Docket 3:23-cv-01034 — Doc 182-20

Record facts

U.S. District Court for the District of Puerto Rico · No. 3:23-cv-01034-GMM · Doc. 182-20 · 2024-12-06 · Docket on CourtListener

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EXHIBIT 1
Case 3:23-cv-01034-GMM     Document 182-20     Filed 12/06/24     Page 1 of 23

From:
Levy, Joshua S.
To:
Michael Lorigas; Hanley, Katherine; Monica Ramos Benitez; Carla S. Loubriel Carrión; Kessler, Thomas; Forbes, Alexandra L.; Kohles,
Mitchell; Schweitzer, Lisa M.; antonio.roig@oneillborges.com; ubaldo.fernandez@oneillborges.com; anibal.roman@oneillborges.com;
Cheney, Alexander; Lombardi, Stuart; Morris, Daniel L.; Morton, Adriana; Palmeri, Vincent; Alejandro J. Cepeda Diaz; Arturo J.
Garcia; Gabriela A. Pérez-Vélez
Cc:
Jaime Torrens Dávila; Camara Fuertes, Roberto; Ricardo Casellas; Jorge L. Piedra; Rasheed Nader; Dwayne Robinson
Subject:
RE: Defendants Responses to Discovery (Oto Analytics LLC v. Benworth Capital Partners PR LLC, et al.)
Date:
Monday, November 11, 2024 9:55:54 AM
Attachments:
image001.png
Mike,
We are concerned about the slow pace at which Defendants are collecting and producing documents, which is
causing weeks of unnecessary delay. In particular, you are unable to provide a date certain by which you will be
able to provide a hit report, let alone begin reviewing and producing ESI documents. It also appears that
Defendants’ next document production, which has been delayed for weeks, will not include key financial
documentation that Defendants have agreed to produce. We expect that Defendants will not unnecessarily prolong
search term negotiations, will promptly review and produce emails, and will produce non-email documents as soon
as possible once they are loaded. Failure to do so may violate the Court-ordered document discovery deadlines.
As to the Navarro-controlled entities, we have met and conferred at length on this issue both by videoconference
and by email and Defendants continue to withhold this information without citing any authority in support of their
position. We are now at impasse and will raise this issue to the Court.
As to the Quickbooks data, you have rejected multiple compromise proposals from Womply without explanation.
There is no valid basis for Defendants to withhold access to or production of the data. You have agreed that the
Quickbooks data contains relevant information, there is no burden to providing Plaintiffs will access to this data,
and the protective order protects the confidentiality of the data. You state that you are “willing to reach a
compromise on the information in Quickbook,” but do not provide any compromise proposals or basis for
withholding the information. Please provide a compromise proposal or explain your basis for withholding the
information so we can promptly raise this issue to the Court.
Finally, as to the hard copy bank statements, we do not agree to pay any vendor retained by Defendants, which is
impermissible cost-shifting of Defendants’ discovery obligations. If Defendants wish to retain their own vendor,
then they can scan and produce the bank statements at their own expense as required by the parties’ ESI stipulation.
Plaintiffs nonetheless remain willing to pay for their own vendor, but do not agree to permit Defendants to
micromanage this process. As a final compromise (subject to the Reserve Bank’s agreement), Plaintiffs’ vendor
can bring its scanning equipment to Defendants’ warehouse if Plaintiffs agree to pay the additional expense
associated with transporting the equipment to the warehouse instead of transporting the documents to the
equipment. Plaintiffs’ vendor estimates the additional cost of transporting the scanning equipment onsite will be
$11,200 to $14,000, depending on how many days it takes to scan all the bank statements.
We are not available for a meet-and-confer call on Wednesday at 3 PM ET. In any event, given the positions in
your email, we do not believe a meet-and-confer call will be productive until you provide additional information
about the Quickbooks data and the hit report.
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: Michael Lorigas <mlorigas@kttlaw.com>
Sent: Friday, November 8, 2024 10:17 AM
To: Levy, Joshua S. <JLevy@willkie.com>; Hanley, Katherine <KHanley@willkie.com>; Monica Ramos Benitez
<mramos@ferraiuoli.com>; Carla S. Loubriel Carrión <CLoubriel@cabprlaw.com>; Kessler, Thomas
<tkessler@cgsh.com>; Forbes, Alexandra L. <aforbes@cgsh.com>; Kohles, Mitchell <mkohles@cgsh.com>;
Case 3:23-cv-01034-GMM     Document 182-20     Filed 12/06/24     Page 2 of 23

Schweitzer, Lisa M. <lschweitzer@cgsh.com>; antonio.roig@oneillborges.com;
ubaldo.fernandez@oneillborges.com; anibal.roman@oneillborges.com; Cheney, Alexander
<ACheney@willkie.com>; Lombardi, Stuart <slombardi@willkie.com>; Morris, Daniel L. <DMorris@willkie.com>;
Morton, Adriana <AMorton@willkie.com>; Palmeri, Vincent <VPalmeri@willkie.com>; Alejandro J. Cepeda Diaz
<Ajc@mcvpr.com>; Arturo J. Garcia <Ajg@mcvpr.com>; Gabriela A. Pérez-Vélez <Gpv@mcvpr.com>
Cc: Jaime Torrens Dávila <jtorrens@ferraiuoli.com>; Camara Fuertes, Roberto <rcamara@ferraiuoli.com>; Ricardo
Casellas <RCasellas@cabprlaw.com>; Jorge L. Piedra <jpiedra@kttlaw.com>; Rasheed Nader
<rnader@kttlaw.com>; Dwayne Robinson <drobinson@kttlaw.com>
Subject: RE: Defendants Responses to Discovery (Oto Analytics LLC v. Benworth Capital Partners PR LLC, et al.)
*** EXTERNAL EMAIL ***
Josh,
Apologies for the delay, I’ve been working on obtaining specific information for you. However, with
respect to ESI, we were still waiting for a response from Benworth’s IT vendor, which we did not finally
receive until this morning. According to the vendor, the ESI will be finished loading onto a hard drive by
next Tuesday. Once we get the hard drive, we’ll begin the process of uploading the data to Relativity and
that will give us an estimate for when the ESI will be finished processing. I expect this process will take
several days due to the amount of data. For example, the shared drive containing all the Womply-related
PPP loan files consists of 6.17M files at 3.2TB (this is the drive that will be produced in its entirety because
it contains only Womply-related files and will not be subject to search terms). Once the ESI finishes
uploading to Relativity, we will run the search terms on the ESI that require review, and it should not take
more than a day or two to provide the hit report.
Our next production will consist of the following documents:
The additional hard copy document from Ms. Avila
Unredacted copies of filings from the California confirmation/vacatur actions
Some bank statements
The remaining corporate structure and formation documents for Benworth FL and Benworth PR
The results of the targeted search for documents and communications relating to the LSA, ALSA,
transfer pricing analysis, and solicitation process
I expect it will be ready by next Friday.
We are available for a call next Wednesday, 11/13, at 3pm/EST to further meet and confer on the Navarro-
controlled entities and Quickbooks data issues. Let us know if that works for you all.
As far as the case law you cited, a single unpublished decision out of the Northern District of Texas hardly
establishes that it is “settled law” you are entitled to the information you seek. Moreover, the case was
brought by a company against its insiders and included allegations that those insiders squandered the
company’s assets for the benefit of the insiders’ affiliated entities. No such allegations are present here with
respect to Navarro-controlled entities. And the case says nothing about giving unfettered access to a
defendant’s Quickbooks data. We’re still willing to reach a compromise on the information in Quickbooks
but cannot agree to the level of access you seek.
We still don’t understand how the Navarro-controlled entities information is relevant. The fraudulent
transfer claim seeks to unwind only transfers between Benworth FL and Benworth PR. You also state the
“information is also relevant to Plaintiffs’ alter ego/successor liability claims and veil piercing claim by
showing how the Navarros moved and controlled funds and undercapitalized Benworth FL.” But Benworth
FL and Benworth PR are closely-held companies owned by only the Navarros. Control over assets is
inherent in such ownership. Moreover, the alter ego/successor liability claim only seeks to declare Benworth
PR the alter ego of Benworth FL. How would information concerning Navarro-controlled entities be
relevant to that claim? Plaintiffs did not allege that the Navarros should be held liable for the debts of
Benworth FL under alter ego/successor or veil piercing theories. With respect to the veil piercing claim,
which is limited to the Navarros being held liable for any debt imputed to Benworth PR, how would
information showing the Navarros “undercapitalized Benworth FL” be relevant? Moreover, even assuming
for arguments’ sake that the Navarros are held liable for any debt imputed to Benworth PR, it would be the
Navarros in their personal capacity, not any Navarro-controlled entity, who would be held liable. The
insistence for information concerning all Navarro-controlled entities at this stage remains speculative in
nature.
Finally, as to the hard copy bank statements, our client has expressed concern over your vendor taking its
sensitive information to a facility without supervision. Since you already planned on paying for the cost of
Case 3:23-cv-01034-GMM     Document 182-20     Filed 12/06/24     Page 3 of 23

