In Dalessandro v. Mitchel, No. BC293472, 2019 Cal.App.LEXIS 1309 (Ct.App. Dec. 17, 2019), the Court of Appeal said that service is ineffective by proof of mailing unless there is proof that the mailing was properly paid for.
We conclude the trial court did not err in denying the motion to compel. The trial court found service of the demand to be ineffective because there was no postage affixed to the envelope containing it. (§ 684.120, subd. (a) [requiring “postage paid” when service of postjudgment “writ, notice, order, or other paper” is by mail]; Lee v. Placer Title Co. (1994) 28 Cal.App.4th 503, 511 [33 Cal. Rptr. 2d 572] [“strict compliance with statutory provisions for service by mail is required, and improper service will be given no effect.”].) Mitchell was not required to respond to a demand that was not served. Appellants make no effort to demonstrate error resulting from the trial court’s finding and thus have failed to meet their burden on appeal.4 (State Farm Fire & Casualty Co. v. Pietak (2001) 90 Cal.App.4th 600, 610 [109 Cal. Rptr. 2d 256] (Pietak).)