Great news! Yes, summons was served, but due to no party from PROM could be located as per previous attempts to serve the summons, the summons was served on The Secretary of State as per the statutes. The actual filing date for when the summons was served is March 2, 2021 and 20 days from that date, March 22, 2021 would be the deadline for a reply. But, since the summons was only served on the SoS, and they do not forward the summons to the respondent, there is nobody to reply.
So, we are just waiting for a judgment from judge Paetra Brownlee to appoint Ms Keaveney as the custodian. This judgment should be forthcoming. We are golden.