HomeMy WebLinkAbout08-7312I ?o
William L. Adler, Esquire
ADLER & ADLER
125 Locust St.
Harrisburg, PA 17101
Phone: 717-234-3289
Fax: 717-234-1670
Email: wmadler(i0dlerandadler.net
Supreme Court ID: 39844
CMX, Inc.,
Plaintiff
V.
Empire Homes, LLC,
Defendants
IN THE COURT OF COMMON PLEAS
Cumberland COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. p- -7 3 1 )- c N;( f c«
N O T I C E
YOU HAVE BEEN SUED IN COURT. If you wish to defend against
the claims set forth in the following pages, you must take action
within Twenty (20) days after this Complaint and Notice are
served by entering a written appearance personally or by attorney
and filing in writing with the court your defenses or objections
to the claims set forth against you. You are warned that if you
fail to do so the case may proceed without you, and a judgment
may be entered against you by the court without further notice
for any money claimed in the Complaint or for any other claim or
relief requested by the Plaintiff. You may lose money or
property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Ave.
Carlisle, PA 17013
(717) 249-3166
N O T I C I A
Le han demandado a usted an la corte. Si usted guiere
defenderse de estas demandas expuestas en las paginas siguientes,
usted tiene viente (20) dias de plazo al partir de la fecha de la
demanda y la notificacion. Usted debe presentar una apariencia
escrita o en persona o por abogado y archivar en la corte en
forma escrita sus defensas o sus objeciones a las demandas en
contra de su persona. Sea avisado gue si usted no se defienda,
la corte tomara medidas y puede entrar una orden contra usted sin
previo aviso o notificacion y por cualquier gueja o alivio gue es
pedido en la peticion de demanda. Usted puede perder dinero o
sus propiedades o otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE
ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION
SE ENCUNENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE
CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Ave.
Carlisle, PA 17013
(717) 249-3166
CMX, Inc.,
Plaintiff
IN THE COURT OF COMMON PLEAS
Cumberland COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
Empire Homes, LLC, :NO. OF-73/01 1 4 c c/u-
Defendant
COMPLAINT
AND NOW COMES the plaintiff, CMX, Inc., through their attorneys, Adler & Adler,
and respectfully represents the following:
1. Plaintiff, CMX, Inc. is a Pennsylvania corporation with an address of 910 Century Drive,
Mechanicsburg, PA 17055.
2. Defendant, Empire Homes, LLC is a Maryland limited liability corporation with an address of
9175 Guilford Road, Suite 100, Columbia, MD 21046.
3. On August 8, 2006, plaintiff purchased Advantage Engineering, LLC.
4. On September 13, 2006, Advantage Engineering, LLC, changed its name to CMX, Inc.
5. All contracts were assigned from Advantage Engineering, LLC to CMX, Inc.
6. Plaintiff has succeeded to all the rights, title and interest in the Agreement referenced in
paragraph 7 by reason of its purchase of Advantage Engineering, LLC.
7. On or about July 16, 2006, plaintiff and defendant entered into a contract for plaintiff to
provide geotechnical services to defendant. A copy of said written agreement is attached hereto
as Exhibit "A." (the Agreement)
8. The plaintiff was to contour bedrock for defendant in preparation for building a housing
development in Highland Township, Adams County, PA.
9. Plaintiff commenced said work on or around September of 2006.
10. Plaintiff completed said work under said Agreement on or around October of 2006.
11 . Under the Agreement, defendant was to have paid plaintiff $45,745.00.
12. Plaintiff completed all work required under the Agreement in a good and workmanlike
manner.
13. Defendant never made any complaints about the work performed by plaintiff.
14. Defendant informed plaintiff that defendant was unable to pay plaintiff due to financial
difficulties of defendant.
15. Plaintiff sent invoices to defendant, which invoices are attached as Exhibit "B."
16. Plaintiff sent letters to defendant demanding payment.
IT Defendant has failed to pay plaintiff anything for work performed by Plaintiff under the
Agreement.
