Exhibit 1 — Womply First Set of Interrogatories to Benworth FL (D.E. 159-1) — OTO Analytics v. Benworth

Record facts

U.S. District Court for the District of Puerto Rico · No. 3:23-cv-01034-GMM · Doc. 159-1 · 2024-08-30 · Docket on CourtListener

Summary

Exhibit 1, filed August 30, 2024 as Document 159-1 in Oto Analytics, LLC v. Benworth Capital Partners PR LLC, Civil Action No. 23-01034, in the U.S. District Court for the District of Puerto Rico. The exhibit is plaintiff Oto Analytics, LLC's first set of interrogatories to defendant Benworth Capital Partners LLC, served under Rules 26 and 33 of the Federal Rules of Civil Procedure, dated July 19, 2024, with answers requested by August 19, 2024. The opening portion is the definitions and instructions section, which defines the Loan Servicing Agreement dated May 31, 2021, the Amended Loan Servicing Agreement dated September 23, 2021, a deposition taken October 26, 2022 and December 16, 2022 in a JAMS arbitration, and a letter dated November 21, 2022. The exhibit is 71 pages and closes with a certificate of service.

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Full text

EXHIBIT 1 
 
 
 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 1 of 71

 
 
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 FIRST SET OF INTERROGATORIES TO 
DEFENDANT BENWORTH CAPITAL PARTNERS LLC 
 
Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure (“Federal Rules”), 
Plaintiff Oto Analytics, LLC (f/k/a Oto Analytics, Inc. d/b/a Womply) (“Womply”) hereby 
requests that, by August 19, 2024, Defendant Benworth Capital Partners LLC answer the following 
interrogatories (the “Interrogatories”) separately and fully under oath and serve the answers in 
the manner prescribed by the Federal Rules.  The following Interrogatories are to be read in 
accordance with the Definitions and Instructions below.  Womply reserves the right to serve 
additional Interrogatories. 
DEFINITIONS 
 
The following Definitions apply throughout these Interrogatories without regard to 
capitalization.   
1. 
“Action” refers to the above-captioned action styled Oto Analytics, LLC v. 
Benworth Capital Partners PR LLC, et al., Civil Action No. 23-01034 (D.P.R.).  
2. 
“ALSA” refers to the Amended Loan Servicing Agreement, dated September 23, 
2021, by and between Benworth FL and Benworth PR.   
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 2 of 71

 
- 2 - 
3. 
“B. Navarro Deposition” refers to the deposition of Mr. Navarro in the JAMS 
Arbitration styled, Oto Analytics, Inc. (d/b/a Womply) v. Benworth Capital Partners LLC, Ref. 
No. 1210038203, on October 26, 2022, and December 16, 2022.  
4. 
“Benworth FL” refers to Benworth Capital Partners LLC and its members, 
managers, agents, partners, owners, associates, employees, representatives, consultants, 
predecessors in interest, successors, subsidiaries, assignees, licensees, or other persons acting or 
purporting to act on their behalf, and all of their present or former subsidiaries, divisions, and/or 
affiliates. 
5. 
“Benworth PR” refers to Benworth Capital Partners PR LLC and its members, 
managers, agents, partners, owners, associates, employees, representatives, consultants, 
predecessors in interest, successors, subsidiaries, assignees, licensees, or other persons acting or 
purporting to act on their behalf, and all of their present or former subsidiaries, divisions, and/or 
affiliates. 
6. 
“Communication(s)” includes every manner or method of disclosure or transfer or 
exchange of information however made.  This includes without limitation communications 
conducted in person, by telephone, mail, email, text message, chat, instant message, facsimile, 
personal delivery, or otherwise. 
7. 
“Concerning” includes without limitation referring to, alluding to, responding to, 
relating to, connected with, commenting on, in respect of, about, regarding, discussing, showing, 
describing, 
mentioning, 
reflecting, 
analyzing, 
comprising, 
constituting, 
evidencing, 
memorializing, pertaining to, and/or supporting. 
8. 
“Document(s)” includes without limitation any Communications, writings, 
drawings, graphs, charts, photographs, phone records, tape recordings, notes, diaries, calendars, 
checkbooks, books, papers, accounts, audio, electronic or videotape recordings, emails, text messages, 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 3 of 71

 
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and any computer-generated, computer-stored, or electronically-stored matter, and other data 
compilations from which information can be obtained and translated, if necessary, into reasonably 
useable form, including documents stored on laptop computers, personal digital assistants (PDAs), 
Blackberrys, iPhones, iPads, and other similar devices. 
9. 
“LSA” refers to the Loan Servicing Agreement, dated May 31, 2021, by and 
between Benworth FL and Benworth PR.  
10. 
“Mr. Navarro” refers to Defendant Bernardo Navarro. 
11. 
“November 2022 H&K Letter” refers to the letter dated November 21, 2022, from 
Wilfredo A. Ferrer, on behalf of Benworth FL, to the Hon. James E. Clyburn.   
12. 
“Person” or “Persons” includes without limitation all natural persons, 
corporations, partnerships, or other business associations and all other legal or governmental 
entities or associations. 
13. 
“Solicitation Process” refers to the process by which Benworth FL solicited 
proposals for the services ultimately performed by Benworth FL under the LSA and/or the ALSA, 
including without limitation from “Professional Bank, Lendio, Lenders Cooperative and . . . 
BDO”, as discussed in the B. Navarro Deposition at 285:4–287:16, 348:3–349:15. 
14. 
“Transfer Pricing Analysis” means the Transfer Pricing Analysis identified in the 
November 2022 H&K Letter. 
15. 
“You,” “Your,” or “Yours” refer to Benworth FL. 
16. 
To bring within the scope of these Requests all information that might otherwise be 
construed to be outside of their scope, the following rules of construction apply:  (i) the masculine, 
feminine, or neutral pronoun shall not exclude other genders; (ii) the word “including” shall be 
read to mean including without limitation; (iii) the present tense shall be construed to include the 
past tense and vice versa; (iv) references to members, managers, employees, officers, directors, 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 4 of 71

 
- 4 - 
owners, agents, or representatives shall include both current and former members, managers, 
employees, officers, directors, owners, agents, and representatives; (v) the words “and” and “or” 
shall be construed in the conjunctive or disjunctive, whichever makes the request more inclusive; 
(vi) the words “any” and “all” are interchangeable; (vii) the use of the singular form of any word 
includes the plural and vice versa. 
17. 
All words and phrases not otherwise defined herein shall be construed in 
accordance with their plain and ordinary meaning. 
INSTRUCTIONS 
1. 
For the purpose of reading, interpreting, or construing the scope of these 
Interrogatories, the terms used shall be given their most expansive and inclusive interpretation. 
2. 
Unless instructed otherwise, each Interrogatory shall be construed independently 
and not by reference to any other Interrogatory for the purpose of limitation or exclusion. 
3. 
You must answer each Interrogatory separately and fully, unless it is objected to.  
If You object to any Interrogatory, or to any Definition or Instruction applicable thereto, state with 
specificity the objection and legal basis for such objection with citations to appropriate legal 
foundations for such objection.  If You object to only a portion of the Interrogatory, or to any 
Definition or Instruction applicable thereto, answer the portion of the Interrogatory which You do 
not object. 
4. 
If, in answering these Interrogatories, You claim any ambiguity in interpreting an 
Interrogatory, or in a Definition or Instruction applicable thereto, You should not use that claim as 
a basis for refusing to respond, but You shall set forth as part of Your response to such 
Interrogatory the language deemed to be ambiguous and the interpretation used in responding to 
the Interrogatory.  
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 5 of 71

 
- 5 - 
5. 
If You are unable to answer any Interrogatory in full after exercising due diligence 
to secure necessary information, so state, answer to the extent possible, specify the reasons for 
Your inability to answer or respond in full, and state whatever is available concerning the 
unanswered portions.  
6. 
Unless otherwise specified, these Interrogatories pertain to the period from January 
1, 2021 to the present. 
7. 
These Interrogatories are continuing in nature.  If You discover further or different 
information, You are required to file supplementary and amended answers relevant to any of these 
Interrogatories. 
INTERROGATORIES 
1. 
Identify all accounts held by Benworth FL including, for each account, the name of 
the bank or other financial institution where such account is held; the type of account (e.g., 
business, individual, joint, etc.); the account number; all Persons with access to or control over the 
account; and, for each such Person, the level of such access to or control over the account, 
including without limitation the authorization to withdraw funds, transfer funds, sign checks, or 
view account balances and/or statements. 
2. 
Identify all payments or transfers made by Benworth FL to Benworth PR, 
including, for each payment or transfer, the amount of the payment or transfer; the date of the 
payments or transfer; the reason for the payment or transfer, the method of the payment or transfer, 
and the account into which such transfer was made. 
3. 
Describe in detail the negotiation and drafting of the LSA and ALSA, including 
without limitation by identifying all Persons involved and their respective roles in the negotiating 
and drafting of the LSA and ALSA. 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 6 of 71

 
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4. 
Describe in detail the Solicitation Process, including without limitation by 
identifying all Persons involved and their respective roles in the Solicitation Process. 
5. 
Identify all Persons involved in the Transfer Pricing Analysis.  
6. 
Identify all accountants, auditors, accounting firms, and/or auditing firms that have 
performed professional services for You.  
7. 
Describe in detail the corporate, management, and ownership structure of Benworth 
FL, including any affiliates, parents, and/or subsidiaries and any changes over time.  
8. 
Identify all members or equityholders of Benworth FL for each year from 2021 to 
present, including, for each member or equityholder in each year, their respective ownership 
percentage in Benworth FL. 
9. 
Identify all entities in which You are, directly or indirectly, an owner, shareholder, 
equityholder, partner, or member for each year from 2021 to present, including for each entity in 
each year, Your ownership percentage.  
10. 
Identify all Benworth FL employees and contractors and for each of them, the dates 
of employment or services to Benworth FL,  job title, and responsibilities.  
11. 
Identify all Persons authorized to send wire transfers, write checks, pay outstanding 
invoices, or otherwise transfer funds on Your behalf, from  January 1, 2021 to the present. 
 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 7 of 71

 
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Dated: July 19, 2024 
 
 
Of Counsel: 
 
Willkie Farr & Gallagher LLP 
 
Alexander L. Cheney (admitted pro hac vice) 
333 Bush Street  
San Francisco, CA 94104 
(415) 858-7400 
acheney@willkie.com 
 
Stuart R. Lombardi (admitted pro hac vice) 
787 Seventh Avenue 
New York, NY 10019 
(212) 728-8882 
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: 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 159-1     Filed 08/30/24     Page 8 of 71

 
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CERTIFICATE OF SERVICE 
This is to certify that a true and correct copy of the foregoing document has been served 
on the following counsel of record, this 19th day of July 2024, by electronic mail at the email 
addresses indicated below:  
Monica Del Pilar Ramos-Benitez 
Roberto A. Camara-Fuertes 
Jaime A. Torrens-Davila 
FERRAIUOLI LLC 
221 Ponce de Leon Ave. 
Suite 500 
San Juan, PR 00917 
(787) 766-7000 
mramos@ferraiuoli.com 
rcamara@ferraiuoli.com 
jtorrens@ferraiuoli.com 
 
 
Jorge L. Piedra (admitted pro hac vice) 
Dwayne Robinson (admitted pro hac vice) 
Michael R. Lorigas (admitted pro hac vice) 
Rasheed K. Nader (admitted pro hac vice) 
KOZYAK TROPIN & THROCKMORTON 
2525 Ponce de Leon Boulevard,  
9th Fl. 
Miami, Florida 33134 
(305) 372-1800 
jpiedra@kttlaw.com 
drobinson@kttlaw.com 
mlorigas@kttlaw.com 
rnader@kttlaw.com 
 
Counsel for Defendants Benworth Capital 
Partners LLC and Bernardo Navarro 
Carla S. Loubriel 
Ricardo F. Casellas 
CASELLAS ALCOVER & 
BURGOS, P.S.C. 
208 Ponce de Leon Ave. 
Popular Center Bldg. Suite 1400 
Hato Rey, PR 00918 
(787) 756-1400 
cloubriel@cabprlaw.com 
rcasellas@cabprlaw.com 
 
 
Counsel for Defendants Benworth 
Capital Partners PR LLC and 
Claudia Navarro 
 
 
 
By: /s/ Alejandro J. Cepeda Diaz 
 
Attorney for Plaintiff Oto Analytics, LLC 
 
 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 9 of 71

 
 
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 FIRST SET OF INTERROGATORIES TO 
DEFENDANT BENWORTH CAPITAL PARTNERS PR LLC 
 
Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure (“Federal Rules”), 
Plaintiff Oto Analytics, LLC (f/k/a Oto Analytics, Inc. d/b/a Womply) (“Womply”) hereby 
requests that, by August 19, 2024, Defendant Benworth Capital Partners PR LLC answer the 
following interrogatories (the “Interrogatories”) separately and fully under oath and serve the 
answers in the manner prescribed by the Federal Rules.  The following Interrogatories are to be 
read in accordance with the Definitions and Instructions below.  Womply reserves the right to 
serve additional Interrogatories. 
DEFINITIONS 
 
