did not get a mortgage on his property he did not owe anyone any money he did not know anyone is looking for him he did not know that payment twenty felt he is the victim of identity theft and even if i ask you question just to very briefly i don't mortgage on the property in two thousand one he retired and moved to indiana he lived in a mobile home which if they were presidents and he lived in indiana plymouth indiana he owns a lot fierro nine one three  still just they could have found the defendant in this case but the problem is they didn't know he lived out of state in two thousand and ten the problem is in two thousand time they didn't tell out that the information because they didn't follow up on the information that they were provided  i'm really following how they were lacking other than to say that they reference this passive voice but what do you think the affidavit in in brewer extensively in the brief a few different time thing is there any question that actor morales never intended any of these proceedings such as the mediation that went on there is no question that he that the matter be mediated well an attorney there was an order signed but was there a dinner record regarding this reverse mortgage that someone had applied for for two hundred fifty thousand dollars that was attached to a second motion for emergencies day of this scale and it's again it's part of the fraud that simply ivan has committed again is that is their request work a mortgage was it but this mortgage that she took out to my client dr ellis never saw a penny of that ninety thousand dollar home equity line of credit and as i stated before he had paid off this market with original purchased market sometime before that s it indicated that louis for alice either reside at the taylor street address or the evergreen street address in sebring florida and the servers indicate that they attempted to serve him not only at twenty three thirty eight west taylor in chicago but they actually made a trip down to sebring florida spoke to louis morales father said he hadn't heard from him in a couple years seventeen o is there an obligation then to get more information from a an apparent resident living at twenty three thirty eight yes there is but the problem with that is that the current president stated that but that  letter went to the address the taylor street address she appeared in the in the or in indicated that she was there on yap loise morales in his affidavit where he lives up but maybe he lives at the taylor street yes well we can't find him because he's concealing himself in the state or the lives out of state but we don't know what is the rest isn't that what yet david basically says yes sure and it is and again listing the statutory rape they did in cause they found that there was suspicion actual dispute as to whether or not there were mailbox names are no buses and whether or not there was a birthday party going on which again i a specific fact off the top of my head again if you want reason to do that but not really any more grief than your question is good cases require a chat with the neighbors is there any requirement that you go and talk to these people or once cases have you handled where one man goes into a bank and says she's the attorney and they act for another individual and takes out a ninety thousand dollar mortgage how many cases if you have like this one you're  bank said they were the attorney in fact for another individual and got him now thousand dollar mortgage a person you know if i could get back to be our publications or so i do want to mention one thing i realize it wasn't mentioned in either brief but i believe that circumstances as they are in the record you he could have been found and do in fact is that is that an accurate representation of the rest of the decision yes because it is this paragraph i mean ok the first thing they do is willing to her dad's information until two thousand and three three years after service and one year after she was living there and laura said it concedes never lived in california but perry that information is simply wrong so between those three suggestions indiana despite multiple attempts at the chicago address it ended in failure and what we want to see before you were given the only information was traveling between this vast expanse of country and out of state search which invited literally thousands of question presented to the two fourteen a warrant is was service brought and if it was proper whether he actually in the quarter not really doesn't speak to the question well o chair and this is his assets that he owned for twenty some years and to have it rost due to the injustice that that was done with your two motions filed that was moved to washington there was a fourteen wan hearing or anything else the court granted the motion to dismiss the combined motion that was filed yesterday wash service and asking to vacate the judgment under fourteen that's correct your honor the summons by publication must be accompanied by that affidavit showing and demonstrating the duke inquiry it's not enough to say well now you know he lives out states now and twenty fifteen or twenty fifty eight or twenty seventeen when this is coming up and we know he lived out of state and twenty times the information with contrary to each other the information that they're relying on from the server throughout the day that from dumping in florida again that affidavit is in for him it doesn't sta