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Exhibit K11 000061 AFFIDAVIT OF ROBERT GUILLO. STATE OF NEW YORK ) Jss. COUNTY OF NASSAU ) ROBERT GUILLO being duly swom, deposes and says: 1. Treside at 2. make this statement conceming the business acts and practices of Trump University (“Trump”) of my own knowledge. 3. learned about Trump in September 2009, from a flyer advertising a free seminar. In addition to Donald Trump's reputation as a successful billionaire real estate investor, the primary reason that my son Alexander R. Guillo and I signed up for the ‘Trump programs, including the Trump Gold Elite program for $35,995, was the fact that ‘Trump University LLC was organized in New York State and we assumed that we were enrolling in “university” that was approved by the New York State Department of Education and the New York State Board of Regents. We did not realize that Trump University LLC was not a “university” until it filed a Certificate of Amendment of the Articles of Organization on May 21, 2010. 4. When I later spoke to George Sorial, the Assistant General Counsel of The ‘Trump Organization, on September 20, 2011, he asked me what type of degree I expected from Trump University LLC. I never expected a degree and pointed out to him that in the State of New York there are many colleges and universities that are approved by the Department of Education and/or the Board of Regents that offer certificates and noncredit ‘courses in addition to undergraduate and graduate degrees. 5. Myson Alexander attended the free seminar on September 16, 2009, and signed us up for the three-day seminar to take place on September 25-27, 2009. 1 000062 ‘Alexander paid a total of $1,495 for the three-day seminar called “Profit From Real Estate 3-Day Training.” 6. Weattended the three-day session at a hotel in Manhattan. The main speaker was James Harris, Tiffany Brinkman and a few other speakers assisted him. Every speaker gave us a synopsis of their life history, told us how they got involved in real estate and how successful they were. They showed us videos of testimonials of other students who had taken the class and who became successful after implementing the ‘Trump methods. 7. Mr, Harris was an excellent motivational speaker who told his “rags to riches” story. He was flashing his Rolex watch to prove how successful he was. 8. Mr. Harris said that Mr. Trump established a “University” for students who wanted to leam the techniques Mr. Trump used to become a billionaire real estate investor. Pictures were taken of us standing next to a cutout of Mr. Trump. 9. The push to enroll in the Trump Gold Blite program began from the first day, We were told to call our credit card companies during lunch to increase our credit limits, so that we would have enough money to enrall in the Trump Gold Elite program. | did not call my credit card company because I had sufficient credit, 10. During his push to sign us up for the Tramp Gold Elite program, Me. Harris gave us his email and contact information and told us that once we enrolled in the program as Gold Elite Members, he and the rest of the Trump staff would be available to us whenever we needed them for a period of 12 months. 11. Mr. Hartis spoke to us one-on-one trying to get us to sign up for the ‘Trump Gold Elite program. He said that if we signed up for the Trump Gold Elite program we would become members ofa select “in-the-know group,” we would be a 000063 wsiders.” and would have access to deals not available to other real estate investors. For ‘example, where Mr. Trump would be involved in building condominiums, we would get the first choice at purchasing an apartment and would then be able to immediately resell it for a profit. 12. Mr. Harris also said that if we signed up for the Trump Elite program, we ‘would work one-on-one with experienced real estate investors who would help us set up a limited liability company and show us how deals are done. 13, Atthe end of the three-day program, Alexander and { decided to sign up for the Gold Elite Program which included three days of in-field mentorship and five retreats. I paid $34,995 originally, but I because I was already familiar with one of the seminar topics, Trump credited my card for $500. 14, Stephen Gilpin was our assigned mentor. He called me to set up the appointment for the one-on-one mentoring session, but | wanted to attend the seminars first to be best prepared for the mentoring session, 15. attended all the retreats that were offered through Trump Elite. Generally. during the first part of each retreat, the instructor would talk about his successes: one instructor even bragged that he lived in the same community as Tiger ‘Woods. A lot ofthe information they taught seemed to come from the website or could have been easily gathered from the IRS website. Afler the first seminar, | began to realize I had been taken, 16, The retreats that we attended were designed to get the attendees to pay for additional programs that were offered by the presenters for thousands of dollars. 000064 17, The “Quick Start Real Estate Retreat” offered on October 2, 3, and 4, 2009, was given to solicit another $995.00 for a “Quick Start Study Group,” which consisted of three group telephone seminar sessions and 15 CDs. 18. The “Wealth Preservation’ retreat taught on October 23, 24, and 25, 2009, by J.J. Childers, who claimed to be “Mr. Trump's Attomey,” was given to solicit another $9,995 for a Wealth Preservation Program. Mr. Childers was also soliciting customers for his tax accounting firm. 19, The “Creative Financing” retreat offered on January 15, 16, and 17, 2010, by Billy Cannon and Eric Brown was given to solicit another $4,495 for their “Sump Start Coaching” program. This program consisted of one-on-one coaching by Billy Cannon and Eric Brown on creative financing methods. 20. The “Multi Family” retreat offered on February 12, 13, and 14, 2010, by Billy Cannon and Eric Brown was given to solicit a3 day one-on-one mentorship for $19,995 by Billy Cannon and Brie Brown. 21, Atthe conclusion of each retreat the presenters asked that the attendees complete a satisfaction questionnaire in order to get a Certificate of Completion for the “course.” They also pleaded for a favorable rating so that “Mr, Trump would invite [thera] back to do other retreats.” 22. filled out favorable evaluations for the speakers because I believed that that was the only way to get my Certificates of Completion for the seminars that I attended. The evaluations did not reflect my actual opinions on the courses. 23. Because I lost faith in the Trump Gold Elite program after taking the ‘seminars, I never did the three-day one-on-one mentorship. [ spoke to other Trump students who said that the mentorship was a big joke, and I saw that there were a lot of 4 000065 complaint filed with the Attorney General's office about Trump and the mentorship program. 24. On August 10, 2011, I wrote a letter to George Sorial, Managing Director of International Development and Assistant General Counsel of the Tramp Organization describing my experience at Trump and requesting a full refund. But instead of refunding my money, Trump staff promised to set me up with their best mentor to complete the one-on-one three-day mentorship program, I refused, because I did not feel that there would be any substance to the mentoring session and believed all Trump mentors to be phonies. I still have not received my refund and I have written two more letters requesting it and threatening to file a Consumer Complaint with the Atomney General of New York. My Commission Expires: Ce 10866 1, d5™ unre reper ees erasers ees aa tesicerd ere s 000066