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).
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EXHIBIT 273
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UNITED STATES DISTRICT COURT
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DISTRICT OF MASSACHUSETTS
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_______________________________
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STUDENTS FOR FAIR ADMISSIONS, INC.,
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Plaintiff,
v.
No. 1:14-cv-14176
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PRESIDENT AND FELLOWS OF
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HARVARD COLLEGE
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(HARVARD CORPORATION),
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Defendant.
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__________________________
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VIDEO DEPOSITION of WILLIAM FITZSIMMONS
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Boston, Massachusetts
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August 3, 2017
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Reported by:
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Dana Welch, CSR, RPR, CRR, CRC
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Job #127104
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Page 62
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FITZSIMMONS
A.
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Not off the top of my head.
MS. ELLSWORTH:
Can we take a quick break.
We've been going a little over an hour.
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MR. STRAWBRIDGE:
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THE VIDEOGRAPHER:
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Time now is 0916.
We're off the record.
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We can take a break.
(Proceedings interrupted at 9:16 a.m. and
reconvened at 9:30 a.m.)
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THE VIDEOGRAPHER:
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We're on the record.
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Time now is 0930.
BY MR. STRAWBRIDGE:
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Q.
During the break, Mr. Fitzsimmons, did you
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speak with your lawyers about your answers to the
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questions in this deposition?
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A.
Only in general terms.
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Q.
What types of general terms?
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A.
Mostly that they could not -- they did not
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want to discuss what I did.
Q.
The substance of your testimony, is that
what you're saying?
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A.
Not on substance.
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Q.
Okay.
We were talking about the searches
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that Harvard purchases from various standardized
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testing companies before the break.
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And you said
Page 63
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FITZSIMMONS
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in the last few years, some socioeconomic divisions
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of the search is available; is that correct?
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A.
Yes.
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Q.
Is that socioeconomic?
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I guess, how is that socioeconomic division made?
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Is that just by,
MS. ELLSWORTH:
A.
Objection.
I haven't seen the -- I'd have to say I
don't know precisely.
Q.
Do you know, for example, if it's by ZIP
Code?
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MS. ELLSWORTH:
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A.
I don't.
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Q.
Okay.
Objection.
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Do you know whether or not it's by,
you know, reported income level?
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MS. ELLSWORTH:
Objection.
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A.
I don't.
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Q.
You just don't know one way or another?
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A.
Not precisely.
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Q.
Okay.
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Does Harvard now purchase swaths of
testing results by socioeconomic status?
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MS. ELLSWORTH:
Objection.
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A.
I don't know precisely.
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Q.
You don't know whether it does or not?
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A.
No.
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