In Liebovich v. Shahrokhkhany (1997) 56 Cal.App.4th 511, the landlord served the tenant with a three-day notice to pay rent or quit via certified mail, and tenant denied that he ever received the notice. To meet its burden to show compliance with Code of Civil Procedure section 1162, the landlord offered evidence at trial comprised of an affidavit of service by certified mail and a certified mail return receipt with an illegible signature. (Liebovich, supra, at p. 514.) Though the trial court entered judgment for the landlord on the basis of this evidence, the appellate court reversed, holding that the landlord did not provide sufficient evidence of proper service in accordance with section 1162. (Liebovich, supra, at p. 514.) The Liebovich court determined "that the affidavit of service alone (putting aside questions concerning the return receipt) was insufficient to prove the controverted fact of service. Affidavits of service may not be relied on at trial to prove a three-day notice was served pursuant to section 1162; testimony of the person who made the service is required. " (Liebovich, supra, 56 Cal.App.4th at p. 514.) The court adopted the reasoning of Lacrabere v. Wise (1904) 141 Cal. 554, 556 75 P. 185 (Lacrabere), where the court determined that the method of proof sanctioned by section 2009 has no application where proper proof of service constitutes an element of the landlord's claim directly in controversy. (Liebovich, supra, at p. 515.) Section 2009 provides in pertinent part: "An affidavit may be used ... to prove the service of a summons, notice, or other paper in an action or special proceeding, to obtain a provisional remedy, the examination of a witness, or a stay of proceedings ... ."