United States District Court

for the

Southern District of Florida

Scanz Technologies, Inc., Plaintiff,

v.

JewMon Enterprises, LLC and 

others, Defendants.

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)

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)

)

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Civil Action No. 20-22957-Civ-Scola

Stipulated Protective Order

This matter is before the Court upon the joint motion of the plaintiff 

Scanz Technologies, Inc. fka Equityfeed Corporation (“Plaintiff”) and the

defendants Jewmon Enterprises, LLC, Timothy Sykes, Zachary Westphal, 

Millionaire Publishing, LLC, Millionaire Media, LLC, and StocksToTrade.com 

Inc. (collectively “Defendants”) for entry of a protective order (the “Protective 

Order”) governing the exchange and receipt of confidential information 

produced during discovery in the above-captioned action (the “Action”). The 

Court grants the parties’ joint motion. (ECF No. 66.) The Plaintiff and each of 

the Defendants shall be referred to herein individually as a “Party,” and 

collectively, as the “Parties.”

WHEREAS, the Parties have sought or may seek certain information from 

one another during discovery in this Action that the Parties may designate as 

confidential because it may include trade secrets or other non-public and 

confidential technical, commercial, financial, and business information;

WHEREAS, a Party's trade secret, confidential, competitive, or 

proprietary information could be abused if its use were not limited to this 

lawsuit and otherwise protected from disclosure as provided herein;

WHEREAS, the Parties seek a protective order limiting disclosure thereof 

in accordance with Federal Rule of Civil Procedure 26(c);

WHEREAS, both the Florida and federal trade secret statutes expressly 

contemplate the entry of such orders in a trade secrets case, FUTSA, Fl. Stat. § 

688.006; DTSA, 18 USC § 1835(a);

WHEREAS, certain persons or entities other than the Parties may 

produce information in this Action that those persons or entities may designate 

as confidential if they execute Exhibit A hereto (the “Declaration”) (all persons 

or entities other than the Parties who may produce information with respect to 

this Action are referred to individually as a “Non-Party” and collectively as 

“Non-Parties”, and a Non-Party who signs the Declaration is referred to as a 

“Non-Party Signatory”); and

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Therefore, it is hereby stipulated among the Parties and is hereby 

ordered that:

1. Designation Of Confidential Materials

A. This Protective Order applies to and governs any information, 

documents, and things produced or provided in this Action, either by a Party or 

Non-Party Signatory (each a “Disclosing Party”), to any other Party or NonParty Signatory (each a “Receiving Party”), including without limitation, 

documents, electronically stored information (“ESI”), things, answers to 

interrogatories, responses to requests for admissions, deposition testimony and 

testimony adduced at trial or a hearing.

B. Any Disclosing Party may designate as “Confidential” any 

information, document, or thing that a Disclosing Party believes in good faith 

constitutes, contains, embodies non-public confidential technical, commercial, 

financial, or business information, or other valuable information covered by a 

legitimate privacy right or interest. Documents or other materials designated 

as “Confidential” shall be conspicuously marked by the designating party with 

the legend “CONFIDENTIAL.”

C. Any Disclosing Party may also designate as “Highly Confidential 

Computer Code” any information, document, or thing that a Disclosing Party 

believes in good faith constitutes, contains, embodies, or reflects especially 

sensitive technical information where the Disclosing Party can demonstrate a 

significant risk of loss of competitive advantage or harm if disclosed to another 

Party without restriction upon use or further disclosure, or that the Disclosing 

Party can demonstrate affords it an actual or potential economic advantage 

over others, which may include, but is not limited to, computer code and 

associated comments and revision histories, formulas, engineering 

specifications, or schematics that define or otherwise describe in detail the 

algorithms or structure of software or hardware designs central to a Party’s 

business. Documents and other materials designated as “Highly Confidential 

Computer Code” shall be conspicuously marked with the legend “HIGHLY 

CONFIDENTIAL—COMPUTER CODE.”

