Navarros’ Reply in Support of Motion to Quash Service of Process — OTO Analytics v. Benworth (D.E. 64) (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. 64 · 2023-05-15 · 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 No. 23-01034 (GMM) 
 
 
 
JOINT REPLY TO OPPOSITION TO MOTION TO QUASH SERVICE OF PROCESS 
PURSUANT TO FED. R. CIV. P. 12(b)(5) 
 
TO THE HONORABLE COURT: 
 
 
COME NOW codefendants Bernardo and Claudia Navarro (“Mr. and Mrs. Navarro”), by 
special appearance and without submitting to the jurisdiction or venue of this Honorable Court nor 
waiving any defense, through the undersigned counsel, and very respectfully file the instant reply1 
to Plaintiff Womply’s Memorandum of Law in Opposition to Bernardo Navarro and Claudia 
Navarro’s Motion to Quash (the “Opposition”) (D.E. 54), and in further support of their Motion 
to Quash Service of Process Pursuant Fed. R. Civ. P. 12(b)(5) (the “Motion to Quash”) (D.E. 37). 
On March 30, 2023, Mr. and Mrs. Navarro filed the Motion to Quash demonstrating that 
plaintiff Oto Analytics, LLC f/k/a Oto Analytics, Inc. d/b/a Womply (“Womply”) failed to comply 
with any of the options allowed under Fed. R. Civ. P. 4(e) to effectively serve them in their 
individual capacity. (D.E. 37). First, service was insufficient under subsections (A) or (B) of Fed. 
R. Civ. P. 4(e)(2), or the state law governing summons under Fed. R. Civ. P. 4(e)(1), because Mr. 
 
1 On May 5, 2023, Mr. and Mrs. Navarro were granted leave to reply and an extension until today to do so. (D.E. 
60). 
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Joint Reply to Opposition to Motion to Quash Service of Process… 
Oto Analytics, LLC v. Benworth Capital Partners PR LLC, et al. 
Civil No. 23-01034 (GMM) 
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and Mrs. Navarro were not served personally or through someone of suitable age and discretion 
who resides at their home or usual place of abode.  Second and most important, service is also 
deficient under subsection (C) of Fed. R. Civ. P. 4(e)(2), governing service through an individual’s 
authorized agent, since Ms. Alondra Gómez (“Gómez”), who the process server described as an 
“Office Administrator,” is not an agent authorized by appointment or by law to receive service on 
behalf of Mr. and Mrs. Navarro.  Consequently, the service claimed as to Mr. and Mrs. Navarro 
and addressed at D.E. 37 should, indeed, be quashed under Fed. R. Civ. P. 12(b)(5) and Womply 
should be required to effectuate service in compliance with the law. 
Faced with the unsurmountable task of showing that the deficient service attempted as to 
Mr. and Mrs. Navarro can somehow withstand the attack under Fed. R. Civ. P. 12(b)(5), on April 
27, 2023, Womply filed the Opposition. (D.E. 52). Womply’s 8-page submission is not a challenge 
to the Motion to Quash but an attempted escape hatch to belatedly move for service by publication, 
without having shown good cause nor requesting an extension of the 90-day term to serve the 
defendants. That explains why Womply expends pages with narrative (and even refers to five 
declarations) of supposed failed efforts to try to serve Mr. and Mrs. Navarro, many of those efforts 
after the Motion to Quash was filed on March 27,2 while advancing in various instances its request 
for service by publication “should this Court hold that the Navarros have not yet been validly 
served.” Id., at p. 7. Nonetheless, Mr. and Mrs. Navarro will address seriatim the three (3) 
 
