For any process server, knowing the state law and the client’s instructions is important, but even more so in cases in which a server is facing someone avoiding service. Process servers must get creative in how they approach cases where the party to be served is knowingly dodging service attempts, but they cannot go rogue and violate any of the rules of civil procedure.
Ensure that the client is providing as much detail as possible about the person to be served. This includes but is not limited to a description of their physical appearance (current height and weight, gender, and other identifying features such as piercings or tattoos), where they can be found (workplace, home address, and information about their routine or addresses of known associates, such as significant others or family members), vehicle description, or other habits. Furthermore, any additional information, such as the demeanor of the party to be served, can make the process server better prepared to complete the serve safely and effectively.
Before attempting service on an avoider, the process server should try to obtain a picture of the individual. While a description is helpful, a current picture can make a positive identification even easier — and make it harder for the individual to lie and claim they are not the person the server is trying to serve. Social media is an excellent place to obtain a current picture.
The client may engage a process server for skip tracing services. This is an incredibly helpful additional service for any process server and may be worth investing in courses or mentorship from a server specializing in skip tracing.