FRBSF Motion to Enforce QuickBooks Order (D.E. 238) — OTO Analytics v. Benworth (N.D. Cal. No. 3:24-cv-03975)

Record facts

U.S. District Court for the District of Puerto Rico · No. 3:23-cv-01034-GMM · Doc. 238 · 2025-05-05 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF PUERTO RICO 
 
FEDERAL RESERVE BANK OF SAN 
FRANCISCO,  
 
Plaintiff, 
 
v. 
 
BENWORTH CAPITAL PARTNERS 
PR, 
LLC; 
BENWORTH 
CAPITAL 
PARTNERS, 
LLC; 
BERNARDO 
NAVARRO and CLAUDIA NAVARRO, 
 
Defendants. 
 
Civil No. 23-01034 (GMM) 
 
 
 
 
 
 
MOTION TO ENFORCE ORDER AT ECF NO. 224 GRANTING PLAINTIFF-
INTERVENOR FEDERAL RESERVE BANK OF SAN FRANCISCO’S 
MOTION TO COMPEL BENWORTH’S QUICKBOOKS ACCOUNTING DATA 
 
TO THE HONOROBLE UNITED STATES DISTRICT JUDGE GINA R. MENDEZ 
MIRO:  
  
COMES NOW Plaintiff Federal Reserve Bank of San Francisco (the “Reserve Bank”) by 
and through undersigned counsel, and respectfully requests that this Court enforce the Order, ECF 
No. 224, granting the Reserve Bank’s Motion to Compel Benworth’s QuickBooks Accounting Data 
(“QuickBooks Motion to Compel” at ECF No. 200) as follows:  
1. 
It has now been over a month since this Court, on March 24, ordered Defendants to 
produce their QuickBooks data, recognizing the Reserve Bank’s legitimate need for financial 
records that Defendants resisted turning over for months.  Despite agreeing that a simple export of 
the QuickBooks data would be the least burdensome and most efficient approach, Defendants 
nonetheless refuse to comply, insisting instead on “supervised access” grounded solely in their 
subjective distrust of the Reserve Bank’s motives.  Their proposed path not only ignores the 
Court’s unambiguous directive but would introduce entirely avoidable logistical challenges over 
Case 3:23-cv-01034-GMM     Document 238     Filed 05/05/25     Page 1 of 13

2 
scheduling, data retrieval, and whether the Reserve Bank has actually received sufficient access. 
Defendants have not—and cannot—articulate any sound basis in fact or law for their refusal to 
simply export the data, and their proposal would mire the Parties and the Court in needless conflict 
and further delay, all to obstruct a legitimate, Court-ordered discovery obligation. Their approach 
should be rejected in favor of a simple export. 
BACKGROUND 
 
2. 
On January 17, 2025, the Reserve Bank filed its QuickBooks Motion to Compel 
seeking an order from this Court compelling Defendants Benworth Capital Partners PR LLC 
(“Benworth PR”), Benworth Capital Partners LLC (“Benworth FL”), Bernardo Navarro (“Mr. 
Navarro”), and Claudia Navarro (together with Mr. Navarro, the “Navarros”; collectively, 
“Defendants”; together with the Reserve Bank, the “Parties”) to  provide “full access to 
Benworth’s QuickBooks data without interference by Defendants’ counsel,”  because this financial 
information is necessary to, among other things, trace the flow of funds among and between 
Defendants and other affiliated entities; assess the value of services provided by Benworth PR to 
Benworth FL; and determine Benworth FL’s solvency.  QuickBooks Motion to Compel at 1-2 & 
12. Following Defendants’ joint opposition and the Reserve Bank’s reply (ECF Nos. 206 & 209), 
on March 24, 2025, the Court entered an Order granting the QuickBooks Motion to Compel 
(“Order” at ECF No. 224).   
3. 
The Order compelled Defendants to produce the QuickBooks data by “either (1) 
provid[ing] Plaintiff-Intervenor with exported data from their QuickBooks database for the period 
January 1, 2020, to the present, or (2) allow[ing] a representative for Plaintiff-Intervenor to have 
access to the QuickBooks database at reasonable times for a reasonable period of time,” with such 
access observed by “a non-attorney representative for Defendants” who “shall not disclose to 
Case 3:23-cv-01034-GMM     Document 238     Filed 05/05/25     Page 2 of 13

