Motion For Substitued Service Against Nancy Carroll (Jackson/Spinks)
Motion For Substitued Service Against Nancy Carroll (Jackson/Spinks)
Motion For Substitued Service Against Nancy Carroll (Jackson/Spinks)
2/16/2016 8:53:01 AM
Velva L. Price
District Clerk
Travis County
D-1-GN-16-000360
Tamara Franklin
INTRODUCTION
The SDR files this Motion pursuant to TEX. R. CIV. P. 106. As more fully described below,
the court has entered a temporary restraining order against Ms. Carroll. Efforts to serve Ms.
Carroll, a Texas resident, with the writ have been unsuccessful. The SDR has now learned that she
has been arrested and is held at the Lake County Illinois jail. Illinois law provides for service on
jail inmates. The SDR requests that the court authorize service on Ms. Carroll pursuant to the
provisions of the Illinois statute. The SDR moves the Court for an order authorizing substituted
service on Ms. Carroll of (i) the Order Granting Special Deputy Receivers Application for a
Temporary Restraining Order [Carroll] and writ,
Receivers Application for a Temporary Injunction and Extending Temporary Restraining Order
FACTS
Ms. Carroll has several aliases including Nancy B. Carroll, Nancy Lelia Carroll, Nancy Jackson
Spinks. She does business under the names of PSS Title, Southwest Bank Acquisitions, LP,
SWBANKACQ, LLC and ZAPP Trust.
2.
The SDR filed its Application to Enforce Permanent Injunction and for Issuance of
Temporary Restraining Order and for Writs of Temporary and Permanent Injunction against Ms.
Carroll and others on February 1, 2016.
3.
On February 2, 2016, this Court entered its Order granting the SDRs Application
for a Temporary Restraining Order (the TRO) enjoining Nancy B. Carroll a/k/a Nancy Jackson
Carroll a/k/a Nancy Carroll; NJC Carroll Law, PLLC d/b/a Integrity Title d/b/a Texas Title;
Millennium 1031 Exchange Services, LLC a/k/a Millennium Title 1031; MT&PS, LLC; ZAPP
TRUST; Southwest Bank Acquisitions, LP; SWBANKACQ, LLC; and PSS Title (collectively,
the Carroll Respondents) and Prosperity Bank; Independent Bank f/k/a Grand Bank; Capitol
One National Association; and Wells Fargo Bank, N.A (collectively, the Bank Respondents).
All of the respondents, with the exception of Nancy B. Carroll a/k/a Nancy Jackson Carroll a/k/a
Nancy Carroll; (Carroll) and her aliases and/or d/b/as ZAPP TRUST; Southwest Bank
Acquisitions, LP; SWBANKACQ, LLC; and PSS Title have been served.
4.
On February 11, 2016 this court entered its Order Granting Special Deputy
Receivers Application for a Temporary Injunction and Extending Temporary Restraining Order
[Carroll].
5.
To date respondent Ms. Carroll, both individually and as d/b/a, has not been served
PAGE 2 OF 8
with this Courts Temporary Restraining Order and writ. Evidence submitted with this motion
establishes that there have been repeated efforts to personally serve Ms. Carroll, that she has left
the state and is presently in custody at the Lake County, Illinois jail.
6.
Respondents as shown in his Affidavits. See Affidavits of Gary Sherman attached hereto as
Exhibit A.
7.
Keller, Texas 76262 known to be Nancy Jackson Carrolls residence. See Exhibit A.
8.
Mr. Sherman made three (3) attempts at varying times at this address but was
This Motion is also supported by the Affidavit of Scott Robert Pomeroy, a licensed
process server in the state of Texas. Mr. Pomeroy has attempted to personally serve the Carroll
Respondents, as shown by his Affidavits. See Affidavits of Scott Robert Pomeroy attached hereto
as Exhibit B.
10.
Mr. Pomeroy attempted to serve the Carroll Respondents at 4401 Hwy 198,
Malakoff, Texas 75148 believed to be Nancy Jackson Carrolls lake house vacation home.
However, Mr. Pomeroy observed that the property was vacant and no one appeared to be living at
that residence. See Exhibit B.