MICHAEL R. LORI GAS, ESQ.
2525 Ponce de Leon Boulevard, Floor 9, Miami, Florida 33134
Phone 305.372.1800 | Direct 305.728.2980 | Email mlorigas@kttlaw.com
Firm Bio | Personal LinkedIn | KTT LinkedIn
From: Levy, Joshua S. <JLevy@willkie.com>
Sent: Thursday, November 7, 2024 12:45 PM
To: Michael Lorigas <mlorigas@kttlaw.com>; Hanley, Katherine <KHanley@willkie.com>; Monica Ramos Benitez
<mramos@ferraiuoli.com>; Carla S. Loubriel Carrión <CLoubriel@cabprlaw.com>; Kessler, Thomas
<tkessler@cgsh.com>; Forbes, Alexandra L. <aforbes@cgsh.com>; Kohles, Mitchell <mkohles@cgsh.com>;
Schweitzer, Lisa M. <lschweitzer@cgsh.com>; antonio.roig@oneillborges.com;
ubaldo.fernandez@oneillborges.com; anibal.roman@oneillborges.com; Cheney, Alexander
<ACheney@willkie.com>; Lombardi, Stuart <slombardi@willkie.com>; Morris, Daniel L. <DMorris@willkie.com>;
Morton, Adriana <AMorton@willkie.com>; Palmeri, Vincent <VPalmeri@willkie.com>; Alejandro J. Cepeda Diaz
<Ajc@mcvpr.com>; Arturo J. Garcia <Ajg@mcvpr.com>; Gabriela A. Pérez-Vélez <Gpv@mcvpr.com>
Cc: Jaime Torrens Dávila <jtorrens@ferraiuoli.com>; Camara Fuertes, Roberto <rcamara@ferraiuoli.com>; Ricardo
Casellas <RCasellas@cabprlaw.com>; Jorge L. Piedra <jpiedra@kttlaw.com>; Rasheed Nader
<rnader@kttlaw.com>; Dwayne Robinson <drobinson@kttlaw.com>
Subject: RE: Defendants Responses to Discovery (Oto Analytics LLC v. Benworth Capital Partners PR LLC, et al.)
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.]
Michael,
We have not heard from Defendants in over a week and are concerned about Defendants’ increasing delays.
Please provide responses to my email with specific information and dates, which you represented you would
provide last week.
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: Levy, Joshua S. <JLevy@willkie.com>
Sent: Monday, November 4, 2024 12:02 PM
To: Michael Lorigas <mlorigas@kttlaw.com>; Hanley, Katherine <KHanley@willkie.com>; Monica Ramos Benitez
<mramos@ferraiuoli.com>; Carla S. Loubriel Carrión <CLoubriel@cabprlaw.com>; Kessler, Thomas
<tkessler@cgsh.com>; Forbes, Alexandra L. <aforbes@cgsh.com>; Kohles, Mitchell <mkohles@cgsh.com>;
Schweitzer, Lisa M. <lschweitzer@cgsh.com>; antonio.roig@oneillborges.com;
ubaldo.fernandez@oneillborges.com; anibal.roman@oneillborges.com; Cheney, Alexander
copying, would you agree to Benworth hiring the vendor and Womply and/or the Federal Reserve directly
paying the vendor we retain?
Best,
Mike
Case 3:23-cv-01034-GMM     Document 182-20     Filed 12/06/24     Page 4 of 23

<ACheney@willkie.com>; Lombardi, Stuart <slombardi@willkie.com>; Morris, Daniel L. <DMorris@willkie.com>;
Morton, Adriana <AMorton@willkie.com>; Palmeri, Vincent <VPalmeri@willkie.com>; Alejandro J. Cepeda Diaz
<Ajc@mcvpr.com>; Arturo J. Garcia <Ajg@mcvpr.com>; Gabriela A. Pérez-Vélez <Gpv@mcvpr.com>
Cc: Jaime Torrens Dávila <jtorrens@ferraiuoli.com>; Camara Fuertes, Roberto <rcamara@ferraiuoli.com>; Ricardo
Casellas <RCasellas@cabprlaw.com>; Jorge L. Piedra <jpiedra@kttlaw.com>; Rasheed Nader
<rnader@kttlaw.com>; Dwayne Robinson <drobinson@kttlaw.com>
Subject: RE: Defendants Responses to Discovery (Oto Analytics LLC v. Benworth Capital Partners PR LLC, et al.)
Michael,
I’m following up about my email below.
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: Michael Lorigas <mlorigas@kttlaw.com>
Sent: Wednesday, October 30, 2024 6:24 PM
To: Levy, Joshua S. <JLevy@willkie.com>; Hanley, Katherine <KHanley@willkie.com>; Monica Ramos Benitez
<mramos@ferraiuoli.com>; Carla S. Loubriel Carrión <CLoubriel@cabprlaw.com>; Kessler, Thomas
<tkessler@cgsh.com>; Forbes, Alexandra L. <aforbes@cgsh.com>; Kohles, Mitchell <mkohles@cgsh.com>;
Schweitzer, Lisa M. <lschweitzer@cgsh.com>; antonio.roig@oneillborges.com;
ubaldo.fernandez@oneillborges.com; anibal.roman@oneillborges.com; Cheney, Alexander
<ACheney@willkie.com>; Lombardi, Stuart <slombardi@willkie.com>; Morris, Daniel L. <DMorris@willkie.com>;
Morton, Adriana <AMorton@willkie.com>; Palmeri, Vincent <VPalmeri@willkie.com>; Alejandro J. Cepeda Diaz
<Ajc@mcvpr.com>; Arturo J. Garcia <Ajg@mcvpr.com>; Gabriela A. Pérez-Vélez <Gpv@mcvpr.com>
Cc: Jaime Torrens Dávila <jtorrens@ferraiuoli.com>; Camara Fuertes, Roberto <rcamara@ferraiuoli.com>; Ricardo
Casellas <RCasellas@cabprlaw.com>; Jorge L. Piedra <jpiedra@kttlaw.com>; Rasheed Nader
<rnader@kttlaw.com>; Dwayne Robinson <drobinson@kttlaw.com>
Subject: RE: Defendants Responses to Discovery (Oto Analytics LLC v. Benworth Capital Partners PR LLC, et al.)
*** EXTERNAL EMAIL ***
Josh,
We have no objection to your proposal for (1) extending the substantial completion deadline by one month,
with no other modifications to the case schedule; and (2) extending Womply’s and the Reserve Bank’s
respective times to respond to Defendants’ document requests by one month. Attached is the joint status
report with one redline. If you accept that redline and do not make any additional changes to the report,
then you have our consent to file. I’ll respond to the balance of your email by the end of this week.
Firm Bio | Personal LinkedIn | KTT LinkedIn
MICHAEL R. LORI GAS, ESQ.
2525 Ponce de Leon Boulevard, Floor 9, Miami, Florida 33134
Phone 305.372.1800 | Direct 305.728.2980 | Email mlorigas@kttlaw.com
From: Levy, Joshua S. <JLevy@willkie.com>
Sent: Wednesday, October 30, 2024 1:20 PM
Case 3:23-cv-01034-GMM     Document 182-20     Filed 12/06/24     Page 5 of 23

To: Michael Lorigas <mlorigas@kttlaw.com>; Hanley, Katherine <KHanley@willkie.com>; Monica Ramos Benitez
<mramos@ferraiuoli.com>; Carla S. Loubriel Carrión <CLoubriel@cabprlaw.com>; Kessler, Thomas
<tkessler@cgsh.com>; Forbes, Alexandra L. <aforbes@cgsh.com>; Kohles, Mitchell <mkohles@cgsh.com>;
Schweitzer, Lisa M. <lschweitzer@cgsh.com>; antonio.roig@oneillborges.com;
ubaldo.fernandez@oneillborges.com; anibal.roman@oneillborges.com; Cheney, Alexander
<ACheney@willkie.com>; Lombardi, Stuart <slombardi@willkie.com>; Morris, Daniel L. <DMorris@willkie.com>;
Morton, Adriana <AMorton@willkie.com>; Palmeri, Vincent <VPalmeri@willkie.com>; Alejandro J. Cepeda Diaz
<Ajc@mcvpr.com>; Arturo J. Garcia <Ajg@mcvpr.com>; Gabriela A. Pérez-Vélez <Gpv@mcvpr.com>
Cc: Jaime Torrens Dávila <jtorrens@ferraiuoli.com>; Camara Fuertes, Roberto <rcamara@ferraiuoli.com>; Ricardo
Casellas <RCasellas@cabprlaw.com>; Jorge L. Piedra <jpiedra@kttlaw.com>; Rasheed Nader
<rnader@kttlaw.com>; Dwayne Robinson <drobinson@kttlaw.com>
Subject: RE: Defendants Responses to Discovery (Oto Analytics LLC v. Benworth Capital Partners PR LLC, et al.)
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.]
Michael,
It’s highly concerning that, months after Defendants identified relevant documents and custodians in their Initial
Disclosures and Plaintiffs served discovery requests, Defendants have not even uploaded the ESI they agreed to
collect. Your email does not provide any timeline for uploading ESI, providing a hit report, or producing the many
categories of non-email documents Defendants agreed to produce during the October 17, 2024 meet-and-confer
call. There is no reason for delays in uploading all ESI to delay rolling productions of documents you have already
collected, uploaded, and agreed to produce. Please provide a date certain by which Defendants will make their
next rolling production and identify what that production will include.
Defendants also refuse to produce any information or documents regarding Navarro-controlled entities or
Quickbooks data, but your email does not provide any explanation or basis for these positions and does not
engage with the case law Womply provided, at your request, in my October 21 email. We were prepared to
discuss these issues during the October 29, 2024 meet-and-confer call, which you cancelled without providing any
dates or times to reschedule. Please provide Defendants’ good-faith basis for refusing to produce the requested
documents and information, including a response to the case law we provided. Please also provide dates and
times you are available to meet and confer about these issues.
We were also prepared to discuss Benworth’s hard-copy bank statements during the October 29 meet and
confer. Please provide the exact address, dates, and times at which our vendor can collect the hard-copy
documents. Our vendor will scan them at its facilities and then return them to the same address.
Finally, given Defendants’ slow pace of conducting discovery, we do not believe that Defendants are on track to
comply with the Court-ordered deadline for the substantial completion of document discovery. Accordingly, we
propose (1) extending the substantial completion deadline by one month, with no other modifications to the case
schedule; and (2) extending Womply’s and the Reserve Bank’s respective times to respond to Defendants’
document requests by one month. Attached is a draft joint status report that reflects this proposal. Please let us
know if you agree. The joint status report is due to the Court today.
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
Case 3:23-cv-01034-GMM     Document 182-20     Filed 12/06/24     Page 6 of 23

