Womply’s Opposition to Motion to Quash Service of Process — OTO Analytics v. Benworth (D.E. 52) (N.D. Cal. No. 3:24-cv-03975)

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U.S. District Court for the District of Puerto Rico · No. 3:23-cv-01034-GMM · Doc. 52 · 2023-04-27 · Docket on CourtListener

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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 
 
 
 
 
  
 
PLAINTIFF WOMPLY’S MEMORANDUM OF LAW IN OPPOSITION TO 
BERNARDO NAVARRO AND CLAUDIA NAVARRO’S MOTION TO QUASH 
 
Alexander L. Cheney (admitted pro hac vice) 
Willkie Farr & Gallagher LLP 
One Front Street  
San Francisco, CA 94111 
(415) 858-7400 
acheney@willkie.com 
 
Joshua S. Levy (admitted pro hac vice) 
Willkie Farr & Gallagher LLP 
1875 K Street, N.W. 
Washington, D.C. 20006 
(202) 303-1000 
jlevy@willkie.com 
 
 
 
 
 
 
 
 
Alejandro J. Cepeda Diaz 
USDC-PR 222110 
McConnell Valdés LLC 
270 Muñoz Rivera Ave. 
Hato Rey PR 00918 
Tel: (787) 250-5637 
Email: ajc@mcvpr.com 
 
 
 
 
 
Attorneys for Plaintiff Oto Analytics, LLC 
 
 
 
April 27, 2023 
 
 
 
Case 3:23-cv-01034-GMM   Document 52   Filed 04/27/23   Page 1 of 13

 
TABLE OF CONTENTS 
TABLE OF AUTHORITIES .......................................................................................................... ii 
PRELIMINARY STATEMENT .....................................................................................................1 
BACKGROUND .............................................................................................................................2 
A. 
Womply Serves Benworth PR, 
........................2 
B. 
Womply Attempts To Serve The Navarros’ Listed Puerto Rico Address. ..............4 
C. 
Womply Attempts To Serve The Navarros’ Florida Home. ....................................4 
D. 
The Navarros’ Counsel Have Each Received And Reviewed The 
Complaint But Refuse To Accept Service. ..............................................................5 
ARGUMENT ...................................................................................................................................6 
CONCLUSION ................................................................................................................................8 
CERTIFICATE OF SERVICE ......................................................................................................10 
 
 
Case 3:23-cv-01034-GMM   Document 52   Filed 04/27/23   Page 2 of 13

ii 
TABLE OF AUTHORITIES 
 
Page(s) 
Cases 
Awadh v. Tourneau, Inc., 
2017 WL 1246326 (D. Mass. Feb. 17, 2017) ............................................................................2 
Calderón Serra v. Banco Santander P.R., 
747 F.3d 1 (1st Cir. 2014) ..........................................................................................................8 
Farb v. Perez-Riera, 
293 F.R.D. 77 (D.P.R. 2013) .....................................................................................................9 
González-Droz v. González-Colón, 
2009 WL 2843338 (D.P.R. Aug. 31, 2009) ...........................................................................7, 8 
Hasebrouck v. Great Lengths Int’l, 
2008 WL 11502476 (D.P.R. Mar. 27, 2008) .........................................................................7, 8 
Henderson v. United States, 
517 U.S. 654 (1996) ...................................................................................................................6 
Live Well Fin., Inc. v. Estate of Santana Martinez, 
2020 WL 12188413 (D.P.R. Jan. 14, 2020)...............................................................................8 
Ramírez de Arellano v. Collloïdes Naturels Int’l, 
236 FR.D. 83 (D.P.R. 2006) ......................................................................................................6 
Rules 
Fed. R. Civ. P. 4(e)(1) ..................................................................................................................1, 8 
Fed. R. Civ. P. 4(e)(2)(B) ........................................................................................................1, 7, 8 
Fed. R. Civ. P. 12(b)(5)................................................................................................................2, 6 
P.R. Law Ann. tit. 32, app. V, R. 4.5 ...........................................................................................1, 8 
P.R. Law Ann. tit. 32, app. V, R. 4.6 ...............................................................................................8 
Other Authorities 
4A Charles A. Wright, Arthur R. Miller, et al., Federal Practice and Procedure 
§ 1094 (4th ed. 2023) .................................................................................................................6 
4A Charles A. Wright, Arthur R. Miller, et al., Federal Practice and Procedure 
§ 1096 (4th ed. 2023) .................................................................................................................7 
Case 3:23-cv-01034-GMM   Document 52   Filed 04/27/23   Page 3 of 13