11.
Mr. Pomeroy made two (2) attempts at this address but was unsuccessful as detailed
11, 2016, Nancy Jackson Carroll was arrested in Lake Forest, Illinois by local authorities. Ms.
PAGE 3 OF 8
Carroll was booked by the Lake County Sheriffs Department under her alias, Nancy Jackson
Spinks. She has not been released pending further hearings before the Lake County court.
III.
13.
RELIEF SOUGHT
TEX. R. CIV. P. 108 provides that service on a party that is absent from the state
shall be the same as provided for a party that is in the state. TEX. R. CIV. P. 106(b) authorizes
substituted service at any other place where a party can be found and in a manner to be reasonably
effective to give the party notice of the lawsuit.
14.
Illinois law, 735 Illinois Compiled Statutes 5/2-203.2, provides that an inmate can
be served with process through personal service on a representative of the jail in which the party
is incarcerated, as follows:
Sec. 2-203.2. Service on an inmate. For the security of a correctional institution
or facility or jail, a process server may be refused entry into that correctional institution or
facility or jail. Each correctional institution or facility or jail shall designate a representative
to accept service from a licensed or registered private detective or agency for purposes of
effectuating service upon an inmate in the custody of the institution, facility, or jail. With
respect to an inmate incarcerated in an Illinois Department of Corrections facility, the
process server shall contact the chief administrative officer in advance to arrange and
designate the time and date, during regularly scheduled business hours, that the facility
representative will meet with and accept service from the process server. Service upon a
warden's or sheriff's representative shall constitute substitute service and a mailing to the
inmate of the process shall be completed by the server in accordance with Section 2-202.
A warden's or sheriff's representative accepting substitute service shall forward the process
to the inmate, but if for any reason the process is not forwarded to the inmate, the sheriff,
sheriff's representative, warden, or warden's representative shall not be responsible for any
civil fine or penalty, or have other liability. If for any reason an inmate is not in the
correctional institution or facility or jail at the time of the service of process, a warden's or
sheriff's representative may refuse to accept service for the inmate. If it is determined after
the process has been left with the designated representative, that the inmate is not present
at that institution or facility or jail, the designated representative shall promptly return it to
the licensed or registered private detective or agency, indicating that the substitute service
could not be effectuated. The process server shall promptly notify the court of the
unsuccessful service.
(Source: P.A. 96-1451, eff. 8-20-10.)
15.
Subject to this Courts order, the SDR has arranged for an Illinois process server to serve the
PAGE 4 OF 8
designated representative of the Lake County Jail at 20 S. Country Street, Waukegan, Illinois
60085 on behalf of Ms. Carroll.
16.
Plaintiff requests that the Court issue an order authorizing substituted service on
Ms. Carroll of (i) the Order Granting Special Deputy Receivers Application for a Temporary
Restraining Order [Carroll] and writ, and (ii) Order Granting Special Deputy Receivers
Application for a Temporary Injunction and Extending Temporary Restraining Order [Carroll] and
writ.
17.
The SDR further requests that, in the event Ms. Carroll is released from custody
before substituted service can be accomplished, the court authorize personal service on Mr.
Carroll.
PRAYER
WHEREFORE PREMISES CONSIDERED, Cantilo & Bennett, L.L.P., Special Deputy
Receiver of Millennium Closing Services, L.L.C. d/b/a Millennium Title respectfully requests that
this Court authorize service upon Nancy B. Carroll a/k/a Nancy Jackson Carroll a/k/a Nancy
Carroll, a/k/a Nancy Spinks, d/b/a PSS Title, Southwest Bank Acquisitions, LP, SWBANKACQ,
LLC and ZAPP Trust, in the manner set forth in TEX. R. CIV. P. 106(b) by delivering a true and
correct copy of the (i) Order Granting Special Deputy Receivers Application for a Temporary
Restraining Order [Carroll], Special Deputy Receivers Application to Enforce Permanent
Injunction and for Issuance of Temporary Restraining Order and writ, and (ii) Order Granting
Special Deputy Receivers Application for a Temporary Injunction and Extending Temporary
Restraining Order [Carroll] and writ to Ms. Carroll at the Lake County Jail, 20 S. Country Street,
Waukegan, Illinois 60085 by and through its designated facility representative, and further
PAGE 5 OF 8
authorizing personal service on Ms. Carroll in the event that she is released before she can served
in jail.
