On July 19, 2021 a
Party Notice
was filed
involving a dispute between
Concordance Healthcare Solutions Llc,
and
Hsiao Chen,
Kori Capital Inc.,
Paf Statutory Trust,
for Commercial Division
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 12/07/2022 06:06 PM INDEX NO. 654450/2021
NYSCEF DOC. NO. 104 RECEIVED NYSCEF: 12/07/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
----------------------------------------------------------------------X
CONCORDANCE HEALTHCARE SOLUTIONS LLC,
Plaintiff, Index No.: 654450/2021
-against- NOTICE OF
CROSS-MOTION
KORI CAPITAL INC., and
PAF STATUTORY TRUST,
Defendants.
----------------------------------------------------------------------X
PLEASE TAKE NOTICE, that upon the annexed Affirmation of Brett G. Canna,
dated December 7, 2022,with exhibits, PAF Statutory Trust’s Memorandum of Law in
Response to Plaintiff Motion for a Default Judgment and in Support of Cross-Motion, and
the motion papers submitted by Plaintiff in support of its motion for a default judgment
against defendant Hsiao Chen, the undersigned will cross-move this Court at the Supreme
Court of the State of New York, County of New York, 60 Centre Street, Room 130, at 9:30
a.m. on the 14h day of December, 2022, or as soon thereafter as counsel can be heard, for
an order: (1) pursuant to CPLR §3215, entering a default judgment against defendant Hsiao
Chen on PAF Statutory Trust’s Cross-Claims for contractual and common law
indemnification and setting forth at the time of trial, inquest or as otherwise determined by
the Court, damages to be awarded; and (2) for such other and further relief as this Court
deems just and proper.
PLEASE TAKE FURTHER NOTICE that pursuant to CLPR § 2214(b),
answering papers and notice of cross-motion, with supporting papers, if any, are to be
served so as to be received by the undersigned no later than seven (7) days before the return
date of this motion.
1 of 2
FILED: NEW YORK COUNTY CLERK 12/07/2022 06:06 PM INDEX NO. 654450/2021
NYSCEF DOC. NO. 104 RECEIVED NYSCEF: 12/07/2022
Dated: New York, New York
December 7, 2022
LIBERMAN CANNA LLP
By:
Brett G. Canna, Esq.
59th
110 East Street, FL 22
New York, New York 10022
Tel. (212) 390-8844
beanna@libermancanna.com
Attorneys for Defendant
PAF Statutory Trust
To: BRYAN CAVE LEIGHTON PAISNER LLP
Chris La Rocco, Esq.
Matias Gallego-Manzano, Esq.
1290 Avenue of Americas
New York, New York 10104
Tel. (212) 541-2000
Attorneys for Plaintiff
ICE MILLER LLP
Heather Maly, Esq.
200 West Madison Street, Suite 3500
Chicago, IL 60606-3417
Tel. (312) 726-8107
Attorneys for Defendant Kori Capital Inc.
and Hsiao Chen
2
2 of 2
Document Filed Date
December 07, 2022
Case Filing Date
July 19, 2021
Category
Commercial Division
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FILED: NEW YORK COUNTY CLERK 12/07/2022 06:06 PM INDEX NO. 654450/2021 NYSCEF DOC. NO. 104 RECEIVED NYSCEF: 12/07/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ----------------------------------------------------------------------X CONCORDANCE HEALTHCARE SOLUTIONS LLC, Plaintiff, Index No.: 654450/2021 -against- NOTICE OF CROSS-MOTION KORI CAPITAL INC., and PAF STATUTORY TRUST, Defendants. ----------------------------------------------------------------------X PLEASE TAKE NOTICE, that upon the annexed Affirmation of Brett G. Canna, dated December 7, 2022,with exhibits, PAF Statutory Trust’s Memorandum of Law in Response to Plaintiff Motion for a Default Judgment and in Support of Cross-Motion, and the motion papers submitted by Plaintiff in support of its motion for a default judgment against defendant Hsiao Chen, the undersigned will cross-move this Court at the Supreme Court of the State of New York, County of New York, 60 Centre Street, Room 130, at 9:30 a.m. on the 14h day of December, 2022, or as soon thereafter as counsel can be heard, for an order: (1) pursuant to CPLR §3215, entering a default judgment against defendant Hsiao Chen on PAF Statutory Trust’s Cross-Claims for contractual and common law indemnification and setting forth at the time of trial, inquest or as otherwise determined by the Court, damages to be awarded; and (2) for such other and further relief as this Court deems just and proper. PLEASE TAKE FURTHER NOTICE that pursuant to CLPR § 2214(b), answering papers and notice of cross-motion, with supporting papers, if any, are to be served so as to be received by the undersigned no later than seven (7) days before the return date of this motion. 1 of 2 FILED: NEW YORK COUNTY CLERK 12/07/2022 06:06 PM INDEX NO. 654450/2021 NYSCEF DOC. NO. 104 RECEIVED NYSCEF: 12/07/2022 Dated: New York, New York December 7, 2022 LIBERMAN CANNA LLP By: Brett G. Canna, Esq. 59th 110 East Street, FL 22 New York, New York 10022 Tel. (212) 390-8844 beanna@libermancanna.com Attorneys for Defendant PAF Statutory Trust To: BRYAN CAVE LEIGHTON PAISNER LLP Chris La Rocco, Esq. Matias Gallego-Manzano, Esq. 1290 Avenue of Americas New York, New York 10104 Tel. (212) 541-2000 Attorneys for Plaintiff ICE MILLER LLP Heather Maly, Esq. 200 West Madison Street, Suite 3500 Chicago, IL 60606-3417 Tel. (312) 726-8107 Attorneys for Defendant Kori Capital Inc. and Hsiao Chen 2 2 of 2