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

Filing 95

DECLARATION re 94 Reply to Response to Motion to Compel by Students for Fair Admissions, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Caldwell, Benjamin)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS

STUDENTS FOR FAIR ADMISSIONS, INC.,
Plaintiff,
v.

Civil Action No. 1:14cv-14176-ADB

PRESIDENT AND FELLOWS OF HARVARD
COLLEGE (HARVARD CORPORATION),

Leave to File Granted
August 7, 2015 (Dkt.
93)

Defendant.
DECLARATION OF PATRICK STRAWBRIDGE
Patrick Strawbridge, pursuant to 28 U.S.C. § 1746, declares the following:
1.

I am an individual over twenty-one years of age, and of sound mind, who

has never been convicted of a felony, is capable of making this declaration, and am fully
competent to declare as to matters stated herein.
2.

I am an attorney for the Plaintiff in this action, Students for Fair

Admissions, Inc. (“SFFA”).
3.

I make this Declaration in connection with the motion to compel the

production of certain documents that SFFA has requested from Defendant President and
Fellows of Harvard College (Harvard Corporation) (“Harvard”).
4.

Attached hereto as Exhibit A is a true and correct copy of an email

exchange I had with counsel for Harvard, renewing SFFA’s request that Harvard provide
information about its database so SFFA could determine the merit of Harvard’s claim that
the database was sufficient for its expert analysis.

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5.

In follow up phone conversations, I made clear to Ms. Ellsworth that

SFFA was willing to review this material, and that if provided it may permit SFFA to
table the pending request for application files. Ms. Ellsworth indicated that her client
would not produce any documents or information pending a decision on the motion to
stay.
6.

Attached hereto as Exhibit B is a true and correct copy of an excerpt from

relevant portions of the transcript of the deposition of Marlyn E. McGrath, Harvard’s
Director of Admissions, taken on June 18, 2015.

Names of individual admissions

officers have been redacted pursuant to Harvard’s request under the Stipulated Protective
Order.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on this day, August 6, 2015.

/s/ Patrick Strawbridge___________
Patrick Strawbridge

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