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 285
HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
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UNITED STATES DISTRICT COURT
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FOR THE DISTRICT OF MASSACHUSETTS
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BOSTON DIVISION
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STUDENTS FOR FAIR ADMISSIONS,
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INC.,
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Plaintiff,
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v.
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PRESIDENT AND FELLOWS OF HARVARD
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COLLEGE (HARVARD CORPORATION),
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Defendant.
Civil Action
No. 14-cv-14176
(ADB)
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HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
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Rule 30(b)(6) Notice to Students for Fair
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Admissions, Inc.
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Videotaped Deposition of EDWARD J. BLUM
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Tuesday, July 12, 2016
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9:05 a.m.
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Wilmer Cutler Pickering Hale and Dorr LLP
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60 State Street - 26th Floor
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Boston, Massachusetts 02109
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J. Edward Varallo, RMR, CRR
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Registered Professional Reporter
212-279-9424
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HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
Page 47
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around the time that you became a member?
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A.
Yes.
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Q.
Which would have been summer of 2013?
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A.
Yes.
5
Q.
So again that's before SFFA was
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incorporated as an entity.
Correct?
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A.
That's correct.
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Q.
Who maintained the member list in those
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early days of the summer of 2013?
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A.
I did.
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Q.
And how did you maintain it?
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In what
form?
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A.
Spreadsheet.
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Q.
An Excel spreadsheet?
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A.
Yes.
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Q.
What was the initial purpose of SFFA?
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A.
Membership organization.
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Q.
A membership organization to do what?
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A.
Dedicated to ending race-based admissions
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policies at American universities.
Q.
And that original -- what did I call it?
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-- initial purpose, is that maintained?
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same purpose of the organization today, as you
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understand it?
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A.
212-279-9424
Is that the
Yes.
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A.
Yes.
2
Q.
And how do you know that?
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4
How would SFFA
determine that a member agreed with the mission?
A.
Our mission statement was quite clear in
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emails, discussions, and subsequently our mission
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statement is very prominent on all of our
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communications and our website.
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Q.
So that describes how people know what the
mission is.
My question is, how do you know that
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the members who became members under these bylaws
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we're looking at in Exhibit 4 agreed with that
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mission?
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A.
I assume they would not have joined had
they disagreed with that mission.
Q.
But you don't know whether they joined
even if they disagreed with that mission?
A.
It seemed unlikely to me that -- If they
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joined, it seemed very likely that they agreed with
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the mission.
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Q.
And why do you say that?
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A.
Well, we were a relatively small group of
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people.
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labored in this movement.
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someone would call me and say "I want to be a
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member" or agree to be a member but disagree with
212-279-9424
We all knew one another.
We had all
It seems unlikely that
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