2 For instance, Womply refers to efforts made on April 4-5, 2023 (D.E. 54, at p. 8 “On April 4-5, 2023, counsel for 
Womply contacted Puerto Rico and Florida counsel for Defendant by email and telephone to propose that […] counsel 
accept service for [Bernardo] and Claudia Navarro, which will avoid them having process servers serve them 
personally”), April 19, 2023 (id., at p. 7 “On April 19, 2023, a process server for Womply went to this address”), April 
20, 2023 (id., at p. 6, “On April 20, 2023, a process server for Womply again went…”), April 21, 2023 (id., “The next 
day, a process server for Womply returned…”), April 25, 2023 (id., at p. 7 “On April 25, 2023, a process server for 
Wemply went to…”), and April 26, 2023 (id., at p. 8 “The next day, the process server returned to the address”). None 
of those efforts are relevant to the Motion to Quash filed on March 30, 2023, and thus, should be disregarded. 
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Joint Reply to Opposition to Motion to Quash Service of Process… 
Oto Analytics, LLC v. Benworth Capital Partners PR LLC, et al. 
Civil No. 23-01034 (GMM) 
Page 3 of 11 
 
arguments of the Opposition, one of them being the request to serve by publication. 
First, Womply argues, in conclusory fashion, that it “served the Navarros at Benworth PR’s 
office.” (D.E. 54, at p. 9). However, as expected, Womply did not challenge the core contention 
of Mr. and Mrs. Navarro that the service attempted through Ms. Gómez is deficient. There is no 
argument, much less any legal support, in the Opposition explaining the validity of the attempted 
service as to Mr. and Mrs. Navarro by leaving the Summonses and the Complaint with Ms. Gómez 
based on the process server’s understanding that Ms. Gómez represented that “she was authorized 
to accept service on behalf of Mr. and Mrs. Navarro.” Id. Considering the declarations under 
penalty of perjury to the contrary submitted by Mr. and Mrs. Navarro at D.E. 37-1 and 37-2, 
Womply has not met the required burden of proving that service through Ms. Gómez was in fact 
proper. Somascan, Inc. v. Phillips Med. Sys. Nederland B.V., Civil No. 09-1139 (ADC), 2009 WL 
4730771, at *3 (D.P.R. Nov. 13, 2009) (internal citation omitted). Specifically, Womply failed to 
submit evidence of Ms. Gómez’s “actual appointment for the specific purpose of receiving 
process.” See, e.g., Nyholm v. Pryce, 259 F.R.D. 101, 104 (D.N.J. 2009) (“[t]he burden remains 
on the plaintiff to prove that an agency relationship existed between the [defendant] and [the 
individual who accepted service].”). Thus, Womply did not prove that Mr. and Mrs. Navarro 
intended to confer Ms. Gómez with the specific authority to receive process. See 5A C. Wright & 
A. Miller, Federal Practice and Procedure § 1097 (3d ed. 2002), cited in Fernández-Salicrup v. 
Figueroa-Sancha, Civil No. 10-1975 (ADC), 2011 WL 13135962, at *2 (D.P.R. May 2, 2011).  As 
a result, the Motion to Quash stands unopposed regarding the insufficiency of service under 
subsection (C) of Fed. R. Civ. P. 4(e)(2) and Rule 4.4(a) of the Puerto Rico Rules of Civil 
Procedure, P.R. Laws Ann. tit. 32 Ap. V, R. 4.4(a), and should be granted on this ground. 
Mindful that the service attempted through Ms. Gómez is deficient and fails to comply with 
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Joint Reply to Opposition to Motion to Quash Service of Process… 
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Civil No. 23-01034 (GMM) 
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the procedural rules, Womply ventures to assert that “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,” quoting from Ha[e]sebrouck v. Great Lenghts Int’l, Civ. 
No. 07-1574 (JAF),2008 WL 11502476, at *4 (D.P.R. Mar. 27, 2008) (collecting cases), and 
González-Droz v. González, Civil No. 06–2263(SEC), 2009 WL 2843338, at *3 (D.P.R. Aug. 31, 
2009). (D.E. 54, at p. 9). As Mr. and Mrs. Navarro will show, Womply’s reliance in Haesebrouck 
and González-Droz is misplaced, inapposite here, and should be disregarded by this Court. 
In Haesebrouck, unlike here, prior to removal the plaintiff served the defendants by 
