Exhibit K22 000122AEFIDAVIT VIN Si ‘STATE OF NEW YORK ) COUNTY OF WESTCHESTER 7. KEVIN SCOTT being duly sworn, deposes and says: 1. Treside at 2, Tmake this statement concerning the business acts and practices of Trump University (“Trump”) of my own knowledge 3, nearly May 2008, I sawan advertisement inthe newspaper fora free presentation by ‘rump atthe Westchester Marriot Hotel [attended the presentation, “where the instructor, James Harris, made a good pitch for Trump's three-day class atthe end of May, Mr. Harts said thatthe program participants would receive intensive training by Trumps experts, such as himself, Dave Sampson and ethers, all top notch professionals in real estate, according to Mr. Harris. These professional. Mr. Harris said, had years of experience with all kinds of real estate transactions. 4. When [signed up forthe Trump seminar, had a credit score of $17, and 1 ‘wanted to make some money to pay off my debts. 5. During the free seminar, Mr. Harris went over very basic information about real estate investing and presented just enough to get us interested in taking the next level seminar. He promised that atthe three-day seminar, Trump experts would show us how to get so-called “hard-money” lenders and how to work with a bank to get financing for our realestate deals 6. I paid $1,495 to attend the three-day seminar on May 30 - June 1. 2008, at the Sheraton Hotel on 57th Street in New York City. 0001237, Ourprimary speaker was once again James Harris, who sai that he had personally worked with Donald Trump. He said that he bad been involved jin numerous real estate transaction ofall kinds with Donald Trump over the years. We were also told that al Trump speakers had been buying and selling properties for a long time, had experience in real estat business, Hipping distressed properties and helping during pre- foreclosure by doing owner-seller financing, Mr. Harris alluded to some unfavorable press around Trump, but said that we should not worry bout it § Mr Hants told stories about his mother being addicted to drugs and about being an underachiever in his early life. He said that he became a millionaire by using ‘rump techniques. He sai hat many years ago he mae $75,000 profit on his Hrs eal setate deal and bought himseif new Porsche, I was not interested in getting a Porsche {simply wanted to make enough money to pay off my outstanding debes, 9, - During the three-day session, Mr. Harris asked us to increase our credit card limits so we could put down payments for our realestate purchases on our credit cards, {increased my credit card limits, and that is how T eventually paid for the Trump Elite program, 10. Atthe three-day seminar, we were told how to find deals by looking through publications, how to research properties for sale, and how to find properties for sale by owner. One of our assignments was to find deals and to bring them to class. Some people brought deals o class, and Mr. Harris called the sellers on a speaker phone s0 we could hear the conversations. 11, Mr. Harris said that Trump had hard-money lenders standing by and ready for those who found deals, At the end of the three-day seminar we were told that we were now ready to invest in real estate, but if anyone felt that they needed more help, the 2 000124“Trump staff were there to do the after-sll. They pushed the Trump ‘mentorship programs envily during the three days and set aside ime for people to look at he different Trump Elite programs. 12,_-Me Harts said that we would beable to make back the tuition for he “Trump Blite programs quickly and used a baseball analogy to demonstras ott future profits: a single would bring in $25,000 profit, double would be $550,000, a triple would tbe $75,000, a home run would be $100,000, and a grand stam would be whatever goal you set for yourself 13, Mr Harris told us that if we signed up for one ofthe Elite programs, We ‘would work one-on-one with a mentor, look at properties, ake offers, have special acooss to hard-money lenders, andl do‘ deal all within the first week, 1 thought sha if they were going to hold my hand that much, how could I say no? 14, then signed up fora $25,000 Gold Elite mentorship, which consisted of nly one-on-one mentorship (no seminars), because that was all that could afford: My ‘mentor was Keith Minchew, 15, The mentorship was where things got off track for me. It was elearly not what they had advertised. Every time I asked Minchew or other people at Trump about the hard-money lenders, they said they would talk to me about it more once | had a real estate deal. Of course, no one would do a deal unless there was financing in place. 16. Mr. Minchew came from Texas to see me in Westchester for the three-day in-person mentorship. 1 picked him up in the morning, and we looked at properties that 1 found before his arrival. However, [ was not able to do any deals. Because the properties 1 viewed were in foreclosure, they were mostly owned by banks, and the banks would not do adeal with me unless and until Lhd financing. And [ was not able to get financing 000125from banks because I did not have a deal with the seller of the property. AAs for the hard- money lenders Trump had promised, they were still nowhere to be found, 17. tried to put together at least three deals with my mentor, Mr. Minchew, and later several more on my own, but none worked out because I was unable to get financing. For seven to eight months I worked diligently trying to find deals and to secure financing, but I got nowhere. | had a feeling that getting a deal and financing were like two hands one foot apart and neither could reach the other. I called Trump and told them that I found properties and put together a proposal and requested them to get me the promised financing from their hard-money lenders. But they just told me that I needed to ‘work harder to get adeal in place first. Because Trump never offered me an opportunity to talk to any hard-money lenders, I began to suspect that there were no hard-money lenders at all 18. I had several follow-up calls with Mr. Minchew, but reality started to set {n that this was not working out. Trump’s theory about real estate investing might have been correct for a real estate mogul like him, but it did not reflect the reality for the average investor. 19. [also purchased Trump software for about $2,000, plus $30 per month data fee. That software was supposed to allow a user to look up information about properties, but I soon discovered that the database was not up to date. For example, when [researched my own property and properties of my friends in the database, information albout these properties was several years behind. 20, Inanexit interview, I rated Mr. Minchew well because I did not think that the problems with the mentorship were his fault. Also, it was Mr. Minchew himself who 000126filled out the evaluation form, while [told him what to write. 1 said that he was courteous ‘and professional, but that { did not see any results. 21. Tealled up Trump in May 2009, to say that I saw no results after participating in Trump Elite Program and I requested a refund. Instead, I got a new ‘mentor, Steve Gilpin. Mr. Gilpin called a couple of times and wanted me to find more deals, He seemed to be following the same script at Mr. Minchew and had nothing new to offer me in terms of information or help with closing a deal, so our communications broke off within a month, 22, I requested a refuund from Trump again, but my calls were never returned. [eft several messages on Trump's main office’s voice mail but received no response. 23, Because of the accumulated debt, in large part exacerbated by debts to ‘Trump, I had to move out of my house into a studio apartment, 50 T could sublet my icra boty KEVIN SCOTT Ree cake yet ia (aa ie oo y ae DAVID | Ss Maw son Bn house and use the rent money to pay oft the debs. Notary Public” State of. My eas Expires: [20-/30lY 000127