the we were not allowed to proceed with any type of hearing where testimony would have been taken even though we requested to do so and so here i was with their reason i'm asking that  two fifteen and the record exhibit nine of that brief contains the defendant's certified copies of their articles of incorporation i would invite you to examine and compare the certified copies of the articles corporation and he asked me into exact additionally the man we did except based upon his deposition testimony said that he was aware of the paperwork that he took that he's interested in it and that that the secretary of state's records say and what is my affidavit of service say they match so then the next thing i did was ask for the sort of my records from the secretary of state we all know that when a plaintiff bring suit against a corporation they have to identify on their own the right how do they do that they go to the secretary of state's website possibly the secretary of state millionaire so perhaps why we went to further step to get there certified articles of incorporation and make sure that that didn't happen in this case it didn't the plaintiff didn't serve jesse gurley at the address that was indicated by the defendant to defend it is and and allowed to exist as a corporation within the state of illinois because it follows the jury requirements to become a legal entity those statutory requirements the charter document is the articles of incorporation the articles of incorporation specify that a registered agent has to be specifically identified the clinton in this case can't be allowed after the fact to play a shell game and say we're not that just a girly girl is just a girly oh sorry we didn't make a record exactly who you needed to serve as the registered agent and that's what's happening in here and to be registered agent so only only just a girl in the state of illinois that lived with that address was the person we serve he also testified that when he was appointed he didn't live there he didn't know he was appointed and if he was asked he would have said no and  would never agree to do it he testified that his membership terminated in two thousand would seem although in two thousand and fifteen he was still defendants named a registered agent he testified that on his driver's license  address because it took him four years to change it so even the plaintiff had done a brown check on the registration which i had filed hundreds of lawsuits my wife and we don't do that but had that happen it would have still revealed jesse grew and that just was seventeen and eighteen on the record do you recall that happening back in june of two thousand and fifteen a process server coming to you and giving you a paper that was like what's identified he said i don't know remember the exact date but i know i received paperwork somewhere to that that i probably signed for because i knew my son was involved in that group at one time and that's my address anything that comes to my house that's got a name just a girl and i'm interested in that and are you going to accept it yes if it has my name on it and it's a possibility that it could be something i need to follow up stuff honor to do something about it and even if it's for your son you're going to accept it correct do you have the authority to accept to live reason packages and mail on behalf of your son that by that definition the defendant's temple had no registered agent in the state of illinois at the time because the one that they gave it for the two said he didn't want it would have said no and couldn't live at that a the one who we serve who is a bit name an address on their charter document that it is statutorily required in the state of illinois i said yeah i accept it i knew he was involved in that organization i was going to pass that along so there was no one think it's intentionally misleading to identify somebody that you haven't even communicated wed as a registered agent who knowingly because you terminated his membership does not live there anyone that they know his name he would refuse to honde to go and figure out how to serve this entity that's not clean if it she followed to the letter of the rock she went to the secretary of state she got the documents she found just a girly appy address he accepted circuits and identified by law as the registered agent this address that's in detail in the depositions about who did or didn't sign for them but we have certified receipts for all of that that happened several times on and then let's see the order for default clearly did sign one of the green cards i think it's clear from his driver's license photo that i entered into evidence that that is his signature and it says the road on that green card the signed green card i believe that was in december of two thousand fifteen that that was the one with his signature the other one was his mother as father testified they received and testified that it was in that pile of mail that they give to him and that they do get from his  just to briefly bring out and i don't believe that in this case we can reward corporate bad actions at the expense of the plaintiff the plaintiff was injured she brought suit for a premises liability against defendants not a nightclub and she did  follow everything she was supposed to do a lot it's been three years she hasn't been able to connect a scullery it's been a source of expensive litigation and all the evidence in the record before you points to the fact that  defendant was not aware of this lawsuits because defendant didn't do the things required of it by all an oil law by complying with the state sure requirements of the secretary of state they plaintiff did in this case they had it and the other thought i have on this is she wants you to assume that because when it finally came to say teaching there were assets the people were got turned over that he would have early or in the case but based on his testimony that he didn't want to do this he had no intention of doing this and his parents had given him all this information how do we know that he didn't just say i don't want to be involved and throw it away i don't know if you're going to assume the line we have to  possibility of the other and my question is at that point it doesn't matter if he gets if he the case was clear doesn't matter if he gave it to the proper people at the corporation if i if service according to the law