Exhibit B - Declaration of Claudia Navarro — Oto Analytics, LLC v. Benworth Capital Partners PR LLC (Dkt. 37.2)

Summary

Exhibit B, a declaration of Claudia Navarro under penalty of perjury, filed 03/30/23 as Document 37-2 in Oto Analytics, LLC v. Benworth Capital Partners PR LLC, Benworth Capital Partners LLC, Bernardo Navarro and Claudia Navarro, Civil No. 23-1034, District of Puerto Rico. It responds to an affidavit of service in which Womply asserted she was served through an office administrator at Benworth Capital Partners PR LLC's San Juan office. Navarro states she has not been served with process personally, that the address is not her residence or place of abode, and that the office administrator was never authorized to accept service on her behalf. Advocacy document; claims are the declarant's.

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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.
DECLARATION OF MRS. CLAUDIA NAVARRO
I, Claudia Navarro, of legal age, married, businesswoman, and resident of Dorado, Puerto
Rico, declare under penalty of perjury as follows:
1. 
My name and personal circumstances are as stated above.
2. 
OnFebruary 2T,z}z3,plaintiffOtoAnalytics,LLCflklaOto Analytics, lnc.dlbla
Womply ("Womply") filed an Affidavit of Service in the captioned case asserting that I was
purportedly served on February 7 ,2023 by delivering the Summons and copy of the Complaint at
Benworth Capital Partners PR LLC, 954 Ave. Ponce de Le6n, Suite 205, San Juan, Puerto Rico
00907, through Ms. Alondra G6mez ("G6mez"), identified by the process server as an "Office
Aadministrator," who purportedly stated that she was authorized to accept service on my behalf.
lD.E.24).
3. 
I have not been served with process personally in this case.
4. 
The address 954 Ave. Ponce de Le6n, Suite 205, San Juan, Puerto Rico 00907 is
not my residence or place of abode.
5. 
Ms. G6mez is not now, was not, nor has she ever been an agent authorized by me
Case 3:23-cv-01034-GMM     Document 37-2     Filed 03/30/23     Page 1 of 2

to receive service of process on my behalf.
6. 
At no time was Ms. G6rnez given any authority whatsoever by me to be served as
my agent, much less to accept service of process on my behalf.
Pursuant to 28 U.S.C. Q 1746,1 hereby declare under penalty of perjury that the foregoing
is true and correct to the best of my knowledge and information.
Executed in Dorado, Puerto Rico, this 3Oth day of March,
Claudia Navarro
2
Case 3:23-cv-01034-GMM     Document 37-2     Filed 03/30/23     Page 2 of 2

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