NOTHING BUT A PIECE OF A PAPER? MEHMET TATLICI’S 740 MILLION DOLLARS U.S. JUDGMENT IN THE LIGHT OF NON-ENFORCEMENT GROUNDS

The case is Tatlici v. Tatlici . [1]

The lawsuit began in 2018 when Mehmet Tatlici, the older son of the deceased Mehmet Salih Tatlici, filed a lawsuit against his step-brother, Ugur Tatlici, alleging that his step-brother published various articles about him on some websites that are also allegedly established and created by the step-brother for the alleged damages concerning a real estate development project that was said to take place in Turkey. [2]

Delving into more details, one would first see this as a case between two Turkish step-brothers. It concerns the allegation of damages related to a real estate development project in Turkey based on certain statements on some websites that are also said to be established in Turkey. One would then naturally expect this case to be heard by the Turkish courts, which is in line with the bedrock principle that the place of tort is where the harm to the plaintiff occurred. [3]

However, this was not the case with Tatlici v. Tatlici .

Mehmet Tatlici brought the lawsuit against his step-brother in the state courts of Florida, which apparently has no personal jurisdiction over Ugur Tatlici, as expressed by the defense lawyers. [4] Further, the 740 million dollars judgment was entered when Ugur Tatlici was absent because he was not notified when the lawsuit was initiated and tried, and he actually became aware of the action for the first time after the judgment was already entered, according to the same legal team. [5]

Cases like Tatlici v. Tatlici illustrate the ways in which legal disputes can become the subject of intense legal debate and how they can raise important questions around personal jurisdiction, due process, proper ways to serve a defendant, and U.S. courts' exorbitant jurisdiction.

Personal jurisdiction is the cornerstone of any legal system, and it ensures that defendants, especially foreign ones, are not subject to the whims of local courts without sufficient contacts with the jurisdiction. [6] If the court asserts power over a defendant with only tenuous contact with the forum, then the issue of exorbitant jurisdiction arises, raising questions in relation to due process protections enshrined in almost every country's constitution. [7]

What is more interesting in Tatlici v. Tatlici is the fraud allegations that Ugur Tatlici seems not to had the chance to argue. In such a case, one would naturally wonder how the allegations of fraud, and thus the violations of due process and public policy, would factor into the enforcement proceedings of the 740 million dollars judgment in jurisdictions other than the United States and especially in civil law countries, including Turkey.

With these questions in mind, this article will analyze the complex issues around the personal jurisdiction and service of process and then examine the grounds for non-enforcement in light of the fact and legal arguments discussed within the ambit of Tatlici v. Tatlici.

A. Forum Shopping: One Possible Reason for Tatlici v. Tatlici to be heard by the U.S. Courts:

Forum shopping is a legal strategy used by plaintiffs to choose the most favorable court or jurisdiction for their claim. [8] In other words, forum shopping is to prefer one particular court or jurisdiction over the other because the preferred jurisdiction is more favorable to the litigant's case than other available options.

Is forum shopping illegal? It is not. However, it is often viewed as a manipulative strategy and thus discouraged because it undermines the fairness and impartiality of the legal system, thereby leading to possible due process violations. [9] Courts and legislators in different jurisdictions have taken steps to prevent forum shopping, in other words, limiting a plaintiff's ability to choose a particular jurisdiction that has a reputation for being more sympathetic to the plaintiff's case over the others. [10]

The lawsuit between Apple and Samsung over patent infringement can be an example of one of the famous lawsuits concerning forum shopping. It all started when Apple filed a lawsuit against Samsung in the United States, alleging that Samsung infringed on Apple's intellectual property rights. [11] Samsung countersued Apple in Seoul, South Korea, Japan, and Germany, claiming that Apple had infringed on its own patents. [12]

The legal battle between the companies, with both filing lawsuits in multiple countries, is perhaps the most well-known example of forum shopping because both Apple and Samsung filed lawsuits in the countries where they believed they would have the best chance of winning.

Turning back to the Tatlici brothers, it is no surprise that Mehmet Tatlici brought a lawsuit against Ugur Tatlici in the United States, even though all the elements in the case are heavily related to Turkey and its laws.