 
Plaintiff Oto Analytics, LLC (f/k/a Oto Analytics, Inc. d/b/a Womply) (“Womply”) 
respectfully submits this memorandum of law in opposition to Bernardo Navarro (“Mr. Navarro”) 
and Claudia Navarro’s (“Ms. Navarro”; together with Mr. Navarro, the “Navarros”) Motion To 
Quash Service Of Process (“Motion” or “Mot. to Quash”; ECF No. 37). 
PRELIMINARY STATEMENT 
Womply filed this action on January 24, 2023, and has repeatedly provided copies of the 
Complaint to the Navarros’ counsel.  The Navarros do not dispute that they have actual notice of 
this action and do not dispute that their counsel have reviewed and analyzed the Complaint.  The 
Navarros nonetheless refuse to accept service of process, and their counsel refuse to speak to 
Womply’s counsel about this issue.  Instead, the Navarros are evading service and filed this Motion 
challenging “the manner in which the process or service of process was performed.”  (Mot. to 
Quash at 3 (cleaned up).)  The Motion is meritless, and Womply regrets that the Navarros have 
wasted both this Court’s and Womply’s resources by filing it instead of waiving service. 
As the accompanying declarations show, Womply has served or attempted to serve the 
Navarros eight times at three different addresses, including at (i) the offices of Benworth Capital 
Partners PR LLC (“Benworth PR”), 
, where service was 
accepted by the Office Administrator; (ii) the Puerto Rico home address listed on the Navarros’ 
drivers’ licenses and on their bank account application; and (iii) the Navarros’ last known home 
address in Florida.  The Navarros admit that “service of process at the individual’s home” is 
sufficient under the Federal Rules of Civil Procedure (the “Federal Rules”), so their Motion 
should be denied.  (Mot. to Quash at 6–7 (citing Fed. R. Civ. P. 4(e)(2)(B)).) 
Should this Court hold that Womply has not yet validly served the Navarros, Womply 
requests leave to serve the Navarros by publication, which is expressly permitted under 
Puerto Rico law.  See P.R. Law Ann. tit. 32, app. V, R. 4.5; Fed. R. Civ. P. 4(e)(1). 
Case 3:23-cv-01034-GMM   Document 52   Filed 04/27/23   Page 4 of 13

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BACKGROUND1 
Womply filed this action on January 24, 2023, and asked counsel for Defendant Benworth 
Capital Partners LLC (“Benworth FL”; collectively with Benworth PR and the Navarros, 
“Defendants”) whether they would accept service.  (ECF No. 1; Ex. 1.)  They never responded.  
(Id.; Levy Decl. ¶ 3.)  The next day, the Clerk of the Court issued Summonses for Defendant 
Benworth FL, Defendant Benworth PR, Defendant Mr. Navarro, and Defendant Ms. Navarro.  
(ECF No. 6.)  For the past four months, Womply has been making efforts to serve all Defendants, 
but the Navarros have sought to avoid being served. 
A. 
Womply Serves Benworth PR, 
. 
Benworth PR is a limited liability company organized under the laws of Puerto Rico with 
its principal place of business located at 221 Avenida Ponce De Leon, Suite 1401, San Juan, Puerto 
Rico 00917.  (Complaint dated Jan. 24, 2023 (“Complaint” or “Compl.”; ECF No. 1) ¶¶ 22, 34.d.)  
  (Id.)  
 
