First Appearance - MET for Responsive Pleading - Claudia Navarro

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Notice of Special Appearance and Motion Under Local Civil Rule 6 for Extension of Time to Answer the Complaint or Otherwise Plead, Document 25 filed February 28, 2023 in OTO Analytics, LLC v. Benworth Capital Partners PR LLC, et al., Civil No. 23-1034 (Case 3:23-cv-01034-GMM), in the U.S. District Court for the District of Puerto Rico. Defendant Claudia Navarro appears by special appearance and without submitting to the jurisdiction of the Court. The motion states that Plaintiff filed an Affidavit of Service indicating that Mrs. Navarro was served with summons on February 7, 2023 through an office administrator who purportedly stated authority to accept service. It requests a first 30-day extension to answer or otherwise plead, to expire on March 30, 2023, and is signed /s/ by Ricardo F. Casellas and Carla S. Loubriel Carrión.

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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 SPECIAL 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 Claudia Navarro, by special appearance and without submitting
to the jurisdiction of this Court, 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.
Yesterday, Plaintiff filed copy of an Affidavit of Service indicating that Mrs.
Navarro was served with summons on February 7, 2023, through Ms. Alondra Goméz, an Office
Administrator who purportedly stated that she was authorized to accept service on behalf of Mrs.
Navarro.  (Docket No. 24.)
3.
Consequently, if properly served, Mrs. Navarro is required to answer or otherwise
defend against the Complaint by today, February 28, 2023.
Case 3:23-cv-01034-GMM     Document 25     Filed 02/28/23     Page 1 of 2

-2-
4.
The appearing defendant and their counsel inform the court that they need
additional time to investigate the pertinent facts and issues of law, so they may properly answer
the Complaint or otherwise respond. Therefore, Ms. Navarro requests, 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 Court), a 30-day extension of time to answer the Complaint or otherwise
respond, to expire on March 30, 2023.
5.
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 30, 2023.
RESPECTFULLY SUBMITTED.
In San Juan, Puerto Rico, today February 28, 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 25     Filed 02/28/23     Page 2 of 2

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