UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 1:22-cv-22696-RNS-JG

EXXON MOBIL CORPORATION,

Plaintiff,

v.

THE INDIVIDUALS AND BUSINESS ENTITIES

IDENTIFIED ON SCHEDULE A, 

Defendants.

___________________________________________/

STIPULATED PROTECTIVE ORDER1

Plaintiff, EXXON MOBIL CORPORATION, and Defendants, AMV Enterprises, Inc.,

Carlo Ribera, 7500 Enterprises, LLC and Everlast Lubricants, LLC (each a “Party,” collectively, 

the “Parties”) believe that certain information that is or will be encompassed by discovery 

demands by the Parties involves the production or disclosure of trade secrets, confidential business

and financial information, or other proprietary information;

WHEREAS, the Parties seek a protective order limiting disclosure thereof in accordance 

with Federal Rule of Civil Procedure 26(c):

THEREFORE, it is hereby stipulated among the Parties and ORDERED that:

1. Each Party may designate as confidential for protection under this Order, in whole 

or in part, any document, information or material that constitutes or includes, in whole or in part, 

confidential or proprietary information or trade secrets of the Party or a Third Party to whom the 

Party reasonably believes it owes an obligation of confidentiality with respect to such document, 

1 The Undersigned modified the proposed stipulated protective order in numbered 

paragraphs 14 and 15. The Undersigned has also made minor edits for stylistic and grammatical 

purposes.

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information or material (“Protected Material”). Protected Material shall be designated by the Party 

producing it by affixing a legend or stamp on such document, information or material as follows: 

“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES ONLY”. The 

word(s) “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES ONLY” 

shall be placed clearly at the bottom of each page of the Protected Material (except deposition and 

hearing transcripts) for which such protection is sought. For deposition, hearing and trial 

transcripts, the word “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL - ATTORNEYS’ 

EYES ONLY” shall be placed on the cover page of the transcript (if not already present on the 

cover page of the transcript when received from the court reporter) by each attorney receiving a 

copy of the transcript after that attorney receives notice of the designation of some or all of that 

transcript as “CONFIDENTIAL or “HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES ONLY”

and on each page where “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL - ATTORNEYS’ 

EYES ONLY” testimony or statements are made.” For video recordings of depositions or hearings, 

the Parties shall instruct the videographer upon the conclusion of the video-testimony, how to 

designate the videorecording, or any portion thereof, as “CONFIDENTIAL” or “HIGHLY 

CONFIDENTIAL – ATTORNEYS’ EYES ONLY”.

2. With respect to documents, information or material designated 

“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES ONLY” 

(“DESIGNATED MATERIAL”),2subject to the provisions herein and unless otherwise stated, 

this Order governs, without limitation: (a) all documents, electronically stored information, and/or 

things as defined by the Federal Rules of Civil Procedure; (b) all trial, pretrial, hearing or 

2 The term DESIGNATED MATERIAL is used throughout this Protective Order to refer to 

the class of materials designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -

ATTORNEYS’ EYES ONLY” both individually and collectively.

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deposition testimony, or documents marked as exhibits or for identification in depositions,

hearings and trial; (c) pretrial pleadings, exhibits to pleadings and other court filings; (d) affidavits; 

and (e) stipulations. All copies, reproductions, extracts, digests and complete or partial summaries 

prepared from any DESIGNATED MATERIAL shall also be considered DESIGNATED 

MATERIAL and treated as such under this Order.

3. A designation of Protected Material (i.e., “CONFIDENTIAL” or “HIGHLY 

CONFIDENTIAL - ATTORNEYS’ EYES ONLY”) may be made at any time. Inadvertent or 

unintentional production of documents, information or material that has not been designated or 

identified as DESIGNATED MATERIAL shall not be deemed a waiver in whole or in part of a 

claim for confidential treatment. If the Designating Party discovers that information should have 

been but was not designated as Confidential Information or Highly Confidential – Attorneys’ Eyes 

Only, then the Designating Party must immediately notify all other parties. In such event, within 

five (5) days of notification, the Designating Party must provide replacement copies of the 

Confidential or Highly Confidential – Attorneys’ Eyes Only Information bearing the proper 

designation in accordance with this Order. The Designating Party may request destruction of that 

undesignated Protected Material by notifying the recipient(s), as soon as reasonably possible after 

providing replacement Protected Material that is properly designated. The recipient(s) shall then 

destroy all copies of the inadvertently or unintentionally produced Protected Materials and any 

documents, information or material derived from or based thereon.

