bates number HARV00003496-3500 that was produced by Harvard in this litigation.
38.

Attached hereto as Exhibit 35 is a true and correct copy of a document bearing

bates number HARV00003516-3519 that was produced by Harvard in this litigation.
39.

Attached hereto as Exhibit 36 is a true and correct copy of a document bearing

bates number HARV00003592-3593 that was produced by Harvard in this litigation.
40.

Attached hereto as Exhibit 37 is a true and correct copy of a document bearing

bates number HARV00003879-3905 that was produced by Harvard in this litigation.

4

41.

Attached hereto as Exhibit 38 is a true and correct copy of a document bearing

bates number HARV00004008-4009 that was produced by Harvard in this litigation.
42.

Attached hereto as Exhibit 39 is a true and correct copy of a document bearing

bates number HARV00004098-4104 that was produced by Harvard in this litigation.
43.

Attached hereto as Exhibit 40 is a true and correct copy of a document bearing

bates number HARV00004202 that was produced by Harvard in this litigation.
44.

Attached hereto as Exhibit 41 is a true and correct copy of a document bearing

bates number HARV00004221 that was produced by Harvard in this litigation.
45.

Attached hereto as Exhibit 42 is a true and correct copy of a document bearing

bates number HARV00004224 that was produced by Harvard in this litigation.
46.

Attached hereto as Exhibit 43 is a true and correct copy of a document bearing

bates number HARV00004225 that was produced by Harvard in this litigation.
47.

Attached hereto as Exhibit 44 is a true and correct copy of a document bearing

bates number HARV00004229-4236 that was produced by Harvard in this litigation.
48.

Attached hereto as Exhibit 45 is a true and correct copy of a document bearing

bates number HARV00004268-4269 that was produced by Harvard in this litigation.
49.

Attached hereto as Exhibit 46 is a true and correct copy of a document bearing

bates number HARV00004274 that was produced by Harvard in this litigation.
50.

Attached hereto as Exhibit 47 is a true and correct copy of a document bearing

bates number HARV00004313-4316 that was produced by Harvard in this litigation.
51.

Attached hereto as Exhibit 48 is a true and correct copy of a document bearing

bates number HARV00004924-4927 that was produced by Harvard in this litigation.

5

52.

Attached hereto as Exhibit 49 is a true and correct copy of a document bearing

bates number HARV00004938 that was produced by Harvard in this litigation.
53.

Attached hereto as Exhibit 50 is a true and correct copy of a document bearing

bates number HARV00004943 that was produced by Harvard in this litigation.
54.

Attached hereto as Exhibit 51 is a true and correct copy of a document bearing

bates number HARV00004981-4984 that was produced by Harvard in this litigation.
55.

Attached hereto as Exhibit 52 is a true and correct copy of a document bearing

bates number HARV00005071 that was produced by Harvard in this litigation.
56.

Attached hereto as Exhibit 53 is a true and correct copy of a document bearing

bates number HARV00005215 that was produced by Harvard in this litigation.
57.

Attached hereto as Exhibit 54 is a true and correct copy of document excerpts

bearing bates number HARV00005346-5369 that were produced by Harvard in this litigation.
58.

Attached hereto as Exhibit 55 is a true and correct copy of a document bearing

bates number HARV00006025 that was produced by Harvard in this litigation.
59.

Attached hereto as Exhibit 56 is a true and correct copy of a document bearing

bates number HARV00007310-7313 that was produced by Harvard in this litigation.
60.

Attached hereto as Exhibit 57 is a true and correct copy of a document bearing

bates number HARV00007347-7348 that was produced by Harvard in this litigation.
61.

Attached hereto as Exhibit 58 is a true and correct copy of a document bearing

bates number HARV00007766-7771 that was produced by Harvard in this litigation.
62.

Attached hereto as Exhibit 59 is a true and correct copy of a document bearing

bates number HARV00007772-7773 that was produced by Harvard in this litigation.

6

63.

Attached hereto as Exhibit 60 is a true and correct copy of a document bearing

bates number HARV00007799-7802 that was produced by Harvard in this litigation.
64.

Attached hereto as Exhibit 61 is a true and correct copy of a document bearing

bates number HARV00007877 that was produced by Harvard in this litigation.
65.

Attached hereto as Exhibit 62 is a true and correct copy of document excerpts

bearing bates number HARV00007944-7982 that were produced by Harvard in this litigation.
66.

Attached hereto as Exhibit 63 is a true and correct copy of a document bearing

bates number HARV00009110-9112 that was produced by Harvard in this litigation.
67.

Attached hereto as Exhibit 64 is a true and correct copy of a document bearing

bates number HARV00010028-10033 that was produced by Harvard in this litigation.
68.

