Students for Fair Admissions, Inc. v. President and Fellows of Harvard College et al
Filing
471
AMICUS BRIEF filed by Coalition for a Diverse Harvard, First Generation Harvard Alumni, Fuerza Latina of Harvard, Harvard Asian American Brotherhood, Harvard Islamic Society, Harvard Japan Society, Harvard Korean Association, Harvard Latino Alumni Alliance, Harvard Minority Association of Pre-Medical Students, Harvard Phillips Brooks House Association, Harvard South Asian Association, Harvard University Muslim Alumni, Harvard Vietnamese Association, Harvard-Radcliffe Asian American Association, Harvard-Radcliffe Asian American Women's Association, Harvard-Radcliffe Black Students Association, Harvard-Radcliffe Chinese Students Association, Kuumba Singers of Harvard College, Native American Alumni of Harvard University, Native Americans At Harvard College, Task Force on Asian and Pacific American Studies at Harvard College in Support of Defendants' Motion for Summary Judgment. (Attachments: # 1 Exhibit 2 Declaration, # 2 Exhibit 3 Declaration, # 3 Exhibit 4 Declaration, # 4 Exhibit 5 Declaration, # 5 Exhibit 6 Declaration, # 6 Exhibit 7 Declaration, # 7 Exhibit 8 Declaration, # 8 Exhibit 9 Declaration, # 9 Exhibit 10 Declaration, # 10 Exhibit 11 Declaration, # 11 Exhibit 12 Declaration, # 12 Exhibit 13 Declaration, # 13 Exhibit 14 Declaration, # 14 Exhibit 15 Declaration, # 15 Exhibit 16 Declaration, # 16 Exhibit 17 Declaration)(Thayer, Kenneth)
EXHIBIT 4
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS
BOSTON DIVISION
STUDENTS FOR FAIR ADMISSIONS, INC,
Plaintiff,
v.
PRESIDENT AND FELLOWS OF
HARVARD COLLEGE (HARVARD
CORPORATION),
Civil Action No. 1:14-cv-14176-ADB
Leave to file granted on July 31, 2018
Defendant.
DECLARATION OF JONATHAN PAEK
(HARVARD-RADCLIFFE ASIAN AMERICAN ASSOCIATION)
Jonathan Paek, pursuant to 28 U.S.C. § 1746, declares the following:
1.
My name is Jonathan Paek. I am a rising junior at Harvard and expect to earn my
bachelor’s degree in Sociology in 2020. I am writing this declaration individually and on behalf
of the Harvard-Radcliffe Asian American Association (“AAA”) in support of race consciousness
in Harvard College’s admissions policy.
2.
Along with Genevieve Hu, I am Co-President of AAA. After consulting with
AAA’s board members, I have been given authority to submit this declaration on behalf of AAA.
3.
AAA was founded in 1976 to unite Asian American students at Harvard and raise
greater awareness of Asian American issues through social, cultural, and political events. AAA
seeks to foster a community within Harvard dedicated to embracing our shared identity and
promoting greater awareness of Asian American issues and perspectives; provide a forum for
Asian Americans at Harvard to voice their opinions and comfortably explore their culture, identity,
and individuality; address political, economic, and social issues affecting our communities at
Harvard, as well as at the local and national levels; celebrate achievements of Asian Americans,
including those in the arts, entertainment, politics, business, science, and academia; develop longlasting partnerships between students, alumni, community activists, and scholars; and inspire
participants to contemplate their roles and responsibilities in forging the future of Asian America.
4.
AAA supports the consideration of race in admission because race plays a serious
role in our lives and greatly affects each person’s lived experiences. Race is a factor, among many,
that should be considered for a university to better understand its applicants and their experiences.
Moreover, it is important to note that we are not currently in a society where all racial backgrounds
have equal opportunities and access to higher education. As such, it is even more critical to take
into consideration the distinct challenges that minority groups face.
5.
In addition, it is important to have a diverse student body in order to promote a
well-rounded educational experience. Learning from people who have lived experiences that are
different from our own helps with the development of genuine human connection and
understanding. I have been able to learn so many valuable lessons from my peers that I have not–
and would not have—been able to experience or understand myself. While these lessons should
never be interpreted as the sole explanation for an entire community or as tokenizing individuals,
they have added different perspectives to my life and have made me a better person.
6.
Outlawing the consideration of race in admissions would detrimentally affect the
student experience at Harvard. Not only would we be deprived of the benefits of learning from a
wealth of experiences of others who are different from us, but students of color would also feel
much less comfortable on campus. Having a sufficient number of students from different minority
groups is imperative to promote genuine environments of inclusion and for organizations like AAA
2
to function properly and serve their communities. If Mr. Blum’s efforts to end the consideration
of race in admissions are successful, future students may not enjoy a sense of belonging and
organizations that historically serve minority communities could lose members of their population
as well as their ability to serve them.
7.
Nevertheless, AAA firmly opposes racial discrimination and is very troubled that
Harvard has been accused of intentionally discriminating against Asian American applicants.
8.
While we are not in a position to say whether those allegations are true, AAA does
believe that those in Harvard’s admissions process may be affected by implicit bias.
9.
It is absolutely imperative that Harvard takes these allegations seriously and takes
deliberate steps to make its admissions process more equitable. We strongly recommend that
Harvard conducts deeper reviews of its admissions process, hires more Asian American
admissions officers, recruits more Asian American alumni interviewers, and does implicit bias
training to ensure that everyone involved in the admissions process is aware of the myriad lived
experiences of applicants from various Asian American subgroups.
10.
Likewise, AAA condemns the prevailing treatment of Asian Americans as a
monolith—as though all Asian Americans have access to the same opportunities and share the
same lived experiences. Asian Americans are incredibly diverse with vastly different lived
experiences. Asian Americans have and do benefit from race conscious policies, and applying
blanket statements on behalf of the population is misleading and irresponsible.
11.
As such, we believe that it is incredibly important that Asian American
organizations on campus are given the opportunity to have conversations with administrators to
help ensure that steps are taken to move forward towards a more equitable admissions process.
3
12.
AAA and its board strongly oppose the usage of Asian Americans as a political
weapon to pit minority groups against each other. We are proud of our history of representing
Asian Americans and lending to our fellow minority communities and people of color. We will
not waver from that support now.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on this day, July 29, 2018
/s/ Jonathan Paek
Jonathan Paek
4
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