Students for Fair Admissions, Inc. v. President and Fellows of Harvard College et al
Filing
571
Opposition re 546 MOTION in Limine filed by President and Fellows of Harvard College. (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)(Waxman, Seth)
EXHIBIT 9
HIGHLY CONFIDENTIAL -
ATTORNEYS EYES ONLY
Page 1
1
Erica J. Bever
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Volume I
Pages 1 to 363
Exhibits 1 to 23
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UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
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:
STUDENTS FOR FAIR ADMISSIONS,
:
INC.,
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Plaintiff,
:
:
vs.
:
:
PRESIDENT AND FELLOWS OF
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HARVARD COLLEGE (HARVARD
:
CORPORATION),
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Defendant.
:
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Civil Action
No.
1:14-cv-14176-ADB
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DEPOSITION OF ERICA J. BEVER, a witness
called on behalf of the Plaintiff, taken pursuant to
the Federal Rules of Civil Procedure, before
Alexander K. Loos, Registered Diplomate Reporter and
Notary Public in and for the Commonwealth of
Massachusetts, at the Offices of WilmerHale, 60
State Street, Boston, Massachusetts, on Thursday,
July 13, 2017, commencing at 9:00 a.m.
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PRESENT:
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HIGHLY CONFIDENTIAL - ATTORNEYS EYES ONLY
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Reported By: Alexander K. Loos
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Job No: 127040
TSG Reporting - Worldwide - 877-702-9580
HIGHLY CONFIDENTIAL -
ATTORNEYS EYES ONLY
Page 121
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ERICA J. BEVER
Q.
And when you say "personal qualities and
character," what are you referring to?
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A.
A variety of things.
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Q.
Such as?
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A.
Again, concern for others.
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Q.
What else?
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A.
Qualities described by recommenders.
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Q.
Anything else?
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MS. ELLSWORTH:
Objection.
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A.
The student's own application materials.
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Q.
Like their academic application materials?
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MS. ELLSWORTH:
A.
I'm referring to their essay, how they
spend their time.
Q.
In your experience does -- is a student's
race sometimes factored into their personal --
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Objection.
MS. ELLSWORTH:
Q.
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Objection.
-- into their personal score?
MS. ELLSWORTH:
Objection.
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A.
No.
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Q.
Do you think that's true with respect to
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all readers?
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MS. ELLSWORTH:
A.
Objection.
I cannot say what other readers do.
TSG Reporting - Worldwide - 877-702-9580
HIGHLY CONFIDENTIAL -
ATTORNEYS EYES ONLY
Page 362
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COMMONWEALTH OF MASSACHUSETTS)
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SUFFOLK, SS.
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)
I, Alexander K. Loos, RDR and Notary Public in
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and for the Commonwealth of Massachusetts, do hereby
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certify that there came before me on the 13th day of
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July, 2017, at 9:00 a.m., the person hereinbefore
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named, who was by me duly sworn to testify to the
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truth and nothing but the truth of her knowledge
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touching and concerning the matters in controversy
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in this cause; that she was thereupon examined upon
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her oath, and her examination reduced to typewriting
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under my direction; and that the deposition is a
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true record of the testimony given by the witness.
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I further certify that I am neither attorney or
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counsel for, nor related to or employed by, any
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attorney or counsel employed by the parties hereto
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or financially interested in the action.
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Under Federal Rule 30:
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___ Reading and Signing was requested
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___ Reading and Signing was waived
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_X_ Reading and Signing was not requested
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TSG Reporting - Worldwide - 877-702-9580
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