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).

EXHIBIT 114

From:

Neal, Jeff A. [[e-mail]]

Sent:

Wednesday, February 06, 2013 1:04:14 AM

To:

Fitzsimmons, William

Subject:

FW: Draft Annual Admissions Applications Gazette Article

Attachments:

2013 Applications Gazette Article.docx; SideBar- 2013 JN.docx; A note on the Collection
JN.docx

Hi Fitz,
Keciactea.

In addition to this, I wanted to share my minor tweaks on the other two pieces. Also, Bob Juliano Attorney-Client Privile
ICCUAL.LeU.
Attornev-Client Privilege

Thanks,
Jeff
From: Neal, Jeff A.
Sent: Tuesday, February 05, 2013 8:03 PM
To: Smith, Michael D.; Hammonds, Evelynn M.; Fitzsimmons, William R.
Cc: Collins, Nina; Rouse, Ms Joan
Subject: Draft Annual Admissions Applications Gazette Article
Hi Deans Smith and Hammonds,
Here is a draft of the story we put out each year in the Gazette to announce the number of applications that the College
has received. We hit another record this year. It includes my small edits, which Fitz hasn't had the opportunity to
approve yet.
Let me know if you have edits or concerns. We might try to get them out Thursday or Friday.
In addition to this article, Fitz has drafted two pieces that could live on the Admissions website. The first explains the
demographic trends that affect the number of applications. In short, America is currently experiencing a peak in the
number of high school seniors and that those numbers are expected to fall in the coming years. This is helpful in
preempting questions we might get about potentially flat or dropping application numbers in coming years. The second
is a piece that explains how we collect and report demographic data, as per federal guidelines. It explains the difference
between what's reported in IPEDS (basically, all students get one ethnicity and they all add up to 100%) and what we
report publicly (students pick as many ethnicities as they think apply to themselves and all our students' ethnicities add
up to more than 100%). It's obviously more complicated than that and Fitz can correct me if I'm very wrong with my
characterizations. I can share the documents if you are interested.
Thanks,
Jeff

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY

HARV00023588

APPLICATIONS TO THE COLLEGE EXCEED 35,000 FOR THE FIRST TIME

While applications to Harvard College reached a record 35,022
this year, it was the third consecutive year with application numbers
near 35,000.

Last year, 34,303 applied; two years ago applicants

numbered 34,950.
"Financial aid continues to be a major factor in students'
decisions to apply to Harvard," said William R. Fitzsimmons, Dean of
Admissions and Financial Aid.

"Students and their families have many

questions about the affordability of college in challenging financial
times.

They are reassured when they learn how our financial aid

program makes it possible for students from modest and middle-income
families to come to Harvard."
"Generations of alumni have established a partnership with
present and future undergraduates," said Fitzsimmons.

"Students as

always contribute to the cost of their own education through term-time
and summer work - and have the option of loans as well.

Alumni

generosity enables the College to provide $172 million this year to
meet the financial needs of our remarkable undergraduates."
"We are deeply grateful to President Drew Faust, Dean of the
Faculty of Arts and Sciences Michael Smith, and Dean of the College
Evelynn Hammonds for their continued leadership in sustaining
Harvard's core value of access for the nation's and the world's most
promising students," he said.
Ovcr More than sixty percent of Harvard students receive needbased aid to attend, and on average their families pay only $11,500

[Page]

CONFIDENTIAL

HARV00023589

annually.

"Our financial aid program requires no contribution from

the twenty percent of Harvard families with annual incomes below
$65,000 and asks an average of no more than ten percent of income from
the majority of families receiving financial aid," said Sarah C.
Donahue, Director of Financial Aid.

"In addition, even families with

incomes greater —than $150,000 are eligible for aid depending on their
particular circumstances such as multiple children in college or
unusual medical or other essential expenses."
"It appears that there is greater economic diversity in the
applicant pool this year," said Donahue.

"We see a thirty-seven

percent increase in the number of students requesting a few waiver, an
indication of more applicants from low- and modest-income
backgrounds."
The demographics of this year's and last year's applicant pools
are generally similar.

"Minority students remain a significant

segment of the applicant pool, the gender breakdown is still about
fifty-two percent male, and geographical distribution is about the
same except for a slight decline in the number of applicants from
Canada," said Marlyn E. McGrath, Director of Admissions.
"We note another increase in applications from those interested
in mathematics, physical sciences, and engineering - and a twenty-six
percent increase in prospective computer scientists," said McGrath.
"The pattern of increases in these four areas began with the
establishment of the School of Engineering and Applied Sciences
(SEAS), and it is clear that SEAS has raised the level of visibility

[Page]

CONFIDENTIAL

HARV00023590

of our superb and expanded offerings in these fields of study," she
said.
The Admissions Committee is now reviewing the applications of
those deferred during Early Action as well as those who applied for
the January 1 Regular Action program.

