Campus Investments, Inc. v. Cullever

The evidence at the trial of this bill of review showed that a certificate of service from the Secretary of State was on file ten days before the underlying default judgment was granted, but citation and return were not. See Tex.R. Civ. P. 107. Relying on its opinion in G.F.S. Ventures, Inc. v. Harris, 934 S.W.2d 813 (Tex.App.-Houston [1st Dist.] 1996, no writ), the First Court of Appeals held this was sufficient. 141 S.W.3d 641. Petitioner points out that this opinion conflicts with the Sixth Court of Appeals’ opinion to the contrary in Onyx TV v. TV Strategy Group, LLC, 990 S.W.2d 427…