The case of the day is Davis v. Zhou (9th Cir. 2019). I covered the case in November 2018. Zhou Liang, a Chinese national, was driving a rental car in Seattle when he collided with a city bus, injuring Michael Davis. He returned to China. Davis sued Zhou in the District Court three days before the expiration of the three-year statute of limitations. He waited 119 days and then transmitted a request for service to the Chinese central authority under the Service Convention. (Recall that FRCP 4(m), which on its face applies only to service within the United States, gives the plaintiff ninety days to effect service; formerly it gave 120 days, which may account for the plaintiff’s attempt on day 119 rather than,…

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