Students for Fair Admissions, Inc. v. President and Fellows of Harvard College et al
Filing
569
Opposition re 547 MOTION in Limine filed by Students for Fair Admissions, Inc.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15, # 16 Exhibit 16)(Mortara, Adam) (Attachment 6 replaced on 10/1/2018) (McDonagh, Christina). (Additional attachment(s) added on 10/2/2018: # 17 Unredacted Memorandum in Opposition (FILED UNDER SEAL), # 18 Exhibit 4 (Filed Under Seal)) (McDonagh, Christina).
Exhibit 14
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UNITED STATES DISTRICT COURT
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DISTRICT OF MASSACHUSETTS
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_______________________________
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STUDENTS FOR FAIR ADMISSIONS, INC.,
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Plaintiff,
v.
No. 1:14-cv-14176
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PRESIDENT AND FELLOWS OF
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HARVARD COLLEGE
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(HARVARD CORPORATION),
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Defendant.
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__________________________
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VIDEO DEPOSITION of WILLIAM FITZSIMMONS
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Boston, Massachusetts
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August 3, 2017
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Reported by:
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Dana Welch, CSR, RPR, CRR, CRC
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Job #127104
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FITZSIMMONS
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can ask that question after a break.
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hour and 20 minutes.
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THE VIDEOGRAPHER:
(Proceedings interrupted at 6:58 p.m. and
reconvened at 7:13 p.m.)
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Time now is 1858.
We're off the record.
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It's been an
THE VIDEOGRAPHER:
Time now is 1913.
We're on the record.
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MR. STRAWBRIDGE:
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BY MR. STRAWBRIDGE:
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was:
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Chosen?
The question before we broke
Have you read Jerome Karabel's book The
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MS. ELLSWORTH:
Objection.
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A.
Yes.
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Q.
Do you believe that he accurately
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describes the history of Harvard's admissions
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process?
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MS. ELLSWORTH:
A.
Objection.
I read his account carefully.
I don't
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have any independent corroboration of what was in
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the book.
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Q.
Is it your testimony that you don't have
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any idea whether or not Harvard's admissions
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process was abused in order to limit the number of
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FITZSIMMONS
Jewish students on campus?
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MS. ELLSWORTH:
Q.
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Last century?
MS. ELLSWORTH:
A.
Objection.
Objection.
What I was saying is that the holistic
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admissions process of which I have been a part
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since I arrived in the office, you know, certainly
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is not like the one you describe.
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Q.
But my question was just is it possible
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that a holistic admissions process could
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nonetheless be abused in a discriminatory fashion?
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MS. ELLSWORTH:
A.
Objection.
Again, I don't know exactly whether what
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was described in that book or what I've read in
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other accounts was anything like holistic
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admissions processes that exist today.
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Q.
to ever abuse a holistic admissions process?
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Do you think it's impossible for anybody
MS. ELLSWORTH:
A.
Objection.
I think it would be impossible to abuse
the admissions process that -- that we have.
Q.
Nothing in this report gave you any
concerns?
MS. ELLSWORTH:
Objection.
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FITZSIMMONS
Q.
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MS. ELLSWORTH:
Are you referring to
Exhibit 17?
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When you saw it?
MR. STRAWBRIDGE:
A.
Yes.
The information provided, we certainly
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looked at the information, and we always like to
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get new information as we proceed.
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Q.
And what did you do with this information?
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A.
I'm not aware there was specific
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follow-up.
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Q.
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Are you aware of any follow-up?
MS. ELLSWORTH:
A.
Objection.
I think the fact that the admission --
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that this information was presented to us and that
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it was delivered to us was certainly something in
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our minds as we proceeded from there.
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Q.
That was -- but you didn't ask for any
further research?
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A.
Not that I recall.
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Q.
And you didn't discuss this with anybody
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else in the admissions office?
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MS. ELLSWORTH:
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A.
Objection.
I think it's possible that were other
members of the admissions office present for this.
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CERTIFICATE
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Commonwealth of Massachusetts
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Suffolk, ss.
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I, Dana Welch, Registered Professional
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Reporter, Certified Realtime Reporter and Notary
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Public in and for the Commonwealth of
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Massachusetts, do hereby certify that WILLIAM
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FITZSIMMONS, the witness whose deposition is
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hereinbefore set forth, was duly sworn by me and
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that such deposition is a true record of the
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testimony given by the witness.
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I further certify that I am neither related
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to nor employed by any of the parties in or counsel
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to this action, nor am I financially interested in
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the outcome of this action.
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In witness whereof, I have hereunto set my
hand and seal this 15th day of August, 2017.
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____________________________
Dana Welch
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Notary Public
My commission expires:
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October 6, 2017
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