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MOTION for Leave to File Document a Reply… — Federal Reserve Bank of San Francisco v. Benworth Capital… (Dkt. 112)
No. 3:23-cv-01034-GMM · Doc. 112 · Docket on CourtListener
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Case 3:23-cv-01034-GMM Document 112 Filed 06/17/24 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF PUERTO RICO
OTO ANALYTICS, LLC, §
§
Plaintiff, §
§
v. § Civil Action No. 23-01034
§
BENWORTH CAPITAL PARTNERS PR §
LLC, BENWORTH CAPITAL PARTNERS §
LLC, BERNARDO NAVARRO and §
CLAUDIA NAVARRO, §
§
Defendants.
PLAINTIFF OTO ANALYTICS, LLC’S
MOTION FOR LEAVE TO FILE A REPLY IN SUPPORT OF ITS NOTICE OF
CONCLUSION OF ARBITRATION AND MOTION TO LIFT STAY
Plaintiff Womply, by and through its undersigned counsel, respectfully submits this
Motion For Leave To File A Reply to Defendants’ Joint Opposition to Plaintiff’s Notice of
Conclusion of Arbitration and Motion to Lift Stay (“Opposition”; ECF No. 111).1
1. On June 12, 2024, Womply filed its Notice of Conclusion of Arbitration and Motion
to Lift Stay.
2. On June 13, 2024, Defendants filed their Opposition to Womply’s Motion.
3. Pursuant to Local Rule 7(c), with leave of this Court, Womply has until June 20,
2024, to file a Reply brief.
4. In its proposed Reply, which is attached as Exhibit 1, Womply responds to
Defendants’ new arguments in the Opposition and Defendants’ characterizations of Womply’s
arguments that are incorrect and require clarification. This includes, without limitation,
1
Capitalized terms have the same meanings as in Womply’s Motion to Lift Stay (“Motion”; ECF
No. 109) unless otherwise indicated.
Case 3:23-cv-01034-GMM Document 112 Filed 06/17/24 Page 2 of 3
Defendants’ new assertions that they intend to challenge the Final Award both under JAMS rules
and Federal Law, and erroneous caselaw included in support of their arguments.
5. The undersigned certify that this request does not have a dilatory intent, and is
sought in the interest of justice, to ensure this Court has complete briefing on the matters before it.
WHEREFORE, Womply respectfully requests that the Court grant it leave to file a reply
in support of its Motion by no later than June 20, 2024.
Dated: June 17, 2024
Of Counsel
Willkie Farr & Gallagher LLP Respectfully submitted,
By: /s/ Alexander L. Cheney By: /s/ Alejandro J. Cepeda Diaz
Alexander L. Cheney (admitted pro hac vice) Alejandro J. Cepeda Diaz
333 Bush St USDC-PR 222110
San Francisco, CA 94104 McConnell Valdés LLC
(415) 858-7400 270 Muñoz Rivera Ave.
acheney@willkie.com Hato Rey PR 00918
Tel: (787) 250-5637
Joshua S. Levy (admitted pro hac vice) Email: ajc@mcvpr.com
1875 K Street, N.W.
Washington, D.C. 20006
(202) 303-1000 Attorneys for Plaintiff Oto Analytics, LLC
jlevy@willkie.com
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Case 3:23-cv-01034-GMM Document 112 Filed 06/17/24 Page 3 of 3
CERTIFICATE OF SERVICE
The undersigned certifies that on June 17, 2024, the foregoing document was filed with the
Clerk of the Court using CM/ECF, which sent notices to all parties receiving notifications through
the CM/ECF system.
Dated: June 17, 2024 By: /s/ Alejandro J. Cepeda Diaz
Attorney for Plaintiff Oto Analytics, LLC
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