LEVENTHAL, Circuit Judge:
In 1967, landlord Lewis Doby filed a suit for possession of an apartment against his tenant, Cecil Tutt, in the Landlord and Tenant Branch of what was then the District of Columbia Court of General Sessions. The complaint alleged that Tutt was in default for $275 rent. The complaint was served by a United States Marshal by "posting" on the door to the apartment. A default judgment was entered fifteen days after the action was filed when Tutt...
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