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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 disparities between prices in different parts

of the state and at different times. I believe they were prepared by

Senator Sanders office.

24. I appeared at the press event on a sidewalk in front of a Burlington gas station at the North Street and North Avenue intersection. There

were a handful of media present, one or more state legislators, Dean

Corren and perhaps two or three of his campaign staff and myself.

The graphs were on one or two easels and were referred to during

the press event. Except for the possibility of a Corren button or

sticker worn by Corren and/or his staff, I saw no campaign banners,

signs or literature. At no time during the press event or at any time

during the campaign was I asked to or did I endorse Correns candidacy. Correns remarks and answers to media questions, as well as my own, were, in my memory, limited to the gas pricing

issues and the proposed legislation.

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25. This was not a campaign rally. Indeed, it was much like other issue-focused events I participated in during 2014 as part of my job as Attorney General. State emails and other resources were

appropriately used by my office in planning with coordinators of the

event because a crucial part of my duties as Attorney General is to

raise awareness about issues of concern to Vermonters and support

legislation that I believe will address those issues.

COUNT FIVE

26. As Attorney General, I have a longstanding policy of accommodating the vast majority of meeting requests I receive. I

personally participate in many such meetings. Other times, I ask one

or more Assistant Attorneys General (AAGs) to meet with the

individual or organization seeking the meeting. The policy remains

the same whether one has or has not financially supported my

candidacy.

27. As Attorney General, I feel a responsibility to be accessible to constituents and others making reasonable requests to meet. Often,

individuals request meetings to advocate action by my Office against

or relating to an individual, a company or an industry. Other times

the request comes on behalf of a potential target of some form of

enforcement action contemplated by my Office. I have typically

used these meetings to obtain information so that my Office might

make more informed future decisions on taking or declining to take

some official action.

28. I have never once in my career insisted on or even requested any campaign support before I would meet or otherwise discuss issues

relevant to the position I hold.

29. The DAGA. To the best of my knowledge, DAGA operates like the Republican Attorneys General Association (RAGA) and the

Democratic and Republican Governors Associations (DGA and

RGA). I believe DAGA was formed two or so years after the

creation of RAGA. In June, 2005, when I assumed the presidency of

the National Association of Attorneys General (NAAG) at a meeting

in Santa Monica, CA, in my speech to the AGs, I called for the

elimination of RAGA and DAGA. I suggested they are not

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beneficial to the collegiality that is helpful in our joint efforts. I also

suggested it is unseemly that the organizations receive large sums

from entities potentially subject to our enforcement efforts.

30. During my year as NAAGs President, RAGA and DAGA continued to exist. I was told that certain Washington, DC officials connected

to RAGA opined that my suggestion was simply a partisan attempt

to disarm the opposition because RAGA was, and remains, much

more successful at fundraising and spending money in AG

campaigns than DAGA.

31. I continue to regret the existence of RAGA and DAGA, but I do attend certain of DAGAs events.

32. The Facebook Event. This event resulted from a Facebook presentation to a bipartisan group of Attorneys General at a

Washington, DC NAAG meeting in late February or early March of

2014. Facebook indicated a willingness to come to individual states

and make a presentation on online safety for youth, particularly

relating to social media. One of the AGs present spoke favorably

about a Facebook presentation in his state. After my return to

Vermont, I spoke to my consumer protection staff about their

interest in a Facebook presentation in Vermont. They felt it a good

idea. We reached out to Facebook and approximately two months

later we sponsored a well-attended evening presentation at Essex

High School for students, parents, teachers and administrators. The

presentation was filmed by local access TV for broadcasting around

the state and is available on our office website.

33. The AT&T Event. Some months earlier, with Vermont highway safety personnel, I arranged for and participated in a well-received

AT&T sponsored presentation at a Windsor County high school on

the dangers of texting while driving.