Respectfully submitted,
FULLER LAW GROUP
By:
/s/Christopher Fuller
Christopher Fuller
State Bar No. 07515500
4612 Ridge Oak Drive
Austin, Texas 78731
Telephone: (512) 470-9544
Email: cfuller@fullerlaw.org
PAGE 6 OF 8
CERTIFICATE OF SERVICE
I certify that on February 16, 2016, the foregoing Special Deputy Receivers Motion for
Substituted Service was served pursuant to the Texas Rules of Civil Procedure and TEX. INS. CODE
ANN. CHAPTER 443 on the following by electronic mail, except as specifically noted:
Via e-Service: specialmasterclerk@tdi.texas.gov
Special Masters Clerk
TEXAS DEPARTMENT OF INSURANCE
582 Rehabilitation & Liquidation Oversight
PO Box 149104
Austin, Texas 78714-9104
Via e-Service:
Cynthia.Morales@texasattorneygeneral.gov
Cynthia Morales
Assistant Attorney General
Financial, Litigation, Tax, & Charitable Trusts
OFFICE OF THE TEXAS ATTORNEY GENERAL
P.O. Box 12548
Austin, Texas 78711-2548
PAGE 7 OF 8
PAGE 8 OF 8
vs
Exhibit
A
shipped, Mr. Carroll replied that he did not. I then asked Mr. Carroll if he knew where
NANCY JACKSON CARROLL was living, Mr. Carroll replied that he did not. For
unknown reasons and without provocation, Mr. Carroll stated that he knew NANCY
JACKSON CARROLL had hired a criminal attorney.
The residence located at 1805 Queensbridge, Keller, Texas 76262 is owned by ZAPP
TRUST, which its listed address is 771 E. Southlake Blvd, Southlake, Texas 76092.
SCHOOOOOO 117
Exp. 8/31 / 17
Date
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KATHLEEN M. MILLER
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02/04/16 @ 01: l 5pm - I arrived at 1805 Queens bridge, Keller, Texas 76262. After
knocking on the door several times, the door was answered by an unknown male who
identified himself as Shelby Carroll. I asked Mr. Carroll if I could speak with NANCY
JACKSON CARROLL. Mr. Carroll stated that NANCY JACKSON CARROLL does
not live here. I explained to Mr. Carroll that we had found that the vehicle parked in fron
of the home was owned by and registered to NANCY JACKSON CARROLL. Mr.
Carroll replied that NANCY JACKSON CARROLL had parked her vehicle there some
time ago and that I vehicle transport company was supposed to come by and retrieve it to
be shipped elsewhere. I asked Mr. Carroll if he knew where the vehicle was being
shipped, Mr. Carroll replied that he did not. I then asked Mr. Carroll if he knew where
NANCY JACKSON CARROLL was living, Mr. Carroll replied that he did not. For
unknown reasons and without provocation, Mr. Carroll stated that he knew NANCY
JACKSON CARROLL had hired a criminal attorney.
The residence located at 1805 Queensbridge, Keller, Texas 76262 is owned by ZAPP
TRUST, which its listed address is 771 E. Southlake Blvd, Southlake, Texas 76092.
Date
This
vs
be shipped elsewhere. I asked Mr. Carroll if he knew where the vehicle was being
shipped, Mr. Carroll replied that he did not. I then asked Mr. Carroll if he knew where
NANCY JACKSON CARROLL was living, Mr. Carroll replied that he did not. For
unknown reasons and without provocation, Mr. Carroll stated that he knew NANCY
JACKSON CARROLL had hired a criminal attorney.
The residence located at 1805 Queensbridge, Keller, Texas 76262 is owned by ZAPP
TRUST, which its listed address is 771 E. Southlake Blvd, Southlake, Texas 76092.
