Womply Notice of Conclusion of Arbitration and Motion to Lift Stay — ECF No. 107 (June 12, 2024) — Oto Analytics v. Benworth

Record facts

U.S. District Court for the District of Puerto Rico · No. 3:23-cv-01034-GMM · Doc. 107 · 2024-06-12 · Docket on CourtListener

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 
 
 
 
 
  
 
PLAINTIFF OTO ANALYTICS, LLC’S NOTICE OF CONCLUSION OF 
ARBITRATION AND MOTION TO LIFT STAY 
On October 12, 2023, this Court issued “a short stay” of the above-captioned action (the 
“Action”) “pending a decision of the arbitrator’” in a JAMS arbitration (the “Arbitration”) 
between Plaintiff Oto Analytics, LLC (f/k/a Oto Analytics, Inc. d/b/a Womply) (“Womply”) and 
Defendant Benworth Capital Partners LLC.  (ECF No. 96 at 13.)  On January 11, 2024, this Court 
held that the Action shall be stayed “until arbitration proceedings between the Parties have 
concluded and a final award has been issued.”  (ECF No. 106.)  Those events have since occurred. 
On June 11, 2024, the arbitrator issued a final award in the Arbitration, which is appended 
as Exhibit A and which concludes the Arbitration.  Accordingly, Womply respectfully requests 
that this Court lift the stay.  See also A.J. Props., LLC v. Stanley Black & Decker, Inc., 2013 WL 
4046329, at *3 (D. Mass. Aug. 7, 2013) (“[T]here is no dispute, nor can there be, that the Court 
has the power to lift the stay that it imposed.”) (citing Ex Parte Peterson, 253 U.S. 300, 312 
(1920). 
Case 3:23-cv-01034-GMM   Document 107   Filed 06/12/24   Page 1 of 3

75259465.6 
- 2 - 
Dated: June 12, 2024 
 
 
Of Counsel 
 
Willkie Farr & Gallagher LLP 
 
By: /s/ Alexander L. Cheney_______ 
 
Alexander L. Cheney (admitted pro hac vice) 
333 Bush St 
San Francisco, CA 94104 
(415) 858-7400 
acheney@willkie.com 
 
Stuart R. Lombardi (admitted pro hac vice) 
Willkie Farr & Gallagher LLP 
787 7th Avenue 
New York, NY 10019 
(212) 728-8000 
slombardi@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: /s/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  
 
 
 
 
Case 3:23-cv-01034-GMM   Document 107   Filed 06/12/24   Page 2 of 3

75259465.6 
- 3 - 
CERTIFICATE OF SERVICE 
The undersigned certifies that on June 12, 2024, 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: June 12, 2024   
 
 
 
By: /s/ Alejandro J. Cepeda Diaz _______ 
Attorney for Plaintiff Oto Analytics, LLC 
 
Case 3:23-cv-01034-GMM   Document 107   Filed 06/12/24   Page 3 of 3

File and source

File

gov.uscourts.prd.175040.107.0.pdf

Size

307,934 bytes

SHA-256

1a3a73c13fedb26f7411c695e873a1e600faaf038867a7c81404f6b3c49aaffa

Our copy

gov.uscourts.prd.175040.107.0.pdf

Original

PACER (login required)