Applicants will be notified of

the Committee's decisions on March 28.
Admitted students will be invited to Cambridge for Visitas, the
visiting program for prospective freshmen, to be held this year from
April 20-22.

Students have until May 1 to notify Harvard of their

decision to enroll.

With revisions 1/28/13

[Page]

CONFIDENTIAL

HARV00023591

AN ADDENDUM ON THE COLLECTION AND REPORTING
OF DATA ON RACE AND ETHNICITY

As noted in the Western Interstate Commission for Higher
Education report, the changes required in recent years by the Fcdcral
federal Covcrnmcnt government in the reporting of race and ethnicity
have produced a good deal of confusion among those seeking to
understand demographic trends:

"Beginning in 2010-11, the last year

for which we obtained enrollments data_,states and institutions were
required to report data...according to a new methodology_"
"The new reporting scheme requires individuals to answer a twopart question to indicate their racial and ethnic identity. The first
question is whether an individual's ethnicity is Hispanic/Latino or
not. The second question is whether the individual is from one or
more of five racial groups... In addition to the new options for racial
and ethnic self-identification, the process for collection of data
from individuals is different than the reporting of the data to the
Department of Education: individuals may self-identify as both
Hispanic and any combination of races, but an individual who is
Hispanic will only be reported as Hispanic. Also, individuals are not
offered the choice of choosing the seventh category, Two or More
Races: rather it is a reporting category derived from the
individual's selections. These factors may account for some
divergence in data across the years that cover the transition from one
reporting scheme to another."
The report indicates that "...There is still only very limited
empirical research into the effects of these reporting changes,"
speculating that the Hispanic population may increase, while others
might decrease.
Like many colleges across the nation, Harvard has, of ccur3c,
complied with the new federal reporting requirements, but continues to
report in other contexts the data based on students' actual responses
to the optional application question.

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY

Harvard and its Ivy League

HARV00023592

peers are members of the Consortium on Financing Higher Education
(COFHE) which has also accommodated changes in federal reporting
requirements. COFHE now compiles data based on all racial/ethnic
categories that apply to individual applicants, as well as data
reflecting the new federal standards.
According to a COFHE publication, many COFHE institutions
"continue to assign multi-racial students to a single category
consistent with each school's historic practices."

A nearly equal

number (including Harvard) "indicated that for certain other contexts,
they would count students in all racial/ethnic/categories marked by
them."
The federal reporting system known as IPEDS (Integrated
Postsecondary Education Data System) has been used by Harvard and all
other institutions well before the recent changes.

IPEDS has always

employed a reporting method different from Harvard's and those of many
other institutions.

The use of yet another method has been confusing

for researchers and others interested in ethnicity. That confusion has
been exacerbated by a reporting paradigm which at times mistakenly
included Harvard Extension School numbers with those of the College.
Such compilation practices led to a public perception that the
number of College students awarded a Pell Grant (a federal grant for
low-income students) was significantly lower than it actually is.

We

have worked hard to correct this crror, but even in the past fcw
As recently as December 2012, it was inaccurately reported in
the media that only 11% of our students have Pell Grants, when the
accurate percentage is 17%.

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY

HARV00023593

Similarly, the IPEDS reporting system leads to significantly
underreported percentages for all ethnicities except Hispanic
Americans.

The method used by Harvard and many peer institutions

gives a more complete report of the way many students, especially
those of mixed heritage, actually view their racial and ethnic
identities.
We mention these various reporting mechanisms for race and
ethnicity to demonstrate how difficult it can be for the Western
Interstate Commission for Higher Education to project the demographics
of future high school graduates in the U.S.

We hope that future

reports will help to clarify the complex and, at times, confusing data
that are used to envision the very different racial and ethnic future
of our nation.

With revision: 1/28/13
.

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY

HARV00023594

BEYOND THE RECORD 35,000 APPLICATIONS:
DEMOGRAPHICS AND THE FUTURE OF COLLEGE ADMISSIONS
Reaching the milestone of 35,022 applications to the Harvard
College calls for some perspective on why colleges have experienced
such rapid growth in their applicant pools.

Ten years ago, 20,987

students applied to Harvard; twenty years ago, it was 13,870.
years from now, will it be close to 50,000?

Ten

The simple answer is

"probably not." While no one can predict the future, we can use
available information to speculate about what may lie ahead.
One does not have to travel far beyond Cambridge to visit
institutions with far more applications.

Boston University and

Northeastern have each exceeded 44,000 applications in recent years.
Many factors can affect application numbers including recruitment, the
public demand for higher education, financial aid availability, and
demographics.
Over the past few decades, colleges have expanded their
recruitment through increasingly strategic sophistication of
communication of all kinds. The Internet has made a great difference
both domestically and internationally.
Higher education is more important than ever for personal and
economic advancement.

