Each card carries the governed distillate name from the database. Open the quoted anchor before relying on the interpretation.
claimallegation
Charles A. Gavin’s signed declaration,filed 22 April 2026 asEDVA197-1, identifies him asAWH/Secure Community counsel. He bases statements on
Charles A. Gavin’s signed declaration,filed 22 April 2026 asEDVA197-1, identifies him asAWH/Secure Community counsel. He bases statements on personal investigation and documents reviewed. This is interested counsel testimony, not a clerk certificate or adjudicated finding.
Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 197-1 Filed 04/22/26 Page 1 of 3 PagelD# 4306
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TEHNOLOGIES CORP.,
Interpleader Plaintiff,
V.
Case Number: 3:25cv483
ATLANTIC WAVE HOLDINGS, LLC, et al.,
Interpleader Defendants/Claimants.
DECLARATION OF CHARLES A. GAVIN, COUNSEL FOR ATLANTIC WAVE
HOLDINGS, LLC AND SECURE COMMUNITY, LLC
Your Declarant is Charles A. Gavin. I am greater than 21 years of age. I am an
attorney licensed in the Commonwealth of Virginia and admitted to practice in state court and
this court. Counsel has been in practice since 1990. I represent AWH and SC and am familiar
with the claims, documents, and information provided to date in the Interpleader.
2.
All related declarations contained herein are based on my personal investigation
or documents gathered and reviewed by me personally.
A true and correct copy of a Writ of Fieri Facias requested by ANPC and obtained
from the City of Richmond Circuit Court is attached hereto as Exhibit A-1.
4.
A true and correct copy of ANPCạis cover letter to the Circuit Court of the City of
Richmond as obtained from the clerk's office is attached hereto as Exhibit A-2.
5.
Counsel has personally reviewed the record at the City of Richmond Circuit Court
clerk's office and it does not reflect that the Writ of Fieri Facias issued by the Richmond Circuit
Court clerk was ever received by, or served on, the Sheriff of the City of Richmond.
6.
A copy of the Suggestion for Garnishment, the Garnishment Summons, the
service return for the garnishment, the docket sheet for the garnishment, the filing cover letter to
the clerk, and the Final Order in the Circuit Court of Fairfax in garnishment CL2025-16055 are
attached hereto as Exhibit A-3.
claimallegation
Gavin says his Richmond clerk record review did not showANPC’s writ received by or served on the Richmond Sheriff. He saysFairfax garnishmen
Gavin says his Richmond clerk record review did not showANPC’s writ received by or served on the Richmond Sheriff. He saysFairfax garnishment records lacked execution delivery date,debtor service or mail acknowledgement,writ request, issuance or return and a cover-letter request for writ service. These are bounded reports of record absence, not definitive proof no service occurred.
Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 197-1 Filed 04/22/26 Page 1 of 3 PagelD# 4306
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TEHNOLOGIES CORP.,
Interpleader Plaintiff,
V.
Case Number: 3:25cv483
ATLANTIC WAVE HOLDINGS, LLC, et al.,
Interpleader Defendants/Claimants.
DECLARATION OF CHARLES A. GAVIN, COUNSEL FOR ATLANTIC WAVE
HOLDINGS, LLC AND SECURE COMMUNITY, LLC
Your Declarant is Charles A. Gavin. I am greater than 21 years of age. I am an
attorney licensed in the Commonwealth of Virginia and admitted to practice in state court and
this court. Counsel has been in practice since 1990. I represent AWH and SC and am familiar
with the claims, documents, and information provided to date in the Interpleader.
2.
All related declarations contained herein are based on my personal investigation
or documents gathered and reviewed by me personally.
A true and correct copy of a Writ of Fieri Facias requested by ANPC and obtained
from the City of Richmond Circuit Court is attached hereto as Exhibit A-1.
4.
A true and correct copy of ANPCạis cover letter to the Circuit Court of the City of
Richmond as obtained from the clerk's office is attached hereto as Exhibit A-2.
5.
Counsel has personally reviewed the record at the City of Richmond Circuit Court
clerk's office and it does not reflect that the Writ of Fieri Facias issued by the Richmond Circuit
Court clerk was ever received by, or served on, the Sheriff of the City of Richmond.
6.