Attached hereto as Exhibit 65 is a true and correct copy of a document bearing

bates number HARV00010315-10317 that was produced by Harvard in this litigation.
69.

Attached hereto as Exhibit 66 is a true and correct copy of a document bearing

bates number HARV00010356-10358 that was produced by Harvard in this litigation.
70.

Attached hereto as Exhibit 67 is a true and correct copy of a document bearing

bates number HARV00010368-10369 that was produced by Harvard in this litigation.
71.

Attached hereto as Exhibit 68 is a true and correct copy of a document bearing

bates number HARV00010469-10475 that was produced by Harvard in this litigation.
72.

Attached hereto as Exhibit 69 is a true and correct copy of a document bearing

bates number HARV00010476-10477 that was produced by Harvard in this litigation.
73.

Attached hereto as Exhibit 70 is a true and correct copy of a document bearing

bates number HARV00010499-10500 that was produced by Harvard in this litigation.

7

74.

Attached hereto as Exhibit 71 is a true and correct copy of a document bearing

bates number HARV00010543 that was produced by Harvard in this litigation.
75.

Attached hereto as Exhibit 72 is a true and correct copy of document excerpts

bearing bates number HARV00010595-10642 that were produced by Harvard in this litigation.
76.

Attached hereto as Exhibit 73 is a true and correct copy of a document bearing

bates number HARV00011118-11141 that was produced by Harvard in this litigation.
77.

Attached hereto as Exhibit 74 is a true and correct copy of document excerpts

bearing bates number HARV00011623-11651 that were produced by Harvard in this litigation.
78.

Attached hereto as Exhibit 75 is a true and correct copy of a document bearing

bates number HARV00011752-11754 that was produced by Harvard in this litigation.
79.

Attached hereto as Exhibit 76 is a true and correct copy of a document bearing

bates number HARV00013119 that was produced by Harvard in this litigation.
80.

Attached hereto as Exhibit 77 is a true and correct copy of document excerpts

bearing bates numbers HARV00013367-13377, 13394-13395, and 13416 that was produced by
Harvard in this litigation.
81.

Attached hereto as Exhibit 78 is a true and correct copy of a document bearing

bates number HARV00014509-14511 that was produced by Harvard in this litigation.
82.

Attached hereto as Exhibit 79 is a true and correct copy of a document bearing

bates number HARV00014628 that was produced by Harvard in this litigation.
83.

Attached hereto as Exhibit 80 is a true and correct copy of a document bearing

bates number HARV00014676 that was produced by Harvard in this litigation.
84.

Attached hereto as Exhibit 81 is a true and correct copy of a document bearing

bates number HARV00014684-14686 that was produced by Harvard in this litigation.

8

85.

Attached hereto as Exhibit 82 is a true and correct copy of a document bearing

bates number HARV00014772-14777 that was produced by Harvard in this litigation.
86.

Attached hereto as Exhibit 83 is a true and correct copy of a document bearing

bates number HARV00015814-15880 that was produced by Harvard in this litigation.
87.

Attached hereto as Exhibit 84 is a true and correct copy of a document bearing

bates number HARV00016009-16010 that was produced by Harvard in this litigation.
88.

Attached hereto as Exhibit 85 is a true and correct copy of a document bearing

bates number HARV00016628-16629 that was produced by Harvard in this litigation.
89.

Attached hereto as Exhibit 86 is a true and correct copy of a document bearing

bates number HARV00016639 that was produced by Harvard in this litigation.
90.

Attached hereto as Exhibit 87 is a true and correct copy of a document bearing

bates number HARV00016645-16646 that was produced by Harvard in this litigation.
91.

Attached hereto as Exhibit 88 is a true and correct copy of document excerpts

bearing bates number HARV00016675-16712 that were produced by Harvard in this litigation.
92.

Attached hereto as Exhibit 89 is a true and correct copy of a document bearing

bates number HARV00016782-16784 that was produced by Harvard in this litigation.
93.

Attached hereto as Exhibit 90 is a true and correct copy of a document bearing

bates number HARV00016806-16807 that was produced by Harvard in this litigation.
94.

Attached hereto as Exhibit 91 is a true and correct copy of a document bearing

bates number HARV00016971-16974 that was produced by Harvard in this litigation.
95.

Attached hereto as Exhibit 92 is a true and correct copy of a document bearing

bates number HARV00017145-17147 that was produced by Harvard in this litigation.

9

96.

Attached hereto as Exhibit 93 is a true and correct copy of a document bearing

bates number HARV00018152-18162 that was produced by Harvard in this litigation.
97.

Attached hereto as Exhibit 94 is a true and correct copy of excerpts of documents

produced by the U.S. Department of Education, Office of Civil Rights on March 26, 2018 in
response to a July 17, 2017 request from Students for Fair Admissions under the Freedom of
Information Act.
98.

