Hirsch v. National Van Lines, Inc
In Hirsch v. National Van Lines, Inc., 136 Ariz. 304, 666 P.2d 49 (1983), the Arizona Supreme Court stated that service by registered mail on an out-of-state corporate defendant under former Rule 4(e)(1) and (2) could be valid even though the requisite affidavit had not stated the circumstances warranting the procedure that had been used.
But, the Hirsch court found that "there was evidence available to the judge at the time the motion to set aside was heard" indicating that the circumstances had in fact existed. Id. at 308, 666 P.2d at 53.