Meza v. Portfolio Recovery Associates, LLC

Summary

The court held that section 98(a) requires an address within 150 miles of trial where lawful service can be made of process capable of compelling the affiant to attend trial. Personal presence at that address is generally required for service of a trial subpoena, but it is not categorically required when another lawful service method, such as service of a notice to attend on an attorney, applies. The court reached this interpretation from the statute's text, purpose, legislative history, and preservation of ordinary service rules.