D. Any Disclosing Party may also designate as “Highly Confidential 

Attorneys Eyes Only” any information, document, or thing that a Disclosing 

Party believes in good faith constitutes, contains, embodies, or reflects 

especially sensitive information where the Disclosing Party can demonstrate a 

significant risk of loss of competitive advantage or harm if disclosed to another 

Party without restriction upon use or further disclosure, or that the Disclosing 

Party can demonstrate affords it an actual or potential economic advantage 

over others, which may include, but is not limited to, trade secrets, product 

sales, product volume, pricing, revenue, profit, costs, margins, customer lists, 

Case 1:20-cv-22957-RNS Document 68 Entered on FLSD Docket 03/22/2021 Page 2 of 14
currently implemented or not yet implemented marketing plans and analyses, 

and research and development information and plans for products not yet 

released to the marketplace. Documents and other materials designated as 

“Highly Confidential Attorneys Eyes Only” shall be conspicuously marked with 

the legend “HIGHLY CONFIDENTIAL—ATTORNEYS EYES ONLY.”

E. Copies or excerpts of information contained within, or summaries, 

notes or charts containing any information from, a document or thing 

designated as “Confidential,” “Highly Confidential Computer Code” or “Highly 

Confidential Attorneys Eyes Only” shall also be treated respectively as 

“Confidential,” “Highly Confidential Computer Code” or “Highly Confidential 

Attorneys Eyes Only.” 

F. A Disclosing Party may not designate or maintain a designation as 

“Confidential,” “Highly Confidential Computer Code” or “Highly Confidential 

Attorneys Eyes Only” as to any information, document or thing that:

(i) at the time of the disclosure is available to the public; or

(ii) after disclosure becomes available to the public through no act, 

or failure to act, by the Receiving Party; or

(iii) the Receiving Party can show: (a) was already known to the 

Receiving Party by reason of being known by the Receiving Party other than 

through unlawful means; or (b) was received by the Receiving Party, after the 

time of disclosure hereunder, from a Non-Party having the right to make such a 

disclosure.

G. A Disclosing Party shall designate documents or things as 

“Confidential,” “Highly Confidential Computer Code” or “Highly Confidential 

Attorneys Eyes Only” at the time of production or service by affixing a 

conspicuous legend to such document or thing. All documents, or any 

portions thereof, made available for inspection (but not yet formally produced 

to the Receiving Party) shall be presumptively deemed to contain such 

designated levels of confidentiality subject to the provisions of this Protective 

Order, regardless of whether so identified, until copies or duplicates thereof are 

formally produced to or made by the Receiving Party. Any information, 

document, or thing that bears all three designations must be treated as “Highly 

Confidential Attorneys Eyes Only.” 

H. Deposition transcripts, or portions thereof, may be designated as 

“Confidential,” “Highly Confidential Computer Code” or “Highly Confidential 

Attorneys Eyes Only” by any Party to this action, or by the deponent, either (a) 

on the record during the deposition, or (b) by written notice to all counsel of 

record within fourteen (14) days after the Party wishing to make the 

designation receives the deposition transcript. If no portions of the transcript 

are designated as “Confidential,” “Highly Confidential Computer Code” or 

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“Highly Confidential Attorneys Eyes Only” during the deposition or within 

fourteen days of receiving the transcript, the transcript shall be considered not 

to contain any “Confidential,” “Highly Confidential Computer Code” or “Highly 

Confidential Attorneys Eyes Only.” Counsel for each Party shall be responsible 

for marking any designated portions of copies of the transcript in their 

possession with a confidentiality legend if written notice is timely provided. 

With regard to testimony designated during a deposition as “Highly 

Confidential Computer Code” or “Highly Confidential Attorneys Eyes Only” 

under this Protective Order, the designating Party shall have the right to 

exclude from the deposition, or any portion thereof, before taking of the 

designated testimony, all persons except: the deponent and its outside counsel, 

outside counsel of record for the Parties, the court reporter, and such other 

persons who are bound by this Protective Order and are authorized to have 

access to such information.

