Summary of published rules, checked on October 13, 2026. Rules change, and local rules or orders can differ. Read the linked rule before relying on it. Postmarkr is a mailing service, not a law firm; this is not legal advice.
What the published rules say about serving papers by mail on opposing counsel or a party, for federal civil, bankruptcy, and appellate courts and the civil courts of Illinois, California, Texas, Florida, Ohio, Pennsylvania, and New Jersey: when mail is allowed instead of e-service, when service by mail is complete, how many days are added, what the proof states and who signs it, and the official form where one exists. More guides for law offices are on the law firm mailing page. Mailing prospective clients instead? See the lawyer direct-mail rules by state.
| Jurisdiction | When mail is allowed vs. e-service | When mail service is complete | Days added and exceptions | What the proof states and who signs | Official form |
|---|---|---|---|---|---|
| Federal civil | Mail to the person’s last known address is a listed way to serve papers after the complaint (on the attorney if the party is represented). E-service reaches registered users by filing in the court’s e-filing system, or uses other electronic means the person consented to in writing. Represented persons file electronically unless the court or a local rule allows paper. | Mail service is complete upon mailing, not on receipt. Electronic service is complete upon filing or sending, but is not effective if the filer or sender learns it did not reach the person. | 3 days are added after the period would otherwise expire when service is by mail (5(b)(2)(C)), leaving with the clerk (D), or other means consented to (F). Electronic service (E) and hand, office or home delivery (A), (B) are not listed, so they add no days. Applies only to periods that run from being served. | No certificate is required when a paper is served through the court’s e-filing system. For other service, including mail: a filed paper needs a certificate filed with it or within a reasonable time after service; for an unfiled paper, none need be filed unless a court order or local rule requires. Rule 5 lists no contents or signer. | None official. Rule 84 and the FRCP Appendix of Forms were abrogated effective Dec. 1, 2015; the current rules contain no certificate-of-service form. District-court local forms were not checked. |
| Federal bankruptcy | Adversary proceedings: Civil Rule 5 governs papers after the complaint, so mail and e-service work as in civil cases. Contested matters: the motion is served like a summons under Rule 7004 (mail allowed); later papers under Civil Rule 5(b). Rule 9036 permits e-service on registered users or consenting recipients, but not for documents Rule 7004 governs. | Mail service of later papers is complete upon mailing (Civil Rule 5(b)(2)(C), via Rules 7005 and 9014(b)(3)). Electronic notice or service is complete upon filing or sending, but not effective if the sender receives notice it did not arrive. A summons and complaint served by mail must be deposited in the mail within 7 days after the summons issues. | 3 days are added when service is made by mail, by leaving with the clerk (Civil Rule 5(b)(2)(D)), or by other consented means (5(b)(2)(F)); electronic service is not listed. The wording says 'by mail' generally rather than citing Civil Rule 5(b)(2)(C). An adversary-proceeding answer runs from summons issuance, not service. Exception: a summons and complaint in an adversary proceeding may be served by first-class mail, postage prepaid, within the United States, in addition to Civil Rule 4 methods, at addresses the rule specifies by defendant type. Insured depository institutions get certified mail to an officer under 7004(h) unless an exception applies. Rule 9036 e-service does not apply. | Summons and complaint (including by mail): Civil Rule 4(l), applied by Rule 7004(a)(1), requires proof to the court by the server’s affidavit unless waived or served by a marshal; failing to prove does not void service. Later adversary papers: Civil Rule 5(d)(1)(B) via Rule 7005. Rule 9014 imports only Civil Rule 5(b) manner; 7005 is not on its list. | Director’s Bankruptcy Form B 2500A, Summons in an Adversary Proceeding (12/15), has a Certificate of Service page: the signer gives name and date and checks a method, e.g. 'Mail service: Regular, first class United States mail, postage fully pre-paid, addressed to:', declared under penalty of perjury, with print name and business address. Issued under Rule 9009; optional unless locally required. |
| Federal appellate | Nonelectronic service may be personal, by mail, or by third-party commercial carrier for delivery within 3 days. Electronic service reaches registered users by filing in the court’s e-filing system, or uses other electronic means consented to in writing. When reasonable, service must be at least as expeditious as the filing method. Represented parties are served through counsel. | Service by mail or commercial carrier is complete on mailing or delivery to the carrier. Electronic service is complete on filing or sending, unless the party making service is notified the paper was not received. | 3 days are added when a party must act within a set time after service, unless the paper was served electronically on the party or delivered to the party on the date stated in the proof of service. Mail and carrier service therefore add 3 days unless delivered on that stated date; electronic service adds none. | A paper served other than through the court’s e-filing system must contain an acknowledgment by the person served, or proof of service by the person who made service certifying date and manner, names served, and their mail or electronic addresses, fax numbers or delivery addresses. A brief or appendix filed by mail also states its mailing date and manner. | None in FRAP. The Appendix of Forms (Forms 1A–7 as of Dec. 1, 2025) has no certificate-of-service form; Form 6 is a type-volume certificate and Form 7 an inmate-filing declaration. Circuit-published forms were not checked in this pass. |