Students fear being left behind as there are

fewer jobs that do not require higher education, a fact especially
evident during our current and past economic downturns.
Students are also increasingly aware that financial aid from both
private and public sources, while stretched, is available. The media,
non-profit organizations, governmental agencies, and colleges

[Page]

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY

HARV00023595

themselves have done much to deliver this message to students from
modest and middle-income backgrounds.
While the availability of financial aid was particularly
involvedothcr factor

may be involved in the increased numbers of

apclications to Harvard College in recent years, demographics tell us
much more about what has led to the current numbers of college
applicants across the nation and what we might see in the future.
Knocking at the College Door, produced by the Western Interstate
Commission for Higher Education with the support of ACT and the
College Board, offers perspective on demographic factors that have
helped shape college admissions. This highly respected publication
released its latest report in December 2012.

It is the eighth edition

in a history of over thirty years - and it has been highly accurate in
the past:
"Beginning around 1990 and continuing through about 2011,
colleges and universities could count on an annually growing number of
students graduating from the nation's high schools. But that period
of abundance appears to be about to end. The nation is entering a
period of modest decline in the number of graduates...
• The peak occurred in the 2010-11 academic year when total
graduates from public and non-public schools reached 3.4 million.
• Production of high school graduates will fall over the immediate
term before settling down at a stable rate between 3.2 and 3.3
million nationally by 2013-14.
• The next period of sustained growth will begin in 2020-21 and
continue through 2026-27. During this time national totals of
high school graduates are projected to climb about 70,000 (2
percent), a much more gradual rise than the one we saw in the two
decades preceding 2010, and one that will not quite reach the
2010-11 peak."

Moreover, there will be great variations from region to region
and state to state.

While Harvard recruits nationally and

internationally (and has done so mindful of previous demographic
[Page]

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY

HARV00023596

fluctuations), it is sobering to see what will happen in our home
base, the Northeast (which includes New England, New York, New Jersey,
and Pennsylvania).

This year there will be 624,097 high school

graduates in the Northeast; by 2027-28 there will be 576,215_"a
uniformly bleak picture of the future supply", according to the
report.

The only state in the Northeast to register even a slight

increase is New York in 2024-25, and that comes after an initial
decline.

Others will see declines of varying magnitudes led by New

Hampshire's

28%,

with Vermont, Rhode Island, and Maine experiencing

significant declines as well.
projected to have about

16%

Massachusetts and Connecticut are

decreases.

As the report summarizes the regional outlook: "In general, the
South and the West are most likely to continue to see growth, while
the Midwest and the Northeast can expect the greatest shrinkage."
While the number of high school graduates will level off, the
ethnic composition is changing. The WICHE report addresses the rapidly
increasing ethnic diversity of America over the coming years:
"White non-Hispanics will no longer be the majority in our
nation's public high school by 2020-2021. Actual and projected data
suggest that the numbers of both White non-Hispanic and Black nonHispanic students...have already peaked, the former in 2005-06 at 8.9
million and the latter in 2008-09 at 2.5 million. By 2019-20 their
numbers are both projected to fall from these peaks by 13 percent and
9 percent, respectively. In the meantime, the numbers of
Asians/Pacific Islanders and Hispanics enrolled will climb without
interruption, rising by approximately 229,000 (29.5 percent) and
850,000 students (27.3 percent), respectively, between 2010-11 and
2019-20."
The Report also includes the following predictive data:
U. S. Public High School Enrollment by Race/Ethnicity

2012-2013

2024-2025

% Change

[Page]

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY

HARV00023597

American Indian / Alaska Native
Asian /Pacific Islander

171886

1.2%

205657

1.3%

19.6%

804850

5.5%

1140483

7.4%

41.7%

Black /Non-Hispanic

2340102

16.1%

2426542

15.7%

3.7%

Hispanic

3207860

22.1%

4248975

27.6%

32.5%

8014474

55.1%

7389783

47.9%

-7.8%

White /Non-Hispanic
Total

14539172

15411440

6.0%

Such projections are complex, as the addendum at the end of this
article indicates. Nevertheless, it is clear that any college that
hopes to educate future leaders of America - those who will lcad guide
the nations intellectually, politically, and in all other ways - must
be highly effective in recruiting the students of the new and diverse
America that awaits us in our schools.
Finally, it is worth noting that the number of international
citizens (those with only a foreign passport) increased only 1.4% this
year.

Last year the increase was 5%; the year before it was 20%.

This leveling off is an indication that our recruiting has become
increasingly effective over the years in reaching outstanding
international students - and that it is likely that we will not see
equally large increases in the future.

For both international

students and Americans, the awareness of the rigorous admissions
competition at selective American colleges, now well publicized in
guidebooks and through the Internet, may also encourage only those who
are fully qualified to apply.
This brief overview of the domestic and international pools, both
present and future, is offered to help put thip y

rccord 35,015

apblicantarecent levels of applications - in and around 35,000 over
the last three years

in context.

While envisioning the future is

[Page]

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY

HARV00023598

difficult, a period of greater stability and less frenzy in college
admissions in the coming years would be welcomed by everyone.
With rcvisions 1/28/13

[Page]

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY

HARV00023599