The case of the day is Lipenga v. Kambalame (D. Md. 2015). Fairness Lipenga sued Jane N. Kambalame, a Malawian diplomat, alleging violations of the Victims of Trafficking and Violence Protection Reauthorization Act, the Fair Labor Standards Act, and Maryland wage and hours laws, as well as for false imprisonment, breach of contract, and other common law claims. The case, in other words, is similar in its broad outlines to Gurung v. Malhotra, 279 F.R.D. 215 (S.D.N.Y. 2011). Kambalame is presently the Malawian high commissioner in Zimbabwe. Lipenga sought to serve process on Kambalame at her personal address in Malawi but could not determine her address. It then sent a request for service to the Malawian central authority (Malawi is party to the Hague…

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