Ltr Mtn for defendant Claudia Navarro
Summary
Letter motion of Holland & Knight LLP on behalf of Defendant Claudia Navarro, Joinder in Benworth Defendants' Pre-Motion Letter, in Kolbert v. Benworth Capital Partners LLC et al., Case No. 1:25-cv-00117-FB-VMS, in the U.S. District Court for the Eastern District of New York, filed 03/26/25 as Document 23. The letter, dated March 26, 2025 and addressed to The Honorable Frederic Block, states that Ms. Navarro joins the pre-motion letter (ECF# 17) filed by Co-Defendants Benworth Capital Partners PR LLC and Benworth Financial LLC, and that a notice of appearance is being filed that day. It reserves the right to move to dismiss the Complaint on grounds of improper service of process and lack of personal jurisdiction, and states that a pre motion conference is scheduled for April 10, 2025 at 4:00 PM (ECF #18). It is signed /s/ Sean C. Sheely.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
- Date
- 2025-03-26
Cite this document
“Ltr Mtn for defendant Claudia Navarro.”
Original at ecf.nyed.uscourts.gov, dated 2025-03-26. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2025-03-26-kolbert-v-benworth-capital-partners-llc-et-al-case-no-1/
, SHA-256 ba78fa53fb5e6e56a2c05ef612e5a541019ea706b6aed38a01434bf9874ab299.Full text
787 Seventh Avenue, 31st Floor | New York, NY 10019 | T 212.513.3200 | F 212.385.9010 Holland & Knight LLP | www.hklaw.com Sean C. Sheely +1 212-513-3538 sean.sheely@hklaw.com Atlanta | Austin | Birmingham | Boston | Century City | Charlotte | Chattanooga | Chicago | Dallas | Denver | Fort Lauderdale Houston | Jacksonville | Los Angeles | Miami | Nashville | Newport Beach | New York | Orlando | Philadelphia Portland | Richmond | San Francisco | Stamford | Tallahassee | Tampa | Tysons | Washington, D.C. | West Palm Beach March 26, 2025 Via ECF The Honorable Frederic Block United States District Court Eastern District of New York 225 Cadman Plaza E Brooklyn, NY 11201 Re: Kolbert v. Benworth Capital Partners LLC et al., Case No. 1:25-cv-00117-FB-VMS Joinder in Benworth Defendants’ Pre-Motion Letter Dear Judge Block: Defendant Claudia Navarro (“Ms. Navarro”) hereby joins in the pre-motion letter (ECF# 17) previously filed by Co-Defendants Benworth Capital Partners PR LLC and Benworth Financial LLC, (collectively, the “Benworth Defendants”). In footnote 2 of the Benworth Defendants’ pre-motion letter, we advised this Court that Ms. Navarro had not been served and we did not appear on her behalf. Last Friday, Plaintiff Kolbert filed a Returned Executed Notice Summons (ECF# 19) alleging service of process on Ms. Navarro. Today, we are filing a notice of appearance on behalf of Ms. Navarro and hereby incorporate by reference the defenses set forth in the Benworth Defendants’ pre-motion letter, as well as, reserving her rights to move to dismiss the Complaint on grounds of improper service of process and lack of personal jurisdiction. A pre motion conference is currently scheduled for April 10, 2025 at 4:00 PM (ECF #18). Respectfully submitted, /s/ Sean C. Sheely cc: Counsel of Record (via ECF) Case 1:25-cv-00117-FB-CHK Document 23 Filed 03/26/25 Page 1 of 1 PageID #: 514
File and source
- File
- gov.uscourts.nyed.525917.23.0.pdf
- Size
- 180,097 bytes
- SHA-256
- ba78fa53fb5e6e56a2c05ef612e5a541019ea706b6aed38a01434bf9874ab299
- Original
- PACER (login required)