MOTION Submitting Certified Translations, Motion In… — Oto Analytics, LLC v. Benworth Capital Partners PR LLC (Dkt. 51)

Summary

Motion submitting translations and in compliance with Local Civil Rule 5(c), filed 04/26/23 as Document 51 in Oto Analytics, LLC v. Benworth Capital Partners PR LLC, Civil No. 23-1034, in the U.S. District Court for the District of Puerto Rico. Benworth Capital Partners PR LLC, appearing specially without submitting to the Court's jurisdiction, files certified translations of Articles 298, 299 and 300 of the Puerto Rico Civil Code. It notes that the official translation of Sucesión Almazán v. López was already submitted by the plaintiff at D.E. 47-3 and 49-3. Benworth PR says it relied on these materials in its Motion to Dismiss or Stay Proceedings Pending the Outcome of Arbitration (D.E. 34). The motion is signed by Ricardo F. Casellas and Carla S. Loubriel Carrión.

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       Case 3:23-cv-01034-GMM            Document 51        Filed 04/26/23      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.



                         MOTION SUBMITTING TRANSLATIONS
                   AND IN COMPLIANCE WITH LOCAL CIVIL RULE 5(C)

TO THE HONORABLE COURT:

       COMES NOW, Defendant Benworth Capital Partners PR LLC (“Benworth PR”), specially

appears without submitting to the Court’s jurisdiction, through the undersigned counsel, and

respectfully submits, as exhibits to this motion, certified translations of Articles 298, 299 and 300

of the Puerto Rico Civil Code, P.R. Laws Ann. tit. 31 §§ 6231, 6232 & 6233.

       The official translation of Sucesión Almazán v. López, 20 P.R. Dec. 537 (1914), which

Benworth PR had sought from the Supreme Court of Puerto Rico, has already been submitted to

the record by Plaintiff at D.E. 47-3 and 49-3.

       These materials were relied upon by Benworth PR in its “Motion to Dismiss or Stay

Proceedings Pending the Outcome of Arbitration” (D.E. 34).

       WHEREFORE, Benworth PR requests that the Court take notice of the above and deem

it in compliance with Local Rule 5(c).

       RESPECTFULLY SUBMITTED.
       Case 3:23-cv-01034-GMM          Document 51       Filed 04/26/23     Page 2 of 2




       In San Juan, Puerto Rico, today April 26, 2023.

       CERTIFICATION: The undersigned certify that this document was filed on this date with

the Clerk of Court using the CM/ECF system, which will serve notice on all attorneys of record.

                                            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




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