18. Defendant has breached the contract with plaintiff by failing to pay plaintiff all amounts
due under the Agreement.
WHEREFORE, Plaintiffs respectfully request judgment in its favor in the amount of $45,745.00
together with interest and costs of suit.
William L. Adler, Esquire
Attorney for Plaintiff
ADLER & ADLER
P.O. Box 11933
125 Locust St.
Harrisburg, PA 17108
717-234-3289
Supreme Court ID Number 39844
Wmadler@adlerandadler.net
December 11, 2008
VERIFICATION
I VERIFYTHATTHE STATEMENTS MADE INTHE FOREGOING PLEADING
ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE
MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S.A. Section 4904 RELATING TO
UNSWORN FALSIFICATION TO AUTHORITIES.
DATE: rz- I Z- V
Ju1.19. 2006 9:43AM EMPIRE HOMES No.9267 P. 2/6
Advantage Engineering
N71 /ooll- Geotechnical and Environmental Engineers
July 18, 2006
Mr. James Hanna
Empire Homes
8945 Guildford Road
Suite 100
Columbia, MD 21046
RE: Proposal to Provide Geotechnical Engineering Services
Highland Overlook
Highland Township, Adams County, Pennsylvania
Advantage Proposal No.: 26421b
Dear Mr. Hanna;
Per your request, Advantage Engineering, LLC (Advantage) is pleased to submit the
following proposal to provide geotechnical engineering services for the above-referenced
project.
PROJECT DESCRIPTION
The project will consist of constructing a residential development on Knoxlyn Road in
Highland Township, Adams County, Pennsylvania. The property is approximately 250 acres in
size, and it is anticipated that approximately 280 residential units will be constructed. Existing
surface elevations vary approximately 200 feet across the property.
The objective of our work will be to collect subsurface data in order to aid in the design
of the development as well as most Highland Township and PennDOT requirements. it is
proposed our work be completed in a phased approach with modifications being made to our
scope as additional information is gathered. Details regarding each phase are presented below.
PHASE I - TEST BORINGS AND GEOTECHNICAL ANALYSIS
It is proposed that Phase I of our scope of work will consist of the completion of the
required test borings within the proposed stormwater management facilities and a preliminary
geotechnical analysis of the subsurface conditions at the site. The proposed scope of work for
this phase will include the following: completion of a field investigation, laboratory analysis of
soils, and a geotechnical engineering analysis. Specific items included within each of these
tasks are presented below.
Field Investigation
In an effort to establish the subsurface profile across the site, a total of twelve (12) test
borings will be conducted at the locations determined by the client and will extend to a depth of
approximately twenty-five (25) feet below existing site grades or until the bedrock surface is
encountered. Should soft or weak soil conditions be encountered at the scheduled termination
depths of the borings, the test borings shall be extended until stable soils are identified.
L-J 7584 Morris Ct., Ste. 200 A
Allentown, PA 18076
610-366-7120
610-366-7121 fax
910 Century Drive
Mechanicsburg, PA 17055
717-458-0800
717-458-0801 fax
n 127-A Gaither Drive
Mt. Laurel, NJ 08054
856-231-0800
RAA_719-00Aa f-%-
A
Ju1,19. 2006 9:43AM EMPIRE HOMES No-9267 P. 3/6
Mr. James Hanna
July 18, 2006
Proposal No. 2642b
Page 2 of 6
The test borings will be conducted using truck-mounted drilling equipment and hollow-
stem augers. Samples of the soils encountered will be recovered at suitable intervals and the
Standard Penetration Resistance Test (SPT) values will be recorded. All sampling procedures
will be performed in accordance with the applicable American Society for Testing and Materials
(ASTM) standards.
In order to confirm the character, composition and competency of the bedrock beneath
the site, two (2) five (5) foot bedrock core samples will be retrieved with the use of N,-size
coring equipment in accordance with all applicable ASTM guidelines. Information regarding
percent recovery, RQD, drilling rates, any loss of drill fluids, and the presence of any voids or
soil seams will be carefully recorded.
