# Todd J. Guerrero Affiant who signed the August 7, 2025 "Affidavit in Support of Trade Secret/Confidential Business Information" submitted with [[GROOT LLC]]'s air construction permit application for the West Memphis / Project Pyramid data center. He swears the affidavit "on behalf of Groot LLC," in Hennepin County, Minnesota — but the affidavit itself states Groot "currently has no employees," so his own employment relationship to Groot or its "affiliated companies" is not established in the record. ## Role and affiliations - Signed for Groot LLC; sworn before Minnesota notary Debra J. Richardson (commission expires Jan 31, 2030). - Employer/title not stated in the production; Minnesota domicile. ## Appearances in the corpus - [[Groot Redacted Air-Permit Application and Trade-Secret Affidavit]] — affiant; claims trade-secret protection over the generators' make/model/manufacturer, capacity/efficiency, and total number, citing *Wal-Mart Stores v. P.O. Market* and agreeing "to act as an indispensable party." ## Notes - His Minnesota location is a thread worth pulling on for the [[GROOT LLC]] / affiliated-company structure; not pursued here.