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Baidoo v. Blood-Dzraku

New York Supreme Court
5 N.Y.S.3d 709 (2015)


Facts

Ellanora Baidoo (plaintiff) filed a divorce action against Victor Blood-Dzraku (defendant). The parties never lived together, and Blood-Dzraku told Baidoo that he had no fixed home address and no place of business. Baidoo also did not have Blood-Dzraku’s email address. Baidoo hired an investigator to locate Blood-Dzraku but was unsuccessful. Accordingly, claiming that it was the only way she could serve him, Baidoo petitioned the court to permit her to serve Blood-Dzraku via his Facebook account. Baidoo submitted an affidavit verifying that the intended Facebook account actually belonged to Blood-Dzraku. In addition, Baidoo submitted an affidavit demonstrating that Blood-Dzraku frequently communicated with her via Facebook.

Rule of Law

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Issue

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Holding and Reasoning (Cooper, J.)

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  • A "yes" or "no" answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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