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)

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EXHIBIT 9 HIGHLY CONFIDENTIAL - ATTORNEYS EYES ONLY Page 1 1 Erica J. Bever 2 Volume I Pages 1 to 363 Exhibits 1 to 23 3 4 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS 5 6 7 8 9 10 11 - - - - - - - - - - - - - - - - -x : STUDENTS FOR FAIR ADMISSIONS, : INC., : Plaintiff, : : vs. : : PRESIDENT AND FELLOWS OF : HARVARD COLLEGE (HARVARD : CORPORATION), : Defendant. : - - - - - - - - - - - - - - - - -x Civil Action No. 1:14-cv-14176-ADB 12 16 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. 17 PRESENT: 13 14 15 18 19 HIGHLY CONFIDENTIAL - ATTORNEYS EYES ONLY 20 21 22 23 24 Reported By: Alexander K. Loos 25 Job No: 127040 TSG Reporting - Worldwide - 877-702-9580 HIGHLY CONFIDENTIAL - ATTORNEYS EYES ONLY Page 121 1 2 3 ERICA J. BEVER Q. And when you say "personal qualities and character," what are you referring to? 4 A. A variety of things. 5 Q. Such as? 6 A. Again, concern for others. 7 Q. What else? 8 A. Qualities described by recommenders. 9 Q. Anything else? 10 MS. ELLSWORTH: Objection. 11 A. The student's own application materials. 12 Q. Like their academic application materials? 13 14 15 16 17 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 -- 18 19 Objection. MS. ELLSWORTH: Q. 20 Objection. -- into their personal score? MS. ELLSWORTH: Objection. 21 A. No. 22 Q. Do you think that's true with respect to 23 all readers? 24 25 MS. ELLSWORTH: A. Objection. I cannot say what other readers do. TSG Reporting - Worldwide - 877-702-9580 HIGHLY CONFIDENTIAL - ATTORNEYS EYES ONLY Page 362 1 2 COMMONWEALTH OF MASSACHUSETTS) 3 SUFFOLK, SS. 4 ) I, Alexander K. Loos, RDR and Notary Public in 5 and for the Commonwealth of Massachusetts, do hereby 6 certify that there came before me on the 13th day of 7 July, 2017, at 9:00 a.m., the person hereinbefore 8 named, who was by me duly sworn to testify to the 9 truth and nothing but the truth of her knowledge 10 touching and concerning the matters in controversy 11 in this cause; that she was thereupon examined upon 12 her oath, and her examination reduced to typewriting 13 under my direction; and that the deposition is a 14 true record of the testimony given by the witness. 15 I further certify that I am neither attorney or 16 counsel for, nor related to or employed by, any 17 attorney or counsel employed by the parties hereto 18 or financially interested in the action. 19 20 Under Federal Rule 30: 21 ___ Reading and Signing was requested 22 ___ Reading and Signing was waived 23 _X_ Reading and Signing was not requested 24 25 TSG Reporting - Worldwide - 877-702-9580

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