jlevy@willkie.com | vCard | www.willkie.com bio
From: Michael Lorigas <mlorigas@kttlaw.com>
Sent: Tuesday, October 29, 2024 9:45 AM
To: Hanley, Katherine <KHanley@willkie.com>; Levy, Joshua S. <JLevy@willkie.com>; Monica Ramos Benitez
<mramos@ferraiuoli.com>; Carla S. Loubriel Carrión <CLoubriel@cabprlaw.com>; Kessler, Thomas
<tkessler@cgsh.com>; Forbes, Alexandra L. <aforbes@cgsh.com>; Kohles, Mitchell <mkohles@cgsh.com>;
Schweitzer, Lisa M. <lschweitzer@cgsh.com>; antonio.roig@oneillborges.com;
ubaldo.fernandez@oneillborges.com; anibal.roman@oneillborges.com; Cheney, Alexander
<ACheney@willkie.com>; Lombardi, Stuart <slombardi@willkie.com>; Morris, Daniel L. <DMorris@willkie.com>;
Morton, Adriana <AMorton@willkie.com>; Palmeri, Vincent <VPalmeri@willkie.com>; Alejandro J. Cepeda Diaz
<Ajc@mcvpr.com>; Arturo J. Garcia <Ajg@mcvpr.com>; Gabriela A. Pérez-Vélez <Gpv@mcvpr.com>
Cc: Jaime Torrens Dávila <jtorrens@ferraiuoli.com>; Camara Fuertes, Roberto <rcamara@ferraiuoli.com>; Ricardo
Casellas <RCasellas@cabprlaw.com>; Jorge L. Piedra <jpiedra@kttlaw.com>; Rasheed Nader
<rnader@kttlaw.com>; Dwayne Robinson <drobinson@kttlaw.com>
Subject: RE: Defendants Responses to Discovery (Oto Analytics LLC v. Benworth Capital Partners PR LLC, et al.)
*** EXTERNAL EMAIL ***
Good morning,
We are going to need to reschedule the meet and confer call. We have not been able to run the search terms
because all the ESI we agreed to collect has not been uploaded to our platform. When I sent my email last
Wednesday, I was under the impression that the ESI was processing in our system. Around that time, I
learned that certain folders in Benworth’s shared drive were not limited to only Womply-specific files like
I was initially told. That is why I originally stated there would be a delay in the production because we
would need to review the files before processing for production. Since then, I have learned that we are still
waiting for Benworth’s independent IT consultant to provide us a link so we can upload all the agreed upon
ESI data to our platform. We’ve reached out to the IT consultant multiple times but have not yet received
an update. I will continue to push for an update today and revert as soon as I have more information. But
under these circumstances, we will not have the information necessary to make a meet and confer call
productive today.
However, there are two other points that were to be discussed today that I can address through this email.
First, with respect to the “Navarro-Controlled Entities” issue, we are maintaining our objection and will not
voluntarily provide a list of the entities owned by the Navarros. Second, with respect to the Quickbooks
data, we do not agree to either (1) export and produce all QuickBooks data to Womply and the Reserve
Bank, or (2) provide Womply and the Reserve Bank with login credentials so they can run their own
searches and reports in the database.
Apologies for any inconvenience this causes. But I will follow up to reschedule the meet and confer call
asap when we have more information.
Best,
MICHAEL R. LORI GAS, ESQ.
<image001.png>
2525 Ponce de Leon Boulevard, Floor 9, Miami, Florida 33134
Phone 305.372.1800 | Direct 305.728.2980 | Email mlorigas@kttlaw.com
Firm Bio | Personal LinkedIn | KTT LinkedIn
From: Hanley, Katherine <KHanley@willkie.com>
Sent: Friday, October 25, 2024 5:03 PM
To: Michael Lorigas <mlorigas@kttlaw.com>; Levy, Joshua S. <JLevy@willkie.com>; Monica Ramos Benitez
<mramos@ferraiuoli.com>; Carla S. Loubriel Carrión <CLoubriel@cabprlaw.com>; Kessler, Thomas
Case 3:23-cv-01034-GMM     Document 182-20     Filed 12/06/24     Page 7 of 23

<tkessler@cgsh.com>; Forbes, Alexandra L. <aforbes@cgsh.com>; Kohles, Mitchell <mkohles@cgsh.com>;
Schweitzer, Lisa M. <lschweitzer@cgsh.com>; antonio.roig@oneillborges.com;
ubaldo.fernandez@oneillborges.com; anibal.roman@oneillborges.com; Cheney, Alexander
<ACheney@willkie.com>; Lombardi, Stuart <slombardi@willkie.com>; Morris, Daniel L. <DMorris@willkie.com>;
Morton, Adriana <AMorton@willkie.com>; Palmeri, Vincent <VPalmeri@willkie.com>; Alejandro J. Cepeda Diaz
<Ajc@mcvpr.com>; Arturo J. Garcia <Ajg@mcvpr.com>; Gabriela A. Pérez-Vélez <Gpv@mcvpr.com>
Cc: Jaime Torrens Dávila <jtorrens@ferraiuoli.com>; Camara Fuertes, Roberto <rcamara@ferraiuoli.com>; Ricardo
Casellas <RCasellas@cabprlaw.com>; Jorge L. Piedra <jpiedra@kttlaw.com>; Rasheed Nader
<rnader@kttlaw.com>; Dwayne Robinson <drobinson@kttlaw.com>
Subject: RE: Defendants Responses to Discovery (Oto Analytics LLC v. Benworth Capital Partners PR LLC, et al.)
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.]
Counsel,
As discussed during our October 17th meet and confer, counsel for Womply and counsel for the Federal Reverse
have conferred on proposed search terms. As we stated during prior meet and confer discussions, these search
terms are intended to identify responsive material rather than limit the scope of the parties’ Requests for
Production, and the requesting parties reserve the right to add additional search terms based on produced
material, including without limitation regarding any Navarro Entity. Accompanying any production based on these
search terms (or a modified set thereof) will be an identification by Defendants of the Requests for Production to
which the production relates.
Additionally, Defendants represented at the October 17th meet and confer that they would run a hit report on the
terms we provide before the October 29 meet and confer. Accordingly, we request that Defendants run the
attached proposed search terms on their document collections and provide a hit report before the October 29
meet and confer so the parties can review and discuss during the meet and confer. To facilitate a productive
discussion, the hit report should include 1) de-duplicated full hits with full families, and 2) de-duplicated unique
hits with full families. For clarity, a unique hit is a document where only one search term hits upon the document.
Accordingly, a unique hit with full family is a document family that has only one hit in it such that if that search
term were removed, then the entire family would drop out of the search. Note that the asterisk (*) in the
attached terms is used as a root expander.
Best,
Katherine
Katherine Hanley
Willkie Farr & Gallagher LLP
300 North LaSalle Dr. | Chicago, IL 60654-3406
Direct: +1 312 728 9320 | Fax: +1 312 728 9199
khanley@willkie.com | vCard | www.willkie.com bio
Pronouns: she, her, hers
Admitted only to the New York Bar and practicing under the supervision of members of the Illinois bar.
From: Michael Lorigas <mlorigas@kttlaw.com>
Sent: Wednesday, October 23, 2024 4:02 PM
To: Hanley, Katherine <KHanley@willkie.com>; Levy, Joshua S. <JLevy@willkie.com>; Monica Ramos Benitez
<mramos@ferraiuoli.com>; Carla S. Loubriel Carrión <CLoubriel@cabprlaw.com>; Kessler, Thomas
<tkessler@cgsh.com>; Forbes, Alexandra L. <aforbes@cgsh.com>; Kohles, Mitchell <mkohles@cgsh.com>;
Schweitzer, Lisa M. <lschweitzer@cgsh.com>; antonio.roig@oneillborges.com;
ubaldo.fernandez@oneillborges.com; anibal.roman@oneillborges.com; Cheney, Alexander
Case 3:23-cv-01034-GMM     Document 182-20     Filed 12/06/24     Page 8 of 23

