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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.
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Civil Action No. 23-01034
MOTION TO RESTRICT WOMPLY’S OPPOSITION TO DEFENDANTS’ MOTIONS
TO DISMISS
Pursuant to Standing Order No. 9 for the United District Court for the District of Puerto
Rico, and in accordance with this Court’s March 31, 2023 Order (“Order”; ECF No. 38), Plaintiff
Oto Analytics, LLC (f/k/a Oto Analytics, Inc. d/b/a Womply) (“Womply”), by and through its
undersigned counsel, seeks leave to file its unredacted Consolidated Opposition to Defendants
Benworth Capital Partners PR LLC’s and Benworth Capital Partners LLC’s Motions to Dismiss
(“Opposition”) and exhibits in the above-captioned action restricted to viewing by the parties and
to publicly file its Opposition and exhibits with redactions.
On March 31, 2023, this Court granted Womply’s Motion to Restrict its Complaint to
viewing by the parties and publicly file its Complaint and exhibits with redactions. (Order at 1.)
Womply’s Opposition cites and quotes material that is redacted in its publicly filed Complaint.
Accordingly, Womply requests leave to redact such material in its publicly filed Opposition.
Case 3:23-cv-01034-GMM Document 48 Filed 04/24/23 Page 1 of 3
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Dated: April 24, 2023
Of Counsel:
Willkie Farr & Gallagher LLP
By: /s/ Alexander L. Cheney
Alexander L. Cheney (admitted pro hac vice)
One Front Street
San Francisco, CA 94111
(415) 858-7400
acheney@willkie.com
Stuart R. Lombardi (admitted pro hac vice)
Willkie Farr & Gallagher LLP
787 7th Avenue
New York, NY 10019
(212) 728-8000
slombardi@willkie.com
Joshua S. Levy (admitted pro hac vice)
1875 K Street, N.W.
Washington, D.C. 20006
(202) 303-1000
jlevy@willkie.com
Respectfully submitted,
By: /s/ Alejandro J. Cepeda Diaz
Alejandro J. Cepeda Diaz
USDC-PR 222110
McConnell Valdés LLC
270 Muñoz Rivera Ave.
Hato Rey PR 00918
Tel: (787) 250-5637
Email: ajc@mcvpr.com
Attorneys for Plaintiff Oto Analytics, LLC
Case 3:23-cv-01034-GMM Document 48 Filed 04/24/23 Page 2 of 3
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CERTIFICATE OF SERVICE
The undersigned certifies that on April 24, 2023, the foregoing document was filed with
the Clerk of the Court using CM/ECF, which sent notices to all parties receiving notifications
through the CM/ECF system.
Dated: April 24, 2023
By: /s/ Alejandro J. Cepeda Diaz
Attorney for Plaintiff Oto Analytics, LLC
Case 3:23-cv-01034-GMM Document 48 Filed 04/24/23 Page 3 of 3