4. Confidential Material: “CONFIDENTIAL” documents, information and material 

may be disclosed only to the following persons, except upon receipt of the prior written consent 

of the Designating Party, upon order of the Court, or as set forth in paragraph 12 herein:

(a) A Party’s counsel of record, including necessary paralegal, secretarial, clerical 

personnel assisting such counsel, and any other employees of counsel or independent contractors 

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operating under counsel’s instruction;

(b) Counsel (whether or not counsel of record) representing or advising the parties in 

this litigation, including in-house counsel or any other legal staff personnel who are employed by 

a party and are participating in the litigation on behalf of the party;

(c) The principals, managers, members, officers, agents and employees of a party who 

are actively involved in the litigation on behalf of such party; 

(d) Witnesses at depositions if the witness is a principal, manager, member, officer, 

agent, employee or expert of the producing party; 

(e) Outside consultants or experts and their staff to whom such experts or consultants 

consider it necessary to disclose Confidential Documents (i.e., not existing employees or affiliates 

of a Party or an affiliate of a Party) retained for the purpose of this litigation, provided that: (1) 

such consultants or experts are not presently employed by the Parties hereto for purposes other 

than this Action; and (2) before access is given, the consultant or expert has completed the 

Undertaking attached as Exhibit A hereto;

(f) The author or recipient of a document containing the information or a custodian or 

other person who otherwise possessed or knew the information;

(g) Any mediator(s), arbitrator(s), or special masters(s) appointed by the Court or 

agreed to by the Parties;

(h) Independent litigation support services, including persons working for or as court 

reporters, stenographers, videographers, graphics or design services, jury or trial consulting 

services, and photocopy, document imaging, and database services retained by counsel and 

reasonably necessary to assist counsel with the litigation of this Action; and

(i) The Court and its personnel;

(j) Court officials involved in this litigation, including court reporters, videographers, 

and persons operating video recording or electronic equipment at depositions, hearings and/or 

trial; and 

(k) Any other person who is approved by subsequent agreement of the parties or order 

of the Court.

5. A Party shall designate documents, information or material as “CONFIDENTIAL” 

only upon a good faith belief that the documents, information or material contains confidential or 

proprietary information or trade secrets of the Party or a Third Party to whom the Party reasonably 

believes it owes an obligation of confidentiality with respect to such documents, information or 

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material. Documents, information or material produced pursuant to any discovery request in this 

Action, including but not limited to Protected Material designated as DESIGNATED MATERIAL, 

shall be used by the Parties only in the litigation of this Action and shall not be used for any other 

purpose. Any person or entity who obtains access to DESIGNATED MATERIAL or the contents 

thereof pursuant to this Order shall not make any copies, duplicates, extracts, summaries or 

descriptions of such DESIGNATED MATERIAL or any portion thereof except as may be 

reasonably necessary in the litigation of this Action. Any such copies, duplicates, extracts, 

summaries or descriptions shall be classified DESIGNATED MATERIALS and subject to all of 

the terms and conditions of this Order.

6. Highly Confidential – Attorneys’ Eyes Only Material: Any party may designate 

Protected Material as “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” when the

producing Party believes in good faith that the Protected Material is so sensitive that its 

dissemination deserves even further limitation, including information that the Designating Party 

in good faith believes that disclosure will likely harm the Designating Party’s competitive position 

concerning, inter alia: sensitive trade secrets; customer/supplier lists and other highly confidential

information regarding customers, dealers, suppliers and distributors; non-public technical 

information; confidential financial information; manufacturing information; confidential research 

and development information; confidential commercial information regarding technology used to 

make and/or confirm the authenticity of the products at issue in the litigation; and/or highly 

sensitive information that is not publicly known. The accused counterfeit products themselves shall 

not be designated as highly confidential.

7. No document shall be designated as “Confidential” or “Attorneys’ Eyes Only” if 

the document contains information that is already in the knowledge or possession of the party to 

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whom disclosure is made unless that party is already bound by an agreement not to disclose such 

information, or information that has been disclosed to the public or third persons in a manner 

making such information no longer confidential.

8. For Protected Material designated as HIGHLY CONFIDENTIAL --

ATTORNEYS’ EYES ONLY, access to, and disclosure of, such Protected Material shall be 

limited to individuals listed in paragraphs 4(a), (b), and (e)-(k).

9. Privilege/Work Product Material: Nothing in this Order shall require production 

of documents, information or other material that a Party contends is protected from disclosure by 

the attorney-client privilege, the work product doctrine, or other privilege, doctrine, or immunity.

