A court may permit service by publication, upon motion without notice, if traditional service is "impracticable." The impracticability standard does not require the applicant to satisfy the more stringent standard of due diligence under CPLR 308(4). Neither does it require the applicant to make an actual showing that service has been attempted pursuant to CPLR 308(1), (2), and (4).
JP Morgan Chase Bank, N.A. v. Perkin, NY Slip Op 04600 (2d Dep't August 4, 2021)
Tomorrow's issue: Labor Law.