2. Restriction On Disclosure Of Designated Materials 

A. No information, documents or things so designated as 

“Confidential,” “Highly Confidential Computer Code” or “Highly Confidential 

Attorneys Eyes Only” under Section 1(B) through (D) of this Protective Order 

shall be disclosed to any person or entity except as set forth in this Protective 

Order. Information, documents or things so designated as “Confidential,” 

“Highly Confidential Computer Code” or “Highly Confidential Attorneys Eyes 

Only” shall be used by the Receiving Parties solely for the purposes of this 

Action, solely to the extent reasonably necessary and solely in full compliance 

with all provisions of this Protective Order. Nothing contained in this 

Protective Order shall affect the right of the Disclosing Party to disclose or use 

for any purpose the information, documents, or things it produces in discovery 

or designates under the Protective Order.

B. Subject to Section 2(D) of this Protective Order and any further 

Order of the Court, information, documents, and things so designated as 

“Confidential” shall not be provided, shown, made available, or communicated 

in any way to any person or entity with the exception of:

(i) the Receiving Party’s Counsel in this Action, as well as 

employees and any legal, investigative, technical, administrative, and other 

support staff of said Counsel to whom it is reasonably necessary to disclose the 

information for this Action;

(ii) the Receiving Party itself, including the officers, directors, and 

employees of the Receiving Party but only when disclosure to such persons is 

reasonably necessary for this Action and only where each of such persons have 

signed the Declaration (Exhibit A);

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(iii) Experts (as defined in this Order) of the Receiving Party to 

whom disclosure is reasonably necessary for this litigation and who have 

signed the Declaration (Exhibit A);

(iv) the Court, its personnel, and jurors;

(v) court reporters and their staff, videographers, professional jury 

or trial consultants, and professional vendors to whom disclosure is reasonably 

necessary for this litigation and who have signed the Declaration (Exhibit A);

(vi) any witnesses testifying at a deposition, hearing or trial in this 

action who have signed the Declaration (Exhibit A);

(vii) the author of a document containing the information or a 

custodian or other person who otherwise possessed or knew the information 

using lawful means; and

(viii) any mediator or settlement officer, and their supporting 

personnel, mutually agreed upon by any of the parties engaged in settlement 

discussions.

C. Subject to Section 2(D) of this Protective Order, and any further 

Order of the Court, information, documents, and things so designated as 

“Highly Confidential Computer Code” or “Highly Confidential Attorneys Eyes 

Only ” shall not be provided, shown, made available, or communicated in any 

way to any person or entity with the exception of those persons or entities 

referred to above in Section 2(B)(i) and Sections 2(B)(iii)-(viii) of this Protective 

Order.

D. The designation of any document or thing as “Confidential,” “Highly 

Confidential Computer Code” or “Highly Confidential Attorneys Eyes Only” 

shall not preclude any Party from showing the document or thing to any 

person: (a) who appears as an author or as an addressee on the face of the 

document and who is not otherwise shown prior to such disclosure not to have 

received the document; (b) who admits to or has been identified by the 

Disclosing Party as having been provided with the document or thing or with 

the information therein in circumstances where having been provided with 

such information was in no way unlawful; (c) who participated in any meeting 

or communication to which the document or thing pertains; (d) who is a 

director, officer or employee of the Disclosing Party; or (e) who has been 

identified by the Disclosing Party as a Fed. R. Civ. P. 30(b)(6) witness for 

subject matter that pertains to said document or thing.

E. In the event that any information designated as “Confidential,” 

“Highly Confidential Computer Code” or “Highly Confidential Attorneys Eyes 

Only” is used in any court proceeding or deposition in connection with this 

Action, it shall not lose its status as “Confidential,” “Highly Confidential 

Computer Code” or “Highly Confidential Attorneys Eyes Only” through such 

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use, provided that the Parties to this Action take steps reasonably calculated to 

protect its confidentiality during such use.

3. Filing Designated Materials

If it is necessary to file documents or things containing “Confidential 

Information,” “Highly Confidential Computer Code” or “Confidential Attorney 

Eyes Only Information” with the Court, the Party seeking to file such 

documents or things shall take the steps necessary to seek Court approval to 

file under seal, as provided by Local Rule 5.4.

