1I serve as Counsel in the Office of General Counsel at Massachusetts Institute of Technology (MIT). I make this declaration in support of MIT’s Motion to Dismiss Count I of Plaintiff’s Complaint. I have personal knowledge of the contents of this declaration and could testify thereto.
2Attached as Exhibit A is a true and correct copy of the Majority Staff Report of the Committee on Education & the Workforce, U.S. House of Representatives (the “Committee”), Antisemitism on College Campuses Exposed, dated October 31, 2024. Exhibit A is quoted in the Complaint at paragraphs 43, 45, 60, and 118 and further referenced at paragraphs 46, 47, 93, 179, and 185.
3Attached as Exhibit B is a true and correct copy of the March 8, 2024 letter from Committee Chairwoman Virginia Foxx to MIT President Sally Kornbluth and Chair of the MIT Corporation Mark P. Gorenberg. Exhibit B is quoted in the Complaint at paragraphs 42 and 53 and further referenced at paragraph 41, 45, 93, 122, and 182–88.
4Attached as Exhibit C is a true and correct copy of the December 11, 2025 letter from Committee Chairman Tim Walberg to MIT President Sally Kornbluth. Exhibit C is quoted in the Complaint at paragraphs 15, 43, 49–54, and 64 and further referenced at paragraphs 17, 26, 41, 45, 93, 122, and 182–88.
5Attached as Exhibit D is a true and correct copy of the Committee’s Majority Staff Report, How Campuses Became Hotbeds: The Rise of Radical Antisemitism on College Campuses, issued March 17, 2026. Exhibit D is quoted in the Complaint at paragraphs 1, 11, 33– 40, and 53 and further referenced at paragraphs 2-4, 41, 57, 93, 122, 179, and 185.
6Attached as Exhibit E is a true and correct copy of the March 17, 2026 letter from Committee Chairman Tim Walberg to MIT President Sally Kornbluth. Exhibit E is referenced in the Complaint at paragraphs 3, 57, 71, 72, 93, and 182–88.
I declare under penalty of perjury that the foregoing is true and correct. Dated: June 2, 2026
Antonio Moriello CERTIFICATE OF SERVICE
I hereby certify that on this 5th day of June, 2026, I caused the foregoing to be electronically filed with the clerk of the court for the U.S. District Court for the District of Massachusetts, by using the CM/ECF system, which will send a notice of electronic filing to all counsel of record, a true and correct copy of the foregoing instrument and all attachments. Dated: June 5, 2026
/s/ Ishan K. Bhabha Ishan K. Bhabha
