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, # 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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).

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EXHIBIT 153 HIGHLYCONFIDENTIALATTORNEYS' EYESONLY Introduction to the Office of Institutional Research IST 89000ffiNH October 2012 HIGHLYCONFIDENTIALATTORNEYS' EYESONLY The Institutional Research office has two primary functions 1. Collect, synthesize and analyze institutional data 2. Support University decision-making ZSI89000A2IVH (in the offices of the President and Provost, and beyond as possible) p a) ii as D a) cL HIGHLY CONFIDENTIAL — ATTORNEYS' EYES ONLY HARV00068153 Office of Institutional Research Organization Chart, September 2012 Erin Driver-Linn Director, OIR Director, HILT Tippi Jilek Executive Assistant Office of Institutional Research HILT Brooke Pulitzer Sam Moulton Erica Bever Assistant Director Liam Schwartz Director of Administration Director of Educational Research and Assessment Project and Outreach Manager Erin Blevins Lan Gao Mark Hansen Part-time Postdoc Senior Project Analyst Research Analyst V ST89000AHVH (Open Position) Senior Analyst for Policy Initiatives John Scanlon Assistant Director Ruth Loescher Elissa Lu Data and Reporting Analyst Research and Reporting Analyst HIGHLYCONFIDENTIALATTORNEYS' EYESONLY Annual Data Collection and Reporting Work in OIR Annual Collections From Harvard Schools and Peer Institutions: Admissions for Harvard programs Completions (Degrees Conferred) Enrollment Financial Aid Data on Awards and Total Costs for All Students Peer Tuition and Fees Student Debt Annual Deliverables For Internal Audiences: Peer Tuition and Fees Tuition, Enrollment, and Financial Aid (TEFA) data and exhibits for presentation to the Corporation SSI89000ffiNH Redacted HIGHLYCONFIDENTIALATTORNEYS' EYESONLY University committees Institutional Research has supported and/or staffed Types of support OIR provides to committees: Redacted • Data analysis and presentation from existing data sources or new data collections 9ST89000MVH Redacted HIGHLYCONFIDENTIALATTORNEYS' EYESONLY Current and Upcoming Work Planned in IR and HILT trategy PIS o icy Reports • Admissions Analysis: Preliminary review of early action; Examine differences, if any, among male and female applicants to the College Redacted • University Financial Aid: Articulate a vision for fin. aid university-wide, develop a proposal for Presidential aid programs in support of the vision and align to school needs for the campaign Redacted Redacted Redacted LST89000MVH Redacted HIGHLYCONFIDENTIALATTORNEYS' EYESONLY Selected Previous OIR Projects and End Products • EarlyAction Admissions Analysis (2011): Understand the effect on our pool of applicants and yield rates as a result of eliminating early action in 2007. Redacted Redacted  Financial Aid at Harvard College (2009): An analysis of the changes in applicants, matriculants, and financial aid expenditures, as a result of recent changes in financial aid. • Undergraduate Financial Aid Budgeting/Forecasting (2007-2011): Provide forecasts to College Finance and Financial Aid based on 2007 models for the Affordability Initiative; Modeled potential changes to inform leadership decisions to modify program in 2011 8ST89000MVH • Financial Aid Calculator Development: Supported the Office of Financial Aid at Harvard College in the development of a simple financial aid calculator, meeting the Department of Education requirement in Fall 2011.  