4. Cancellation Of Designation

The Receiving Party may challenge any designation by notifying the 

Disclosing Party in writing. Within ten (10) days of receiving a written notice 

challenging any designation, the Parties shall meet-and-confer in person or 

over telephone or video conference. If the dispute cannot be resolved during 

the meet-and-confer, the Disclosing Party must present the dispute to the 

Court within ten (10) days of the meet-and-confer. If the Disclosing Party fails 

to timely present the matter to the Court, the information designated as 

“Confidential,” “Highly Confidential Computer Code” or “Highly Confidential 

Attorneys Eyes Only” shall automatically lose any confidentiality designation.

Pending the Court’s determination of any dispute contesting a designation, the 

Parties shall treat the materials as designated by the Disclosing Party. 

5. Notice 

All notices required by this Protective Order are to be served by email 

and on all counsel of record. The date by which a Party receiving a notice shall 

respond, or otherwise take action, shall be computed from the date the email 

was sent. Any of the notice requirements herein may be waived in whole or in 

part, but only in writing signed by an attorney for the Disclosing Party.

6. Disposition Of Designated Materials At End Of The Case 

A. Termination of this Action shall not relieve any Party or Non-Party 

Signatory from the obligations of this Protective Order, unless the Court orders 

otherwise.

B. With respect to any documents or things that have been filed with 

the Court under seal, upon termination of this Action, the Parties recognize 

that the ultimate disposition of any such documents or things, including all 

copies or summaries of, or excerpts from, such documents which may have 

been made, shall be as directed by the Court. The Parties shall not oppose 

efforts to show good cause to maintain such materials and documents as 

sealed or to remove such materials and documents from the Court record.

C. Except as described below, within sixty days after the final 

adjudication of this Action including appeals, or resolution through settlement, 

unless otherwise agreed to in writing by an attorney of record for the Disclosing 

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Party, each Party and Non-Party Signatory shall either (a) assemble and return 

all information, documents and things so designated as “Confidential,” “Highly 

Confidential Computer Code” or “Highly Confidential Attorneys Eyes Only,” 

including all copies, summaries, excerpts, charts or notes thereof, to the 

Disclosing Party from whom the “Confidential,” “Highly Confidential Computer 

Code” or “Highly Confidential Attorneys Eyes Only” information was obtained; 

or (b) certify in writing that all such information and material has been 

destroyed or deleted. Notwithstanding the foregoing, outside counsel for the 

Parties may retain copies of court filings, discovery responses, deposition and 

hearing transcripts, and documents provided pursuant to the Court’s 

scheduling orders containing “Confidential,” “Highly Confidential Computer 

Code” or “Highly Confidential Attorneys Eyes Only” information provided that 

all such documents will be held for their internal use only, subject to the 

continuing obligations imposed by this Protective Order. Where a Party has 

disclosed “Confidential,” “Highly Confidential Computer Code” or “Highly 

Confidential Attorneys Eyes Only” information to persons or entities identified 

in Section 2(B) of this Protective Order, that Party is responsible for returning, 

destroying or deleting such material and obtaining appropriate certifications as 

set forth above.

7. Amendments And Exceptions By Order Of The Court 

This Protective Order may be modified by further order of the Court, and 

is without prejudice to the rights of any Party, or any Non-Party subject to 

discovery in this action to move for relief from any of its provisions, or different 

or additional protection for any particular information, documents or things.

8. Restriction On Use Of Designated Materials 

Information designated “Confidential,” “Highly Confidential Computer 

Code” or “Highly Confidential Attorneys Eyes Only” shall be held in confidence 

by each person or entity to whom it is disclosed, shall be used by the recipient 

only for purposes of preparation and trial of this Action, for resolution of 

disputes between the Parties, and for no other purposes, and shall not be 

disclosed to any person or entity who is not entitled to receive such information 

under this Protective Order. All “Confidential,” “Highly Confidential Computer 

Code” and “Highly Confidential Attorneys Eyes Only” information shall be 

carefully maintained so as to preclude access by persons or entities who are 

not entitled to receive such information.

