California, United States of America
The following excerpt is from Cnty. of Riverside v. Flores, E071141 (Cal. App. 2020):
Finally, the proof of service stated that the process server had made two previous attempts to serve Flores personally at the same location. Reasonable diligence for purposes of substituted service is a different and less stringent standard than for purposes of service by publication. (Espindola v. Nunez (1988) 199 Cal.App.3d 1389, 1392-1393.) It does not require the plaintiff "to show exhaustive attempts to locate the defendant . . . ." (Ibid.) "'Two or three attempts to personally serve a defendant at a proper place ordinarily qualifies as "'reasonable diligence.'"' [Citation.]" (Rodriguez v. Cho (2015) 236 Cal.App.4th 742, 750.) Thus, the two attempts here were sufficient.
Page 13
Flores nevertheless argues that the proof of service failed to show reasonable diligence, for two reasons.7
The above passage should not be considered legal advice. Reliable answers to complex legal questions require comprehensive research memos. To learn more visit www.alexi.com.