Capital One Bank, N.A. v. Czekala

Plaintiff, Capital One Bank (Capital One), filed a complaint against “Joseph Czekala DBA SEALAND FOODS” and served Joseph Czekala by substitute abode service. The circuit court entered a default judgment against “Joseph Czekala, Defendant.” Five years later, plaintiff issued a wage deduction notice and order naming Joseph Czekala, individually. Defendant filed a petition to vacate the default judgment and dismiss the wage deduction order. The trial court denied the petition to vacate and a subsequent motion to reconsider. Defendant appeals from the court’s ruling denying the petition to…