U.S. courts are subject to forum shopping for several reasons, but the most important reason for plaintiffs to bring a tort claim in the United States is perhaps the existence of a jury. [13] Ugur Tatlici, who appears to have inherited most of his father's estate, was ordered to pay 740 million dollars to his brother, Mehmet Tatlici, the inheritance share of whom is reduced to the minimum under Turkish law. [14] It is then no surprise that the U.S. jury would sympathize with Mehmet Tatlici, who plans to present himself to them as someone facing off against Ugur Tatlici, the heir with the most shares. Such David vs. Goliath dynamic could be one of the main reasons for Mehmet Tatlici to file this lawsuit in Florida rather than Turkey so that, as a plaintiff, he can elicit sympathy from the jury and make them more likely to side with him.

Another related factor that may make Florida a more friendly forum for his case against Ugur Tatlici is the fact that jury members are human beings, and they can be affected by emotions when making decisions. This is especially true when there is no defendant present to share his side of the story, as this was the case with Ugur Tatlici . [15] As such, sympathizing with the older step-brother whose share from the inheritance was reduced, a jury may feel a strong emotional connection to Mehmet Tatlici and reflect bias rather than a rational assessment of his losses.

One may ponder that once the case was filed in Florida in 2018, Ugur Tatlici could have objected to this lawsuit being filed in Florida courts. He could have filed a motion to dismiss on the grounds of forum non conveniens and sought to stop Mehmet Tatlici from attempting to circumvent the legal process, arguing that Florida is an improper forum because the location of the parties and the location where the alleged tort occurred all points to Turkey.

But how a party who has no idea about a lawsuit filed against him can object to the lawsuit and allege that the case was filed in an improper forum?

The court docket, specifically the filings for the defendant, reveal that this was what happened to Ugur Tatlici. Thus, the next logical step is to consider the service of the lawsuit.

B. Service of Process

Service of process is crucial in any action. It provides notice to the defendant of the pending lawsuit or legal action, giving them an opportunity to respond and defend themselves. [16] Proper notification of the lawsuit ensures that individuals are informed of legal actions brought against them. [17]

One of the main issues in Tatlici v. Tatlici was whether there was a proper notification of the lawsuit, or in other words, whether Ugur Tatlici was informed of the lawsuit brought against him in the courts of Florida. [18] "Service of process abroad" or "international service of process" involves serving legal documents, such as a complaint or summons, to a defendant who is located outside of the country where the lawsuit is filed. International service of process can be achieved in many ways, such as through letters rogatory, or consulates. [19] However, it is typically governed by the Convention on the Service Abroad of Judicial and Extrajudicial Documents in Civil or Commercial Matters ("Hague Service Convention"), which sets forth rules and procedures for serving documents to other Contracting parties. [20]

The Hague Service Convention is an international treaty that provides a framework for the service of judicial and extrajudicial documents between member countries. One of the primary methods of service of process under the Hague Service Convention is through the use of Central Authorities. [21]

A Central Authority is a designated office or agency within each member country that is responsible for receiving and transmitting requests for service of process. Under the Convention, the plaintiff in a lawsuit prepares a request for service of process complying with the requirements of the Hague Service Convention and submits it to the Central Authority in their own country. The Central Authority then forwards the request to the Central Authority in the recipient country. The Hague Service Convention sets out very specific procedures and timelines for the transmission and execution of requests for service of process through Central Authorities. These procedures may include requirements for translation of the documents or the use of particular forms or methods of transmission, all with the aim of creating a standardized and reliable process for effecting international service of process. [22]

Since both the United States and Turkey are parties to the Hague Service Convention for more than 50 years, service of a Florida lawsuit should be achieved under the Hague Service Convention. Moreover, under Article 10 of the Hague Service Convention, Turkey declared that the service of judicial and extrajudicial documents might not be made through postal channels directly to the addressee but must be made through the Central Authority of the state in which the documents originate. [23] Accordingly, Mehmet Tatlici should have served the Florida lawsuit on Ugur Tatlici by sending the documents to the designated central authority of Turkey, who will then arrange for service on Ugur Tatlici in accordance with the laws of that country, i.e ., Turkish Notification Law no. 7201. [24] It appears, however, from the record that Mehmet Tatlici rather resorted to substitute service of process under the local rules of Florida law on the grounds that he “does not know” Ugur Tatlici's address for service and that the Hague Service Convention is inapplicable. [25]

