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 284 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 PETER ARCIDIACONO I, Peter Arcidiacono, pursuant to 28 U.S.C. § 1746, declare the following: 1. I make this declaration at the request of counsel for Plaintiff Students for Fair Admissions, Inc. (“SFFA”), and if called upon to testify as to the contents of this declaration would testify competently thereto. 2. In my opening report, I included figures showing the share of admits to Harvard by race from the Class of 2000 through the Class of 2019. See Arcidiacono Rep. Figures B.1.1B.1.4. The table below provides the numbers that correspond with those charts: 1 Table 1: Share of admits by race and year 3. In Professor Card’s Rebuttal Report, he presents a chart comparing the average marginal effect of several different characteristics, including being African American, being Hispanic, going from a 3 to a 1 on the academic rating, going from a 3 to a 1 on the extracurricular rating, and going from a 3 to a 1 on the personal rating. See Card Rebuttal 72, ¶ 143 & Ex. 23. Professor Card provided me with the model by which he calculated these figures. The table below provides various numbers of applicants in each of these groups from the model Professor Card produced: 2 Table 2: Number and Share by Characteristic for Professor Card’s Estimation Sample 4. According to data produced by Harvard in this matter, Harvard has admitted the following numbers and shares of single-race African-American admits and total domestic admits: Table 3: Number of single-race African-American and total admits by admission cycle 5. In advance of the deposition of Professor David Card, counsel for SFFA asked me to pull data showing how the admission rates of certain groups of white and Asian-American applicants vary with the academic rating. Specifically, counsel asked for such data for recruited athletes, applicants from the other special recruiting categories, and all other domestic applicants. 3 In response to this request, I created the table that is Exhibit 8 to the Card deposition transcript. It reflects an accurate count of domestic applicants in these categories (and their respective admission rates) and is reproduced here: Table 4: Admissions Rates by ALDC and Academic Rating for Domestic white and Asian-American Applicants 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/ Peter Arcidiacono Peter Arcidiacono 4

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