person’s lawyer will not suffice.”). Nonetheless, more recent cases in the Second Circuit interpret Rule 45’s personal service requirement liberally where the type of service used “was calculated to provide timely actual notice.” CareCore, 2008 WL 3833238, at *2 (noting that “nothing in the word ‘delivering’ [in Rule 45(b)(1) ] indicates personal service, and a personal service requirement can be unduly restrictive”); see also Cartier v. Geneve Collections, Inc., No. CV 2007-0201, 2008 WL 552855, at *1 (E.D.N.Y. Feb.27, 2008) (agreeing that “ ‘delivery’ under Rule 45 means a manner of service reasonably designed to ensure actual receipt of a subpoena by a witness, rather than personal service”); Cordius Trust v. Kummerfeld, No. 99 Civ. 3200, 2000 WL 10268, at *2 (S.D.N.Y. Jan. 3, 2000) (<HOLDING>). Aristocrat first sought to serve individual
holding that inhand delivery is not required under rule 45 so long as service is made in a manner that reasonably insures actual receipt of the subpoena holding that because alternative service by means of certified mail reasonably insures actual receipt of the subpoena by the witness the delivery requirement of rule 45 will be met holding that delivery of subpoena via federal express was sufficient because effective service under rule 45 is not limited to personal service holding that service of a subpoena via certified mail is sufficient under rule 45 particularly when defendant does not deny actual receipt holding the rule 4 requirement of delivery to the appropriate united states attorney required personal service not service by certified mail