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).

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EXHIBIT 34 2014 Harvard College Admissions and Financial Aid Staff Name Title and Areas of Responsibility Phone ICM Fax E-mail Assistant Director ofAdmissions; Manager ofFreshman and Transfer Mail and Records Operations • Ian Anderson(IAN) Records Operations • Freshman and Transfer Mail 8821 ianders 5-8638 39 8328 balian 5-1572 27 8328 rbanks 5-5458 75 6-0256 boutte 36 8328 bowman 5-5379 48 8328 brown 6-5332 63 8328 clark6 5-8866 07 8328 gscheng 5-2224 76 8328 kclagett 4-7526 18 6-3229 molliedickerson 6-6752 58 8328 mdikkers 5-1580 45 6-0256 sdonahue 5- 133,1 31 8328 esposito Equipment • 23 6-5119 • 5-8637 Building Operations and Access Assistant to the Director ofAdmissions Andrea Balian • Faculty Standing Committee Director of Recruitment • Visitor Services * Tour Guide Program • Undergraduate hefinority RecruitmentProp= Roger Banks(RX13) Caroline Boutte-Thompson IT Operations Administrator for Financial Aid and Student Employment Admissions and Financial Aid Officer Pharen Bowman(PFl3) • Harvard Financial Aid Initiative and Outreach Program Admissions Officer • Publications • Yield Activity • Digital Communications Rachel Brown(RED) Assistant Director ofFinancial Aid and Senior Admissions Officer Jessica Clark Biyan gRq • Grace Cheng(GSC) Harvard UppexClass Renewal Team Associate Director of Admissions for Staff Development Admissions and Financial Aid Officer Mollie Dickerson • Harvard Upperclass Renewal Team • Katie Clagett(KEC) Study Abroad Funding Coordinator of Admissions Records Operations • Liaison to the Music Department • Liaison to the New England Conservatory Admissions Officer • Undergraduate Admissions Council • Visitas Hosting • Visitas Max Dikkers(MDD) Sarah Clark Donahue(SCD) Director ofFinancial Aid and Senior Admissions Officer Admissions and Financial Aid Officer • Beneficiary Aid • Mike Esposito(MFE) Harvard Summer School Funding Revised 01/14 CONFIDENTIAL HARV00003496 2014 Harvard College Admissions and Financial Aid Staff Name Title and Areas of Responsibility Phone ICM Fax E-mail Senior Admissions Officer David L.Evans(t)LE.) 5-5375 26 8328 dlevans Data Entry Coordinator 6-2374 50 8821 dicarlo Dean ofAdmissions and Financial Aid 5-1557 29 8321 wrf Reception Area Coordinator 4-5853 85 6-0256 efoley 5-2863 34 8328 jakefolcy 6-6635 16 8821 cfrodeim 6-0079 91 8328 jgandy 6-6438 92 6-0256 gambino 6-6692 46 8821 gilfillian 6-6812 11 6-0937 ggoode 5-0786 09 6-0256 gouinloc • Patricia DiCarlo Fagioli W illiam R. Fitzsimmons Undergraduate Admissions Council CWRF) Emily Foley Admissions Officer • Survey Information Local Event Outreach • Harvard Summer Institute • Cheryl Frodermann • • Jake Foley OAF) Undergraduate Admissions Council Digital Communications-. Oversight ofBlogs Director ofFinancial Administration and Special Projects Senior Admissions Officer Jennifer Gandy(IWG) • Stefanie Gambino Joint Travel Program . StaffAssistant III Admissions Officer • Tour Guide Program • Digital Communications • Visitas Events Bryce Gilfdlian(BJG) Gabriella Goode Admissions Information Area Representative Office Manager and Financial Aid Officer Hafting Gouinlock • Freshman Application Team Anthony Grant Admissions Information Services Supervisor 6-6728 12 6-0937 acgrant Rosemary Green (RisAG) Special Senior Admissions Officer 6-6741 32 8821 rgreen 5-5349 59 8328 swharty 6-5239 42 8328 howtigan 6-5163 33 6-0256 irons 6-6778 51 8821 kizzo Senior Admissions Officer Sally White Harty(SWH) Kaitlin Howligan(KAH) • Boston Area Recruiting Program Associate Director for Recruitment and Senior Admissions Officer Senior Associate Director ofFinancial Aid and Senior Admissions Officer Janet Irons OLD Financial Aid Statistics Reporting • Kristen Izzo • Liaison to International Office Information Processing Specialist Revised 01/14 CON FlDENTIAL HARV00003497 2014 Harvard College Admissions and Financial Aid Staff Title and Areas of Responsibility Name Niki Applebaum Johnson ( NAJ) ICM Fax E-mail Senior Admissions Officer Financial Aid Officer s Liaison to Harvard Dance Programs • Robyn Jones(REJ) Phone 5-9708 31 8328 applebaum 6-6786 30 8328 rejones 6-6188 71 6-0256 hones 6-5296 52 6-0256 jmkaufm 6-6189 69 6-0256 ckeating 89 8328 cskim Student Events Fund Admissions and Financial Aid Officer • Financial Literacy Senior Financial Aid Officer Tanya Joyner • Leaves ofAbsence • Loan Funding Associate Director ofFinancial Aid and Senior Admissions Officer Jake Kaufmann(JMK) Freshman Application Process • Charlene Keating • Military