Declaration of Alexander L Cheney in Support — Oto Analytics, LLC v. Benworth Capital Partners LLC (Dkt. 56-1, N.D. Cal. No. 3:24-cv-03975)

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A Declaration of Alexander L. Cheney in Support of Petitioner's Reply in Support of Motion to Confirm Arbitration Award and for Entry of Judgment, filed September 13, 2024 as Doc. 56-1 in Oto Analytics, LLC v. Benworth Capital Partners LLC, Case No. 3:24-cv-03975-AMO, in the U.S. District Court for the Northern District of California. Cheney, a partner at Willkie Farr & Gallagher LLP, counsel for Petitioner Oto Analytics, LLC, declares under 28 U.S.C. § 1746 and attaches three exhibits. They are excerpts from the transcript of closing arguments at a hearing dated June 29, 2023, Benworth's Motion to Disqualify William M. Manger, Jr., as Womply's Expert Witness dated January 25, 2023, and Womply's Opposition to Benworth's Motion to Stay the Arbitration dated September 14, 2023.

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DECLARATION OF ALEXANDER L. CHENEY IN SUPPORT OF PETITIONER’S REPLY IN SUPPORT OF 
MOTION TO CONFIRM ARBITRATION AWARD AND FOR ENTRY OF JUDGMENT 
CASE No. 3:24-cv-03975-AMO 
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UNITED STATES DISTRICT COURT 
NORTHERN DISTRICT OF CALIFORNIA 
SAN FRANCISCO DIVISION 
 
 
WILLKIE FARR & GALLAGHER LLP 
Alexander L. Cheney (SBN 302157) 
acheney@willkie.com 
333 Bush Street 
San Francisco, CA 94104 
Telephone: 
(415) 858-7400 
 
Attorney for Petitioner 
Oto Analytics, LLC 
OTO ANALYTICS, LLC, 
Petitioner, 
v. 
BENWORTH CAPITAL PARTNERS LLC, 
Respondent. 
 Case No. 3:24-cv-03975-AMO 
 
 
DECLARATION OF ALEXANDER L. 
CHENEY IN SUPPORT OF 
PETITIONER’S REPLY IN SUPPORT OF 
MOTION TO CONFIRM ARBITRATION 
AWARD AND FOR ENTRY OF 
JUDGMENT 
 
 
Case 4:24-cv-03975-AMO     Document 56-1     Filed 09/13/24     Page 1 of 2

 
 
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DECLARATION OF ALEXANDER L. CHENEY IN SUPPORT OF PETITIONER’S REPLY IN SUPPORT OF 
MOTION TO CONFIRM ARBITRATION AWARD AND FOR ENTRY OF JUDGMENT 
CASE No. 3:24-cv-03975-AMO 
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I, Alexander L. Cheney, pursuant to 28 U.S.C. § 1746, declare as follows: 
1. 
I am a member in good standing of the bars of California and New York.  I am 
admitted to practice in the United States District Court for the Northern District of California.  I 
am a partner at Willkie Farr & Gallagher LLP, counsel for Petitioner Oto Analytics, LLC (f/k/a 
Oto Analytics, Inc. d/b/a Womply) (“Womply”).  
2. 
I respectfully submit this declaration to provide this Court with documents cited in 
Womply’s Reply in Support of the Motion to Confirm the Arbitration Award and for Entry of 
Judgment, as permitted by Local Civil Rule 7-3(c).  This declaration is based on my personal 
knowledge or information provided to me.   
3. 
A true and correct copy of excerpts from the transcript of the closing arguments 
presented during the hearing dated June 29, 2023 is attached hereto as Exhibit 1. 
4. 
A true and correct copy of Benworth’s Motion to Disqualify William M. Manger, 
Jr., as Womply’s Expert Witness, dated January 25, 2023 is attached hereto as Exhibit 2. 
5. 
A true and correct copy of Womply’s Opposition to Benworth’s Motion to Stay the 
Arbitration, dated September 14, 2023 is attached hereto as Exhibit 3. 
 
I declare under the penalty of perjury under the laws of the State of California and the United 
States that the foregoing is true and correct. 
 
Executed at San Francisco, California on this 13 day of September, 2024. 
 
 
Dated: September 13, 2024 
WILLKIE FARR & GALLAGHER LLP 
 
By: /s/ Alexander L. Cheney 
 
Alexander L. Cheney 
 
Attorney for Petitioner 
Oto Analytics, LLC 
Case 4:24-cv-03975-AMO     Document 56-1     Filed 09/13/24     Page 2 of 2

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