Attached hereto as Exhibit 95 is a true and correct copy of document excerpts

bearing bates number HARV00018452-18462 that were produced by Harvard in this litigation.
99.

Attached hereto as Exhibit 96 is a true and correct copy of a document bearing

bates number HARV00018624 that was produced by Harvard in this litigation.
100.

Attached hereto as Exhibit 97 is a true and correct copy of a document bearing

bates number HARV00018646 that was produced by Harvard in this litigation.
101.

Attached hereto as Exhibit 98 is a true and correct copy of document excerpts

bearing bates number HARV00018900-18938 that were produced by Harvard in this litigation.
102.

Attached hereto as Exhibit 99 is a true and correct copy of a document bearing

bates number HARV00019403-19404 that was produced by Harvard in this litigation.
103.

Attached hereto as Exhibit 100 is a true and correct copy of a document bearing

bates number HARV00019910 that was produced by Harvard in this litigation.
104.

Attached hereto as Exhibit 101 is a true and correct copy of a document bearing

bates number HARV00021281-21284 that was produced by Harvard in this litigation.
105.

Attached hereto as Exhibit 102 is a true and correct copy of a document bearing

bates number HARV00021585 that was produced by Harvard in this litigation.

10

106.

Attached hereto as Exhibit 103 is a true and correct copy of a document bearing

bates number HARV00022117-22118 that was produced by Harvard in this litigation.
107.

Attached hereto as Exhibit 104 is a true and correct copy of a document bearing

bates number HARV00022625-22626 that was produced by Harvard in this litigation.
108.

Attached hereto as Exhibit 105 is a true and correct copy of a document bearing

bates number HARV00023143-23144 that was produced by Harvard in this litigation.
109.

Attached hereto as Exhibit 106 is a true and correct copy of a document bearing

bates number HARV00023173-23174 that was produced by Harvard in this litigation.
110.

Attached hereto as Exhibit 107 is a true and correct copy of a document bearing

bates number HARV00023314-23316 that was produced by Harvard in this litigation.
111.

Attached hereto as Exhibit 108 is a true and correct copy of a document bearing

bates number HARV00023318-23319 that was produced by Harvard in this litigation.
112.

Attached hereto as Exhibit 109 is a true and correct copy of a document bearing

bates number HARV00023320 that was produced by Harvard in this litigation.
113.

Attached hereto as Exhibit 110 is a true and correct copy of a document bearing

bates number HARV00023430-23431 that was produced by Harvard in this litigation.
114.

Attached hereto as Exhibit 111 is a true and correct copy of a document bearing

bates number HARV00023432-23433 that was produced by Harvard in this litigation.
115.

Attached hereto as Exhibit 112 is a true and correct copy of a document bearing

bates number HARV00023547-23555 that was produced by Harvard in this litigation.
116.

Attached hereto as Exhibit 113 is a true and correct copy of a document bearing

bates number HARV00023563-23564 that was produced by Harvard in this litigation.

11

117.

Attached hereto as Exhibit 114 is a true and correct copy of a document bearing

bates number HARV00023588-23599 that was produced by Harvard in this litigation.
118.

Attached hereto as Exhibit 115 is a true and correct copy of a document bearing

bates number HARV00023613-23616 that was produced by Harvard in this litigation.
119.

Attached hereto as Exhibit 116 is a true and correct copy of a document bearing

bates number HARV00023643-23649 that was produced by Harvard in this litigation.
120.

Attached hereto as Exhibit 117 is a true and correct copy of document excerpts

bearing bates number HARV00023650-23695 that were produced by Harvard in this litigation.
121.

Attached hereto as Exhibit 118 is a true and correct copy of a document bearing

bates number HARV00024781-24782 that was produced by Harvard in this litigation.
122.

Attached hereto as Exhibit 119 is a true and correct copy of a document bearing

bates number HARV00024974 that was produced by Harvard in this litigation.
123.

Attached hereto as Exhibit 120 is a true and correct copy of a document bearing

bates number HARV00026381-26384 that was produced by Harvard in this litigation.
124.

Attached hereto as Exhibit 121 is a true and correct copy of a document bearing

bates number HARV00026390-26391 that was produced by Harvard in this litigation.
125.

Attached hereto as Exhibit 122 is a true and correct copy of a document bearing

bates number HARV00026550-26552 that was produced by Harvard in this litigation.
126.

Attached hereto as Exhibit 123 is a true and correct copy of a document bearing

bates number HARV00026562-26565 that was produced by Harvard in this litigation.
127.

Attached hereto as Exhibit 124 is a true and correct copy of a document bearing

bates number HARV00026671-26697 that was produced by Harvard in this litigation.