A copy of the Suggestion for Garnishment, the Garnishment Summons, the
service return for the garnishment, the docket sheet for the garnishment, the filing cover letter to
the clerk, and the Final Order in the Circuit Court of Fairfax in garnishment CL2025-16055 are
attached hereto as Exhibit A-3.
claimallegation
He saysdefence counsel spoke to a Fairfax deputy who saidonly the garnishment summons was received, not the writ. The deputy is unnamed and
He saysdefence counsel spoke to a Fairfax deputy who saidonly the garnishment summons was received, not the writ. The deputy is unnamed and the statement is relayed; do not present it as a review of sheriff logs or a court finding.
Read the anchor · page 2
Case 3:25-cv-00483-JAG Document 197-1 Filed 04/22/26 Page 2 of 3 PagelD# 4307
The suggestion for summons of garnishment attached hereto reflects the original
Judgment date as August 21, 2025, but does not reflect a date of execution delivery.
A review of the Fairfax Circuit Court garnishment file does not reflect on the
return an acknowledgment that the garnishment documents were mailed to the judgment debtor,
or that the judgment debtor was served.
9.
A review of Fairfax garnishment 2302516055 file does not reflect the request of
the issuance of a Writ of Fieri Facias to be generated by the Circuit Court Clerk for service or
placement with the Sheriff of Fairfax County.
10.
The cover letter forwarded to the clerk pursuant to the garnishment issuance does
not reflect a request for service of any Writ of Fieri Facias on the Sheriff of Fairfax County.
11.
Detense counsel personally spoke with a Deputy Sheriff in the County of Fairfax
Sheriff's Office who advised that the Sheriff only received the garnishment summons, and did
not receive a Writ of Fieri Facias from ANPC or the Clerk.
12.
The Fairfax garnishment docket sheet does not reflect issuance of a Writ of Fieri
Facias to the Sheriff or a return of the writ. A-4
13.
The Consent Final Order entered in the Richmond Circuit case number CL24-
3910 includes a ruling that the Receiver, Robert Berleth, had the authority under the
Receivership Order to resolve the litigation claim in CL24-3910. A-5, See Will Welter 179-11,
Declaration #25 (Exhibit 9).
14.
A copy of the Complaint filed by ARG in North Carolina is attached hereto as
Exhibit A-6.
15. The Answer of CYBL to ARG's Complaint in North Carolina is attached hereto
as Exhibit A-7.
2
claimallegation
He reports a RichmondCL24-3910consent final order recognises Berleth’s authority to resolve that litigation claim, citing A-5 and Welter179-
He reports a RichmondCL24-3910consent final order recognises Berleth’s authority to resolve that litigation claim, citing A-5 and Welter179-11paragraph 25. The order itself is not in this three-page PDF; this assertion cannot establish general corporate receiver authority or cure all other temporal restrictions.
Read the anchor · page 2
Case 3:25-cv-00483-JAG Document 197-1 Filed 04/22/26 Page 2 of 3 PagelD# 4307
The suggestion for summons of garnishment attached hereto reflects the original
Judgment date as August 21, 2025, but does not reflect a date of execution delivery.
A review of the Fairfax Circuit Court garnishment file does not reflect on the
return an acknowledgment that the garnishment documents were mailed to the judgment debtor,
or that the judgment debtor was served.
9.
A review of Fairfax garnishment 2302516055 file does not reflect the request of
the issuance of a Writ of Fieri Facias to be generated by the Circuit Court Clerk for service or
placement with the Sheriff of Fairfax County.
10.
The cover letter forwarded to the clerk pursuant to the garnishment issuance does
not reflect a request for service of any Writ of Fieri Facias on the Sheriff of Fairfax County.
11.
Detense counsel personally spoke with a Deputy Sheriff in the County of Fairfax
Sheriff's Office who advised that the Sheriff only received the garnishment summons, and did
not receive a Writ of Fieri Facias from ANPC or the Clerk.
12.
The Fairfax garnishment docket sheet does not reflect issuance of a Writ of Fieri
Facias to the Sheriff or a return of the writ. A-4
13.
The Consent Final Order entered in the Richmond Circuit case number CL24-
3910 includes a ruling that the Receiver, Robert Berleth, had the authority under the
Receivership Order to resolve the litigation claim in CL24-3910. A-5, See Will Welter 179-11,
Declaration #25 (Exhibit 9).
14.
A copy of the Complaint filed by ARG in North Carolina is attached hereto as
Exhibit A-6.
