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Federal Court Authorizes Rare Service by Text Message in Williams Case

Justly Prudent secures rare procedural victory allowing service of legal documents through text messaging, email, and publication.

Jul 1, 2025

In a significant procedural victory that reflects the evolution of modern legal practice, the United States District Court for the District of Columbia has authorized Justly Prudent to serve legal documents through an innovative combination of methods, including text messaging. This rare authorization was granted in the case of Williams v. Tesfalidet, where the firm represents clients Edward Williams and Grow Club, LLC in their effort to recover $40,000 from a defendant who has been deliberately evading service of process.


On June 29, 2025, Judge Randolph D. Moss granted Justly Prudent's motion for alternative service, recognizing that the firm had made "diligent but unsuccessful efforts over a five-month period" to serve the defendant through traditional methods. The court found that our proposed three-pronged approach of service by publication, email, and text message was "reasonably calculated" to provide the defendant with actual notice of the legal proceedings.


This authorization is particularly noteworthy because it represents the court's recognition that modern communication methods can satisfy constitutional due process requirements when implemented properly. The firm demonstrated that text messaging was the defendant's preferred method of communication, having maintained regular contact through this medium until the defendant ceased all communication after being informed of potential legal action.


The case stems from allegations that Defendant Benhur Amanuel Tesfalidet accepted $40,000 in December 2021 for the stated purpose of booking musical artists for a concert event that never occurred. Despite extensive efforts to locate Mr. Tesfalidet, including professional investigations, background searches using legal databases, and multiple attempts at personal service across three different addresses, all traditional service methods proved unsuccessful.


The court's decision highlights the challenges attorneys face when defendants deliberately evade service and demonstrates how the legal system is adapting to ensure that due process rights are protected even when traditional methods fail. This procedural victory ensures that the underlying case can move forward, allowing Justly Prudent's clients to seek justice and recover the funds they are owed while establishing important precedent for future cases involving similar challenges in serving defendants who use modern communication methods.

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