Can I file a motion to vacate judgment by Pressler & Pressler?

Hello again all.

First of all, I am still embroiled with forster and garbus - we're in a lull now.

Second, yet another problem popped up. My DH bank account was seized/frozen. Turns out there was an old phone bill from before we were married. So, they sent all correspondence to the old address. Apparently they just kept sending the correspondence there (an apartment building) and got the judgement and the seizure that way.

This apparently has been going on behind the scenes for the last six years or so (he hasn't lived at that old address for six years AND he put a forwarding on that address.)

So now the account is frozen. He called them (against my advice) and made a settlement promise over the phone. But I say since nothing is in writing it can still be fought.

Can a Motion to vacate judgment on the basis of improper service be filed? He did file a change of address form, but this was in 2001, so of course we don't have the paperwork for the change of address form.

Also, since the bank account is seized, what else can they do if the payment plan is not honored? We're not exactly in the position to make payments on this.

Thanks in advance!