3 
Plaintiff or Plaintiff’s counsel any information regarding searches conducted or data retrieved.”1  
The Order also ordered the Parties to “meet and confer to discuss the preferred mode of compliance 
with the Court’s order on or before April 11, 2025.”   
4. 
On March 31, 2025, the Parties met to discuss, among other issues, the preferred 
mode of compliance with the Order (the “First Meet and Confer”).  At the First Meet and Confer, 
both Parties agreed that exporting all data (the “Export” option) would be both feasible and far less 
burdensome on both Parties than arranging for supervised access (the “Supervised Access” 
option).  See Exhibit 1 at 18 (summarizing counsels’ discussions).  Defendants’ counsel also 
explained that they were considering Supervised Access with their client and asked how the 
Reserve Bank envisioned the logistics of that option would work in practice.  The Reserve Bank 
responded that arranging for supervised access would involve significantly more logistical 
complexity than an Export and would require additional information from Defendants, including 
the amount and type of data, whether the access was virtual or on-site, and other information 
learned through a review of the QuickBooks data itself.  Defendants’ counsel represented that they 
would need to discuss these questions with their client and that they would report back to the 
Reserve Bank by April 4, 2025.  On April 4, 2025, Defendants’ counsel represented that their 
client needed additional time to discuss the options and would do so on April 7, 2025. 
5. 
On April 9, 2025, Defendants responded via email asserting a unilateral right to 
determine the mode of access and electing Supervised Access.  Defendants provided no 
 
1  
The operative text of the Order states in full: “Defendants are ordered to either (1) provide Plaintiff-Intervenor 
with exported data from their QuickBooks database for period January 1, 2020, to the present, or (2) allow a 
representative for Plaintiff-Intervenor to have access to the QuickBooks database at reasonable times for a reasonable 
period of time.  A non-attorney representative for Defendants may observe the Plaintiff- Intervenor's representative's 
access to the database, provided, however that such representative shall not disclose to Plaintiff or Plaintiff's counsel 
any information regarding searches conducted or data retrieved.  Parties shall meet and confer to discuss the preferred 
mode of compliance with the Courts' order on or before April 11, 2025.” ECF No. 224.  
Case 3:23-cv-01034-GMM     Document 238     Filed 05/05/25     Page 3 of 13

4 
explanation for their purported election and did not answer any of the logistical questions raised 
during the First Meet and Confer, other than stating that the Supervised Access sessions would be 
“conducted via Zoom.”  Exhibit 1 at 9.   
6. 
On April 11, 2025, the Reserve Bank requested the Parties meet and confer to 
discuss the QuickBooks production and other outstanding discovery issues.  The Parties exchanged 
several emails to select a date and time for the meet and confer, throughout which Defendants 
changed their availability.  On April 16, 2025, the Reserve Bank sent an email requesting that 
Defendants clarify their stance about the QuickBooks mode of compliance and seeking to finalize 
the date and time of the meet and confer as the time proposed by the Defendants (April 24, 2024, 
at 2:30pm).  On April 22, 2025, Defendants indicated their about-face on the form of access to the 
QuickBooks data was motivated by their subjective opinion of the Reserve Bank’s motives for 
filing this suit. See Exhibit 1 at 1-2.   
7. 
On April 24, 2025, the Parties met again to discuss, among other issues, 
Defendants’ preference for Supervised Access (the “Second Meet and Confer”).  At the Second 
Meet and Confer, the Reserve Bank repeated its view that the Court’s order does not give 
Defendants the unilateral right to elect the mode of production of the QuickBooks data and asked 
whether Defendants had any additional detail to share beyond that sessions would be conducted 
via Zoom.  Defendants’ additional information was limited to explaining that each time the Parties 
coordinate to schedule a QuickBooks database access session, the representative for the Reserve 
Bank would be provided a one-time username and password on that day, would access the database 
through their computer, and would share their screen, using Zoom, with Defendants’ non-attorney 
representative.  The Reserve Bank also asked what benefits were gained by Supervised Access, 
Case 3:23-cv-01034-GMM     Document 238     Filed 05/05/25     Page 4 of 13

