INDEX NO. 451962/2016
NYSCEF DOC. NO. 162 RECEIVED NYSCEF: 05/19/2017

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK

 

In the Matter of the Application of the

PEOPLE OF THE STATE OF NEW YORK, by
ERIC T. SCHNEIDERMAN,

Attorney General of the State of New York, Index NO- 451962/2016

Petitioner, IAS Part 61
-against- Hon. Barry R. Ostrager
PRICEWATERHOUSECOOPERS LLP and Sequence NO- 

EXXON MOBIL CORPORATION,

Respondents.

 

 

AFFIRMATION OF INTENT TO RESTRICT ACCESS

DANIEL J. TOAL, an attorney duly admitted to practice law before the
Courts of the State of New York, af?rms the following under penalties of perjury.
1. I am a member of the law ?rm of Paul, Weiss, Rifkind, Wharton 
Garrison LLP, counsel for Exxon Mobil Corporation (?ExxonMobil?).
2. On May 19, 2017, my firm, on behalf of ExxonMobil, electronically filed
placeholders for documents that ExxonMobil wishes to have permanently sealed.
3. Speci?cally, placeholders for certain documents were ?led publicly on
NYSCEF. These documents are:
a. Exxon Mobil Corporation?s Brief in Support of its Motion to Quash

and for a Protective Order (N YSCEF No. 130);

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INDEX NO. 451962/2016
NYSCEF DOC. NO. 162 RECEIVED NYSCEF: 05/19/2017

b. The Af?rmation of Justin Anderson in Support of Exxon Mobil
Corporation?s Motion to Quash and for a Protective Order (N YSCEF
No. 132)

c. The Af?rmation of Good Faith (N YSCEF No. 131)

d. Exhibit to the Af?rmation of Justin Anderson in Support of Exxon
Mobil Corporation?s Motion to Quash and for a Protective Order,
which is a letter, dated May 3, 2017, from John Oleske to Michele
Hirshman, Theodore Wells, and Daniel Toal (N YSCEF No. 156);

e. Exhibit to the Af?rmation of Justin Anderson in Support of Exxon
Mobil Corporation?s Motion to Quash and for a Protective Order,
which is a subpoena dated May 8, 2017 (NYSCEF No. 158);

f. Exhibit to the Af?rmation of Justin Anderson in Support of Exxon
Mobil Corporation?s Motion to Quash and for a Protective Order,
which is a subpoena dated May 8, 2017 (NYSCEF N0. 159);

g. Exhibit to the Af?rmation of Justin Anderson in Support of Exxon
Mobil Corporation?s Motion to Quash and for a Protective Order,
which is a subpoena dated May 8, 2017 (NYSCEF No. 160);

h. Exhibit to the Af?rmation of Justin Anderson in Support of Exxon
Mobil Corporation?s Motion to Quash and for a Protective Order
(NYSCEF No. 161).

4. The remaining documents ExxonMobil ?led on May 19, 2017 were

publicly ?led on NYSCEF.

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INDEX NO. 451962/2016
NYSCEF DOC. NO. 162 RECEIVED NYSCEF: 05/19/2017

5. I respectfully request that the Clerk permit the documents listed above to
be ?led as restricted from public view for a period of 10 days.

6. To further comply with the e-?ling protocol I will move by Order to Show
Cause or Proposed Stipulation to Be So Ordered to have these documents ?led under seal
and permanently removed from public View within 10 days of ?ling this af?rmation. I
understand that if I comply by ?ling an Order to Show Cause or Proposed Stipulation to

Be So Ordered I will be given an additional 14 days of restricted status.

Dated: New York, New York
May 19, 2017

Maya/??

DanielAI/Toal

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