Transamerica Title Ins. Co. v. Hendrix

In Transamerica Title Ins. Co. v. Hendrix (1995) 34 Cal.App.4th 740, the plaintiff falsified the application for an order for publication by stating service could not be made by mail under section 415.30. The plaintiff knew defendant's post office address and knew defendant was receiving mail at that address. ( Transamerica, supra, at pp. 744-745.) On appeal, the court held a post office box is a sufficient address for compliance with section 415.30. ( Transamerica, supra, at p. 745.) Because plaintiff did not first attempt to serve defendant by mail, the order for service by publication was improper and the trial court erred by entering default. ( Id. at p. 746.)