5 
and Defendants referred to the security of knowing that access to Defendants’ data would be 
supervised.  
8. 
The Reserve Bank explained that this limited explanation did not address the 
burdens previously discussed or answer any questions raised by the Reserve Bank during the First 
Meet and Confer on March 31. Specifically, the Reserve Bank explained that Defendants’ position 
failed to adequately address (1) the difficulties of scheduling multiple rounds of supervised access 
with an undetermined number of individuals, including Reserve Bank attorneys, Reserve Bank 
experts, Benworth personnel required to provide QuickBooks credentials, and Defendants’ non-
attorney representative, (2) the uncertainty over the need for additional access sessions, given 
incomplete and ongoing discovery by Defendants, (3) the Reserve Bank’s lack of knowledge about 
the type and volume of data creating uncertainty over how long a particular access session will 
need to be for sufficient factual development, and (4) Defendants’ failure to describe how they 
envision the Reserve Bank retrieving data in the course of supervised access sessions.  The Reserve 
Bank specifically asked how it could retrieve data through Supervised Access sessions. Defendants 
declined to answer the question and insisted that the Reserve Bank propose exactly what the 
Reserve Bank envisioned doing during remote access sessions and what the Reserve Bank is 
“going to do with the data,” and to somehow answer these questions without revealing privileged 
work product. See Exhibit 2 at 3. The Reserve Bank noted it could not provide these answers 
without knowing what the QuickBooks data contains or having all relevant discovery and again 
requested Defendants’ position on data retrieval, which Defendants declined to share. 
9. 
Given the facts, the Reserve Bank seeks enforcement of the Order from the Court. 
Given that the Parties agreed at the March 31 First Meet and Confer that the less burdensome 
Case 3:23-cv-01034-GMM     Document 238     Filed 05/05/25     Page 5 of 13

6 
option is for the Defendants to export the QuickBooks data, the Reserve Bank requests that the 
Court order the Defendants to export such data within 5 days of the Court’s order.2   
ARGUMENT 
 
I. 
The Court’s Order Does Not Give The Defendants A Unilateral Right To Elect The 
Most Burdensome Mode Of Compliance, And Their Position Is Inconsistent With 
Basic Principles Of The Federal Rules And Judicial Economy.    
 
10. 
The Court’s Order requiring production of Defendants’ QuickBooks data does not 
permit Defendants to unilaterally elect to produce such data via the more burdensome production 
option.  Instead, the Court ordered Defendants to produce the QuickBooks data through one of two 
methods and required the Parties to “meet and confer to discuss the preferred mode of compliance.”  
The Local Rules in this District make clear that the purpose of meet and confer discussions is 
precisely to attempt “to reach an agreement with opposing counsel” prior to bringing a discovery 
dispute to the Court for resolution.  See D.P.R. R. 26(b) (2024).  The Parties have done so and 
agreed that a simple export of QuickBooks data—which the Court found to be discoverable—is 
the least burdensome mode of production.  Defendants agree this is feasible but have asserted a 
right to proceed with Supervised Access without this Court’s approval and—critically—without 
providing any reasoned, fact-based explanation, rationale, or plan.  Defendants have repeatedly 
failed to give a basis or explanation for why an export of the QuickBooks data provides any risk 
to Defendants.  Under Federal Rule of Civil Procedure 26(b)(2)(C)(i), “the court must limit the 
frequency or extent of discovery otherwise allowed by these rules or by local rule if it determines 
that the discovery sought is unreasonably cumulative or duplicative, or can be obtained from some 
other source that is more convenient, less burdensome, or less expensive.”  As discovery shall be 
obtained from the most convenient, less burdensome, and less expensive source, the Court should 
 
2  
See infra n. 7 (explaining alternative relief sought through this Motion).  
Case 3:23-cv-01034-GMM     Document 238     Filed 05/05/25     Page 6 of 13

7 
enforce its Order and require that the Defendants export the data to avoid further disputes and 
significant additional burdens on both parties and counsel.  
a. Supervised Access is Expensive, Burdensome, and Inconvenient 
 
11. 
Supervised Access would drain both Parties’ resources attending to cumbersome 
logistical arrangements, such as repeatedly scheduling and attending sessions, while needlessly 
introducing questions regarding the completeness of the Reserve Bank’s access to the QuickBooks 
data.  Should disputes arise over which files were disclosed or how they were presented during 
supervised sessions, the Parties may be forced to return to this Court to resolve complicated, fact-
intensive issues. All of these burdens could easily be eliminated with a simple Export, which 
allows the Reserve Bank to conduct a complete and efficient review without any looming questions 
for the Parties or Court.  The Court should order an Export for the following reasons:  
12. 
First, discovery remains ongoing, and the Reserve Bank will require access to the 
QuickBooks database multiple times over the next several months as additional facts come to 
light.3  This will require ongoing scheduling between the parties, likely prompting scheduling 
conflicts, which have already occurred, often on short notice from Defendants.4  Under the current 
 