| Illinois | Electronic service (e-mail or an approved EFSP) is the default. U.S. mail is an alternative only when a self-represented party has no e-mail address, a rule or court order specifies non-electronic service, or extraordinary circumstances prevent timely e-service. Mail goes to the address in the party's appearance, postage fully prepaid. | Service by U.S. mail is complete four days after mailing. Electronic service and personal, office or residential delivery are complete on the day of transmission. Third-party commercial carrier service is complete on the third court day after delivery to the carrier. | No separate add-on. The four-day delay is built into when mail service is complete (R. 12(c)). A search of the compiled rules found no general mail add-on for trial-court civil practice. Reviewing-court motion responses (R. 361(b)(3)) use their own longer by-mail periods. | Proof of service is filed with the clerk. For mail, the person who deposited the document in the mail certifies under 735 ILCS 5/1-109 the time and place of mailing, the complete address on the envelope, and that proper postage was prepaid. E-service through the EFM/EFSP is proved by its automated verification. | Proof of Delivery (ATJ 851.7, rev. 09/25), a statewide form approved by the Illinois Supreme Court that all circuit courts must accept. For mail it asks for the address, the location of the mailbox or carrier, and the date and time sent. The person sending signs under 735 ILCS 5/1-109. |
| California | A represented person who has appeared must accept electronic service of anything that may be served by mail, and the court may order e-service on represented persons. Unrepresented parties get e-service only if they consent. Otherwise mail is available. E-service is not allowed when certified or registered mail is required. | Mail service is complete when the sealed, postage-paid envelope is deposited with USPS (post office, mailbox or similar facility). It must be addressed to the office address last given on a filed and served document, otherwise the residence. E-service is complete at transmission or when the e-notification is sent. | Mail: +5 calendar days within California; +10 if mailing or address is outside California but in the U.S.; +12 if the address is in the Secretary of State's address confidentiality program; +20 if outside the U.S. Not extended: notices of intention to move for new trial or to vacate (§ 663a), notice of appeal. E-service: +2 court days, same exceptions. | Affidavit by a person over 18, not a party, who lives or works in the county where the mailing occurs, stating the document title, the server's address, the date and place of deposit, the name and address on the envelope, and sealing with postage fully prepaid. Alternatives: a State Bar member's certificate (no county requirement) or a business-practice affidavit. | POS-030, Proof of Service by First-Class Mail—Civil (Judicial Council of California). Footer: 'POS-030 [New January 1, 2005]', 'Form Approved for Optional Use'. Signed under penalty of perjury by the person who mailed. Item 1 states over 18, not a party, and living or working in the mailing county. Item 3 asks for the date and city/state mailed from. |
| Texas | An e-filed document must be served through the electronic filing manager when the recipient's e-mail is on file there. Otherwise it may be served by the other methods. Documents not e-filed may be served in person, by mail, commercial delivery, fax, e-mail, or as the court directs. Attorneys must e-file where e-filing is mandated. | Mail service is complete when the document is deposited in the mail, postpaid and properly addressed. Electronic service is complete on transmission to the serving party's electronic filing service provider. | Three days are added to the prescribed period when the paper was served by mail; weekends and holidays count toward them (Rule 4). The rule text adds no days for e-service, fax or commercial delivery. A party may prove non-receipt, or non-receipt within three days of deposit, and the court may then extend time. | The party or attorney of record certifies compliance in writing, over signature, on the filed instrument (a certificate of service). A certificate by a party or attorney, an officer's return, or another person's affidavit is prima facie evidence of service. A party, attorney, sheriff, constable, or anyone competent to testify may serve. | None official. The txcourts.gov forms page lists no standalone certificate-of-service form, and the rules put the certificate on the filed instrument itself (21a(e), 21(d)). |
