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MIDWEST COMMERCIAL FUNDING, LLC v. KELLY

No. 1-21-0644.

204 N.E.3d 909 (2022)

2022 IL App (1st) 210644

MIDWEST COMMERCIAL FUNDING, LLC, Plaintiff-Appellee, v. Robert Sylvester KELLY, Defendant, (Sony Music Holdings, Inc., Citation Respondent, and Heather Williams, Adverse Claimant-Appellant).

Appellate Court of Illinois, First District, Fourth Division.

Filed February 17, 2022.

Attorney(s) appearing for the Case

Jeffrey S. Deutschman , of Deutschman & Skafish, P.C., of Chicago, for appellant.

Jamie L. Burns , of Levenfeld Pearlstein, LLC, of Chicago, for appellee.

OPINION

¶ 1 The issue in this case is whether a judgment creditor may perfect service of a citation to discover assets by electronic mail upon a third party prior to that third party's appearance in the matter and, thereby, secure a superior lien over another

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