34. Meeting with AT&T Officials. I met with high level officials of AT&T in Washington, DC. I was concerned about cramming, the practice of unknown and unwanted charges on customers monthly cell phone bills for services supposedly provided by third parties. I

had been crammed on my state cell phone account and my Office

had conducted surveys indicating that cramming was a widespread

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practice in Vermont and was costing Vermonters many, many

thousands of dollars. I received unsatisfactory responses to my

questions from AT&T.

35. During the period 2013-2015, my office took the national lead in a 50 state effort to address cramming by the nations four major wireless carriers. I reached out to federal regulators. Ultimately, the

FTC, FCC and CFPB all engaged on the issue. During this past ten

months, I have twice journeyed to Washington, DC to announce

major state and federal settlements with the carriers, including

AT&T, resulting in approximately $400M in restitution amounts for

consumers and approximately $100M in payments primarily to the

states with approximately $20M going to the federal treasury.

36. Meeting with Lawyers for Five Hour Energy. During 2014, I took a meeting in Vermont relating to Five Hour Energy, at the

request of attorneys from a DC law firm. While not relevant to my

decision to take the meeting, I note this firm has contributed to my

campaigns. Within a few months of the meeting, Vermont, with two

other states, filed a consumer-protection lawsuit against Five Hour

Energy. Some other states have subsequently filed similar litigation.

The cases are pending.

37. There are numerous other instances that I can provide in which contributors to my campaigns have requested that my Office do

something or refrain from doing something, and I have taken actions

contrary to those requests.

38. Meeting with Representatives of Comcast. Comcast gave a presentation at a DAGA meeting, touting the advantages of a

contemplated merger with Time Warner. Vermont was among the

states concerned about a reduction in competition if the merger went

forward. We engaged with the Department of Justice on the issue

and ultimately Comcast scrapped its plans for the merger.

39. The Patent Troll Suits. Vermont became the first state to file a state enforcement action against an alleged patent troll when we sued MPHJ Technologies in the spring of 2013. My Offices concern about patent trolls resulted not from requests or suggestions

by national corporations or their counsel, but rather from my

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requested attendance at a meeting in Vermont in the spring of 2012

with representatives of several well-known Vermont companies,

including My Web Grocer. They talked about their victimization by

patent trolls and asked me and the Secretary of Commerce to try to

help address the issue.

40. With strong support from my office, a first of its kind in the nation statute prohibiting bad faith assertions of patent infringement was

enacted by the legislature in 2013. I have spoken at NAAG

meetings and to various groups about Vermonts efforts in this arena. Other states and the FTC have subsequently engaged with

MPHJ and approximately 20 states now have statutes akin to our

Vermont law. I have testified before at least one Congressional

committee urging that state statutes, like Vermonts, not be preempted by federal law. Our litigation against MPHJ continues in

state and federal court. Vermonts anti-patent troll efforts have pleased any number of national corporations, including clients of the

Dickstein Shapiro law firm.

41. My Travel. I am frequently asked to speak in different locations in Vermont and around the country on GMO labeling, patent trolls,

campaign finance reform, consumer privacy and other issues. When

asked to travel out of state, other than for certain NAAG functions or

Congressional testimony, I typically only agree to do so if Vermont

taxpayers will not need to pay my travel expenses. Consequently, in

the past year, I have had travel expenses covered by the likes of Yale

Law School, the American Conference Institute and the National

Attorneys General Training & Research Institute (NAGTRI).

42. In February of 2014, I responded to an email by an attorney, who offered me use of her ski house. I stated, Colorado skiing would be fun! In truth, I would like to ski some day in Colorado. It would be fun to do so. But I have yet to ski in Colorado.

43. The MTBE Suit. I have never accepted $10,000 in campaign contributions (or any amount) in return for filing a lawsuit and

retaining as counsel those making the contributions.

44. At a dinner at a DAGA or AGs meeting in late 2013, I was joined at a table by Michael Messina and some Texas lawyers with whom he

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indicated he is affiliated. Mike Messina is married to former New

Mexico AG Patricia Madrid, known as Patsy. I do not specifically

recall Patsy being at the dinner table, but it is certainly possible she

was present.

