MOTION for Extension of Time until September… — Federal Reserve Bank of San Francisco v. Benworth Capital… (Dkt. 147)

Summary

A Motion for Extension of Time to Answer or Otherwise Respond to the Complaint in Intervention, Document 147, stamped Filed 08/13/24, in OTO Analytics, LLC v. Benworth Capital Partners PR LLC, et al., Civil No. 23-01034 (GMM), in the District of Puerto Rico. Oto Analytics, LLC (called Womply) says the Federal Reserve Bank of San Francisco filed the Complaint in Intervention on August 2, 2024 (ECF No. 146) and that its response deadline expires August 23, 2024. It asks for an additional thirty days to investigate the allegations, to Monday, September 23, 2024, because the thirtieth day falls on a Sunday. The motion is signed by counsel and dated August 13, 2024.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

        Case 3:23-cv-01034-GMM              Document 147        Filed 08/13/24     Page 1 of 3



                            IN THE UNITED STATES DISTRICT COURT
                              FOR THE DISTRICT OF PUERTO RICO

OTO ANALYTICS, LLC,

        Plaintiff,

                             vs.                              Civil No. 23-01034 (GMM)

BENWORTH CAPITAL PARTNERS PR LLC,
BENWORTH CAPITAL PARTNERS LLC,
BERNARDO NAVARRO and CLAUDIA
NAVARRO,

        Defendants.

FEDERAL RESERVE BANK OF SAN
FRANCISCO,

        Plaintiff-Intervenor,

                             vs.

OTO ANALYTICS, LLC, BENWORTH CAPITAL
PARTNERS PR LLC, BENWORTH CAPITAL
PARTNERS LLC, BERNARDO NAVARRO and
CLAUDIA NAVARRO,

        Defendants in Intervention.
                  MOTION FOR EXTENSION OF TIME TO
    ANSWER OR OTHERWISE RESPOND TO THE COMPLAINT IN INTERVENTION

TO THE HONORABLE COURT:

         COMES NOW Plaintiff and Defendant in Intervention, Oto Analytics, LLC (“Womply”),

through the undersigned counsel, and respectfully requests an extension of time to file its answer

or otherwise respond to the Complaint in Intervention and in support therefore states and prays as

follows:

         1.          On August 2, 2024, the Federal Reserve Bank of San Francisco (“Intervenor”) filed

the Complaint in Intervention. (ECF No. 146.)

         2.          According to Federal Rule of Civil Procedure 12(a)(1)(A)(i), Womply’s deadline

to respond to the Complaint in Intervention or otherwise defend currently expires on August 23,

2024.
         Case 3:23-cv-01034-GMM             Document 147        Filed 08/13/24      Page 2 of 3



          3.       Womply and its attorneys are currently in the process of investigating Intervenor’s

   factual allegations and causes of action. To complete this investigation and responsibly prepare a

   responsive answer or otherwise respond to the Complaint in Intervention, Womply respectfully

   requests that the Court allow it an extension of time of an additional thirty days (30) days to answer

   or otherwise respond to the Complaint in Intervention. Because the thirtieth day is Sunday,

   September 22, 2024, Womply requests this extension to Monday, September 23, 2024, as allowed

   under Federal Rule of Civil Procedure 6(a)(1)(C).

          4.       This extension is sought in good faith and will not unreasonably delay the

   proceedings in this case.

                   WHEREFORE, Womply respectfully requests an extension of an additional thirty

   (30) days up to September 23, 2024, to answer or otherwise respond to the Complaint in

   Intervention.

Dated: August 13, 2024


Of Counsel

Willkie Farr & Gallagher LLP                       Respectfully submitted,

Alexander L. Cheney (admitted pro hac vice)        By: /s/Alejandro J. Cepeda Diaz
333 Bush St
San Francisco, CA 94104                            Alejandro J. Cepeda Diaz
(415) 858-7400                                     USDC-PR 222110
acheney@willkie.com                                McConnell Valdés LLC
                                                   270 Muñoz Rivera Ave.
Stuart R. Lombardi (admitted pro hac vice)         Hato Rey PR 00918
Willkie Farr & Gallagher LLP                       Tel: (787) 250-5637
787 7th Avenue                                     Email: ajc@mcvpr.com
New York, NY 10019
(212) 728-8000
slombardi@willkie.com                              Attorneys for Plaintiff Oto Analytics, LLC

Joshua S. Levy (admitted pro hac vice)
1875 K Street, N.W.
Washington, D.C. 20006
(202) 303-1000
jlevy@willkie.com


                                                   -2-
          Case 3:23-cv-01034-GMM          Document 147           Filed 08/13/24     Page 3 of 3



                                  CERTIFICATE OF SERVICE

       The undersigned certifies that on August 13, 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: August 13, 2024                                        By: /s/ Alejandro J. Cepeda Diaz

                                                       Attorney for Plaintiff Oto Analytics, LLC




                                                 -3-


File and source

File

gov.uscourts.prd.175040.147.0.pdf

Size

91,273 bytes

SHA-256

2d9cb0e75aaa9957e3c71a4cf7bdae0af266ae12da67a26d84c679989df5431e

Our copy

gov.uscourts.prd.175040.147.0.pdf

Original

PACER (login required)