Laboratory Analysis of Soils
In order to define the physical characteristics of the soils encountered, it is proposed that
laboratory analysis of soils, consisting of a USCS classification, be conducted in accordance
with ASTM 2487 standards and specifications. This testing will Include Atterberg limits
determination, mechanical gradation analysis, and natural moisture content testing. It is
proposed that four (4) standard classification test be performed on representative soil samples
obtained from the project site.
Geofechnica/ Engineering Analysis and Report
A geotechnical engineering analysis and report presenting our results and
recommendations, based on the scope work outlined above, will be prepared which will include
the following:
Geologic Site Evaluation (including terrain description, brief geological history,
and surface drainage conditions)
Description of Subsurface Conditions (including description of exploration and
sampling methods, soil identification and classification)
Results of Geotechnical Analysis
• Test Boring Logs
• Test Boring Profiles
• Test Boring Location Plan
• Results of All Laboratory Testing
• Recommendations Concerning:
Foundation Types (including)
(a) Allowable Bearing Capacity Values
(b) Placement Depths
(c) Design Frost Depths
(d) Preparation of Foundation Areas
Soil Strength Conditions
(a) Stratification Characteristics and Correlated Soil Strengths
(b) Potential for Construction and/or Differential Settlements
General Earthwork Criteria
(a) Use and Treatment of In-situ Materials for Controlled Backfill
(b) Control of Surfa;e Runoff Water and Groundwater
(c) Quality Control Requirements during Foundation Construction
(d) Subgrade Preparation for Slabs and Pavements
Ju1.19. 2006 9:44AM EMPIRE HOMES No.9267 P. 4/6
Mr. James Hanna
July 18, 2006
Proposal No. 2642b
Page 3 of 6
Lateral Earth Pressures for Design of Walls Below Grade
Rock Excavation Characteristics, if Required
PHASE 11-BEDROCK CONTOUR MAPPING AND ROADWAY PROFILE
The objective of the Phase li scope of work will be to determine the approximate bedrock
elevation throughout the proposed development. This scope of work is intended to provide the
client with approximate (tim) bedrock elevation contours throughout the site as well as,
bedrock surface profile along the centerline of the proposed roads. In order to collect the
required data, the following field work will be completed.
One hundred and seventy five (175) geoprobe borings shall be completed along
the center of the proposed roadways. Each test boring will extend to bedrock,
which will be defined as depth of geoprobe refusal.
Two Hundred and Seventy Nine (279) geoprobe borings shall be completed
within each proposed building lot. Each test boring will extend to bedrock, which
will be defined as depth of geoprobe refusal.
Five (5) auger probes and one (1) rock core shall be completed to evaluate the
bedrock competency.
The test borings will be conducted using a truck/track-mounted geoprobe equipped with
sounding points, and will extend to the depths specified above. Each boring location will be field
surveyed with the use of a GPS survey unit capable of both horizontal and vertical accuracy of
one (1) meter. The surface elevation, depth to bedrock, and spatial location of each boring will
be recorded. No soil sampling will be completed during this phase of the investigation.
Based on the data collected during the field investigation a bedrock elevation contour
map will be developed. The contours will be generated using the IDW spline method with
statistical algorithms used to correct for time shift in the GPS unit. The final data will consist of a
contour map delineating the soil to bedrock interface. Accuracy will be sub-meter to the data
points gathered through soil borings. An electronic version of the contour map with two (2) foot
contours will be provided to the client and its engineers in AutoCAD format.
In addition, bedrock profiles will be prepared for the centerline of the proposed roadways
and through the proposed buildings, it is anticipated the roadway profiles will be prepared
based on the roadway profiles provided by the client. The profiles for the buildings will prepared
based on the proposed foundation elevations to be provided by the client.
