First Appearance - MET for Responsive Pleading - Benworth PR

Summary

Notice of Appearance and Motion Under Local Civil Rule 6 for Extension of Time to Answer the Complaint, filed February 22, 2023 as Document 16 in OTO Analytics, LLC v. Benworth Capital Partners PR LLC, Benworth Capital Partners LLC, Bernardo Navarro and Claudia Navarro, Civil No. 23-1034 (3:23-cv-01034-GMM), U.S. District Court for the District of Puerto Rico. Defendant Benworth Capital Partners PR LLC gives notice that new counsel will represent it and states that it was served with summons on February 2, 2023, with its response due February 23, 2023. It asks for a first 30-day extension, to March 27, 2023, to investigate the facts and law. The two-page motion is signed by counsel at Casellas Alcover & Burgos PSC.

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

OTO ANALYTICS, LLC,
Plaintiff,
vs.
BENWORTH CAPITAL PARTNERS PR LLC,
BENWORTH CAPITAL PARTNERS LLC,
BERNARDO NAVARRO and CLAUDIA
NAVARRO,
Defendants.
Civil No. 23-1034
NOTICE OF APPEARANCE AND MOTION UNDER LOCAL CIVIL RULE 6 FOR
EXTENSION OF TIME TO ANSWER THE COMPLAINT OR OTHERWISE PLEAD
TO THE HONORABLE COURT:
NOW COMES defendant Benworth Capital Partners PR LLC, through the undersigned
counsel, and respectfully states and prays as follows:
1.
Notice is hereby given that the appearing defendant will be represented by the
undersigned attorneys who were recently retained to assume their legal representation.
2.
The appearing defendant was served with summons on February 2, 2023. The
deadline to respond to the Complaint or otherwise defend currently expires tomorrow, February
23, 2023.
3.
The appearing defendant and their counsel inform the court that it needs additional
time to investigate the pertinent facts and issues of law, so they may properly answer the Complaint
or otherwise respond. Therefore, they request, under Local Civil Rule 6 (authorizing the Clerk of
the Court to grant a first extension of time not to exceed 30 days without further direction of the
Case 3:23-cv-01034-GMM     Document 16     Filed 02/22/23     Page 1 of 2

-2-
Court), a 30-day extension of time to answer the Complaint or otherwise respond, to expire on
March 27, 2023.
4.
If granted, this extension of time would not cause undue prejudice or delay, and it
is sought in the interest of justice.
WHEREFORE, the appearing defendant request the court to: (i) take notice of who will
represent it; and (ii) grant a first 30-day extension of time under L.Cv.R. 6 to answer the Complaint
or otherwise plead to expire on March 27, 2023.
RESPECTFULLY SUBMITTED.
In San Juan, Puerto Rico, today February 22, 2023.
CERTIFICATION: The undersigned counsel hereby certify that the instant document has
been filed with the Court’s CM/ ECF System, which will simultaneously serve notice on all
counsel of record to their registered email addresses.
CASELLAS ALCOVER & BURGOS PSC
PO Box 364924
San Juan, PR 00936-4924
Tel. (787) 756-1400
Fax. (787) 756-1401
rcasellas@cabprlaw.com
cloubriel@cabprlaw.com
/s/ Ricardo F. Casellas
USDC-PR Bar No. 203114
/s/ Carla S. Loubriel Carrión
USDC-PR Bar No. 227509
Case 3:23-cv-01034-GMM     Document 16     Filed 02/22/23     Page 2 of 2

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