12

128.

Attached hereto as Exhibit 125 is a true and correct copy of a document bearing

bates number HARV00028373-28384 that was produced by Harvard in this litigation.
129.

Attached hereto as Exhibit 126 is a true and correct copy of a document bearing

bates number HARV00028629 that was produced by Harvard in this litigation.
130.

Attached hereto as Exhibit 127 is a true and correct copy of a document bearing

bates number HARV00028633 that was produced by Harvard in this litigation.
131.

Attached hereto as Exhibit 128 is a true and correct copy of a document bearing

bates number HARV00029858 that was produced by Harvard in this litigation.
132.

Attached hereto as Exhibit 129 is a true and correct copy of a document bearing

bates number HARV00029873-29874 that was produced by Harvard in this litigation.
133.

Attached hereto as Exhibit 130 is a true and correct copy of a document bearing

bates number HARV00029909 that was produced by Harvard in this litigation.
134.

Attached hereto as Exhibit 131 is a true and correct copy of a document bearing

bates number HARV00029930-29932 that was produced by Harvard in this litigation.
135.

Attached hereto as Exhibit 132 is a true and correct copy of a document bearing

bates number HARV00029940-29945 that was produced by Harvard in this litigation.
136.

Attached hereto as Exhibit 133 is a true and correct copy of a document bearing

bates number HARV00030509-30512 that was produced by Harvard in this litigation.
137.

Attached hereto as Exhibit 134 is a true and correct copy of a document bearing

bates number HARV00031687-31729 that was produced by Harvard in this litigation.
138.

Attached hereto as Exhibit 135 is a true and correct copy of a document bearing

bates number HARV00031933 that was produced by Harvard in this litigation.

13

139.

Attached hereto as Exhibit 136 is a true and correct copy of a document bearing

bates number HARV00032339-32341 that was produced by Harvard in this litigation.
140.

Attached hereto as Exhibit 137 is a true and correct copy of a document bearing

bates number HARV00032454-32455 that was produced by Harvard in this litigation.
141.

Attached hereto as Exhibit 138 is a true and correct copy of a document bearing

bates number HARV00032477 that was produced by Harvard in this litigation.
142.

Attached hereto as Exhibit 139 is a true and correct copy of a document bearing

bates number HARV00032509-32524 that was produced by Harvard in this litigation.
143.

Attached hereto as Exhibit 140 is a true and correct copy of a document bearing

bates number HARV00035478-35479 that was produced by Harvard in this litigation.
144.

Attached hereto as Exhibit 141 is a true and correct copy of documents excerpts

bearing bates numbers HARV00056250, 57292 that were produced by Harvard in this litigation.
145.

Attached hereto as Exhibit 142 is a true and correct copy of a document bearing

bates number HARV00065444 that was produced by Harvard in this litigation.
146.

Attached hereto as Exhibit 143 is a true and correct copy of a document bearing

bates number HARV00065449-65460 that was produced by Harvard in this litigation.
147.

Attached hereto as Exhibit 144 is a true and correct copy of a document bearing

bates number HARV00065693-65695 that was produced by Harvard in this litigation.
148.

Attached hereto as Exhibit 145 is a true and correct copy of a document bearing

bates number HARV00065741-65757 that was produced by Harvard in this litigation.
149.

Attached hereto as Exhibit 146 is a true and correct copy of a document bearing

bates number HARV00066245-66247 that was produced by Harvard in this litigation.

14

150.

Attached hereto as Exhibit 147 is a true and correct copy of a document bearing

bates number HARV00066372-66373 that was produced by Harvard in this litigation.
151.

Attached hereto as Exhibit 148 is a true and correct copy of document excerpts

bearing bates numbers HARV00066521 and HARV00066528 that were produced by Harvard in
this litigation.
152.

Attached hereto as Exhibit 149 is a true and correct copy of document excerpts

bearing bates numbers HARV00066599 and HARV00066607-66608 that were produced by
Harvard in this litigation.
153.

Attached hereto as Exhibit 150 is a true and correct copy of document excerpts

bearing bates numbers HARV00066632 and HARV00066679-66681 that were produced by
Harvard in this litigation.
154.

Attached hereto as Exhibit 151 is a true and correct copy of a document bearing

bates number HARV00066685 that was produced by Harvard in this litigation.
155.

Attached hereto as Exhibit 152 is a true and correct copy of a document bearing

bates number HARV00067540-67542 that was produced by Harvard in this litigation.
156.

Attached hereto as Exhibit 153 is a true and correct copy of document excerpts

bearing bates number HARV00068151-68174 that were produced by Harvard in this litigation.
157.

