IN THE SUPERIOR COURT FOR THE STATE OF ALASKA

THIRD JUDICIAL DISTRICT AT KODIAK

PATRICK M. CALLAHAN and

ROBYN E. GALLAGHER CALLAHAN,

Plaintiffs,

vs.

WILLIAM MICHAEL BACUS, JR.

and WENDY LEE BUNDY,

Defendants.

_________________________

Case No. 3KO-20-00154 CI

NOTICE OF APPLICATION FOR ENTRY OF DEFAULT

To: William Michael Bacus, Jr.

      Wendy Lee Bundy

You are hereby notified that plaintiffs have filed an Application for Entry of Default against you for failure to file a timely answer to the complaint in this action. To avoid entry of default against you your answer must be filed with the court at 204 Mission Road, Room 124, Kodiak, Alaska 99615, within 30 days after the last date of publication of this notice. In addition, a copy of your answer must be sent to the plaintiffs’ attorney, whose address is:

Stuart C. Rader, Esquire

Ingaldson Fitzgerald, P.C.

813 West Third Avenue

Anchorage, Alaska 99501

If you fail to file your answer within the required time, an entry of default and default judgment will be entered against you for the relief demanded in the complaint.

This is an action to recover damages for your intentional non-disclosure of an environmental hazard pursuant to AS 34.70.1010-200.

You have been made a party to this action because you discharged fuel oil on the subject property and failed to disclose that fact to the Plaintiffs as described in the complaint in this action.

DATED: 11-2-20

CLERK OF THE COURT

/s/ Paige Thies

Deputy Clerk

Certificate of Service

The undersigned hereby certifies that on the 27th day of October, 2020, a copy of the foregoing was sent to the following via: U.S. Mail, First Class, Postage Paid

William M. Bacus, Jr.

517 10th Avenue, N.W.

Glenwood, MN 56334

Wendy L. Bundy

517 10th Avenue, N.W.

Glenwood, MN 56334

/s/ Jennifer Ditcharo

Jennifer Ditcharo

Ingaldson, Fitzgerald, P.C.

Lawyers

813 W. 3rd Avenue

Anchorage, Alaska 99501-2001

Phone: (907) 258-8750

FAX: (907) 258-8751

Nov. 9, 16, 23, 30