Court filing
Exhibit 10 — Oto Analytics, LLC v. Benworth Capital Partners PR LLC (Dkt. 52.11)
Record facts
| Court | U.S. District Court for the District of Puerto Rico |
|---|---|
| Filed | 2023-04-27 |
U.S. District Court for the District of Puerto Rico · No. 3:23-cv-01034-GMM · Doc. 52-11 · 2023-04-27 · Docket on CourtListener
Summary
Exhibit 10, filed April 27, 2023 as Doc. 52-11 in Oto Analytics, LLC v. Benworth Capital Partners PR LLC, No. 3:23-cv-01034-GMM, in the U.S. District Court for the District of Puerto Rico. It is a five-page chain of emails between counsel at Willkie Farr & Gallagher LLP and Kozyak Tropin & Throckmorton under the subject line Womply v. Benworth (D.P.R.). In an April 5, 2023 email, Joshua S. Levy proposes that the parties stay the litigation pending an interim decision by the Arbitrator, that defendants withdraw their motions to dismiss without prejudice, and that counsel accept service for two individuals. Opposing counsel agrees the same day to a 2-week extension of the deadline to respond to the motions to dismiss. In an April 13, 2023 reply, Jorge L. Piedra states that his clients do not agree to any of the three parts of the proposal.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Full text
EXHIBIT 10 Case 3:23-cv-01034-GMM Document 52-11 Filed 04/27/23 Page 1 of 5 From: Jorge L. Piedra <jpiedra@kttlaw.com> Sent: Thursday, April 13, 2023 1:13 PM To: Levy, Joshua S. <JLevy@willkie.com>; Corali Lopez-Castro <clc@kttlaw.com> Cc: Michael Lorigas <mlorigas@kttlaw.com>; Cheney, Alexander <ACheney@willkie.com>; Lombardi, Stuart <slombardi@willkie.com>; Camara Fuertes, Roberto <rcamara@ferraiuoli.com>; Ricardo Casellas <RCasellas@cabprlaw.com>; Carla S. Loubriel Carrión <CLoubriel@cabprlaw.com>; Monica Ramos Benitez <mramos@ferraiuoli.com> Subject: RE: Womply v. Benworth (D.P.R.) *** EXTERNAL EMAIL *** Josh, Benworth, Benworth PR, and Mr. and Mrs. Navarro do not agree to any of the three parts of your proposal below. Sincerely, Jorge L. Piedra, Esq. | Partner KOZYAK TROPIN & THROCKMORTON 2525 Ponce de Leon Blvd., FL 9, Miami, FL 33134 Phone 305.372.1800 | Direct 305.728.2975 | Email jpiedra@kttlaw.com From: Jorge L. Piedra Sent: Wednesday, April 5, 2023 3:23 PM To: Levy, Joshua S. <JLevy@willkie.com>; Corali Lopez-Castro <clc@kttlaw.com> Cc: Michael Lorigas <mlorigas@kttlaw.com>; Cheney, Alexander <ACheney@willkie.com>; Lombardi, Stuart <slombardi@willkie.com> Subject: RE: Womply v. Benworth (D.P.R.) Case 3:23-cv-01034-GMM Document 52-11 Filed 04/27/23 Page 2 of 5 CAUTION: [This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.] We will do so at our convenience. Jorge L. Piedra, Esq. | Partner KOZYAK TROPIN & THROCKMORTON 2525 Ponce de Leon Blvd, FL 9, Miami, FL 33134 Phone 305.372.1800 | Direct 305.728.2975 | Email jpiedra@kttlaw.com From: Levy, Joshua S. <JLevy@willkie.com> Sent: Wednesday, April 5, 2023 3:15 PM To: Corali Lopez-Castro <clc@kttlaw.com> Cc: Jorge L. Piedra <jpiedra@kttlaw.com>; Michael Lorigas <mlorigas@kttlaw.com>; Cheney, Alexander <ACheney@willkie.com>; Lombardi, Stuart <slombardi@willkie.com> Subject: RE: Womply v. Benworth (D.P.R.) Thanks Cori, we really appreciate it. Would you mind also reaching out to counsel for Benworth Puerto Rico to get back to us as well? Regards, Josh Joshua S. Levy Willkie Farr & Gallagher LLP 1875 K Street, N.W. | Washington, DC 20006-1238 Direct: +1 202 303 1147 | Mobile: +1 516 680 5751 jlevy@willkie.com | vCard | www.willkie.com bio From: Corali Lopez-Castro <clc@kttlaw.com> Sent: Wednesday, April 5, 2023 3:02 PM To: Levy, Joshua S. <JLevy@willkie.com> Cc: Jorge L. Piedra <jpiedra@kttlaw.com>; Michael Lorigas <mlorigas@kttlaw.com>; Cheney, Alexander <ACheney@willkie.com>; Lombardi, Stuart <slombardi@willkie.com> Subject: Re: Womply v. Benworth (D.P.R.) *** EXTERNAL