Intelligender LLC v. Soriano (E.D. Tex. 2011). Where plaintiff served process on a Chilean defendant using an alternate means of service without first requesting leave of court under Rule 4(f)(3) and did not show that the alternate means were permissible under the Inter-American Convention, the court denied a motion to approve the alternate means of service nunc pro tunc.

In re Braga (S.D. Fla. 2011). Granting in part a motion to stay discovery under the judicial assistance statute pending the resolution of issues in litigation in Brazil and the Cayman Islands. The court had previously denied a motion to vacate its order allowing an application for judicial assistance in taking discovery on an ex parte application.