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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 MOTION FOR LEAVE TO SERVE BY
PUBLICATION DEFENDANTS BERNARDO NAVARRO AND CLAUDIA NAVARRO
Pursuant to Standing Order No. 9 for the United District Court for the District of Puerto
Rico, and in accordance with this this Court’s March 31, 2023 Order (ECF No. 38), April 24, 2023
Order (ECF No. 50), May 3, 2023 Order (ECF No. 58), June 13, 2023 Order (ECF Nos. 68, 72;
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 Motion for
Leave to Serve by Publication (the “Motion”) Defendants Bernardo Navarro and Claudio Navarro
(the “Navarros”) and exhibits in the above-captioned action restricted to viewing by the parties
and to publicly file its Motion 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 and sensitive financial
information of the Navarros and their family members, including home addresses, license plate
information, social security numbers, drivers’ licenses, bank account information, and credit
headers. This Court approved redacting much of this same information in its May 3 and June 13
Orders.
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Second, Womply seeks to redact in its Motion and accompanying exhibits material that is
redacted in its publicly filed Complaint and its exhibits, which this Court approved in its March 31,
April 24, and May 3 Orders.
Third, Womply’s Motion 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 (the “Arbitration”). Womply’s Motion and exhibits also include two
transcripts from the Arbitration, which include discussions of material Benworth FL designated as
“Confidential.” Womply seeks to redact this material in accordance with Benworth FL’s
confidentiality designations.
Dated: July 13, 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
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CERTIFICATE OF SERVICE
The undersigned certifies that on July 13, 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: July 13, 2023
By: /s/ Alejandro J. Cepeda Diaz
Attorney for Plaintiff Oto Analytics, LLC
Case 3:23-cv-01034-GMM Document 75 Filed 07/13/23 Page 3 of 3