Attached hereto as Exhibit 154 is a true and correct copy of a document bearing

bates number HARV00069096-69101 that was produced by Harvard in this litigation.
158.

Attached hereto as Exhibit 155 is a true and correct copy of a document bearing

bates number HARV00069113-69119 that was produced by Harvard in this litigation.
159.

Attached hereto as Exhibit 156 is a true and correct copy of a document bearing

bates number HARV00069732-69734 that was produced by Harvard in this litigation.

15

160.

Attached hereto as Exhibit 157 is a true and correct copy of a document bearing

bates number HARV00069760-69767 that was produced by Harvard in this litigation.
161.

Attached hereto as Exhibit 158 is a true and correct copy of a document bearing

bates number HARV00072342 that was produced by Harvard in this litigation.
162.

Attached hereto as Exhibit 159 is a true and correct copy of a document bearing

bates number HARV00072344-72345 that was produced by Harvard in this litigation.
163.

Attached hereto as Exhibit 160 is a true and correct copy of a document excerpt

bearing bates number HARV00072346 that was produced by Harvard in this litigation.
164.

Attached hereto as Exhibit 161 is a true and correct copy of a document bearing

bates number HARV00074898 that was produced by Harvard in this litigation.
165.

Attached hereto as Exhibit 162 is a true and correct copy of a document bearing

bates number HARV00074976-74978 that was produced by Harvard in this litigation.
166.

Attached hereto as Exhibit 163 is a true and correct copy of a document bearing

bates number HARV00075051-75052 that was produced by Harvard in this litigation.
167.

Attached hereto as Exhibit 164 is a true and correct copy of document excerpts

bearing bates number HARV00075053 that were produced by Harvard in this litigation.
168.

Attached hereto as Exhibit 165 is a true and correct copy of a document bearing

bates number HARV00075057-75059 that was produced by Harvard in this litigation.
169.

Attached hereto as Exhibit 166 is a true and correct copy of a document bearing

bates number HARV00075060 that was produced by Harvard in this litigation.
170.

Attached hereto as Exhibit 167 is a true and correct copy of a document bearing

bates number HARV00075072 that was produced by Harvard in this litigation.

16

171.

Attached hereto as Exhibit 168 is a true and correct copy of a document bearing

bates number HARV00076081-76082 that was produced by Harvard in this litigation.
172.

Attached hereto as Exhibit 169 is a true and correct copy of a document bearing

bates number HARV00076247 that was produced by Harvard in this litigation.
173.

Attached hereto as Exhibit 170 is a true and correct copy of a document bearing

bates number HARV00076274-76276 that was produced by Harvard in this litigation.
174.

Attached hereto as Exhibit 171 is a true and correct copy of a document bearing

bates number HARV00076335 that was produced by Harvard in this litigation.
175.

Attached hereto as Exhibit 172 is a true and correct copy of a document bearing

bates number HARV00076469-76471 that was produced by Harvard in this litigation.
176.

Attached hereto as Exhibit 173 is a true and correct copy of a document bearing

bates number HARV00076506-76508 that was produced by Harvard in this litigation.
177.

Attached hereto as Exhibit 174 is a true and correct copy of a document bearing

bates number HARV00076529-76530 that was produced by Harvard in this litigation.
178.

Attached hereto as Exhibit 175 is a true and correct copy of a document bearing

bates number HARV00076339-76640 that was produced by Harvard in this litigation.
179.

Attached hereto as Exhibit 176 is a true and correct copy of a document bearing

bates number HARV00076691-76694 that was produced by Harvard in this litigation.
180.

Attached hereto as Exhibit 177 is a true and correct copy of a document bearing

bates number HARV00076821-76824 that was produced by Harvard in this litigation.
181.

Attached hereto as Exhibit 178 is a true and correct copy of a document bearing

bates number HARV00076934 that was produced by Harvard in this litigation.

17

182.

Attached hereto as Exhibit 179 is a true and correct copy of a document bearing

bates number HARV00077069-77071 that was produced by Harvard in this litigation.
183.

Attached hereto as Exhibit 180 is a true and correct copy of a document bearing

bates number HARV00077072 that was produced by Harvard in this litigation.
184.

Attached hereto as Exhibit 181 is a true and correct copy of a document bearing

bates number HARV00077154 that was produced by Harvard in this litigation.
185.

Attached hereto as Exhibit 182 is a true and correct copy of a document bearing

bates number HARV00077297-77299 that was produced by Harvard in this litigation.
186.

Attached hereto as Exhibit 183 is a true and correct copy of a document bearing

bates number HARV00077346-77347 that was produced by Harvard in this litigation.
187.

Attached hereto as Exhibit 184 is a true and correct copy of document excerpts

bearing bates numbers HARV00077521-77523, 77562-77565, 77582-77586, 77595, 77599, and
77645-77656 that were produced by Harvard in this litigation.
188.