45. Many years ago I was part of an AGs delegation to Israel with then-General Madrid. Mike was among the spouses making the trip.

Mike and Patsy became and remain friends. They supported me

financially in my 2012 campaign. Over the years they have invited

me to visit them in New Mexico. I have yet to do so.

46. Just before sitting down to dinner, Mike gave me an envelope saying that he and the attorneys from the Texas firm Barron & Budd (B&B)

wished to contribute to my campaign for re-election. I thanked them

and accepted the envelope. During the dinner, Mike and the B&B

attorneys mentioned they are involved in national MTBE (a gasoline

additive no longer in use) litigation and they suggested they would

come to Vermont at a future date to discuss the possibility of

Vermont suing the oil and gas industry, if I was interested. I

indicated I was aware of the MTBE issue and would talk to some

folks in Vermont and get back to them if a meeting made sense.

They gave me some printed material about their firm and a memo

they had prepared about the pending litigation which included, I

believe, some attention to the specifics of relevant Vermont law. I

took the folder or manila envelope but did not then or ever read its

contents.

47. Later that evening or the next morning I opened the contribution envelope and found $2000 checks to my campaign. Each of these

contributions was duly reported on my next campaign finance filing.

48. During my time as AG, there have been a number of occasions when former AGs and/or other counselsome campaign contributors, some nothave approached me about Vermont potentially retaining them for litigation relating to issues like opioid marketing practices

by pharmaceutical companies, flame retardants in furniture and

clothing, etc. My standard practice has been to ask them for a memo

on the facts they have uncovered and their applicability to Vermont

law. If they supply such information, I turn it over to AAGs

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working in the relevant substantive area for review, response and

recommendation.

49. As stated, I was aware of MTBE litigation. My Office had been following the issue for a number of years. Matt Pawa, a Boston

attorney we had worked with on other issues in the past, was

representing one or more plaintiffs in MTBE litigation for alleged

groundwater contamination. Attorney Pawa inquired of my

Environmental Protection Division (EP) whether we would be

interested in considering a lawsuit. Scot Kline is Chief of EP in my

office. He reached out to the Agency of Natural Resources (ANR)

during the Douglas Administration inquiring as to their interest in

the issue. ANR support would be important since much of the

records reviews and necessary pre-trial preparation for a lawsuit

would fall to ANR personnel. When asked, ANR was not interested

in the litigation.

50. Subsequently, the PAWA firm obtained a judgment for $100s of millions against one of the major oil companies on behalf of the

state of New Hampshire. Other MTBE cases had been consolidated

in a multi-district litigation lawsuit (MDL) in federal court in New

York and the trial judge had made some decisions favorable to

plaintiffs.

51. After returning to Vermont from the meeting at which the dinner occurred, I gave the B&B materials to Scot Kline for his review. He

told me about the MDL and the New Hampshire case judgment. I

asked him to check with the current ANR hierarchy to determine

whether theyd like to discuss the possibility of suit. He did so and the state officials were most interested in talking with us. In late

February, 2014, I met with Department of Environmental

Conservation Commissioner David Mears, one or more of his staff,

Scot Kline and one or two other EP AAGs at our offices. I made

very clear that this was simply to discuss the possibility of litigation

and to gauge their interest. I also made clear that if ANR/DEC was

not fully supportive, we would not take any MTBE-related actions

on behalf of the state. We discussed, among other issues, that we had

potential statute of limitations concerns as of approximately late

June, thus, we would need to move rather expeditiously if we

wanted to pursue the possibility of suit. It was also made clear that

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DEC personnel would need to be active participants in the next few

months if we were going to engage in records reviews, etc.

52. Commissioner Mears and his staff were most enthusiastic about pursuing a lawsuit. We indicated that in the event of suit, our Office

would intend to be lead counsel, but we would certainly need

outside counsel assistance if we were going to sue. I believe the

B&B offer to come to Vermont to discuss litigation and perhaps

review some records was mentioned in the meeting. There was

certainly discussion that a decision on outside counsel would need to

be a priority.