publication within the then allowed six-month period. The defendants moved to dismiss because 
(1) plaintiff failed to complete process within six (6) months of filing the complaint, (2) plaintiff 
failed to comply with the state court order shortening the term to service process, (3) plaintiff did 
not timely mail the summons and the complaint, and (4) both the state court order allowing service 
by publication and the summons by publication were defective. The district court validated said 
service and denied the defendants’ dispositive motion.  Haesebrouck, 2009 WL 2843338, at *2-3. 
The district court held that the plaintiff served the defendants within the six (6) month period and 
that the state court had allowed such a term, despite its order shortening the term for service, by 
requiring plaintiff to show compliance of service within six (6) months. Moreover, plaintiff did 
not timely mail the summons and the complaint after service by publication, but the defendants 
conceded that the state court failed to order plaintiff to do so, plus the defendants did not claim 
any prejudice in the delay of the mailing of the summons and the complaint. Id., at *3. The district 
court further stated that, “[d]espite the omissions in the [state] court’s order, however, Plaintiff 
substantially complied with the publication requirements. […] Additionally, Defendants have 
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Joint Reply to Opposition to Motion to Quash Service of Process… 
Oto Analytics, LLC v. Benworth Capital Partners PR LLC, et al. 
Civil No. 23-01034 (GMM) 
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received actual notice in time to preserve their rights and do not claim any prejudice.” Id., at *4 
(internal citations omitted). The district court concluded that the defendants received actual notice 
because it found that service by publication was valid. Nevertheless, the district court “ordered 
Plaintiff to re-serve Defendants in compliance with PRRCP 4.5 [by publication] in order to perfect 
service of process” and the “Defendants to answer the complaint within twenty (20) days from 
perfection of service.” Id.  
Here, unlike in Haesebrouck, Womply has not validly served process upon Mr. and Mrs. 
Navarro under any of the options provided by Fed. R. Civ. P. 4(e). Unlike in Haesebrouck, 
Womply has not served Mr. and Mrs. Navarro by publication, much less did it mail the Summonses 
and the Complaint as part of the service by publication process, to claim that Mr. and Mrs. Navarro 
“received actual notice in time to preserve their rights.” Id. Here, Womply ineffectively attempted 
service of Mr. and Mrs. Navarro through Ms. Gómez, who undisputedly has never been an agent 
authorized by Mr. and Mrs. Navarro to receive process on their behalf, nor is Ms. Gómez 
authorized by law to receive service on their behalf. See D.E. 37-1, 37-2 (Declarations of Mr. and 
Mrs. Navarro at ¶¶ 5-6).  Therefore, the ineffective service attempted through Ms. Gómez cannot 
only be deemed “technically incorrect” but defective and invalid in its entirety. As such, Mr. and 
Mrs. Navarro did not receive “actual notice in time to preserve their rights” through the challenged 
attempt at service. In any event, the district court in Haesebrouck did not accept “‘[s]ervice of 
process that is technically incorrect’ and order ‘Defendants to answer the complaint’ while service 
is perfected,” as characterized by Womply (D.E. 54 at 6), but instead ordered the plaintiff to re-
serve the defendants by publication and the defendants to answer the complaint in twenty 
(20) days after perfection of service, which is ultimately the relief sought in the Motion to Quash: 
“deem the service of process upon Mr. and Mrs. Navarro as insufficient under Rule 4(e), and 
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Joint Reply to Opposition to Motion to Quash Service of Process… 
Oto Analytics, LLC v. Benworth Capital Partners PR LLC, et al. 
Civil No. 23-01034 (GMM) 
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require Womply to effectuate proper service of process.” (D.E. 37, at p. 7 (prayer for relief)). As 
