Mercedes-Benz Financial v. 1188 Stratford Avenue, LLC

Summary

The court held that the defendants timely moved to open the default judgment because they filed their motion within four months after judgment. The trial court abused its discretion by relying on an erroneous timeliness determination that may have affected both the governing legal standard and its assessment of the defendants’ showing under the statute. The judgment was reversed and the matter remanded for an evidentiary hearing before a different judge.