Date
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shipped, Mr. Carroll replied that he did not. I then asked Mr. Carroll if he knew where
NANCY JACKSON CARROLL was living, Mr. Carroll replied that he did not. For
unknown reasons and without provocation, Mr. Carroll stated that he knew NANCY
JACKSON CARROLL had hired a criminal attorney.
The residence located at 1805 Queensbridge, Keller, Texas 76262 is owned by ZAPP
TRUST, which its listed address is 771 E. Southlake Blvd, Southlake, Texas 76092.
Date
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shipped, Mr. Carroll replied that he did not. I then asked Mr. CaiToll if he knew where
NANCY JACKSON CARROLL was living, Mr. Carroll replied that he did not. For
unknown reasons and without provocation, Mr. Carroll stated that he knew NANCY
JACKSON CARROLL had hired a criminal attorney.
The residence located at 1805 Queensbridge, Keller, Texas 76262 is owned by ZAPP
TRUST, which its listed address is 771 E. Southlake Blvd, Southlake, Texas 76092.
Date
PLAINTIFF(S)
vs.
DEFENDANT(S)
NON-SERVE AFFIDAVIT
On THURSDAY, FEBRUARY 4, 2016, at 12:29 P.M., I received a
CITATION, PLAINTIFF'S ORIGINAL AGREED PETITION, APPLICATION FOR ORDER
APPOINTING LIQUIDATOR AND REQUEST FOR INJUNCTIVE RELIEF, AGREED ORDER
APPOINTING LIQUIDATOR AND PERMANENT INJUNCTION, CIVIL CASE INFORMATION
SHEET AND A DOCUMENT TITLED, THE LAWYER REFERRAL SERVICE OF CENTRAL TEXAS
to be delivered to
Exhibit
B
NON-SERVE AFFIDAVIT FOR NANCY B CARROLL A/K/A NANCY JACKSON CARROLL A/K/A NANCY CARROLL
Page 1 of2
Results
FEBRUARY 4, 2016 1:45 P.M.
Due to the above-referenced information, I am unable to deliver said documents to the Defendant,
_j:!!:__
day
of_-1---<~~U4.o'4.4----' 2016.
:30
"
NON-SERVE AFFIDAVIT FOR NANCY B CARROLL A/KIA NANCY JACKSON CARROLL A/KIA NANCY CARROLL
Page 2 of2
PLAINTIFF(S)
vs.
DEFENDANT(S)
NON-SERVE AFFIDAVIT
On THURSDAY, FEBRUARY 4, 2016, at 12:29 P.M., I received a
TEMPORARY RESTRAINING ORDER WRIT, ORDER GRANTING SPECIAL DEPUTY
RECEIVER'S APPLICATION FOR A TEMPORARY RESTRAINING ORDER [CARROLL],
SPECIAL DEPUTY RECEIVER'S APPLICATION TO ENFORCE PERMANENT INJUNCTION AND
FOR ISSUANCE OF TEMPORARY RESTRAINING ORDER AND FOR WRITS OF TEMPORARY
AND PERMANENT INJUNCTION AND EXHIBIT(S)
to be delivered to
NON-SERVE AFFIDAVIT FOR NANCY B CARROLL A/KIA NANCY JACKSON CARROLL A/KIA NANCY CARROLL
Page t of 2
Time
FEBRUARY 4, 2016 1:45 P.M.
Results
ON THIS FIRST ATTEMPT, THERE WAS NO ONE
AVAILABLE.
THIS HOUSE IS VA CANT.
I LEFT MY CONTACT INFORMATION ON THE FRONT
DOOR OF THE ABODE.
Due to the above-referenced information, I am unable to deliver said documents to the Defendant,
of_-=f.-..!!(;....'1..l..-~~!iC4----' 2016.
"
contact@holeinoneprocess.com
NON-SERVE AFFIDAVIT FOR NANCY B CARROLL A/KIA NANCY JACKSON CARROLL A!K/A NANCY CARROLL
Page 2 of2
PLAINTIFF(S)
vs.
