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

Filing 454

DECLARATION of Michael Connolly in Support of SFFA's Opposition to Harvard's Motion for Summary Judgment by Students for Fair Admissions, Inc.. (Attachments: # 1 Exhibit 262, # 2 Exhibit 263, # 3 Exhibit 264, # 4 Exhibit 265, # 5 Exhibit 266, # 6 Exhibit 267, # 7 Exhibit 268, # 8 Exhibit 269, # 9 Exhibit 270, # 10 Exhibit 271, # 11 Exhibit 272, # 12 Exhibit 273, # 13 Exhibit 274, # 14 Exhibit 275, # 15 Exhibit 276, # 16 Exhibit 277, # 17 Exhibit 278, # 18 Exhibit 279, # 19 Exhibit 280, # 20 Exhibit 281, # 21 Exhibit 282, # 22 Exhibit 283, # 23 Exhibit 284, # 24 Exhibit 285)(Consovoy, William) (Additional attachment(s) added on 7/31/2018: # 25 Unredacted DECLARATION of Michael Connolly in Support of SFFA's Opposition to Harvard's Motion for Summary Judgment (Filed Under Seal), # 26 Exhibit 262 (Filed Under Seal), # 27 Exhibit 263 (Filed Under Seal), # 28 Exhibit 264 (Filed Under Seal), # 29 Exhibit 265 (Filed Under Seal), # 30 Exhibit 266 (Filed Under Seal), # 31 Exhibit 267 (Filed Under Seal), # 32 Exhibit 268 (Filed Under Seal), # 33 Exhibit 269 (Filed Under Seal), # 34 Exhibit 270 (Filed Under Seal), # 35 Exhibit 271 (Filed Under Seal), # 36 Exhibit 272 (Filed Under Seal), # 37 Exhibit 273 (Filed Under Seal), # 38 Exhibit 274 (Filed Under Seal), # 39 Exhibit 275 (Filed Under Seal), # 40 Exhibit 276 (Filed Under Seal), # 41 Exhibit 277 (Filed Under Seal), # 42 Exhibit 278 (Filed Under Seal), # 43 Exhibit 279 (Filed Under Seal), # 44 Exhibit 280 (Filed Under Seal), # 45 Exhibit 281 (Filed Under Seal), # 46 Exhibit 282 (Filed Under Seal), # 47 Exhibit 283 (Filed Under Seal), # 48 Exhibit 284 (Filed Under Seal), # 49 Exhibit 285 (Filed Under Seal)) (McDonagh, Christina).

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 SFFA’S
OPPOSITION TO HARVARD’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 opposition to Harvard’s motion for

summary judgment.
4.

Attached hereto as Exhibit 262 is a true and correct copy of excerpts of SFFA’s

Objections and Responses to Plaintiff’s Second Set of Interrogatories.
5.

Attached hereto as Exhibit 263 is a true and correct copy of a document bearing

bates number SFFA-Harvard 0000008-51 that was produced by SFFA in this litigation.
6.

Attached hereto as Exhibit 264 is a true and correct copy of a document bearing

bates number SFFA-Harvard 0000059-65 that was produced by SFFA in this litigation.

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7.

Attached hereto as Exhibit 265 is a true and correct copy of a document bearing

bates number SFFA-Harvard 0000001 that was produced by SFFA in this litigation.
8.

Attached hereto as Exhibit 266 is a true and correct copy of a document bearing

bates number SFFA-Harvard 0000052-67 that was produced by SFFA in this litigation.
9.

Attached hereto as Exhibit 267 is a true and correct copy of excerpts of the June

6, 2017 deposition of Sally Donahue.
10.

Attached hereto as Exhibit 268 is a true and correct copy of a document entitled

“2,058 Accepted Into Class of 2011,” which was obtained on July 27, 2018 from the website
https://www.thecrimson.com/article/2007/3/29/2058-accepted-into-class-of-2011/.
11.

Attached hereto as Exhibit 269 is a true and correct copy of a document entitled

“College admits Class of ’18,” which was obtained on July 27, 2018 from the website
https://news.harvard.edu/gazette/story/2014/03/college-admits-class-of-18/.
12.

Attached hereto as Exhibit 270 is a true and correct copy of a document entitled

“Harvard College admits 1,990,” which was obtained on July 27, 2018 from the website
https://news.harvard.edu/gazette/story/2015/04/harvard-college-admits-1990/.
13.

Attached hereto as Exhibit 271 is a true and correct copy of a document entitled

“College admits 2,037,” which was obtained on July 27, 2018 from the website
https://news.harvard.edu/gazette/story/2016/04/college-admits-2037/.
14.

Attached hereto as Exhibit 272 is a true and correct copy of a document entitled

“Harvard College admits 2,056 to Class of ’21,” which was obtained on July 27, 2018 from the
website

https://news.harvard.edu/gazette/story/2017/03/2056-applicants-were-invited-today-to-

join-harvard-colleges-class-of-2021.

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15.

Attached hereto as Exhibit 273 is a true and correct copy of excerpts of the

August 3, 2017 deposition of William Fitzsimmons.
16.

Attached hereto as Exhibit 274 is a true and correct copy of document excerpts

bearing bates numbers HARV00007805 through HARV00007810 that were produced by
Harvard in this litigation.
17.

Attached hereto as Exhibit 275 is a true and correct copy of excerpts of the June

16, 2017 deposition of
18.

Attached hereto as Exhibit 276 is a true and correct copy of excerpts of the July

12, 2017 deposition of
19.

Attached hereto as Exhibit 277 is a true and correct copy of the declaration of
, which was executed on June 27, 2018.

20.

Attached hereto as Exhibit 278 is a true and correct copy of the declaration of
, which was executed on June 26, 2018.

21.

Attached hereto as Exhibit 279 is a true and correct copy of the declaration of

, which was executed on April 4, 2018.
22.

Attached hereto as Exhibit 280 is a true and correct copy of the declaration of
, which was executed on June 19, 2018.

23.

Attached hereto as Exhibit 281 is a true and correct copy of the declaration of
, which was executed on July 3, 2018.

24.

Attached hereto as Exhibit 282 is a true and correct copy of the declaration of

, which was executed on June 26, 2018.
25.

Attached hereto as Exhibit 283 is a true and correct copy of the declaration of
, which was executed on June 21, 2018.

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26.

Attached hereto as Exhibit 284 is a true and correct copy of the declaration of

Peter Arcidiacono, which was executed on July 30, 2018.
27.

Attached hereto as Exhibit 285 is a true and correct copy of excerpts of the July

12, 2016 deposition of Edward Blum.

*

*

*

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, July 30, 2018.

/s/ Michael Connolly
Michael Connolly

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