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EXHIBIT 1
Case 4:24-cv-03975-AMO Document 50-3 Filed 08/29/24 Page 1 of 2
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From:
Daniel Herrera <dherrera@kttlaw.com>
Sent:
Sunday, August 25, 2024 11:47 AM
To:
Levy, Joshua S.; Palmeri, Vincent; Cheney, Alexander; Lombardi, Stuart; Morris, Daniel L.;
Hanley, Katherine; Morton, Adriana
Cc:
Jorge L. Piedra; Dwayne Robinson; Michael Lorigas; Simon S. Grille
Subject:
Benworth Capital Partners LLC v. Oto Analytics, LLC Meet and Confer
*** EXTERNAL EMAIL ***
Counsel,
We would like to have a meet and confer on Monday via zoom to discuss the following items:
1. Response to Womply’s MoƟon to Confirm. Instead of doing briefing separately on Womply's peƟƟon to confirm and
Benworth's peƟƟon to vacate, we propose doing it all together. In other words, Benworth's response to Womply’s
moƟon would also be a cross-peƟƟon to vacate. Under our proposal, Womply would respond in opposiƟon to that
(instead of the peƟƟon filed in the related acƟon), and then Benworth will file a reply that solely addresses our cross-
peƟƟon components. Are you agreeable to this?
2. Extension of Time and Enlargement of Page Limits. Benworth intends to move the Court for an expansion of the page
limits for its response/cross peƟƟon. Along with the request for addiƟonal pages, we intend to ask the Court to extend
our deadline to oppose Womply’s moƟon to confirm unƟl 10 days aŌer it rules on the request for addiƟonal pages.
Would Womply be willing to sƟpulate to this, and a limit of 60 pages?
3. Sealing Documents. As a follow-up to our conversaƟon last week, we would like to discuss our compeƟng moƟons to
seal.
4. ConsolidaƟon. Benworth agrees to consolidate the two acƟons.
Please let me know you availability.
Best,
DANIEL HERRERA, ESQ.
2525 Ponce de Leon Boulevard, Floor 9, Miami, Florida 33134
Phone 305.372.1800 | Direct 305.728.2921 | Email dherrera@kttlaw.com
Firm Bio | Personal LinkedIn | KTT LinkedIn
Case 4:24-cv-03975-AMO Document 50-3 Filed 08/29/24 Page 2 of 2