Note that the 14 years of inheritance fight between the step brothers and other heirs has been named "Turkey's biggest inheritance fight," which means that Mehmet Tatlici has been serving Ugur Tatlici here in Turkey numerous times at his address, which was told to be “unknown” in the Florida proceedings. [26]

The case gets particularly interesting because one of Mehmet Tatlici's lawyers, Jeremy D. Friedman, brought a personal legal action against Ugur Tatlici in the courts of Florida by resorting to the Hague Service Convention and obtaining successful service on Ugur Tatlici, as per the filings made with the Florida court. [27]

Florida trial court's decision of finding the Hague Service Convention inapplicable shows that state courts as opposed to Federal courts may lack the necessary expertise and resources to effectively handle international legal issues and thus may not be the ideal venue for handling legal issues involving multiple jurisdictions.

Another argument by Mehmet Tatlici's lawyer was that Ugur Tatlici was aware of the lawsuit when it was filed. This argument raises the question of whether the actual knowledge of a lawsuit cures insufficient service of process.

The Florida state court entered a non-final judgment against Ugur Tatlici and found that actual knowledge would cure the improper service of process. According to the trial court, not resorting to the Hague Service Convention or failing to complete the necessary steps for the service of process under Florida local law does not matter. This decision of the trial court is highly doubtful given that there is a clear and binding precedent that simply being aware of a lawsuit does not rectify a lack of proper service of process. [28] In fact, the Fourth District Court of Appeal of Florida, which handles appeals from the trial court that entered the judgment against Ugur Tatlici, decided on a case very recently, establishing once more that actual knowledge of the existence of the action against the defendant has no bearing on the question of whether the service was successful. [29]

If the service of process is not properly executed, then the court may not have jurisdiction over the defendant, and the case may be dismissed. As such, the Florida trial court appears to have erred in dismissing Mehmet Tatlici's claim based on the lack of service of process from the beginning. It is notable that Mehmet Tatlici alleged other grounds to establish Florida courts' jurisdiction over Ugur Tatlici, of which the next section will examine whether they are properly established.

C. Personal Jurisdiction

By definition, personal jurisdiction refers to a given court's authority to hear and decide a case involving a particular individual. [30] In principle, the defendant must have sufficient contacts with the state or jurisdiction in which the court is located in order for a court to exercise its power, in other words, its personal jurisdiction, over a defendant. [31] For example, if a defendant is physically present or is domiciled in the state or jurisdiction in which the court is located, the court generally has personal jurisdiction over the defendant. Another common ground for personal jurisdiction is the defendant's minimum contact with the jurisdiction in which the court is located, such as conducting business within the state.

In looking at Tatlici v. Tatlici , the trial court found that it has jurisdiction over Ugur Tatlici even though the last date of Ugur Tatlici's physical presence in Florida was 15 years ago and even though Ugur Tatlici did not conduct business in Florida for a long time. [32] The U.S. courts are notorious for a broad reach beyond their borders, in legal terms, exercising exorbitant jurisdiction. [33] In this context, the term "exorbitant jurisdiction" refers to the ability of U.S. courts to assert jurisdiction over a defendant who has no meaningful connection with the United States. This jurisdiction is often criticized as being excessive or overly broad, and can lead to conflicts with other countries' legal systems, especially countries with the civil law system. [34]

Exorbitant personal jurisdiction is problematic for numerous reasons. One of the most concerning reasons is that exorbitant personal jurisdiction is likely to be unfair to defendants, thus raising questions in terms of fairness and due process. Defendants like Ugur Tatlici may be required to defend themselves in a foreign country where they have no significant contacts. Ultimately, this can be expensive, time-consuming, and inconvenient. When a court exercises jurisdiction over a defendant who has no meaningful connection with the forum state, it can deprive the defendant of his right to fair notice and an opportunity to be heard in a court of law.

In Tatlici v. Tatlici , the Florida trial court's exercising jurisdiction over Ugur Tatlici appears to be exorbitant because of the insufficient contacts of Ugur Tatlici with the state of Florida. If a defendant commits a tort within a state, it may be possible to establish personal jurisdiction over the defendant based on the fact that the defendant's actions caused harm within the state. However, the court docket does not establish that Ugur Tatlici committed a tort in Florida because the lawsuit filed by Mehmet Tatlici, a Turkish citizen, against Ugur Tatlici, another Turkish citizen, concerns the statements allegedly published in the websites established in Turkey and damages affecting an alleged project said to take place in Turkey.