such, Haesebrouck does not support Womply’s flawed proposition and is inapposite here. 
Meanwhile, in González-Droz, the plaintiff validly served the defendants but after the 
former 120-day term to serve process under Fed. R. Civ. P. 4(m) had elapsed. Although there was 
no issue with the method of service, the defendants moved to dismiss because service was made 
after the 120-day limit had elapsed and plaintiff did not move for an extension of time to effectuate 
service. The district court denied the defendants’ motion to dismiss. Although it concluded that 
plaintiff had failed to show good cause for the delay in service, the district court considered other 
factors that could warrant an extension of time to serve process. First, it considered that the statute 
of limitations barred refiling of plaintiff’s claims, which shifted the balance in plaintiff’s favor. 
The district court stated that “courts have exercised discretion, and granted extensions under Rule 
4(m), after considering: ‘whether the defendant had actual notice of the claims asserted in the 
complaint… whether the defendant evaded service… whether the defendant would be prejudiced 
by the granting of plaintiff’s request for relief from the provision,’ and ‘… whether service was 
required to be made on multiple defendants.” González-Droz, 2009 2843338, at *3. On those 
considerations, the district court stated that “[s]ince the other six defendants were served 
expediently, this Court finds it reasonable to infer that Co-Defendants were aware of the claims 
asserted against them,” that there was no reason to believe the defendants were prejudiced by the 
3-week delay in service, and that the defendants did not show that the delay affected their ability 
to defend themselves. Id. For these reasons, the district court deemed all parties as properly served. 
To begin with, the instant case does not involve an issue regarding the timing of the service 
of process beyond the limitation of Fed. R. Civ. P. 4(m). Once again, unlike in González-Droz, 
Womply has not validly served process upon Mr. and Mrs. Navarro under any of the options under 
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Joint Reply to Opposition to Motion to Quash Service of Process… 
Oto Analytics, LLC v. Benworth Capital Partners PR LLC, et al. 
Civil No. 23-01034 (GMM) 
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Fed. R. Civ. P. 4(e). Womply ineffectively attempted service of Mr. and Mrs. Navarro through 
Ms. Gómez, and that ineffective attempt at service cannot be considered valid or as providing 
“actual notice” of this action. Even if we assume, for the sake of argument, that Mr. and Mrs. 
Navarro somehow have “actual notice” of this action, there is no legal foundation to conclude that 
they should be deemed as “properly served” on that basis, as Womply disingenuously submits at 
page 10 of its Opposition. Nowhere in González-Droz did the district court hold that having “actual 
notice” of a lawsuit is tantamount to a defendant being deemed as “properly served”. As such, 
González-Droz does not support Womply’s wronged proposition and is inapposite here. 
Second, the above discussion leads to Womply’s argument that it “attempted to serve the 
Navarros at their home address.” (D.E. 52, at p. 10). As demonstrated in the Motion to Quash, 
Womply has not actually served Mr. and Mrs. Navarro at their dwelling or place of abode. See, 
D.E. 37-1, 37-2 (Declarations of Mr. and Mrs. Navarro at ¶4). Womply asserts only that it 
“attempted” to serve Mr. and Mrs. Navarro at certain addresses in Puerto Rico and in Florida. Id. 
Yet, Womply again concludes, without any foundation, that Mr. and Mrs. Navarro “have actual 
notice of this action” and that “this Court should ‘deem all parties properly served’ pursuant to 
Rule 4(e)(2)(B)” citing González-Droz, 2009 WL 2843338, at *3. (D.E. 52, at p. 10). As indicated, 
Mr. and Mrs. Navarro have not been effectively served under any of the options of Fed. R. Civ. P. 
4(e). Again, there is no legal foundation to conclude that Mr. and Mrs. Navarro should be deemed 
as “properly served” based on purported “actual notice” under the facts of this case, as Womply 
