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 03/18/2024 05:10 PM INDEX NO. EF2023-281
NYSCEF DOC. NO. 27 RECEIVED NYSCEF: 03/18/2024
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 March 18, 2024, with the exhibits attached thereto, the accompanying
Memorandum of Law, dated March 18, 2024, 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 8th day of April, 2024 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, 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 03/18/2024 05:10 PM INDEX NO. EF2023-281
NYSCEF DOC. NO. 27 RECEIVED NYSCEF: 03/18/2024
Dated: March 18, 2024 COUCH WHITE, LLP
Dona V. Hillman
C s es G. Carlu io, Esq.
Blake C. Saunders, Esq.
Attorneysfor 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
2 of 2
Preview
FILED: GREENE COUNTY CLERK 03/18/2024 05:10 PM INDEX NO. EF2023-281 NYSCEF DOC. NO. 27 RECEIVED NYSCEF: 03/18/2024 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 March 18, 2024, with the exhibits attached thereto, the accompanying Memorandum of Law, dated March 18, 2024, 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 8th day of April, 2024 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, 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. 1 of 2 FILED: GREENE COUNTY CLERK 03/18/2024 05:10 PM INDEX NO. EF2023-281 NYSCEF DOC. NO. 27 RECEIVED NYSCEF: 03/18/2024 Dated: March 18, 2024 COUCH WHITE, LLP Dona V. Hillman C s es G. Carlu io, Esq. Blake C. Saunders, Esq. Attorneysfor 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 2 of 2