The Party serving privileged/work product material, shall simultaneously provide a privilege log 

to the receiving Party. If documents, information or other material subject to a claim of attorneyclient privilege, work product doctrine, or other privilege, doctrine, or immunity is inadvertently 

or unintentionally produced, then such production shall in no way prejudice or otherwise 

constitute a waiver of, or estoppel as to, any such privilege, doctrine, or immunity. Any Party that 

inadvertently or unintentionally produces documents, information or other material it reasonably 

believes are protected under the attorney-client privilege, work product doctrine, or other 

privilege, doctrine, or immunity may obtain the return of such documents, information or other 

material by promptly notifying the recipient(s) and shall simultaneously provide a privilege log

for the inadvertently or unintentionally produced documents, information or other material. 

10. Any Party that believes they have inadvertently or unintentionally received 

DESIGNATED MATERIAL, or documents, information or other material subject to a claim of 

attorney-client privilege, work product doctrine, or other privilege, doctrine, or immunity, shall 

immediately notify the producing Party of the potential inadvertent disclosure. The recipient(s) 

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shall within ten (10) business days sequester, gather and return all copies of such documents, 

information or other material to the producing Party (and take reasonable action to retrieve from 

Third Parties for return, sequester, or destruction), except for any pages containing privileged or 

otherwise protected markings by the recipient(s), which pages shall instead be destroyed and 

certified as such to the producing Party. Nothing in this provision shall waive or limit any party’s 

obligations under Fed. R. Civ. P. 26(b)(5)(B) or, to the extent applicable to inadvertently-produced 

privileged information, the Florida Rules of Professional Conduct.

11. There shall be no disclosure of any DESIGNATED MATERIAL by any person 

authorized to have access thereto to any person who is not authorized for such access under this 

Order. The Parties are hereby ORDERED to safeguard all such documents, information and 

material to protect against disclosure to any unauthorized persons or entities.

12. Use of Designated Material: Nothing contained herein shall be construed to 

prejudice any Party’s right to use any DESIGNATED MATERIAL in taking testimony at any 

deposition, hearing or trial provided that the DESIGNATED MATERIAL is disclosed only to a 

person(s) who is: (i) eligible to have access to the DESIGNATED MATERIAL by virtue of his 

or her employment with the designating party, (ii) identified in the DESIGNATED MATERIAL 

as an author, addressee, or copy recipient of such information, (iii) although not identified as an 

author, addressee, or copy recipient of such DESIGNATED MATERIAL, has, in the ordinary 

course of business, seen such DESIGNATED MATERIAL, (iv) a current or former officer, 

director or employee of the producing Party or a current or former officer, director or employee 

of a company affiliated with the producing Party; (v) for CONFIDENTIAL MATERIAL, counsel 

for a Party, including outside counsel, and in-house counsel, and for HIGHLY CONFIDENTIAL 

- ATTORNEYS’ EYES ONLY MATERIAL, those in the categories identified above, unless 

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agreed in a prior writing; (vi) subject to Paragraph 4(e), an independent contractor, consultant, 

and/or expert retained for the purpose of this litigation; (vii) court reporters and videographers; 

(viii) the Court; or (ix) other persons entitled hereunder to access to DESIGNATED MATERIAL. 

DESIGNATED MATERIAL shall not be disclosed to any other persons unless prior authorization 

is obtained from counsel representing the producing Party.

13. If a question is asked at a deposition or hearing the answer to which might disclose 

confidential information, counsel for the deponent or party with an interest in protecting the 

confidential information may, either on the record at the deposition or within thirty (30) days after 

receipt of the deposition or hearing transcript, designate the appropriate portions of the transcript 

as “Confidential” or “Attorneys’ Eyes Only.” As soon as the designation is made, that portion of 

the original and all copies of the deposition transcript shall bear the legend “Confidential” or 

“Attorneys’ Eyes Only” and shall be considered as DESIGNATED MATERIAL for purposes of 

this Order. Nothing in this paragraph shall be construed as a waiver of confidentiality of any 

DESIGNATED MATERIAL attached as an exhibit to a deposition. Documents labeled 

“Confidential” or “Attorneys’ Eyes Only” attached as exhibits to a deposition or hearing shall 

automatically be considered DESIGNATED MATERIAL without any further action on the part 

of any party. Prior to expiration of the 30-day period, the entire deposition or hearing transcript 

or videorecording shall be treated as confidential.

