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California Court Finds Russian Court's Service Comported With Due Process

California adopted the 1962 Uniform Foreign Money-Judgments Recognition Act in 1967.  The Act was intended to encourage the reciprocal recognition of United States judgments abroad by codifying rules as to foreign money judgments.  In 2005, the Uniform Law Commission updated the 1962 Act and renamed it the Uniform Foreign Country Money Judgments Recognition Act.  In California, the act is codified in its present form at Sections 1713 to 1725 of the Code of Civil Procedure.

Yesterday, the Court of Appeal took up the question of whether service of process by a Russian court was effective.  AO Alpha Bank v. Yakovlev, 2018 Cal. App. LEXIS 198.  In an opinion by Justice William Dato, the Fourth District Court of Appeal found "due process does not require actual notice; it requires only a method of service 'reasonably calculated' to impart actual notice under the circumstances of the case".  In this case, service was mailed to the judgment debtor at the address provided in the surety agreement upon which he was sued.  

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