EMAIL *** Josh I light off deadline to respond to motions to dismiss and upcoming holidays (Passover starting tonight), we agree to an extend the deadline to respond to the motions to dismiss for 2 weeks. I hope this helps. We will respond on other requests next week. Cori Case 3:23-cv-01034-GMM Document 52-11 Filed 04/27/23 Page 3 of 5 CAUTION: [This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.] Corali Lopez-Castro Kozyak Tropin & Throckmorton, LLP This message may contain privileged or confidential information. If you are not the intended recipient, please immediately delete this message. On Apr 5, 2023, at 11:48 AM, Levy, Joshua S. <JLevy@willkie.com> wrote: Cori, We’re reaching out about the pending motions to dismiss in the District of Puerto Rico litigation. As your team has noted in the Arbitration, the Easter and Passover holidays are coming up this week, which affects availability to work on briefing. We also think that these motions, which focus on the timing of the arbitral decision and service of process, can be resolved among the parties. We propose that (1) all parties agree to stay the litigation pending an interim decision by the Arbitrator in the ongoing Arbitration (i.e., a decision on the merits of the arbitration hearing, not a final determination of attorneys’ fees and costs), (2) defendants withdraw their motions to dismiss without prejudice, and (3) counsel accept service for Bernie and Claudia Navarro, which will avoid them having process servers serve them personally. Our local Puerto Rico counsel has reached out to Defendants’ Puerto Rico counsel about this but has not yet heard back. In light of the upcoming holidays and briefing deadlines, we ask that you please get back to us by the end of the day today. I’m happy to discuss by phone if that would be helpful. Regards, Josh Joshua S. Levy Willkie Farr & Gallagher LLP 1875 K Street, N.W. | Washington, DC 20006-1238 Direct: +1 202 303 1147 | Mobile: +1 516 680 5751 jlevy@willkie.com | vCard | www.willkie.com bio Important Notice: This email message is intended to be received only by persons entitled to receive the confidential information it may contain. Email messages to clients of Willkie Farr & Gallagher LLP presumptively contain information that is confidential and legally privileged; email messages to non-clients are normally confidential and may also be legally privileged. Please do not read, copy, forward or store this message unless you are an intended recipient of it. If you have received this message in error, please forward it back. Willkie Farr & Gallagher LLP is a limited liability partnership organized in the United States Case 3:23-cv-01034-GMM Document 52-11 Filed 04/27/23 Page 4 of 5 under the laws of the State of Delaware, which laws limit the personal liability of partners. Important Notice: This email message is intended to be received only by persons entitled to receive the confidential information it may contain. Email messages to clients of Willkie Farr & Gallagher LLP presumptively contain information that is confidential and legally privileged; email messages to non- clients are normally confidential and may also be legally privileged. Please do not read, copy, forward or store this message unless you are an intended recipient of it. If you have received this message in error, please forward it back. Willkie Farr & Gallagher LLP is a limited liability partnership organized in the United States under the laws of the State of Delaware, which laws limit the personal liability of partners. Case 3:23-cv-01034-GMM Document 52-11 Filed 04/27/23 Page 5 of 5
File and source
- File
- gov.uscourts.prd.175040.52.11.pdf
- Size
- 279,742 bytes
- SHA-256
- 926fc110532e1056e805209c08d0f1b435920aff315200fbfcf2d8ef207c0498
- Original
- PACER (login required)