The following Definitions apply throughout these Interrogatories without regard to 
capitalization.   
1. 
“Action” refers to the above-captioned action styled Oto Analytics, LLC v. 
Benworth Capital Partners PR LLC, et al., Civil Action No. 23-01034 (D.P.R.).  
2. 
“ALSA” refers to the Amended Loan Servicing Agreement, dated September 23, 
2021, by and between Benworth FL and Benworth PR.   
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 10 of 71

 
- 2 - 
3. 
“B. Navarro Deposition” refers to the deposition of Mr. Navarro in the JAMS 
Arbitration styled, Oto Analytics, Inc. (d/b/a Womply) v. Benworth Capital Partners LLC, Ref. 
No. 1210038203, on October 26, 2022, and December 16, 2022.  
4. 
“Benworth FL” refers to Benworth Capital Partners LLC and its members, 
managers, agents, partners, owners, associates, employees, representatives, consultants, 
predecessors in interest, successors, subsidiaries, assignees, licensees, or other persons acting or 
purporting to act on their behalf, and all of their present or former subsidiaries, divisions, and/or 
affiliates. 
5. 
“Benworth PR” refers to Benworth Capital Partners PR LLC and its members, 
managers, agents, partners, owners, associates, employees, representatives, consultants, 
predecessors in interest, successors, subsidiaries, assignees, licensees, or other persons acting or 
purporting to act on their behalf, and all of their present or former subsidiaries, divisions, and/or 
affiliates. 
6. 
“Communication(s)” includes every manner or method of disclosure or transfer or 
exchange of information however made.  This includes without limitation communications 
conducted in person, by telephone, mail, email, text message, chat, instant message, facsimile, 
personal delivery, or otherwise. 
7. 
“Concerning” includes without limitation referring to, alluding to, responding to, 
relating to, connected with, commenting on, in respect of, about, regarding, discussing, showing, 
describing, 
mentioning, 
reflecting, 
analyzing, 
comprising, 
constituting, 
evidencing, 
memorializing, pertaining to, and/or supporting. 
8. 
“Document(s)” includes without limitation any Communications, writings, 
drawings, graphs, charts, photographs, phone records, tape recordings, notes, diaries, calendars, 
checkbooks, books, papers, accounts, audio, electronic or videotape recordings, emails, text messages, 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 11 of 71

 
- 3 - 
and any computer-generated, computer-stored, or electronically-stored matter, and other data 
compilations from which information can be obtained and translated, if necessary, into reasonably 
useable form, including documents stored on laptop computers, personal digital assistants (PDAs), 
Blackberrys, iPhones, iPads, and other similar devices. 
9. 
“LSA” refers to the Loan Servicing Agreement, dated May 31, 2021, by and 
between Benworth FL and Benworth PR.  
10. 
“Mr. Navarro” refers to Defendant Bernardo Navarro. 
11. 
“November 2022 H&K Letter” refers to the letter dated November 21, 2022, from 
Wilfredo A. Ferrer, on behalf of Benworth FL, to the Hon. James E. Clyburn.   
12. 
“Person” or “Persons” includes without limitation all natural persons, 
corporations, partnerships, or other business associations and all other legal or governmental 
entities or associations. 
13. 
“Solicitation Process” refers to the process by which Benworth FL solicited 
proposals for the services ultimately performed by Benworth FL under the LSA and/or the ALSA, 
including without limitation from “Professional Bank, Lendio, Lenders Cooperative and . . . 
BDO”, as discussed in the B. Navarro Deposition at 285:4–287:16, 348:3–349:15. 
14. 
“Transfer Pricing Analysis” means the Transfer Pricing Analysis identified in the 
November 2022 H&K Letter. 
15. 
“You,” “Your,” or “Yours” refer to Benworth PR. 
16. 
To bring within the scope of these Requests all information that might otherwise be 
construed to be outside of their scope, the following rules of construction apply:  (i) the masculine, 
feminine, or neutral pronoun shall not exclude other genders; (ii) the word “including” shall be 
read to mean including without limitation; (iii) the present tense shall be construed to include the 
past tense and vice versa; (iv) references to members, managers, employees, officers, directors, 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 12 of 71

 
- 4 - 
owners, agents, or representatives shall include both current and former members, managers, 
employees, officers, directors, owners, agents, and representatives; (v) the words “and” and “or” 
shall be construed in the conjunctive or disjunctive, whichever makes the request more inclusive; 
(vi) the words “any” and “all” are interchangeable; (vii) the use of the singular form of any word 
includes the plural and vice versa. 
17. 
All words and phrases not otherwise defined herein shall be construed in 
accordance with their plain and ordinary meaning. 
INSTRUCTIONS 
1. 
For the purpose of reading, interpreting, or construing the scope of these 
Interrogatories, the terms used shall be given their most expansive and inclusive interpretation. 
2. 
Unless instructed otherwise, each Interrogatory shall be construed independently 
and not by reference to any other Interrogatory for the purpose of limitation or exclusion. 
3. 
You must answer each Interrogatory separately and fully, unless it is objected to.  
If You object to any Interrogatory, or to any Definition or Instruction applicable thereto, state with 
specificity the objection and legal basis for such objection with citations to appropriate legal 
foundations for such objection.  If You object to only a portion of the Interrogatory, or to any 
Definition or Instruction applicable thereto, answer the portion of the Interrogatory which You do 
not object. 
4. 
If, in answering these Interrogatories, You claim any ambiguity in interpreting an 
Interrogatory, or in a Definition or Instruction applicable thereto, You should not use that claim as 
a basis for refusing to respond, but You shall set forth as part of Your response to such 
Interrogatory the language deemed to be ambiguous and the interpretation used in responding to 
the Interrogatory.  
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 13 of 71

 
- 5 - 
5. 
If You are unable to answer any Interrogatory in full after exercising due diligence 
to secure necessary information, so state, answer to the extent possible, specify the reasons for 
Your inability to answer or respond in full, and state whatever is available concerning the 
unanswered portions.  
6. 
Unless otherwise specified, these Interrogatories pertain to the period from January 
1, 2021 to the present. 
7. 
These Interrogatories are continuing in nature.  If You discover further or different 
information, You are required to file supplementary and amended answers relevant to any of these 
Interrogatories. 
INTERROGATORIES 
1. 
Identify all accounts held by Benworth PR including, for each account, the name 
of the bank or other financial institution; the type of account (e.g., business, individual, joint, etc.); 
the account number; all Persons with access to or control over the account; and, for each such 
Person, the level of such access to or control over the account, including without limitation the 
authorization to withdraw funds, transfer funds, sign checks, or view account balances and/or 
statements. 
2. 
Identify all payments or transfers received by Benworth PR from Benworth FL, 
including, for each payment or transfer, the amount of the payment or transfer; the date of the 
payments or transfer; and the reason for the payment or transfer.  
3. 
Describe in detail the negotiation and drafting of the LSA and ALSA. 
4. 
Identify all accountants, auditors, accounting firms, and/or auditing firms that have 
performed professional services for You.  
5. 
Describe in detail the corporate, management, and ownership structure of Benworth 
PR, including any affiliates, parents, and/or subsidiaries and any changes over time.  
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 14 of 71

 
- 6 - 
6. 
Identify all members or equityholders of Benworth PR for each year from 2021 to 
present, including, for each member or equityholder in each year, their respective ownership 
percentage in Benworth PR. 
7. 
Identify all Benworth PR employees and contractors, including, for each employee 
or contractor, years of employment, job title, and job description.  
8. 
Identify all Persons authorized to send wire transfers, write checks, pay outstanding 
invoices, or otherwise transfer funds on Your behalf. 
Dated: July 19, 2024 
 
 
Of Counsel: 
 
Willkie Farr & Gallagher LLP 
 
Alexander L. Cheney (admitted pro hac vice) 
333 Bush Street  
San Francisco, CA 94104 
(415) 858-7400 
acheney@willkie.com 
 
Stuart R. Lombardi (admitted pro hac vice) 
787 Seventh Avenue 
New York, NY 10019 
(212) 728-8882 
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: 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 159-1     Filed 08/30/24     Page 15 of 71

 
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CERTIFICATE OF SERVICE 
This is to certify that a true and correct copy of the foregoing document has been served 
on the following counsel of record, this 19th day of July 2024, by electronic mail at the email 
addresses indicated below:  
Monica Del Pilar Ramos-Benitez 
Roberto A. Camara-Fuertes 
Jaime A. Torrens-Davila 
FERRAIUOLI LLC 
221 Ponce de Leon Ave. 
Suite 500 
San Juan, PR 00917 
(787) 766-7000 
mramos@ferraiuoli.com 
rcamara@ferraiuoli.com 
jtorrens@ferraiuoli.com 
 
 
Jorge L. Piedra (admitted pro hac vice) 
Dwayne Robinson (admitted pro hac vice) 
Michael R. Lorigas (admitted pro hac vice) 
Rasheed K. Nader (admitted pro hac vice) 
KOZYAK TROPIN & THROCKMORTON 
2525 Ponce de Leon Boulevard,  
9th Fl. 
Miami, Florida 33134 
(305) 372-1800 
jpiedra@kttlaw.com 
drobinson@kttlaw.com 
mlorigas@kttlaw.com 
rnader@kttlaw.com 
 
Counsel for Defendants Benworth Capital 
Partners LLC and Bernardo Navarro 
Carla S. Loubriel 
Ricardo F. Casellas 
CASELLAS ALCOVER & 
BURGOS, P.S.C. 
208 Ponce de Leon Ave. 
Popular Center Bldg. Suite 1400 
Hato Rey, PR 00918 
(787) 756-1400 
cloubriel@cabprlaw.com 
rcasellas@cabprlaw.com 
 
 
Counsel for Defendants Benworth 
Capital Partners PR LLC and 
Claudia Navarro 
 
 
 
By: /s/ Alejandro J. Cepeda Diaz 
 
Attorney for Plaintiff Oto Analytics, LLC 
 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 16 of 71

 
 
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 FIRST SET OF INTERROGATORIES TO 
DEFENDANT BERNARDO NAVARRO 
 
Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure (“Federal Rules”), 
Plaintiff Oto Analytics, LLC (f/k/a Oto Analytics, Inc. d/b/a Womply) (“Womply”) hereby 
requests that, by August 19, 2024, Defendant Bernardo Navarro answer the following 
interrogatories (the “Interrogatories”) separately and fully under oath and serve the answers in 
the manner prescribed by the Federal Rules.  The following Interrogatories are to be read in 
accordance with the Definitions and Instructions below.  Womply reserves the right to serve 
additional Interrogatories. 
DEFINITIONS 
 
The following Definitions apply throughout these Interrogatories without regard to 
capitalization.   
1. 
“Action” refers to the above-captioned action styled Oto Analytics, LLC v. 
Benworth Capital Partners PR LLC, et al., Civil Action No. 23-01034 (D.P.R.). 
2. 
“ALSA” refers to the Amended Loan Servicing Agreement, dated September 23, 
2021, by and between Benworth FL and Benworth PR.   
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 17 of 71

 
- 2 - 
3. 
“B. Navarro Deposition” refers to the deposition of Mr. Navarro in the JAMS 
Arbitration styled, Oto Analytics, Inc. (d/b/a Womply) v. Benworth Capital Partners LLC, Ref. 
No. 1210038203, on October 26, 2022, and December 16, 2022.  
4. 
“B. Navarro Entity” refers to (i) any entity in which Mr. Navarro has or had voting 
or operational control during the Relevant Time Period; (ii) any entity in which Mr. Navarro holds 
or held a majority ownership or equity interest, either directly or indirectly, during the Relevant 
Time Period; or (iii) any trust or similar entity for which Mr. Navarro is or was a beneficiary or 
beneficial owner during the Relevant Time Period. 
5. 
“Benworth FL” refers to Benworth Capital Partners LLC and its members, 
managers, agents, partners, owners, associates, employees, representatives, consultants, 
predecessors in interest, successors, subsidiaries, assignees, licensees, or other persons acting or 
purporting to act on their behalf, and all of their present or former subsidiaries, divisions, and/or 
affiliates. 
6. 
“Benworth PR” refers to Benworth Capital Partners PR LLC and its members, 
managers, agents, partners, owners, associates, employees, representatives, consultants, 
predecessors in interest, successors, subsidiaries, assignees, licensees, or other persons acting or 
purporting to act on their behalf, and all of their present or former subsidiaries, divisions, and/or 
affiliates. 
7. 
“Communication(s)” includes every manner or method of disclosure or transfer or 
exchange of information however made.  This includes without limitation communications 
conducted in person, by telephone, mail, email, text message, chat, instant message, facsimile, 
personal delivery, or otherwise. 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 18 of 71