DEFENDANT(S)
NON-SERVE AFFIDAVIT
On THURSDAY, FEBRUARY 4, 2016, at 12:30 P.M., I received a
CITATION, PLAINTIFF'S ORIGINAL AGREED PETITION, APPLICATION FOR ORDER
APPOINTING LIQUIDATOR AND REQUEST FOR INJUNCTIVE RELIEF, AGREED ORDER
APPOINTING LIQUIDATOR AND PERMANENT INJUNCTION, CIVIL CASE INFORMATION
SHEET AND A DOCUMENT TITLED, THE LAWYER REFERRAL SERVICE OF CENTRAL TEXAS
to be delivered to
Page 1 of2
Results
FEBRUARY 4, 2016 1:45 P.M.
Due to the above-referenced information, I am unable to deliver said documents to the Defendant,
_!ft:__
day
of~~~'Llllt.la.l'.K.!.----' 2016.
"
NON-SERVE AFFIDA VTT FOR PSS TITLE C/O NANCY JACKSON CARROLL
Page 2 of 2
PLAINTIFF(S)
53RDJUDICIAL DISTRICT
vs.
DEFENDANT(S)
NON-SERVE AFFIDAVIT
On THURSDAY, FEBRUARY 4, 2016, at 12:30 P.M., I received a
TEMPORARY RESTRAINING ORDER WRIT, ORDER GRANTING SPECIAL DEPUTY
RECEIVER'S APPLICATION FOR A TEMPORARY RESTRAINING ORDER [CARROLL],
SPECIAL DEPUTY RECEIVER'S APPLICATION TO ENFORCE PERMANENT INJUNCTION AND
FOR ISSUANCE OF TEMPORARY RESTRAINING ORDER AND FOR WRITS OF TEMPORARY
AND PERMANENT INJUNCTION AND EXHIBIT(S)
to be delivered to
Results
FEBRUARY 4, 2016 1:45 P.M.
Due to the above-referenced information, I am unable to deliver said documents to the Defendant,
PSS TITLE C/O NANCY JACKSON CARROLL
I do not have any other information about PSS TITLE C/O NANCY JACKSON CARROLL.
the ~ day o~
"
Page 2 of2
'2016.
PLAINTIFF(S)
vs.
DEFENDANT(S)
NON-SERVE AFFIDAVIT
On THURSDAY, FEBRUARY 4, 2016, at 12:31 P.M., I received a
TEMPORARY RESTRAINING ORDER WRIT, ORDER GRANTING SPECIAL DEPUTY
RECEIVER'S APPLICATION FOR A TEMPORARY RESTRAINING ORDER [CARROLL],
SPECIAL DEPUTY RECEIVER'S APPLICATION TO ENFORCE PERMANENT INJUNCTION AND
FOR ISSUANCE OF TEMPORARY RESTRAINING ORDER AND FOR WRITS OF TEMPORARY
AND PERMANENT INJUNCTION AND EXHIBIT(S)
to be delivered to
SOUTHWEST BANK ACQUISITIONS LP C/O NANCY JACKSON CARROLL
at the address,
4401 HIGHWAY 198, MALAKOFF, TEXAS 75148
NON-SERVE AFFIDAVIT FOR SOUTHWEST BANK ACQUISITIONS LP C/O NANCY JACKSON CARROLL
Page l of 2
Results
FEBRUARY 4, 2016 1:45 P.M.
Due to the above-referenced information, I am unable to deliver said documents to the Defendant,
.!ft::_
~----+~~UL\.c~.c.\----' 2016.
day ofL
"
contact@holeinoneprocess.com
NON-SERVE AFFIDAVIT FOR SOUTHWEST BANK ACQUISITIONS LP C/O NANCY JACKSON CARROLL
Page 2 of2
PLAINTIFF(S)
vs.
