Moriarty v. Hashemite Kingdom of Jordan

CourtDistrict Court, District of Columbia
DecidedJune 14, 2024
DocketCivil Action No. 2018-2649
StatusPublished

This text of Moriarty v. Hashemite Kingdom of Jordan (Moriarty v. Hashemite Kingdom of Jordan) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Moriarty v. Hashemite Kingdom of Jordan, (D.D.C. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ____________________________________ ) JAMES R. MORIARTY, et al., ) ) Plaintiffs, ) ) v. ) Case No. 18-cv-2649 (CKK) ) THE HASHEMITE KINGDOM OF, ) JORDAN et al., ) ) Defendants. ) ____________________________________)

MEMORANDUM OPINION AND ORDER

Presently pending before the Court is Plaintiffs’ renewed motion seeking to execute service

of process by publication on Defendant Ma’arek Al-Tawayha a/k/a Abu Tayeh (“Abu Tayeh”).

ECF No. 48. The motion was referred to the undersigned for resolution on July 18, 2023. ECF

No. 42. After a thorough review of Plaintiffs’ motion and the record, 1 the undersigned GRANTS

the motion.

I. BACKGROUND

A. Procedural History

Plaintiffs are the family members of three U.S. Army Special Forces members—James

Moriarty, Matthew Lewellen, and Kevin McEnroe—who were killed on November 4, 2016,

during an ambush as they entered a Jordanian air base that was home to the American military

during operations opposing the regime of Bashar al-Asad in Syria. ECF No. 6, ¶¶ 1–4. The

1 The docket entries relevant to this Memorandum Opinion and Order are: (1) Plaintiffs’ Amended Complaint, ECF No. 6; (2) Plaintiffs’ Motion for Leave to Execute Service of Process by Publication, ECF No. 41; (3) Minute Order (Aug. 28, 2023); (4) Plaintiffs’ response to the Minute Order. ECF No. 43; (5) Memorandum Opinion and Order denying ECF No. 41 without prejudice, ECF No. 44; and (6) Plaintiffs’ Renewed Motion for Leave to Execute Service of Process by Publication, ECF No. 48. Citations to page numbers herein reflect the pagination assigned by the Court’s Electronic Case Filing system. Amended Complaint alleges that the perpetrator, Defendant Abu Tayeh, was a member of the

Jordanian military on duty at the entrance to the base who opened fire in an unprovoked attack

on the Special Forces members as they entered the base. Id., ¶ 3.

Plaintiffs bring this action seeking to recover damages related to the wrongful deaths of

their loved ones. ECF No. 6 at 20–27. In February 2019, Plaintiffs filed the Amended Complaint

against Abu Tayeh and the Hashemite Kingdom of Jordan (“Jordan”), which Plaintiffs allege aided

and abetted the attack. Id., ¶¶ 4, 12. Plaintiffs allege that Abu Tayeh was criminally prosecuted

in Jordan for the attack and was convicted in July 2017 of “manslaughter for killing more than one

person and for violating military orders and regulations.” Id., ¶ 12. Abu Tayeh was sentenced to

life in prison, and he is believed to be in prison in Jordan. Id., ¶ 12 & n.2. In June 2019, Plaintiffs

filed a request for the issuance of letters rogatory requesting that Jordan serve the Amended

Complaint on Abu Tayeh in prison. ECF No. 14. That request was granted by the Court the

following month. ECF Nos. 17, 18. Shortly thereafter, the claims against Jordan were dismissed

with prejudice. See generally Moriarty v. Hashemite Kingdom of Jordan, No. 18-cv-2649, 2019

WL 3593169 (D.D.C. Aug. 6, 2019).

