AGREED PERMANENT INJUNCTION Page 1

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

SHERMAN DIVISION

PRUVIT VENTURES, INC. § 

§

Plaintiff, § 

§

v. § CIVIL ACTION NO. 4:23cv00867-SDJ

§

HAYLEY WITTE §

§

§

Defendants. §

AGREED PERMANENT INJUNCTION AND FINAL JUDGMENT

Pending before the Court is Plaintiff Pruvit Ventures, Inc. (“Pruvit” or “Plaintiff”) and 

Defendant Hayley Witte (“Witte” or “Defendant”) Joint Application for Entry of Agreed 

Permanent Injunction. Parties have advised the Court that they request the Court enter the 

following Agreed Permanent Injunction (the “Order”) have fully and completely consented to and 

agreed to be bound by this Order,

1

and have reached a settlement in this case. 

After considering the application, the record, the relevant authorities, and in light of the 

agreement of the parties, the Court finds that there is good cause to grant this Order. The Court 

further finds that Pruvit is entitled to the Agreed Permanent Injunction in this matter, hereby makes 

all necessary findings to support the entry of this Order, and the parties hereto waive any other 

findings or procedural requirements necessary to support entry of this Order.

For purposes of this Order, the below referenced terms are defined as follows: Witte shall 

be defined as including herself in her individual capacity and any agent acting both on her behalf 

and at her direction, as it relates to the terms of this Order. Pruvit shall be defined as its agents, 

1 The parties have stipulated, and the Court now finds, that all parties enjoined by this Order have waived all rights to 

seek judicial review or otherwise challenge or contest the validity of this Order, whether directly or collaterally. 

Case 4:23-cv-00867-SDJ-AGD Document 15 Filed 02/03/24 Page 1 of 4 PageID #:

202
AGREED PERMANENT INJUNCTION Page 2

employees, consultants, attorneys, representatives, affiliates, entities, successors, and assigns, and 

any and all other persons and entities under their control and/or direction or acting in active concert 

and participation with them. This definition specifically excludes Pruvit’s independent distributors 

commonly known as Pruvers.

Based on the Parties’ agreement and the Court’s findings, it is ORDERED as follows: 

Witte is enjoined and restrained, both directly and indirectly, from engaging in any of the 

following: 

1. Through July 27, 2024, Witte is restrained from knowingly inducing any existing customer

of Pruvit to terminate his/her/its business relationship with Pruvit, including requesting that

customer to promote Witte’s 7 Figure Accelerator business or Witte’s other non-Pruvit

business on his/her/its social media and/or networking sites that he/she/it uses to promote

Pruvit’s products or services.

2. Through July 27, 2024, Witte is restrained from knowingly inducing any existing promoter

of Pruvit to terminate his/her/its business relationship with Pruvit, including requesting that

promoter to promote Witte’s 7 Figure Accelerator business or Witte’s other non-Pruvit

business on his/her/its social media and networking sites that he/she/it uses to promote Pruvit’s

products or services;

3. Knowingly inducing any existing promoter of Pruvit to violate or breach the terms of

his/her/its business relationship with Pruvit; and

4. Through July 27, 2024, Witte is restrained from directly or indirectly recruiting any other

Pruvit promoters and customers, of which she had a previous relationship with, for any other

direct sales, multi-level marketing or network marketing business. This restriction does not

apply to an affiliate program that does not satisfy the definition of a network marketing and/or

direct sales company under the Pruvit Policies & Procedures, which states that such companies

are defined as “[a]ny multi-level marketing, direct sales, network marketing, affiliate

marketing, or other business opportunity or program with a multi-tier (i.e., more than one (1)

level) commission structure and/or other inventive to refer, recruit, sponsor and/or enroll

participants in that opportunity or program.” Moreover, for purposes of this provision,

“recruiting” does not include responding to inquiries that were first initiated by the

customer/promoter, or communications with those individuals who desire to join another

opportunity without any recruiting efforts or initial contact by Witte, or a third party instructed

by Witte to recruit such person(s).

Case 4:23-cv-00867-SDJ-AGD Document 15 Filed 02/03/24 Page 2 of 4 PageID #:

203
AGREED PERMANENT INJUNCTION Page 3

If Pruvit believes that there has been a violation of any of the injunctive provisions above, 

then Pruvit shall provide written Notice to Witte. Notice shall be provided to Wellman & Warren, 

LLP, at email addresses cwellman@w-wlaw.com and hfrljuckic@w-wlaw.com, and to Conley 

Rosenberg & Mendez PC, at email addresses pjc@crm-lawfirm.com and jmr@crm-lawfirm.com. 

Witte will then have seven (7) days from receipt of the Notice to cure the alleged violation (“Cure 

Period”), to the extent cure is possible. 

Other than the injunctive relief granted hereby, the Court ORDERS that any other claims 

by and between the parties are DISMISSED WITH PREJUDICE and this case closed.

The Court further ORDERS that it shall retain jurisdiction over this matter solely to 

enforce this Order, hold contempt and other proceedings to enforce this Order, and to issue any 

relief the Court deems appropriate should any of the parties violate this Order. 

This Final Judgment and Agreed Permanent Injunction shall be entered as a final judgment 

under Federal Rule of Civil Procedure 54 and 58(a).

Case 4:23-cv-00867-SDJ-AGD Document 15 Filed 02/03/24 Page 3 of 4 PageID #:

204
AGREED PERMANENT INJUNCTION Page 4

AGREED AS TO FORM AND SUBSTANCE

AND ENTRY REQUESTED:

/s/ Kelly E. Kleist________

BYRON K. HENRY

KELLY E. KLEIST

Attorney for Plaintiff

/s/ Chris Wellman (with permission)

CHRIS WELLMAN

Attorney for Defendant

Case 4:23-cv-00867-SDJ-AGD Document 15 Filed 02/03/24 Page 4 of 4 PageID #:

205