Baidoo v. Blood-Dzraku
New York Supreme Court
5 N.Y.S.3d 709 (2015)
Relevant factsFree
Ellanora Baidoo (plaintiff) sued Victor Blood-Dzraku (defendant) for divorce, but the couple had never lived together, Blood-Dzraku had no fixed address or workplace, and Baidoo had no email address for him; a hired investigator could not locate him either. Baidoo asked the court to allow service through Blood-Dzraku's Facebook account, supporting the request with an affidavit confirming the account belonged to him and evidence that he regularly communicated with her through it.
IssueFree
Whether a court may authorize service of process by private Facebook message when traditional methods of service are impracticable and the alternative method can reasonably be expected to give the defendant actual notice.
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