15. The Answer of CYBL to ARG's Complaint in North Carolina is attached hereto
as Exhibit A-7.
2
claimallegation
The declaration inventoriesA-1–A-13:ANPC writ, letter and garnishment records,consent order,ARG complaint and answer,Thin Air complaint, ord
The declaration inventoriesA-1–A-13:ANPC writ, letter and garnishment records,consent order,ARG complaint and answer,Thin Air complaint, order and affidavit,Catalyst termination certificate,30 May 2025creditor certification andAWH Fairfax order. None of those attachments is physically included in this three-page file.
Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 197-1 Filed 04/22/26 Page 1 of 3 PagelD# 4306
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TEHNOLOGIES CORP.,
Interpleader Plaintiff,
V.
Case Number: 3:25cv483
ATLANTIC WAVE HOLDINGS, LLC, et al.,
Interpleader Defendants/Claimants.
DECLARATION OF CHARLES A. GAVIN, COUNSEL FOR ATLANTIC WAVE
HOLDINGS, LLC AND SECURE COMMUNITY, LLC
Your Declarant is Charles A. Gavin. I am greater than 21 years of age. I am an
attorney licensed in the Commonwealth of Virginia and admitted to practice in state court and
this court. Counsel has been in practice since 1990. I represent AWH and SC and am familiar
with the claims, documents, and information provided to date in the Interpleader.
2.
All related declarations contained herein are based on my personal investigation
or documents gathered and reviewed by me personally.
A true and correct copy of a Writ of Fieri Facias requested by ANPC and obtained
from the City of Richmond Circuit Court is attached hereto as Exhibit A-1.
4.
A true and correct copy of ANPCạis cover letter to the Circuit Court of the City of
Richmond as obtained from the clerk's office is attached hereto as Exhibit A-2.
5.
Counsel has personally reviewed the record at the City of Richmond Circuit Court
clerk's office and it does not reflect that the Writ of Fieri Facias issued by the Richmond Circuit
Court clerk was ever received by, or served on, the Sheriff of the City of Richmond.
6.
A copy of the Suggestion for Garnishment, the Garnishment Summons, the
service return for the garnishment, the docket sheet for the garnishment, the filing cover letter to
the clerk, and the Final Order in the Circuit Court of Fairfax in garnishment CL2025-16055 are
attached hereto as Exhibit A-3.
claimallegation
Source wording identifiesANPC’s original judgment date as 21 August 2025 and elsewhere prints Fairfax2302516055; it names Thin Air Group and
Source wording identifiesANPC’s original judgment date as 21 August 2025 and elsewhere prints Fairfax2302516055; it names Thin Air Group and closes Atlantic Wave, LLC whilst the caption uses Atlantic Wave Holdings. These source variant labels are preserved, not silently converted into new legal entities or reconciled to different records.
Read the anchor · page 2
Case 3:25-cv-00483-JAG Document 197-1 Filed 04/22/26 Page 2 of 3 PagelD# 4307
The suggestion for summons of garnishment attached hereto reflects the original
Judgment date as August 21, 2025, but does not reflect a date of execution delivery.
A review of the Fairfax Circuit Court garnishment file does not reflect on the
return an acknowledgment that the garnishment documents were mailed to the judgment debtor,
or that the judgment debtor was served.
9.
A review of Fairfax garnishment 2302516055 file does not reflect the request of
the issuance of a Writ of Fieri Facias to be generated by the Circuit Court Clerk for service or
placement with the Sheriff of Fairfax County.
10.
The cover letter forwarded to the clerk pursuant to the garnishment issuance does
not reflect a request for service of any Writ of Fieri Facias on the Sheriff of Fairfax County.
11.
Detense counsel personally spoke with a Deputy Sheriff in the County of Fairfax
Sheriff's Office who advised that the Sheriff only received the garnishment summons, and did
not receive a Writ of Fieri Facias from ANPC or the Clerk.
12.
The Fairfax garnishment docket sheet does not reflect issuance of a Writ of Fieri
Facias to the Sheriff or a return of the writ. A-4
13.
The Consent Final Order entered in the Richmond Circuit case number CL24-
3910 includes a ruling that the Receiver, Robert Berleth, had the authority under the
Receivership Order to resolve the litigation claim in CL24-3910. A-5, See Will Welter 179-11,
Declaration #25 (Exhibit 9).
