MOTION to Restrict Document Womply's Motion… — Federal Reserve Bank of San Francisco v. Benworth Capital… (Dkt. 75)

Summary

A Motion to Restrict Womply's Motion for Leave to Serve by Publication filed July 13, 2023 as Doc. 75 by plaintiff Oto Analytics, LLC (d/b/a Womply) in Oto Analytics, LLC v. Benworth Capital Partners PR LLC, et al., Civil Action No. 23-01034, in the U.S. District Court for the District of Puerto Rico. Citing Standing Order No. 9 and the Court's earlier orders, it asks to file its unredacted Motion for Leave to Serve by Publication on Bernardo Navarro and Claudia Navarro restricted to the parties, with a redacted public version. It seeks to redact three categories: personal identifying and financial information under Local Civil Rule 5.2, material already redacted in its public Complaint, and material Benworth Capital Partners LLC designated Confidential in a private JAMS arbitration. The three-page motion is signed by Alexander L. Cheney and Alejandro J. Cepeda Diaz.

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       Case 3:23-cv-01034-GMM             Document 75       Filed 07/13/23     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 MOTION FOR LEAVE TO SERVE BY
 PUBLICATION DEFENDANTS BERNARDO NAVARRO AND CLAUDIA NAVARRO

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

Rico, and in accordance with this this Court’s March 31, 2023 Order (ECF No. 38), April 24, 2023

Order (ECF No. 50), May 3, 2023 Order (ECF No. 58), June 13, 2023 Order (ECF Nos. 68, 72;

together, the “Orders”), 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 Motion for

Leave to Serve by Publication (the “Motion”) Defendants Bernardo Navarro and Claudio Navarro

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

and to publicly file its Motion and exhibits with redactions.

          Womply seeks to redact three categories of information. First, Pursuant to Local Civil

Rule 5.2, Womply seeks to redact personally identifying information and sensitive financial

information of the Navarros and their family members, including home addresses, license plate

information, social security numbers, drivers’ licenses, bank account information, and credit

headers. This Court approved redacting much of this same information in its May 3 and June 13

Orders.
       Case 3:23-cv-01034-GMM            Document 75        Filed 07/13/23      Page 2 of 3




       Second, Womply seeks to redact in its Motion and accompanying exhibits material that is

redacted in its publicly filed Complaint and its exhibits, which this Court approved in its March 31,

April 24, and May 3 Orders.

       Third, Womply’s Motion and exhibits include one document and two deposition

transcripts that Benworth Capital Partners LLC (“Benworth FL”) designated as “Confidential”

pursuant to a protective order issued by the arbitrator in a private JAMS arbitration between

Womply and Benworth FL (the “Arbitration”). Womply’s Motion and exhibits also include two

transcripts from the Arbitration, which include discussions of material Benworth FL designated as

“Confidential.”   Womply seeks to redact this material in accordance with Benworth FL’s

confidentiality designations.



Dated: July 13, 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
Joshua S. Levy (admitted pro hac vice)           Email: ajc@mcvpr.com
1875 K Street, N.W.
Washington, D.C. 20006
(202) 303-1000                                   Attorneys for Plaintiff Oto Analytics, LLC
jlevy@willkie.com




                                                -2-
       Case 3:23-cv-01034-GMM           Document 75       Filed 07/13/23      Page 3 of 3




                                CERTIFICATE OF SERVICE

       The undersigned certifies that on July 13, 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: July 13, 2023                                By: /s/ Alejandro J. Cepeda Diaz

                                                    Attorney for Plaintiff Oto Analytics, LLC




                                              -3-


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