Court filing
Joint MOTION for extension of time until… — Federal Reserve Bank of San Francisco v. Benworth Capital… (Dkt. 246)
No. 3:23-cv-01034-GMM · Doc. 246 · Docket on CourtListener
Full text
Case 3:23-cv-01034-GMM Document 246 Filed 05/27/25 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF PUERTO RICO
FEDERAL RESERVE BANK OF SAN Civil No. 23-01034 (GMM) cons.
FRANCISCO,
Civil No. 24-01313 (GMM)
Plaintiff
v.
OTO ANALYTICS, LLC; BENWORTH
CAPITAL PARTNERS PR, LLC;
BENWORTH CAPITAL PARTNERS, LLC;
BERNARDO NAVARRO and CLAUDIA
NAVARRO,
Defendants.
UNOPPOSED MOTION FOR EXTENSION OF TIME
TO COMPLY WITH THE COURT’S DISCOVERY ORDER [DE 245]
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” and, jointly with Benworth PR and Benworth FL, the “Defendants”), through the
undersigned counsel and pursuant to Local Rule 16(h)(i)(1), and respectfully request that the Court
extend the deadline for Defendants to comply with the Court’s Order on Plaintiff’s Motion to
Enforce Order at ECF No. 224 Granting Plaintiff-Intervenor Federal Reserve Bank of San
Francisco’s Motion to Compel Benworth’s Quickbooks Accounting Data (the “Order”):
1. On May 21, 2025, the Court entered the Order, ordering Defendants to provide
Plaintiff-Intervenor the Federal Reserve Bank of San Franisco (the “Reserve Bank”) with exported
data from their QuickBooks database for the period of January 1, 2020, to the present, by May 27,
2025. (See D.E. 245).
Case 3:23-cv-01034-GMM Document 246 Filed 05/27/25 Page 2 of 4
Unopposed Motion for Extension of Time to Comply with the Court’s Discovery Order (D.E. 245)
Civil No. 23-01034 (GMM) cons. 23-01313 (GMM)
Page 2 of 3
2. Due to technical issues out of their control, Defendants have not had access to their
servers, including the QuickBooks database, since May 18, 2025. Defendants immediately
engaged an IT firm to restore access, but the IT firm has stated that it will need another two weeks
to fully restore the servers.
3. Accordingly, Defendants respectfully request a 2-week extension, through June 10,
2025, to fully comply with the Court’s Order.
4. Counsel for Defendants initially raised the need for extension with counsel for the
Reserve Bank via email on May 23, 2025. Counsel for the parties conferred further via phone and
email on May 27, 2025. Counsel for the Reserve Bank represented that it will not oppose the
extension requested herein if Defendants agree to two conditions: (1) that Defendants attach to this
Motion a declaration, under penalty of perjury, by an individual at Benworth FL with personal
knowledge of the issue necessitating the extension that describes the issue and how it prevents
access to the QuickBooks data, and (2) to note on this Motion that, although Defendants are
seeking a two-week extension, Defendants agree to produce the data at the earliest possible date,
as soon as it is available.
5. Defendants agree to both conditions. But due to the nature of the issue necessitating
the extension, Defendants are unable to submit the declaration requested by the Reserve Bank with
the instant Motion. However, Defendants will file the requested declaration no later than
tomorrow, May 28, 2025, to which the Reserve Bank expressed no objection.
6. This motion is made in good faith to ensure compliance with the Court’s Order and
based on circumstances out of the Defendants’ control, and not for purposes of delaying the
proceedings. Granting this motion will not prejudice any party.
WHEREFORE, Defendants respectfully request that the Court grant this unopposed
Case 3:23-cv-01034-GMM Document 246 Filed 05/27/25 Page 3 of 4
Unopposed Motion for Extension of Time to Comply with the Court’s Discovery Order (D.E. 245)
Civil No. 23-01034 (GMM) cons. 23-01313 (GMM)
Page 3 of 4
motion and extend the deadline to comply with the Court’s Order at D.E. 245 to June 10, 2025.
CERTIFICATE OF SERVICE: We hereby certify that on this same date the foregoing
reply 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 May 27, 2025.
PO Box 195168
San Juan, PR 00919-5168
Tel.: 787.766.7000
Fax: 787.766.7001
s/ Roberto A. Cámara-Fuertes
USDC-PR 219002
rcamara@ferraiuoli.com
s/ Jaime A. Torrens-Dávila
USDC-PR 223810
jtorrens@ferraiuoli.com
s/ Mónica Ramos Benítez
USDC-PR 308405
mramos@ferraiuoli.com
KOZYAK TROPIN & THROCKMORTON
2525 Ponce de Leon Blvd., 9th Fl.
Miami, FL 33134
(305) 372-1800
Jorge L. Piedra (admitted pro hac vice)
jpiedra@kttlaw.com
Michael R. Lorigas (admitted pro hac vice)
mlorigas@kttlaw.com
Rasheed K. Nader (admitted pro hac vice)
rnader@kttlaw.com
Counsel for Benworth Capital Partners LLC and Bernardo Navarro
Case 3:23-cv-01034-GMM Document 246 Filed 05/27/25 Page 4 of 4
Unopposed Motion for Extension of Time to Comply with the Court’s Discovery Order (D.E. 245)
Civil No. 23-01034 (GMM) cons. 23-01313 (GMM)
Page 4 of 4
CASELLAS ALCOVER & BURGOS PSC
PO Box 364924
San Juan, PR 00936-4924
Tel. (787) 756-1400
Fax. (787) 756-1401
rcasellas@cabprlaw.com
cloubriel@cabprlaw.com
/s/ Carla S. Loubriel Carrión
USDC-PR Bar No. 227509
Ricardo F. Casellas
USDC-PR Bar No. 203114
Counsel for Benworth Capital Partners PR LLC and Claudia Navarro
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