1. All consumers procured via the www.Iibertya towarranty.coin platform have been notified of the error
in the sample contract. Furthermore, no contracts were activated or accepted with the erroneous CNA
language as our e-sign server boarded the correct contract and the error occurred after Defendants
terminated selling direct to consumers.
Defendants discontinued sales and activation of extended service contracts direct to consumer via
www.libertyautowarrafsty.com in June 2019 as many consumer confused our brand with Liberty
Protection Plans located in New Jersey which is closed. Since June of 2019 www.mot ro.com’s interface
wouldn’t allow us to login and edit PDF’s and changes in BBB relationship. Requests to terminate service
were unanswered. Yet, the site remains live even though no payment for services or hosting has been
provided since June 2019.
Defendants were A+ Rated and an accredited BBB business till roughly September 2019 when
Defendants requested to cancel membership and discontinued paying monthly dues.
Defendants have requested again that »ww.mopro.com terminate site and the domain
www.libertyautcwarrar›ty.cum is set to expire 2/20/2020 and will not be renewed.
It is estimated after refunds and cancellations of extended service contracts roughly 57 were active and
consumers have been notified via email of changes in administration processes. We will
advise consumers of the error on the sample contract even though consumers were not able to get a
quote, email or call the sales department.
Defendants response to allegations of previous fraudulent activity is derived from a tabloid article
written in Oct. 2005. The article disseminates 3’d party opinions and comments, not legal facts. A full
investigation during bankruptcy was conducted and no fraudulent activity was found. Furthermore,
Defendant Anthony Hodel is incarcerated for child support matters, not fraud.
Lastly, Defendants ask the court to set any case management hearings or trial after the release date of
Defendant Hodel from incarceration. Defendants have no ability to communicate via phone or in person
2