I cannot recommend today’s case of the day, Development Specialists, Inc. v. Li (In re Coudert Bros. LLP) (S.D.N.Y. 2017), highly enough. It’s an excellent piece of work by Judge Kenneth M. Karas, a rare tour de force through FRCP 4 and its interplay with the Service Convention. Coudert Brothers, a New York law firm, had dissolved in 2005 and filed a Chapter 11 bankruptcy petition in New York in 2006. A plan of liquidation was confirmed in 2008. The plan allowed Coudert’s former partners to enter into a settlement agreement with Development Specialists, the plan administrator. According to the plan administrator’s declaration, Rupert X. Li, one of the former partners, who resided in Hong Kong, did not executed the agreement or otherwise participate…

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