Peaceful Paws Memorial Services LLC v. Tarves
A judgment creditor served a post-judgment continuing writ of garnishment on an LLC garnishee by delivering it to a person described as an employee/authorized member of the company, invoking section 48.081 (corporations), and obtained a clerk's default and default final judgment. The Third DCA reversed, holding service on an LLC is governed by section 48.062, which permits substitute service on an employee of the registered agent (not merely an employee of the LLC) on a first attempt, and permits service on a member only after the registered agent cannot be served with reasonable diligence "a showing absent from the return of service.
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