 
- 3 - 
8. 
“Concerning” includes without limitation referring to, alluding to, responding to, 
relating to, connected with, commenting on, in respect of, about, regarding, discussing, showing, 
describing, 
mentioning, 
reflecting, 
analyzing, 
comprising, 
constituting, 
evidencing, 
memorializing, pertaining to, and/or supporting. 
9. 
“Dividend Payments” refers to the dividend payment(s) made by Benworth FL to 
Mr. Navarro of “at least $48,240,502.75, a portion of which was paid between 2021 and 2023,” as 
described in Paragraph 53 of the complaint filed in the action styled Federal Reserve Bank of San 
Francisco v. Benworth Capital Partners PR LLC et al., Civil Action No. 3:24-cv-01313 (D.P.R.). 
10. 
“Document(s)” includes without limitation any Communications, writings, 
drawings, graphs, charts, photographs, phone records, tape recordings, notes, diaries, calendars, 
checkbooks, books, papers, accounts, audio, electronic or videotape recordings, emails, text messages, 
and any computer-generated, computer-stored, or electronically-stored matter, and other data 
compilations from which information can be obtained and translated, if necessary, into reasonably 
useable form, including documents stored on laptop computers, personal digital assistants (PDAs), 
Blackberrys, iPhones, iPads, and other similar devices. 
11. 
“LSA” refers to the Loan Servicing Agreement, dated May 31, 2021, by and 
between Benworth FL and Benworth PR.  
12. 
“Mr. Navarro” refers to Defendant Bernardo Navarro. 
13. 
“Person” or “Persons” includes without limitation all natural persons, 
corporations, partnerships, or other business associations and all other legal or governmental 
entities or associations. 
14. 
“Solicitation Process” refers to the process by which Benworth FL solicited 
proposals for the services ultimately performed by Benworth FL under the LSA and/or the ALSA, 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 19 of 71

 
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including without limitation from “Professional Bank, Lendio, Lenders Cooperative and . . . 
BDO”, as discussed in the B. Navarro Deposition at 285:4–287:16, 348:3–349:15. 
15. 
“You,” “Your,” or “Yours” refer to Mr. Navarro. 
16. 
To bring within the scope of these Requests all information that might otherwise be 
construed to be outside of their scope, the following rules of construction apply:  (i) the masculine, 
feminine, or neutral pronoun shall not exclude other genders; (ii) the word “including” shall be 
read to mean including without limitation; (iii) the present tense shall be construed to include the 
past tense and vice versa; (iv) references to members, managers, employees, officers, directors, 
owners, agents, or representatives shall include both current and former members, managers, 
employees, officers, directors, owners, agents, and representatives; (v) the words “and” and “or” 
shall be construed in the conjunctive or disjunctive, whichever makes the request more inclusive; 
(vi) the words “any” and “all” are interchangeable; (vii) the use of the singular form of any word 
includes the plural and vice versa. 
17. 
All words and phrases not otherwise defined herein shall be construed in 
accordance with their plain and ordinary meaning. 
INSTRUCTIONS 
1. 
For the purpose of reading, interpreting, or construing the scope of these 
Interrogatories, the terms used shall be given their most expansive and inclusive interpretation. 
2. 
Unless instructed otherwise, each Interrogatory shall be construed independently 
and not by reference to any other Interrogatory for the purpose of limitation or exclusion. 
3. 
You must answer each Interrogatory separately and fully, unless it is objected to.  
If You object to any Interrogatory, or to any Definition or Instruction applicable thereto, state with 
specificity the objection and legal basis for such objection with citations to appropriate legal 
foundations for such objection.  If You object to only a portion of the Interrogatory, or to any 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 20 of 71

 
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Definition or Instruction applicable thereto, answer the portion of the Interrogatory which You do 
not object. 
4. 
If, in answering these Interrogatories, You claim any ambiguity in interpreting an 
Interrogatory, or in a Definition or Instruction applicable thereto, You should not use that claim as 
a basis for refusing to respond, but You shall set forth as part of Your response to such 
Interrogatory the language deemed to be ambiguous and the interpretation used in responding to 
the Interrogatory.  
5. 
If You are unable to answer any Interrogatory in full after exercising due diligence 
to secure necessary information, so state, answer to the extent possible, specify the reasons for 
Your inability to answer or respond in full, and state whatever is available concerning the 
unanswered portions.  
6. 
Unless otherwise specified, these Interrogatories pertain to the period from January 
1, 2021 to the present. 
7. 
These Interrogatories are continuing in nature.  If You discover further or different 
information, You are required to file supplementary and amended answers relevant to any of these 
Interrogatories. 
INTERROGATORIES 
1. 
Identify all payments or transfers received by You or a B. Navarro Entity from 
Benworth FL, including the Dividend Payments, and for each payment or transfer, list the amount 
of the payment or transfer; the date of the payments or transfer; and the reason for the payment or 
transfer.  
2. 
Identify all payments or transfers received by You or a B. Navarro Entity from 
Benworth PR, including, for each payment or transfer, the amount of the payment or transfer; the 
date of the payments or transfer; and the reason for the payment or transfer.  
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3. 
Identify all accountants, auditors, accounting firms, and/or auditing firms that have 
performed professional services for You.  
4. 
Identify the entities (including trusts) in which You are, directly or indirectly, an 
owner, shareholder, equityholder, partner, member, beneficiary, or beneficial owner for each year 
from 2021 to present, including for each entity in each year, Your ownership percentage.   
5. 
Identify all of Your home address(es) from 2021 to 2024.  
 
Dated: July 19, 2024 
 
 
Of Counsel: 
 
Willkie Farr & Gallagher LLP 
 
Alexander L. Cheney (admitted pro hac vice) 
333 Bush Street  
San Francisco, CA 94104 
(415) 858-7400 
acheney@willkie.com 
 
Stuart R. Lombardi (admitted pro hac vice) 
787 Seventh Avenue 
New York, NY 10019 
(212) 728-8882 
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: 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 
This is to certify that a true and correct copy of the foregoing document has been served 
on the following counsel of record, this 19th day of July 2024, by electronic mail at the email 
addresses indicated below:  
Monica Del Pilar Ramos-Benitez 
Roberto A. Camara-Fuertes 
Jaime A. Torrens-Davila 
FERRAIUOLI LLC 
221 Ponce de Leon Ave. 
Suite 500 
San Juan, PR 00917 
(787) 766-7000 
mramos@ferraiuoli.com 
rcamara@ferraiuoli.com 
jtorrens@ferraiuoli.com 
 
 
Jorge L. Piedra (admitted pro hac vice) 
Dwayne Robinson (admitted pro hac vice) 
Michael R. Lorigas (admitted pro hac vice) 
Rasheed K. Nader (admitted pro hac vice) 
KOZYAK TROPIN & THROCKMORTON 
2525 Ponce de Leon Boulevard,  
9th Fl. 
Miami, Florida 33134 
(305) 372-1800 
jpiedra@kttlaw.com 
drobinson@kttlaw.com 
mlorigas@kttlaw.com 
rnader@kttlaw.com 
 
Counsel for Defendants Benworth Capital 
Partners LLC and Bernardo Navarro 
Carla S. Loubriel 
Ricardo F. Casellas 
CASELLAS ALCOVER & 
BURGOS, P.S.C. 
208 Ponce de Leon Ave. 
Popular Center Bldg. Suite 1400 
Hato Rey, PR 00918 
(787) 756-1400 
cloubriel@cabprlaw.com 
rcasellas@cabprlaw.com 
 
 
Counsel for Defendants Benworth 
Capital Partners PR LLC and 
Claudia Navarro 
 
 
 
By: /s/ Alejandro J. Cepeda Diaz 
 
Attorney for Plaintiff Oto Analytics, LLC 
 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 23 of 71

 
 
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 FIRST SET OF INTERROGATORIES TO 
DEFENDANT CLAUDIA NAVARRO 
 
Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure (“Federal Rules”), 
Plaintiff Oto Analytics, LLC (f/k/a Oto Analytics, Inc. d/b/a Womply) (“Womply”) hereby 
requests that, by August 19, 2024, Defendant Claudia Navarro answer the following interrogatories 
(the “Interrogatories”) separately and fully under oath and serve the answers in the manner 
prescribed by the Federal Rules.  The following Interrogatories are to be read in accordance with 
the Definitions and Instructions below.  Womply reserves the right to serve additional 
Interrogatories. 
DEFINITIONS 
 
The following Definitions apply throughout these Interrogatories without regard to 
capitalization.   
1. 
“Action” refers to the above-captioned action styled Oto Analytics, LLC v. 
Benworth Capital Partners PR LLC, et al., Civil Action No. 23-01034 (D.P.R.). 
2. 
“ALSA” refers to the Amended Loan Servicing Agreement, dated September 23, 
2021, by and between Benworth FL and Benworth PR.   
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3. 
“B. Navarro Deposition” refers to the deposition of Mr. Navarro in the JAMS 
Arbitration styled, Oto Analytics, Inc. (d/b/a Womply) v. Benworth Capital Partners LLC, Ref. 
No. 1210038203, on October 26, 2022, and December 16, 2022.  
4. 
“Benworth FL” refers to Benworth Capital Partners LLC and its members, 
managers, agents, partners, owners, associates, employees, representatives, consultants, 
predecessors in interest, successors, subsidiaries, assignees, licensees, or other persons acting or 
purporting to act on their behalf, and all of their present or former subsidiaries, divisions, and/or 
affiliates. 
5. 
“Benworth PR” refers to Benworth Capital Partners PR LLC and its members, 
managers, agents, partners, owners, associates, employees, representatives, consultants, 
predecessors in interest, successors, subsidiaries, assignees, licensees, or other persons acting or 
purporting to act on their behalf, and all of their present or former subsidiaries, divisions, and/or 
affiliates. 
6. 
“C. Navarro Entity” refers to (i) any entity in which Ms. Navarro has or had voting 
or operational control during the Relevant Time Period; (ii) any entity in which Ms. Navarro holds 
or held a majority ownership or equity interest, either directly or indirectly, during the Relevant 
Time Period; or (iii) any trust or similar entity for which Ms. Navarro is or was a beneficiary or 
beneficial owner during the Relevant Time Period.  
7. 
“Communication(s)” includes every manner or method of disclosure or transfer or 
exchange of information however made.  This includes without limitation communications 
conducted in person, by telephone, mail, email, text message, chat, instant message, facsimile, 
personal delivery, or otherwise. 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 25 of 71

 
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8. 
“Concerning” includes without limitation referring to, alluding to, responding to, 
relating to, connected with, commenting on, in respect of, about, regarding, discussing, showing, 
describing, 
mentioning, 
reflecting, 
analyzing, 
comprising, 
constituting, 
evidencing, 
memorializing, pertaining to, and/or supporting. 
9. 
“Document(s)” includes without limitation any Communications, writings, 
drawings, graphs, charts, photographs, phone records, tape recordings, notes, diaries, calendars, 
checkbooks, books, papers, accounts, audio, electronic or videotape recordings, emails, text messages, 
and any computer-generated, computer-stored, or electronically-stored matter, and other data 
compilations from which information can be obtained and translated, if necessary, into reasonably 
useable form, including documents stored on laptop computers, personal digital assistants (PDAs), 
Blackberrys, iPhones, iPads, and other similar devices. 
10. 
“LSA” refers to the Loan Servicing Agreement, dated May 31, 2021, by and 
between Benworth FL and Benworth PR.  
11. 
“Mr. Navarro” refers to Defendant Bernardo Navarro. 
12. 
“Ms. Navarro” refers to Defendant Claudia Navarro 
13. 
“Person” or “Persons” includes without limitation all natural persons, 
corporations, partnerships, or other business associations and all other legal or governmental 
entities or associations. 
14. 
“Solicitation Process” refers to the process by which Benworth FL solicited 
proposals for the services ultimately performed by Benworth FL under the LSA and/or the ALSA, 
including without limitation from “Professional Bank, Lendio, Lenders Cooperative and . . . 
BDO”, as discussed in the B. Navarro Deposition at 285:4–287:16, 348:3–349:15. 
15. 
“You,” “Your,” or “Yours” refer to Ms. Navarro. 
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16. 
To bring within the scope of these Requests all information that might otherwise be 
construed to be outside of their scope, the following rules of construction apply:  (i) the masculine, 
feminine, or neutral pronoun shall not exclude other genders; (ii) the word “including” shall be 
read to mean including without limitation; (iii) the present tense shall be construed to include the 
past tense and vice versa; (iv) references to members, managers, employees, officers, directors, 
owners, agents, or representatives shall include both current and former members, managers, 
employees, officers, directors, owners, agents, and representatives; (v) the words “and” and “or” 
shall be construed in the conjunctive or disjunctive, whichever makes the request more inclusive; 
(vi) the words “any” and “all” are interchangeable; (vii) the use of the singular form of any word 
includes the plural and vice versa. 
17. 
All words and phrases not otherwise defined herein shall be construed in 
accordance with their plain and ordinary meaning. 
INSTRUCTIONS 
1. 
For the purpose of reading, interpreting, or construing the scope of these 
Interrogatories, the terms used shall be given their most expansive and inclusive interpretation. 
2. 
Unless instructed otherwise, each Interrogatory shall be construed independently 
and not by reference to any other Interrogatory for the purpose of limitation or exclusion. 
3. 
You must answer each Interrogatory separately and fully, unless it is objected to.  
If You object to any Interrogatory, or to any Definition or Instruction applicable thereto, state with 
specificity the objection and legal basis for such objection with citations to appropriate legal 
foundations for such objection.  If You object to only a portion of the Interrogatory, or to any 
Definition or Instruction applicable thereto, answer the portion of the Interrogatory which You do 
not object. 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 27 of 71