Attached hereto as Exhibit 185 is a true and correct copy of a document bearing

bates number HARV00077839 that was produced by Harvard in this litigation.
189.

Attached hereto as Exhibit 186 is a true and correct copy of a document bearing

bates number HARV00077840 that was produced by Harvard in this litigation.
190.

Attached hereto as Exhibit 187 is a true and correct copy of a document bearing

bates number HARV00077882 that was produced by Harvard in this litigation.
191.

Attached hereto as Exhibit 188 is a true and correct copy of a document bearing

bates number HARV00092081-92082 that was produced by Harvard in this litigation.
192.

Attached hereto as Exhibit 189 is a true and correct copy of document excerpts

bearing bates number HARV00097167 that were produced by Harvard in this litigation.

18

193.

Attached hereto as Exhibit 190 is a true and correct copy of a document bearing

bates number HARV00097310-97328 that was produced by Harvard in this litigation.
194.

Attached hereto as Exhibit 191 is a true and correct copy of a document bearing

bates number HARV00097370-97371 that was produced by Harvard in this litigation.
195.

Attached hereto as Exhibit 192 is a true and correct copy of document excerpts

bearing bates numbers HARV00097697 and HARV00097710 that were produced by Harvard in
this litigation.
196.

Attached hereto as Exhibit 193 is a true and correct copy of document excerpts

bearing bates number SFFA-Harvard 0000059 that were produced by SFFA in this litigation.
197.

Attached hereto as Exhibit 194 is a true and correct copy of a document bearing

bates number SFFA-Harvard 0001939-1940 that was produced by SFFA in this litigation.
198.

Attached hereto as Exhibit 195 is a true and correct copy of a document bearing

bates number SFFA-Harvard 0001941-1942 that was produced by SFFA in this litigation.
199.

Attached hereto as Exhibit 196 is a true and correct copy of a document bearing

bates number SFFA-Harvard 0001953-1954 that was produced by SFFA in this litigation.
200.

Attached hereto as Exhibit 197 is a true and correct copy of a document bearing

bates number SFFA-Harvard 0001995-1996 that was produced by SFFA in this litigation.
201.

Attached hereto as Exhibit 198 is a true and correct copy of a document bearing

bates number SFFA-Harvard 0001997-1998 that was produced by SFFA in this litigation.
202.

Attached hereto as Exhibit 199 is a true and correct copy of a document bearing

bates number SFFA-Harvard 0001999-2000 that was produced by SFFA in this litigation.
203.

Attached hereto as Exhibit 200 is a true and correct copy of Pedrick Exhibit 11

which was marked by SFFA at the Pedrick deposition.

19

204.

Attached hereto as Exhibit 201 is a true and correct copy of Hansen Exhibit 1,

which was marked by SFFA at the Hansen deposition.
205.

Attached hereto as Exhibit 202 is a true and correct copy of Hansen Exhibit 6,

which was marked by SFFA at the Hansen deposition.
206.

Attached hereto as Exhibit 203 is a true and correct copy of McGrath Exhibit 2,

which was marked by SFFA at the McGrath deposition.
207.

Attached hereto as Exhibit 204 is a true and correct copy of McGrath Exhibit 3,

which was marked by SFFA at the McGrath deposition.
208.

Attached hereto as Exhibit 205 is a true and correct copy of

was marked by SFFA at the
209.

210.

deposition.

Attached hereto as Exhibit 206 is a true and correct copy of

was marked by SFFA at the

Exhibit 5, which

Exhibit 6, which

deposition.

Attached hereto as Exhibit 207 is a true and correct copy of Pedrick Exhibit 10,

which was marked by SFFA at the Pedrick deposition.
211.

Attached hereto as Exhibit 208 is a true and correct copy of Pedrick Exhibit 13,

which was marked by SFFA at the Pedrick deposition.
212.

Attached hereto as Exhibit 209 is a true and correct copy of Pedrick Exhibit 14,

which was marked by SFFA at the Pedrick deposition.
213.

Attached hereto as Exhibit 210 is a true and correct copy of a document entitled

“Stuyvesant High School,” which was obtained on June 13, 2018 from the website
http://stuy.enschool.org/ourpages/auto/2013/3/7/37096823/Class%20of%202018%20profile%20
FINAL%20-ilovepdf-compressed.pdf.

20

214.

Attached hereto as Exhibit 211 is a true and correct copy of Smith Exhibit 9,

which was marked by SFFA at the April 23, 2018 deposition of Michael Smith.
215.

