The issue regarding whether some kind of service of process may be used other than personal service by a process server or service by publication arises today in a query from a colleague. In 2015, this writer had a case involving a defendant who lived in Thailand. Not only did the wife not have a mailbox to which certified mail with restricted delivery could be sent, but also, she was then living with a new boyfriend—and her address was unknown. Thailand was not a signatory to the Hague Service Convention. Husband had access however to her Facebook and he also had two email addresses for her.
Fortunately, a New York court had just decided a case involving similar facts—a case so new that it was then only available in a slip opinion. Fortunately, that case was published. For your easy reference, the citation is Baidoo v. Blood-Dzraku, 5 N.Y.S.3d 709 (N.Y.Sup.Ct. 2015). In Baidoo, the defendant was served using Facebook. The plaintiff wife in that case lacked a physical address or even an email address for her husband. However, she did have the ability to contact him through Facebook. Thus in my 2015 case, I asked the trial judge to permit service of process by Facebook--but (perhaps a little over-kill) also by the two email addresses.