<ACheney@willkie.com>; Lombardi, Stuart <slombardi@willkie.com>; Morris, Daniel L. <DMorris@willkie.com>;
Morton, Adriana <AMorton@willkie.com>; Palmeri, Vincent <VPalmeri@willkie.com>; Alejandro J. Cepeda Diaz
<Ajc@mcvpr.com>; Arturo J. Garcia <Ajg@mcvpr.com>; Gabriela A. Pérez-Vélez <Gpv@mcvpr.com>
Cc: Jaime Torrens Dávila <jtorrens@ferraiuoli.com>; Camara Fuertes, Roberto <rcamara@ferraiuoli.com>; Ricardo
Casellas <RCasellas@cabprlaw.com>; Jorge L. Piedra <jpiedra@kttlaw.com>; Rasheed Nader
<rnader@kttlaw.com>; Dwayne Robinson <drobinson@kttlaw.com>
Subject: RE: Defendants Responses to Discovery (Oto Analytics LLC v. Benworth Capital Partners PR LLC, et al.)
*** EXTERNAL EMAIL ***
Counsel,
This email serves as Defendants’ response to your emails from earlier this week on discovery issues.
With respect to Katherine’s email concerning your difficulties in identifying which documents are new due
to the lack of certain metadata, below are links to the overlay DAT files for BEGATTACH,
ENDATTACH, ATTACHRANGE and CUSTODIAN FIELDS for VOL001 and VOL002. Let us know if
you have any issues accessing the links. This should resolve your ESI concerns on those productions. If
not, we can revisit identifying the new documents by bates range.
DEFENDANTS VOL001-OVERLAY.zip
Password:
VOL001: D9n65w68nZz4odAM
<image002.png>
Defendants VOL002.rar
Password:
VOL002: Ea2aEHaGJ5rk0tpK
On the hard copy documents kept by Ms. Avila, I can confirm there is only one additional responsive
document and it will be produced.
For the hard copy bank statements, our intention is to make them available at the storage unit where they
are currently located. Will you all have a vendor who has the ability to copy the bank statements on-site at
the storage unit?
With respect to the “Navarro-Controlled Entities” issue, due to varying schedules, our team has not yet had
the opportunity to collectively discuss whether we will voluntarily provide a list of names of all entities
controlled by the Navarros. We ask that you give us until the upcoming meet and confer call to give you
our final position on this issue.
Finally, as to our next production, it will not be ready this Friday. I’ll have an update on the anticipated
timing of our next production by the upcoming meet and confer call on Tuesday, October 29 at 11am/EST
and will be happy to answer any questions concerning the delay in the production at that time. In the
meantime, we will continue focusing on addressing the outstanding items from Josh’s email memorializing
our October 17 meet and confer call.
Best,
MICHAEL R. LORI GAS, ESQ.
<image001.png>
2525 Ponce de Leon Boulevard, Floor 9, Miami, Florida 33134
Phone 305.372.1800 | Direct 305.728.2980 | Email mlorigas@kttlaw.com
Firm Bio | Personal LinkedIn | KTT LinkedIn
Case 3:23-cv-01034-GMM     Document 182-20     Filed 12/06/24     Page 9 of 23

From: Hanley, Katherine <KHanley@willkie.com>
Sent: Monday, October 21, 2024 6:18 PM
To: Levy, Joshua S. <JLevy@willkie.com>; Monica Ramos Benitez <mramos@ferraiuoli.com>; Carla S. Loubriel
Carrión <CLoubriel@cabprlaw.com>; Kessler, Thomas <tkessler@cgsh.com>; Forbes, Alexandra L.
<aforbes@cgsh.com>; Kohles, Mitchell <mkohles@cgsh.com>; Schweitzer, Lisa M. <lschweitzer@cgsh.com>;
antonio.roig@oneillborges.com; ubaldo.fernandez@oneillborges.com; anibal.roman@oneillborges.com; Cheney,
Alexander <ACheney@willkie.com>; Lombardi, Stuart <slombardi@willkie.com>; Morris, Daniel L.
<DMorris@willkie.com>; Morton, Adriana <AMorton@willkie.com>; Palmeri, Vincent <VPalmeri@willkie.com>;
Alejandro J. Cepeda Diaz <Ajc@mcvpr.com>; Arturo J. Garcia <Ajg@mcvpr.com>; Gabriela A. Pérez-Vélez
<Gpv@mcvpr.com>
Cc: Jaime Torrens Dávila <jtorrens@ferraiuoli.com>; Camara Fuertes, Roberto <rcamara@ferraiuoli.com>; Ricardo
Casellas <RCasellas@cabprlaw.com>; Jorge L. Piedra <jpiedra@kttlaw.com>; Rasheed Nader
<rnader@kttlaw.com>; Michael Lorigas <mlorigas@kttlaw.com>; Dwayne Robinson <drobinson@kttlaw.com>
Subject: RE: Defendants Responses to Discovery (Oto Analytics LLC v. Benworth Capital Partners PR LLC, et al.)
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.]
Counsel,
We are continuing to review Defendants’ productions, but it appears that many (perhaps the vast majority) of the
documents that Defendants have produced were already produced in the arbitration. Because of the ESI
deficiencies in Defendants’ production we previously discussed, we are having difficulty identifying which
documents are new. By Wednesday, October 23, please provide (1) the Bates range for documents in Defendants’
production that were produced in the arbitration, and (2) a list of newly-produced documents by Bates number.
Best,
Katherine
Katherine Hanley
Willkie Farr & Gallagher LLP
300 North LaSalle Dr. | Chicago, IL 60654-3406
Direct: +1 312 728 9320 | Fax: +1 312 728 9199
khanley@willkie.com | vCard | www.willkie.com bio
Pronouns: she, her, hers
Admitted only to the New York Bar and practicing under the supervision of members of the Illinois bar.
From: Levy, Joshua S. <JLevy@willkie.com>
Sent: Monday, October 21, 2024 3:54 PM
To: Hanley, Katherine <KHanley@willkie.com>; Monica Ramos Benitez <mramos@ferraiuoli.com>; Carla S. Loubriel
Carrión <CLoubriel@cabprlaw.com>; Kessler, Thomas <tkessler@cgsh.com>; Forbes, Alexandra L.
<aforbes@cgsh.com>; Kohles, Mitchell <mkohles@cgsh.com>; Schweitzer, Lisa M. <lschweitzer@cgsh.com>;
antonio.roig@oneillborges.com; ubaldo.fernandez@oneillborges.com; anibal.roman@oneillborges.com; Cheney,
Alexander <ACheney@willkie.com>; Lombardi, Stuart <slombardi@willkie.com>; Morris, Daniel L.
<DMorris@willkie.com>; Morton, Adriana <AMorton@willkie.com>; Palmeri, Vincent <VPalmeri@willkie.com>;
Alejandro J. Cepeda Diaz <Ajc@mcvpr.com>; Arturo J. Garcia <Ajg@mcvpr.com>; Gabriela A. Pérez-Vélez
<Gpv@mcvpr.com>
Cc: Jaime Torrens Dávila <jtorrens@ferraiuoli.com>; Camara Fuertes, Roberto <rcamara@ferraiuoli.com>; Ricardo
Casellas <RCasellas@cabprlaw.com>; Jorge L. Piedra <jpiedra@kttlaw.com>; Rasheed Nader <rnader@kttlaw.com>;
Michael Lorigas <mlorigas@kttlaw.com>; Dwayne Robinson <drobinson@kttlaw.com>
Subject: RE: Defendants Responses to Discovery (Oto Analytics LLC v. Benworth Capital Partners PR LLC, et al.)
<<nc>>
Case 3:23-cv-01034-GMM     Document 182-20     Filed 12/06/24     Page 10 of 23

All – During the parties’ October 17, 2024 meet-and-confer call, counsel for Defendants withdrew their
representation from the October 10 meet-and-confer call that they would produce a list of names of all entities
controlled by Mr. and/or Mrs. Navarro. Defendants stated that they objected to producing such information on
relevance grounds, but represented that they were willing to reconsider their position if Plaintiffs provide case law
on this issue. As we discussed during the October 17 meet-and-confer call, it is settled law that the names of
entities controlled by defendants are relevant in a fraudulent transfer action. See, e.g., VeroBlue Farms USA, Inc. v.
Wulf, 2019 WL 12043593, at *2–4 (N.D. Tex. Sept. 10, 2019) (ordering defendants in fraudulent transfer action to
respond to interrogatories seeking to identify “all of Defendants’ Affiliated Entities, including the identity of all
shareholders, owners, managers, and/or directors”). Such information is particularly relevant where, as here,
Plaintiffs bring claims against individual “family members.” Id. Such information is also relevant to Plaintiffs’
alter ego/successor liability claims and veil piercing claim by showing how the Navarros moved and controlled
funds and undercapitalized Benworth FL. By close of business on October 23, please provide a written
representation that Defendants will provide a list of names of all entities controlled by Mr. and/or Mrs. Navarro, or
we will be at impasse will need to raise this issue with the Court.
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: Levy, Joshua S. <JLevy@willkie.com>
Sent: Friday, October 18, 2024 5:20 PM
To: Hanley, Katherine <KHanley@willkie.com>; Monica Ramos Benitez <mramos@ferraiuoli.com>; Carla S. Loubriel
Carrión <CLoubriel@cabprlaw.com>; Kessler, Thomas <tkessler@cgsh.com>; Forbes, Alexandra L.
<aforbes@cgsh.com>; Kohles, Mitchell <mkohles@cgsh.com>; Schweitzer, Lisa M. <lschweitzer@cgsh.com>;
antonio.roig@oneillborges.com; ubaldo.fernandez@oneillborges.com; anibal.roman@oneillborges.com; Cheney,
Alexander <ACheney@willkie.com>; Lombardi, Stuart <slombardi@willkie.com>; Morris, Daniel L.
<DMorris@willkie.com>; Morton, Adriana <AMorton@willkie.com>; Palmeri, Vincent <VPalmeri@willkie.com>;
Alejandro J. Cepeda Diaz <Ajc@mcvpr.com>; Arturo J. Garcia <Ajg@mcvpr.com>; Gabriela A. Pérez-Vélez
<Gpv@mcvpr.com>
Cc: Jaime Torrens Dávila <jtorrens@ferraiuoli.com>; Camara Fuertes, Roberto <rcamara@ferraiuoli.com>; Ricardo
Casellas <RCasellas@cabprlaw.com>; Jorge L. Piedra <jpiedra@kttlaw.com>; Rasheed Nader <rnader@kttlaw.com>;
Michael Lorigas <mlorigas@kttlaw.com>; Dwayne Robinson <drobinson@kttlaw.com>
Subject: RE: Defendants Responses to Discovery (Oto Analytics LLC v. Benworth Capital Partners PR LLC, et al.)
<<nc>>
All – Below is a memorialization of our meet-and-confer call yesterday.
Timing:
1. Defendants represented that they expect to make their next document production by Friday, October 25,
which will include:
1. TIFF files for documents lacking native or image files;
2. DAT files for the documents with missing custodian and range metadata;
3. Two drives on Defendants’ cloud-based system containing Womply-specific files;
4. A DropBox folder;
5. Additional physical documents collected from Mildred Avila; and
6. Additional documents discussed below, including documents and communications concerning the
LSA, ALSA, transfer pricing analysis, and solicitation process, and operating agreements and/or LLC
agreements for Benworth FL and Benworth PR.
Case 3:23-cv-01034-GMM     Document 182-20     Filed 12/06/24     Page 11 of 23

