Students for Fair Admissions, Inc. v. President and Fellows of Harvard College et al

Filing 570

PRETRIAL MEMORANDUM by Students for Fair Admissions, Inc.. (Attachments: # 1 Exhibit A1, # 2 Exhibit A2, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F)(Mortara, Adam) (Additional attachment(s) added on 10/2/2018: # 8 Exhibit A1 (Filed Under Seal)) (McDonagh, Christina).

Exhibit A2

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS
BOSTON DIVISION
STUDENTS FOR FAIR ADMISSIONS, INC.,
Plaintiff,
v.

Civ. Act. No. 1:14-cv-14176-ADB

PRESIDENT AND FELLOWS OF HARVARD
COLLEGE,
Defendant.

HARVARD’S OBJECTIONS TO SFFA’S WITNESS LIST
Defendant President and Fellows of Harvard College (“Harvard”) hereby submits the
following objections to Students for Fair Admissions, Inc.’s (“SFFA”) witness list. Harvard
reserves the right to supplement these objections.
Name
Charlene Kim

Christina Lopez

Casey Pedrick

Contact
Information

Will Call/
May Call

Harvard’s Objections

Contact through
counsel

May Call

SFFA did not timely disclose Ms. Kim as a
witness. SFFA did not add Ms. Kim to its
witness list until September 19, 2018, nearly
two weeks after the September 7, 2018
deadline by which to disclose witnesses.

111 Milbank Hall
3009 Broadway
New York, NY
10027
212-854-2014
345 Chambers St
New York, NY
10282
212-312-4800

May Call
(by deposition)

Ms. Lopez’s testimony is not relevant under
FRE 401.

May Call
(by deposition)

Ms. Pedrick’s testimony is not relevant under
FRE 401.

Name

Contact
Information

Will Call/
May Call

Harvard’s Objections

Ruth Simmons

P.O. Box 519;
MS 1001
Alvin I. Thomas
Bldg., Suite 202
Prairie View, TX
77446
936-261-2111

Will Call

Fabio Zuluaga

8115 Gatehouse Rd
Falls Church, VA
22042
571-423-1120

May Call
(by deposition)

As Harvard’s expert witness, Dr. Simmons
cannot be called in SFFA’s case-in-chief.
SFFA may cross-examine Dr. Simmons after
she has offered testimony on direct
examination by Harvard. Additionally, SFFA
did not timely disclose President Simmons as a
live witness. On September 7, 2018, the date
on which the parties exchanged witness lists,
SFFA indicated that it might call President
Simmons by deposition. SFFA did not indicate
that it will call President Simmons as a live
witness until September 11, 2018.
Mr. Zuluaga’s testimony is not relevant under
FRE 401.