  (Id. ¶¶ 11, 24, 197, 
200.)  
  (Id. ¶¶ 25, 200.)   
On February 2, 2023, a process server for Womply delivered the Summonses and 
Complaint at Benworth PR’s offices to Maria de la Cruz, who was the “authorized person to 
receive the summons” for Benworth PR.  (Ex. 2 (Pérez Decl.) ¶ 2.)  The process server asked for 
Mr. Navarro and Ms. Navarro, and Ms. de la Cruz represented that “Claudia Navarro never goes 
to the office, Bernardo Navarro rarely comes to the office, and, when he does, it is for a short 
time.”  (Id.)  She further represented that she was not authorized to accept the Summonses on 
                                                 
1 On a Rule 12(b)(5) motion, “the Court accepts as true the facts alleged in [the] complaint,” and 
“[t]he Court may consider such matters outside of the pleadings.”  Awadh v. Tourneau, Inc., 2017 
WL 1246326, at *1 n.2 (D. Mass. Feb. 17, 2017) (collecting cases).  All reference to “Ex.” refer 
to exhibits to the accompanying declaration of Joshua S. Levy (“Levy Decl.”). 
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behalf of Mr. Navarro or Ms. Navarro and refused to provide their contact information.  (Id.)  The 
process server provided his contact information to Ms. de la Cruz and asked the Navarros to contact 
him.  (Id.)  They did not do so.  (Id.) 
The next day, a process server for Womply returned to Benworth PR’s offices and asked 
for Mr. Navarro and Ms. Navarro.  (Id. ¶ 3.)  He spoke to Ms. de la Cruz who represented that 
Mr. Navarro “was out of Puerto Rico” and refused to provide additional information.  (Id.) 
On February 7, 2023, a process server for Womply again delivered the Summonses and 
Complaint to Benworth PR’s offices, which was accepted by Office Administrator 
Alondra Gómez, who represented that she was “authorized to accept service on behalf of” 
Benworth PR, Mr. Navarro, and Ms. Navarro.  (ECF Nos. 22–24.)   
On April 20, 2023, a process server for Womply again went to Benworth PR’s offices and 
spoke to Aida Medina, whose LinkedIn profile lists her as an “Accounting Bookkeeper” for 
“Benworth Capital” in “San Juan, Puerto Rico.”  (Ex. 2 (Pérez Decl.) ¶ 5; Ex. 3.)  Ms. Medina 
represented that neither Mr. Navarro nor Ms. Navarro were available, Mr. Navarro “rarely comes 
to the office,” and “it was going to be very hard to serve him at the office location.”  (Ex. 2 (Pérez 
Decl.) ¶ 5.)  She refused to provide any additional information.  (Id.)  The process server offered 
to provide his contact information, and Ms. Medina represented that “they” already had it.  (Id.)  
The process server then waited in the lobby of Benworth PR’s office for over two hours but did 
not see the Navarros.  (Id. ¶ 6.) 
The next day, a process server for Womply returned to Benworth PR’s offices and spoke 
to Ms. Medina.  Ms. Medina again represented that neither Mr. Navarro nor Ms. Navarro were 
available and refused to provide any additional information.  (Id. ¶ 7.) 
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B. 
Womply Attempts To Serve The Navarros’ Listed Puerto Rico Address. 
The Navarros list 
 as 
their 
“home 
address” 
on 
their 
Puerto 
Rico 
drivers’ 
licenses. 
 
