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).
<![CDATA[
EXHIBIT 267
In The Matter Of:
Students for Fair Admissions, Inc. v.
President and Fellows of Harvard College
Sarah C. Donahue
June 6, 2017
Highly Confidential - For Attorneys' Eyes Only
195 State Street • Boston, MA 02109
888.825.3376 - 617.399.0130
Global Solutions
court-reporting.com
Original File Sarah Donahue 6-6-17.txt
Min-U-Script® with Word Index
Sarah C. Donahue - June 6, 2017
Highly Confidential - For Attorneys' Eyes Only
1
MS. ELLSWORTH:
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3
A.
Objection.
Sometimes.
BY MR. STRAWBRIDGE:
4
Q.
Is ethnicity sometimes the subject of
5
questions or commentary by other members of the
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committee?
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MS. ELLSWORTH:
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9
A.
Objection.
Not usually.
BY MR. STRAWBRIDGE:
10
Q.
Can you say how often in a given case --
11
sorry -- how often in a given cycle someone
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presenting a candidate for admission might
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mention ethnicity?
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MS. ELLSWORTH:
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16
A.
Q.
all?
Can you give me any quantification at
Is it rare?
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It is hard to say.
BY MR. STRAWBRIDGE:
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Objection.
MS. ELLSWORTH:
A.
Objection.
I would say it is not often.
21
information is right there.
22
The
BY MR. STRAWBRIDGE:
23
24
Q.
To what extent does Dean Fitzsimmons
participate in the individual candidate
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Sarah C. Donahue - June 6, 2017
Highly Confidential - For Attorneys' Eyes Only
1
discussions?
2
A.
As a member of the committee.
3
Q.
Does his view get deference, in your
4
experience?
5
MS. ELLSWORTH:
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7
A.
Objection.
I think people respect his view.
BY MR. STRAWBRIDGE:
8
Q.
Been doing this for a long time; right?
9
A.
Yes.
10
Q.
He is the leader of the office?
11
A.
Yes.
12
Q.
Perhaps not surprising to think that
13
people would be inclined to give a lot of weight
14
to his view, just by those reasons alone?
15
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MS. ELLSWORTH:
Objection.
BY MR. STRAWBRIDGE:
17
Q.
Is that correct?
18
A.
Yes.
19
Q.
Do you recall occasions when his view or
20
his support for a candidate has not carried the
21
day?
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MS. ELLSWORTH:
A.
Objection.
Yes.
BY MR. STRAWBRIDGE:
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Sarah C. Donahue - June 6, 2017
Highly Confidential - For Attorneys' Eyes Only
1
2
Q.
Can you give me an example of that, just
off the top of your head?
3
MS. ELLSWORTH:
Objection.
4
I will just remind the witness not to
5
disclose any identifying information about any
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students to that extent.
7
MR. STRAWBRIDGE:
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of anybody.
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12
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MS. ELLSWORTH:
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Or any information that
could make someone identifiable.
A.
I can't recall the specific cases.
BY MR. STRAWBRIDGE:
Q.
You just know it has happened on
occasion?
15
16
I don't want the names
MS. ELLSWORTH:
A.
Objection.
Yes.
BY MR. STRAWBRIDGE:
Q.
What about Ms. McGrath?
Does she
19
participate in the discussion of the individual
20
candidates?
21
A.
Yes.
22
Q.
Do Dean Fitzsimmons and Ms. McGrath take
23
an interest or participate at any level greater
24
than the other people in the room?
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Sarah C. Donahue - June 6, 2017
Highly Confidential - For Attorneys' Eyes Only
1
2
3
4
MS. ELLSWORTH:
A.
Objection.
Not particularly.
BY MR. STRAWBRIDGE:
Q.
Does Ms. McGrath's view, like Dean
5
Fitzsimmons, tend to get considerable respect
6
from the people in the room?
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8
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MS. ELLSWORTH:
A.
Objection.
Yes.
BY MR. STRAWBRIDGE:
Q.
People during the committee process -- I
11
mean do they sometimes get -- do they sometimes
12
make strong pushes for particular candidates who
13
they feel strongly about?
14
A.
Yes.
15
Q.
Can it sometimes be a robust discussion
16
in terms of trying to make these decisions?
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MS. ELLSWORTH:
A.
Objection.
Yes.
BY MR. STRAWBRIDGE:
Q.
And does Dean Fitzsimmons sometimes bring
21
forward people who he thinks that the committee
22
should consider or take another look at?
23
24
MS. ELLSWORTH:
A.
Objection.
Not usually.
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