14. Before filing any DESIGNATED MATERIAL or discussing or referencing such 

material in court filings, or using DESIGNATED MATERIAL at depositions, hearings and/or 

trial, the filing party shall confer with the designating party, in accordance with Local Rule

7.1(a)(3), to determine whether the designating party will remove the confidential designation, 

whether the document should be redacted, or whether a motion to seal or stipulation and proposed 

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order is warranted. During the meet and confer process, the designating party must identify the 

basis for sealing the specific confidential information at issue, and the designating party shall 

include this basis in its motion to seal, along with any objection to sealing the information at issue.

Submissions filed with the Court are presumptively open and accessible to the public. A party 

seeking to file material under seal shall have the burden of demonstrating why sealing is necessary 

-- especially if the material is filed in connection with a request for a substantive ruling, like a 

summary judgment motion. Local Rule 5.4 sets forth the procedures that must be followed and 

the standards that will be applied when a party seeks permission from the Court to file material 

under seal. A party who seeks to maintain the confidentiality of its information must satisfy the 

requirements of Local Rule 5.4, even if it is not the party filing the motion to seal. 

15. Challenging Confidentiality Designations: Any party may challenge a 

designation given to any DESIGNATED MATERIAL at any time by notifying the designating 

Party in writing of the basis for the dispute, identifying the specific document[s] or thing[s] as to

which the designation is disputed and proposing a new designation for such materials. The Parties 

must make every attempt to resolve any dispute without court involvement. Any motion regarding 

confidentiality designation or for a protective order must include a certification, in the motion or 

in a declaration or affidavit, that the movant has engaged in a good faith meet and confer 

conference with other affected parties in an effort to resolve the dispute without court action. The 

certification must list the date, manner, and participants to the conference. A good faith effort to 

confer requires a face-to-face meeting or a telephone conference. If the parties are unable to 

resolve their dispute informally, then a party objecting to the designation of information may 

move for an order vacating the designation pursuant to the Undersigned’s Discovery Procedures 

Order [ECF No. 12]. Pending the Court’s determination of the application, the designation of the 

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designating Party shall be maintained. A Party’s failure to contest a designation of information as 

Confidential or Highly Confidential is not an admission that the information was properly 

designated as such.

16. Acknowledgement Form: Each outside consultant or expert to whom 

DESIGNATED MATERIAL is disclosed in accordance with the terms of this Order shall be 

advised by counsel of the terms of this Order, shall be informed that he or she is subject to the 

terms and conditions of this Order, and shall sign an acknowledgment that he or she has received 

a copy of, has read, and has agreed to be bound by this Order. A copy of the acknowledgment 

form is attached as Exhibit A.

17. Third Party Material: To the extent that any discovery is taken of persons who 

are not Parties to this Action (“Third Parties”) and in the event that such Third Parties contend the 

discovery sought involves the Third Parties’ trade secrets, confidential business information, or 

other proprietary information, then such Third Parties may agree to be bound by this Order.

18. To the extent that discovery or testimony is taken of Third Parties, the Third Parties 

may designate as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES 

ONLY” any documents, information or other material, in whole or in part, produced or given by 

such Third Parties. The Third Parties shall have ten (10) days after production of such documents, 

information or other materials to make such a designation. Until that time period lapses or until 

such a designation has been made, whichever occurs sooner, all documents, information or other 

material so produced or given shall be treated as “CONFIDENTIAL” in accordance with this 

Order.

19. To the extent that any discovery is sought of any Third Party, and in the event such 

Third Party or any party hereto contends that the discovery sought involves DESIGNATED 

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MATERIAL or other confidential information, then such Third Party shall be asked to agree, by 

executing the declaration attached as Exhibit B, to join in and be bound by this Order. If the Third 

Party agrees, in writing, to join in and be bound by this Order, then such Third Party’s 

DESIGNATED MATERIAL and other confidential information shall be protected by this Order.

20. Service of Designated Material: Any Party electronically serving 

DESIGNATED MATERIAL, shall share the DESIGNATED MATERIAL by email or a shared 

file link to all email eservice addresses identified in the Parties’ Counsel’s signature blocks below.

The subject line of the email shall include the language “SERVICE OF DESIGNATED

MATERIAL, Exxon Mobil v. AMV, USDC SD FLA Case No.: 1:22-cv-22696-RNS”. NonDesignated Material shall be served by the same method, may be eserved in the same email, and 

the Subject reference line may be modified accordingly. Any files or documents classified as 

Designated Material shall include in its file name the DESIGNATION assigned to that file, folder 

or document, (i.e., ExxonMobil bates number XXXX, AEO, etc.)

