KARMIN v. ROGOVE, 3:25-cv-01036

Plaintiff Alan Karmin alleges that 13 defendants, including Adreinne C. Rogove and several publishing entities, disseminated defamatory statements about him regarding unauthorized practice of law.
The dispute arose after Karmin performed document preparation work in 2017, was subsequently sued in state court, and the associated case was discussed in blog posts.
Karmin claims his requests to remove or correct online posts by Ms. Rogove and others were ignored, leading to alleged physical, financial, and emotional harm.
Karmin seeks damages for various torts including defamation, trade libel, and breach of fiduciary duty.
Procedurally, Karmin moved for an order to authorize alternative service, arguing defendants had knowledge of the complaint and that some service attempts had already been made.
The Court is ruling on whether Karmin’s efforts satisfy the legal standard for alternative service.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of prior service attempts	Knowledge of complaint is enough	Mere knowledge is insufficient	Plaintiff’s efforts do not meet due diligence
Due diligence in attempting personal service	Three attempts by one process server	Insufficient investigative effort	Plaintiff failed to show reasonable effort
Service via mail without personal attempt	Allowed based on awareness	Contravenes court rules	Jumping to mail service is not compliant
Acceptance of service by attorney	Declined offer as unnecessary	Willing to accept for more time	Declining was unjustified

None listed with official reporter citations in the opinion excerpt. (All key precedents referenced used unpublished or Westlaw citations.)