According to a representative of the Department of State, the letters rogatory were

delivered to Jordan via diplomatic channels in early September 2019. ECF No. 21 at 2. Thereafter,

believing they had located Abu Tayeh at Suwaqa Prison 2 in Jordan, Plaintiffs attempted to serve

him personally in the prison in October 2019 through a process server. Id. That attempt was

unsuccessful because the prison guards would neither permit the process server to serve an

2 In their current motion, Plaintiffs state that they do not know where or whether Abu Tayeh is presently incarcerated. ECF No. 48 at 3 (“While personal service is generally achievable in Jordan, the fact of Defendant Abu Tayeh’s incarceration, and the lack of information regarding the location of his incarceration, makes such personal service impossible.”); ECF No. 41-1, ¶ 9 (“[A] search of prison [facilities] was conducted, including Suwaga Prison . . . . Result: Could not confirm that Abu Tayeh was incarcerated in any of the prison facilities.”).

2 individual prisoner directly nor accept the service on Abu Tayeh’s behalf. Id. Because the attempt

was unsuccessful, Plaintiffs concluded their efforts to serve Defendant Abu Tayeh were

“constrained to the Letters Rogatory Process.” Id.

Twenty months later, in August 2021, Plaintiffs reported to the Court that an attorney at

the Department of State had been told that Abu Tayeh had been served by Jordanian authorities

but that Jordan’s formal response to the letters rogatory was delayed by the COVID-19 pandemic.

ECF No. 33 at 1–2. To date, Jordan’s formal response has yet to be received. 3 ECF Nos. 34, 35.

Thus, Plaintiffs concede that while “[i]t is likely that [Abu Tayeh] has received actual notice of

the lawsuit through the letters rogatory process, . . . with a lack of formal response from the

Jordanian authorities, this cannot be verified, and the case cannot proceed” on that basis. ECF No.

48 at 3–4. With other methods of service having proven unsuccessful, Plaintiffs sought leave to

effect service on Abu Tayeh by publication in June 2023. ECF Nos. 37–41.

In their initial motion, Plaintiffs requested to serve Abu Tayeh by publication through a

website entitled Global Legal Notices, LLC (“Global Legal Notices”). ECF No. 41 at 1. In the

first paragraph of the motion, Plaintiffs also stated that they would effect service through

publication of a legal notice in “one national newspaper of general circulation” in Jordan. ECF

No. 41 at 1. In arguing in favor of publication through Global Legal Notices, Plaintiffs relied on

3 That said, in June 2022, Plaintiffs received an email from the Department of State stating that the American Embassy in Amman had conveyed that “our only letters rogatory on file were received at the Embassy in August 2020, and per the Jordanian Ministry of Foreign Affairs, were delivered to [Abu Tayeh] on January 23, 2021.” ECF No. 36-1 at 2. Appended to that email was a July 26, 2021 letter, written in Arabic, which states, in relevant part, that “[t]he Ministry would like to inform you that the Embassy has been notified by [a] memorandum . . . dated 05/18/2021 regarding informing [Abu Tayeh] of the civil case filed against him on 01/23/2020 and that the delay in reply is due to the exceptional circumstances resulting from Covid-19 global pandemic.” ECF No. 36-2 at 3. Plaintiffs do not argue that any of those communications serve as formal notice of service of process by Jordanian authorities of Abu Tayeh. ECF No. 48 at 3 (Plaintiffs asserting that “service through the letters rogatory process has proven futile in the sense that Plaintiffs’ counsel has been unable to obtain actual and verifiable information from the Office of the Legal Adviser on the status of service of process, and attempts to obtain additional information from the U.S. Embassy in Amman, Jordan or the Jordanian Ministry of Foreign Affairs have proven unfruitful in obtaining the requisite formal notice of service.”); see also ECF No. 41 at 7 (describing how the letters rogatory process has “languished for four years”).

3 the declaration of Nelson Tucker, an experienced international process server, which asserted that

“newspapers in Jordan will not publish legal notices which originate in the United States.” ECF

No. 41 at 7 (quoting ECF No. 41-1, ¶ 15). Because of this discrepancy, the Court ordered Plaintiffs

to respond in writing to clarify whether they were in fact seeking service by publication through a

Jordanian newspaper. See Minute order (Aug. 28, 2023).

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