Court filing
Joint MOTION for extension of time until… — Federal Reserve Bank of San Francisco v. Benworth Capital… (Dkt. 154)
No. 3:23-cv-01034-GMM · Doc. 154 · Docket on CourtListener
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Case 3:23-cv-01034-GMM Document 154 Filed 08/19/24 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF PUERTO RICO
OTO ANALYTICS, LLC,
Plaintiff,
v. 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,
v.
OTO ANALYTICS, LLC; BENWORTH
CAPITAL PARTNERS PR, LLC;
BENWORTH CAPITAL PARTNERS,
LLC; BERNARDO NAVARRO and
CLAUDIA NAVARRO,
Defendants in Intervention.
JOINT MOTION FOR EXTENSION OF TIME TO
ANSWER PLAINTIFF’S DISCOVERY REQUESTS
TO THE HONORABLE COURT:
COME NOW defendants Benworth Capital Partners PR, LLC (“Benworth PR”),
Benworth Capital Partners, LLC (“Benworth FL”), and Bernardo and Claudia Navarro (“Mr. and
Mrs. Navarro,” jointly with Benworth PR and Benworth FL, the “Defendants”), through the
undersigned counsel, and respectfully state and pray as follows:
1. On July 19, 2024, plaintiff Oto Analytics, LLC (“Plaintiff”) notified each of the
Case 3:23-cv-01034-GMM Document 154 Filed 08/19/24 Page 2 of 4
Joint Motion for Extension of Time to Answer Plaintiff’s Discovery Requests
Oto Analytics, LLC v. Benworth Capital Partners PR LLC, et al.
Civil No. 23-01034 (GMM)
Page 2 of 4
Defendants with a First Set of Interrogatories and a Request for Production of Documents
(“Discovery Requests”), to be answered within thirty (30) days, or by today, August 19, 2024.
2. To date, the Defendants have been working in identifying any relevant and
responsive information and/or documents, as well as working on the answers and objections to the
discovery requests while simultaneously preparing their respective answers to the Amended
Complaint, which were also due today, August 19th. However, despite the best efforts to complete
this process by today’s deadline, additional time is needed to finalize the investigation and draft
the answers and objections to the Discovery Requests and secure approval to execute the same.
3. To that end, on August 16, 2024, the Defendants reached out to Plaintiff requesting
a good-faith extension of time of thirty (30) additional days, or until September 18th, to submit
their answers to the Discovery Requests. However, today, August 19th, the Plaintiff rejected the
extension requested by Defendants before the deadline and, instead, offered a mere two-day
extension to respond to the documents requests and one week to answer the interrogatories on the
condition that the Defendants agree to answer the interrogatories and waive any objections to them.
Plaintiff’s proposition is simply unreasonable and not feasible for the Defendants.
4. The Defendants very respectfully inform this Honorable Court that the 30-day
extension that was requested in good faith to Plaintiff is indispensable to complete their efforts in
compiling the relevant and responsive information and documents and developing the responses
and objections to the Discovery Requests, and therefore respectfully request that the Court allow
such 30-day extension of time, until September 18, 2024, to do so.
5. The extension requested herein is sought in good faith, within the original deadline
to respond, and will not cause undue delay in the instant proceedings or cause any prejudice,
considering that the responses to the Discovery Requests would be submitted a month before the
Case 3:23-cv-01034-GMM Document 154 Filed 08/19/24 Page 3 of 4
Joint Motion for Extension of Time to Answer Plaintiff’s Discovery Requests
Oto Analytics, LLC v. Benworth Capital Partners PR LLC, et al.
Civil No. 23-01034 (GMM)
Page 3 of 4
deadline for substantial completion of document discovery under the Proposed Scheduling Order
(D.E. 122). Moreover, Plaintiff-Intervenor just filed a request to consolidate this case with the case
styled Federal Reserve Bank of San Francisco v. Benworth Capital Partners LLC, et al., Civil No.
24-01313 (GMM), to which Plaintiff has already expressed its consent and the Defendants have
indicated they will not oppose. If that motion is granted, it is likely to require new proposed case
management deadlines, including the extension of the discovery deadline.
WHEREFORE, the Defendants respectfully request that this Honorable Court grant the
instant joint motion and, consequently, allow a 30-day extension of time, until September 18, 2024,
for the Defendants to notify their answers to Plaintiff’s Discovery Requests.
CERTIFICATE OF SERVICE: We hereby certify that on this same date the foregoing
motion was filed with the Clerk of the Court using the CM/ECF system, which will send
notification of such filing to all attorneys and participants of record.
RESPECTFULLY SUBMITTED.
In San Juan, Puerto Rico, on this 19th day of August 19, 2024.
[SIGNATURE PAGE FOLLOWS]
Case 3:23-cv-01034-GMM Document 154 Filed 08/19/24 Page 4 of 4
Joint Motion for Extension of Time to Answer Plaintiff’s Discovery Requests
Oto Analytics, LLC v. Benworth Capital Partners PR LLC, et al.
Civil No. 23-01034 (GMM)
Page 4 of 4
PO Box 195168
San Juan, PR 00919-5168
Tel.: 787.766.7000
Fax: 787.766.7001
s/ Roberto A. Cámara-Fuertes
Roberto A. Cámara-Fuertes
USDC-PR 219002
rcamara@ferraiuoli.com
s/ Jaime A. Torrens-Dávila
Jaime A. Torrens-Dávila
USDC-PR 223810
jtorrens@ferraiuoli.com
s/ Mónica Ramos Benítez
Mónica Ramos-Benítez
USDC-PR 308405
mramos@ferraiuoli.com
Counsel for Benworth Capital Partners, LLC and Bernardo Navarro
CASELLAS ALCOVER & BURGOS PSC
PO Box 364924
San Juan, PR 00936-4924
Tel. (787) 756-1400
Fax. (787) 756-1401
/s/ Ricardo F. Casellas
USDC-PR Bar No. 203114
rcasellas@cabprlaw.com
/s/ Carla S. Loubriel Carrión
USDC-PR Bar No. 227509
cloubriel@cabprlaw.com
Counsel for Benworth Capital Partners PR, LLC and Claudia Navarro
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