2. The parties agreed to hold their next meet-and-confer call on Tuesday, October 29 at 11:00 am ET.
3. Womply and the Reserve Bank represented that they expect to send proposed search terms in advance of
that meet-and-confer call. Defendants represented that they will provide a hit report in advance of that
meet-and-confer call so that the parties can discuss search terms and ESI review during the meet-and-confer
call.
ESI:
1. Defendants represented that, for the documents Womply identified in their October 15 email, Defendants
will include in their next production on Friday, October 25:
1. TIFF image files for the documents Womply identified as missing image or native files.
2. A DAT file that contains a populated “All Custodians” field for the 42,930 documents Womply
identified as missing this metadata field.
1. Defendants will get back to Womply about whether such metadata will be produced as an
overlay file or as a new production of the same documents containing the metadata field.
2. Defendants represented that Benworth FL and Benworth PR share the same system, so
Defendants cannot distinguish between the two entities in the custodian field for documents
collected from shared drives and have therefore listed the custodian as “Benworth.”
3. Defendants represented that they will produce all missing metadata for the 5,000 documents Womply
identified as missing attachment and range metadata.
1. Defendants stated that they believed such documents were documents Womply produced in
the Arbitration. Womply responded that it produced documents with such metadata, which
was not included in Defendants’ production in this action.
2. Defendants represented that are willing to meet and confer about any additional missing metadata,
including in any future document productions.
Email Collections:
3. Defendants represented that Benworth FL and Benworth PR both use the Microsoft Office 365 platform for
emails.
4. Defendants represented that they are in the process of collecting Angelica Castro’s documents.
5. Defendants represented that they have collected PST files from 2020 to the present. Defendants further
represented that they collected emails for Mildred Avila going back to 2009, Bernardo Navarro going back to
2011, and Toya de la Cruz going back to 2020.
6. Defendants represented that the PST files they collected include both inboxes and sent folders.
7. Defendants represented that they will run searches for documents in connection with the solicitation
process and transfer pricing analysis by the email domain of the relevant entity, and will produce such
documents in their Friday, October 25 production.
1. Defendants stated that they may need to use additional search modifiers for Professional Bank to
identify documents concerning the solicitation process, which may delay the production of such
documents.
Non-Email Collections:
1. Defendants represented that they use a cloud system with three different drives.
1. Two of the drives contain Womply-specific files and will be produced in entirety on Friday October, 25.
2. The third drive contains data general to PPP loans. Defendants will collect, review, and produce the
files in the third drive.
2. Defendants represented that their document custodians do not have files stored in local folders, laptops, or
personal computers. Defendants further represented that all business files are saved on Defendants’ cloud
system.
3. Defendants stated that they believed that their document custodians do not conduct worked-related
communications through external messaging apps, such as WhatsApp, but have not yet received
confirmation. Defendants are following up and will get back to Plaintiffs about this.
4. Defendants represented that text messages for all custodians have been preserved by turning off auto-
delete functions and backing up such text messages to the cloud.
Case 3:23-cv-01034-GMM     Document 182-20     Filed 12/06/24     Page 12 of 23

1. Defendants stated that they believed all custodians used iPhone but are following up to confirm.
Defendants are also looking into which cloud system text messages are backed up in (e.g., iCloud),
whether the text messages are backed up across devices (e.g., iPads, iMacs, etc.), and will get back to
Plaintiffs.
2. Defendants represented that the custodians’ phones have not yet been imaged.
3. Defendants represented that they will review text messages from Mr. Navarro’s and Mrs. Navarro’s
phones and produce relevant text messages in the Friday, October 25 production.
4. Defendants stated that the custodians had minimal business-related text messages, as was the case in
the Arbitration, and that most business was conducted by email. Womply responded that in the
Arbitration Benworth FL produced business text messages between Bernardo Navarro and Mildred
Avila and between Bernardo Navarro and Toya De La Cruz, so Defendants must also review and
produce text messages from Ms. Avila’s and Ms. De La Cruz’s phones.
5. Defendants stated that they had not yet looked into drafts and communications in connection with the LSA
and ASLA. Defendants represented that they would search for such documents and include them in their
Friday, October 25 production.
6. Defendants represented that they will produce corporate structure and formation documents, such as
operating agreements and LLC agreements, for Benworth FL and Benworth PR in their Friday, October 25
production.
Hard Copy Documents:
1. Defendants represented that Ms. Avila has additional hard copy documents. Defendants will collect these
documents next week and will produce them in their Friday, October 25 production.
1. Defendants represented that none of the other documents custodians have hard copy documents.
2. Womply stated that, while they continue to believe that it is Defendants’ obligation to scan and produce
Defendants’ hard copy bank statements contained in 10-15 banker’s boxes, as a compromise, Womply and
the Reserve Bank are willing to inspect and scan the documents. Defendants responded that this was
acceptance of their proposal from the prior meet-and-confer call.
1. Defendants represented that they will promptly follow up by email about the dates, times, and
locations where Womply and the Reserve Bank can inspect and scan these documents.
Financial and Accounting Documents:
1. Womply stated that Defendants produced audited financials for Benworth FL that excluded PPP loans and
therefore excluded highly relevant information. Womply requested that Defendants produced all financial
documentation requested in Womply’s RFPs, including without limitation ledgers, unaudited financials,
quarterly financials, annual financials, and all tax returns and filings.
1. Defendants represented that Benworth FL and Benworth PR maintain an accounting folder within the
DropBox, which has not yet been collected or reviewed. Defendants believed that the financial
documentation Womply is requesting is stored in this folder and will follow up to confirm. Defendants
represented that they will produce financial documentation from this folder in their Friday, October
25 production.
2. Defendants will follow up about whether Benworth FL’s and Benworth PR’s tax returns are included in
the Accounting folder or whether they will review and produce them as part of ESI discovery.
2. Defendants represented that Benworth FL and Benworth PR use QuickBooks Premier Plus 2022 accounting
software, which they used to generate the chart of transfers Defendants produced.
1. Womply stated that asking Defendants to run reports on Womply’s behalf in the database would
reveal Womply’s work product and proposed that Defendants (1) export and produce all QuickBooks
data to Womply and the Reserve Bank, or (2) provide Womply and the Reserve Bank with login
credentials so they can run their own searches and reports in the database.
2. Defendants responded that they will confer internally and will follow up.
3. Defendants represented that the list of bank accounts they produced on October 11 is the full list of
Benworth FL’s and Benworth PR’s bank accounts.
4. Defendants acknowledged that they produced bank statements with redactions. Defendants represented
Case 3:23-cv-01034-GMM     Document 182-20     Filed 12/06/24     Page 13 of 23

that these documents were emailed to the Reserve Bank with redactions and were produced with those
same redactions.
1. Womply stated that the ESI protocol does not permit such redactions.
2. The Reserve Bank had no objections to reproducing these documents without redactions.
3. Defendants represented that they will locate unredacted bank statements and produce those
documents in accordance with the ESI protocol.
Navarro-Controlled Entities:
1. Defendants withdrew their representation from the October 10 meet-and-confer call that they would
produce a list of names of all entities controlled by Mr. and/or Mrs. Navarro. Defendants now state that they
are standing on their relevance objection and will not produce such information.
2. Womply and the Reserve Bank responded that Benworth FL and Benworth PR transferring money to the
Navarros through entities they control is directly relevant to their fraudulent transfer claims and that
Plaintiffs would not know the names of these entities, which are in Defendants’ possession, custody, and
control. Womply further responded that such information is relevant to its alter ego/successor liability
claims and veil piercing claim by showing how the Navarros moved and controlled funds and
undercapitalized Benworth FL.
3. All parties agreed that this was an issue of material disagreement between the parties.
1. Defendants represented that they are willing to reconsider their position if Plaintiffs provide case law
on this issue.
2. Womply requested that Defendants produce the names of the “Related Parties” referenced in the
chart of transfers Defendants produced and in Benworth PR’s audited financials.
3. Defendants represented that the “Related Parties” in these documents are Mr. and Mrs. Navarro.
4. Womply requested that Defendants produce the promissory notes between the Benworth entities and Mr.
and Mrs. Navarro referenced in in the chart of transfers Defendants produced and in Benworth PR’s audited
financials, and Defendants agreed to produce these promissory notes, likely in their Friday, October 25
production.
1. Womply noted that Defendants had represented that, other than operating agreements, there were
no agreements between Mr. and Mrs. Navarro and the Benworth entities. However, the promissory
notes are such agreements.
2. Defendants will follow up about whether there were additional agreements between Mr. and Mrs.
Navarro and the Benworth entities and will amend their responses to Womply’s discovery requests if
needed.
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: Hanley, Katherine <KHanley@willkie.com>
Sent: Tuesday, October 15, 2024 8:04 PM
To: Levy, Joshua S. <JLevy@willkie.com>; Monica Ramos Benitez <mramos@ferraiuoli.com>; Carla S. Loubriel
Carrión <CLoubriel@cabprlaw.com>; Kessler, Thomas <tkessler@cgsh.com>; Forbes, Alexandra L.
<aforbes@cgsh.com>; Kohles, Mitchell <mkohles@cgsh.com>; Schweitzer, Lisa M. <lschweitzer@cgsh.com>;
antonio.roig@oneillborges.com; ubaldo.fernandez@oneillborges.com; anibal.roman@oneillborges.com; Cheney,
Alexander <ACheney@willkie.com>; Lombardi, Stuart <slombardi@willkie.com>; Morris, Daniel L.
<DMorris@willkie.com>; Morton, Adriana <AMorton@willkie.com>; Palmeri, Vincent <VPalmeri@willkie.com>;
Alejandro J. Cepeda Diaz <Ajc@mcvpr.com>; Arturo J. Garcia <Ajg@mcvpr.com>; Gabriela A. Pérez-Vélez
Case 3:23-cv-01034-GMM     Document 182-20     Filed 12/06/24     Page 14 of 23

