By Phil Lamos, Chief Legal Counsel, Office of the Chapter 13 Trustee Craig Shopneck (Cleveland, OH)
Before 1973, service by mail on any party in an adversary proceeding was simply not allowed. Only personal service or service by publication was permitted. In 1973 the Bankruptcy Rules were amended to allow service by any form of mail which required a signed receipt, and in 1976 the Bankruptcy Rules were further amended to eliminate the signed receipt requirement altogether, with service by first-class mail allowed. But in 1994 Rule 7004 was amended again including 7004(h), which mandated that . . .
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