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 276
HIGHLY CONFIDENTIAL
Page 1
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IN THE UNITED STATES DISTRICT COURT
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FOR THE DISTRICT OF MASSACHUSETTS
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BOSTON DIVISION
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5
------------------------------------------X
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STUDENTS FOR FAIR ADMISSIONS, INC.,
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Plaintiff,
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Civil Action No.
9
vs.
1:14-cv-14176-ADB
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PRESIDENT AND FELLOWS OF HARVARD COLLEGE,
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(HARVARD CORPORATION),
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Defendant.
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------------------------------------------X
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** HIGHLY CONFIDENTIAL **
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18
Deposition of
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July 12, 2017
9:10 a.m.
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Taken at:
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23
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Wendy L. Klauss, RPR
212-279-9424
Veritext Legal Solutions
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212-490-3430
HIGHLY CONFIDENTIAL
Page 50
1
A.
Yes.
2
Q.
Did you see it before your
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deposition preparation?
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A.
Yes.
5
Q.
When did you see it?
6
A.
When I signed it on May 27, 2017.
7
Q.
Is that your signature on the
8
second page?
9
A.
Yes.
10
Q.
I'm sorry, I should have done this.
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I'll note for the record that this is a
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document titled the Declaration of
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MR. PARK:
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MS. MOONEY:
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2000.
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I'm sorry.
1999 to
Sorry about that.
Q.
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That's the second page.
Did you write this document?
MR. PARK:
Objection.
You can
answer.
20
A.
No.
21
Q.
Do you know who wrote it?
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A.
No.
23
Q.
Did counsel provide this document
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for you to sign?
25
A.
212-279-9424
Counsel, as in -Veritext Legal Solutions
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HIGHLY CONFIDENTIAL
Page 51
1
Q.
Did Mr. Park or one of his
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colleagues at Consovoy McCarthy & Park or from
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Burns & Levinson provided this document for you
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to sign?
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MR. PARK:
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7
A.
I can't recall exactly who gave me
the document to sign, but, yeah.
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9
Objection.
Q.
It was one of SFFA's lawyers who
gave you the document to sign?
10
A.
I believe so.
11
Q.
Did you review the document before
12
signed it?
13
A.
Yes.
14
Q.
Did you make any changes to the
15
document before you signed it?
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A.
No.
17
Q.
Sitting here today, is everything
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in this declaration true and accurate?
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MR. PARK:
Objection.
20
A.
Yes, as far as I see.
21
Q.
Could you please read paragraph 6
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for me.
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A.
"I am able and ready to apply to
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transfer to Harvard were it to cease the use of
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race or ethnicity as an admissions preference
212-279-9424
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212-490-3430
HIGHLY CONFIDENTIAL
Page 52
1
and to cease its intentional discrimination
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against Asian Americans."
3
4
Q.
Thank you.
Was this statement
accurate when you signed the declaration?
5
A.
Yes.
6
Q.
Is it still true?
7
A.
Yes.
8
Q.
The statement says that you are
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ready to apply only if it ceases the use of
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race or ethnicity as an admissions preference
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and to cease its intentional discrimination
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against Asian Americans, correct?
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MR. PARK:
Objection.
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A.
Correct.
15
Q.
If Harvard does cease the use of
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race or ethnicity as an admissions preference,
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would you plan to apply to transfer?
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MR. PARK:
19
A.
Objection.
As the document says, I'm able and
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ready to apply to transfer, were it to cease
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the use of race.
22
Q.
If it doesn't cease the use of race
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or ethnicity during your time at
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next four years, do you plan to apply to
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transfer?
212-279-9424
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in the
212-490-3430
HIGHLY CONFIDENTIAL
Page 53
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MR. PARK:
2
A.
Objection.
I would definitely plan less so,
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because it is a matter of worth at that point.
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Only if I think that it is worth it, meaning if
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I think my chances are at least feasible would
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I consider to apply for a transfer, and that,
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as the document says, were it to cease the use
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of race or ethnicity, I think those chances
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would be improved and it would be worth the
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effort to apply for a transfer at that point.
11
Q.
Do you think it will be worth it
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even if you made friends at
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enrolled in a course of study and gotten
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comfortable at
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MR. PARK:
16
A.
and
Objection.
Again, highly speculative.
Perhaps
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at the time, but I would have to consider, I
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would have to weigh my options at the time to
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determine how they are.
20
Q.
Would you read paragraph 7 for me.
21
A.
"I became a member of Students For
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Fair Admissions in April 2017 because I support
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its mission and belief that Harvard College and
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many other colleges and universities wrongly
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discriminate against Asian Americans applicants
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