 
- 5 - 
4. 
If, in answering these Interrogatories, You claim any ambiguity in interpreting an 
Interrogatory, or in a Definition or Instruction applicable thereto, You should not use that claim as 
a basis for refusing to respond, but You shall set forth as part of Your response to such 
Interrogatory the language deemed to be ambiguous and the interpretation used in responding to 
the Interrogatory.  
5. 
If You are unable to answer any Interrogatory in full after exercising due diligence 
to secure necessary information, so state, answer to the extent possible, specify the reasons for 
Your inability to answer or respond in full, and state whatever is available concerning the 
unanswered portions.  
6. 
Unless otherwise specified, these Interrogatories pertain to the period from January 
1, 2021 to the present. 
7. 
These Interrogatories are continuing in nature.  If You discover further or different 
information, You are required to file supplementary and amended answers relevant to any of these 
Interrogatories. 
INTERROGATORIES 
1. 
Identify all payments or transfers received by You or a C. Navarro Entity from 
Benworth FL, and for each payment or transfer, list the amount of the payment or transfer; the date 
of the payments or transfer; and the reason for the payment or transfer.  
2. 
Identify all payments or transfers received by You or a C. Navarro Entity from 
Benworth PR, including, for each payment or transfer, the amount of the payment or transfer; the 
date of the payments or transfer; and the reason for the payment or transfer.  
3. 
Identify all accountants, auditors, accounting firms, and/or auditing firms that have 
performed professional services for You.  
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4. 
Identify the entities (including trusts) in which You are, directly or indirectly, an 
owner, shareholder, equityholder, partner, member, beneficiary, or beneficial owner for each year 
from 2021 to present, including for each entity in each year, Your ownership percentage.   
5. 
Identify Your home address on each of the following dates: January 1, 2021; 
January 1, 2022; January 1, 2023; and January 1, 2024.  
 
Dated: July 19, 2024 
 
 
Of Counsel: 
 
Willkie Farr & Gallagher LLP 
 
Alexander L. Cheney (admitted pro hac vice) 
333 Bush Street  
San Francisco, CA 94104 
(415) 858-7400 
acheney@willkie.com 
 
Stuart R. Lombardi (admitted pro hac vice) 
787 Seventh Avenue 
New York, NY 10019 
(212) 728-8882 
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: 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 159-1     Filed 08/30/24     Page 29 of 71

 
- 7 - 
CERTIFICATE OF SERVICE 
This is to certify that a true and correct copy of the foregoing document has been served 
on the following counsel of record, this 19th day of July 2024, by electronic mail at the email 
addresses indicated below:  
Monica Del Pilar Ramos-Benitez 
Roberto A. Camara-Fuertes 
Jaime A. Torrens-Davila 
FERRAIUOLI LLC 
221 Ponce de Leon Ave. 
Suite 500 
San Juan, PR 00917 
(787) 766-7000 
mramos@ferraiuoli.com 
rcamara@ferraiuoli.com 
jtorrens@ferraiuoli.com 
 
 
Jorge L. Piedra (admitted pro hac vice) 
Dwayne Robinson (admitted pro hac vice) 
Michael R. Lorigas (admitted pro hac vice) 
Rasheed K. Nader (admitted pro hac vice) 
KOZYAK TROPIN & THROCKMORTON 
2525 Ponce de Leon Boulevard,  
9th Fl. 
Miami, Florida 33134 
(305) 372-1800 
jpiedra@kttlaw.com 
drobinson@kttlaw.com 
mlorigas@kttlaw.com 
rnader@kttlaw.com 
 
Counsel for Defendants Benworth Capital 
Partners LLC and Bernardo Navarro 
Carla S. Loubriel 
Ricardo F. Casellas 
CASELLAS ALCOVER & 
BURGOS, P.S.C. 
208 Ponce de Leon Ave. 
Popular Center Bldg. Suite 1400 
Hato Rey, PR 00918 
(787) 756-1400 
cloubriel@cabprlaw.com 
rcasellas@cabprlaw.com 
 
 
Counsel for Defendants Benworth 
Capital Partners PR LLC and 
Claudia Navarro 
 
 
 
By: /s/ Alejandro J. Cepeda Diaz 
 
Attorney for Plaintiff Oto Analytics, LLC 
 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 30 of 71

 
 
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 FIRST SET OF REQUESTS FOR 
PRODUCTION TO DEFENDANT BENWORTH CAPITAL PARTNERS LLC 
 
Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure (“Federal Rules”), 
Plaintiff Oto Analytics, LLC (f/k/a Oto Analytics, Inc. d/b/a Womply) (“Womply”) hereby 
requests that, by August 19, 2024, Defendant Benworth Capital Partners LLC produce for 
inspection and copying the documents and other tangible things described below (the “Requests”) 
at the offices of McConnell Valdés LLC, 270 Muñoz Rivera Ave., Hato Rey PR 00918 in the 
manner prescribed by the Federal Rules.  The following Requests are to be read in accordance with 
the Definitions and Instructions below.  Womply reserves the right to serve additional Requests.  
DEFINITIONS 
 
The following Definitions apply throughout these Requests without regard to 
capitalization.   
1. 
“2021 Transfer” refers to the transfer or transfers of approximately $171 million 
from Benworth FL to Benworth PR during the Summer of 2021, as referenced in the B. Navarro 
Deposition at 326:10–21, 327:21–328:6.   
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- 2 - 
2. 
“ALSA” means the Amended Loan Servicing Agreement, dated September 23, 
2021, by and between Benworth FL and Benworth PR.   
3. 
“B. Navarro Deposition” refers to the deposition of Mr. Navarro in the JAMS 
Arbitration styled, Oto Analytics, Inc. (d/b/a Womply) v. Benworth Capital Partners LLC, Ref. 
No. 1210038203, on October 26, 2022, and December 16, 2022.  
4. 
“B. Navarro Entity” refers to (i) any entity in which Mr. Navarro has or had voting 
or operational control during the Relevant Time Period; (ii) any entity in which Mr. Navarro holds 
or held a majority ownership or equity interest, either directly or indirectly, during the Relevant 
Time Period; or (iii) any trust or similar entity for which Mr. Navarro is or was a beneficiary or 
beneficial owner during the Relevant Time Period.  
5. 
“BDO Business” refers to the “business” between You and the accounting firm 
“BDO,” as referenced in the B. Navarro deposition at 348:15–349:23. 
6. 
“Benworth FL” refers to Benworth Capital Partners LLC and its members, 
managers, agents, partners, owners, associates, employees, representatives, consultants, 
predecessors in interest, successors, subsidiaries, assignees, licensees, or other persons acting or 
purporting to act on their behalf, and all of their present or former subsidiaries, divisions, and/or 
affiliates. 
7. 
“Benworth PR” refers to Benworth Capital Partners PR LLC and its members, 
managers agents, partners, owners, associates, employees, representatives, consultants, 
predecessors in interest, successors, subsidiaries, assignees, licensees, or other persons acting or 
purporting to act on their behalf, and all of their present or former subsidiaries, divisions, and/or 
affiliates. 
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- 3 - 
8. 
“C. Navarro Entity” refers to (i) any entity in which Ms. Navarro has or had voting 
or operational control during the Relevant Time Period; (ii) any entity in which Ms. Navarro holds 
or held a majority ownership or equity interest, either directly or indirectly, during the Relevant 
Time Period; or (iii) any trust or similar entity for which Ms. Navarro is or was a beneficiary or 
beneficial owner during the Relevant Time Period.  
9. 
“Communication(s)” includes every manner or method of disclosure or transfer or 
exchange of information however made.  This includes without limitation communications 
conducted in person, by telephone, mail, email, text message, chat, instant message, facsimile, 
personal delivery, or otherwise. 
10. 
“Concerning” includes without limitation referring to, alluding to, responding to, 
relating to, connected with, commenting on, in respect of, about, regarding, discussing, showing, 
describing, 
mentioning, 
reflecting, 
analyzing, 
comprising, 
constituting, 
evidencing, 
memorializing, pertaining to, and/or supporting. 
11. 
“Dividend Payments” refers to the dividend payments made by Benworth FL to 
Mr. Navarro of “at least $48,240,502.75, a portion of which was paid between 2021 and 2023,” as 
described in Paragraph 53 of the Complaint filed in the action styled Federal Reserve Bank of San 
Francisco v. Benworth Capital Partners PR LLC et al., Civil Action No. 3:24-cv-01313 (D.P.R.).  
12. 
“Document(s)” includes without limitation any Communications, writings, 
drawings, graphs, charts, photographs, phone records, tape recordings, notes, diaries, calendars, 
checkbooks, books, papers, accounts, audio, electronic or videotape recordings, emails, text messages, 
and any computer-generated, computer-stored, or electronically-stored matter, and other data 
compilations from which information can be obtained and translated, if necessary, into reasonably 
useable form, including documents stored on laptop computers, personal digital assistants (PDAs), 
Blackberrys, iPhones, iPads, and other similar devices. 
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13. 
“LSA” refers to the Loan Servicing Agreement, dated May 31, 2021, by and 
between Benworth FL and Benworth PR.  
14. 
“Mr. Navarro” refers to Defendant Bernardo Navarro. 
15. 
“Ms. Navarro” refers to Defendant Claudia Navarro.  
16. 
“November 2022 H&K Letter” refers to the letter dated November 21, 2022, from 
Wilfredo A. Ferrer, on behalf of Benworth FL, to the Hon. James E. Clyburn.   
17. 
“Person” or “Persons” includes without limitation all natural persons, 
corporations, partnerships, or other business associations and all other legal or governmental 
entities or associations. 
18. 
“SBA” refers to the United States Small Business Administration. 
19. 
“Solicitation Process” refers to the process by which Benworth FL solicited 
proposals for the services ultimately performed by Benworth FL under the LSA and/or the ALSA, 
including without limitation from “Professional Bank, Lendio, Lenders Cooperative and . . . 
BDO”, as discussed in the B. Navarro Deposition at 285:4–287:16, 348:3–349:15. 
20. 
“Transfer Pricing Analysis” means the Transfer Pricing Analysis identified in the 
November 2022 H&K Letter. 
21. 
“You,” “Your,” or “Yours” refer to Benworth FL. 
22. 
To bring within the scope of these Requests all information that might otherwise be 
construed to be outside of their scope, the following rules of construction apply:  (i) the masculine, 
feminine, or neutral pronoun shall not exclude other genders; (ii) the word “including” shall be 
read to mean including without limitation; (iii) the present tense shall be construed to include the 
past tense and vice versa; (iv) references to members, managers, employees, officers, directors, 
owners, agents, or representatives shall include both current and former members, managers, 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 34 of 71

 
- 5 - 
employees, officers, directors, owners, agents, and representatives; (v) the words “and” and “or” 
shall be construed in the conjunctive or disjunctive, whichever makes the request more inclusive; 
(vi) the words “any” and “all” are interchangeable; (vii) the use of the singular form of any word 
includes the plural and vice versa. 
23. 
All words and phrases not otherwise defined herein shall be construed in 
accordance with their plain and ordinary meaning. 
INSTRUCTIONS 
1. 
For the purpose of reading, interpreting, or construing the scope of these Requests, 
the terms used shall be given their most expansive and inclusive interpretation. 
2. 
Unless instructed otherwise, each Request shall be construed independently and not 
by reference to any other Request for the purpose of limitation or exclusion, except that each 
Request shall not be construed to call for Documents that are called for by previous Requests. 
3. 
You must respond to each Request separately and fully, unless it is objected to.  If 
You object to any Request, or to any Definition or Instruction applicable thereto, state with 
specificity the objection and legal basis for such objection with citations to appropriate legal 
foundations for such objection.  If You object to only a portion of the Request, or to any Definition 
or Instruction applicable thereto, answer the portion of the Request to which You do not object. 
4. 
If, in responding to these Requests, You claim any ambiguity in interpreting a 
Request, or in a Definition or Instruction applicable thereto, You should not use that claim as a 
basis for refusing to respond, but You shall set forth as part of Your response to such Request the 
language deemed to be ambiguous and the interpretation used in responding to the Request.  
5. 
In responding to these Requests, You are required to produce all requested 
Documents in Your possession, custody, or control, including without limitation all requested 
Documents in the possession, custody, or control of any of Your predecessors, successors, 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 35 of 71