(Ex. 
4 
(BENWORTHPROD_0096384).)  They also provided this address as their “home address” on a 
bank account application.  (Id.)  On April 19, 2023, a process server for Womply went to this 
address.  (Ex. 2 (Pérez Decl.) ¶ 4.)  He was unable to enter the apartment building but spoke to 
“Lisa,” who was standing on the balcony of 
 (she refused to give her last name).  
(Id.)  “Lisa” represented that she has lived in the apartment for the past 30 years and did not know 
Mr. Navarro or Ms. Navarro.  (Id.) 
C. 
Womply Attempts To Serve The Navarros’ Florida Home. 
A public records search identified 
 as the 
Navarros’ last known home address.  (Levy Decl. ¶ 7.)  According to Miami-Dade County public 
records, the Navarros purchased this home in 2005.  (Id.)  On May 12, 2021, the Navarros 
transferred this property to the Ocean Terrace Family Trust.  (Id.)  The mailing address of the 
Ocean Terrace Family Trust is 700 Biltmore Way, Suite C1, Miami, Florida 33134.  (Id.)  On its 
website, Benworth FL lists its address as 700 Biltmore Way, Suite C1, Miami, Florida 33134.  
(Ex. 5.)  Benworth FL’s sole member and equity holder is Mr. Navarro.  (Compl. ¶¶ 23–24.) 
On April 25, 2023, a process server for Womply went to 
 
.  (Ex. 6 (Brady Decl. B. Navarro) ¶ 4; Ex. 7 (Brady Decl. C. Navarro) ¶ 4.)  The address 
has a gated entrance with an intercom callbox.  (Id.)  The process sever rang the call box several 
times but no one answered, so he was unable to enter the property.  (Id.)  There was a Range Rover 
in the driveway of the address with a Florida license plate.  (Id.)  A public records search of the 
license plate number identified that the Range Rover was registered to Gilberto Navarro, who is 
Mr. Navarro’s father and a Benworth FL employee.  (Ex. 8; Ex. 9 (Navarro Dep.) at 16:19–17:9.) 
-
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The next day, the process server returned to the address.  (Ex. 6 (Brady Decl. B. Navarro) 
¶ 5; Ex. 7 (Brady Decl. C. Navarro) ¶ 5.)  The Range Rover was parked in the driveway but no 
one answered the call box so he was unable to enter the property.  (Id.)  The process server also 
called Benworth FL’s offices to inquire whether the Navarros were there.  (Ex. 6 (Brady Decl. B. 
Navarro) ¶ 6; Ex. 7 (Brady Decl. C. Navarro) ¶ 6.)  The Benworth FL employee who answered the 
phone represented that they were not there and were not in Miami.  (Id.) 
D. 
The Navarros’ Counsel Have Each Received And Reviewed The Complaint 
But Refuse To Accept Service. 
On February 28, 2023, Benworth PR’s counsel appeared as counsel for Ms. Navarro.  (ECF 
No. 25.)  On February 28 and March 1, 2023, Benworth FL’s counsel appeared as counsel for 
Mr. Navarro.  (ECF Nos. 26–30.)  On March 27, 2023, after reviewing the Complaint, Benworth 
PR moved to dismiss or stay proceedings pending the outcome of the Arbitration.  (ECF No. 34.)  
On March 29, 2023, Benworth FL moved to join Benworth PR’s Motion.  (ECF No. 35.)  Neither 
Benworth PR nor Benworth FL has contested service.  (ECF Nos. 34–35.)  On March 30, 2023, 
the Navarros, represented by counsel for Benworth PR and Benworth FL, moved to quash 
Womply’s service of process.  (ECF No. 37.) 
On April 4–5, 2023, counsel for Womply contacted both Puerto Rico and Florida counsel 
for Defendants by email and telephone to 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 [Bernardo] and Claudia Navarro, which will avoid them having process servers serve them 
personally.”  (Ex. 10.)  After delaying for over a week, Defendants’ counsel responded that 
“Benworth, Benworth PR, and Mr. and Mrs. Navarro do not agree to any of the three parts of your 
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proposal.”  (Id.)  Defendants’ counsel did not return calls to discuss this issue.  (Levy Decl. ¶¶ 13–
14, 16.) 
ARGUMENT 
“[T]he core function of service is to supply notice of the pendency of a legal action.”  
Henderson v. United States, 517 U.S. 654, 672 (1996).  Service is governed by Rule 4, which is 
“interpreted broadly if defendant[s] received actual notice of [the] action.”  4A Charles A. Wright, 
Arthur R. Miller, et al., Federal Practice and Procedure § 1094 (4th ed. 2023) (collecting cases).  
A party “contesting the manner in which process of service was performed” under Rule 12(b)(5) 
has “the absolute burden of specifically establishing to the Court how plaintiff failed to satisfy the 
requirements of the service provision utilized.”  Ramírez de Arellano v. Collloïdes Naturels Int’l, 
236 FR.D. 83, 85 (D.P.R. 2006) (collecting cases).  “[D]ismissal of the action under Fed. R. Civ. 
P. 12(b)(5) is inappropriate when there is a ‘reasonably conceivable means’ through which service 
may be obtained.”  Id. at 85 n.4 (collecting cases).  Womply has repeatedly served the Navarros, 
who do not dispute that they have received actual notice of this action. 
First, Womply served the Navarros at Benworth PR’s office.  The Navarros do not dispute 
that 
 and acknowledge that Womply served the Summonses and 
Complaint on the Benworth PR “Office Administrator” Ms. Gómez, who represented that “she 
was authorized to accept service on behalf of Mr. and Mrs. Navarro.”  (Mot. to Quash at 2.)  The 
Navarros claim that, unbeknownst to Womply, Ms. Gómez was not “authorized by Mr. and Mrs. 
Navarro to receive process on their behalf.”  (Id. at 4–5.)  But where, as here, “Defendants have 
received actual notice in time to preserve their rights and do not claim any prejudice,” courts in 
this District accept even “[s]ervice of process that is technically incorrect” and order “Defendants 
to answer the complaint” while service is perfected.  Hasebrouck v. Great Lengths Int’l, 2008 WL 
11502476, at *4 (D.P.R. Mar. 27, 2008) (collecting cases); see also González-Droz v. González-
Case 3:23-cv-01034-GMM   Document 52   Filed 04/27/23   Page 9 of 13

