On April 26, 2023 a
Motion,Ex Parte
was filed
involving a dispute between
And Warranty Solutions Management Corporation,,
Ws Aftermarket Services Corporation,
and
And Rebecca Schatzel, In Her Individual Capacity,,
Larissa Ortiz D B A We Cover That,
Larissa Ortiz, In Her Individual Capacity,
Peter Schatzel, In His Individual Capacity,
We Cover That,
for Commercial - Business Entity
in the District Court of Greene County.
Preview
FILED: GREENE COUNTY CLERK 10/16/2023 10:37 AM INDEX NO. EF2023-281
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 10/16/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF GREENE
WS AFTERMARKET SERVICES CORPORATION, NOTICE OF MOTION
AND WARRANTY SOLUTIONS MANAGEMENT
CORPORATION, Index No.: EF2023-281
Plaintiffs,
- against -
WE COVER THAT!, LARISSA ORTIS d/b/a WE
COVER THAT!, LARISSA ORTIS, in her individual
capacity, PETER SCHATZEL, in his individual capacity,
and REBECCA SCHATZEL, in her individual capacity,
Defendants.
PLEASE TAKE NOTICE, that upon the annexed Affirmation of Blake C.
Saunders, Esq., dated October 13, 2023, with the exhibits attached thereto, the accompanying
Memorandum of Law, dated October 13, 2023, and upon all of the pleadings heretofore had herein,
the Plaintiffs, WS Aftermarket Services Corporation and Warranty Solutions Management
Corporation, will move this Court at the New York State Courthouse, Greene County, located at
320 Main St, Catskill, NY 12414, on the 3rd day of November, 2023 at 9:30 o'clock in the forenoon
thereof, or as soon thereafter as counsel may be heard, for an Order, pursuant to CPLR § 3215 for
a default judgment against the Defendants, We Cover That!, Larissa Ortis d/b/a We Cover That!,
Lariss Ortis, individually, and Peter Schatzel, individually, on the issue of liability, and for the
Court to set this matter down for inquest on damages and award of equitable relief, and such further
relief as the Court deems just and proper.
PLEASE TAKE FURTHER NOTICE, that pursuant to Section 2214(b) of the CPLR,
Answering Affidavits, if any, must be submitted at least seven days (7) days prior to the return
date of this motion.
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FILED: GREENE COUNTY CLERK 10/16/2023 10:37 AM INDEX NO. EF2023-281
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 10/16/2023
Dated: October 13, 2023 COUCH WHITE LLP
D d J. Hill , Esq.
harles G. C. luccio, Esq.
Blake C. Saunders, Esq.
Attorneys for Plaintiffs'
WS Aftermarket Services Corporation and
Warranty Solutions Management Corporation
540 Broadway
P.O. Box 22222
Albany, New York 12201-2222
Telephone: (518) 426-4600
TO: WE COVER THAT!
59 Weed Road
Freehold, New York 12431
LARISSA ORTIS
d/b/a WE COVER THAT!
59 Weed Road
Freehold, New York 12431
LARISSA ORTIS
59 Weed Road
Freehold, New York 12431
PETER SCHATZEL
59 Weed Road
Freehold, New York 12431
2
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