 
- 6 - 
assignees, principals, owners, employees, agents, attorneys, or other Persons acting or purporting 
to act on Your behalf, regardless of location. 
6. 
If any portion of a Document is responsive to any Request, the entire Document 
shall be produced. 
7. 
The Documents shall be produced as they are kept in the ordinary course of 
business. 
8. 
In the event that a copy of a Requested Document is not identical to any other copy 
of the same Document in Your possession, custody, or control, all non-identical copies shall be 
produced.  A Document shall be deemed to be within Your control if You have the right to secure 
the Document or a copy of the Document from another person having possession or custody of the 
Document. 
9. 
The fact that a Document is produced by another party does not relieve You of Your 
obligation to produce Your copy of the same Document, even if the two Documents are identical. 
10. 
If any of these Documents cannot be produced in full, produce them to the extent 
possible, specifying the reasons for Your inability to produce the remainder and stating whatever 
information, knowledge, or belief You have concerning the unproduced portion. 
11. 
If You withhold any of the requested Documents or portions of Documents under 
a claim of privilege, immunity, or protection, including the attorney-client privilege or work-
product doctrine, You shall provide a written privilege log that sets forth the information required 
by Rule 26(b)(5) of the Federal Rules. 
12. 
If information is redacted or otherwise withheld from a Document produced in 
response to a Request, You shall identify the redaction or otherwise withheld information by 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 36 of 71

 
- 7 - 
stamping the word “Redacted” on the Document at each place from which information has been 
redacted or otherwise withheld, and separately log each such redaction on the privilege log. 
13. 
Documents, including but not limited to electronically stored information, shall be 
produced as TIFF image files and document-level extracted text or optical character recognition 
(OCR) text files for scanned documents and redacted documents, and shall be accompanied by an 
image load file (OPT file) and a metadata load file (DAT file).  Documents shall be delivered on 
CD, DVD, USB, or hard drive media, or by file transfer protocol, with clearly marked Bates ranges.  
Womply is available to confer about a stipulation regarding electronically stored information and 
a protective order and confidentiality agreement pursuant to Rule 26(c) of the Federal Rules. 
14. 
Unless otherwise specified, these Requests pertain to the period January 1, 2021 to 
the present (the “Relevant Time Period”). 
15. 
These Requests are continuing in nature.  If You discover further or different 
information, You are required to serve supplementary and amended responses relevant to any of 
these Request and/or produce additional Documents. 
REQUESTS FOR PRODUCTION 
1. 
All statements for bank accounts owned or controlled by Benworth FL or for which 
Benworth FL is a beneficiary or beneficial owner. 
2. 
All financial and accounting records for Benworth FL, including without limitation 
general ledgers, accounts receivable ledgers, and accounts payable ledgers. 
3. 
All financial statements for Benworth FL, including without limitation audited 
financial statements, unaudited financial statements, annual financial statements, quarterly 
financial statements, and interim financial statements for the fiscal years 2021, 2022, and 2023.  
4. 
All tax returns for Benworth FL, including without limitation all federal, state, 
municipal, and territorial tax returns.  
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 37 of 71

 
- 8 - 
5. 
All Documents and Communications Concerning Puerto Rico taxes. 
6. 
All Documents and Communications exchanged between You and the Puerto Rico 
Department of the Treasury, including without limitation forms SC 6045 and SC 6047. 
7. 
Documents sufficient to show Benworth FL’s assets and liabilities from 2021 to the 
present. 
8. 
All Documents and Communications from January 1, 2021, to the present 
Concerning Your solvency or Your ability to satisfy debts.  
9. 
All Documents and Communications Concerning the drafting and negotiation of 
the LSA.  
10. 
All Documents and Communications Concerning the drafting and negotiation of 
the ALSA.  
11. 
All agreements by or between Benworth PR and Benworth FL, including without 
limitation the LSA and ALSA.  
12. 
All Communications with the SBA or any other government agency Concerning 
Benworth PR, the LSA, the ALSA, or the services Benworth PR performed or is performing for 
Benworth FL.  
13. 
All Documents and Communications Concerning any payments or transfers You 
made to Benworth PR, including without limitation the 2021 Transfer.   
14. 
All Documents and Communications Concerning the Transfer Pricing Analysis.  
15. 
All Documents and Communications Concerning the services Benworth PR 
provided or is providing to Benworth FL. 
16. 
All Documents and Communications Concerning the Solicitation Process.  
17. 
All Documents and Communications Concerning the BDO Business.  
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18. 
All Documents and Communications Concerning payments or distributions from 
You to Mr. Navarro, Ms. Navarro, any B. Navarro Entity, or any C. Navarro Entity, including 
without limitation the Dividend Payments.  
19. 
Documents sufficient to show all payments or distributions made to Your 
employees and contractors. 
20. 
All contracts and agreements between You and Ms. Navarro, including without 
limitation all employment agreements, consulting agreements, services agreements, ownership 
agreements, and voting agreements.  
21. 
All contracts and agreements between You and any C. Navarro Entity. 
22. 
All contracts and agreements between You and Mr. Navarro, including without 
limitation all employment agreements, consulting agreements, services agreements, ownership 
agreements, and voting agreements. 
23. 
All contracts and agreements between You and any B. Navarro Entity. 
24. 
All organizational documents for Benworth FL, including without limitation any 
limited liability company agreements, shareholder agreements, corporate resolutions, member 
resolutions, and written consents. 
25. 
Documents sufficient to show Your corporate structure.  
26. 
All Documents identified, directly or indirectly, in Your answers to Womply’s First 
Set of Interrogatories to You, dated July 19, 2024. 
 
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Dated: July 19, 2024 
 
 
Of Counsel: 
 
Willkie Farr & Gallagher LLP 
 
Alexander L. Cheney (admitted pro hac vice) 
333 Bush Street  
San Francisco, CA 94104 
(415) 858-7400 
acheney@willkie.com 
 
Stuart R. Lombardi (admitted pro hac vice) 
787 Seventh Avenue 
New York, NY 10019 
(212) 728-8882 
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: 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 
This is to certify that a true and correct copy of the foregoing document has been served 
on the following counsel of record, this 19th day of July 2024, by electronic mail at the email 
addresses indicated below:  
Monica Del Pilar Ramos-Benitez 
Roberto A. Camara-Fuertes 
Jaime A. Torrens-Davila 
FERRAIUOLI LLC 
221 Ponce de Leon Ave. 
Suite 500 
San Juan, PR 00917 
(787) 766-7000 
mramos@ferraiuoli.com 
rcamara@ferraiuoli.com 
jtorrens@ferraiuoli.com 
 
 
Jorge L. Piedra (admitted pro hac vice) 
Dwayne Robinson (admitted pro hac vice) 
Michael R. Lorigas (admitted pro hac vice) 
Rasheed K. Nader (admitted pro hac vice) 
KOZYAK TROPIN & THROCKMORTON 
2525 Ponce de Leon Boulevard,  
9th Fl. 
Miami, Florida 33134 
(305) 372-1800 
jpiedra@kttlaw.com 
drobinson@kttlaw.com 
mlorigas@kttlaw.com 
rnader@kttlaw.com 
 
Counsel for Defendants Benworth Capital 
Partners LLC and Bernardo Navarro 
Carla S. Loubriel 
Ricardo F. Casellas 
CASELLAS ALCOVER & 
BURGOS, P.S.C. 
208 Ponce de Leon Ave. 
Popular Center Bldg. Suite 1400 
Hato Rey, PR 00918 
(787) 756-1400 
cloubriel@cabprlaw.com 
rcasellas@cabprlaw.com 
 
 
Counsel for Defendants Benworth 
Capital Partners PR LLC and 
Claudia Navarro 
 
 
 
By: /s/ Alejandro J. Cepeda Diaz 
 
Attorney for Plaintiff Oto Analytics, LLC 
 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 41 of 71

 
 
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 FIRST SET OF REQUESTS FOR 
PRODUCTION TO DEFENDANT BENWORTH CAPITAL PARTNERS PR LLC 
 
Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure (“Federal Rules”), 
Plaintiff Oto Analytics, LLC (f/k/a Oto Analytics, Inc. d/b/a Womply) (“Womply”) hereby 
requests that, by August 19, 2024, Defendant Benworth Capital Partners PR LLC produce for 
inspection and copying the documents and other tangible things described below (the “Requests”) 
at the offices of McConnell Valdés LLC, 270 Muñoz Rivera Ave., Hato Rey PR 00918 in the 
manner prescribed by the Federal Rules.  The following Requests are to be read in accordance with 
the Definitions and Instructions below.  Womply reserves the right to serve additional Requests.  
DEFINITIONS 
 
