Defendants admit that the plaintiff purports to sue Shields in his individual and official capacities. Defendants state that the Complaint inaccurately describes the University of Michigan Law School's admissions process, and therefore that no response is required. To the extent that a response is deemed necessary, defendants state that they do have a current intention to continue using race as a factor in admissions, as part of a broad array of qualifications and characteristics of which racial or ethnic origin is but a single through important element. Defendants admit that plaintiff purports to bring this action as a class action. No response is necessary to the plaintiff's characterization of her claims in the remainder of paragraph 10 of the Complaint.
Defendants admit that plaintiff seeks to maintain a class.
No response is necessary to the plaintiff's characterization of her claims in the remainder of paragraph 11 of the Complaint. Defendants admit that the University of Michigan Law School receives thousands of applications for admission each year, and that some of the names and addresses or rejected applicants may be obtained from files maintained by the Law School's Admissions Office. Defendants deny all of the remaining allegations in paragraph 12 of the Complaint. Defendants deny the allegations in paragraph 13 of the Complaint. Defendants deny the allegations in paragraph 14 of the Complaint, except that defendants lack information or knowledge sufficient to form a belief as to the truth of the allegations regarding the competence and experience of plaintiff's counsel.