WPP – 4

Case 1:20-cv-23287-DPG Document 337-4 Entered on FLSD Docket 09/18/2023 Page 1 of 4
EXHIBIT C

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

LUIS MANUEL RODRIGUEZ,

MARIA TERESA RODRIGUEZ, a/k/a 

MARIA TERESA LANDA,

ALFREDO RAMON FORNS,

RAMON ALBERTO RODRIGUEZ,

RAUL LORENZO RODRIGUEZ,

CHRISTINA CONROY, and

FRANCISCO RAMON RODRIGUEZ,

Plaintiffs,

v.

IMPERIAL BRANDS PLC,

CORPORACIÓN HABANOS, S.A.,

WPP PLC, YOUNG & RUBICAM LLC,

and BCW LLC,

Defendants.

Case No.: 1:20-cv-23287-DPG

DECLARATION OF GERALD LOMBARDO IN SUPPORT OF DEFENDANTS’

OPPOSITION TO PLAINTIFFS’ MOTION TO CONDUCT JURISDICTIONAL 

DISCOVERY AS TO Y&R, LLC AND BCW, LLC 

I, Gerald Lombardo, hereby declare under penalty of perjury the truth of the following statements 

based upon personal knowledge and knowledge gained from the review of corporate records of 

BCW LLC (“BCW” or the “Company”) and from discussions with others with such knowledge:

1. I am an adult and competent to testify to the matters below. I make this Declaration to set 

forth discrete facts relevant to: (i) BCW’s motion to dismiss the March 22, 2021 Amended

Complaint (“Amended Complaint”) filed in the above-captioned litigation; and (ii) BCW’s 

opposition to Plaintiffs’ motion seeking jurisdictional discovery.

2. I am the Chief Financial Officer (“CFO”) at BCW. I have knowledge of the matters set 

forth herein based upon my position at BCW.

3. To the extent information is not based on first-hand knowledge, such information was 

gathered by: (i) conferring with a subject matter expert within the Company; and/or

(ii) reviewing BCW business records and personnel records.

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4. I am aware that Plaintiffs’ motion seeking jurisdictional discovery cites a website that 

belongs to Corporación Habanos S.A. (“Habanos”). I have reviewed the following link: 

https://www.festivaldelhabano.com/contact.htm. 

5. The Habanos website lists two names under the heading “YOUNG AND RUBICAM 

CONTACT”: Cristina Andreu and Alberto Jiménez. 

6. I searched for each of these names in BCW’s current personnel database as well as BCW’s 

legacy personnel system. 

7. These searches showed that neither Cristina Andreu nor Alberto Jiménez is a current 

employee of BCW.

8. These searches also showed that neither Cristina Andreu nor Alberto Jiménez is a former 

employee of BCW.

9. Instead, the search of BCW’s legacy system showed that both Cristina Andreu and Alberto 

Jiménez were former employees of the company BCW S.L. of Spain. 

10. The legacy system lists home addresses in Barcelona, Spain for each of the two former 

employees of that company’s Barcelona office.

11. As I explained in my prior declaration dated April 28, 2021, BCW S.L. of Spain is 

incorporated pursuant to the laws of Spain and is headquartered in Spain. This foreign 

corporation has its own employees who work out of offices in Madrid and Barcelona, 

Spain. It has no offices in the United States.

12. BCW S.L. of Spain is not a direct or indirect subsidiary of the U.S.-headquartered company 

BCW for which I serve as CFO. BCW S.L. of Spain is not found anywhere in the corporate 

chain of ownership for BCW. 

I declare under penalty of perjury that the foregoing is true and correct, to the best of my

knowledge. 

Executed on June ____, 2021, in New York, New York. 

 _______________________ 

 Gerald Lombardo 

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