53. It was only at this point that my staff communicated with B&B and agreed to a Vermont meeting. B&B attorneys and Mike Messina

journeyed to Vermont for a meeting I did not attend. Matt Pawa

(never, to my knowledge, a contributor to any of my campaigns) was

invited to come to Vermont to discuss the possibility of a Vermont

MTBE lawsuit. I sat in a portion of that meeting. At no time did I

speak to Scot Kline or anyone else about what firm or firms we

should retain to assist our office in an MTBE case. At no time

during this decision-making process, did I inform my staff of what

firms or entities had contributed to my campaign. I was unaware

that a NY law firm was co-counseling with B&B in the MDL case.

Ultimately, after interviews by Scot and others from EP and DEC

staff, Scot informed me that their joint recommendation was for us

to retain B&B, the NY firm, Mike Messina and the PAWA firm. I

indicated I was fine with that and we should move ahead.

54. We thereafter engaged in discussions/negotiations primarily with B&B for a contingency fee arrangement binding the four firms. We

pushed back on the initial suggested retention agreements and

ultimately agreed on terms significantly more favorable to Vermont

in the event of a recovery, than those initially suggested. The firms

will cover the vast majority of pre-trial expenses and will not receive

any reimbursement of expenses or a percentage of recovery unless

there is a judgment or settlement in favor of the state.

55. There was absolutely no violation of state or federal law on my part in conjunction with the MTBE lawsuit or retention of outside

counsel.

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COUNT SIX

56. I was successfully represented by Richard Cassidy when I was sued by Jack McMullen in connection with the DAGA/CJF allegations

back in late 2012.

57. Richard Cassidy and his wife are close personal friends of mine and my siblings. They have frequently attended gatherings at my home.

I have dined and socialized at their residence.

58. The complaint alleges that the states settlement of a matter involving two clients represented by Attorney Cassidy two days

after a decision by the Chittenden Superior Court in my favor in the

McMullen case constituted an indisputable conflict of interest.

59. As of January 30, 2013, the date of the settlement, I was unaware that Richard Cassidy was representing any client in a matter in

conflict with my Office. Richard Cassidy never, during our

discussions prior to that date, mentioned he represented a party in a

dispute with the Office, let alone the substance of any settlement

discussions.

60. I have approximately 80 AAGs in my Office. I have active involvement in discussions and certain decisions relating to major

civil and criminal cases, but there are numerous lawsuits and

disputes involving my Office of which I am unaware and/or play no

part in case decisions.

61. I was never, prior to the settlement, aware of the case or the substance of any settlement discussions at issue, even without

knowing of Attorney Cassidys involvement. I do not believe I took any action contrary to the best interests of the State of Vermont in

the case in question.

Transcripts of Ads

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Transcripts of Ads

1. Democratic Attorneys General Association TV Spot

Governor Dean (30 seconds)

They sold dishonest mortgages and illegally foreclosed on peoples homes.

But when the big banks tried to get away with it, one man in Vermont held them

accountable.

Attorney General Bill Sorrell cracked down on deceptive bankers and won

millions in relief for homeowners.

Hes fought to stop predatory lenders and protected seniors from scams.

Im proud to call Bill Sorrell my friend, but more proud to call him Vermonts Attorney General.

2. Re-Elect Attorney General Bill Sorrell Radio Spots

Radio Script #1 for Gov. Dean Radio Spot 60 second spot

Governor Dean (45 seconds)

This is Governor Howard Dean. Im supporting Attorney General Bill Sorrell in the democratic primary on August 28.

Like me, Bill Sorrell is willing to take on the tough fights without regard to

political consequence.

Bill Sorrell successfully fought Big Tobacco and secured Vermont over $300

million dollars.

Bill Sorrell successfully fought the auto industry to make Vermont a national

leader in the effort to reverse global climate change.

And Bill Sorrell successfully fought the Bush Administration over the EPAs environmental regulations.

