In Re Franchi

Memorandum Opinion & Order

JOHN K. OLSON, Bankruptcy Judge.

These cases present the issue of whether service upon an unnamed corporate officer satisfies Fed.R.Bankr.P. 9014, incorporating Rules 7004(b)(3) and 7004(h). As a general rule, it does not.

This court published an order in 2008 which held that specific individuals must be named because “nationwide service of process by first class mail is a rare privilege ... not to be taken lightly.” 1 The court explained that:... limiting the service requirements to first class mail underscores the importance that the defendant receives service by…