9. Other Proceedings 

By entering this Protective Order and limiting the disclosure of 

information in this case, the Court does not intend to preclude another court 

from finding that information may be relevant and subject to disclosure in 

another case. Any Party or Non-Party Signatory who becomes subject to a 

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motion, discovery request, or subpoena to disclose another Party or Non-Party 

Signatory’s information designated pursuant to this Protective Order shall 

promptly notify that Disclosing Party of the motion, discovery request, or 

subpoena so that the Disclosing Party may have an opportunity to appear and 

be heard on whether that information should be disclosed. If the Disclosing 

Party objects to the disclosure, the Receiving Party shall withhold production 

or disclosure of such protected information to the fullest extent permitted by 

law until any dispute relating to the production or disclosure of such protected 

information is resolved. If a Receiving Party has timely notified a Disclosing 

Party of a motion, discovery request, or subpoena as provided in this 

paragraph, the Receiving Party’s obligation to withhold production or 

disclosure does not include an obligation to affirmatively seek relief from a 

court or take other affirmative steps to protect the designated material. 

Notwithstanding any provision in this Protective Order, any Receiving Party 

subject to an order of any court to disclose a Disclosing Party’s information 

designated pursuant to this Protective Order may comply with said court order.

10. Production Of Non-Party Protected Material

 A. The terms of this Protective Order are applicable to information 

produced by a Non-Party in this Action and designated as “CONFIDENTIAL,” 

“HIGHLY CONFIDENTIAL COMPUTER CODE” and “HIGHLY CONFIDENTIAL 

ATTORNEYS EYES ONLY.” Such information produced by Non-Parties in 

connection with this litigation is protected by the remedies and relief provided 

by this Protective Order. Nothing in these provisions should be construed as 

prohibiting a Non-Party from seeking additional protections, including 

negotiating a separate protective order with any third party, provided that all 

parties to this litigation are included in the negotiation of such agreement and 

ultimately agree to the terms of such agreement.

 B. In the event that a Party is required, by a valid discovery request, to 

produce a Non-Party’s protected material in its possession, and the Party is 

subject to an agreement with the Non-Party not to produce the Non-Party’s 

protected material, then the Party shall:

(i) notify the Requesting Party and the Non-Party in writing within 

seven (7) days of receiving the discovery request(s), that some or all of the 

information requested is subject to a confidentiality agreement with a NonParty;

(ii) provide the Non-Party with a copy of the Protective Order in this 

Action within seven (7) days of receiving the discovery request(s), the relevant 

discovery request(s), and a reasonably specific description of the information 

requested; and

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(iii) make the information requested available for inspection by the 

Non-Party, if requested.

 C. If the Non-Party fails to seek a protective order from this court 

within seven (7) days of receiving the notice and accompanying information, 

the Producing Party may produce the Non-Party’s protected material 

responsive to the discovery.

11. General Provisions 

A. The designation of information, documents, or things as 

“Confidential,” “Highly Confidential Computer Code” or “Highly Confidential 

Attorneys Eyes Only” pursuant to this Protective Order shall not be construed 

as a concession that such information is relevant or material to any issues or 

is otherwise discoverable or admissible. Nor shall the inspection or receipt by 

a Party to this action of information, documents, or things so designated as 

“Confidential,” “Highly Confidential Computer Code” or “Highly Confidential 

Attorneys Eyes Only” hereunder constitute a concession that the information, 

documents, or things are confidential.

B. Nothing in this Protective Order shall bar or otherwise restrict any 

attorney from rendering advice with respect to this Action and, in the course 

thereof, from generally referring to or relying upon the attorney’s examination 

or receipt of “Confidential,” “Highly Confidential Computer Code” or “Highly 

Confidential Attorneys Eyes Only.” In rendering such advice or in otherwise 

communicating, the attorney shall not disclose the specific content of any 

information, document, or thing identified as “Confidential,” “Highly 

Confidential Computer Code” or “Highly Confidential Attorneys Eyes Only” by a 

Disclosing Party where such disclosure would not otherwise be permitted 

under the terms of this Protective Order.

C. The disclosure by a Disclosing Party of information, documents, or 

things which it believes should have been designated as “Confidential,” “Highly 

Confidential Computer Code” or “Highly Confidential Attorneys Eyes Only” 

(regardless of whether the information, documents, or things were so 

designated at the time of disclosure) shall not be deemed a waiver in whole or 

in part of the Disclosing Party’s claim of confidentiality, either as to the specific 

information disclosed or as to any other information relating thereto or on the 

same or related subject matter, provided that the Disclosing Party notifies the 

Receiving Party within seven (7) days after discovery of the failure to designate. 

