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Declaration of William H. Sorrell

I, William H. Sorrell, under penalties of perjury, declare the following

to be true and correct to the best of my knowledge and belief:

1. I am and have been the Attorney General for the State of Vermont since 1997. My personal integrity, the integrity of the Office I hold

and zealous adherence to my oath of office have been and remain of

the utmost priority for me.

2. I have not violated the law in the performance of my duties as Attorney General nor besmirched the ethical obligations attendant

with being the states chief law enforcement officer.

3. In this Declaration, I speak only for myself and my campaigns. To the extent Mr. Toensing makes claims against other individuals or

organizations, I cannot and do not speak for them.

4. In the interest of avoiding repetition in responding to the individual counts, I ask that my responses to individual counts be considered

regarding other counts, if relevant.

COUNT ONE

5. Former Governor Howard Dean was a strong supporter of my candidacy in 2012. He publically endorsed my candidacy at a press

event, attended and made remarks at two or three fundraisers and

joined me on one occasion for the recording of one or more radio

spots. Early in the campaign Governor Dean made one suggestion consisting of about one sentence and one sentence only regarding my campaign strategy, which I followed. I neither requested nor

received other strategic advice from Governor Dean. He was never

made an agent of the campaign for any purpose, nor was he asked or

empowered to represent the campaign in interactions with any

individual or organization, including the Democratic Attorneys

General Association (DAGA) or the Committee for Justice and

Fairness (CJF).

6. During the 2012 campaign, I reported campaign expenditures to the Vermont Democratic Party (VDP) totaling $13,000, as detailed in

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my filings of October 15 and November 13, 2012. These filings are

attached as exhibits to this Declaration.

7. Neither on July 25, 2012 nor on any other date did my office issue guidance to (clear) the way for theCJF expenditures made on (my) behalf during the primary.

8. I note as background and to clarify that, until the August, 2012 date on which the first CJF television ad involving Howard Dean

espousing my candidacy was broadcast in Vermont, I had absolutely

no idea that DAGA or CJF had any plans or had taken any action to

support my candidacy. I had no idea Howard Dean had even talked

with anyone affiliated with DAGA or a DAGA-funded PAC. The

television ads and other advertising expenditures espousing my

candidacy were created and distributed without my knowledge. I

first learned of the television ads existence when I received a media call asking for my reaction to its airing. I was not aware of the

existence of the Committee for Justice and Fairness (CJF), let alone

whether it was or is an independent-expenditures-only PAC.

9. My Offices guidance and related press release expressing an intention not to enforce contribution limits spelled out in Vermonts campaign finance laws for independent-expenditure-only PACs

were prompted solely by a July 18, 2012 notice to the state of the

existence of Priorities PAC, an independent-expenditures-only PAC. We changed our guidance and decided not to enforce the

contribution limits for independent-expenditures-only PACs in order

to avoid potentially costly and, for the State, unsuccessful litigation,

in light of various federal court decisions, including a decision by

Judge William Sessions in Vermont Right to Life Committee v.

Sorrell, 875 F.Supp.2d 376 (2012), which made clear that such

limits were unconstitutional. I attach our press release in this regard.

10. The television ad created by CJF was about the mortgage foreclosure crisis. The radio ads, scripted by my campaign without

DAGA or CJF involvement, were about my work fighting Big

Tobacco and my efforts to reduce environmental pollution. A

transcript of all three ads is attached.

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11. During the summer of 2012, I heard from a friend and former AG about a Vermont resident Jim Jordan, who works on national

campaigns. Jordan supported my candidacy.

12. At a meeting in Bennington County, Jordan indicated he could connect us with a firm that could help us with media placement.

Ultimately, he put my campaign in touch with a man named John

Hutchinson of Media Strategies. Discussions ensued as to our

budget for radio spots, etc., he advised us we would need wire the

payment to his firm and the ads would be aired. We followed his

wiring instructions and effected payment in mid-August.

13. Until the McMullen allegations/filing some months later, we had no idea that DAGA and Media Strategies were apparently located in the

same building. Looking at Media Strategies website at present, it

appears that that company is no longer located at that address.

14. We have no information to establish DAGA and Media Strategies are at all affiliated and we believe they are not affiliated.

15. Neither I nor my campaign requested that Howard Dean provide advice to DAGA and/or CJF. Similarly, neither I nor my campaign

has any knowledge of any advice Governor Dean may have

provided those entities, if he did.

COUNT TWO

16. I am not familiar with detailed facts relating to DAGA and CJFs actions and inactions in connection with their involvement in the

2012 Attorney Generals race in Vermont. I have no authority to speak for them. Given their support of my candidacy, I could not

ethically be involved in looking into the allegations against them.

However, I am aware that, after the matter was referred to the

Addison County States Attorney, that office declined to bring any charges.

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COUNT THREE

17. To the best of my knowledge, my campaigns have met all obligations to accurately report campaign expenditures. The amount,

date, to whom paid and the purpose of the expenditures have been

disclosed in public filings over my nine separate campaigns for

Attorney General.

18. To the extent that I used block expense claims to describe expenditures of my campaign, I did not and do not believe that such

descriptors violate the law. I did and do believe the description

reimbursement or other such general description is sufficient for purposes of the law. To my knowledge, this has been the custom

and practice of numerous candidates for office over the years that I

have been Attorney General.

COUNT FOUR

19. The September, 2014 press event with Dean Corren described in the Complaint highlighted an issue that has long been a priority for me

and my Office, i.e. periodic gasoline price disparities between retail

prices in northwestern Vermont as compared to elsewhere in the

state. I participated in that event in my role as Attorney General. It

was not a campaign event.

20. During the 2013-2014 legislative session, I strongly and publically supported a House bill, sponsored by Rep. Pearson, that would have

required gasoline distributors to provide more information on

pricing issues to my Office and would have required advance notice

to my Office of the planned sale of a gasoline wholesaler or retailer

to a competitor. I testified in favor of the bill in the House

Transportation Committee. Unfortunately, the bill did not advance.

21. During 2014, I again observed significant price disparities in the State. As Attorney General, I questioned the reason for the high

prices, particularly in light of the fact that stations in northwestern

Vermont are closer to Canadian distribution points than stations in

surrounding counties. I also noted the fact that certain parties in the

gasoline business were litigating, allegedly for environmental

reasons, Costcos plans to sell retail gasoline. (Costcos sale of

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gasoline would significantly increase competition in the area.) I

mentioned my continuing support for the bill and my hope that the

2015 session of the legislature would again take up the bill that had

failed to gain passage in the previous session.

22. At Governor Shumlins re-election kickoff event in Burlington in early September, Rep. Pearson asked me if gasoline price disparities

were still of importance to me. I indicated very much so. He said he

was working on the Corren campaign and stated that Dean Corren

was looking to address the pricing issue at a press event, stating his

support for the proposed legislation. Rep. Pearson inquired whether

I might be willing to appear at the press event and state my support not for Dean Corren, but for the proposed bill. I indicated I might be

willing to do so.

23. Rep. Pearson again communicated with me a week or so later and there followed some communications about scheduling. I was sent a

draft press release that included statements critical of Senator Dick

Mazza. I responded I would not participate in any press event that

included criticism of the senator. The language was removed from a

subsequent draft. I also had the opportunity to review some visual

aids for the press event. These were, as I recall, graphs depicting

gas price increases and disparitie