Hearn v. Howard

In Hearn v. Howard (2009) 177 Cal.App.4th 1193, the plaintiff served the defendant, an attorney, by substituted service at a private post office box rental store by leaving the documents with the mail store clerk "at the business address on her letterhead and reported by the California State Bar," followed by mailing to the same address. (Id. at p. 1202.) The process server had "made three attempts to personally serve" the defendant at the mail store, where the "store clerk declined to confirm that the defendant rented a post office box there." (Id. at p. 1198.) The process server then left the documents with the store clerk, and mailed copies of the documents to the defendant at the same address. The court held that substituted service was properly effected. (Id. at pp. 1201-1203.)