NOTICE OF MOTION (Motion #001) *Corrected* - NOTICE OF MOTION TO DISMISS COUNTERCLAIMS - Apollo Funding Co v. K Haynes Trucking, K Haynes Trucking Llc-Dba, Kevin D Haynes

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On August 21, 2023 a case was filed by Apollo Funding Co, and Apollo Funding Co., represented by Nichols, Adam Richard, and O'Brien, Sean Michael, against Kevin D Haynes, K Haynes Trucking, K Haynes Trucking Llc, and K Haynes Trucking Llc-Dba, represented by Dale, Dominick R., in the jurisdiction of Rockland County. Judge Hal B Greenwald presiding.

                        
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                          FILED: ROCKLAND COUNTY CLERK 09/05/2023 04:44 PM                                                    INDEX NO. 034051/2023
NYSCEF DOC. NO. 11                                                                          RECEIVED NYSCEF: 09/06/2023




          SUPREME COURT OF THE STATE OF NEW YORK
          COUNTY OF ROCKLAND

           APOLLO FUNDING CO.,
                                                                             Index No.: 136379/2023
                                                          Plaintiff(s),
                                   -against-

           K HAYNES TRUCKING LLC, DBA K HAYNES
           TRUCKING and KEVIN DAMONE HAYNES
                                            Defendants(s),                     NOTICE OF MOTION


                  PLEASE TAKE NOTICE that upon the Affirmation of Sean O’Brien, Esq., and on the exhibits

          attached thereto, and on the Affidavit with all exhibits attached thereto, and Memorandum of Law, and all

          pl…