On February 28, 2024 a
Motion,Ex Parte
was filed
involving a dispute between
and
for AC Suit on Account
in the District Court of Washington County.
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Electronically Filed - WASHINGTON - February 28, 2024 - 03:10 PM
24WA-AC00097
IN THE CIRCUIT COURT OF WASHINGTON COUNTY, MISSOURI
ASSOCIATE CIRCUIT DIVISION
PORTFOLIO RECOVERY ASSOCIATES, LLC
PLAINTIFF, CASE NO.
vs.
TIMOTHY J HALBERT JR,
DEFENDANT.
MOTION FOR ORDER APPOINTING SPECIAL PROCESS SERVER
COMES NOW Plaintiff and moves the Court for an Order pursuant to R.S.Mo. Section
506.140 appointing a special process server to serve process in this case and in support of this
motion states:
1. That expedited service is needed, and furthermore nighttime service may be necessary.
2. That the following are independent contractor process servers:
Grady Barton, John Frago, John Schwab, Kelley Diffey, Michael Shay
3. That the foregoing independent contractor process servers are over eighteen years of
age and are not parties to this case and are contactable at ABC LEGAL SERVICES,
633 YESLER WAY, SEATTLE WA, WA 98104.
4. That the foregoing independent contractor process servers are persons of lawful age
with experience and expertise in serving process upon the parties to litigation and are
duly qualified to serve the summons in this case.
WHEREFORE, Plaintiff prays that foregoing independent contractor process servers be
appointed to serve the Summons and Petition in this case upon Defendant.
Respectfully submitted,
/s/ Sean Hadican
Sean Hadican, Esq. Bar No. 56131
Counsel for Plaintiff
120 Corporate Blvd.
Norfolk, VA, 23502
866/428-8102 Fax: 757/518-0860
Sean.Hadican@portfoliorecovery.com
Document Filed Date
February 28, 2024
Case Filing Date
February 28, 2024
Category
AC Suit on Account
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Electronically Filed - WASHINGTON - February 28, 2024 - 03:10 PM 24WA-AC00097 IN THE CIRCUIT COURT OF WASHINGTON COUNTY, MISSOURI ASSOCIATE CIRCUIT DIVISION PORTFOLIO RECOVERY ASSOCIATES, LLC PLAINTIFF, CASE NO. vs. TIMOTHY J HALBERT JR, DEFENDANT. MOTION FOR ORDER APPOINTING SPECIAL PROCESS SERVER COMES NOW Plaintiff and moves the Court for an Order pursuant to R.S.Mo. Section 506.140 appointing a special process server to serve process in this case and in support of this motion states: 1. That expedited service is needed, and furthermore nighttime service may be necessary. 2. That the following are independent contractor process servers: Grady Barton, John Frago, John Schwab, Kelley Diffey, Michael Shay 3. That the foregoing independent contractor process servers are over eighteen years of age and are not parties to this case and are contactable at ABC LEGAL SERVICES, 633 YESLER WAY, SEATTLE WA, WA 98104. 4. That the foregoing independent contractor process servers are persons of lawful age with experience and expertise in serving process upon the parties to litigation and are duly qualified to serve the summons in this case. WHEREFORE, Plaintiff prays that foregoing independent contractor process servers be appointed to serve the Summons and Petition in this case upon Defendant. Respectfully submitted, /s/ Sean Hadican Sean Hadican, Esq. Bar No. 56131 Counsel for Plaintiff 120 Corporate Blvd. Norfolk, VA, 23502 866/428-8102 Fax: 757/518-0860 Sean.Hadican@portfoliorecovery.com