Bein v. Brechtel-Jochim Group, Inc

In Bein v. Brechtel-Jochim Group, Inc. (1992) 6 Cal.App.4th 1387, substituted service was made as to the Jochim defendants by service on a " 'Linda Doe,' " as she left the Jochim residence, and as to the Brechtel defendants by service on an unnamed guard at the gate of their gated community. (Id. at pp. 1390-1391.) The court did not explicitly address the "Linda Doe" service, but upheld the substituted service on the unnamed gate guard, reasoning in part as follows: "Appellants further maintain the declaration of attempted service was invalid because it failed to identify the person to be served on behalf of the corporation. But minor, harmless deficiencies will not be allowed to defeat service." (Id. at p. 1394.)