Attached hereto as Exhibit 212 is a true and correct copy of a document entitled

“Stuyvesant High School,” which was obtained on June 13, 2018 from the website
http://stuy.enschool.org/ourpages/auto/2013/3/7/37096823/Class%20of%202018%20profile%20
FINAL%20-ilovepdf-compressed.pdf.
216.

Attached hereto as Exhibit 213 is a true and correct copy of a document entitled

“Harvard College Admissions & Financial Aid,” which was obtained on June 13, 2018 from the
website https://college.harvard.edu/admissions/application-process/what-we-look.
217.
“James

E.

Attached hereto as Exhibit 214 is a true and correct copy of a document entitled
Ryan,”

which

was

obtained

on

June

13,

2018

from

the

website

https://www.gse.harvard.edu/faculty/james-ryan.
218.

Attached hereto as Exhibit 215 is a true and correct copy of a document entitled

“Office of the President,” which was obtained on June 13, 2018 from the website
https://www.harvard.edu/president/news/2017/future-plans.
219.

Attached hereto as Exhibit 216 is a true and correct copy of a document entitled

“Harvard Shuns Quotas and Narrow Criteria” by Jeff Neal and dated December 19, 2012, which
was obtained from The New York Times website on June 14, 2018.
220.

Attached hereto as Exhibit 217 is a true and correct copy of the declaration of Lee

Cheng, which was executed on August 4, 2017.
221.

Attached hereto as Exhibit 218 is a true and correct copy of a document entitled

“Writing the Wrong: A. Lawrence Lowell,” which was obtained on June 13, 2018 from the
website https://www.thecrimson.com/article/2005/11/3/writing-the-wrong-a-lawrence-lowell//.

21

222.

Attached hereto as Exhibit 219 is a true and correct copy of a document entitled

“Ed. Department Clears Harvard,” which was obtained on June 13, 2018 from the website
https://www.thecrimson.com/article/1990/10/6/ed-department-clears-harvard-pin-the/.
223.

Attached hereto as Exhibit 220 is a true and correct copy of a document bearing

bates number HARV00076503-76505 that was produced by Harvard in this litigation.
224.

Attached hereto as Exhibit 221 is a true and correct copy of a document bearing

bates number HARV00001812-1813 that was produced by Harvard in this litigation.
225.

Attached hereto as Exhibit 222 is a true and correct copy of a document bearing

bates number ABAFAOILLSS08-15 that was produced by the Association of Black Admissions
and Financial Aid Officers of the Ivy League and Sister Schools in this litigation.
226.

Attached hereto as Exhibit 223 is a true and correct copy of a document bearing

bates number HARV00016809 that was produced by Harvard in this litigation.
227.

Attached hereto as Exhibit 224 is a true and correct copy of a document bearing

bates number HARV00004890 that was produced by Harvard in this litigation.
228.

Attached hereto as Exhibit 225 is a true and correct copy of a document bearing

bates number HARV00035209-35211 that was produced by Harvard in this litigation.
229.

Attached hereto as Exhibit 226 is a true and correct copy of a document bearing

bates number HARV00008301-8302 that was produced by Harvard in this litigation.
230.

Attached hereto as Exhibit 227 is a true and correct copy of a document bearing

bates number HARV00075471 that was produced by Harvard in this litigation.
231.

Attached hereto as Exhibit 228 is a true and correct copy of a document bearing

bates number HARV00076245-76246 that was produced by Harvard in this litigation.

22

232.

Attached hereto as Exhibit 229 is a true and correct copy of a document bearing

bates number HARV00076841-76844 that was produced by Harvard in this litigation.
233.

Attached hereto as Exhibit 230 is a true and correct copy of document excerpts

bearing bates numbers HARV00094536-94623 that was produced by Harvard in this litigation.
234.

Attached hereto as Exhibit 231 is a true and correct copy of a document bearing

bates number HARV00023177-23178 that was produced by Harvard in this litigation.
235.

Attached hereto as Exhibit 232 is a true and correct copy of Harvard’s Privilege

236.

Attached hereto as Exhibit 233 is a true and correct copy of excerpts of Harvard’s

Log.

Objections and Responses to Plaintiff’s Requests for Admission.
237.

Attached hereto as Exhibit 234 is a true and correct copy of excerpts of Harvard’s

Objections and Responses to Plaintiff’s Second Set of Interrogatories.
238.

Attached hereto as Exhibit 235 is a true and correct copy of Harvard’s

Supplemental Privilege Log.
239.

Attached hereto as Exhibit 236 is a true and correct copy of a document bearing

bates number HARV00072453-72456 produced by Harvard in this litigation.
240.

Attached hereto as Exhibit 237 is a true and correct copy of a report of the Special

Committee on the Limitation of the Size of the Freshman Class dated January 11, 1926, which
was obtained from Harvard’s library.
241.