14.
A copy of the Complaint filed by ARG in North Carolina is attached hereto as
Exhibit A-6.
15. The Answer of CYBL to ARG's Complaint in North Carolina is attached hereto
as Exhibit A-7.
2
entityobservation
Charles A. Gavin
Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 197-1 Filed 04/22/26 Page 1 of 3 PagelD# 4306
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TEHNOLOGIES CORP.,
Interpleader Plaintiff,
V.
Case Number: 3:25cv483
ATLANTIC WAVE HOLDINGS, LLC, et al.,
Interpleader Defendants/Claimants.
DECLARATION OF CHARLES A. GAVIN, COUNSEL FOR ATLANTIC WAVE
HOLDINGS, LLC AND SECURE COMMUNITY, LLC
Your Declarant is Charles A. Gavin. I am greater than 21 years of age. I am an
attorney licensed in the Commonwealth of Virginia and admitted to practice in state court and
this court. Counsel has been in practice since 1990. I represent AWH and SC and am familiar
with the claims, documents, and information provided to date in the Interpleader.
2.
All related declarations contained herein are based on my personal investigation
or documents gathered and reviewed by me personally.
A true and correct copy of a Writ of Fieri Facias requested by ANPC and obtained
from the City of Richmond Circuit Court is attached hereto as Exhibit A-1.
4.
A true and correct copy of ANPCạis cover letter to the Circuit Court of the City of
Richmond as obtained from the clerk's office is attached hereto as Exhibit A-2.
5.
Counsel has personally reviewed the record at the City of Richmond Circuit Court
clerk's office and it does not reflect that the Writ of Fieri Facias issued by the Richmond Circuit
Court clerk was ever received by, or served on, the Sheriff of the City of Richmond.
6.
A copy of the Suggestion for Garnishment, the Garnishment Summons, the
service return for the garnishment, the docket sheet for the garnishment, the filing cover letter to
the clerk, and the Final Order in the Circuit Court of Fairfax in garnishment CL2025-16055 are
attached hereto as Exhibit A-3.
inferenceinference
The declaration is useful for the precise procedural defect Gavin alleged, but an asserted absence in selected files cannot alone resolve se
The declaration is useful for the precise procedural defect Gavin alleged, but an asserted absence in selected files cannot alone resolve service, perfection or creditor priority.
omissiongap
Thirteen referenced exhibits are not included; the declaration cannot substitute for full review of the underlying orders, returns and plead
Thirteen referenced exhibits are not included; the declaration cannot substitute for full review of the underlying orders, returns and pleadings.
Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 197-1 Filed 04/22/26 Page 1 of 3 PagelD# 4306
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TEHNOLOGIES CORP.,
Interpleader Plaintiff,
V.
Case Number: 3:25cv483
ATLANTIC WAVE HOLDINGS, LLC, et al.,
Interpleader Defendants/Claimants.
DECLARATION OF CHARLES A. GAVIN, COUNSEL FOR ATLANTIC WAVE
HOLDINGS, LLC AND SECURE COMMUNITY, LLC
Your Declarant is Charles A. Gavin. I am greater than 21 years of age. I am an
attorney licensed in the Commonwealth of Virginia and admitted to practice in state court and
this court. Counsel has been in practice since 1990. I represent AWH and SC and am familiar
with the claims, documents, and information provided to date in the Interpleader.
2.
All related declarations contained herein are based on my personal investigation
or documents gathered and reviewed by me personally.
A true and correct copy of a Writ of Fieri Facias requested by ANPC and obtained
from the City of Richmond Circuit Court is attached hereto as Exhibit A-1.
4.
A true and correct copy of ANPCạis cover letter to the Circuit Court of the City of
Richmond as obtained from the clerk's office is attached hereto as Exhibit A-2.
5.
Counsel has personally reviewed the record at the City of Richmond Circuit Court
clerk's office and it does not reflect that the Writ of Fieri Facias issued by the Richmond Circuit
Court clerk was ever received by, or served on, the Sheriff of the City of Richmond.
6.
