Attorney declaration in support of opposition to motion to dismiss — OTO Analytics v. Benworth

Summary

The Declaration of Alexander L. Cheney in Support of Plaintiff Womply's Opposition to the Motions to Dismiss of Benworth Capital Partners PR LLC and Benworth Capital Partners LLC, in Oto Analytics, LLC v. Benworth Capital Partners PR LLC, et al., Civil Action No. 23-01034, in the U.S. District Court for the District of Puerto Rico, executed the 24th day of April 2023 and filed 04/24/23 as Document 47-1. Cheney, an attorney at Willkie Farr & Gallagher, LLP, counsel for Womply, states that the fact hearing in JAMS arbitration Ref. No. 1210038203 between Womply and Benworth FL took place March 20–28, 2023, with closing arguments scheduled for June 15, 2023. The declaration attaches an April 2023 email thread between counsel and English translations of the Puerto Rico Supreme Court decisions in Sucesión Almazán v. López and De Jesus Díaz v. Carrero. It is signed /s/ Alexander L. Cheney.

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

Record facts

Full text

IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF PUERTO RICO 
 
OTO ANALYTICS, LLC, 
 
Plaintiff, 
 
v. 
 
BENWORTH CAPITAL PARTNERS PR 
LLC, BENWORTH CAPITAL PARTNERS 
LLC, BERNARDO NAVARRO and 
CLAUDIA NAVARRO, 
 
Defendants. 
§ 
§ 
§ 
§ 
§ 
§ 
§ 
§ 
§ 
§ 
§ 
 
 
Civil Action No. 23-01034 
 
 
 
 
  
 
 
DECLARATION OF ALEXANDER L. CHENEY IN SUPPORT OF PLAINTIFF 
WOMPLY’S OPPOSITION TO BENWORTH CAPITAL PARTNERS PR LLC’S AND 
BENWORTH CAPITAL PARTNERS LLC’S MOTIONS TO DISMISS 
 
I, Alexander L. Cheney, pursuant to 28 U.S.C. § 1746, hereby declare as follows:  
1. 
I am a member of the bars of California and New York, am admitted pro hac vice 
in the United States District Court for the District of Puerto Rico, and am an attorney at the law 
firm of Willkie Farr & Gallagher, LLP, counsel for Plaintiff Oto Analytics, LLC, d/b/a Womply 
(f/k/a Oto Analytics, Inc.) (“Womply”).  
2. 
I respectfully submit this declaration in support of Womply’s Opposition to 
Defendant Benworth Capital Partners PR LLC’s and Defendant Benworth Capital Partners LLC’s 
(“Benworth FL”) Motions to Dismiss in the above-captioned action. 
3. 
In the JAMS arbitration between Womply and Benworth FL, JAMS Ref. No. 
1210038203, the fact hearing was held on March 20–28, 2023, and closing arguments are 
scheduled for June 15, 2023. 
Case 3:23-cv-01034-GMM   Document 47-1   Filed 04/24/23   Page 1 of 2

 
-2- 
 
4. 
Attached hereto as Exhibit 1 is a true and correct copy of an email thread between 
counsel for Womply and counsel for Benworth FL and Defendant Bernardo Navarro, dated April 5 
to April 13, 2023. 
5. 
Attached hereto as Exhibit 2 is a true and correct copy of a certified English 
translation of the Puerto Rico Supreme Court’s decision in Sucesión Almazán v. López, 20 P.R. 
Dec. 537, 1914 WL 5079 (1914). 
6. 
Attached hereto as Exhibit 3 is a true and correct copy of an official English 
translation of the Puerto Rico Supreme Court’s decision in De Jesus Díaz v. Carrero, 112 P.R. 
Dec. 631, 12 P.R. Offic. Trans. 786 (1982), which was obtained from Westlaw. 
Executed this 24th day of April 2023 in San Francisco, California. 
 
 
 
 
 
 
 
 
/s/_Alexander L. Cheney_________ 
Alexander L. Cheney 
 
Case 3:23-cv-01034-GMM   Document 47-1   Filed 04/24/23   Page 2 of 2

File and source

File

gov.uscourts.prd.175040.47.1.pdf

Size

417,056 bytes

SHA-256

9912b7ef4d0d83ce65f07d0c5e7ab83006167ec10ff0efd559ffe8324461d92c

Our copy

gov.uscourts.prd.175040.47.1.pdf

Original

PACER (login required)