<Gpv@mcvpr.com>
Cc: Jaime Torrens Dávila <jtorrens@ferraiuoli.com>; Camara Fuertes, Roberto <rcamara@ferraiuoli.com>; Ricardo
Casellas <RCasellas@cabprlaw.com>; Jorge L. Piedra <jpiedra@kttlaw.com>; Rasheed Nader <rnader@kttlaw.com>;
Michael Lorigas <mlorigas@kttlaw.com>; Dwayne Robinson <drobinson@kttlaw.com>
Subject: RE: Defendants Responses to Discovery (Oto Analytics LLC v. Benworth Capital Partners PR LLC, et al.)
<<nc>>
Counsel,
We are in the process of reviewing your initial productions on behalf of all defendants. In reviewing, we noticed a
few issues with the production that we would like to raise in advance of our meet and confer this week.
First, we are missing images or native files for a number of documents that were produced. For example, counsel
identified Defendants_00240127 as Mr. Navarro’s Supplementary Response to Interrogatory No. 2 and Mrs.
Navarro’s Response to Interrogatory No. 2, however we did not receive an image file for this document and only
received the document-level extracted text. As a reminder, our ESI Stipulation provides that “all documents should
be produced as Bates-stamped tagged image file format (‘TIFF’) images along with an image load/cross reference
file, a data load file with fielded metadata, and document-level extracted text for electronically stored information”
and that “[a]ll documents, except those produced in native format . . . shall be produced as TIFF images in 300x300
dpi Group IV single-page monochrome.” Please advise as to when we can expect to receive image files or native
files for the documents identified in the attached spreadsheet.
Second, we are missing custodian information for 42,930 documents. Per our ESI Stipulation, “all custodians
determined to have a copy of an email, email family, or loose electronic document in its collection shall be listed in
the ‘AllCustodians’ metadata field for every document in the family.” Please advise as to when defendants intend to
provide this information.
Third, the BegAttach \ EndAttach \ Attach-Range values for the last 5,000 documents or so are absent from the
DAT file for Defendants VOL001. The remaining documents in the production have data populated in these fields
regardless of whether the respective document has an attachment or not, as shown in the below image. Can you
clarify why these 5,000 documents do not have these fields populated and confirm whether you intend to re-
produce these items in accordance with the requirements of our ESI Stipulation?
Best,
Katherine
Katherine Hanley
Willkie Farr & Gallagher LLP
300 North LaSalle Dr. | Chicago, IL 60654-3406
Direct: +1 312 728 9320 | Fax: +1 312 728 9199
khanley@willkie.com | vCard | www.willkie.com bio
Pronouns: she, her, hers
Admitted only to the New York Bar and practicing under the supervision of members of the Illinois bar.
From: Levy, Joshua S. <JLevy@willkie.com>
Sent: Tuesday, October 15, 2024 3:16 PM
To: Monica Ramos Benitez <mramos@ferraiuoli.com>; Carla S. Loubriel Carrión <CLoubriel@cabprlaw.com>;
Kessler, Thomas <tkessler@cgsh.com>; Forbes, Alexandra L. <aforbes@cgsh.com>; Kohles, Mitchell
<mkohles@cgsh.com>; Schweitzer, Lisa M. <lschweitzer@cgsh.com>; antonio.roig@oneillborges.com;
ubaldo.fernandez@oneillborges.com; anibal.roman@oneillborges.com; Cheney, Alexander
<ACheney@willkie.com>; Lombardi, Stuart <slombardi@willkie.com>; Morris, Daniel L. <DMorris@willkie.com>;
Morton, Adriana <AMorton@willkie.com>; Palmeri, Vincent <VPalmeri@willkie.com>; Alejandro J. Cepeda Diaz
<Ajc@mcvpr.com>; Arturo J. Garcia <Ajg@mcvpr.com>; Gabriela A. Pérez-Vélez <Gpv@mcvpr.com>
Cc: Jaime Torrens Dávila <jtorrens@ferraiuoli.com>; Camara Fuertes, Roberto <rcamara@ferraiuoli.com>; Ricardo
Case 3:23-cv-01034-GMM     Document 182-20     Filed 12/06/24     Page 15 of 23

Casellas <RCasellas@cabprlaw.com>; Jorge L. Piedra <jpiedra@kttlaw.com>; Rasheed Nader <rnader@kttlaw.com>;
Michael Lorigas <mlorigas@kttlaw.com>; Dwayne Robinson <drobinson@kttlaw.com>
Subject: RE: Defendants Responses to Discovery (Oto Analytics LLC v. Benworth Capital Partners PR LLC, et al.)
Thanks Monica.
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: Monica Ramos Benitez <mramos@ferraiuoli.com>
Sent: Tuesday, October 15, 2024 3:46 PM
To: Levy, Joshua S. <JLevy@willkie.com>; Carla S. Loubriel Carrión <CLoubriel@cabprlaw.com>; Kessler, Thomas
<tkessler@cgsh.com>; Forbes, Alexandra L. <aforbes@cgsh.com>; Kohles, Mitchell <mkohles@cgsh.com>;
Schweitzer, Lisa M. <lschweitzer@cgsh.com>; antonio.roig@oneillborges.com;
ubaldo.fernandez@oneillborges.com; anibal.roman@oneillborges.com; Cheney, Alexander
<ACheney@willkie.com>; Lombardi, Stuart <slombardi@willkie.com>; Morris, Daniel L. <DMorris@willkie.com>;
Morton, Adriana <AMorton@willkie.com>; Palmeri, Vincent <VPalmeri@willkie.com>; Alejandro J. Cepeda Diaz
<Ajc@mcvpr.com>; Arturo J. Garcia <Ajg@mcvpr.com>; Gabriela A. Pérez-Vélez <Gpv@mcvpr.com>
Cc: Jaime Torrens Dávila <jtorrens@ferraiuoli.com>; Camara Fuertes, Roberto <rcamara@ferraiuoli.com>; Ricardo
Casellas <RCasellas@cabprlaw.com>; Jorge L. Piedra <jpiedra@kttlaw.com>; Rasheed Nader <rnader@kttlaw.com>;
Michael Lorigas <mlorigas@kttlaw.com>; Dwayne Robinson <drobinson@kttlaw.com>
Subject: RE: Defendants Responses to Discovery (Oto Analytics LLC v. Benworth Capital Partners PR LLC, et al.)
*** EXTERNAL EMAIL ***
Josh,
In response to your prior email:
1. Benworth FL’s Response to Interrogatory No. 2;
1. Defendants_00227699
2. Benworth FL’s Responses to Interrogatories Nos. 7 and 10;
1. Defendants_00226809-00226873;
2. Defendants_00227186-00227252; and
3. Defendants_00227616-00227682
3. Benworth FL’s Supplementary Responses to Interrogatories Nos. 1 and 11;
1. Defendants_00227683
4. Mr. Navarro’s Response to Interrogatory No. 1;
1. Defendants_00227697-00227698
5. Mr. Navarro’s Supplementary Response to Interrogatory No. 2;
1. Defendants_00240127
6. Benworth PR’s Response to Interrogatory No. 2;
1. Defendants_00227699
7. Benworth PR’s Responses to Interrogatories Nos. 5 and 7;
1. Defendants_00226809-00226873;
2. Defendants_00227186-00227252; and
3. Defendants_00227616-00227682
8. Benworth PR’s Supplementary Responses to Interrogatories Nos. 1 and 8; and
Case 3:23-cv-01034-GMM     Document 182-20     Filed 12/06/24     Page 16 of 23