If a Disclosing Party produces or provides discovery of any “Confidential,” 

“Highly Confidential Computer Code” or “Highly Confidential Attorneys Eyes 

Only” information without designating it as such, the Disclosing Party may give 

written notice to the Receiving Party(ies) that the information or material is 

“Confidential,” “Highly Confidential Computer Code” or “Highly Confidential 

Case 1:20-cv-22957-RNS Document 68 Entered on FLSD Docket 03/22/2021 Page 9 of 14
Attorneys Eyes Only” and should be treated in accordance with the provisions 

of this Protective Order. The Receiving Party(ies) must treat such information 

or material as “Confidential,” “Highly Confidential Computer Code” or “Highly 

Confidential Attorneys Eyes Only” as notified from the date such notice is 

received. Disclosure of such information or material, before receiving such 

notice, to persons not authorized to receive “Confidential,” “Highly Confidential 

Computer Code” or “Highly Confidential Attorneys Eyes Only” shall not be 

deemed a violation of this Protective Order; however, those persons to whom 

disclosure was made are to be advised that the material disclosed is 

“Confidential,” “Highly Confidential Computer Code” or “Highly Confidential 

Attorneys Eyes Only” and must be treated in accordance with this Protective 

Order.

D. If a Disclosing Party has inadvertently disclosed to a Receiving 

Party documents or information that it believes is privileged, such disclosure 

does not constitute a waiver of privilege or work product protection for those 

materials or the subject matter of those materials in this proceeding or in any 

other Federal or State proceedings involving the parties to this proceeding or 

third parties provided that promptly upon discovery of such disclosure the 

Disclosing Party notifies the Receiving Party that the inadvertently disclosed 

documents or information are privileged, identifies the grounds on which the 

assertion of privilege is based, and requests that the documents or information 

be returned. Upon receipt of such written notice, the Receiving Party will 

return or destroy the inadvertently produced documents or information and all 

copies thereof within ten (10) calendar days of receiving the written notice and 

request for return of such documents or information. The Receiving Party that 

returns inadvertently produced documents or information may thereafter seek 

production of any such documents or information, but may not assert waiver 

of privilege based on the inadvertent production request. 

E. This Protective Order shall survive the final adjudication of this 

Action (including any appellate proceedings), with the Court retaining 

jurisdiction to enforce the provisions thereof, to the extent information or 

material so designated remains “Confidential,” “Highly Confidential Computer 

Code” or “Highly Confidential Attorneys Eyes Only” as defined in Section 1 of 

this Protective Order.

F. If a Receiving Party learns that, by inadvertence or otherwise, it has 

disclosed protected material to any person or in any circumstance not 

authorized under this Protective Order, the Receiving Party must immediately 

(a) notify in writing the Disclosing Party of the unauthorized disclosures, (b) 

use its best efforts to retrieve all unauthorized copies of the protected material, 

(c) inform the person or persons to whom unauthorized disclosures were made 

Case 1:20-cv-22957-RNS Document 68 Entered on FLSD Docket 03/22/2021 Page 10 of 14
of all the terms of this Protective Order, and (d) request such person or persons 

to execute the Declaration (Exhibit A).

G. By stipulating to the entry of this Protective Order, no Disclosing 

Party waives any right it otherwise would have to object to disclosing or 

producing any information or item on any ground not addressed in this 

Protective Order. Similarly, no Disclosing Party waives any right to object on 

any ground to use in evidence of any of the material covered by this Protective 

Order.

Done and ordered at Miami, Florida on March 19, 2021 .

Robert N. Scola, Jr.

United States District Judge

Case 1:20-cv-22957-RNS Document 68 Entered on FLSD Docket 03/22/2021 Page 11 of 14
STIPULATED AND AGREED:

Dated: March 19, 2021

SQUIRE LAW GROUP, P.A.

