Service Of Process Quashed.

Plaintiff/tenant sued defendant/owner for constructive eviction and fraud. Plaintiff’s process server purportedly served defendant by substituted service by serving defendant’s mother at the California address provided by defendant for plaintiff to remit her monthly rental payments, and checking “home” on the proof of service. The trial court granted defendant’s motion to quash service. The appellate court affirmed, noting there was no evidence presented that defendant was other than a resident of England when service was attempted, and plaintiff was required to show that service of process on defendant comported with the Hague Convention, or a proper basis why the Hague Convention did not apply. Lebel v. Mai  (Cal. App. Second Dist., Div. 8;  November 6, 2012) 210 Cal.App.4th 1154.