1. Defendants_00227683
9. Mrs. Navarro’s Response to Interrogatory No. 2.
1. Defendants_00240127
Cordially,
Mónica Ramos Benítez
_____________________________________________________________________________________________
PO Box 195168 • San Juan, PR 00919-5168
250 Muñoz Rivera Avenue, 6th Floor • San Juan, PR 00918
T. 787.766.7000
F. 787.766.7001
D. 787.777.1391
E. mramos@ferraiuoli.com
________________________________________________________________________________________________
The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s)
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P Before you print this E-mail, ask if it's really necessary. Our environment concerns us all…
From: Levy, Joshua S. <JLevy@willkie.com>
Sent: Monday, October 14, 2024 9:28 PM
To: Carla S. Loubriel Carrión <CLoubriel@cabprlaw.com>; Kessler, Thomas <tkessler@cgsh.com>; Forbes, Alexandra
L. <aforbes@cgsh.com>; Kohles, Mitchell <mkohles@cgsh.com>; Schweitzer, Lisa M. <lschweitzer@cgsh.com>;
antonio.roig@oneillborges.com; ubaldo.fernandez@oneillborges.com; anibal.roman@oneillborges.com; Cheney,
Alexander <ACheney@willkie.com>; Lombardi, Stuart <slombardi@willkie.com>; Morris, Daniel L.
<DMorris@willkie.com>; Morton, Adriana <AMorton@willkie.com>; Palmeri, Vincent <VPalmeri@willkie.com>;
Alejandro J. Cepeda Diaz <Ajc@mcvpr.com>; Arturo J. Garcia <Ajg@mcvpr.com>; Gabriela A. Pérez-Vélez
<Gpv@mcvpr.com>
Cc: Monica Ramos Benitez <mramos@ferraiuoli.com>; Jaime Torrens Dávila <jtorrens@ferraiuoli.com>; Roberto
Camara Fuertes <rcamara@ferraiuoli.com>; Ricardo Casellas <RCasellas@cabprlaw.com>; Jorge L. Piedra
<jpiedra@kttlaw.com>; Rasheed Nader <rnader@kttlaw.com>; Michael Lorigas <mlorigas@kttlaw.com>; Dwayne
Robinson <drobinson@kttlaw.com>
Subject: RE: Defendants Responses to Discovery (Oto Analytics LLC v. Benworth Capital Partners PR LLC, et al.)
WARNING: External Sender.
All – We write regarding Defendants’ Answers to Womply’s Interrogatories, dated October 7, 2024, and
Defendants’ Supplementary Answers to Womply’s Interrogatories, dated October 11, 2024. Federal Rule of Civil
Procedure 33(d)(1) permits a responding party to answer an interrogatory by “specifying the records that must be
reviewed, in sufficient detail to enable the interrogating party to locate and identify them as readily as the
responding party could.” For each of the responses to Womply’s interrogatories listed below, Defendants
responded by referencing a particular document (or documents) produced by Defendants, but Defendants have not
provided Bates numbers for these documents to enable Womply “to locate and identify them as readily” as
Defendants could. Under Rule 33(d)(1), if Defendants choose to respond to interrogatories by producing
documents, it is not Womply’s burden to have to search through Defendants’ document production to identify such
documents. By the close of business on Tuesday, October 15, please provide Bates numbers for the documents
referenced in the following interrogatory responses:
10. Benworth FL’s Response to Interrogatory No. 2;
11. Benworth FL’s Responses to Interrogatories Nos. 7 and 10;
Case 3:23-cv-01034-GMM     Document 182-20     Filed 12/06/24     Page 17 of 23

12. Benworth FL’s Supplementary Responses to Interrogatories Nos. 1 and 11;
13. Mr. Navarro’s Response to Interrogatory No. 1;
14. Mr. Navarro’s Supplementary Response to Interrogatory No. 2;
15. Benworth PR’s Response to Interrogatory No. 2;
16. Benworth PR’s Responses to Interrogatories Nos. 5 and 7;
17. Benworth PR’s Supplementary Responses to Interrogatories Nos. 1 and 8; and
18. Mrs. Navarro’s Response to Interrogatory No. 2.
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: Levy, Joshua S.
Sent: Friday, October 11, 2024 5:04 PM
To: Carla S. Loubriel Carrión <CLoubriel@cabprlaw.com>; Kessler, Thomas <tkessler@cgsh.com>; Forbes, Alexandra
L. <aforbes@cgsh.com>; Kohles, Mitchell <mkohles@cgsh.com>; Schweitzer, Lisa M. <lschweitzer@cgsh.com>;
antonio.roig@oneillborges.com; ubaldo.fernandez@oneillborges.com; anibal.roman@oneillborges.com; Cheney,
Alexander <ACheney@willkie.com>; Lombardi, Stuart <slombardi@willkie.com>; Morris, Daniel L.
<DMorris@willkie.com>; Morton, Adriana <AMorton@willkie.com>; Palmeri, Vincent <VPalmeri@willkie.com>;
Alejandro J. Cepeda Diaz <Ajc@mcvpr.com>; Arturo J. Garcia <Ajg@mcvpr.com>; Gabriela A. Pérez-Vélez
<Gpv@mcvpr.com>
Cc: Monica Ramos Benitez <mramos@ferraiuoli.com>; Jaime Torrens Dávila <jtorrens@ferraiuoli.com>; Camara
Fuertes, Roberto <rcamara@ferraiuoli.com>; Ricardo Casellas <RCasellas@cabprlaw.com>; Jorge L. Piedra
<jpiedra@kttlaw.com>; Rasheed Nader <rnader@kttlaw.com>; Michael Lorigas <mlorigas@kttlaw.com>; Dwayne
Robinson <drobinson@kttlaw.com>
Subject: RE: Defendants Responses to Discovery (Oto Analytics LLC v. Benworth Capital Partners PR LLC, et al.)
All – As we discussed, below is a memorialization of our meet-and-confer call yesterday.
Timing:
1. Defendants represented that they will make an initial production of documents in response to Womply’s and
the Reserve Bank’s document requests by Friday, October 11.
2. Defendants represented that they will serve supplemental responses to Womply’s interrogatories, which
substantively respond to all outstanding interrogatories, by Friday, October 11.
3. Womply stated that Defendants’ responses were due Monday, October 7, and that it may file a motion to
compel if documents and supplemental interrogatory responses are not served by Friday, October 11.
4. All parties agreed to hold another meet and confer by Zoom on Thursday, October 17 at 11:00 am ET.
ESI:
5. Document Custodians: Defendants identified as document custodians Bernardo Navarro, Claudia Navarro,
Mildred Avila, and Toya De La Cruz. Womply asked to include Angelica Castro as a document custodian
because Defendants identified her in their Rule 26(a) Initial Disclosures and Defendants agreed to add Ms.
Castro as a document custodian.
6. Document Collection: Defendants represented that they are collecting documents from Benworth FL’s and
Benworth PR’s emails for all document custodians, Benworth FL’s and Benworth PR’s centralized database
related to PPP servicing, and text messages for Bernardo Navarro and Claudia Navarro.
1. Defendants represented that Benworth FL and Benworth PR use the same email domain and
Microsoft Outlook accounts such that emails are sent to and from the same Benworth email address
Case 3:23-cv-01034-GMM     Document 182-20     Filed 12/06/24     Page 18 of 23

for both entities.
1. Defendants will confirm whether Benworth FL and Benworth PR use Microsoft Exchange.
2. Defendants represented that they have already pulled full PST files for the document custodians they
identified and did not run any search terms or other limiting parameters before collection.
1. Defendants believe they pulled PST files from 2021 to the present by using the arbitration PST
collections and refreshing them to the present.
2. The Reserve Bank requested that Defendants pull PST files from 2020 to the present.
3. Defendants will confirm the exact date from which the PST files have been pulled and get back
to the Reserve Bank about its request.
3. Defendants have pulled the centralized database related to servicing PPP loans but have not reviewed
it yet.
1. Defendants will verify whether the database is a server, cloud-based, or other type of system.
2. The Reserve Bank stated that this system is not amenable to search terms and requested all
loan files. Defendants represented that this is a centralized system where all loan files can be
found and represented that they will produce all loan files as they are maintained.
4. Defendants will follow up about collecting documents and information stored on document
custodians’ local folders, laptops, and computers.
5. Defendants have collected certain bank account statements from online bank accounts for Benworth
FL and Benworth PR and will produce them by Friday, October 11.
1. Defendants represented that Benworth FL had bank accounts with Professional Bank and TD
Bank that closed in 2023 and Defendants are investigating how to retrieve bank statements
from those accounts.
2. Defendants are currently determining the full list of bank accounts Benworth FL and Benworth
PR use and will follow up. Defendants asked whether Womply wanted bank statements for
accounts used for their clients’ mortgage-servicing business, and Womply stated that it needed
to be able to trace the flow of funds because this is a fraudulent transfer case and cash is
fungible.
6. Defendants represented that Benworth FL and Benworth PR do not use internal messaging or chat
systems, such as Slack.
7. Defendants will check whether Defendants or any document custodians conducted work-related
communications through external messaging apps, such as WhatsApp or Viber.
8. Defendants have not pulled personal emails or text messages for Bernardo Navarro or Claudia
Navarro. Defendants represented that Bernardo Navarro and Claudia Navarro do not discuss business
using personal email.
1. Womply stated that Bernardo Navarro’s text messages were collected and produced in the
Arbitration because he conducted business by text message, so they should also be collected
and produced in this litigation.
2. Defendants acknowledged that Benworth FL and Benworth PR personnel may have conducted
business through personal accounts and text messages, which would be discoverable.
Defendants believed the non-Defendant custodians’ phone data would not be responsive to
Womply’s document requests.
3. Womply agreed to review Defendants’ initial productions and reserved the right to seek
additional text messages, including from all document custodians.
7. Document Preservation: Defendants represented that they preserved text messages on Bernardo and
Claudia Navarro’s phones by turning off auto-delete functions. Defendants represented that non-Defendant
custodians were advised to take the same steps regarding preservation of mobile data as were taken to
preserve Bernardo and Claudia Navarro’s mobile data.
1. Defendants will get back to Womply about whether Mr. and Mrs. Navarro use iPhones and whether
data from their phones is backed up on iCloud.
2. Defendants will follow up about whether the Navarros’ phones have been imaged.
8. Privilege:
1. Defendants represented that they are not refusing to collect any documents based on privilege,
Case 3:23-cv-01034-GMM     Document 182-20     Filed 12/06/24     Page 19 of 23

