Deutsche Bank National Trust Co. v. Sedys

Court entered default judgments of foreclosure. Defendants argued that judgments were void because record does not reflect that court clerk mailed Defendants a copy of the published notice at address listed in affidavit that Plaintiff prepared in support of service by publication. Records on appeal are insufficiently complete to support Defendants' claims of error. The absence of a clerk's certificate from the record does not, of itself, show a failure to comply with mailing requirement of Section 2-206(a) of Code of Civil Procedure, as proof of mailing may take the form of other documentary evidence and testimony. (ZENOFF and BURKE, concurring.)