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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 BERNARDO NAVARRO’S
AND CLAUDIA NAVARRO’S MOTION TO QUASH SERVICE OF PROCESS
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 (ECF No. 38) and April 24, 2023
Order (ECF No. 50; together, the “Orders”), 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 Opposition to Bernardo Navarro’s and Claudia Navarro’s (together, the “Navarros”)
Motion To Quash Service Of Process (“Opposition”) and exhibits in the above-captioned action
restricted to viewing by the parties and to publicly file its Opposition and exhibits with redactions.
Womply seeks to redact three categories of information. First, pursuant to Local Civil
Rule 5.2, Womply seeks to redact personally identifying information of the Navarros and their
family members, including home addresses, license plate information, drivers’ licenses, and bank
account information.
Second, Womply seeks to redact in its Opposition and accompanying exhibits material that
is redacted in its publicly filed Complaint and its exhibits, which this Court approved in its
March 31 and April 24 Orders.
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Third, Womply’s Opposition and exhibits include one document and two deposition
transcripts that Benworth Capital Partners LLC (“Benworth FL”) designated as “Confidential”
pursuant to a protective order issued by the arbitrator in a private JAMS arbitration between
Womply and Benworth FL.
Womply seeks to redact this material in accordance with
Benworth FL’s confidentiality designation.
Dated: April 27, 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
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 53 Filed 04/27/23 Page 2 of 3
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CERTIFICATE OF SERVICE
The undersigned certifies that on April 27, 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 27, 2023
By: /s/ Alejandro J. Cepeda Diaz
Attorney for Plaintiff Oto Analytics, LLC
Case 3:23-cv-01034-GMM Document 53 Filed 04/27/23 Page 3 of 3