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VIRGINIA: IN THE CIRCUIT COURT OF RICHMOND CITY ‘The Democratic Party of Virginia, Plaintiff, | v. | At Law No, CL18004061-00 (Christopher E. Piper in his offical eapacity as the Conmissionerof the Depariment of Election; the Department of Elections; the Virginia Site Board of Elections, James B. ‘Aleor in his official capacity as member of the Stae Board of Elections; Clara Belle ‘Wheeler in her official capacity ag member of the Stae Board of Elections; and Singleton B ‘MeAllister, in his official capacity as member ofthe State Board of Elections, Defendants, and Shaun Brown, | Defendant-Intervenor. _| AFFIDAVIT OF HEATHER GUILLOT IN LIEU OF TESTIMONY |, Heather Guillot, declare under penalty of perjury thatthe following is true and correct, based on my personal knowledge, and that lam competent to testify to these matters: 1. My name is Heather Guillot and I have been subpoeneed to testify ata hearing in this matter scheduled for September 5, 2018 at 10:00 arm. in Richmond City Cireuit Court (the “Hearing”. 2. If Lwere called tothe stand to testify at the Hearing and asked the question, “You knew that there were forged signatures on the petitions you signed as circulator in suppor of Ms. Brown's candidacy?" I would invoke my Fifth Amendment privilege on the advice of counsel, and decline to answer the question. 2. If were called to the stand to testify athe Hearing and asked the question, “You knew that there were forged signatures on other petitions circulated by Seot Taylor's eampaign staff that wer submited in support of Ms Brown's candidacy?” I would invoke my Fith "Amendment privilege on the advice of counsel, and decline to answer the question. 4, ICT were called tothe stand to testify tthe Hearing and asked the question, “Isn't ic tre thatthe effort of Scot Taylors campaign staffo collect signatures in support of Ms. Brown's candidacy was directed by the Congressman Scott Taylor?” I would invoke my Fifth “Amendment privilege on advice of counsel, and decline o answer the questcn, 5. IFT were called tothe stand to testify atthe Hearing and asked the question, “When you signed the petition affidavit asa circulator, the notary public was not present to ‘wines your signature?” I would invoke my Fith Amendment privilege on advice of counsel and decline to answer the question. FURTHER AFFIANT SAYETH NOT. ee ‘Acknowledged, subseribed, and sworn to before me this _th day of September, 2018. ( SeBhemach S, 201F Date My Commision gi sca Apt 3a