21. Return or Destruction of Documents: Within thirty (30) days of any settlement

or final termination of this Action, including any appeals, all DESIGNATED MATERIAL, 

including all copies, duplicates, abstracts, indexes, summaries, descriptions, and excerpts or 

extracts thereof (excluding excerpts or extracts incorporated into any privileged memoranda of 

the Parties and materials which have been admitted into evidence in this Action), shall at the 

producing Party’s election either be returned to the producing Party or be destroyed. The receiving 

Party shall verify the return or destruction by affidavit furnished to the producing Party, upon the 

producing Party’s request.

22. The failure to designate documents, information or material in accordance with 

this Order and the failure to object to a designation at a given time shall not preclude the filing of 

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a motion at a later date seeking to impose such designation or challenging the propriety thereof.

The entry of this Order and/or the production of documents, information and material hereunder 

shall in no way constitute a waiver of any objection to the furnishing thereof, all such objections 

being hereby preserved.

23. Any Party knowing or believing that any other party is in violation of or intends to 

violate this Order and has raised the question of violation or potential violation with the opposing 

party and has been unable to resolve the matter by agreement may move the Court for such relief 

as may be appropriate in the circumstances. Pending disposition of the motion by the Court, the 

Party alleged to be in violation of or intending to violate this Order shall discontinue the 

performance of and/or shall not undertake the further performance of any action alleged to 

constitute a violation of this Order.

24. Production of DESIGNATED MATERIAL by each of the Parties shall not be 

deemed a publication of the documents, information and material (or the contents thereof) 

produced so as to void or make voidable whatever claim the Parties may have as to the proprietary 

and confidential nature of the documents, information or other material or its contents.

25. Nothing in this Order shall be construed to effect an abrogation, waiver or 

limitation of any kind on the rights of each of the Parties to assert any applicable discovery or trial 

privilege. The use of DESIGNATED MATERIAL at trial of this case, shall be the subject of 

further agreement of the parties or order of the Court.

26. Each of the Parties shall also retain the right to file a motion with the Court (a) to 

modify this Order to allow disclosure of DESIGNATED MATERIAL to additional persons or 

entities if reasonably necessary to prepare and present this Action and (b) to apply for additional 

protection of DESIGNATED MATERIAL.

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27. If another court or agency or party to another action subpoenas or orders production 

of DESIGNATED MATERIAL that a party has obtained under the terms of this Protective Order, 

such party (1) shall promptly notify the producing Party who designated the Documents of the 

subpoena, public records request, or court order in writing; and (2) to the extent permitted by law, 

court rule, and court order, shall withhold production of the requested information until (a) the 

producing Party permits production, (b) a court of competent jurisdiction orders otherwise, (c) the 

producing Party files a motion or other legal action to protect such material and the court has ruled 

on said motion, or (d) the producing Party fails to file a motion or other legal action to protect 

such material within five (5) business days following receipt of the notice required in Paragraph 

24(1). The purpose of imposing these duties is to alert the interested parties to the existence of 

this Protective Order and to afford the designating party in this litigation an opportunity to try to 

protect its confidentiality interests in the court from which the subpoena, request or order issued.

28. The signature of counsel for each party will bind such party as well as all other 

counsel of record for the party.

29. Survival: This Order’s obligations regarding Confidential and Highly 

Confidential information survive the conclusion of this case.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD this 9th day of September, 2022.

NELLES LAW GROUP LAW OFFICE OF ALEXIS GONZALEZ

101 NE 3

rd Avenue, Suite 1500 3162 Commodore Plaza, Suite 3E

Fort Lauderdale, Florida 33301 Coconut Grove, Florida 33133

Telephone: (954) 246-4800 Telephone: (305) 223-9999

By: /s/ Matthew S. Nelles By: /s/ Alejandro Hoyos

Matthew S. Nelles Alejandro Hoyos 

Florida Bar No. 009245 Florida Bar No.: 181072

mnelles@nelleslawfl.com AHoyos@aglawpa.com

Elizabeth P. Perez Megha Mahajan

Florida Bar No. 182461 Florida Bar No.: 91831

eperez@nelleslawfl.com MMahajan@aglawpa.com

Eservice: yberstein@nelleslawfl.com EService: EService@aglawpa.com

Case 1:22-cv-22696-RNS Document 38 Entered on FLSD Docket 09/23/2022 Page 13 of 18
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PIRKEY BARBER PLLC Attorneys for AMV Enterprises, Inc., 

