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Notice of Special Appearance, MOTION for… — Federal Reserve Bank of San Francisco v. Benworth Capital… (Dkt. 25)

No. 3:23-cv-01034-GMM · Doc. 25 · Docket on CourtListener

Summary

A notice of special appearance and motion under Local Civil Rule 6 for extension of time, filed February 28, 2023 as Doc. 25 by defendant Claudia Navarro in Oto Analytics, LLC v. Benworth Capital Partners PR LLC, et al., No. 3:23-cv-01034-GMM, in the U.S. District Court for the District of Puerto Rico. Appearing without submitting to the Court's jurisdiction, Ms. Navarro gives notice of newly retained counsel. The motion states that the plaintiff's affidavit of service (Docket No. 24) indicates service on February 7, 2023 through an office administrator, making an answer due February 28, 2023 if service was proper. It asks for a first 30-day extension to answer or otherwise plead, to expire on March 30, 2023. The two-page filing is signed by counsel from Casellas Alcover & Burgos PSC.

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       Case 3:23-cv-01034-GMM              Document 25       Filed 02/28/23        Page 1 of 2




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



OTO ANALYTICS, LLC,

      Plaintiff,

                           vs.                              Civil No. 23-1034

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

      Defendants.



              NOTICE OF SPECIAL APPEARANCE AND MOTION UNDER
                  LOCAL CIVIL RULE 6 FOR EXTENSION OF TIME
               TO ANSWER THE COMPLAINT OR OTHERWISE PLEAD

TO THE HONORABLE COURT:

       NOW COMES defendant Claudia Navarro, by special appearance and without submitting

to the jurisdiction of this Court, and respectfully states and prays as follows:

       1.          Notice is hereby given that the appearing defendant will be represented by the

undersigned attorneys who were recently retained to assume their legal representation.

       2.          Yesterday, Plaintiff filed copy of an Affidavit of Service indicating that Mrs.

Navarro was served with summons on February 7, 2023, through Ms. Alondra Goméz, an Office

Administrator who purportedly stated that she was authorized to accept service on behalf of Mrs.

Navarro. (Docket No. 24.)

       3.          Consequently, if properly served, Mrs. Navarro is required to answer or otherwise

defend against the Complaint by today, February 28, 2023.
       Case 3:23-cv-01034-GMM            Document 25        Filed 02/28/23      Page 2 of 2




        4.      The appearing defendant and their counsel inform the court that they need

additional time to investigate the pertinent facts and issues of law, so they may properly answer

the Complaint or otherwise respond. Therefore, Ms. Navarro requests, under Local Civil Rule 6

(authorizing the Clerk of the Court to grant a first extension of time not to exceed 30 days without

further direction of the Court), a 30-day extension of time to answer the Complaint or otherwise

respond, to expire on March 30, 2023.

        5.      If granted, this extension of time would not cause undue prejudice or delay, and it

is sought in the interest of justice.

        WHEREFORE, the appearing defendant request the court to: (i) take notice of who will

represent it; and (ii) grant a first 30-day extension of time under L.Cv.R. 6 to answer the Complaint

or otherwise plead to expire on March 30, 2023.

        RESPECTFULLY SUBMITTED.

        In San Juan, Puerto Rico, today February 28, 2023.

        CERTIFICATION: The undersigned counsel hereby certify that the instant document has

been filed with the Court’s CM/ ECF System, which will simultaneously serve notice on all

counsel of record to their registered email addresses.

                                              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/ Ricardo F. Casellas
                                              USDC-PR Bar No. 203114

                                              /s/ Carla S. Loubriel Carrión
                                              USDC-PR Bar No. 227509




                                                 -2-

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