Federal Civil and Criminal Rules no longer require a certificate of service if all attorneys and parties in a case are served via the courts electronic filing system, i.e., the filing is electronic and everyone in the case receives notification via e-mail. If, however, an attorney or pro se party files in paper or a party in a case receives notice via any other means, such as regular mail, the requirement for a certificate of service remains. A certificate of service is required for all documents filed under seal and for all documents filed in sealed cases.