A copy of the Suggestion for Garnishment, the Garnishment Summons, the
service return for the garnishment, the docket sheet for the garnishment, the filing cover letter to
the clerk, and the Final Order in the Circuit Court of Fairfax in garnishment CL2025-16055 are
attached hereto as Exhibit A-3.
otherattribution
Complete supplied 3-page source reviewed at SHA-256 98323bfc6e960bbef79659be67eee0f172be8694a581e4a6cd2a599378f1defd. Source assertions, ori
Complete supplied 3-page source reviewed at SHA-256 98323bfc6e960bbef79659be67eee0f172be8694a581e4a6cd2a599378f1defd. Source assertions, original visual features, filing/communication context and identified missing attachments are retained. Full 3-page reading and visual QA of registered version version_1a5f65e7459e45dc810d7e63f4356e11, exactSHA256 98323bfc6e960bbef79659be67eee0f172be8694a581e4a6cd2a599378f1defd; no source replacement or live-docket update.
Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 197-1 Filed 04/22/26 Page 1 of 3 PagelD# 4306
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TEHNOLOGIES CORP.,
Interpleader Plaintiff,
V.
Case Number: 3:25cv483
ATLANTIC WAVE HOLDINGS, LLC, et al.,
Interpleader Defendants/Claimants.
DECLARATION OF CHARLES A. GAVIN, COUNSEL FOR ATLANTIC WAVE
HOLDINGS, LLC AND SECURE COMMUNITY, LLC
Your Declarant is Charles A. Gavin. I am greater than 21 years of age. I am an
attorney licensed in the Commonwealth of Virginia and admitted to practice in state court and
this court. Counsel has been in practice since 1990. I represent AWH and SC and am familiar
with the claims, documents, and information provided to date in the Interpleader.
2.
All related declarations contained herein are based on my personal investigation
or documents gathered and reviewed by me personally.
A true and correct copy of a Writ of Fieri Facias requested by ANPC and obtained
from the City of Richmond Circuit Court is attached hereto as Exhibit A-1.
4.
A true and correct copy of ANPCạis cover letter to the Circuit Court of the City of
Richmond as obtained from the clerk's office is attached hereto as Exhibit A-2.
5.
Counsel has personally reviewed the record at the City of Richmond Circuit Court
clerk's office and it does not reflect that the Writ of Fieri Facias issued by the Richmond Circuit
Court clerk was ever received by, or served on, the Sheriff of the City of Richmond.
6.
A copy of the Suggestion for Garnishment, the Garnishment Summons, the
service return for the garnishment, the docket sheet for the garnishment, the filing cover letter to
the clerk, and the Final Order in the Circuit Court of Fairfax in garnishment CL2025-16055 are
attached hereto as Exhibit A-3.
questionquestion
What certified clerk/sheriff records and the actual writ/garnishment returns confirm or rebut Gavin’s bounded absence assertions?
questionquestion
What exact language and entry date in the referenced CL24-3910consent order definesBerleth’s authority for that settlement?
distillategap
CONNECT
Reviewed relationships
The canvas follows the database: source to DISTIL record, DISTIL record to knowledge object, then reviewed relationship. Position alone means nothing.
The declaration inventoriesA-1–A-13:ANPC writ, letter and garnishment records,consent order,ARG complaint and answer,Thin Air complaint, order and affidavit,Catalyst termination certificate,30 May 2025creditor certification andAWH Fairfax order. None of those attachments is physically included in this three-page file.supportsDoes thisdeclaration itself establishANPC never perfected an interest or Berleth had unlimited authority?
Specifically named source propositions support the bounded distinction or question.
He saysdefence counsel spoke to a Fairfax deputy who saidonly the garnishment summons was received, not the writ. The deputy is unnamed and the statement is relayed; do not present it as a review of sheriff logs or a court finding.supportsDoes thisdeclaration itself establishANPC never perfected an interest or Berleth had unlimited authority?
Specifically named source propositions support the bounded distinction or question.
Gavin says his Richmond clerk record review did not showANPC’s writ received by or served on the Richmond Sheriff. He saysFairfax garnishment records lacked execution delivery date,debtor service or mail acknowledgement,writ request, issuance or return and a cover-letter request for writ service. These are bounded reports of record absence, not definitive proof no service occurred.supportsWhat certified clerk/sheriff records and the actual writ/garnishment returns confirm or rebut Gavin’s bounded absence assertions?
Specifically named source propositions support the bounded distinction or question.
