UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF FLORIDA

RICCARDO SILVA, 

Plaintiff, 

vs. 

MOBILE BILLBOARDS, INC., et al. 

 Defendants.

Case No.: 22-cv-24262-Altman/Reid 

 

PLAINTIFF RICCARDO SILVA’S UNOPPOSED MOTION FOR PROTECTIVE 

ORDER GOVERNING THIRD-PARTY PRODUCTION OF DOCUMENTS 

Plaintiff Riccardo Silva (“Plaintiff”), through his counsel, respectfully moves the Court for 

a protective order governing third-party production of documents, and in support thereof, states as 

follows: 

1. Plaintiff filed this lawsuit on December 30, 2022. [ECF No. 1]. 

2. In the Complaint, [ECF No. 7-1], Plaintiff names five defendants: Mobile 

Billboards, Inc. (“Mobile Billboards”) and four John Doe Defendants (the “John Does”). 

3. In particular, Plaintiff alleges in his Complaint that the four John Does have 

anonymously defamed him, through forums such as Twitter, Reddit, a website (the “Website”), 

and a mobile billboard. 

4. Since filing his lawsuit, Plaintiff has been working diligently to identify the 

anonymous John Does, including for purposes of service of process. See Joint Sched. Rpt. [ECF 

No. 18] (Plaintiff informing the Court that his efforts to identify the John Does are underway); 

Mot. to Re-Open the Case [ECF No. 23]. Since those filings, Plaintiff has issued numerous 

subpoenas to individuals and companies he has learned have been in contact with the anonymous 

individuals believed to be involved in the defamation campaign against him. See Mot. to Re-Open 

the Case [ECF No. 23]. 

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5. Plaintiff has received document productions from some of the subpoenaed parties. 

To the extent those productions, however, contain confidential or personally-identifiable 

information (“PII”), Plaintiff seeks a protective order—a proposed form of which is attached 

hereto as Exhibit A—to protect against disclosure of this confidential information or PII. 

6. In fact, one of the subpoenaed third parties made its production of documents 

conditional on Plaintiff’s agreement to the attached proposed protective order. 

7. Good cause thus exists to enter the attached proposed protective order. 

8. Accordingly, Plaintiff respectfully requests that the Court grant this Motion and 

enter the proposed protective order governing third-party production of documents attached hereto. 

9. Plaintiff has conferred with counsel of record for Defendant Mobile Billboards, 

which does not oppose the relief sought through this Motion. 

WHEREFORE, Plaintiff Riccardo Silva respectfully requests that this Court enter the 

proposed protective order attached hereto as Exhibit A, and for such further relief as this Court 

deems equitable, just, and proper. 

 

Case 1:22-cv-24262-RKA Document 29 Entered on FLSD Docket 05/02/2023 Page 2 of 4
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Dated: May 2, 2023 Respectfully submitted, 

By: /s/ Joshua M. Mandel 

GREENBERG TRAURIG, P.A. 

333 S.E. 2nd Avenue, Suite 4400 

Miami, Florida 33131 

Telephone: (305) 579-0570 

Facsimile: (305) 961-5702 

THOMAS R. HEISLER 

Florida Bar No. 1029852 

heislert@gtlaw.com 

BENJAMIN GREENBERG 

Florida Bar No. 192732 

greenbergb@gtlaw.com 

JOSHUA M. MANDEL 

Florida Bar No. 1031396 

mandelj@gtlaw.com

cruzm@gtlaw.com

fernandezf@gtlaw.com

FLService@gtlaw.com 

Counsel for Plaintiff Riccardo Silva

 

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CERTIFICATE OF SERVICE 

I hereby certify that on this 2nd day of May, 2023, I electronically filed the foregoing 

document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document 

is being served this day on all counsel of record via transmission of Notices of Electronic Filing 

generated by CM/ECF. 

/s/ Joshua M. Mandel 

 JOSHUA M. MANDEL 

 

Case 1:22-cv-24262-RKA Document 29 Entered on FLSD Docket 05/02/2023 Page 4 of 4