Gene Moen, JD, on his inclusion in
Super Lawyers© “Top 100 Lawyers
in Washington” for the fifth time
Angela Macey-Cushman, RN, JD,
on her inclusion in Super Lawyers©
“Rising Stars” for the sixth time.
It’s All We Do.
155 NE 100th St., Ste. 400
Medical Malpractice. It’s All We Do.
of limitations. Another issue was the
failure by the plaintiff to have the documents translated into Norwegian. The
court held service was sufficient since
Norway’s central authority had concluded that translation was unnecessary because the defendant understood English.
After reviewing and considering the
information summarized in this article,
we decided to proceed with service of
the pleadings via registered mail, return
receipt requested, pursuant to Washington’s CR 4. We did use the model
summary form on the Hague’s website
— even though it is not required for the
alternate methods of service — because
it is strongly recommended by the Special Commission and because we chose
not to have the documents translated
into Japanese. We were not concerned
about enforcing a judgment against a
Japanese national. If we had been, we
likely would have taken the Central Authority route instead. NWL
at Hertog &
focuses on the
Ellen attended the University of
Puget Sound School of Law and
worked as a litigator for many
years at various firms. She also
acts as a settlement guardian
ad litem in King County. Ellen
can be contacted at ellenb@
1. Although a court could conclude that “
actual notice” requires translation of the documents into the recipient’s native language.
2. If you must serve someone in a country that
is not a member of this Convention, you
will need to do some more digging. Also,
there may be bilateral or multilateral trea-
ties that differ from the Service Conven-
3. “Persons authorized” in the United States
4. You can also do an internet search for the
individual country, but the information
may not be in English.
5. Our paralegal located the 2006 version at
the Seattle University Law Library and was
able to obtain copies of the relevant pages.
6. A revised version dated 2016 is now available on the Hague website for €105. The
current version is not yet available through
the local law schools or the King County
7. Members of the Permanent Bureau are listed on the Hague website, under the “
8. A Special Commission drafts the convention to be adopted or amended and meets
occasionally to monitor the practical operation of the Conventions.
9. Only citation available as of this writing.