Attached hereto as Exhibit 238 is a true and correct copy of the Harvard College

Admission Policy dated December 12, 1949, which was obtained from Harvard’s library.

23

242.

Attached hereto as Exhibit 239 is a true and correct copy of an excerpt of a

description of Harvard’s prior admissions policies dated September 8, 1952, which was obtained
from Harvard’s library.
243.

Attached hereto as Exhibit 240 is a true and correct copy of correspondence from

A. Lawrence Lowell to Professor William Hocking dated May 19, 1922, which was obtained
from Harvard’s library.
244.

Attached hereto as Exhibit 241 is a true and correct copy of correspondence from

A. Lawrence Lowell to Rufus Tucker, Esq. dated May 20, 1922, which was obtained from
Harvard’s Library.
245.

Attached hereto as Exhibit 242 is a true and correct copy of correspondence to

Attorney Martin dated June 10, 1922, which was obtained from Harvard’s library.
246.

Attached hereto as Exhibit 243 is a true and correct copy of an application for

admission to Harvard from 1922, which was obtained from Harvard’s library.
247.

Attached hereto as Exhibit 244 is a true and correct copy of correspondence from

Delmar Leighton to A. Lawrence Lowell dated October 25, 1925, which was obtained from
Harvard’s library.
248.

Attached hereto as Exhibit 245 is a true and correct copy of correspondence from

M. E. T. Brown, an alumnus, to A. Lawrence Lowell dated December 17, 1925, which was
obtained from Harvard’s library.
249.

Attached hereto as Exhibit 246 is a true and correct copy of correspondence from

A. Lawrence Lowell to M. E. T. Brown, an alumnus, dated December 18, 1925, which was
obtained from Harvard’s library.

24

250.

Attached hereto as Exhibit 247 is a true and correct copy of correspondence from

A. Lawrence Lowell to Henry James, Esq. dated November 3, 1925, which was obtained from
Harvard’s library.
251.

Attached hereto as Exhibit 248 is a true and correct copy of correspondence from

Henry James, Esq. to A. Lawrence Lowell dated November 4, 1925, which was obtained from
Harvard’s library.
252.

Attached hereto as Exhibit 249 is a true and correct copy of correspondence from

Henry James, Esq. to A. Lawrence Lowell dated November 10 1925, which was obtained from
Harvard’s library.
253.

Attached hereto as Exhibit 250 is a true and correct copy of an article from the

Chicago Daily Tribune entitled, “Harvard Scans Racial Traits of Applicants,” dated May 8,
1926, which was obtained from https://chicagotribune.newspapers.com/.
254.

Attached hereto as Exhibit 251 is a true and correct copy of an article in the

Jewish Telegraphic Agency entitled, “Race Determining Factor in Regard to Harvard
Applicants,”

dated

May

10,

1926,

which

was

obtained

from

the

website

https://www.jta.org/1926/05/11/archive/race-determining-factor-in-regard-to-harvard-applicantshe-admits.
255.

Attached hereto as Exhibit 252 is a true and correct copy of the Report of David

Card, Ph.D. dated December 15, 2017.
256.

Attached hereto as Exhibit 253 is a true and correct copy of the Rebuttal Report of

David Card, Ph.D. dated March 15, 2018.
257.

Attached hereto as Exhibit 254 is a true and correct copy of a document bearing

bates number SFFA-Harvard 0001943-1944 that was produced by SFFA in this litigation

25

258.

Attached hereto as Exhibit 255 is a true and correct copy of a document bearing

bates number SFFA-Harvard 0001945-1946 that was produced by SFFA in this litigation.
259.

Attached hereto as Exhibit 256 is a true and correct copy of a document bearing

bates number SFFA-Harvard 0001949-1950 that was produced by SFFA in this litigation.
260.

Attached hereto as Exhibit 257 is a true and correct copy of the document

“Affirmative Action and the Harvard College Diversity: Discretion Model Paradigm or
Pretext?”.
261.

Attached hereto as Exhibit 258 is a true and correct copy of a document bearing

bates number SFFA-Harvard 0001955-56 that was produced by SFFA in this litigation.
262.

Attached hereto as Exhibit 259 is a true and correct copy of a document bearing

bates number SFFA-Harvard 0001957-1958 that was produced by SFFA in this litigation.
263.

Attached hereto as Exhibit 260 is a true and correct copy of a document bearing

bates number SFFA-Harvard 0001959-60 that was produced by SFFA in this litigation.
264.

Attached hereto as Exhibit 261 is a true and correct copy of a document bearing

bates number SFFA-Harvard 0001961-1962 that was produced by SFFA in this litigation.
*

*

*

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 15, 2018.

/s/ Michael Connolly
Michael Connolly

26