Sometimes serving a subpoena can be a pain. Strangely, when process servers attempt to serve, people sometimes refuse to accept or offer a variety of other barriers. In that circumstance, substitute service is often attempted. But is it proper?
Reiner v. Pejman Bady is an unpublished decision from the Supreme Court of Nevada. The district court dismissed a lawsuit for failure to timely serve; the plaintiff appealed. The plaintiff served defendant’s receptionist and argued this “was proper because his receptionist had apparent authority to accept service of process….” However, “Dr. Bady denied that his receptionist had actual authority to accept service of process, and Dr. Reiner did not submit any evidence to contradict Dr. Bady’s position. Thus, we conclude that leaving the summons and complaint with Dr. Bady’s receptionist does not constitute effective service of process on Dr. Bady or his corporations.”
Applied to subpoenas, accomplishing appropriate service is sometimes a pain. However if not accomplished then the subpoena is unenforceable.
 No. 59314, 2013 Nev. Unpub. LEXIS 1743, 2013 WL 7162026 (2013).