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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.
FEDERAL RESERVE BANK OF SAN
FRANCISCO,
Plaintiff-Intervenor,
v.
OTO ANALYTICS, LLC; BENWORTH
CAPITAL PARTNERS PR, LLC;
BENWORTH CAPITAL PARTNERS, LLC;
BERNARDO NAVARRO and CLAUDIA
NAVARRO,
Defendants in Intervention.
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Civil No. 23-01034 (GMM) cons. Civil
No. 24-01313 (GMM)
PLAINTIFF OTO ANALYTICS, LLC’S CERTIFICATE OF COMPLIANCE WITH
FED.R.CIV.P 37(A)(1) AND L.CV.R. 26(B)
TO THE HONORABLE COURT:
COMES NOW Plaintiff Oto Analytics, LLC, d/b/a Womply (“Womply”), through the
undersigned counsel, and very respectfully states and prays:
1.
On December 6, 2024, Womply moved the Court for an order to compel the
Defendants to respond to certain written discovery requests. (Docket Nos. 182, 184).
2.
In compliance with Fed.R.Civ.P. 37(a) and L.Cv.R. 26(b), Womply hereby certifies
that, prior to the filing of the Motion to Compel, Womply made a reasonable and good-faith effort
Case 3:23-cv-01034-GMM Document 185 Filed 12/10/24 Page 1 of 3
to reach an agreement with Defendants’ counsel on the matters set forth on the motion, but that
the parties were unable to reach an agreement.
3.
As stated in the Motion to Compel, the parties exchanged various communications
and participated in video conferences on two separate occasions to discuss Womply’s objections
to Defendant’s discovery responses. (Docket Nos. 182, 184 pp. 5-7). Nevertheless, the parties
could not agree and reached an impasse as to the matters discussed in the motion. Thus, Womply
understands it made reasonable and good faith efforts to resolve the dispute prior to filing its
motion with the Court.
WHEREFORE, Womply respectfully requests that the Court take notice of the above.
Case 3:23-cv-01034-GMM Document 185 Filed 12/10/24 Page 2 of 3
Dated: December 10, 2024
Of Counsel
Willkie Farr & Gallagher LLP
By: /s/ Alexander L. Cheney
Alexander L. Cheney (admitted pro hac vice)
333 Bush St
San Francisco, CA 94104
(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 and Defendant in
Intervention Oto Analytics, LLC
CERTIFICATE OF SERVICE
The undersigned certifies that on this date 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: December 10, 2024
By: /s/ Alejandro J. Cepeda Diaz
Attorney for Plaintiff Oto Analytics, LLC
Case 3:23-cv-01034-GMM Document 185 Filed 12/10/24 Page 3 of 3