Exhibit 27: Affidavit of Process Server John Brady — Failed Service in Florida (July 11, 2023)

Record facts

U.S. District Court for the District of Puerto Rico · No. 3:23-cv-01034-GMM · Doc. 74-28 · 2023-07-13 · Docket on CourtListener

Full text

Case 3:23-cv-01034-GMM Document 74-28 Filed 07/13/23. Page 1of4

EXHIBIT 27
Case 3:23-cv-01034-GMM Document 74-28 Filed 07/13/23 Page 2of4

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF PUERTO RICO

OTO ANALYTICS, LLC, §
§
Plaintiff, §
§
V. § Civil Action No. 23-01034 (GMM)
§
BENWORTH CAPITAL PARTNERS PR §
LLC, BENWORTH CAPITAL PARTNERS §
LLC, BERNARDO NAVARRO and §
CLAUDIA NAVARRO, §
§
Defendants.
AFFIDAVIT OF JOHN BRADY

I, John Brady, pursuant to 28 U.S.C. §1746, hereby declare under penalty of perjury that
the following is true and correct based on my personal knowledge:

1. I am over the age of 18, am a process server, and am not a party to or otherwise
interested in this matter.

2. I was asked by counsel for Plaintiff Oto Analytics, LLC (f/k/a Oto Analytics, Inc.
d/b/a Womply) in the above-captioned action (the “Action”) to effect service of process on

Defendants Bernardo Navarro (“Mr. Navarro”) and Claudia Navarro (“Ms. Navarro”; together

with Mr. Navarro, the “Navarros’’) at PO
3. On June 16, 2023, at approximately 7:55 PM ET, I went to PO

GE 1h property is restricted by a large security gate, but the gate was open when

I arrived so I was able to enter the property. There was a Range Rover in the driveway with Florida
license plate [J 1 knocked on the front door of the house and waited outside the house for
approximately 30 minutes but no one answered. At approximately 8:30 PM ET, I again knocked

on the front door of the house but no one answered.
Case 3:23-cv-01034-GMM Document 74-28 Filed 07/13/23 Page 3of4

4. On June 17, 2023, at 4:00 PM ET, | again went 0

a. The security gate was open and I was able to enter the property. The same Range Rover
with Florida license plate {J was in the driveway. I knocked on the front door and waited
outside the house for approximately 30 minutes but no one answered. I did not see any movement
inside the house.

5. On June 19, 2023, at 2:00 PM ET, | again went to
a. The security gate was open and I was able to enter the property. There was a white Toyota
in the driveway with Florida license plate J 1 knocked on the front door of the house and
a dog came to the door but no one answered the door. I waited outside the house for approximately
30 minutes and knocked on the door again but no one answered.

6. On June 22, 2023, at 7:45 AM ET, | again went to
f The security gate was closed so I was not able to enter the property. The same Range
Rover with Florida license plate P| was in the driveway. I tried to page someone inside the
property for several minutes. [ waited outside the residence for approximately 15 minutes, but I
did not notice any movement from within the property.

7. On June 22, 2023, at 2 PM ET, | again went to
GR The security gate was open and | was able to enter the property. The same Range Rover
with Florida license plate J was in the driveway. I knocked on the front door of the house
and a dog inside was barking a lot. A woman in her sixties answered the door. She did not speak
English very well so we spoke in Spanish, but she did not provide her name. She told me that the
Navatrros were not at the property now. She then called her husband, who she identified as
Mr. Navarro’s father, Mr. Navarro’s father spoke to me in English and said that the Navarros were

on vacation in Europe until the end of July. He told me that | could bring the Summonses and
Case 3:23-cv-01034-GMM Document 74-28 Filed 07/13/23 Page 4of4

Complaint to his office at 700 Biltmore Way, Suite C1, Coral Gables, FL 33134 and he would

send copies to the Navarros.

8. On June 23, 2023, at 4:20 PM, I delivered the Summonses and Complaint in the

Action to Mr. Navarro’s father at 700 Biltmore Way, Suite C1, Coral Gables, FL 33134, and asked

that he provide them to the Navarros. He accepted the documents and told. me that he would be

sure to get the documents to the Navarros.

In Miami, Florida, this // day of July, 2023.

VIVA

John Bray VA

Signed and sworn before me by John Brady, of the personal circumstances stated above, whom I

have identified by means of DE

In Miami, Florida, this day of July, 2023.

(Za
MARIA D, NUNEZ Public
Notary Public (

State of Florida Ww

= Commé HH218282

GPs” Expires 1/20/2026

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