The Complaint alleges the defendants were engaged in a scheme involving improper litigation activities and the hiring of process serving agencies engaged in Sewer Service.
The complaint mentions the names of the individuals process servers and agencies it alleges were part of the scheme.
For example, some of the affidavits of service falsely attested that the process server effected "personal service" on the defendant at an address where that person did not live at that time, or never lived.
Other affidavits of service attested that the process server served the defendant at an accurate address but by " substitute service" on a fictitious person, such as a non-existent relative.
Other affidavits of service reported that the process server effected "nail and mail" service on an address where the defendant never lived.
On information and belief, Defendants knew that the affidavits of service were highly likely to be false.
On information and belief, Defendants knew that the vast majority of affidavits of
service supporting Defendants' applications for default judgment were fraudulent.