Declaration of Paulette Mueller

I declare under penalty of perjury that I have personal knowledge of the following facts,

and they are all true and correct:

1. My name is Paulette Mueller.

2. My date of birth is September 18, 1953.

3. My address is 10770 Inwood Road, Dallas, Dallas County, Texas 75229.

4. I am of sound mind and capable of making this Declaration. I declare under penalty

of perjury that the facts stated in this Declaration are true and correct.

5. I am the President of the Beta Sigma Facility Corporation of Kappa Alpha Theta

Fraternity ("Facility Corp.") a nonprofit organization.

6. In my position as President, I am responsible for reviewing, executing, and

maintaining the corporate records of Facility Corp.

7. The Plaintiffs and other members of the Beta Sigma Chapter of Kappa Alpha Theta

Fraternity (the "Chapter") enter into Room Rental Licenses with the Chapter, but Facility Corp. is

not a party to those Room Rental Licenses.

8. Facility Corp. does not collect rent or other payments from the members of the

Chapter, and Facility Corp is not involved in the activities or management of the Chapter.

9. I have personal knowledge of available alternative housing appropriate for SMU

students, located directly across the street from SMU's campus on Daniel Avenue. I have seen the

"for rent" and vacancy signs out in yards on nearby streets within walking distance of campus (i.e.

Auburndale, McFarlin, and others) this week.

10. My statements contained in this Declaration are based on my personal knowledge,

including my review of and in some instances, creation of the official records of Facility Corp. that

EXHIBIT A

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were made at or near the time indicated on the document—or from information transmitted by—

someone with knowledge of the facts or matters reflected therein. The records which are attached

are true and correct copies of the original documents. Each of these records were kept in the

ordinary course of a regularly conducted activity, and it was the regular practice of Facility Corp.

to maintain such records of the matters described herein.

1 1. A true and correct copy of the Chapter-Corporation Lease for the 2022-2023

academic year is attached hereto as Exhibit "A." This document is submitted electronically for

acceptance and is accepted electronically, without the need for physical signatures or electronic

signatures.

12. Facility Corp leases the ground upon which its building is located from Southern

Methodist University. The Original Ground Lease was executed on December 14, 1950. The

Original Ground Lease was subsequently extended, modified and amended in October of 2015

("First Amendment") and was signed and accepted by me, for and on behalf of Facility Corp.

during the time Facility Corp reconstructed and rebuilt its building.

13. A true and correct copy of the First Amendment to Lease Agreement is attached

hereto as Exhibit "A-2."

14. A true and correct copy of the Original Ground Lease is attached hereto as Exhibit

"A-3."

15. Theta Educational Foundation of Southern Methodist University was formed on

July 11, 1950. A true and correct copy of the current Bylaws of Theta Educational Foundation of

Southern Methodist University is attached hereto as Exhibit "A-4."

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16. A true and correct copy of the Certificate of Fact reflecting Facility Corp.'s name

change from "Theta Educational Foundation of Southern Methodist University" to "Beta Sigma

Facility Corporation of Kappa Alpha Theta" is attached hereto as Exhibit "A-5."

Executed in Dallas County, Texas on the 17th day of August, 2022.

(Signature)

Name: 19Avckl-r

Title: be:QT —20. atoc,

FAG Ku( ma

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