3  
An incomplete list of discovery still to be produced from Defendants includes: (a) production of responsive 
mobile data from the Navarros’ phones, including communications between the Navarros and communications among 
the Navarros and other Benworth employees, (b) production of responsive documents based on search parameters 
agreed during the March 31 meet and confer, and (c) production of promissory notes between the Navarros and 
Benworth or its affiliates.  See Exhibit 2 at 4-5.  In addition, the Reserve Bank’s review of Defendants’ productions 
has required, on multiple occasions, that Defendants make additional productions or, in one case, an entire re-
production due to Defendants’ failure to comply with the ESI protocol. See e.g., Exhibit 1 at 5-6 (observing 
Defendants’ re-production of over 40,000 documents because the prior production did not include family-complete 
communications).  
4  
Defendants’ counsel has previously canceled meet-and-confer discussion on several occasions in these 
proceedings, including October 29, 2024 (Defendants’ counsel canceled less than two hours before the call without 
providing any dates or times to reschedule) and March 25, 2025 (on the morning of the scheduled call, Defendants’ 
counsel proposed rescheduling because they had inadvertently not calendared the Parties’ previously agreed deadline 
for delivering privilege logs, had not yet discussed with their clients the Court’s discovery-related orders issued the 
prior day, and had not completed a previously-agreed review of documents for responsiveness).  The March 25, 2025 
meet-and-confer discussion was only scheduled in the first place after the Reserve Bank’s request on March 11, 2025, 
which was met with multiple delayed responses and the announcement of a rescheduled production by Defendants’ 
Case 3:23-cv-01034-GMM     Document 238     Filed 05/05/25     Page 7 of 13

8 
schedule, fact discovery extends until June 9, 2025, and fact depositions will not be complete until 
August 8, 2025.5  The Reserve Bank will almost certainly require access to the QuickBooks 
database at various time intervals in response to additional information learned through discovery.  
For example, less than two weeks ago, Defendants apparently completed production of documents 
in response to the Reserve Bank’s requests regarding entities controlled by Mr. and Mrs. Navarro.  
The Reserve Bank is actively reviewing these documents, but recent history—including a required 
re-production of over 40,000 documents by Defendants—indicates additional issues may arise 
during that review that require additional productions. See infra n. 3. Moreover, a considerable 
volume of the Defendants’ discovery remains unproduced, including mobile data from the 
Navarros and any communications from Mrs. Navarro.  See Exhibit 2 at 4-5.  Further, scheduling 
conflicts will inevitably arise, and the Parties may disagree about whether the number of sessions 
is “reasonable” under the Court’s Order, potentially requiring further involvement by this Court.6  
Managing such scheduling conflicts during the next several months is a non-essential burden on 
the Parties and the Court’s resources that can be completely avoided by the Export option. 
13. 
Second, Supervised Access would be impractical, burdensome, and inefficient 
because unknown limitations or disputes about the “data retrieved”—which Defendants refused to 
take a position on during the Second Meet and Confer—will hamper the Reserve Bank’s ability to 
iterate on a review strategy and build its case in an efficient and expedient way.  In short, under 
Defendant’s proposal, the Reserve Bank’s factual development will become stop-and-go traffic.  
For example, the Reserve Bank is likely to learn of facts that materially change its understanding 
 
counsel, which further delayed the scheduled discussion.  In January, Defendants also refused to offer any availability 
by any of its attorneys for a nearly two-week period to discuss open discovery matters.  
5  
Order at ECF No. 233. 
6  
Defendants previewed the likelihood of dispute on this issue by stating during the Second Meet and Confer 
that they did not agree with the Reserve Bank that multiple sessions would be necessary.  
Case 3:23-cv-01034-GMM     Document 238     Filed 05/05/25     Page 8 of 13