The test borings will be conducted along the proposed roadways that will be
surveyed in the field by the client. It Is understood that a scaled drawing, depicting the
locations of the proposed roadways and centerlines will be provided prior to the onset of
the field Investigation.
Ju1.19. 2006 9:44AM EMPIRE HOMES
Mr. James Hanna
July 18, 2006
Proposal No. 2642b
Page 5 of 6
PHASE III - PERCOLATION TESTING
Project Coordination and Management
Percolation Test
t=our (4) Tests @ $200.00/Test
Report Analysis and Preparation
Total Phase III Cost
Total Phase I, Il and III Cost
No.9267 P. 5/6
$ 150.00
800.00
$ 500.00
$ 1 A50.00
$ 45,745.00
This proposal also assumes that proposed stormwater facilities and the centerline
of the roadways will be surveyed in the field by others, and an electronic topographic
survey of the site will be provided to Advantage Engineering.
This proposal assumes the use of a truck-mounted drill rig and does not include
additional work caused by unexpected subsurface conditions or by site conditions outside the
control of Advantage Engineering. All samples collected shall be kept ninety (90) days after
completion of site construction unless a written request is submitted prior to this duration.
The field investigation will be completed twenty (20) working days from receipt of written
notice to proceed. This timetable may be adversely affected by weather conditions, as well as
subsurface conditions not anticipated at the time of this proposal. The Geotechnical
Engineering Report will be prepared by a registered Professional Engineer licensed in the
Commonwealth of Pennsylvania and qualified in geotechnical engineering and will be provided
fifteen (15) working days from completion of the field investigation. Three (3) copies of the final
report will be provided to the client.
Ju1.19. 2006 9:44AM EMPIRE HOMES No-9267 P. 6/6
Mr. James Hanna
July 18, 2006
Proposal No. 2642b
Page 6 of 6
Acceptance of this proposal assumes agreement to payment terms of net 30 days from
the Advantage invoice date.
Advantage Engineering, LLC appreciates the opportunity to submit this proposal.
Should you have any questions regarding this proposal, or if we may be of further assistance,
please do not hesitate to contact our office.
Sincerely,
ADVANTAGE ENGINEERING, LLC
David C. Clouser
Director of Environmental Services
To indicate acts ce of th proposal, please sign on the space provided and return
one (1) copy to o p
Accepted By, tF? ?Ofh ?, L L L
Advantage Engineering
Geotechnical and Environmental Engineers
Invoice
Sold To:
Empire Homes
8945 Guildford Road
Suite 100
Columbia, MD 21046
Attn: Mr. James Hanna
Customer PO
Due
Terns
Invoice Number:
060277-1s
Invoice Date:
09/11105
Page:
1 of 1
Project Name
Highland Overlook
Per Advantage Proposal No. 2646b
Phase I
Project Management $150.00
Field Investigation $6,015.00
III
Project Management $400.00
Field Investigation
80% Complete
28,800 X 0.80 $23,040.00
TOTAL $29,605.00
Payment Terms: Due upon receipt. Interest of 1.5% per month will be accrued on all accounts over 30 days
MAKE CHECKS PAYABLE TO:
Advantage Engineering, LLC 717.458.0800 phone
910 Century Drive 717.458.0801 fax
Mechanicsburg, PA 17055 www.advantageenglneering.net
13
Advantage Engineering
Geotechnical and Environmental Engineers
Invoice
Sold To:
Empire Homes
9175 Guilford Road
Suite 100
Columbia, MD 21046
Attn: Mr. James Hanna
Invoice Number:
060277-2s
invoice Date:
10/20/06
Page:
1 of 1
Customer PO Payment Terms Project Name
Due Upon Receipt Highland Overlook
Description Amount
Geophysical Engineering Services
As Per Advantage Proposal No. 2646b
Phase I
Laboratory Analysis $580.00
Report Preparation $1,600.00
Phase II
Field Investigation
