Dore v. Quezada

Plaintiff obtained judgment against Defendants and initiated supplemental proceedings under Section 2-1402 of Code of Civil Procedure by filing 3rd-party citations against 2 Respondents. Court did not abuse its discretion in deciding not to sanction one Respondent, as Defendant, who signed over $1,000 check to Respondent, had no garnishable interest in proceeds and thus did not violate citation. Court properly sua sponte raised issue of personal jurisdiction over Defendant who failed to appear. Court did not abuse its discretion in quashing service on that Defendant, as court found that apartment where he was served via substitute service was not his usual place of abode.(SIMON and MIKVA, concurring.)