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Colón, 2009 WL 2843338, at *3 (D.P.R. Aug. 31, 2009) (“deem[ing] all parties as properly 
served,” despite untimely service without good cause, because it was “reasonable to infer that Co–
Defendants were aware of the claims asserted against them” and “Co–Defendants have not shown 
that the delay has affected their ability to defend themselves on the merits”). 
Second, Womply attempted to serve the Navarros at their home address.  The Navarros 
admit that the Federal Rules “allow[] an individual to be served by ‘leaving a copy of [the 
Summons and Complaint] at the individual’s dwelling or usual place of abode with someone of 
suitable age and discretion who resides there.’”  (Mot. to Quash at 6 (quoting Fed. R. Civ. P. 
4(e)(2)(B)).)  “[T]he fact of actual notice control[s] the application” of Rule 4(e)(2)(B), which 
“should be liberally construed to effectuate service and uphold the jurisdiction of the court, thus 
insuring the opportunity for a trial on the merits.”  4A Wright & Miller § 1096 (cleaned up; 
collecting cases).  Accordingly, courts hold that, where, as here, defendants have received actual 
notice, serving process to an address listed “on forms” or to a “former residence” is sufficient.  Id. 
(collecting cases). 
Womply attempted to serve the Navarros at the address they listed on their Puerto Rico 
drivers’ licenses and bank account applications.  (See supra Background Section B.)  Womply also 
attempted to serve the Navarros at their last known address in Florida.  (See supra Background 
Section C.)  Because the Navarros have actual notice of this action, this Court should “deem all 
parties as properly served” pursuant to Rule 4(e)(2)(B).  González-Droz, 2009 WL 2843338, at *3. 
Third, should this Court hold that the Navarros have not yet been validly served, Womply 
requests leave to serve the Navarros by publication.  The Navarros admit that the Federal Rules 
“provide[] that an individual may be served by ‘following state law for serving a summons in an 
action brought in courts of general jurisdiction in the state where the district court is located or 
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where service is made.’”  (Mot. to Quash at 4 (quoting Fed. R. Civ. P. 4(e)(1).)  Puerto Rico law 
provides that “[t]he court shall issue an order providing for summons by publication” in a 
“newspaper of general circulation in Puerto Rico” where “the person to be served . . . could not be 
located even after pertinent efforts have been made” and the movant provides “an affidavit stating 
the efforts made.”  Calderón Serra v. Banco Santander P.R., 747 F.3d 1, 8 (1st Cir. 2014) 
(emphasis added) (quoting P.R. Law Ann. tit. 32, app. V, R. 4.6).2  Womply has submitted five 
declarations showing that Womply has sought to serve the Navarros eight times at three different 
addresses, which is more than sufficient to warrant service by publication.  See, e.g., Calderón 
Serra, 747 F.3d at 8–9 (affirming service by publication based on a single affidavit showing “last 
known address”); see also Hasebrouck, 2008 WL 11502476, at *1 (“The Puerto Rico court 
authorized service by publication . . . .”); Live Well Fin., Inc. v. Estate of Santana Martinez, 2020 
WL 12188413, at *1 (D.P.R. Jan. 14, 2020) (granting plaintiff additional time “to serve 
process . . . by publication”); Farb v. Perez-Riera, 293 F.R.D. 77, 79 (D.P.R. 2013) (“grant[ing] 
Plaintiff an additional term of ten days to correctly serve Perez Riera through publication”).3 
CONCLUSION 
For the foregoing reasons, Womply respectfully requests that this Court deny the Navarros’ 
Motion in its entirety.  In the alternative, Womply respectfully requests leave to serve the Navarros 
by publication. 
                                                 
