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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 AMENDED COMPLAINT
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; the
“Order”), 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 Amended Complaint and exhibits in
the above-captioned action restricted to viewing by the parties and to publicly file its Amended
Complaint and exhibits with redactions.
The Amended Complaint quotes, describes, and references certain documents and
testimony that Defendant Benworth Capital Partners LLC (“Benworth FL”) designated as
“Confidential” pursuant to a protective order (the “Protected Material”) issued by an arbitrator
in a private JAMS arbitration between Womply and Benworth FL (the “Arbitration”). On
January 17, 2023, the arbitrator in the Arbitration permitted Womply to file Protected Material in
this Court and directed that the “parties shall, consistent with applicable law, take all reasonable
and lawful steps to file the Protected Material under seal.” Womply seeks to redact the material
Benworth FL designated as “Confidential” in the Arbitration, and information Defendants may
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assert is confidential, in its public filing and file the unredacted Amended Complaint and exhibits
restricted to viewing by the parties.
These same redactions were previously approved by this Court’s Order on March 31, 2023
(ECF No. 38).
Dated: July 1, 2024
Of Counsel:
Willkie Farr & Gallagher LLP
By: /s/ Alexander L. Cheney
Alexander L. Cheney (admitted pro hac vice)
333 Bush Street
San Francisco, CA 94111
(415) 858-7400
acheney@willkie.com
Stuart R. Lombardi (admitted pro hac vice)
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
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CERTIFICATE OF SERVICE
The undersigned certifies that on July 1, 2024, 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 1, 2024
By: /s/ Alejandro J. Cepeda Diaz
Attorney for Plaintiff Oto Analytics, LLC
Case 3:23-cv-01034-GMM Document 124 Filed 07/01/24 Page 3 of 3