Order for Alternate Service - Pembroke - 5/31/23
State of Michigan in the 18th Circuit Court for the County of Bay. Bay County Court Facility, 1230 Washington Avenue, Bay City, Michigan 989-895-4265. Case No. 23-3157-DO. Hon. Jessie Scott Wood (P47004). Patrick A. Pembroke, Plaintiff, v. Brooke M. Rangel, Defendant. Bock and Wallen, PLC. By: Thomas E. Bock (29488), Attorney for Plaintiff, 708 Center Avenue, Suite 2B, Bay City, Michigan 48708, 989-892-6016, Fax 989-892-4742. Brooke M. Rangel, Defendant in Pro Per. Verified Motion for Ex Parte Order for Alternate Service. Now Comes the Plaintiff, Patrick A. Pembroke, after first being duly sworn, deposes and states as follows:
1. I caused a Complaint for Divorce to be filed March 10, 2023.
2. Plaintiff and Defendant, Brooke M. Rangel, have been separated from each other without contact since April of 2009.
3. A previous action in which Plaintiff was seeking alternate service was dismissed before that could be accomplished. See previous Motion for Alternate Service in Bay County Circuit Court file 22-3186-JS attached herein as Exhibit A. The case was dismissed for lack of progress.
4. I do not know of any employment of business address for Defendant.
5. I hired a Process Server who made multiple efforts at four different addresses to locate Defendant. See the attached Affidavit of Paul R. Jezak, Court Officer, detailing attempts to locate and serve Defendant.
6. Up to and including the date of filing this Motion, I have no information as to the Defendant’s whereabouts nor where she resides. Accordingly, I am unable to accomplish service of process pursuant to MCR 2.105.
Wherefore, Plaintiff respectfully request this Honorable Court order service by alternate means.
I declare that the statements above are true and to the best of my information, knowledge, and belief.
Signed By: Patrick A. Pembroke, Plaintiff.
State of Michigan, County of Bay. On the 12th day of May, 2023 before me personally appeared Patrick A. Pembroke who made oath that he has read the foregoing by his subscribed and that the same is true of his own knowledge, except as to those matters herein stated to be on information and belief, and that to those matters she believes them to be true.
Signed By: Mai Bea Cheng, Notary Public, Bay County, Michigan, My commission expires: November 10, 2027.
Prepared by: Dated: May 10, 2023. Signed By: Thomas E. Bock (P29488), Attorney for Plaintiff. 22-3
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