DEFENDANT(S)
NON-SERVE AFFIDAVIT
On THURSDAY, FEBRUARY 4, 2016, at 12:31 P.M., I received a
CITATION, PLAINTIFF'S ORIGINAL AGREED PETITION, APPLICATION FOR ORDER
APPOINTING LIQUIDATOR AND REQUEST FOR INJUNCTIVE RELIEF, AGREED ORDER
APPOINTING LIQUIDATOR AND PERMANENT INJUNCTION, CIVIL CASE INFORMATION
SHEET AND A DOCUMENT TITLED, THE LAWYER REFERRAL SERVICE OF CENTRAL TEXAS
to be delivered to
SOUTHWEST BANK ACQUISITIONS LP
C/O NANCY JACKSON CARROLL
at the address,
4401 HIGHWAY 198, MALAKOFF, TEXAS 75148
NON-S ERVE AFFIDAVIT FOR SOUTHWEST BANK ACQUISITIONS LP C/O NANCY JACKSON CARROLL
Page 1 of2
Results
FEBRUARY 4, 2016 1:45 P.M.
Due to the above-referenced information, I am unable to deliver said documents to the Defendant,
,,
NON-SERVE AFFIDAVIT FOR SOUTHWEST BANK ACQUISITIONS LP C/O NANCY JACKSON CARROLL
Page 2 of2
' 2016.
PLAINTIFF(S)
vs.
DEFENDANT(S)
NON-SERVE AFFIDAVIT
On THURSDAY, FEBRUARY 4, 2016, at 12:32 P.M., I received a
CITATION, PLAINTIFF'S ORIGINAL AGREED PETITION, APPLICATION FOR ORDER
APPOINTING LIQUIDATOR AND REQUEST FOR INJUNCTIVE RELIEF, AGREED ORDER
APPOINTING LIQUIDATOR AND PERMANENT INJUNCTION, CIVIL CASE INFORMATION
SHEET AND A DOCUMENT TITLED, THE LA WYER REFERRAL SERVICE OF CENTRAL TEXAS
to be delivered to
SWBANKACQ LLC
C/O NANCY JACKSON CARROLL
at the address,
4401 HIGHWAY 198, MALAKOFF, TEXAS 75148
Page 1 of2
Time
Results
ON THIS FIRST ATTEMPT, THERE WAS NO ONE
AVAILABLE.
THIS HOUSE IS VACANT.
I LEFT MY CONTACT INFORMATION ON THE FRONT
DOOR OF THE ABODE.
Due to the above-referenced information, I am unable to deliver said documents to the Defendant,
SWBANKACQ LLC
C/O NANCY JACKSON CARROLL
,,
Scott Robert Pomeroy
contact@holeinoneprocess.com
NON-SERVE AFFIDAVIT FOR SWBANKACQ LLC C/0 NANCY JACKSON CARROLL
Page 2 of2
PLAINTIFF(S)
vs.
DEFENDANT(S)
NON-SERVE AFFIDAVIT
On THURSDAY, FEBRUARY 4, 2016, at 12:32 P.M., I received a
TEMPORARY RESTRAINING ORDER WRIT, ORDER GRANTING SPECIAL DEPUTY
RECEIVER'S APPLICATION FOR A TEMPORARY RESTRAINING ORDER [CARROLL],
SPECIAL DEPUTY RECEIVER'S APPLICATION TO ENFORCE PERMANENT INJUNCTION AND
FOR ISSUANCE OF TEMPORARY RESTRAINING ORDER AND FOR WRITS OF TEMPORARY
AND PERMANENT INJUNCTION AND EXHIBIT(S)
to be delivered to
SWBANKACQ LLC
C/O NANCY JACKSON CARROLL
at the address,
4401 HIGHWAY 198, MALAKOFF, TEXAS 75148
NON-SERVE AFFIDA VlT FOR SWBANKACQ LLC C/0 NANCY JACKSON CARROLL
Page 1 of2
Results
FEBRUARY 4, 2016 1:45 P.M.
Due to the above-referenced information, I am unable to deliver said documents to the Defendant,
"
Page 2 of2
PLAINTIFF(S)
vs.