Exorbitant personal jurisdiction can lead to unfair and inefficient outcomes in the legal system, and there have been efforts to limit its use in recent years. [35] Accordingly, if this judgment is attempted to be enforced outside the United States, this is one of the main red flags for the judgment's enforceability, together with the grounds that will be explored in detail next.

D. Ground for non-enforcement: Is the 740-million-dollar judgment nothing but a piece of paper?

A monetary award in hand is meaningless without enforcement, rendering it a mere piece of paper since the judgment itself does not actually provide the plaintiff with any funds. As any creditor would know, enforcement actions can be time-consuming and costly since there is no guarantee that the plaintiff will be able to recover the amount owed.

Non-enforcement grounds for foreign judgments refer to situations where a court may refuse to enforce a judgment obtained in a foreign country. While the 740-million-dollar judgment represents a legal victory for Mehmet Tatlici, it may not provide him with any actual compensation due to the grounds for non-enforcement of this judgment, such as fraud in obtaining judgment, lack of jurisdiction, violation of due process, and violation of public policy.

a. Fraud in Obtaining the Judgment

The recognition and enforcement of foreign judgments are generally governed by the laws of the country where the enforcement is sought. [36] Not surprisingly, fraud is considered to be a fundamental defect that can be ground for non-enforcement of the judgment. As such, the party seeking enforcement may need to prove that the judgment was obtained fairly and without any deception.

One of the issues in Tatlici v. Tatlici is the allegations of fraud, which seems Ugur Tatlici did not have the chance to pursue yet because he did not want to submit himself to the Florida court's personal jurisdiction. However, certain filings and the information obtained from the legal team representing him indicate that Ugur Tatlici has a strong fraud claim against his step-brother Mehmet Tatlici, thus creating an important hurdle for the enforcement of the 740-million-dollar judgment outside of Florida. Based on the assessment of the legal team, Ugur Tatlici possesses a compelling case of fraud that his lawyers intend to pursue as either a defense in the United States or independent civil and criminal actions against Mehmet Tatlici in various jurisdictions.

The fraud allegations stem from the Investment Agreement allegedly executed between Monolit Construct Division SRL, a Romanian Company, and Tatlici Gayrimenkul, Mehmet Tatlici's Turkish company, together with Mehmet Tatlici himself. What Mehmet Tatlici alleged during the trial in the absence of his step-brother was that the Romanian company terminated the Investment Agreement due to these alleged defamatory websites after three different exchanges of letters, and he incurred damages because the Project got canceled. [37]

According to Ugur Tatlici's lawyers, not only the Investment Agreement and the purported real-estate project subject to it but also the letters themselves is fraudulent and fabricated. Ugur Tatlici's fraud claim against his step-brother Mehmet Tatlici can be discussed under three legs:

The first leg of the fraud committed upon the court concerns certain websites where the alleged defamatory news was reportedly published. Together with the Investment Agreement, Mehmet Tatlici is understood to have presented three letters of correspondence that allegedly took place between him and the Romanian Company. [38] One of these letters particularly claims the spotlight because the Romanian company allegedly terminated the Investment Agreement through this one-page letter upon encountering some defamatory statements about Mehmet Tatlici on three different websites. These are the websites and news that Mehmet Tatlici alleges they are created and published by his step-brother to injure his business practices.

However, the Florida I.T. expert report establishes that two out of the three websites that were referred to in this letter did not exist at the time when this letter was allegedly signed. [39]

The plot thickens for the remaining third website referred to in this letter terminating the alleged Investment Agreement. Accordingly, the same I.T. expert's report establishes that the domain name of this remaining website was not even registered until fifteen months later from the letter. [40]

Taking a leaf from Don Quixote's fighting against imaginary enemies and tilting at windmills, the letters between Mehmet Tatlici and the Romanian company appear to refer to imaginary websites and news that were not even brought into existence at the date of the letter in order to terminate the alleged real-estate business project.

The court docket provides no filings about how Mehmet Tatlici answered these fraud allegations backed by I.T. expert findings. He may eventually face these findings in the enforcement proceedings once Ugur Tatlici relieves himself of the Florida courts' exorbitant jurisdiction over him and find a possible forum to raise his fraud claims. Until then, it seems like these uncontested technical findings will cause problems or difficulties for Mehmet Tatlici in the foreign enforcement proceedings.

