5 Common Mistakes Attorneys Make When Sending Service Requests (and How to Avoid Them)

We all know how fast-paced litigation can be. Deadlines stack up, court rules get tricky, and service of process sometimes feels like one more thing to rush through. But here’s the reality: small mistakes in a service request can cause big headaches. Papers get delayed, costs go up, and in the worst cases, a judge might even throw out the service.

At Miami PSPI, we see the same issues over and over again. The good news? They’re all avoidable. Here are the five most common mistakes we see from attorneys and their staff—and some easy ways to fix them.

1. Sending an Incomplete or Incorrect Address

The problem: Many service requests arrive with outdated or incomplete addresses. Even a missing apartment number or a typo in the street address can waste valuable time.

The fix: Verify the address before sending it out. Use property appraiser records. At Miami PSPI, we can cross-check information and can conduct a targeted skip trace if the subject’s location is uncertain.

2. Forgetting to Include All Required Documents

The problem: A summons arrives, but the complaint or exhibits are missing. Without a full packet, service is defective and can be challenged in court.

The fix: Review jurisdiction-specific rules. In Florida, for example, a summons must typically be served with a copy of the complaint. Always check: Summons ✔ Complaint ✔ Exhibits ✔ Cover Letter ✔

3. Not Providing Deadlines or Special Instructions

The problem: We get a lot of service requests marked “ASAP,” but that can mean very different things to different people. For one client, “ASAP” might mean routine service - just handle it when you can. For another, it might mean today (priority) or tomorrow (rush). The problem is, each of those has a different fee and level of urgency. If we have to stop and reach out to clarify, we could lose valuable time, especially if the attorney, secretary, or paralegal has already stepped out for lunch or left for the day.

The fix: Include any statutory deadlines, hearing dates, or special rush requirements. If a case needs rush or priority service of process in Miami-Dade or Broward County, mark it clearly. It is important to note not to send out service docs with a hearing or depo date in two days, and then mark it routine. This will also cause a delay as we need to confirm that the service request is a Priority or Rush.

4. Overlooking Defendant Identifiers

The problem: Serving “John Smith” at a large apartment complex is nearly impossible without more information.

The fix: Along with identifiers like age, DOB, or employer, share practical details that help in the field. An apartment number, gate code, building layout, or description of the unit entrance can make the difference between successful service and wasted attempts. Vehicle information (make, model, license plate) is also very useful when we’re trying to confirm we’re at the right residence. And if you have a photo of the subject, that helps us identify them immediately when they answer the door or spot them coming or going.

5. Failing to Communicate About Special Circumstances

The problem: If the defendant is evasive, has a history of violence, or is only home during specific hours, that matters. Without this context, servers may waste time or face unnecessary risks.

The fix: Share what you know, even if it seems minor. Notes like “arrives home after 7 p.m.” or “uses the side entrance” make service more efficient.

A Quick Checklist Before Sending Service Requests

• ✅ Verified address (double-checked for accuracy)

• ✅ Complete document set (summons, complaint, exhibits)

• ✅ Clear deadlines and priority level noted

• ✅ Defendant identifiers (DOB, description, vehicle, photo)

• ✅ Special instructions or background details included

Proper service of process is the foundation of due process. By avoiding these common mistakes, law firms save time, reduce costs, and strengthen their cases.

At Miami PSPI, we provide nationwide service of process, skip tracing, background checks, and investigative support. Our team is committed to compliance with Florida statutes and court rules, ensuring that every affidavit and return of service meets legal standards.

process server in Miami; Miami service of process; Florida process server; private investigator in Miami; common service of process mistakes; attorney checklist for service requests; skip trace; nationwide process serving; tips for attorneys on process serving; Miami PSPI investigations