disingenuously submits at page 10 of its Opposition. Womply’s interpretation of Haesebrouck and 
González-Droz is misplaced, and its unsubstantiated proposition should be rejected. 
Third, as indicated, Womply knows that it has not effectively served Mr. and Mrs. Navarro 
and, for that precise reason, it “requests leave to serve the Navarros by publication.” (D.E. 52, at 
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Civil No. 23-01034 (GMM) 
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pp. 4, 10). Notably, such a request is made in response to the Motion to Quash, and not as an 
independent motion. Such a belated request cannot be an afterthought and filed only in reaction to 
Mr. and Mrs. Navarro’s Motion to Quash. Cognizant of the infirmities of the service of process 
attempted upon Mr. and Mrs. Navarro, Womply could not “keep the card up its sleeve” regarding 
the purported difficulties to serve them and raise those arguments only in the event of a challenge 
to the (improperly) effectuated service. If Womply truly had valid grounds for service by 
publication, then it should have timely filed a motion setting forth compelling reasons as to why 
service by publication was warranted, especially past the 90-day window afforded by Fed. R. Civ. 
P. 4(m). Yet, Womply failed to do so and is now late, aside from the fact that it has not met the 
required good cause showing for this Court to extend the term for service of process. 
Fed. R. Civ. P. 4(m) “requires a defendant to be served within [90] days after the complaint 
is filed.” Carmona-Delgado v. Admin. de Servs. Médicos de P.R., Civil No. 18-1949 (CCC/GAG), 
2020 WL 11627597, at *1 (D.P.R. Aug. 5, 2020) (internal citation omitted). Hence, “[i]f plaintiff 
fails to serve a defendant within the 90 days, ‘the court--on motion or on its own after notice to the 
plaintiff--must dismiss the action without prejudice against that defendant or order that service be 
made within a specified time.’” Id. (citing Fed. R. Civ. P. 4(m)). 
In the instant case, the Complaint was filed on January 24, 2023, and the Summonses to 
Mr. and Mrs. Navarro were issued on January 25, 2023. (D.E. 6). Pursuant to Fed. R. Civ. P. 4(m), 
Womply had ninety (90) days, until April 24, 2023, to effectively serve Mr. and Mrs. Navarro. 
However, the April 24, 2023, deadline expired and Womply failed to effectively serve Mr. and 
Mrs. Navarro. Hence, almost four (4) months have elapsed since Womply filed the Complaint 
without effectively serving Mr. and Mrs. Navarro. Given that Womply has not properly served Mr. 
and Mrs. Navarro, there is no room for any argument from Womply on whether good cause exists 
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Joint Reply to Opposition to Motion to Quash Service of Process… 
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Civil No. 23-01034 (GMM) 
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for the untimeliness of service. Moreover, nowhere in the Opposition does Womply request an 
extension of the 90-day term to serve Mr. and Mrs. Navarro. Womply has not addressed in its 
Opposition any of the factors that district courts in the First Circuit have considered in granting a 
discretionary extension under Rule 4(m). By failing to do so, Womply did not make the required 
showing to move this Court to exercise its discretion to extend the 90-day term for service of 
process. As result, Womply is now late, and the Complaint should be dismissed for failure to serve 
within the time limitations of Rule 4(m). Carmona-Delgado, 2020 WL 11627597, at *2 (internal 
citation omitted) (“Rule 4(m) mandates dismissal ‘if service is not made within [90] days of the 
filing of the complaint unless the plaintiff shows ‘good cause’ for the failure.’”)). 
If this Court were to entertain Womply’s request for service by publication, the same fails 
to comply with the strict requirements for service by publication established in Rule 4.5 of the 
Puerto Rico Rules of Civil Procedure, P.R. Laws Ann. Tit. 32, App. V, R. 4.5.  The strictness of 
such requirements is “based on the fact that service by publication permits a plaintiff to proceed 
