Luerica Fiffee and Michael Jiggetts were the unmarried parents of six children. After an earlier custody order divided primary physical custody between them, Jiggetts sought to modify custody and served the hearing notice on Fiffee’s lawyer by facsimile. Fiffee and her counsel did not appear, and the trial court awarded Jiggetts primary physical custody of all six children. The Georgia Court of Appeals held that the facsimile notice did not satisfy Georgia’s statutory service requirements and created a nonamendable defect on the face of the record. Because the hearing proceeded without legally sufficient notice, the trial court’s custody-modification order could not stand. The appellate court reversed the denial of Fiffee’s motion to set aside the order.