DEFENDANT(S)
NON-SERVE AFFIDAVIT
On THURSDAY, FEBRUARY 4, 2016, at 12:33 P.M., I received a
CITATION, PLAINTIFF'S ORIGINAL AGREED PETITION, APPLICATION FOR ORDER
APPOINTING LIQUIDATOR AND REQUEST FOR INJUNCTIVE RELIEF, AGREED ORDER
APPOINTING LIQUIDATOR AND PERMANENT INJUNCTION, CIVIL CASE INFORMATION
SHEET AND A DOCUMENT TITLED, THE LA WYER REFERRAL SERVICE OF CENTRAL TEXAS
to be delivered to
ZAPP TRUST
C/O NANCY JACKSON CARROLL
at the address,
Pagel of2
Results
FEBRUARY 4, 2016 1:45 P.M.
Due to the above-referenced information, I am unable to deliver said documents to the Defendant,
ZAPP TRUST
C/O NANCY JACKSON CARROLL
~~
,,
contact@holeinoneprocess.com
Page 2 of2
PLAINTIFF(S)
vs.
DEFENDANT(S)
NON-SERVE AFFIDAVIT
On THURSDAY, FEBRUARY 4, 2016, at 12:33 P.M., I received a
TEMPORARY RESTRAINING ORDER WRIT, ORDER GRANTING SPECIAL DEPUTY
RECEIVER'S APPLICATION FOR A TEMPORARY RESTRAINING ORDER [CARROLL],
SPECIAL DEPUTY RECEIVER'S APPLICATION TO ENFORCE PERMANENT INJUNCTION AND
FOR ISSUANCE OF TEMPORARY RESTRAINING ORDER AND FOR WRITS OF TEMPORARY
AND PERMANENT INJUNCTION AND EXHIBIT(S)
to be delivered to
ZAPP TRUST
C/O NANCY JACKSON CARROLL
at the address,
Page J of2
Results
FEBRUARY 4, 2016 1:45 P.M.
Due to the above-referenced information, I am unable to deliver said documents to the Defendant,
ZAPP TRUST
C/O NANCY JACKSON CARROLL
I do not have any other information about
ZAPP TRUST C/O NANCY JACKSON CARROLL.
"
Exhibit
C
BEFORE ME, the undersigned Notary Public, on this day, personally appeared Brian M.
Falligant, known to me to be the person whose name is subscribed hereto, and after being duly
sworn on oath stated the following:
1.
2.
On February 15, 2016, I obtained a copy of the docket sheet in Case Number
16CF00000400, People vs. Spinks from the Lake County Clerk Circuit Court
website. A true and correct copy of the Docket Sheet is attached to this Affidavit
as Exhibit 1.
3.
The Docket Sheet indicates that as of February 13, 2016, the Defendant was
presently in custody.
4.
On February 15, 2016, I obtained a copy of the Inmate Detail for Nancy Jackson
Spinks from the Lake County Illinois Sheriffs website. A true and correct copy
of the Inmate Detail is attached to this Affidavit as Exhibit 2.
5.
The Inmate Detail indicates that she is in full custody at the Lake County Illinois
jail with two pending charges. A bond review on the fugitive from justice offense
is currently set for February 16, 2016 at 9:00 a.m.
6.
On February 15, 2016 at 4:02 p.m., I contacted the Lake County, Illinois jail
inquiring as to Nancy Jackson Spinks current whereabouts. Amy in the Lake
County, Illinois booking department confirmed that Nancy Jackson Spinks is
PAGE 1 OF 2
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PAGE 2 OF2
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Exhibit
1
https://circuitclerk.lakecountyil.gov/publicAccess/html/common/courtCaseDetails.xhtml?c... 2/15/2016
Page 1 of 1
Inmate Detail
Name: NANCY JACKSON SPINKS
Address: LAKE FOREST, IL 60045
Booking #: l158940
Sex: F
Status: Full Custody
Visit_Inmate
Confined
02/11/2016
02/11/2016
Court Date
Disposition Bond Type
02/16/2016 09:00
PENDING
02/16/2016 09:00
PENDING
TEN
Bond Amount
$250,000.00
Offense
FUGITIVE FROM JUSTICE
THEFT/STOLEN/INTENT PERS <$500
Close
Exhibit
2
http://apps01.lakecountyil.gov/spsheriff/inmatesearch/InmateDetail.aspx?BookingNumber... 2/15/2016