A checkmark indicates example work from this project is included in subsequent pages. Redacted 1VIlN30IJNODAlFIDIH A1N0S3A3 ,SA3N1OLLV Examples of OIR Work The following slides represent a sample of previous and ongoing work in the Office of Institutional Research. These are taken from presentations or other OIR work and do not represent complete reports in any case. Redacted • Selected Slides from Financial Aid at Harvard College (2009) 6ST89000/MH Redacted F II i III III IIIi 1' 1 1 1 1 1 1 1 1 1 1 1 1 1 HIGHLY CONFIDENTIAL — ATTORNEYS' EYES ONLY 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 HARV00068160 F II i III III IIIi 1' 1 1 1 1 1 1 1 1 1 1 1 1 1 HIGHLY CONFIDENTIAL — ATTORNEYS' EYES ONLY 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 HARV00068161 1114 iv um ompoll 11111ll li i i l 11II I II I Ili i0111II 111 HIGHLY CONFIDENTIAL — ATTORNEYS' EYES ONLY HARV00068162 1114 iv um ompoll 11111ll li i i l 11II I II I Ili i0111II 111 HIGHLY CONFIDENTIAL — ATTORNEYS' EYES ONLY HARV00068163 1114 iv um ompoll 11111ll li i i l 11II I II I Ili i0111II 111 HIGHLY CONFIDENTIAL — ATTORNEYS' EYES ONLY HARV00068164 I 01 II ty Salar Anal tis 1 1 HIGHLY CONFIDENTIAL — ATTORNEYS' EYES ONLY I I I I I I I 1 1 I I I I I I I I I I I I I I 1 1 I I I I I I I 1 1 I I I I I I I 1 1 HARV00068165 I 01 II ty Salar Anal tis 1 1 HIGHLY CONFIDENTIAL — ATTORNEYS' EYES ONLY I I I I I I I 1 1 I I I I I I I I I I I I I I 1 1 I I I I I I I 1 1 I I I I I I I 1 1 HARV00068166 s 111111 11 1111111 11 1111111 1111111 11 1111111 11 1111111 11 II I II I II I II I II I II I II I II I I II I II I II I II I II I II I II I II I I I -cs a) 0 (s a) CC HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY HARV00068167 s 111111 11 1111111 11 1111111 1111111 11 1111111 11 1111111 11 II I II I II I II I II I II I II I II I I II I II I II I II I II I II I II I II I I I -cs a) 0 (s a) CC HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY HARV00068168 111111 thiat b andPeers'Anabis HIGHLY CONFIDENTIAL — ATTORNEYS' EYES ONLY I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I HARV00068169 111111 thiat b andPeers'Anabis HIGHLY CONFIDENTIAL — ATTORNEYS' EYES ONLY I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I HARV00068170 HIGHLYCONFIDENTIALATTORNEYS' EYESONLY The diversity of applicants and matriculants has increased Harvard Applicants by Race/Ethnicity Harvard Matriculants by Race/Ethnicity 2009 2000 2000 Entering Fall Entering Fall ILT 89000ffiNH s Black 21 2009 s Hispanic D International HIGHLYCONFIDENTIALATTORNEYS' EYESONLY Increasing diversity while maintaining admissions standards is a slow process, but the initiatives appear to be helping: Applicants Average number of "minority" and "majority" entering applicants and admits: two decades preceding the initiatives compared to the five years since the initiatives 1984-1993 Average 1994-2003 Average 4 2916 Applicants Initiatives 4919 2004-2008 Average "Minority" applicants have grown pre-initiative to post initiative (+100%) more than "Majority" applicants (+29%) 7849 Underrepresented minority and international students Admits ZLI89000ffiNH White, Asian, Other, Unknown 22 10,369 13,158 15,215 HIGHLYCONFIDENTIALATTORNEYS' EYESONLY Increasing diversity while maintaining admissions standards is a slow process, but the initiatives appear to be helping: Admits and Matriculants Average number of "minority" and "majority" entering admits and matriculants: two decades preceding the initiatives compared to the five years since the initiatives "Minority" admits and matriculants have increased postinitiative (+24% and +32% respectively), while "Majority" admits and matriculants have decreased (-13% and -6% respectively) Initiatives 1984-1993 Average 1994-2003 Average 2004-2008 Average 458 522 609 (68% yield) (73% yield) (75% yield) Underrepresented minority and international students UT89000MVH White, Asian, Other, Unknown 1738 Admits 1552 1436 (75% yield) (80% yield) (83% yield) i . M ..P ... 1111=1=117 I II I I I I I I I I HIGHLY CONFIDENTIAL — ATTORNEYS' EYES ONLY 1111111 II 1111111 1111111 II 1111111 I 1111111 II HARV00068174

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