10. If personal service is impossible or impractical, what methods of service become reasonable? In DOBKIN v. CHAPMAN, 21 N.Y.2d 490, 289 N.Y.S.2d 161, 236 N.E.2d 451

(1968), the New York Court of Appeals upheld court-ordered service in three automobile accident cases by ordinary mail to the defendant’s last known address and publication in a local newspaper,214when the whereabouts of the defendants were unknown and service in the manner attempted was the best the plaintiffs could do, explaining that these were

“situations in which insistence on actual notice, or even on the high probability of actual notice, would be both unfair to plaintiffs and harmful to the public interest.” Id. at 503, 289 N.Y.S.2d at 172, 236 N.E.2d at 458. The court stressed that if the defendants failed to get notice it was their fault since they either had failed to furnish the plaintiff a correct address at the scene of the accident, as required by New York law, or had failed to leave a forwarding address.