CKR Law LLP v. Anderson Investments International, LLC, 1:20-cv-07937

Petitioner CKR Law LLP (escrow agent) filed to compel arbitration on Sept. 25, 2020 against several foreign respondents, including Gulzhan Namazbaeva, who is alleged to be located outside the U.S.
Petitioner's initial request for alternative service on Namazbaeva (via Five Stars Design Ltd. address) was denied for insufficient proof of her connection to that company and due process concerns.
Court previously granted alternative service as to other respondents and gave petitioner time to complete a UK private investigator's inquiry into Namazbaeva.
The investigator located a residential address in Twickenham, London, and traced Namazbaeva to UK corporate records listing her as director of Five Stars and Steppe Capital (UK) Ltd.
Petitioner moved under Fed. R. Civ. P. 4(f)(3) to serve Namazbaeva by registered mail to: (1) her UK residence, (2) Five Stars’ registered office (UK), and (3) Anderson’s office in Nevis (which shares an address with a registered agent).
The Court evaluated Hague Convention constraints (UK is a signatory and does not object to service by mail), due process (Mullane ‘‘reasonably calculated’’ standard), and whether service to a corporate employer or registered agent address would likely notify a high-level employee.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Service by registered mail to Namazbaeva's UK residential address	PI located a current residential address; registered mail will notify her	Previously: insufficient proof of association with a listed corporate address; no effective opposition to current proof	Granted — UK allows mail under Hague; service is reasonably calculated to notify her
Service by registered mail to Five Stars' registered office (UK)	Namazbaeva is a director; service on employer likely to reach a high‑level employee	Same as above / no effective opposition	Granted — service on corporate employer comports with due process
Service by registered mail to Anderson's Nevis office	Anderson's Nevis address matches a registered agent; mail likely forwarded to Namazbaeva; Nevis has no treaty prohibition	No effective opposition raised	Granted — Nevis has no Hague prohibition and service to corporate address satisfies due process

Water Splash, Inc. v. Menon, 137 S. Ct. 1504 (2017) (service by mail permitted under Hague Service Convention where receiving state does not object and domestic law authorizes mail)
Mullane v. Central Hanover Bank & Trust Co., 339 U.S. 306 (1950) (due process requires notice be "reasonably calculated" to apprise interested parties of the action)