The following Definitions apply throughout these Requests without regard to 
capitalization.   
1. 
“2021 Transfer” refers to the transfer or transfers of approximately $171 million 
from Benworth FL to Benworth PR during the Summer of 2021, as referenced in the B. Navarro 
Deposition at 326:10–21, 327:21–328:6.   
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2. 
“ALSA” means the Amended Loan Servicing Agreement, dated September 23, 
2021, by and between Benworth FL and Benworth PR.   
3. 
“B. Navarro Deposition” refers to the deposition of Mr. Navarro in the JAMS 
Arbitration styled, Oto Analytics, Inc. (d/b/a Womply) v. Benworth Capital Partners LLC, Ref. 
No. 1210038203, on October 26, 2022, and December 16, 2022.  
4. 
“B. Navarro Entity” refers to (i) any entity in which Mr. Navarro has or had voting 
or operational control during the Relevant Time Period; (ii) any entity in which Mr. Navarro holds 
or held a majority ownership or equity interest, either directly or indirectly, during the Relevant 
Time Period; or (iii) any trust or similar entity for which Mr. Navarro is or was a beneficiary or 
beneficial owner during the Relevant Time Period.  
5. 
“BDO Business” refers to the “business” between You and the accounting firm 
“BDO,” as referenced in the B. Navarro deposition at 348:15–349:23. 
6. 
“Benworth FL” refers to Benworth Capital Partners LLC and its members, 
managers, agents, partners, owners, associates, employees, representatives, consultants, 
predecessors in interest, successors, subsidiaries, assignees, licensees, or other persons acting or 
purporting to act on their behalf, and all of their present or former subsidiaries, divisions, and/or 
affiliates. 
7. 
“Benworth PR” refers to Benworth Capital Partners PR LLC and its members, 
managers, agents, partners, owners, associates, employees, representatives, consultants, 
predecessors in interest, successors, subsidiaries, assignees, licensees, or other persons acting or 
purporting to act on their behalf, and all of their present or former subsidiaries, divisions, and/or 
affiliates. 
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76182698.4 
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8. 
“C. Navarro Entity” refers to (i) any entity in which Ms. Navarro has or had voting 
or operational control during the Relevant Time Period; (ii) any entity in which Ms. Navarro holds 
or held a majority ownership or equity interest, either directly or indirectly, during the Relevant 
Time Period; or (iii) any trust or similar entity for which Ms. Navarro is or was a beneficiary or 
beneficial owner during the Relevant Time Period.  
9. 
“Communication(s)” includes every manner or method of disclosure or transfer or 
exchange of information however made.  This includes without limitation communications 
conducted in person, by telephone, mail, email, text message, chat, instant message, facsimile, 
personal delivery, or otherwise. 
10. 
“Concerning” includes without limitation referring to, alluding to, responding to, 
relating to, connected with, commenting on, in respect of, about, regarding, discussing, showing, 
describing, 
mentioning, 
reflecting, 
analyzing, 
comprising, 
constituting, 
evidencing, 
memorializing, pertaining to, and/or supporting. 
11. 
“Document(s)” includes without limitation any Communications, writings, 
drawings, graphs, charts, photographs, phone records, tape recordings, notes, diaries, calendars, 
checkbooks, books, papers, accounts, audio, electronic or videotape recordings, emails, text messages, 
and any computer-generated, computer-stored, or electronically-stored matter, and other data 
compilations from which information can be obtained and translated, if necessary, into reasonably 
useable form, including documents stored on laptop computers, personal digital assistants (PDAs), 
Blackberrys, iPhones, iPads, and other similar devices. 
12. 
“LSA” refers to the Loan Servicing Agreement, dated May 31, 2021, by and 
between Benworth FL and Benworth PR.  
13. 
“Mr. Navarro” refers to Defendant Bernardo Navarro. 
14. 
“Ms. Navarro” refers to Defendant Claudia Navarro.  
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76182698.4 
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15. 
“November 2022 H&K Letter” refers to the letter dated November 21, 2022, from 
Wilfredo A. Ferrer, on behalf of Benworth FL, to the Hon. James E. Clyburn.   
16. 
“Person” or “Persons” includes without limitation all natural persons, 
corporations, partnerships, or other business associations and all other legal or governmental 
entities or associations. 
17. 
“SBA” refers to the United States Small Business Administration. 
18. 
“Solicitation Process” refers to the process by which Benworth FL solicited 
proposals for the services ultimately performed by Benworth FL under the LSA and/or the ALSA, 
including without limitation from “Professional Bank, Lendio, Lenders Cooperative and . . . 
BDO”, as discussed in the B. Navarro Deposition at 285:4–287:16, 348:3–349:15. 
19. 
“Transfer Pricing Analysis” means the Transfer Pricing Analysis identified in the 
November 2022 H&K Letter. 
20. 
“You,” “Your,” or “Yours” refer to Benworth PR. 
21. 
To bring within the scope of these Requests all information that might otherwise be 
construed to be outside of their scope, the following rules of construction apply:  (i) the masculine, 
feminine, or neutral pronoun shall not exclude other genders; (ii) the word “including” shall be 
read to mean including without limitation; (iii) the present tense shall be construed to include the 
past tense and vice versa; (iv) references to members, managers, employees, officers, directors, 
owners, agents, or representatives shall include both current and former members, managers, 
employees, officers, directors, owners, agents, and representatives; (v) the words “and” and “or” 
shall be construed in the conjunctive or disjunctive, whichever makes the request more inclusive; 
(vi) the words “any” and “all” are interchangeable; (vii) the use of the singular form of any word 
includes the plural and vice versa. 
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76182698.4 
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22. 
All words and phrases not otherwise defined herein shall be construed in 
accordance with their plain and ordinary meaning. 
INSTRUCTIONS 
1. 
For the purpose of reading, interpreting, or construing the scope of these Requests, 
the terms used shall be given their most expansive and inclusive interpretation. 
2. 
Unless instructed otherwise, each Request shall be construed independently and not 
by reference to any other Request for the purpose of limitation or exclusion, except that each 
Request shall not be construed to call for Documents that are called for by previous Requests. 
3. 
You must respond to each Request separately and fully, unless it is objected to.  If 
You object to any Request, or to any Definition or Instruction applicable thereto, state with 
specificity the objection and legal basis for such objection with citations to appropriate legal 
foundations for such objection.  If You object to only a portion of the Request, or to any Definition 
or Instruction applicable thereto, answer the portion of the Request to which You do not object. 
4. 
If, in responding to these Requests, You claim any ambiguity in interpreting a 
Request, or in a Definition or Instruction applicable thereto, You should not use that claim as a 
basis for refusing to respond, but You shall set forth as part of Your response to such Request the 
language deemed to be ambiguous and the interpretation used in responding to the Request.  
5. 
In responding to these Requests, You are required to produce all requested 
Documents in Your possession, custody, or control, including without limitation all requested 
Documents in the possession, custody, or control of any of Your predecessors, successors, 
assignees, principals, owners, employees, agents, attorneys, or other Persons acting or purporting 
to act on Your behalf, regardless of location. 
6. 
If any portion of a Document is responsive to any Request, the entire Document 
shall be produced. 
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76182698.4 
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7. 
The Documents shall be produced as they are kept in the ordinary course of 
business. 
8. 
In the event that a copy of a Requested Document is not identical to any other copy 
of the same Document in Your possession, custody, or control, all non-identical copies shall be 
produced.  A Document shall be deemed to be within Your control if You have the right to secure 
the Document or a copy of the Document from another person having possession or custody of the 
Document. 
9. 
The fact that a Document is produced by another party does not relieve You of Your 
obligation to produce Your copy of the same Document, even if the two Documents are identical. 
10. 
If any of these Documents cannot be produced in full, produce them to the extent 
possible, specifying the reasons for Your inability to produce the remainder and stating whatever 
information, knowledge, or belief You have concerning the unproduced portion. 
11. 
If You withhold any of the requested Documents or portions of Documents under 
a claim of privilege, immunity, or protection, including the attorney-client privilege or work-
product doctrine, You shall provide a written privilege log that sets forth the information required 
by Rule 26(b)(5) of the Federal Rules. 
12. 
If information is redacted or otherwise withheld from a Document produced in 
response to a Request, You shall identify the redaction or otherwise withheld information by 
stamping the word “Redacted” on the Document at each place from which information has been 
redacted or otherwise withheld, and separately log each such redaction on the privilege log. 
13. 
Documents, including but not limited to electronically stored information, shall be 
produced as TIFF image files and document-level extracted text or optical character recognition 
(OCR) text files for scanned documents and redacted documents, and shall be accompanied by an 
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76182698.4 
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image load file (OPT file) and a metadata load file (DAT file).  Documents shall be delivered on 
CD, DVD, USB, or hard drive media, or by file transfer protocol, with clearly marked Bates ranges.  
Womply is available to confer about a stipulation regarding electronically stored information and 
a protective order and confidentiality agreement pursuant to Rule 26(c) of the Federal Rules. 
14. 
Unless otherwise specified, these Requests pertain to the period January 1, 2021 to 
the present (the “Relevant Time Period”). 
15. 
These Requests are continuing in nature.  If You discover further or different 
information, You are required to serve supplementary and amended responses relevant to any of 
these Request and/or produce additional Documents. 
REQUESTS FOR PRODUCTION 
1. 
All statements for bank accounts owned or controlled by Benworth PR or for which 
Benworth PR is a beneficiary or beneficial owner. 
2. 
All financial and accounting records for Benworth PR, including without limitation 
general ledgers, accounts receivable ledgers, and accounts payable ledgers. 
3. 
All financial statements for Benworth PR, including without limitation audited 
financial statements, unaudited financial statements, annual financial statements, quarterly 
financial statements, interim financial statements, and annual reports submitted to La Oficina 
Comsionado de Instituciones Financieras, for the fiscal years 2021, 2022, and 2023.  
4. 
All tax returns for Benworth PR, including without limitation all federal, state, 
municipal, and territorial tax returns.  
5. 
All Documents and Communications Concerning Puerto Rico taxes. 
6. 
All Documents and Communications exchanged between You and the Puerto Rico 
Department of the Treasury, including without limitation forms SC 6045 and SC 6047. 
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76182698.4 
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7. 
Documents sufficient to show Benworth PR’s assets and liabilities from 2021 to 
the present. 
8. 
All Documents and Communications from January 1, 2021, to the present 
Concerning Your solvency or Your ability to satisfy debts.  
9. 
All Documents and Communications Concerning the drafting and negotiation of 
the LSA.  
10. 
All Documents and Communications Concerning the drafting and negotiation of 
the ALSA.  
11. 
All agreements by or between Benworth PR and Benworth FL, including without 
limitation the LSA and ALSA.  
12. 
All Communications with the SBA or any other government agency Concerning 
Benworth PR, the LSA, the ALSA, or the services Benworth PR performed or is performing for 
Benworth FL.  
13. 
All Documents and Communications Concerning any payments or transfers You 
received from Benworth FL, including without limitation the 2021 Transfer.   
14. 
All Documents and Communications Concerning the Transfer Pricing Analysis.  
15. 
All Documents and Communications Concerning the services Benworth PR 
provided or is providing for Benworth FL. 
16. 
All Documents and Communications Concerning the Solicitation Process.  
17. 
All Documents and Communications Concerning the BDO Business.  
18. 
All Documents and Communications Concerning payments or distributions from 
You to Mr. Navarro any B. Navarro Entity, or any C. Navarro Entity.  
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76182698.4 
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19. 
All Documents and Communications Concerning payments or distributions from 
You to Mr. Navarro or Ms. Navarro. 
20. 
Documents sufficient to show all payments or distributions made to Your 
employees and contractors. 
21. 
All contracts and agreements between You and Ms. Navarro, including without 
limitation all employment agreements, consulting agreements, services agreements, ownership 
agreements, and voting agreements.  
22. 
All contracts and agreements between You and any C. Navarro Entity. 
23. 
All contracts and agreements between You and Mr. Navarro, including without 
limitation all employment agreements, consulting agreements, services agreements, ownership 
agreements, and voting agreements. 
24. 
All contracts and agreements between You and any B. Navarro Entity. 
25. 
All Documents and Communications concerning the formation of Benworth PR.  
26. 
All organizational documents for Benworth PR, including without limitation any 
limited liability company agreements, shareholder agreements, corporate resolutions, member 
resolutions, and written consents. 
27. 
Documents sufficient to show Your corporate structure.  
28. 
All Documents identified, directly or indirectly, in Your answers to Womply’s First 
Set of Interrogatories to You, dated July 19, 2024. 
 
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76182698.4 
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Dated: July 19, 2024 
 
 
Of Counsel: 
 
Willkie Farr & Gallagher LLP 
 
Alexander L. Cheney (admitted pro hac vice) 
333 Bush Street  
San Francisco, CA 94104 
(415) 858-7400 
acheney@willkie.com 
 
Stuart R. Lombardi (admitted pro hac vice) 
787 Seventh Avenue 
New York, NY 10019 
(212) 728-8882 
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: 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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76182698.4 
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CERTIFICATE OF SERVICE 
This is to certify that a true and correct copy of the foregoing document has been served 
on the following counsel of record, this 19th day of July 2024, by electronic mail at the email 
addresses indicated below:  
Monica Del Pilar Ramos-Benitez 
Roberto A. Camara-Fuertes 
Jaime A. Torrens-Davila 
FERRAIUOLI LLC 
221 Ponce de Leon Ave. 
Suite 500 
San Juan, PR 00917 
(787) 766-7000 
mramos@ferraiuoli.com 
rcamara@ferraiuoli.com 
jtorrens@ferraiuoli.com 
 
 
Jorge L. Piedra (admitted pro hac vice) 
Dwayne Robinson (admitted pro hac vice) 
Michael R. Lorigas (admitted pro hac vice) 
Rasheed K. Nader (admitted pro hac vice) 
KOZYAK TROPIN & THROCKMORTON 
2525 Ponce de Leon Boulevard,  
9th Fl. 
Miami, Florida 33134 
(305) 372-1800 
jpiedra@kttlaw.com 
drobinson@kttlaw.com 
mlorigas@kttlaw.com 
rnader@kttlaw.com 
 
Counsel for Defendants Benworth Capital 
Partners LLC and Bernardo Navarro 
Carla S. Loubriel 
Ricardo F. Casellas 
CASELLAS ALCOVER & 
BURGOS, P.S.C. 
208 Ponce de Leon Ave. 
Popular Center Bldg. Suite 1400 
Hato Rey, PR 00918 
(787) 756-1400 
cloubriel@cabprlaw.com 
rcasellas@cabprlaw.com 
 
 
Counsel for Defendants Benworth 
Capital Partners PR LLC and 
Claudia Navarro 
 
 
 
By: /s/ Alejandro J. Cepeda Diaz 
 
Attorney for Plaintiff Oto Analytics, LLC 
 
 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 52 of 71

 
 
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 FIRST SET OF REQUESTS FOR 
PRODUCTION TO DEFENDANT BERNARDO NAVARRO 
 
Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure (“Federal Rules”), 
Plaintiff Oto Analytics, LLC (f/k/a Oto Analytics, Inc. d/b/a Womply) (“Womply”) hereby 
requests that, by August 19, 2024, Defendant Bernardo Navarro produce for inspection and 
copying the documents and other tangible things described below (the “Requests”) at the offices 
of McConnell Valdés LLC, 270 Muñoz Rivera Ave., Hato Rey PR 00918 in the manner prescribed 
by the Federal Rules.  The following Requests are to be read in accordance with the Definitions 
and Instructions below.  Womply reserves the right to serve additional Requests.  
DEFINITIONS 
 
The following Definitions apply throughout these Requests without regard to 
capitalization.   
1. 
“2021 Transfer” refers to the transfer or transfers of approximately $171 million 
from Benworth FL to Benworth PR during the Summer of 2021, as referenced in the B. Navarro 
Deposition at 326:10–21, 327:21–328:6.   
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 53 of 71

 
- 2 - 
2. 
“ALSA” means the Amended Loan Servicing Agreement, dated September 23, 
2021, by and between Benworth FL and Benworth PR.   
3. 
“B. Navarro Deposition” refers to the deposition of Mr. Navarro in the JAMS 
Arbitration styled, Oto Analytics, Inc. (d/b/a Womply) v. Benworth Capital Partners LLC, Ref. 
No. 1210038203, on October 26, 2022, and December 16, 2022.  
4. 
“B. Navarro Entity” refers to (i) any entity in which Mr. Navarro has or had voting 
or operational control during the Relevant Time Period; (ii) any entity in which Mr. Navarro holds 
or held a majority ownership or equity interest, either directly or indirectly, during the Relevant 
Time Period; or (iii) any trust or similar entity for which Mr. Navarro is or was a beneficiary or 
beneficial owner during the Relevant Time Period.  
5. 
“BDO Business” refers to the “business” between You and the accounting firm 
“BDO”, as referenced in the B. Navarro deposition at 348:15–349:23. 
6. 
“Benworth FL” refers to Benworth Capital Partners LLC and its members, 
managers, agents, partners, owners, associates, employees, representatives, consultants, 
predecessors in interest, successors, subsidiaries, assignees, licensees, or other persons acting or 
purporting to act on their behalf, and all of their present or former subsidiaries, divisions, and/or 
affiliates. 
7. 
“Benworth PR” refers to Benworth Capital Partners PR LLC and its members, 
managers, agents, partners, owners, associates, employees, representatives, consultants, 
predecessors in interest, successors, subsidiaries, assignees, licensees, or other persons acting or 
purporting to act on their behalf, and all of their present or former subsidiaries, divisions, and/or 
affiliates. 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 54 of 71