9 
of QuickBooks data previously reviewed during a given “access session,” requiring another 
“access session” to investigate, for example, a newly relevant time period for key transfers or 
records of Defendants’ relationships with newly-identified third parties.   
14. 
But even then, it is no answer that the Reserve Bank could just request another 
“access session.”  The Reserve Bank, like any litigant, must have the ability to incorporate and 
synthesize new information with what it has previously received, which means re-reviewing 
information and developing connections as it supports is claims and crafts appropriate relief.  This 
process would be hamstrung by Supervised Access and the uncertainty over what data may be 
retrieved from the database.  For example, the Reserve Bank may need to compare multiple 
examples of a certain type of document stored on the QuickBooks database, but an “access session” 
would permit review of only a single document or ledger by one individual at a time.  Furthermore, 
the Reserve Bank, in consultation with its expert, may need to review the QuickBooks data 
alongside documents previously produced from Defendants or third parties, or even work product 
prepared by counsel or its experts.  Whether doing so is even possible under Defendants’ proposal 
is unclear.  And even if it were, the associated burden of securing both Parties’ agreement to any 
necessary protocols, including to protect privileged information, makes obvious the superiority of 
a simple Export.  
b. Supervised Access Provides No Benefits, and Defendants Provide No Facts to 
Justify Overriding the Attendant Burdens 
 
15. 
In the face of these burdens and inefficiencies, Defendants fail to identify any 
affirmative reason for electing Supervised Access other than their subjective view that the Reserve 
Bank has an improper motive for pursuing this litigation.  Defendants’ objection is absurd.  The 
Reserve Bank’s need for the QuickBooks data is genuine, as this Court recognized by issuing its 
Order in the first place.  Defendant’s purported concern that Supervised Access is needed “to 
Case 3:23-cv-01034-GMM     Document 238     Filed 05/05/25     Page 9 of 13

10 
ensure no improper actions are taken with respect to the data,” Exhibit 1 at 2, is vague and 
imprecise, is unmoored from any conduct by the Reserve Bank and, in any case, can be addressed 
by an appropriate designation pursuant to the Protective Order, which the Reserve Bank has 
complied with throughout these proceedings. See ECF No. 176.   
16. 
When the Reserve Bank directly asked, during the Second Meet and Confer, how 
an Export introduced any risk to Defendants or why Supervised Access introduced any benefit, 
Defendants again failed to provide any coherent rationale for their purported election. Instead, 
Defendants repeatedly returned to the idea that the Reserve Bank owed Defendants an explanation 
of what the Reserve Bank intended to do with the QuickBooks data, which has been provided to 
the Defendants numerous times.  In short, Defendants have no answer to the notion that an Export 
is both simple and risk-free. 
c. Supervised Access Is Inconsistent with Applicable Discovery Caselaw 
 
17. 
The Supervised Access option is also not aligned with case law on this issue.  
Courts have repeatedly and consistently ordered and required that production be provided in the 
least burdensome, least expensive, and most convenient way.  See Fed. R. Civ. P. 26(b)(2)(C)(i); 
W Holding Co. v. Chartis Ins. Co. of Puerto Rico, No. CIV. 11-2271 GAG, 2013 WL 1352562, at 
*1 (D.P.R. Apr. 3, 2013) (holding that parties produce static images in load files if it was the least 
burdensome way); Treister v. PNC Bank, No. 05-23207-CIV, 2007 WL 521935, at *1 (S.D. Fla. 
Feb. 15, 2007) (ruling that some discovery was not necessary as it could be found from another 
source that was more convenient and less burdensome); Johns v. United States, No. 0:23-CV-
60576, 2024 WL 2977224, at *2 (S.D. Fla. June 13, 2024) (limiting discovery when there was a 
most convenient, less burdensome, or less expensive option).  
Case 3:23-cv-01034-GMM     Document 238     Filed 05/05/25     Page 10 of 13

11 
18. 
 The Reserve Bank appreciates that the Court’s Order closely tracked the language 
from an order in von Kahle v. Cargill, Inc., No. 1:21-cv-08532, ECF No. 194 (S.D.N.Y. Dec. 13, 
2023) (“von Kahle”) cited in Plaintiff’s QuickBooks Motion to Compel, at 10, which granted a 
similar motion to compel.  But, having now had the benefit of meeting and conferring, it is clear 
that the facts that led the Court to provide access via shared access in von Kahle are not present 
here. 
19. 
Specifically, in von Kahle, the Defendant sought access to Plaintiff’s database, 
which was impossible to export without destroying discoverable data.  QuickBooks Motion to 
Compel at Ex. 5.7    Given that fact, the only way to provide Defendants with access to the data 
while preserving its existence was to utilize a shared access model.  Here, Defendants acknowledge 
that exporting the raw data from QuickBooks is readily feasible and the least burdensome option, 
and there is no basis to think doing so would compromise the underlying data in any way (and 
indeed, Defendants’ stated reason for refusing to export the data is exclusively motive-based and 
has no connection to the kinds of facts present in von Kahle). 
20. 
The purpose of the QuickBooks Motion to Compel and the accompanying Order 
was to provide the Reserve Bank with the discoverable data it sought in the manner least 
burdensome to both parties.  The Defendants do not contest that the Export option is the least 
burdensome production option.   
21. 
Accordingly, the Court should enforce the Order which required the Defendants to 
produce the QuickBooks database via the least burdensome method as mutually selected by the 
 