/s/ Gustavo D. Lage

Gustavo D. Lage

Florida Bar No. 972551 

301 W. Atlantic Avenue, Suite 5

Delray Beach, FL 33444

Phone: 888.788.8816

Fax: 786.577.0425

dlage@squirelawgroup.com 

Attorneys for Plaintiff Scanz 

Technologies, Inc.

BERGER SINGERMAN LLP 

/s/ Justin B. Elegant

Justin B. Elegant 

Florida Bar No. 0134597 

Sabrina T. Zarco 

Florida Bar No. 1025800

1450 Brickell Avenue, Suite 1900 

Miami, FL 33131 

Phone: (305) 755-9500 

jelegant@bergersingerman.com 

szarco@bergersingerman.com 

ALSTON & BIRD LLP

Brett D. Jaffe (admitted pro hac vice)

Steven R. Campbell (admitted pro hac 

vice)

Reade W. Seligmann (admitted pro hac 

vice)

90 Park Avenue 

New York, New York 10016-1387 

Phone: 212-210-9400 

brett.jaffe@alston.com 

steven.campbell@alston.com

reade.seligmann@alston.com

Case 1:20-cv-22957-RNS Document 68 Entered on FLSD Docket 03/22/2021 Page 12 of 14
David S. Frist (admitted pro hac vice)

One Atlantic Center

1201 West Peachtree Street

Suite 4900

Atlanta, GA 30309-3424

Phone: 404-881-7000

david.frist@alston.com

Attorneys for Defendants Jewmon 

Enterprises, LLC, Timothy Sykes, 

Millionaire Publishing, LLC, and 

Millionaire Media, LLC

SQUIRE PATTON BOGGS (US) LLP

/s/ Raúl B. Mañón

Raúl B. Mañón 

Florida Bar No. 18847

200 South Biscayne Boulevard, Suite 

4700

Miami, FL 33131

Phone: +1 305-577-7000

raul.manon@squirepb.com

Gabriel Colwell (admitted pro hac vice)

555 South Flower Street, 31st Floor

Los Angeles, CA 90071

Phone: +1 213-689-5126

gabriel.colwell@squirepb.com

Joseph A. Meckes (admitted pro hac vice) 

275 Battery Street, Suite 2600 

San Francisco, CA 94111

Phone: +1 415-954-0201

joseph.meckes@squirepb.com

Attorneys for Defendants 

StocksToTrade.com, Inc. and Zachary 

Westphal

Case 1:20-cv-22957-RNS Document 68 Entered on FLSD Docket 03/22/2021 Page 13 of 14
EXHIBIT A

United States District Court

For The Southern District Of Florida

Undertaking

I, _______________________________, declare as follows:

1. My business address is _________________________________________.

2. My present employer and the address of my present employer (if 

different from above) is ____________________________________________________.

3. My present occupation of job description is _____________________.

4. My job title is __________________________________________________.

5. I have received a copy of the Protective Order in Scanz Technogies, 

Inc. v. Jewmon Enterprises, LLC et al., Case No. 20-cv-22957-RNS.

6. I have carefully read and understand the provisions of the 

Protective Order.

7. I agree to be bound by the terms of the Protective Order.

8. I will hold in confidence, will not disclose to anyone not qualified 

under the Protective Order, and will use only for the purposes of this action, 

any “Confidential,” “Highly Confidential Computer Code,” and/or “Highly 

Confidential Attorneys Eyes Only” information that is disclosed to me.

9 I will return to outside counsel for the party by whom I am 

employed or retained all “Confidential,” “Highly Confidential Computer Code,” 

and/or “Highly Confidential Attorneys Eyes Only” information that came into 

my possession, and documents or things which I have prepared relating 

thereto. Alternatively, I will provide to outside counsel for the party by whom I 

am employed or retained a written certification that all such information and 

documents or things have been destroyed.

10. I hereby submit myself to the jurisdiction of the U.S. District Court 

for the Southern 

District of Florida for the purpose of enforcement of the Protective Order in this 

action.

I declare under penalty of perjury under the laws of the United 

States of America that the foregoing is true and correct.

Signed:__________________________

Case 1:20-cv-22957-RNS Document 68 Entered on FLSD Docket 03/22/2021 Page 14 of 14