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82 subject property address, all without success. However, the affidavit also evidenced searches conducted which resulted in the discovery of additional potential addresses for the defendant, one of which was in Merrillville, Indiana. In Merrillville, the process server spoke to an unknown woman getting into her car. When asked if the defendant was at home, the woman replied that she didn't know him. e defendant filed a motion to quash service several months after the foreclosure sale, stating that he'd lived at the Merrillville location for approximately 14 years and arguing that Deutsche Bank failed to properly serve him. e Court agreed. e Court ruled that the plaintiff failed to evidence an "honest and well directed effort" to ascertain the defendant's whereabouts, em- phasizing the fact that the plaintiff only made one attempt at the Merrillville location, which "consisted only of a conversation with some unnamed person in front of the house who said that she did not know [the defendant.] is was not 'due inquiry'." It seems safe to say that the more precise and particular the details of a process server's affidavit is, the stronger a plaintiff 's publica- tion service may be. At a minimum, the name and relationship to a party should always be obtained if a witness's statement is meant to be relied upon. Lauren Riddick handles contested foreclosure matters as a member of the Codilis & Associates, P.C.'s Contested Litigation Unit and also assists with title matters. She joined the firm in August 2013. Prior to joining the firm, she was an Adjunct Professor of Law with several colleges and a Secu- rities Attorney for a large broker-dealer in Florida. Riddick is a member of the Illinois and Florida Bar Associations. She received her Juris Doctor in 2001 from the University of Florida Levin College of Law, and her Bachelor of Science in 1998 from the University of Florida. MICHIGAN Expansion Plans Class Valuation, a national appraisal man- agement company headquartered in Michigan, announced its acquisition of California-based Landmark Network—a real estate valuation firm specializing in the reverse mortgage lend- ing industry. "As we continue to execute our innovation strategy, we will take great interest in those firms that excel in service and reputation in markets we believe in," said Michael Detwiler, CEO of Class Valuation. "With an impressive list of clients, includ- ing a meaningful percentage of the industry's top reverse mortgage lenders, Landmark has done a fantastic job delivering quality, service, and reverse valuation products backed by innovative technology. at's the kind of spe- cialization and expertise we're seeking as we continue to expand our footprint," Detwiler said. Landmark Network was launched with the vision of providing financial services compa- nies with a superior solution for their appraisal management and technology needs. Since inception, the company has been dedicated to providing exceptional customer service to its client base. is vision fits in-line with Class Valua- tion's commitment to service and technology that is shaping the future of the valuation space, so more borrowers can realize their American Dream. "We were very impressed with the strategic plan that Class Valuation presented and look forward to growing together—both organi- cally and through acquisition," said Erik Rich- ard, former CEO of Landmark—now COO of Class Valuation's Western Region. "I'm pleased that the team at Class understands the intrinsic value of customer relationships and service as well as the reverse mortgage market and values we bring to the company. ere is no doubt that this market will continue ILLINOIS Publication Service in Foreclosure By Lauren Riddick In litigation, "personal jurisdiction" is required against all named defendants. e crux of this power flows from the party filing an action (the plaintiff) properly making an individual (the defendant) aware of the litiga- tion filed. Stated another way, if a plaintiff fails to properly make a defendant aware of an action, then personal jurisdiction is lacking, and any orders the court makes are subject to being canceled at any time—even long after litigation is thought to have been concluded. In mortgage foreclosure actions, this can cause additional delays and costs to an often lengthy and expensive process. Publication service, which involves notify- ing a defendant via a local newspaper, requires an affidavit evidencing that a diligent inquiry has occurred to ascertain the defendant's loca- tion. Additionally, in Cook County mortgage foreclosure actions, affidavits must be sworn by the individual who made the "due inquiry," setting forth "with particularity" an "honest and well-directed effort" to ascertain the loca- tion of the defendant. In early 2018, the Fourth Division of the First District Appellate Court held that only one attempt at personal service was suffi- cient, given the circumstances of the case. In Neighborhood Lending Services, Inc. v. Griffin, 2018 IL App (1st) 162855, the defendant's wife stated that the defendant didn't live at the residence and refused to provide any further information. e defendant, appearing nearly a year later, alleged that Neighborhood Lending failed to exercise due inquiry or due diligence. e Court disagreed. "is is a case in which the defendant's spouse—a resident of the single-family home at issue—directly informed the process server that defendant did not reside at that address and no alternate address could be found… ere is no reason to believe that subsequent visits would have yielded any different results ..." Id. ¶ 21-22. Towards the end of 2018, the First Division of the First District Appellate Court encoun- tered a somewhat similar fact pattern, but with a very different result. In Deutsche Bank Nat' l Trust Co. v. Burrell, 2018 (Ill. App. Unpub. LEXIS 1563), the plaintiff filed an affidavit stating that a process server attempted to serve the defendant a total of 29 times at the According to a monthly jobs report released by the Illinois Department of Employment Security, in 2018 Illinois ranked 46 out of 50 states for private sector job growth. KNOW THIS

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