Parks v. Neuf

Plaintiff Gloria Parks filed this action in the circuit court of Sangamon County to recover damages for false affidavits of service executed by defendant Marla S. Neuf, the private process server in a separate small claims action. Defendant’s motion to dismiss count IV of plaintiff’s second-amended complaint captioned “Falsification of Affidavit of Service” was denied. The following issue has been certified to this court pursuant to Supreme Court Rule 308 (134 Ill. 2d R. 308): Is a civil cause of action for money damages for falsification of an affidavit of service by a private person on a…