For fifteen years Attorney General Bill Sorrell has been fighting to make Vermont

cleaner safer and healthier. Now it is time for us to fight for him.

Join me and vote to re-elect Attorney General Bill Sorrell in the democratic

primary on August 28th

2

AG Sorrell (12 seconds):

This is Attorney General Bill Sorrell. I am honored to have the support of Howard

Dean and I would be honored to have your vote in the democratic primary on

August 28.

Please visit BillSorrell.com learn more about my campaign.

Public Announcer (03 seconds):

Paid for by the Sorrell Campaign Committee, P.O. Box 809 Montpelier, Vermont.

Radio Script #2 for Gov. Dean Radio Spot 30 second spot

Governor Dean (26):

This is Governor Howard Dean.

For fifteen years Attorney General Bill Sorrell has fought to make Vermont

cleaner, safer and healthier

Bill Sorrell has fought to secure hundreds of millions of dollars for Vermont

taxpayers;

And Bill Sorrell has fought to make Vermont a national leader in the effort to

reverse global climate change.

For fifteen years Bill has fought for us, now its time we fight for him.

Join me and vote to re-elect Attorney General Bill Sorrell in the democratic

primary on August 28th

.

AG Sorrell (03 seconds):

Paid for by the Sorrell Campaign Committee, P.O. Box 809 Montpelier, Vermont

Sorrell Campaign Finance Disclosure FormOctober 15, 2012

Sorrell Campaign Finance Disclosure FormNovember 13, 2012

ATTORNEY GENERAL'S GUIDANCEREGARDING INDEPENDENT

EXPENDITURE COMMITTEES

ATTORNEY GENERAL'S GUIDANCE REGARDING INDEPENDENT EXPENDITURE COMMITTEES

Under Vermont's campaign finance laws, a "political committee" or "PAC" is any entity or group of individuals that receives and spends more than $500 in a calendar year for the purpose of supporting or opposing a candidate in a Vermont election. Vermont's statutes do not distinguish between a PAC that makes contributions to or coordinates with a candidate and one that conducts its activities entirely independent of any candidates. Thus, Vermont's requirements regarding registration, reporting and contribution limits for P ACs apply equally to all entities or groups that attain PAC status. In other words, all Vermont P ACs must complete the registration process, file appropriate disclosure reports with the Secretary of State's Office, and comply with statutory contribution limits.

Since the Supreme Court's decision in Citizens United v. Federal Election Commission, 130 S. Ct. 876 (2010), a number of federal appellate courts have held that limiting contributions to P ACs that make only independent expenditures is not constitutionally permissible. Consistent with these decisions, Judge Sessions of the federal district court of Vermont expressed a similar view in his recent opinion issued in Vermont Right to L~re Committee v. Sorrell, Docket No. 2: 1 0-cv-188, on pages 59-63 and 78. VRLC has appealed Judge Sessions's decision to the Second Circuit Court of Appeals.

While the VRLC case is pending on appeal and until further guidance is received from the Second Circuit or Vermont courts, the Attorney General's Office will follow Judge Sessions's opinion regarding contribution limits for independent expenditure PACs. Accordingly, the Office will not enforce the $2000 contribution limit for those P ACs that demonstrate they make only independent expenditures. Of course, such groups must continue to comply with Vermont's registration and reporting requirements. Further, to be clear, if investigation reveals, as Judge Sessions found in the VRLC case, that a PAC's political activities are not conducted entirely independently of candidates, the PAC will continue to be subject to Vermont's contribution limits.

Dated: July 25,2012

Declaration of General Sorrell FINAL 13 page.pdfSorrell Signature PageTranscripts of Ads coverDAGA TV Spot Sorrell Radio Spot1Sorrell Campaign Finance Disclosure FormOctober 15Oct 13 2012 CF DisclosureSorrell Campaign Finance Disclosure FormNov 13Nov 13 2012 CF DisclosureAG's guidanceIndependent Expenditure Guidance- 07-25-12 - HKT2L87