| Florida | Portal-filed documents must be served through the portal, and attorneys must file through the portal. Unrepresented parties must designate e-mail unless in custody or excused on Form 2.601. Paper service (hand, U.S. mail, commercial delivery) is permitted or required for those parties, or any who never registered or designated e-mail, unless the parties agree otherwise. | Service by mail is complete on mailing. Portal service is complete on filing, e-mail service when sent, and hand or commercial delivery on the day of delivery. | Five days are added after the period would otherwise expire when service is made only by mail. The rule adds nothing for portal or e-mail service. | A certificate of service is prima facie proof when it includes a certification, the date of service, the names of the persons served, their service addresses, and the method of service. The rule's sample is signed 'Attorney at Law'. Every served document must be signed by the attorney, the unrepresented party, or another authorized person (2.515(a)). | None official as a standalone civil form. The rule's own sample certificate is the closest thing, and its current wording differs from the older '(e-mail) (delivery) (mail)' text. RGJP Forms 2.601–2.606 cover e-mail excusal, e-mail designation, address changes and case-status notices, not proof of service. |
| Ohio | A represented party is served through the attorney, and directly too if the attorney has a limited appearance. U.S. mail to the last known address is allowed. E-service goes to a fax or e-mail address given under Civ.R. 11, or another platform if all agree in writing. Court facilities can be used only if a local rule allows. | Mail service is complete on mailing. Commercial carrier service (delivery within three calendar days) is complete when the paper is handed to the carrier. Electronic service is complete on transmission, but is not effective if the server learns it did not reach the person. | Add 3 days when a paper is served by mail or commercial carrier under 5(B)(2)(c) or (d). This does not apply to responses to a summons (Civ.R. 4 to 4.6). The rule adds nothing for electronic service. The 2012 Staff Note says the 3-day rule does not apply to papers served under other divisions of Civ.R. 5. | Each served document must come with a completed proof of service. It states the date and manner of service and names the exact Civ.R. 5(B)(2) division used. It is signed under Civ.R. 11, by the attorney of record or the unrepresented party. The court will not consider a filed document until proof is endorsed on it or filed separately. | No official form for general civil service after the complaint. The Appendix of Forms' General Civil Forms 1–20 (Civ.R. 84) include no proof-of-service form. Some Uniform Domestic Relations forms in the appendix include a 'Certificate of Service' block. |
| Pennsylvania | Mail is a default method. Papers go to the attorney of record's endorsed address. An unrepresented party is served at their endorsed address, residence or place of business, or else the last known address. Electronic (non-fax) service is allowed if the parties agree or an e-mail address appears on an earlier filing. Fax service is under 440(d). | Mail service is complete on mailing. Electronic service is complete when the paper is sent to the recipient's e-mail address, or posted to the e-filing website with the system's e-mail notice to the recipient. Fax service is complete when transmission is confirmed. | Civil rules: no general rule adding days for mail service was found. Pa.R.C.P. 106 (computation of time) was rescinded effective Jan. 1, 2024. Its replacement, Pa.R.J.A. 107, adds no days for mail. Appellate courts only: Pa.R.A.P. 121(e) adds 3 days for U.S. mail or commercial carrier service, except for court orders. | Rule 440 states no proof requirement. A motion must include a certificate of service giving the manner of service and address served. It names each attorney of record and their party, and marks unrepresented parties 'pro se'. The motion is signed and endorsed. No statewide requirement was found for other papers. On appeal, the server certifies proof (Pa.R.A.P. 121(d)). | No official form found. The pacourts.us 'Forms for the Public' page lists no certificate-of-service form (checked 2026-10-13). Pa.R.C.P. 208.2(a)(4) sets the required content but provides no form. County local forms were not checked. |
| New Jersey | Attorneys: ordinary mail to their office, e-mail by an attorney to addresses listed on eCourts, hand delivery, or leaving it at the office. A party without an attorney: as in R. 4:4-4, or certified or registered mail, return receipt requested, plus ordinary mail at the same time. eCourts guidance: paper service for self-represented litigants and parties lacking confirmed eCourts e-mail. | Ordinary mail: complete on mailing. Certified or registered only: on acceptance. Both sent together: when the ordinary mail is sent. Certified refused or unclaimed: when the ordinary mail is sent. Motions differ: complete only on receipt, with ordinary mail presumed received the third business day after mailing. Courier: when the courier takes it, if next-business-day delivery is guaranteed. | Add 5 days (not 3) when a paper is served by ordinary mail and a deadline runs from service. R. 1:3-3 names ordinary mail only; it adds nothing for e-mail or eCourts service. Motion deadlines instead use the receipt presumption in R. 1:6-3(c). | Proof can be an acknowledgment of service, an affidavit of the server, or a certification of service attached to the paper and signed by the serving party's attorney. For mail, it states the mailing went to the last known address. It names and gives addresses for each attorney served (with their party) and any pro se party. File it promptly. | No form found for Superior Court trial-level civil cases. Searching the NJ Courts forms catalog for 'certification of service' and 'proof of service' returned three unrelated forms. They are Appellate (12227), Supreme Court (12908) and a Tax Court 'Supplemental eCourts Proof of Service' (12548). Self-help packets with built-in certifications were not checked. |
These show how the rules differ on the same facts. They don't work out a deadline: count the days under the court's own rules on computing time.
