SLEUTHING THE SUMMONS AND COMPLAINT
By Linnea Sinclair-Bernadino, Chief Investigator at island Investigations
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One of the most frustrating experiences for a private investigator involved in process serving can be the repeated return of a summons and complaint because the defendants are no longer at the address provided by the attorney. Often, this can be avoided--and the process server can shine in the attorney's esteem--by a quick but thorough review of both the case file and, more importantly, the exhibits attached to the complaint.
When the client confers with the attorney on the case, he or she may not be aware of the defendant's current address, or alternative address. But documents such as mortgage papers, deeds, contracts, copies of invoices and applications--often an integral part of the lawsuit--may contain the very answers you need to get your lawsuit served.


In a property foreclosure where the owners have abandoned the property, information such as full legal name (including middle initials), spouse's name (or name of significant other), social security numbers and previous addresses (where did they live prior to purchasing the property?) can be of help in getting the complaint served. Private investigators who are certified to serve legal process often utilize the Department of Motor Vehicle database in order to confirm and locate an individual, and the small fact that the subject is not just "John Public" but "John Q. Public" can cut time--and cost--off of a locate necessary to serve the papers. The same is true if "Et Ux" turns out to be "Mary R. Public also known as Mary R. General Public". With this information, often found on deeds or mortgage documents, you now have provided not only middle initials, but a maiden or former married name for the spouse.


If your lawsuit revolved around the collection of fees or monies due a professional client or business there is often a credit application or personal history on file and possibly attached to the suit. If not, have the attorney check with their client; they may have such a document in their files on the defendant. Here again, you should look for full legal names, social security numbers and dates of birth, as well as additional information such as vehicle license tags or driver's license numbers. References or "Person to Contact in Emergency" information is also capable of providing a lead. Rental applications for apartments are great sources of information of this kind.
Copies of invoices can often reveal work telephone numbers for subject (who wanted to be notified prior to the delivery of his furniture) or unpublished home telephone numbers. Credit applications can provide banking associations, relatives, neighbors and sometimes employment history.


Five minutes spent reviewing the exhibits attached to the complaint can save hours of headaches and running in circles. And--just as important--can earn you praise from your client for being thorough, professional and with a sharp eye for detail.

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