 
- 3 - 
8. 
“Communication(s)” includes every manner or method of disclosure or transfer or 
exchange of information however made.  This includes without limitation communications 
conducted in person, by telephone, mail, email, text message, chat, instant message, facsimile, 
personal delivery, or otherwise. 
9. 
“Concerning” includes without limitation referring to, alluding to, responding to, 
relating to, connected with, commenting on, in respect of, about, regarding, discussing, showing, 
describing, 
mentioning, 
reflecting, 
analyzing, 
comprising, 
constituting, 
evidencing, 
memorializing, pertaining to, and/or supporting. 
10. 
“Dividend Payments” refers to the payment(s) made by Benworth FL to Mr. 
Navarro of “at least $48,240,502.75, a portion of which was paid between 2021 and 2023,” as 
described in Paragraph 53 of the complaint filed in the action styled Federal Reserve Bank of San 
Francisco v. Benworth Capital Partners PR LLC, et al., Civil Action No. 3:24-cv-01313 (D.P.R.).  
11. 
“Document(s)” includes without limitation any Communications, writings, 
drawings, graphs, charts, photographs, phone records, tape recordings, notes, diaries, calendars, 
checkbooks, books, papers, accounts, audio, electronic or videotape recordings, emails, text messages, 
and any computer-generated, computer-stored, or electronically-stored matter, and other data 
compilations from which information can be obtained and translated, if necessary, into reasonably 
useable form, including documents stored on laptop computers, personal digital assistants (PDAs), 
Blackberrys, iPhones, iPads, and other similar devices. 
12. 
“LSA” refers to the Loan Servicing Agreement, dated May 31, 2021, by and 
between Benworth FL and Benworth PR.  
13. 
“Mr. Navarro” refers to Defendant Bernardo Navarro. 
14. 
“November 2022 H&K Letter” refers to the letter dated November 21, 2022, from 
Wilfredo A. Ferrer, on behalf of Benworth FL, to the Hon. James E. Clyburn.   
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 55 of 71

 
- 4 - 
15. 
“Person” or “Persons” includes without limitation all natural persons, 
corporations, partnerships, or other business associations and all other legal or governmental 
entities or associations. 
16. 
“Solicitation Process” refers to the process by which Benworth FL solicited 
proposals for the services ultimately performed by Benworth FL under the LSA and/or the ALSA, 
including without limitation from “Professional Bank, Lendio, Lenders Cooperative and . . . 
BDO”, as discussed in the B. Navarro Deposition at 285:4–287:16, 348:3–349:15. 
17. 
“Transfer Pricing Analysis” means the Transfer Pricing Analysis identified in the 
November 2022 H&K Letter. 
18. 
“You,” “Your,” or “Yours” refer to Mr. Navarro. 
19. 
To bring within the scope of these Requests all information that might otherwise be 
construed to be outside of their scope, the following rules of construction apply:  (i) the masculine, 
feminine, or neutral pronoun shall not exclude other genders; (ii) the word “including” shall be 
read to mean including without limitation; (iii) the present tense shall be construed to include the 
past tense and vice versa; (iv) references to members, managers, employees, officers, directors, 
owners, agents, or representatives shall include both current and former members, managers, 
employees, officers, directors, owners, agents, and representatives; (v) the words “and” and “or” 
shall be construed in the conjunctive or disjunctive, whichever makes the request more inclusive; 
(vi) the words “any” and “all” are interchangeable; (vii) the use of the singular form of any word 
includes the plural and vice versa. 
20. 
All words and phrases not otherwise defined herein shall be construed in 
accordance with their plain and ordinary meaning. 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 56 of 71

 
- 5 - 
INSTRUCTIONS 
1. 
For the purpose of reading, interpreting, or construing the scope of these Requests, 
the terms used shall be given their most expansive and inclusive interpretation. 
2. 
Unless instructed otherwise, each Request shall be construed independently and not 
by reference to any other Request for the purpose of limitation or exclusion, except that each 
Request shall not be construed to call for Documents that are called for by previous Requests. 
3. 
You must respond to each Request separately and fully, unless it is objected to.  If 
You object to any Request, or to any Definition or Instruction applicable thereto, state with 
specificity the objection and legal basis for such objection with citations to appropriate legal 
foundations for such objection.  If You object to only a portion of the Request, or to any Definition 
or Instruction applicable thereto, answer the portion of the Request to which You do not object. 
4. 
If, in responding to these Requests, You claim any ambiguity in interpreting a 
Request, or in a Definition or Instruction applicable thereto, You should not use that claim as a 
basis for refusing to respond, but You shall set forth as part of Your response to such Request the 
language deemed to be ambiguous and the interpretation used in responding to the Request.  
5. 
In responding to these Requests, You are required to produce all requested 
Documents in Your possession, custody, or control, including without limitation all requested 
Documents in the possession, custody, or control of any of Your predecessors, successors, 
assignees, principals, owners, employees, agents, attorneys, or other Persons acting or purporting 
to act on Your behalf, regardless of location. 
6. 
If any portion of a Document is responsive to any Request, the entire Document 
shall be produced. 
7. 
The Documents shall be produced as they are kept in the ordinary course of 
business. 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 57 of 71

 
- 6 - 
8. 
In the event that a copy of a Requested Document is not identical to any other copy 
of the same Document in Your possession, custody, or control, all non-identical copies shall be 
produced.  A Document shall be deemed to be within Your control if You have the right to secure 
the Document or a copy of the Document from another person having possession or custody of the 
Document. 
9. 
The fact that a Document is produced by another party does not relieve You of Your 
obligation to produce Your copy of the same Document, even if the two Documents are identical. 
10. 
If any of these Documents cannot be produced in full, produce them to the extent 
possible, specifying the reasons for Your inability to produce the remainder and stating whatever 
information, knowledge, or belief You have concerning the unproduced portion. 
11. 
If You withhold any of the requested Documents or portions of Documents under 
a claim of privilege, immunity, or protection, including the attorney-client privilege or work-
product doctrine, You shall provide a written privilege log that sets forth the information required 
by Rule 26(b)(5) of the Federal Rules. 
12. 
If information is redacted or otherwise withheld from a Document produced in 
response to a Request, You shall identify the redaction or otherwise withheld information by 
stamping the word “Redacted” on the Document at each place from which information has been 
redacted or otherwise withheld, and separately log each such redaction on the privilege log. 
13. 
Documents, including but not limited to electronically stored information, shall be 
produced as TIFF image files and document-level extracted text or optical character recognition 
(OCR) text files for scanned documents and redacted documents, and shall be accompanied by an 
image load file (OPT file) and a metadata load file (DAT file).  Documents shall be delivered on 
CD, DVD, USB, or hard drive media, or by file transfer protocol, with clearly marked Bates ranges.  
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 58 of 71

 
- 7 - 
Womply is available to confer about a stipulation regarding electronically stored information and 
a protective order and confidentiality agreement pursuant to Rule 26(c) of the Federal Rules. 
14. 
Unless otherwise specified, these Requests pertain to the period January 1, 2021 to 
the present (the “Relevant Time Period”).  
15. 
These Requests are continuing in nature.  If You discover further or different 
information, You are required to serve supplementary and amended responses relevant to any of 
these Request and/or produce additional Documents. 
REQUESTS FOR PRODUCTION 
1. 
All Documents and Communications Concerning the drafting and negotiation of 
the LSA.  
2. 
All Documents and Communications Concerning the drafting and negotiation of 
the ALSA.  
3. 
All Documents and Communications Concerning the 2021 Transfer. 
4. 
All Documents and Communications Concerning any payments or transfers You 
received from Benworth FL, including without limitation the Dividend Payments.  
5. 
All Documents and Communications Concerning any payments or transfers You 
received from Benworth PR.  
6. 
All Documents and Communications Concerning any payments or transfers made 
to a B. Navarro Entity by Benworth FL.  
7. 
All Documents and Communications Concerning any payments or transfers made 
to a B. Navarro Entity by Benworth PR. 
8. 
All Documents and Communications Concerning the Solicitation Process.  
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 59 of 71

 
- 8 - 
9. 
All contracts and agreements between You and Benworth FL, including without 
limitation all employment agreements, consulting agreements, services agreements, ownership 
agreements, and voting agreements.  
10. 
All contracts and agreements between You and Benworth PR, including without 
limitation all employment agreements, consulting agreements, services agreements, ownership 
agreements, and voting agreements. 
11. 
All contracts and agreements between a B. Navarro entity and Benworth FL.  
12. 
All contracts and agreements between a B. Navarro entity and Benworth PR.  
13. 
All Documents and Communications Concerning the formation of Benworth PR.  
14. 
All Documents and Communications Concerning the solvency of Benworth FL. 
15. 
All Documents and Communications Concerning the services performed by 
Benworth PR, including without limitation all Documents and Communications between You and 
any members or employees of the United States Small Business Administration, the United States 
Congress, or the Federal Reserve Bank of San Francisco.   
16. 
Documents sufficient to show your home address.  
17. 
All Documents identified, directly or indirectly, in Your answers to Womply’s First 
Set of Interrogatories to You, dated July 19, 2024. 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 60 of 71

 
- 9 - 
Dated: July 19, 2024 
 
 
Of Counsel: 
 
Willkie Farr & Gallagher LLP 
 
Alexander L. Cheney (admitted pro hac vice) 
333 Bush Street  
San Francisco, CA 94104 
(415) 858-7400 
acheney@willkie.com 
 
Stuart R. Lombardi (admitted pro hac vice) 
787 Seventh Avenue 
New York, NY 10019 
(212) 728-8882 
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: 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 159-1     Filed 08/30/24     Page 61 of 71

 
- 10 - 
CERTIFICATE OF SERVICE 
This is to certify that a true and correct copy of the foregoing document has been served 
on the following counsel of record, this 19th day of July 2024, by electronic mail at the email 
addresses indicated below:  
 
Monica Del Pilar Ramos-Benitez 
Roberto A. Camara-Fuertes 
Jaime A. Torrens-Davila 
FERRAIUOLI LLC 
221 Ponce de Leon Ave. 
Suite 500 
San Juan, PR 00917 
(787) 766-7000 
mramos@ferraiuoli.com 
rcamara@ferraiuoli.com 
jtorrens@ferraiuoli.com 
 
 
Jorge L. Piedra (admitted pro hac vice) 
Dwayne Robinson (admitted pro hac vice) 
Michael R. Lorigas (admitted pro hac vice) 
Rasheed K. Nader (admitted pro hac vice) 
KOZYAK TROPIN & THROCKMORTON 
2525 Ponce de Leon Boulevard,  
9th Fl. 
Miami, Florida 33134 
(305) 372-1800 
jpiedra@kttlaw.com 
drobinson@kttlaw.com 
mlorigas@kttlaw.com 
rnader@kttlaw.com 
 
Counsel for Defendants Benworth Capital 
Partners LLC and Bernardo Navarro 
Carla S. Loubriel 
Ricardo F. Casellas 
CASELLAS ALCOVER & 
BURGOS, P.S.C. 
208 Ponce de Leon Ave. 
Popular Center Bldg. Suite 1400 
Hato Rey, PR 00918 
(787) 756-1400 
cloubriel@cabprlaw.com 
rcasellas@cabprlaw.com 
 
 
Counsel for Defendants Benworth 
Capital Partners PR LLC and 
Claudia Navarro 
 
 
 
By: /s/ Alejandro J. Cepeda Diaz 
 
Attorney for Plaintiff Oto Analytics, LLC 
 
 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 62 of 71

 
 
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 FIRST SET OF REQUESTS FOR 
PRODUCTION TO DEFENDANT CLAUDIA NAVARRO 
 
Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure (“Federal Rules”), 
Plaintiff Oto Analytics, LLC (f/k/a Oto Analytics, Inc. d/b/a Womply) (“Womply”) hereby 
requests that, by August 19, 2024, Defendant Claudia Navarro produce for inspection and copying 
the documents and other tangible things described below (the “Requests”) at the offices of 
McConnell Valdés LLC, 270 Muñoz Rivera Ave., Hato Rey PR 00918 in the manner prescribed 
by the Federal Rules.  The following Requests are to be read in accordance with the Definitions 
and Instructions below.  Womply reserves the right to serve additional Requests.  
DEFINITIONS 
 
