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EFTA00725476
mer Rule 4(d)(1)(now Rule 4(e)) was insufficient where nothing indicated that recipient resided in defendant's apartment); Franklin America, Inc. v. Franklin Cast Prods., Inc., 94 F.R.D. 645, 647 (E.D. Mich. 1982) (Rule 4(d)(1) requires the recipient to live in the same place as the party to be served). As in Trov
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