2 Puerto Rico law is considered “state law” for purposes of Rule 4(e)(1).  See Calderón Serra, 747 
F.3d at 8.  Under the 2020 amendments to the Puerto Rico Civil Code, which have not yet been 
translated, former Rule 4.6 was restyled as Rule 4.5 but was not substantively changed.  P.R. Law 
Ann. tit. 32, app. V, R. 4.5. 
 
3 To the extent this Court also requires Womply to submit an affidavit attesting to the merits of its 
case, Womply submits the documents and testimony on which it relied to prepare and investigate 
the Complaint, including the sworn declaration of Womply’s CEO (Ex. 11), sworn deposition 
testimony of Mr. Navarro (Exs. 9, 12), and agreements between Benworth and Benworth PR 
(Exs. 13–14). 
Case 3:23-cv-01034-GMM   Document 52   Filed 04/27/23   Page 11 of 13

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Dated: April 27, 2023 
 
 
Of Counsel: 
 
Willkie Farr & Gallagher LLP 
 
By: Alexander L. Cheney         
 
Alexander L. Cheney (admitted pro hac vice) 
One Front Street  
San Francisco, CA 94111 
(415) 858-7400 
acheney@willkie.com 
 
Joshua S. Levy (admitted pro hac vice) 
1875 K Street, N.W. 
Washington, D.C. 20006 
(202) 303-1000 
jlevy@willkie.com 
 
 
 
 
 
 
 
Respectfully submitted, 
 
By: Alejandro J. Cepeda Diaz         
 
Alejandro J. Cepeda Diaz 
USDC-PR 222110 
McConnell Valdés LLC 
270 Muñoz Rivera Ave. 
Hato Rey PR 00918 
Tel: (787) 250-5637 
Email: ajc@mcvpr.com 
 
 
 
Attorneys for Plaintiff Oto Analytics, LLC 
 
 
 
 
 
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CERTIFICATE OF SERVICE 
The undersigned certifies that on April 27, 2023, the foregoing document was filed with 
the Clerk of the Court using CM/ECF, which sent notices to all parties receiving notifications 
through the CM/ECF system. 
Dated: April 27, 2023  
 
 
 
By: /s/ Alejandro J. Cepeda Diaz 
Attorney for Plaintiff Oto Analytics, LLC 
 
 
 
Case 3:23-cv-01034-GMM   Document 52   Filed 04/27/23   Page 13 of 13

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