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And as we continue to go on, I want to make sure the record is clear. The statutes governing service of process are strictly construed, and that's the Stella versus, I won't butcher the name, but you can go to 763d 1054, 155.
Furthermore, I wanted to bring this to your attention as well. If you look in the Court's record, you'll see that there was more than one amended complaint. The rule only allows you one amended complaint for cause. After that, you must get permission from the court for leave to amend. And unless there's an objection to what we see that there was more than one amended complaint in this case.
And I'll just give you the rule. It's the FL Rules of Procedure 1.19 states that a party may amend a pleading once as a matter of course at any time before responsive pleading is served. Otherwise, a pleading, a party may amend a pleading only by leave of the court or by consent to the party. We know I didn't consent to anything, and that's within the rule.
And by the way, in Warner, that Warner, Hien, Lambert Company versus Patrick, 428 so2d 718, the Florida DCA, a Florida DCA, the fourth in fact, ruled that they reverse and remand the case to the trial court with instructions to dismiss the amended complaint and vacate the default final judgment. And that's actually inside of your, inside of the exhibits that I gave you as well.
And now, in saying that, as I put inside of the record as well, it's not to say that at some point in time the department could not have amended the complaint. But now, because the, bless you, because the, they're not a child anymore, the 36-year-old individual is now beyond the four-year statute of limitations for when the department could have even brought back the case. We have a dead case. And at any time, the department, through their various attorneys, had every ability and option to have corrected the record. But what they chose to do was disregard well-established law.
And because I don't have the original complaint, the court has no basis to show that the proper grounds for establishing jurisdiction are even in the record. You know, before the court can take jurisdiction, it has to say, okay, we have jurisdiction. Did the facts, the facts giving rise to the action, take place in Florida? I need Mrs. Brit or Mrs. McCarthy, they can answer it. But I don't have any proof in the record that there was an allegation that the facts or events that gave rise to this action took place in North Carolina, Florida, or Texas, or anywhere else. There's absolutely no evidence in the record whatsoever to have supported this.