never received notice of this action by personal service or by mail.
3. Defendant first learned about this action on about September 1, 2011 when thePlaintiff received a Wage Deduction Summons.
Exh. A at ¶ 5.4.The Affidavit of Paul A Schacherer, if unrebutted, should be taken as true and issufficient to support quashing service and setting aside any default judgment entered against himin this case. Nibco Inc. v. Johnson, 98 Ill. 2d 166, 173, 456 N.E.2d 120 (1983); Four LakesManagement and Development Co. v. Brown, 129 Ill. App. 3d 680, 683-84, 472 N.E.2d 1199(2
Dist. 1984).5.Because the Court never obtained personal jurisdiction over Defendant, theservice of process must be quashed and any defaults or ex parte judgments entered againstDefendant Paul A Schacherer are void. See, e.g., Dec and Aque v. Manning, 248 Ill. App. 3d341, 618 N.E.2d 367 (1st Dist. 1993), cert. denied, 153 Ill. 2d 558, 624 N.E.2d 805 (1993);Bank of Ravenswood v. King, 70 Ill. App. 3d 908, 912, 388 N.E.2d 998, 1001 (1
Dist. 1979),quoting Illinois Valley Bank v. Newman, 351 Ill. 380, 383, 184 N.E. 636, 637 (1933) (“A partyclaiming the benefit of a decree upon constructive service must show a strict compliance withevery requirement of the statute, and nothing else will invest the court with jurisdiction or givevalidity to a decree when the same is called into question in a direct proceeding.”)WHEREFORE, Defendant Paul A. Schacherer respectfully requests that this Court enter an order:A.Quashing the service of the summons and complaint in this matter;B.Setting aside and vacating any default orders and ex parte judgments againstDefendant, Paul A. Schacherer andC. Granting any other relief this Court deems just.