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MEMORANDUM OF LAW IN SUPPORT OF
RENEWED MOTION BY DEFENDANTS BOLLINGER, LEHMAN, AND SHIELDS
FOR SUMMARY JUDGMENT ON GROUNDS OF QUALIFIED IMMUNITY
INDEX OF EXHIBITS
Volume 1: Documents and Materials*/
Exhibit Description
A. University of Michigan Law School Bulletin: 1995-1997 (Deposition Exhibit 7).
B. Law School Admissions Office: Daily Summary of Applicant Status ("Daily Report") (Deposition Exhibit 10).
C. University of Michigan Law School Bulletin: 1997-1999 (Deposition Exhibit 8).
D. Law School Admissions Policy (Deposition Exhibit 4).
E. Letter, dated December 8, 1997, from Jeffrey S. Lehman (Deposition Exhibit 59).
F. "The Gospel According To Dennis" (Deposition Exhibit 5).
G. Tables 5 and 6 of Expert Report submitted by plaintiff�s expert, Kinley Larntz.
H. Smith v. University of Washington Law School, No. C97-335Z (W.D. Wash. Feb. 12, 1999).
I. Law School Announcement: 1988-89 (Deposition Exhibit 55).
J. Standard 212 (Deposition Exhibit 84).
K. American Bar Association Report on the University of Michigan Law School: February 9-12, 1992 (p. 38) (Deposition Exhibit 60).
L. Memorandum from Don Regan (Deposition Exhibit 32).
M. Letter, dated August 16, 1992, from Edward H. Cooper to James P. White (included in Deposition Exhibit 61).
N. Report of Kinley Larntz, plaintiff�s expert (p. 9); charts produced by Larntz (Deposition Exhibit 68).
O. The University of Michigan Law School Admissions Office Grid of LSAT & GPA (Deposition Exhibit 15).
P. ABA Standards For approval of Law Schools (Deposition Exhibit 30).
Q. Association of American Law Schools (AALS) 1994 Handbook (Deposition Exhibit 31).
R. Center for Individual Rights: Racial Preferences in Higher Education, A Handbook for College and University Trustees, 1998.
* / Certain of the documents included in Volume 1 of the Appendix were designated by defendants as confidential pursuant to the Unopposed Stipulation and Protective Order Concerning Confidentiality, entered May 28, 1998. Pursuant to ¶ 5 of that Order, defendants waive their confidential designations for any materials included in the Appendix.
Volume 2: Deposition Excerpts**/
Deponent Deposition date Lee Bollinger February 9, 1999 Susan Eklund June 2, 1998 Donald Herzog August 26, 1998 Kinley Larntz February 2, 1999 Jeffrey Lehman January 21, 1999 Richard Lempert November 5, 1998 Alissa Leonard November 2, 1998 Marcea Metzler February 5, 1999 Erica Munzel June 1, 1998 Stephen Raudenbush March 9, 1999 Donald Regan August 27, 1998 Theodore Shaw February 3, 1999 Dennis Shields December 7, 1998 Allan Stillwagon November 6, 1998 Jean Wong July 21, 1998
** / Some of the deposition testimony included in Volume 2 of the Appendix was designated by defendants as confidential pursuant to the Unopposed Stipulation and Protective Order Concerning Confidentiality, entered May 28, 1998. Pursuant to ¶ 5 of that Order, defendants waive their confidential designations for any materials included in the Appendix
Volume 3: Expert Witness Reports
Expert Witness
Derek Bok
Albert Camarillo
Eric Foner
Patricia Gurin
Stephen Raudenbush (with Supplemental Reports)
Claude Steele
Thomas Sugrue
Kent Syverud
Robert Webster
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Questions? Comments? Please send e-mail to diversitymatters@umich.edu.
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