Outreach Coordinator ofUpperclass Renewal Process Senior Admissions and Financial Aid Officer Charlene Kim(CSK) • Harvard Financial Aid Initiative and Outreach Program • Liaison for Arts/Music/ NEC Funding 7819 Amy Lavoie Director of Digital Communications 6-6925 01 8328 aalavoic Kate Lebel Accounting Assistant 6-4372 40 8821 klebel 6-5134 54 6-0256 looby 5-2587 68 8422 iluvish 6-5231 61 6-0256 magnuson 3847629 88 8328 mascolo Senior Admissions and Financial Aid Officer Chris Looby(CJL) ROTC/Veterans Benefits Program • Ilya Luvish(FL) • GRE Waiver Program Manager ofFederal Work Study Program Associate Director ofFinancial Aid and Senior Admissions Officer Mary Magnuson oswm) • Officer of the Day Program Associate Director of Admissions;Director ofTransfer and VUS Admissions and Athletics Coordination Christine Gibbons Mascolo ( CGIV1) • Li Liaison to the Department of Athletics • Transfer Admissions • Visiting Undergraduate Student Program Victoria Maizilli Manager ofSocial Media Recruitment TBD Marlyn McGrath (IVIEM) Director of Admissions 5-5339 15 8321 mmcg Anne Marie McNamara Information Processing Specialist 6-6778 51 8821 mcnamara 6-6779 17 8328 miller16 Senior Admissions Officer Dwight Miller(DDM) • Administrative Plant* Justin Munio Loan Coordinator 6-1284 86 6-0256 ininnio Ben Norton Human Resources Assistant 6-4260 93 8821 l)notion Revised 01/14 CONFIDENTIAL HARV00003498 2014 Harvard College Admissions and Financial Aid Staff Name Title and Areas of Responsibility Phone ICM Fax E-mail Senior Admissions Officer Luceato Ortiz(LLO) • Tour Guide Program • Undergraduate Minority Recruitment Program 5-3634 37 8328 lortiz 6-6785 20 8321 pacholok 5-9839 35 8328 jparting 6-5173 77 6-0256 ccplumb 3847741 90 8328 tiamy 6-6775 49 8323 gregan Assistant to the Dean of Admissions and Financial Aid Olesia Pacholok • Judy Partington(JCP) Cambridge Admissions Conference Admissions Officer and International Admissions Administrator Assistant Director ofFinancial Aid Christopher Plumb • Freshman Application Process Admissions Officer Trudy Regan • Undergraduate Minority Recruitment Program • Visitas • Tia Ray(TMR) Non-Traditional Schooling Coordinator ofVUS Program • Liaison to the Freshman Dean's Office Vicky Robson Admissions Information Area Representative 6-6747 13 6-0937 robson Jonathan Rossi Outside Awards Coordinator 6-5179 70 6-5179 jonathanrossi Kristen Ryan(I(PR) Admissions and Financial Aid Officer 6-5117 60 6 C236 6-6828 56 8821 hframpt 6-5250 73 6-0256 lunymorse 5-1583 82 6-0256 mstetson 6-6628 24 8821 suorsa • GRE Waiver Program • kristetuyan Harvard Summer School Funding Mail and Transfer Operations Coordinator • College Nights and Publication Requests • Office Social Events • Transfer,VUS,and Freshman admissions reader Haley Frampton Shore(HFS) Associate Director ofFinancial Aid Amy Staffier Financial Aid for Federal Programs • Meghan Stetson (M/VIS) • Financial Aid Operations Group Admissions and Financial Aid Officer • Sage Suorsa Freshman Application Process Financial Associate • Admissions Phone Coordinator Meg Brooks Swift(MBS) Associate Director of Financial Aid 8c Director ofStudent Employment/Senior Admissions Officer 6-3190 84 8422 mbswift Dimity Thornton Admissions Information Area Representative 6-6842 10 6-0937 dimity.thornton @gmail.com Rick Van Rice Director ofInformation Technology for Harvard College Admissions and Financial Aid 6-1793 SO 6-0256 lice2 6-5218 65 6-0256 vidra Associate Director of Financial Aid and Senior Admissions Officer Ka duyit Vidra(KAV) • Scholarship Stewardship and Funding Revised 01/14 CONFIDENTIAL HARV00003499 2014 Harvard College Admissions and Financial Aid Staff Name Title and Areas of Responsibility Phone ICM Fax E-mail Admissions Officer • Brock Walsh(BPW) Alumni/ae Network Officer • 'Cambridge Admissions Conference • Vaughn Waters 38 8328 brockwalsh 5-3260 44 8321 vaughn_waters ©harvard.edu 6-5120 64 8328 weaver 6-6875 43 8328 klum Liaison to the Accessible Education Office • 5-5376 Host Family Program Administrative Director Admissions Officer Caroline Weaver(CAW) • Alumni/ae Network Officer • Visitas Admissions Officer Kanoe Lum Williams(KL\X) • Joint Travel Program • Visitas Eric Wong Systems Administrator for Admissions 5-8838 08 8821 ericwong Robin Worth (RIV1W) Director ofInternational Admissions 6-6923 47 8323 twordi Elizabeth Yong Special Projects Administrator for Admissions Policy,Research & Operations 6-4519 41 8821 yong TBD Data/Reporting Analyst TBD Program Manager for TT Revised 01/14 CONFIDENTIAL HARV00003500

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