On August 21, 2023 a
Party Discovery
was filed
involving a dispute between
Apollo Funding Co,
Apollo Funding Co.,
and
Kevin D Haynes,
K Haynes Trucking,
K Haynes Trucking Llc,
K Haynes Trucking Llc-Dba,
for Commercial - Contract
in the District Court of Rockland County.
Preview
FILED: ROCKLAND COUNTY CLERK 08/26/2023 12:48 AM INDEX NO. 034051/2023
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 08/26/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ROCKLAND
X
COUNTY OF ROCKLAND
APOLLO FUNDING CO,
Plaintiff, NOTICE TO TAKE
DEPOSITION
-against-
Index No.: 034051/2023
K HAYNES TRUCKING LLC, DBA K HAYNES
TRUCKING, AND KEVIN DAMONE HAYNES,
Defendant.
X
PLEASE TAKE NOTICE that pursuant to CPLR §3107, the testimony upon oral
examination will be taken of Plaintiff, Apollo Funding Co., whose address is 1545 U.S. 202, suite
203, Pomona, NY 10970, as an adverse party, before a notary public who is not an attorney or
employee of an attorney for any party or prospective party herein and is not a person who would
be disqualified to act as a juror because of interest or because of consanguinity or affinity to any
party herein, at the offices of Dominick Dale Esq., 81 Court Street, Brooklyn, NY 11201, on
September 5, 2023 at 10:00 a.m. with respect to evidence material and necessary in the prosecution
or defense of this action.
DATED: August 26, 2023
Brooklyn, New York
DOMINICK DALE, ESQ
Dominick Dale Esq.
Attorney(s) for Defendant
81 Court Street
Brooklyn, NY 11201
(917) 816-8327
To: Piekarski Law
Attorney(s) for Plaintiff
1 Whitehall Street
Suite suite 200
New York, New York 10004
1 of 1
Document Filed Date
August 26, 2023
Case Filing Date
August 21, 2023
Category
Commercial - Contract
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FILED: ROCKLAND COUNTY CLERK 08/26/2023 12:48 AM INDEX NO. 034051/2023 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 08/26/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ROCKLAND X COUNTY OF ROCKLAND APOLLO FUNDING CO, Plaintiff, NOTICE TO TAKE DEPOSITION -against- Index No.: 034051/2023 K HAYNES TRUCKING LLC, DBA K HAYNES TRUCKING, AND KEVIN DAMONE HAYNES, Defendant. X PLEASE TAKE NOTICE that pursuant to CPLR §3107, the testimony upon oral examination will be taken of Plaintiff, Apollo Funding Co., whose address is 1545 U.S. 202, suite 203, Pomona, NY 10970, as an adverse party, before a notary public who is not an attorney or employee of an attorney for any party or prospective party herein and is not a person who would be disqualified to act as a juror because of interest or because of consanguinity or affinity to any party herein, at the offices of Dominick Dale Esq., 81 Court Street, Brooklyn, NY 11201, on September 5, 2023 at 10:00 a.m. with respect to evidence material and necessary in the prosecution or defense of this action. DATED: August 26, 2023 Brooklyn, New York DOMINICK DALE, ESQ Dominick Dale Esq. Attorney(s) for Defendant 81 Court Street Brooklyn, NY 11201 (917) 816-8327 To: Piekarski Law Attorney(s) for Plaintiff 1 Whitehall Street Suite suite 200 New York, New York 10004 1 of 1