Task: Wrong Candidate Generation
Input (English): service on an individual’s lawyer will not suffice. See Khachikian v. BASF Corp., No. 91-CV-573, 1994 WL 86702, at **1-2 (N.D.N.Y. Mar. 4,1994) (quashing subpoena that plaintiff mailed to the defendant corporation’s attorney rather than to the corporation itself, which was the party named in the subpoena); In re Deposition Subpoena Directed to Smith, 126 F.R.D. 461, 462 (E.D.N.Y.1989) (McLaughlin, J.) (denying plaintiffs motion to serve a deposition subpoena and a subpoena duces tecum on a non-party witness by delivering the subpoenas to the witness’s attorney where Rule 45 required service on the person named in the subpoena; noting that Rule 45 should be reevaluated to permit service of subpoenas other than by personal delivery); Harrison v. Prather, 404 F.2d 267, 273 (5th Cir.1968) (<HOLDING>); see also 9A Wright & Miller, Federal Practice 
 Holding statements: (A) holding that delivery of subpoena via federal express was sufficient because effective service under rule 45 is not limited to personal service (B) holding that service is not avoided by service on a partys attorney as service on an attorney is ineffective unless he has been authorized to accept such service (C) holding that service of subpoena on plaintiffs counsel as opposed to the plaintiff himself renders such service a nullity (D) holding that an attempted service on the partys counsel was insufficient without proof of the counsels actual authority to receive service (E) holding that if service is inadequate defendant never submitted to courts jurisdiction and underlying judgment is therefore a nullity
Output (English): holding that an attempted service on the partys counsel was insufficient without proof of the counsels actual authority to receive service