Digest for April 28, 2011

Domanus v. Lewicki (N.D. Ill. 2011). The plaintiff served process on several Polish firms by serving an officer in the U.S., where the Polish firms had stated, in an interrogatory resposne, that the officer was “second vice president,” and where the plaintiff had offered additional evidence necessary to make a prima facie showing that he had de facto control of the entities. The court rejected a motion to dismisss for insufficient service of process on the grounds that in light of the prima facie showing, service on the officer was proper under Rule 4(h).

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