The Case of the Day is Jon D. Derrevere, P.A. v. Mirabella Foundation (M.D. Fla. 2011). Derrevere was Mirabella’s lawyer. He had represented Mirabella, apparently a Panamanian entitiy, in Naseer v. Mirabella Foundation, in which Mirabella was accused of a fraudulent transfer of real estate. Although Panama is a party to the Inter-American Convention on Letters Rogatory, Derrevere sought leave to serve Mirabella by alternate means under Rule 4(f)(2)(C). In particular, he sought to serve Mirabella by mail to Mirabella’s registered agent in Panama, which was a Panamanian law firm. (Panamanian law, as described in the opinion, is unclear. On the one hand, the law firm was “the registered agent … as designated in Mirabella’s formation papers.” On the other hand, “the Republic of…
Tagged: Inter-American Convention, Panama, service by mail