including the attorney-client privilege and martial privilege. Defendants represented that they will
review collected documents for privilege and will identify any responsive, privileged documents they
are withholding on a privilege log.
9. Search Terms:
1. Womply agreed to search terms as a process for Defendants to identify documents responsive to its
documents requests. Womply did not agree to narrow the scope of its document requests based on
any search terms.
2. Womply and the Reserve Bank will confer and will jointly propose search terms to Defendants.
Hard Copy Documents:
10. Defendants represented that there are 10-15 bankers’ boxes of hard copy bank statements located in a
storage unit in Miami.
1. Defendants offered to make these boxes available for inspection and copying. Defendants stated that
they will not incur costs to scan these documents.
2. Womply stated that Defendants’ refusal to scan and copy these documents is inconsistent with the
parties’ ESI Stipulation.
3. The parties agreed to follow up about this issue in the next meet-and-confer call.
11. Defendants represented that Mildred Avila maintained a hard copy folder, which was produced in the
Arbitration. Defendants will follow up to confirm whether there are additional hard copy documents.
Plaintiffs’ Non-ESI Requests for Production:
12. Financial Documentation (Womply Request Nos. 1-3 to Benworth FL and Benworth PR; Reserve Bank
Request Nos. 1-3 to Benworth FL and Benworth PR): Benworth FL represented that it will produce audited
financial statements and bank statements for the years 2020 through 2022. Defendants stated that they are
amenable to further productions as needed by Womply and the Reserve Bank.
1. Womply stated that because solvency is an element of its claim it needs full financial information,
including unaudited financial statements, ledgers, quarterly reports, and any other financial
documentation. Defendants agreed to follow up about what financial documentation they possess.
2. The Reserve Bank requested audited financial statements for Benworth FL for 2023. Defendants
represented that there are no audited financial statements for Benworth FL for 2023 because
preparing audited financials was a requirement for its mortgage license and Benworth FL did not
renew its mortgage license. Defendants acknowledged that the Reserve Bank requested unaudited
financial statements and would follow up about these.
13. Taxes (Womply Request No. 4 to Benworth FL and Benworth PR; Reserve Bank Request No. 4 to Benworth FL
and Benworth PR): Defendants will produce tax returns for Bernardo Navarro and Claudia Navarro by Friday,
October 11.
1. Defendants objected to producing tax returns from Benworth FL and Benworth PR on the grounds
that they were unnecessary and invasive because the audited financials will already provide
substantial information.
2. Womply responded that any confidentiality concerns are fully addressed by the protective order, tax
returns contained different information from audited financials and bank statements, and tax returns
are directly relevant to Benworth FL’s solvency, which is an element of their claims.
1. Defendants agreed to follow up about this and represented that they would not unreasonably
withhold Benworth FL’s and Benworth PR’s tax returns.
14. Agreements (Womply Request No. 11 to Benworth FL and Benworth PR; Reserve Bank Request No. 14 to
Benworth FL and No. 12 to Benworth PR): Defendants represented that the LSA and ASLA are the only
agreements between Benworth FL and Benworth PR, and there are no other agreements between Benworth
FL and Benworth PR. Defendants represented that they will produce any discussions, drafts, or notes
regarding the LSA and ASLA.
15. Payments (including Womply Request No. 13 to Benworth FL and Benworth PR and Request Nos. 3 to
Bernardo and Claudia Navarro; Reserve Bank Request No. 16 to Benworth FL and No. 14 to Benworth PR and
Request Nos. 3 to Bernardo and Claudia Navarro): Womply requested the documents underlying the table
Defendants agreed to produce in response to these requests. Defendants represented that the table was
generated by Benworth employees exporting information from a database; it was not created by outside
Case 3:23-cv-01034-GMM     Document 182-20     Filed 12/06/24     Page 20 of 23

counsel.
1. Defendants will follow up to understand the scope of the documents used to create these tables and
will provide additional information to Womply and the Reserve Bank regarding those documents.
2. Womply stated that the underlying documents used to create these tables must be produced and
agreed to confer further on this issue after reviewing the table.
16. Confirmation/Vacatur Actions (Reserve Bank Request No. 41): Defendants agreed to produce to the Reserve
Bank unredacted versions of the sealed/redacted filings in the Motion to Confirm and Motion to Vacate
actions in the Northern District of California. Defendants represented that the parties did not exchange any
discovery in these actions.
17. Solicitation Process (Womply Request No. 16 to Benworth FL and Benworth PR and Request No. 8 to
Bernardo and Claudia Navarro; Reserve Bank Request No. 19 to Benworth FL and No. 17 to Benworth PR and
Request No. 12 to Bernardo and Claudia Navarro): Womply requested that Defendants produce all
documents in connection with the solicitation process without using search terms. Womply proposed that
Defendants search by the email domains of the companies that submitted proposals to capture all
documents sent to and from those companies.
1. Defendants represented that they will produce the solicitation proposals and accompanying cover
emails by Friday, October 11. Defendants also represented that Mr. Navarro communicated with
these companies by phone and then these companies submitted proposals, so there are very few
written communications related to the proposals, which Defendants agreed to produce.
2. Womply agreed to review Defendants’ initial production and reserved its rights to seek additional
documents and information.
18. Transfer Pricing Analysis (Womply Request No. 14 to Benworth FL and Benworth PR; Reserve Bank Request
No. 18 to Benworth FL and No. 16. To Benworth PR and Request No. 11 to Bernardo and Claudia Navarro):
Womply requested that Defendants produce all documents in connection with the transfer pricing analysis.
Womply proposed that Defendants search by the email domains of the accounting firms to capture all
documents and communications sent to or from these accounting firms. Defendants agreed to circle back
about this issue.
19. Navarro Entities (including Womply Request No. 6-7 to Bernardo and Claudia Navarro; Reserve Bank Request
No. 6-7 to Bernardo and Claudia Navarro): Defendants represented that, in response to Womply’s
interrogatories, Defendants will produce a full list of all B. Navarro and C. Navarro entities as defined by the
RFPs by Friday, October 11.
1. Womply and the Reserve Bank stated that any payments from Benworth FL or Benworth PR to any B.
Navarro and C. Navarro entities are highly relevant because they show Benworth FL and Benworth PR
paying the Navarros through entities they control.
2. Defendants disputed that all such payments were relevant, stated that they were still gathering
information on this issue, and represented that they were open to providing information in
connection with specifically identified entities. The Federal Reserve stated that it has no way of
knowing which entities are being used to channel funds and that Defendants must provide that
information.
3. Womply and the Federal Reserve agreed to review Defendants’ October 11 production and reserved
the right to seek further documents and information about B. Navarro and C. Navarro entities.
20. Corporate Structure (Womply Request No. 24 to Benworth FL; Reserve Bank Request Nos. 35 to Benworth
FL): Womply requested that Defendants produce corporate structure or formation documents for Benworth
FL, such as any operating or LLC agreements. Defendants stated that those documents were created before
the relevant time period. Womply responded that its requests seek such documents that were operative
during the relevant time period and, alternatively, requested that Defendants produce the discrete
documents requested even if they were created earlier. Defendants acknowledged that these were good
points and agreed to circle back about producing these documents.
Womply’s Interrogatories:
1. Defendants represented that they will produce all materials relied upon in formulating their responses to
Womply’s interrogatories, except for the accounting information obtained from a database underlying the
chart Defendants will produce. Defendants are investigating this database and how to produce the
Case 3:23-cv-01034-GMM     Document 182-20     Filed 12/06/24     Page 21 of 23

underlying information.
Regards,
Josh
From: Carla S. Loubriel Carrión <CLoubriel@cabprlaw.com>
Sent: Monday, October 7, 2024 9:54 PM
To: Kessler, Thomas <tkessler@cgsh.com>; Forbes, Alexandra L. <aforbes@cgsh.com>; Kohles, Mitchell
<mkohles@cgsh.com>; Schweitzer, Lisa M. <lschweitzer@cgsh.com>; antonio.roig@oneillborges.com;
ubaldo.fernandez@oneillborges.com; anibal.roman@oneillborges.com; Cheney, Alexander
<ACheney@willkie.com>; Levy, Joshua S. <JLevy@willkie.com>; Lombardi, Stuart <slombardi@willkie.com>; Morris,
Daniel L. <DMorris@willkie.com>; Morton, Adriana <AMorton@willkie.com>; Palmeri, Vincent
<VPalmeri@willkie.com>; Alejandro J. Cepeda Diaz <Ajc@mcvpr.com>; Arturo J. Garcia <Ajg@mcvpr.com>;
Gabriela A. Pérez-Vélez <Gpv@mcvpr.com>
Cc: Monica Ramos Benitez <mramos@ferraiuoli.com>; Jaime Torrens Dávila <jtorrens@ferraiuoli.com>; Camara
Fuertes, Roberto <rcamara@ferraiuoli.com>; Ricardo Casellas <RCasellas@cabprlaw.com>; Jorge L. Piedra
<jpiedra@kttlaw.com>; Rasheed Nader <rnader@kttlaw.com>; Michael Lorigas <mlorigas@kttlaw.com>; Dwayne
Robinson <drobinson@kttlaw.com>
Subject: Defendants Responses to Discovery (Oto Analytics LLC v. Benworth Capital Partners PR LLC, et al.)
*** EXTERNAL EMAIL ***
Counsel,
Attached are each Defendant’s responses to Womply’s and the Reserve Bank’s respective discovery requests.
Despite diligent efforts to fully answer all the interrogatories by today, we will need to supplement certain
interrogatory answers and anticipate doing so by this Friday. With respect to our document production, the first
wave of our rolling production is currently being processed by our eDiscovery vendor. However, due to the amount
of data being processed, we are advised that the documents may not be ready for production until this Friday. If we
are able to provide the supplemental interrogatory answers and document production in advance of the meet and
confer call scheduled for this Thursday, we will do so.
Best,
GAM Tower, Suite 400 • 2 Tabonuco St. • San Patricio, PR 00968
PO Box 364924 • San Juan, PR 00936-4924 •
(787) 756-1400 •
(787) 756-1401
Visit us at our website: www.cabprlaw.com.
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Carla S. Loubriel Carrión, Esq.
Casellas Alcover & Burgos, P.S.C.
Case 3:23-cv-01034-GMM     Document 182-20     Filed 12/06/24     Page 22 of 23

legally privileged. Please do not read, copy, forward or store this message unless you are an intended recipient of it. If
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Case 3:23-cv-01034-GMM     Document 182-20     Filed 12/06/24     Page 23 of 23

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