Eastern Savings Bank v. Flores

Plaintiff bank filed foreclosure complaint, and served homeowners by substitute service by leaving copy with brother, identified on affidavit of service as a member of household. As Defendant acknowledged that service was valid in original proceeding in July 2009, by signing forbearance agreement, and as waiver of objections to personal jurisdiction applies both prospectively and retroactively under amended Section 2-301 of Code of Civil Procedure, default judgment issued in November 2009 was entered with personal jurisdiction over Defendant. (McBRIDE and TAYLOR, concurring.)