Within the rule of Due Process, a person has “an obligation to accept service of process when service is attempted reasonably.” In the case of Peoples Trust Company v. Kozuck, Zimmerman attempted to service the papers to Mrs. Kozuck in a reasonable manner as she denied her presence at the household and denied her proper identity to this service. Despite Mrs. Kozuck not personally receiving the service of process, she is still liable as Zimmerman informed and located the papers in a retrievable position near the address. The case of Chernick v. Rodriguez declared that service of process can still be valid even if the person being served is not witness to personally accept the papers, supporting the ruling of the court. Also, the case of Roth