Morristown Memorial Hosp. v. Tureo

In Morristown Memorial Hosp. v. Tureo, 329 N.J.Super. 154, 746 A.2d 1088, certif. denied, 165 N.J. 487, 758 A.2d 647 (2000), plaintiff certified that, on a specific date, a motion for a wage execution was sent to defendant's last known address by certified mail, return receipt requested, and by regular mail. The court held that in order for the creditor to rely on the ordinary mail service, it was required to submit supplemental proof of service reciting "either that the certified or registered mail was accepted and the date of acceptance or . . . it was either refused or not accepted." Id. at 157, 746 A.2d 1088.