Final 20%
$28,800 X 0.20
$5,760.00
Phase III
$1,450.00
TOTAL $9,390.00
Payment Terms: Due upon receipt. Interest of 1.5% per month will be accrued on all accounts over 30 days
MAKE CHECKS PAYABLE TO:
Advantage Engineering, LLC 717.458.0800 phone
910 Century Drive 717.458.0801 fax
Mechanicsburg, PA 17056 www.advantageengineering.net
Advantage Engineering
Geotechnical and Environmental Engineers
Invoice
Sold To:
Empire Homes
9175 Guilford Road
Suite 100
Columbia, MD 21046
Attn: Mr. James Hanna
Invoice Number:
060277-3
Invoice Date:
10/31/06
Page:
1 of 1
Customer PO Payment Terms Project Name
Due Upon Receipt -Highland Overlook
Description Amount
Geophysical Engineering Services
As Per Advantage Proposal No. 2646b
Phase 11
Data Analysis and Contour Preparation $3,750.00
Preparation of Roadway Bedrock Profiles $1,500.00
Preparation of Lot Bedrock Profiles $1,500.00
TOTAL $6,750.00
Payment Terms: Due upon receipt. Interest of 1.5% per month will be accrued on all accounts over 30 days
MAKE CHECKS PAYABLE TO:
Advantage Engineering, LLC 717.458.0800 phone
910 Century Drive 717.458.0801 fax
Mechanicsburg, PA 17055 www.advantageonginearing.net
C
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r-17 i
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Administrative Office (410) 222-1571
P.O. Box 507, Annapolis, INiD 21404 Administrative FAX (410) 222-1583
Anne Arundel County Sheriffs Office
Sheriff Ronald S. Bateman
'Major Paul R. Tabor
Civil Process Division (410) 222-1189 FAX (410) 222-1262
Child Support Enforcement (410) 222-1212 FAX (410) 222-1262
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Warrant Division (410) 222-1490 FAX (410) 222-1262
Warrant Recall and Dispatcher (410) 222-1570 FAX (410) 222-1231
AFFIDAVIT OF SERVICE
STATE OF MARYLAND
COUNTY OF ANNE ARUNDEL
Deputy Sheriff s 01 «?'? being first duly sworn, deposes and says that he, she is a person over 21
years of age and has no interest whatsoever in the below entitled action, and that on the Cr day of
200f bj,/she served Case in C'H X ? iyG vs "00jry e: HI2C--1 fs" '
in the said action upon T -rFL' lie y 13 , k O Z f RG by personally delivering a true copy of summons,
complaint and A10 71C £ to him/her personally and leaving the same at
/ t Qr--" F?ft0 atvp H>111ei vnu f !?f/.2 a/OrOs-"
in the County of Anne Arundel in the State of Maryland.
Signature of Deputy Sheriff
SUBSCRIBED and SWORN BEFORE ,11E THIS day of 2007
and 1 hereby certify that under the taws of Mary land, am authorized t dt ittister oaths.
... '.y% *yvuu ?
V10TAgy Anne Arundel County,, laryland
.a:
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William L. Adler, Esquire
ADLER & ADLER ,
125 Locust St.
Harrisburg, PA 17101
Phone: 717-234-3289
Fax: 717-234-1670
Email. wFinadler&adlerandadler.net
Supreme Court ID: 39844
CMX, Inc.. : IN THE COURT OF COMMON PLEA S
Plaintiff : Cumberland COUNTY, PENNSY LVANIA
". : CIVIL ACTION - LAW
Empire Homes, LLC, : NO.
Defendants
N O T I C E
YOU HAVE BEEN SUED IN COURT. If you wish to defend against
the claims set forth in the following pages, you must take action
within Twenty (20) days after this Complaint and Notice are
served by entering a written appearance personally or by attorney
and filing in writing with the court your defenses or objections
to the claims set forth against you. You are warned that if you
fail to do so the case may proceed without you, and a judgment
may be entered against you by the court without further notice
for any money claimed in the Complaint or for any other claim or
relief requested by the Plaintiff. You may lose money or
property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CAI MOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Ave.
