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  • Kyle R Milk v. David Menard, Janet OmaraReal Property - Other (Article 15 Proceeding) document preview
  • Kyle R Milk v. David Menard, Janet OmaraReal Property - Other (Article 15 Proceeding) document preview
  • Kyle R Milk v. David Menard, Janet OmaraReal Property - Other (Article 15 Proceeding) document preview
  • Kyle R Milk v. David Menard, Janet OmaraReal Property - Other (Article 15 Proceeding) document preview
						
                                

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FILED: OSWEGO COUNTY CLERK 07/14/2021 11:27 AM INDEX NO. EFC-2021-0742 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 07/14/2021 SUPREME COURT STATE OF NEW YORK COUNTY OF OSWEGO KYLE R. MILK, NOTICE OF CROSS-MOTION Index No.EFC-2021-6744 Plaintiff, RJI No. v. Judge: Gilbert DAVID MENARD, JANET O'MARA, JOHN AND JANE DOES #1 - 10. Defendants. MOTION BY: Defendants David Menard and Janet O'Mara TIME, DATE AND PLACE OF MOTION: Supreme Court, County of Oswego located at the Oswego County Courthouse 25 East Oneida Street, Oswego, New York at 9:30 A.M. or as soon as counsel may be heard on July 22, 2021 OBJECTION OF MOTION: a. Dismissal of all Causes of action; and, b. Costs and Disbursements including reasonable attorney's fees; and, c. Such other and further relief as the court finds just and proper. SUPPORTING PLEADINGS: Affidavit of David P. Antonucci with Exhibits; if any. BASIS FOR RELIEF: CPLR 1001(a) and CPLR 3211(a)(10). 1 of 2 FILED: OSWEGO COUNTY CLERK 07/14/2021 11:27 AM INDEX NO. EFC-2021-0742 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 07/14/2021 TIME TO RESPOND: In accordance with CPLR 2214 THIS CROSS-MOTION IS UPON SUBMISSION ONLY. ORAL ARGUMENT IS ALLOWED ONLY BY PERMISSION OR REQUEST OF THE COURT DATED: July 14, 2021 ANTONUCCI LAW FIRM LLP David P. Antonucci Esq. Attorneys for Defendant Office and P.O. Address 12 Public Square Watertown, New York 13601 (315) 788-7300 Antonlaws@nnymail.com and Richard K. Champney P.C. Attorneys for Defendant Office and P.O. Address 4 Market Street, Suite B Alexandria Bay, New York 13607 (315) 482-3660 RKC@Gisco.net To: ERIN M. TYREMAN ESQ. MELVIN AND MELVIN PLLC Attorney for the Plaintiff Office and P.O. Address 217 South Salina Street Watertown, New York 13601 (315) 422-1311 etyreman@melvinlaw.com 2 of 2