February 13, 2017

1. My name is Sara Carter. I am 24 years old and I currently reside at 700 New Hampshire Avenue, N.W. Washington, D.C. 20037.

2. On December 19, 2016, I was served with a subponea from the plaintiff to give a deposition and to produce documents in the lawsuit filed against Congressman Blair.

3. I can not fathom any reason that the plaintiff would seek information from me for his case.

4. I have never had a sexual relationship with the Congressman, he did not propose that we have a sexual relationship, he did not offer me employment or other benefits in exchange for a sexual relationship, he did not deny me employment or other benefits for rejecting a sexual relationship. I do not know of any other person who had a sexual relationship with the Congressman, was offered employment or other benefits in exchange for a sexual relationship, or was denied employment or other benefits for rejecting a sexual relationship. The occasions that I saw the Congressman after I left employment at the White House in April, 2015, were official receptions, formal functions or events related to the U.S. Department of Defense, where I was working at the time. There were other people present on those occasions.

5. Since I do not possess any information that could possibly be relevant to the allegations or lead to possible admissible evidence in this case, I asked my attorney to provide this affidavit to plaintiff’s counsel. Requiring my disposition in this matter would cause disruption to my life, especially since I am looking for employment, unwarranted attorney’s fees and costs, and constitute an invasion of my right to privacy.

I declare under the penalty of perjury that the foregoing is true and correct.

(signed)
Sara Carter