7  
The von Kahle Court also granted supervised access to the database and prohibited the “non-attorney 
representative of Plaintiff or Plaintiff’s counsel” from disclosing “to Plaintiff or Plaintiff’s counsel” any information 
about Defendant’s searches.  As explained below, the Court’s Order in the instant case prohibited the “non-attorney 
representative for Defendants” from disclosing “to Plaintiff or Plaintiff's counsel any information regarding searches 
conducted or data retrieved.” Plaintiff seeks through this Motion to clarify, in the case of supervised access, that the 
Court’s Order prohibits disclosure to Defendants or their counsel. 
Case 3:23-cv-01034-GMM     Document 238     Filed 05/05/25     Page 11 of 13

12 
Parties.  The Court should enforce the Order based on the Parties’ discussion at the First Meet and 
Confer in which the Parties agreed that the Export method is the least burdensome method and 
order Defendants to export the QuickBooks database within 5 days of the Court’s order, so as to 
avoid the burdens described above and to allow the Reserve Bank fair and efficient access to the 
database.   
WHEREFORE, the Reserve Bank respectfully requests that the Court grant this motion 
and, accordingly, enter an order enforcing the Order at ECF No. 224 requiring that Defendants 
must complete production of the QuickBooks data within 5 days of the Court’s order.  In the 
alternative, should the Court instead agree with the Defendants’ position that they have the 
unilateral right to determine how to manage the QuickBooks data, the Reserve Bank (1) seeks 
clarification that the language in the Order prohibiting the “non-attorney representative for 
Defendants” from disclosing “to Plaintiff or Plaintiff's counsel any information regarding searches 
conducted or data retrieved” was a typographical error, and, in fact, there is a prohibition on the 
disclosure to Defendants or their counsel in the case of supervised access and (2) asks the Court to 
explicitly allow the Reserve Bank to export data during Supervised Access sessions.  
 
 
 
 
 
 
 
 
 
Case 3:23-cv-01034-GMM     Document 238     Filed 05/05/25     Page 12 of 13

13 
Respectfully submitted in San Juan, Puerto Rico on May 5, 2025. 
CERTIFICATE OF SERVICE 
 
 
I certify that on May 5, 2025, I filed a copy of the foregoing document using the Court’s 
CM/ECF system, which will automatically generate a Notice of Electronic Filing to all counsel of 
record in this matter. 
Thomas S. Kessler (admitted pro hac vice) 
tkessler@cgsh.com 
 
CLEARY GOTTLIEB STEEN & 
HAMILTON LLP 
One Liberty Plaza 
New York, New York 10006 
Telephone: (212) 225-2000 
Facsimile: (212) 225-3999 
Attorneys for the Federal Reserve Bank of 
San Francisco  
 
 
s/ Antonio L. Roig Lorenzo 
antonio.roig@oneillborges.com 
USDC-PR No. 207712 
 
s/ Salvador J. Antonetti Stutts  
salvador.antonetti@oneillborges.com 
USDC-PR No. 215002 
 
s/  Ubaldo M. Fernández Barrera 
ubaldo.fernandez@oneillborges.com 
USDC-PR No. 224807 
 
s/ Aníbal A. Román Medina  
anibal.roman@oneillborges.com 
USDC-PR No. 308410 
 
O’NEILL & BORGES LLC 
250 Muñoz Rivera Ave., Ste. 800 
San Juan, PR 00918-1813 
Tel: (787) 764-8181 
Fax: (787) 753-8944 
Attorneys for the Federal Reserve Bank of 
San Francisco 
 
Case 3:23-cv-01034-GMM     Document 238     Filed 05/05/25     Page 13 of 13

File and source

File

gov.uscourts.prd.175040.238.0.pdf

Size

266,463 bytes

SHA-256

8855a2b915070da49418975925510457ed8b9ad8db17170b5d2635c454c82674

Our copy

gov.uscourts.prd.175040.238.0.pdf

Original

PACER (login required)