The declaration inventoriesA-1–A-13:ANPC writ, letter and garnishment records,consent order,ARG complaint and answer,Thin Air complaint, order and affidavit,Catalyst termination certificate,30 May 2025creditor certification andAWH Fairfax order. None of those attachments is physically included in this three-page file.supportsThirteen referenced exhibits are not included; the declaration cannot substitute for full review of the underlying orders, returns and pleadings.
Specifically named source propositions support the bounded distinction or question.
The declaration inventoriesA-1–A-13:ANPC writ, letter and garnishment records,consent order,ARG complaint and answer,Thin Air complaint, order and affidavit,Catalyst termination certificate,30 May 2025creditor certification andAWH Fairfax order. None of those attachments is physically included in this three-page file.supportsWhat exact language and entry date in the referenced CL24-3910consent order definesBerleth’s authority for that settlement?
Specifically named source propositions support the bounded distinction or question.
Gavin says his Richmond clerk record review did not showANPC’s writ received by or served on the Richmond Sheriff. He saysFairfax garnishment records lacked execution delivery date,debtor service or mail acknowledgement,writ request, issuance or return and a cover-letter request for writ service. These are bounded reports of record absence, not definitive proof no service occurred.supportsDoes thisdeclaration itself establishANPC never perfected an interest or Berleth had unlimited authority?
Specifically named source propositions support the bounded distinction or question.
The declaration inventoriesA-1–A-13:ANPC writ, letter and garnishment records,consent order,ARG complaint and answer,Thin Air complaint, order and affidavit,Catalyst termination certificate,30 May 2025creditor certification andAWH Fairfax order. None of those attachments is physically included in this three-page file.supportsThe declaration is useful for the precise procedural defect Gavin alleged, but an asserted absence in selected files cannot alone resolve service, perfection or creditor priority.
Specifically named source propositions support the bounded distinction or question.
He reports a RichmondCL24-3910consent final order recognises Berleth’s authority to resolve that litigation claim, citing A-5 and Welter179-11paragraph 25. The order itself is not in this three-page PDF; this assertion cannot establish general corporate receiver authority or cure all other temporal restrictions.supportsDoes thisdeclaration itself establishANPC never perfected an interest or Berleth had unlimited authority?
Specifically named source propositions support the bounded distinction or question.
He reports a RichmondCL24-3910consent final order recognises Berleth’s authority to resolve that litigation claim, citing A-5 and Welter179-11paragraph 25. The order itself is not in this three-page PDF; this assertion cannot establish general corporate receiver authority or cure all other temporal restrictions.supportsWhat exact language and entry date in the referenced CL24-3910consent order definesBerleth’s authority for that settlement?
Specifically named source propositions support the bounded distinction or question.
The declaration inventoriesA-1–A-13:ANPC writ, letter and garnishment records,consent order,ARG complaint and answer,Thin Air complaint, order and affidavit,Catalyst termination certificate,30 May 2025creditor certification andAWH Fairfax order. None of those attachments is physically included in this three-page file.supportsWhat certified clerk/sheriff records and the actual writ/garnishment returns confirm or rebut Gavin’s bounded absence assertions?
Specifically named source propositions support the bounded distinction or question.
He saysdefence counsel spoke to a Fairfax deputy who saidonly the garnishment summons was received, not the writ. The deputy is unnamed and the statement is relayed; do not present it as a review of sheriff logs or a court finding.supportsThe declaration is useful for the precise procedural defect Gavin alleged, but an asserted absence in selected files cannot alone resolve service, perfection or creditor priority.
Specifically named source propositions support the bounded distinction or question.
Gavin says his Richmond clerk record review did not showANPC’s writ received by or served on the Richmond Sheriff. He saysFairfax garnishment records lacked execution delivery date,debtor service or mail acknowledgement,writ request, issuance or return and a cover-letter request for writ service. These are bounded reports of record absence, not definitive proof no service occurred.supportsThe declaration is useful for the precise procedural defect Gavin alleged, but an asserted absence in selected files cannot alone resolve service, perfection or creditor priority.
Specifically named source propositions support the bounded distinction or question.
He saysdefence counsel spoke to a Fairfax deputy who saidonly the garnishment summons was received, not the writ. The deputy is unnamed and the statement is relayed; do not present it as a review of sheriff logs or a court finding.supportsWhat certified clerk/sheriff records and the actual writ/garnishment returns confirm or rebut Gavin’s bounded absence assertions?
Specifically named source propositions support the bounded distinction or question.
WEIGH
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