Y’all, if you know you’re going to be removed, just initiate the case in federal court to begin with.  It’ll save everybody involved a whole bunch of time and headache. Lots of plaintiffs’ lawyers gasp when I say that.  They look at me like I have three heads. “Are you nuts?” “Oh, you’re a comedian now?” “Clearly, you’re an idiot.” I certainly understand why they react that way.  State juries are kinder to plaintiffs, generally…

Since the beginning, the primary purpose of this blog has been to educate the practicing bar on the practical application of the Hague Service Convention.  While we’re happy to give away the recipe to the Special Sauce (there’s no secret about this stuff, really), we’ve been lucky to have a whole bunch of great people trust us to handle their Hague Service Requests from start to finish.  Many of them find us through the Hague…

Yet another “FAQ” post, if you will… “Hey, Aaron, the complaint is under seal, and the judge has ordered me to instruct the process server that he’s under the same obligation as I am.” I respond: Well, that’s all fine and good, if you’re using private agent service in a country that would enforce the seal.  But Article 5 service via a Central Authority?  In a word, fugghetaboutit.  Once this thing goes overseas, all…

Squarely in the heart of the Caribbean Sea lies an island that has played host to countless movies, spring break junkets, and movies about spring break junkets.  The mere mention of Jamaica conjures images of Bob Marley, cabanas under palm trees, and scantily clad beachgoers who have escaped the frigid northern winter.  And lots of tour packages… which naturally leads to lots of litigation. Jamaica is not party to the Hague Service Convention (HSC), although…

Back when dinosaurs roamed the earth, I took Civil Procedure from a couple of highly talented professors.  One was among my favorite teachers of all time— he taught the concept of joinder with a shopping bag full of Beanie Babies™ and, for some baffling reason, a Jessie the Cowgirl™ doll from Toy Story 2.*  On the surface, that’s a very weird thing for a licensed attorney to put into a blog post, but…

A routine question from clients across the continent– especially those in my own state*:  “Hey, Aaron, the clerk says I have to tell the court who is going to be serving the documents in China or they won’t issue my summons.  Could you get me the process server’s name and qualifications so they can appoint him?” There’s a lot loaded into that, with some compelling responses.  The primary response: No… you and I don’t get…

Client queries: “hey, Aaron, the clerk says the Hague Service Convention requires certified copies of the Summons and Complaint and something called an Apostille.  Where do I get that?” I get some variant of that question pretty regularly, most often from colleagues within just a few miles of me.* For starters… no, the Hague Service Convention says nothing of the sort. Sure, at one time, some Hague Central Authorities required court-certified copies to be submitted…