The following Definitions apply throughout these Requests without regard to 
capitalization.   
1. 
“2021 Transfer” refers to the transfer or transfers of approximately $171 million 
from Benworth FL to Benworth PR during the Summer of 2021, as referenced in the B. Navarro 
Deposition at 326:10–21, 327:21–328:6.   
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 63 of 71

 
- 2 - 
2. 
“ALSA” means the Amended Loan Servicing Agreement, dated September 23, 
2021, by and between Benworth FL and Benworth PR.   
3. 
“B. Navarro Deposition” refers to the deposition of Mr. Navarro in the JAMS 
Arbitration styled, Oto Analytics, Inc. (d/b/a Womply) v. Benworth Capital Partners LLC, Ref. 
No. 1210038203, on October 26, 2022, and December 16, 2022.  
4. 
“C. Navarro Entity” refers to (i) any entity in which Ms. Navarro has or had voting 
or operational control during the Relevant Time Period; (ii) any entity in which Ms. Navarro holds 
or held a majority ownership or equity interest, either directly or indirectly, during the Relevant 
Time Period; or (iii) any trust or similar entity for which Ms. Navarro is or was a beneficiary or 
beneficial owner during the Relevant Time Period.  
5. 
“Benworth FL” refers to Benworth Capital Partners LLC and its members, 
managers, agents, partners, owners, associates, employees, representatives, consultants, 
predecessors in interest, successors, subsidiaries, assignees, licensees, or other persons acting or 
purporting to act on their behalf, and all of their present or former subsidiaries, divisions, and/or 
affiliates. 
6. 
“Benworth PR” refers to Benworth Capital Partners PR LLC and its members, 
managers, agents, partners, owners, associates, employees, representatives, consultants, 
predecessors in interest, successors, subsidiaries, assignees, licensees, or other persons acting or 
purporting to act on their behalf, and all of their present or former subsidiaries, divisions, and/or 
affiliates. 
7. 
“Communication(s)” includes every manner or method of disclosure or transfer or 
exchange of information however made.  This includes without limitation communications 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 64 of 71

 
- 3 - 
conducted in person, by telephone, mail, email, text message, chat, instant message, facsimile, 
personal delivery, or otherwise. 
8. 
“Concerning” includes without limitation referring to, alluding to, responding to, 
relating to, connected with, commenting on, in respect of, about, regarding, discussing, showing, 
describing, 
mentioning, 
reflecting, 
analyzing, 
comprising, 
constituting, 
evidencing, 
memorializing, pertaining to, and/or supporting. 
9. 
“Document(s)” includes without limitation any Communications, writings, 
drawings, graphs, charts, photographs, phone records, tape recordings, notes, diaries, calendars, 
checkbooks, books, papers, accounts, audio, electronic or videotape recordings, emails, text messages, 
and any computer-generated, computer-stored, or electronically-stored matter, and other data 
compilations from which information can be obtained and translated, if necessary, into reasonably 
useable form, including documents stored on laptop computers, personal digital assistants (PDAs), 
Blackberrys, iPhones, iPads, and other similar devices. 
10. 
“LSA” refers to the Loan Servicing Agreement, dated May 31, 2021, by and 
between Benworth FL and Benworth PR.  
11. 
“Mr. Navarro” refers to Defendant Bernardo Navarro. 
12. 
“Ms. Navarro” refers to Defendant Claudia Navarro. 
13. 
“Person” or “Persons” includes without limitation all natural persons, 
corporations, partnerships, or other business associations and all other legal or governmental 
entities or associations. 
14. 
“Solicitation Process” refers to the process by which Benworth FL solicited 
proposals for the services ultimately performed by Benworth FL under the LSA and/or the ALSA, 
including without limitation from “Professional Bank, Lendio, Lenders Cooperative and . . . 
BDO”, as discussed in the B. Navarro Deposition at 285:4–287:16, 348:3–349:15. 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 65 of 71

 
- 4 - 
15. 
“You,” “Your,” or “Yours” refer to Ms. Navarro. 
16. 
To bring within the scope of these Requests all information that might otherwise be 
construed to be outside of their scope, the following rules of construction apply:  (i) the masculine, 
feminine, or neutral pronoun shall not exclude other genders; (ii) the word “including” shall be 
read to mean including without limitation; (iii) the present tense shall be construed to include the 
past tense and vice versa; (iv) references to members, managers, employees, officers, directors, 
owners, agents, or representatives shall include both current and former members, managers, 
employees, officers, directors, owners, agents, and representatives; (v) the words “and” and “or” 
shall be construed in the conjunctive or disjunctive, whichever makes the request more inclusive; 
(vi) the words “any” and “all” are interchangeable; (vii) the use of the singular form of any word 
includes the plural and vice versa. 
17. 
All words and phrases not otherwise defined herein shall be construed in 
accordance with their plain and ordinary meaning. 
INSTRUCTIONS 
1. 
For the purpose of reading, interpreting, or construing the scope of these Requests, 
the terms used shall be given their most expansive and inclusive interpretation. 
2. 
Unless instructed otherwise, each Request shall be construed independently and not 
by reference to any other Request for the purpose of limitation or exclusion, except that each 
Request shall not be construed to call for Documents that are called for by previous Requests. 
3. 
You must respond to each Request separately and fully, unless it is objected to.  If 
You object to any Request, or to any Definition or Instruction applicable thereto, state with 
specificity the objection and legal basis for such objection with citations to appropriate legal 
foundations for such objection.  If You object to only a portion of the Request, or to any Definition 
or Instruction applicable thereto, answer the portion of the Request to which You do not object. 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 66 of 71

 
- 5 - 
4. 
If, in responding to these Requests, You claim any ambiguity in interpreting a 
Request, or in a Definition or Instruction applicable thereto, You should not use that claim as a 
basis for refusing to respond, but You shall set forth as part of Your response to such Request the 
language deemed to be ambiguous and the interpretation used in responding to the Request.  
5. 
In responding to these Requests, You are required to produce all requested 
Documents in Your possession, custody, or control, including without limitation all requested 
Documents in the possession, custody, or control of any of Your predecessors, successors, 
assignees, principals, owners, employees, agents, attorneys, or other Persons acting or purporting 
to act on Your behalf, regardless of location. 
6. 
If any portion of a Document is responsive to any Request, the entire Document 
shall be produced. 
7. 
The Documents shall be produced as they are kept in the ordinary course of 
business. 
8. 
In the event that a copy of a Requested Document is not identical to any other copy 
of the same Document in Your possession, custody, or control, all non-identical copies shall be 
produced.  A Document shall be deemed to be within Your control if You have the right to secure 
the Document or a copy of the Document from another person having possession or custody of the 
Document. 
9. 
The fact that a Document is produced by another party does not relieve You of Your 
obligation to produce Your copy of the same Document, even if the two Documents are identical. 
10. 
If any of these Documents cannot be produced in full, produce them to the extent 
possible, specifying the reasons for Your inability to produce the remainder and stating whatever 
information, knowledge, or belief You have concerning the unproduced portion. 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 67 of 71

 
- 6 - 
11. 
If You withhold any of the requested Documents or portions of Documents under 
a claim of privilege, immunity, or protection, including the attorney-client privilege or work-
product doctrine, You shall provide a written privilege log that sets forth the information required 
by Rule 26(b)(5) of the Federal Rules. 
12. 
If information is redacted or otherwise withheld from a Document produced in 
response to a Request, You shall identify the redaction or otherwise withheld information by 
stamping the word “Redacted” on the Document at each place from which information has been 
redacted or otherwise withheld, and separately log each such redaction on the privilege log. 
13. 
Documents, including but not limited to electronically stored information, shall be 
produced as TIFF image files and document-level extracted text or optical character recognition 
(OCR) text files for scanned documents and redacted documents, and shall be accompanied by an 
image load file (OPT file) and a metadata load file (DAT file).  Documents shall be delivered on 
CD, DVD, USB, or hard drive media, or by file transfer protocol, with clearly marked Bates ranges.  
Womply is available to confer about a stipulation regarding electronically stored information and 
a protective order and confidentiality agreement pursuant to Rule 26(c) of the Federal Rules. 
14. 
Unless otherwise specified, these Requests pertain to the period January 1, 2021 to 
the present (the “Relevant Time Period”).  
15. 
These Requests are continuing in nature.  If You discover further or different 
information, You are required to serve supplementary and amended responses relevant to any of 
these Request and/or produce additional Documents. 
REQUESTS FOR PRODUCTION 
1. 
All Documents and Communications Concerning the drafting and negotiation of 
the LSA.  
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 68 of 71

 
- 7 - 
2. 
All Documents and Communications Concerning the drafting and negotiation of 
the ALSA.  
3. 
All Documents and Communications Concerning the 2021 Transfer. 
4. 
All Documents and Communications Concerning any payments or transfers You 
received from Benworth FL.  
5. 
All Documents and Communications Concerning any payments or transfers You 
received from Benworth PR.  
6. 
All Documents and Communications Concerning any payments or transfers made 
to a C. Navarro Entity by Benworth FL.  
7. 
All Documents and Communications Concerning any payments or transfers made 
to a C. Navarro Entity by Benworth PR. 
8. 
All Documents and Communications Concerning the Solicitation Process.  
9. 
All contracts and agreements between You and Benworth FL, including without 
limitation all employment agreements, consulting agreements, services agreements, ownership 
agreements, and voting agreements.  
10. 
All contracts and agreements between You and Benworth PR, including without 
limitation all employment agreements, consulting agreements, services agreements, ownership 
agreements, and voting agreements. 
11. 
All contracts and agreements between a C. Navarro entity and Benworth FL.  
12. 
All contracts and agreements between a C. Navarro entity and Benworth PR.  
13. 
All Documents and Communications Concerning the formation of Benworth PR.  
14. 
All Documents and Communications Concerning the solvency of Benworth FL. 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 69 of 71

 
- 8 - 
15. 
All Documents and Communications Concerning the services performed by 
Benworth PR, including without limitation all Documents and Communications between You and 
any members or employees of the United States Small Business Administration, the United States 
Congress, or the Federal Reserve Bank of San Francisco. 
16. 
Documents sufficient to show your home address.  
17. 
All Documents identified, directly or indirectly, in Your answers to Womply’s First 
Set of Interrogatories to You, dated July 19, 2024. 
 
Dated: July 19, 2024 
 
 
Of Counsel: 
 
Willkie Farr & Gallagher LLP 
 
Alexander L. Cheney (admitted pro hac vice) 
333 Bush Street  
San Francisco, CA 94104 
(415) 858-7400 
acheney@willkie.com 
 
Stuart R. Lombardi (admitted pro hac vice) 
787 Seventh Avenue 
New York, NY 10019 
(212) 728-8882 
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: 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 159-1     Filed 08/30/24     Page 70 of 71

 
- 9 - 
CERTIFICATE OF SERVICE 
This is to certify that a true and correct copy of the foregoing document has been served 
on the following counsel of record, this 19th day of July 2024, by electronic mail at the email 
addresses indicated below:  
Monica Del Pilar Ramos-Benitez 
Roberto A. Camara-Fuertes 
Jaime A. Torrens-Davila 
FERRAIUOLI LLC 
221 Ponce de Leon Ave. 
Suite 500 
San Juan, PR 00917 
(787) 766-7000 
mramos@ferraiuoli.com 
rcamara@ferraiuoli.com 
jtorrens@ferraiuoli.com 
 
 
Jorge L. Piedra (admitted pro hac vice) 
Dwayne Robinson (admitted pro hac vice) 
Michael R. Lorigas (admitted pro hac vice) 
Rasheed K. Nader (admitted pro hac vice) 
KOZYAK TROPIN & THROCKMORTON 
2525 Ponce de Leon Boulevard,  
9th Fl. 
Miami, Florida 33134 
(305) 372-1800 
jpiedra@kttlaw.com 
drobinson@kttlaw.com 
mlorigas@kttlaw.com 
rnader@kttlaw.com 
 
Counsel for Defendants Benworth Capital 
Partners LLC and Bernardo Navarro 
Carla S. Loubriel 
Ricardo F. Casellas 
CASELLAS ALCOVER & 
BURGOS, P.S.C. 
208 Ponce de Leon Ave. 
Popular Center Bldg. Suite 1400 
Hato Rey, PR 00918 
(787) 756-1400 
cloubriel@cabprlaw.com 
rcasellas@cabprlaw.com 
 
 
Counsel for Defendants Benworth 
Capital Partners PR LLC and 
Claudia Navarro 
 
 
 
By: /s/ Alejandro J. Cepeda Diaz 
 
Attorney for Plaintiff Oto Analytics, LLC 
 
Case 3:23-cv-01034-GMM     Document 159-1     Filed 08/30/24     Page 71 of 71

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