MOTION to Restrict Document filed by Alejandro… — Federal Reserve Bank of San Francisco v. Benworth Capital… (Dkt. 48)

Summary

A motion to restrict filed April 24, 2023 as Doc. 48 by plaintiff Oto Analytics, LLC (d/b/a Womply) 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. Citing Standing Order No. 9 and the Court's March 31, 2023 Order (ECF No. 38), it seeks leave to file its unredacted Consolidated Opposition to the Benworth defendants' motions to dismiss, with exhibits, restricted to viewing by the parties, and to file the Opposition publicly with redactions. The motion states that on March 31, 2023 the Court granted the same treatment for Womply's Complaint and that the Opposition cites and quotes material redacted in the public Complaint. The three-page filing is signed by counsel for the plaintiff and ends with a certificate of service.

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         Case 3:23-cv-01034-GMM Document 48 Filed 04/24/23 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.


 MOTION TO RESTRICT WOMPLY’S OPPOSITION TO DEFENDANTS’ MOTIONS
                          TO DISMISS

       Pursuant to Standing Order No. 9 for the United District Court for the District of Puerto

Rico, and in accordance with this Court’s March 31, 2023 Order (“Order”; ECF No. 38), Plaintiff

Oto Analytics, LLC (f/k/a Oto Analytics, Inc. d/b/a Womply) (“Womply”), by and through its

undersigned counsel, seeks leave to file its unredacted Consolidated Opposition to Defendants

Benworth Capital Partners PR LLC’s and Benworth Capital Partners LLC’s Motions to Dismiss

(“Opposition”) and exhibits in the above-captioned action restricted to viewing by the parties and

to publicly file its Opposition and exhibits with redactions.

       On March 31, 2023, this Court granted Womply’s Motion to Restrict its Complaint to

viewing by the parties and publicly file its Complaint and exhibits with redactions. (Order at 1.)

Womply’s Opposition cites and quotes material that is redacted in its publicly filed Complaint.

Accordingly, Womply requests leave to redact such material in its publicly filed Opposition.
        Case 3:23-cv-01034-GMM Document 48 Filed 04/24/23 Page 2 of 3




Dated: April 24, 2023


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
One Front Street                              USDC-PR 222110
San Francisco, CA 94111                       McConnell Valdés LLC
(415) 858-7400                                270 Muñoz Rivera Ave.
acheney@willkie.com                           Hato Rey PR 00918
                                              Tel: (787) 250-5637
Stuart R. Lombardi (admitted pro hac vice)    Email: ajc@mcvpr.com
Willkie Farr & Gallagher LLP
787 7th Avenue
New York, NY 10019                            Attorneys for Plaintiff Oto Analytics, LLC
(212) 728-8000
slombardi@willkie.com

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 48 Filed 04/24/23 Page 3 of 3




                               CERTIFICATE OF SERVICE

       The undersigned certifies that on April 24, 2023, 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: April 24, 2023                              By: /s/ Alejandro J. Cepeda Diaz

                                                   Attorney for Plaintiff Oto Analytics, LLC




                                             -3-


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