to judgment with nothing more than a form of notice to defendant—publication—that is quite 
likely to go unobserved.” Bautista Cayman Asset Company v. Las Casitas Oasis, Inc., Civil No. 
16-3165 (CCC), 2017 WL 7362732, at *2 (D.P.R. Jun. 20, 2017) (internal citation omitted).  
This Court has explained that “Rule 4.5 mandates that when the person to be served cannot 
be located in Puerto Rico despite diligent efforts or hides to avoid service, and this is satisfactorily 
shown to the Court by means of a sworn statement setting forth such efforts, and said statement or 
complaint justifies the granting of some relief against the person to be served, then the Court may 
order that the person be served through edict.” Las Casitas Oasis, 2017 WL 7362732, at *1. More 
to the fact that it has failed to serve Mr. and Mrs. Navarro, Womply states that it “has submitted 
five declarations showing that Womply has sought to serve the Navarros eight times at three 
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Joint Reply to Opposition to Motion to Quash Service of Process… 
Oto Analytics, LLC v. Benworth Capital Partners PR LLC, et al. 
Civil No. 23-01034 (GMM) 
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different addresses, which is more than sufficient to warrant service by publication.” (D.E. 52, at 
p. 11). However, a perusal of those declarations reflects that they consist of mere generalities other 
than hearsay evidence, as well as formulaic recitations, and do not state specific probative facts of 
the diligences made, which the Puerto Rico Supreme Court has expressly stated is insufficient. Las 
Casitas Oasis, 2017 WL 736732, at *1 (internal citation omitted). As such, this Court should 
conclude that Womply failed to comply with the strict requirements for service by publication and, 
consequently, deny the untimely request. 
In sum, given that the bases for quashing service in the Motion to Quash are unchallenged, 
the same should be granted and Womply should be required to effectuate service upon Mr. and 
Mrs. Navarro in compliance with Rule 4(e) and applicable law. Moreover, Womply flouted the 90-
day term to serve process under Rule 4(m), failed to timely move for service by publication, and 
has not complied with the strict requirements for service by publication. Therefore, the Complaint 
should be dismissed as to Mr. and Mrs. Navarro for failure to serve within the time limitations of 
Rule 4(m).  
WHEREFORE, Mr. and Mrs. Navarro respectfully request that this Honorable Court 
grant the Motion to Quash (D.E. 37) and, consequently, deem the service of process upon Mr. and 
Mrs. Navarro as insufficient under Rule 4(e) and, further, request dismissal of the Complaint as to 
Mr. and Mrs. Navarro under Rule 4(m). 
CERTIFICATE OF SERVICE: We hereby certify that on this same date the foregoing 
reply was filed with the Clerk of the Court using the CM/ECF system, which will send notification 
of such filing to all attorneys and participants of record. 
RESPECTFULLY SUBMITTED. 
In San Juan, Puerto Rico, this 15th day of May 2023. 
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Joint Reply to Opposition to Motion to Quash Service of Process… 
Oto Analytics, LLC v. Benworth Capital Partners PR LLC, et al. 
Civil No. 23-01034 (GMM) 
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PO Box 195168 
San Juan, PR 00919-5168 
Tel.: 787.766.7000 
Fax: 787.766.7001 
 
s/ Roberto A. Cámara-Fuertes 
Roberto A. Cámara-Fuertes 
USDC-PR 219002 
Email: rcamara@ferraiuoli.com 
 
s/ Jaime A. Torrens-Dávila 
Jaime A. Torrens-Dávila 
USDC-PR 223810 
Email: jtorrens@ferraiuoli.com 
 
s/ Mónica Ramos Benítez 
Mónica Ramos-Benítez 
USDC-PR 308405 
Email: mramos@ferraiuoli.com 
 
Counsel for Bernardo Navarro 
 
CASELLAS ALCOVER & BURGOS PSC 
PO Box 364924 
San Juan, PR 00936-4924 
Tel. (787) 756-1400 
Fax. (787) 756-1401 
rcasellas@cabprlaw.com 
cloubriel@cabprlaw.com  
/s/ Ricardo F. Casellas 
USDC-PR Bar No. 203114 
/s/ Carla S. Loubriel Carrión 
USDC-PR Bar No. 227509 
 
Counsel for Claudia Navarro  
Case 3:23-cv-01034-GMM     Document 64     Filed 05/15/23     Page 11 of 11

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