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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