A paralegal mails a paper to opposing counsel. When it counts as served, and how many days are added, depends on the court.
Federal district court: service is complete upon mailing, and 3 days are added after the period would otherwise expire. Illinois: service by U.S. mail is complete four days after mailing, with no separate add-on. Texas: service is complete when the document is deposited in the mail, and three days are added to the prescribed period.
A paralegal in Los Angeles mails the same paper to counsel in San Diego and to counsel in Chicago.
For San Diego the period is extended by 5 calendar days within California. For Chicago it is 10, because the address is outside California but in the U.S. The place of mailing counts too: a paper mailed from another state gets 10 even when the address is in California, and an address outside the U.S. means 20. None of these extend the time for a notice of appeal.
In a New Jersey Superior Court case, opposing counsel can be served by ordinary mail. To serve a party without an attorney by mail, the rule lists certified or registered mail, return receipt requested, plus ordinary mail at the same time; service is then complete when the ordinary mail is sent.
A deadline that runs from ordinary-mail service gets 5 days added. Motion papers differ: they count as served on receipt, with ordinary mail presumed received the third business day after mailing. A Postmarkr First-Class letter could only be the ordinary-mail half; Postmarkr doesn't send Certified Mail.
U.S. district courts. Source: Federal Rules of Civil Procedure, December 1, 2025 (House Committee on the Judiciary, Committee Print No. 4, 119th Cong., 1st Sess., GPO 2026)
U.S. bankruptcy courts. Source: Federal Rules of Bankruptcy Procedure, December 1, 2025 (House Committee on the Judiciary, Committee Print No. 3, 119th Cong., 1st Sess., GPO 2026)
U.S. courts of appeals. Source: Federal Rules of Appellate Procedure with Forms, December 1, 2025 (House Committee on the Judiciary, Committee Print No. 2, 119th Cong., 1st Sess.)
Civil cases. Source: Illinois Supreme Court Rules (compiled PDF), "Current May 29, 2026"; amendment listing at https://www.illinoiscourts.gov/supreme-court-rules/
Civil cases. Source: California Legislative Information, Code of Civil Procedure §§ 1010.6, 1012, 1013, 1013a (sectionNum=1010.6, 1012, 1013, 1013a on the same leginfo page)
Civil cases. Source: Texas Rules of Civil Procedure (Supreme Court of Texas, txcourts.gov Rules & Standards)
Civil cases. Source: Florida Rules of General Practice and Judicial Administration (The Florida Bar, linked from floridabar.org/rules/ctproc/), July 1, 2026 edition
Courts under the Ohio Civil Rules. Source: Ohio Rules of Civil Procedure (Supreme Court of Ohio, official compilation PDF)
Courts of common pleas, civil. Source: 231 Pa. Code Rule 440. Service of Legal Papers Other than Original Process (Pennsylvania Code & Bulletin)
Superior Court, civil. Source: New Jersey Rules of Court — NJ Courts website rule viewer (rule text served by https://www.njcourts.gov/njcourts_rules_of_court/get-term?tid=<id>: 1:5-2=24256, 1:5-3=24261, 1:5-4=24266, 1:3-3=24191, 1:32-2A=25281, 1:5-1=24251)
Not under a court rule's service-by-mail procedure. Those rules usually come with a proof-of-service form that the person who mailed the papers fills in. Illinois's statewide form, for example, asks who mailed it, where and when. Postmarkr's record shows the PDF we printed and the letter's status, not who deposited it or where.
For a dated USPS record you make at the counter, see Postmark and proof of mailing. For how a certificate of service is worded, see Certificate of service wording and mail rules.
All 51 rule summaries in the table, each with its citation, source URL and the date we read it, as CSV or JSON.