1801 E. 6th Street, Suite 300 Carlo Ribera, 7500 Enterprises, LLC, and 

Austin, TX 78702 Everlast Lubricants, LLC

Telephone: (512) 322-5200

By: _/s/ Stephen P. Meleen

Stephen P. Meleen, Esq. (Admitted Pro Hac Vice)

Texas Bar No. 00795776

smeleen@pirkeybarber.com

Tyson D. Smith, Esq. (Admitted Pro Hac Vice)

Texas Bar No. 24079362

tsmith@pirkeybarber.com

Attorneys for EXXON MOBIL CORPORATION

PURSUANT TO STIPULATION, IT IS SO ORDERED

IT IS FURTHER ORDERED that pursuant to Fed. R. Evid. 502(d), the production of 

any documents in this proceeding shall not, for the purposes of this proceeding or any other federal 

or state proceeding, constitute a waiver by the producing party of any privilege applicable to those 

documents, including the attorney-client privilege, attorney work-product protection, or any other 

privilege or protection recognized by law.

DONE AND ORDERED in Chambers, at Miami, Florida, on September 23, 2022.

Copies furnished to:

The Honorable Robert N. Scola

All counsel of record

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 1:22-cv-22696-RNS-JG

EXXON MOBIL CORPORATION,

Plaintiff,

v.

THE INDIVIDUALS AND BUSINESS ENTITIES

IDENTIFIED ON SCHEDULE A, 

Defendants.

___________________________________________/

EXHIBIT A

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

I, ____________________________________ [print or type full name], of 

____________________________________ [print] _________________________________ 

[full address], declare under penalty of perjury of the laws of the United States of America that:

1. I have received a copy of the Protective Order in this action. I have carefully read 

in its entirety and understand the Protective Order that was issued by the United States District 

Court for the Southern District of Florida on [date] in the case of Exxon Mobil Corporation v. The 

Individuals and Business Entities identified in Schedule A, Case No. 1:22-cv-22696-RNS. 

2. I agree to comply with and to be bound by all the terms of this Protective Order and 

I understand and acknowledge that failure to so comply could expose me to sanctions and 

punishment in the nature of contempt. 

3. I solemnly promise that I will hold in confidence, will not disclose to anyone not 

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

designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES 

ONLY” that is disclosed to me.

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4. Promptly upon termination of these actions, I will return all documents and things 

designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES 

ONLY” that came into my possession, and all documents and things that I have prepared relating 

thereto, to the outside counsel for the party by whom I am employed.

5. I hereby submit to the jurisdiction of this Court for the purpose of enforcement of 

the Protective Order in this action even if such enforcement proceedings occur after termination 

of this action.

Date: ________________ Signature: _____________________________________

Printed Name: __________________________________

City/State where sworn and signed: _________________

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 1:22-cv-22696-RNS-JG

EXXON MOBIL CORPORATION,

Plaintiff,

v.

THE INDIVIDUALS AND BUSINESS ENTITIES

IDENTIFIED ON SCHEDULE A, 

Defendants.

___________________________________________/

EXHIBIT B

DECLARATION OF [_____________________________]

RE: STIPULATED PROTECTIVE ORDER WITH RESPECT TO CONFIDENTIAL 

INFORMATION AND DOCUMENTS

I, _____________________________________, declare that:

1. I am [title] of [Third Party], and I have the authority to bind [Third Party].

2. [Third Party’s] address is ________________________________.

3. On behalf of [Third Party], I have read and understand the contents of the Stipulated 

Protective Order in the above-captioned case (the “Order”). [Third Party] is a Third Party as 

described in Paragraph 17 of the Order, and I am executing this Declaration and agreeing on behalf 

of [Third Party] to be bound by its terms to ensure that [Third Party’s] DESIGNATED 

MATERIAL and other confidential information is protected by the Order. 

4. [Third Party] agrees to join in and be bound by all of the terms of the Order. 

5. [Third Party] subjects itself to the continuing jurisdiction of the Court over its 

person, wherever it shall be, concerning the enforcement of the Order.

Case 1:22-cv-22696-RNS Document 38 Entered on FLSD Docket 09/23/2022 Page 17 of 18
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I declare under penalty of perjury under the laws of the United States of America that the 

foregoing is true and correct.

Date: [Third Party] 

Signature

Printed Name:______________________________

Title: ____________________________________

Full Address: ______________________________

__________________________________________

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