was Allsopp standing inside the house, and he later identified Allsopp in court. The process server testified that he told Davis that he had papers to serve on Allsopp and that he then gave those papers to Davis. The process server did not attempt to hand the papers to Allsopp. We recognize that courts have upheld service when a defendant attempts to evade service, and, therefore, “in-hand” delivery is not required. See Travelers Cas. & Sur. Co. v. Brenneke, 551 F.3d 1132 (9th Cir.2009) (upholding service where process server testified that, after five attempts to serve defendant, pa pers were left on the front step after the defendant spoke to process server through an intercom system but refused to answer and unlock the door); Errion v. Connell, 236 F.2d 447, 457 (9th Cir.1956) (<HOLDING>); and Slaieh v. Zeineh, 539 F.Supp.2d 864
holding that defendants constitutionally protected privacy interest began at the door to his room not at the door to the rooming house holding that service is not avoided by service on a partys attorney as service on an attorney is ineffective unless he has been authorized to accept such service holding that arrest by the back door of defendants house was unlawful holding that service of a statecourt summons and complaint after removal to federal court is valid service holding that service was sufficient where sheriff pitched papers through a hole in defendants screen door after she spoke with him and ducked behind a door to avoid service