No. No, no no… NO.
Stop believing key word results without thinking things through. Just stop it.
Continue Reading Process Server India
Insight and commentary on the 1965 Hague Service Convention (among other Hague Conventions) and how it works for litigators in the United States and Canada.
No. No, no no… NO.
Stop believing key word results without thinking things through. Just stop it.
Continue Reading Process Server India

The single biggest challenge in my practice is layered– like a cake or a parfait or an onion or… everybody’s favorite grumpy, Glaswegian-accented ogre.
Continue Reading Managing client expectations across borders

Let’s dig a little deeper into what that query truly means, because some variation of it pops into my inbox at least once or twice a month, from litigators in both the U.S. and Canada. There’s a lot to unpack in those eight words, and a few things need to be clarified to get to the heart of the question, but the quick answer is… yes.
Continue Reading “Do I have to go through the Hague?”

Here’s a Hollywood story that’s relevant to Hague Service issues (I promise)…
Late last month, the story broke that Jason Sudeikis had a custody action served on Olivia Wilde while she was on stage, at a public event, announcing her new movie. In front of a room full of fans and press and industry bigwigs, that’s got to be a shocker, and more than a bit embarrassing. The Twitterati naturally went berzerk, throwing as much vitriol at the actor as they could muster.
Continue Reading Manner of service overseas? It’s up to the authorities.

Very regularly, clients will email me a batch of documents to have served on an offshore defendant and my staff* and I will get to work putting the paperwork together. Occasionally, a document will jump off the screen at me and make me scratch my head in wonder.
Continue Reading Hague defendants do not warrant special summonses.

Back in law school, I was always befuddled by those gunner types who insisted that no legal argument could be made without a case citation. The professor would ask a question and these guys (I use that in the non-gender-exclusive sense) would go thumbing through their casebooks and brief notes to find just the right response, because they’d swallowed too much law review Kool-Aid.
Meanwhile, we of the nuts & bolts persuasion (read: 50th percentile performers) would pull up a browser page and have an answer from Google far more quickly.
Continue Reading Yes, counsel, you can use Google as a *starting* point. Wikipedia, too.

(See Part One here and Part Two here. Both discuss parts of FRCP 4, while this one hits on the Hague Service Convention itself.)
One day toward the end of my 2L year, this wisdom came from one of my mentors, a retired Army JAG officer who had more than his share of trial experience in military and civilian courts:
Lawyers are the most helpless race of people on the planet.
An axiom of life was posed to me one day toward the end of my 2L year:
Lawyers are the most helpless race of people on the planet.

An axiom of life was posed to me one day toward the end of my 2L year:
Lawyers are the most helpless race of people on the planet.

[Update, August 2025: Michigan is a special situation, outlined here.]
A while back, I wrote that removing the self-expiration language in a standard bankruptcy summons is imperative when serving overseas defendants in adversary proceedings. I’ve used that post on several occasions to advise litigators in various state venues to do likewise, where the documents contain text like “This summons is effective for service only if served within 30 days after the date it is issued.”
The same basic logic applies:
Continue Reading Modify State Court Summons Deadlines. Just do it.