As a general rule, I don’t talk to litigants. Even if their lawyer consents or hops on the call with us. Sure, the litigant is the guy paying my fee, but his lawyer is my client, and I’m not about to get in the middle of their relationship. Besides, it’s always a terrible idea to give a litigant control over something that is a lawyer’s ethical obligation. Continue Reading Run away when the litigant says this…
How to Fill Out a Hague Convention Request

(See the author’s note below for clarification on which Hague Convention!)
A Hague Service Request, commonly known in the United States as a “USM-94” but also used in Canada, can be at once straightforward and daunting. On the surface, it’s really just a fill-in-the-blank form. But the devil is in the details, and when hell breaks loose in Georgia, the devil deals the cards. It’s not as easy as it might seem, for a whole bunch of reasons.* Continue Reading How to Fill Out a Hague Convention Request
Process Server China
No. No, no no… NO.
Stop believing key word results without thinking things through. Just stop it. Continue Reading Process Server China
Process Server Mexico
No. No, no no… NO.
Stop believing key word results without thinking things through. Just stop it. Continue Reading Process Server Mexico
Process Server India
No. No, no no… NO.
Stop believing key word results without thinking things through. Just stop it. Continue Reading Process Server India
Managing client expectations across borders

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
“Do I have to go through the Hague?”

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?”
Manner of service overseas? It’s up to the authorities.

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.
Hague defendants do not warrant special summonses.

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.
Keep reading, Part Four.
(See Part One here and Part Two here. Part Three is linked below.)
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.