Carlisle, PA 17013
(717) 249-3166
:'; foil goiiy'w o1w?k Itttfdt1447< ? iy}?'?.;?
of 4Wd OW A 69?", t Air
lr --
ADLER & ADLER
ATTORNEYS AT LAW
125 LOCUST STREET
P.O. BOX 11933
HARRISBURG, PENNSYLVANIA 17108-1933
TELEPHONE
(717) 234-3289
FAX (717) 234-1670
WILLIAM L. ADLER
CRAIG L ADLER*
*ALSO ADMITTED TO PRACTICE IN NJ
OVERNIGHT MAIL ADDRESS:
125 LOCUST STREET
HARRISBURG, PENNSYLVANIA 17101
LEWIS F. ADLER
(1934-1984)
DAVID S. KOHN
(1934-1985)
LOUIS 1. ADLER
(1959_1999)
KOHN AND ADLER
(19341960)
KOHN, ADLER & ADLER
(1960-1981)
Anne Arundel County Sheriff
Civil Process
P.O. Box 507
Annapolis, MD 21401
February 26, 2009
RE: Service Civil Complaint
Dear Sheriff:
Enclosed please find a complaint and copy to be served on Empire Homes,
LLC, at The Tech Group, 1111 Benfield Blvd., Millersville, MD 21108. A check
for $60.00 is enclosed for this purpose.
Thank you.
WLA
J16 4
a. ?? 0 F12,0
Very truly yours,
William L. Adler
b i's L'?-I' I (0-ki
OF The !"NOTARY,
2009 AUG 27 Ph E : 0 3
'NTY
FE.
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CMX, Inc. : IN THE COURT OF COMMON PLEAS
Plaintiff : Cumberland COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
Empire Homes, LLC, : NO. 08-7312 Civil Action
Defendant
PRAECIPE TO ENTER DEFAULT JUDGMENT
To the Prothonotary:
Please enter a judgment by default against the defendant in the amount of $45,745.00 plus filing
fees in the amount of $138.50 for a total of $45,883.50.
A ten day notice of default was sent in accordance with PaRCP 237.1, copy of which is
attached.
William L. Adler, Esquire
Attorney for Plaintiff
ADLER & ADLER
P.O. Box 11933
125 Locust St.
Harrisburg, PA 17108
717-234-3289
717-234-1670 (fax)
Supreme Court ID Number 39844
Wmadler@adlerandadler.net
Dated: August 3, 2009
CMX, Inc.,
Plaintiff
V.
Empire Homes, LLC,
Defendants
DATE OF NOTICE: April 1, 2009
To: Defendant: Empire Homes, LLC
Attn: Jeffery Kozero
IN THE COURT OF COMMON PLEAS
Cumberland COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
EM PORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
2 Liberty Ave.
Carlisle, PA 17013
(717) 249-3166
AVISO EAPORTANTE
A: April 1, 2009
To: Defendant
ABOGADO Y SOMETER CON LA CORTE SUS DEFENSAS U OBJECCIONES A LOS
CARGOS QUE SE HAN PRESENTADO CONTRA USTED, A MENOS QUE USTED
ACTUE DENTRO DE DIEZ DIAS DE HABER RECIBIDO ESTE AVISO, LA CORTE
PUEDE TOMAR UNA DECISION EN CONTRA SUYA SIN TENER DERECHOS A UNA
VISTA Y USTED PUEDE PERDER SU PROPIEDAD U OTROS DERECHOS
IMPORTANTES.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI
USTED NO TIENE UN ABOGADO, LLAME 0 VAYA A LA SIGUIENTE OFICINA. ESTA
OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN
ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVIOS DE UN ABOGADO ES POSIBLE QUE
ESTA OFICINA LE PUEDA PROVEER INFORMATION SOBRE AGENCIAS QUE
OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE
CALIFICAN.
Cumberland County Bar Association
2 Liberty Ave.
Carlisle, PA 17013
(717) 249-3165
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