These claims can also be raised in a whole different set of civil and criminal actions by Ugur Tatlici in other jurisdictions, as the claims of fraud against Mehmet Tatlici was told to be serious and deserving of significant compensation and penalty. Thus, it is a matter of great interest as to the method and location in which Ugur Tatlici will proceed with the allegations of fraud against his step-brother, and whether these fraud claims would result in a record-breaking judgment, too.

Other expert findings come from the alleged real-estate project part, which is told to be the second leg of the fraud allegedly committed by Mehmet Tatlici. [41]

The beginning of a worrisome pattern starts with a deeper look at the Romanian company, Monolit Construct Division SRL and the other companies engaged in the project. Upon initial analysis of the records and the statements of the lawyers, it seems that offshore shell companies were used to conceal the true owner of the Romanian companies, and there were also certain documents submitted as evidence that contained names and signatures of individuals who were confirmed to be fictitious. There are claims that even the signatures of deceased individuals were used in specific transactions that were notarized, which raises serious concerns about the validity and legality of such transactions.

Even if one assumes that despite the unusual structures of the Romanian investor, the question of how the purported real estate project would take place in Istanbul's Sisli district begs an answer. This is because the Project was and is reported to be legally and technically not possible to realize under the framework of the existing development and zoning plans. [42] Further expert findings show that the said real estate project was mostly situated in public lands such as roads and green areas, and there were no preliminary real estate sales agreements or real estate sale contracts for the ownership of the vast number of private properties in the alleged Project site, where the approval of all parties involved in these private properties was required.

Many questions remain unanswered as to how the ownership of the private properties in the Project area would be acquired from hundreds of different owners, as it was revealed that neither Mehmet Tatlici nor his company had or have had the ownership of the immovables in the Project area.

Another point concerns the feasibility studies. One would expect that Mehmet Tatlici and/or the purported Romanian Investor would carry out technical and legal due diligence assessments for this multi-million-dollar Project and ultimately find out that the Project is not possible to be developed under the zoning plans.

To give Mehmet Tatlici his due, he indeed obtained an appraisal report when the defamation action was pending in 2019. [43] But again, the Investment Agreement presented by Mehmet Tatlici to the Florida court was dated 2013. This then raises the question of why no other site investigation reports/feasibility study for the Project was done until it became necessary for Mehmet Tatlici to prove his alleged damages in Florida in 2019.

The fraud claims of Ugur Tatlici heat up when the Investment Agreement executed for the real-estate project is closely examined.

What captures the most attention is the choice of court clause in the agreement. Parties seemed to have agreed that a Federal or State court located in Bucharest, Romania will govern the dispute, only to find out later that there are no "states" or "state courts" in the Country of Romania, unlike the United States. [44] This bodes well with one of the serious allegations that Mehmet Tatlici's Florida lawyer participated in the fraud by allegedly fabricating the Investment Agreement because he assumed Romania has state and federal jurisdiction distinctions like the United States, as stipulated in the Agreement.

Among other peculiarities in the Investment Agreement's provisions, what is most notable is the existence of a moral clause. In canceling the real-estate Project, the Romanian company refers to this clause on the grounds of bad press about Mehmet Tatlici. Such clauses are often found in contracts between companies and celebrities, and other public figures in order to secure termination of the contract or legal action in case the public figure engages in immoral or unethical action damaging to his or her reputation. According to Ugur Tatlici's lawyer, this sneaky moral clause is carefully crafted and slipped into the Investment Agreement so that the fabricated real-estate project and Agreement itself can be terminated on this ground and the jury's sympathies in Mehmet Tatlici’s favor can be secured, leading the way for Mehmet Tatlici's allegedly suffered damages and compensation.

These are some of the arguments and defenses Ugur Tatlici's lawyers unearthed in building a what appears to be a comprehensive fraud claim against Mehmet Tatlici and against the enforcement proceedings in case Mehmet Tatlici would attempt to enforce the judgment outside Florida, despite its shortcomings.

This article limits itself with the legal aspects of the fraud claims although Tatlici’s lawyers stated that several significant issues have arisen, including the possibility that Mehmet Tatlici and certain bureaucrats may be connected to said offshore shell companies that have not yet been traced back to their Ultimate Beneficial Owners (UBOs). However, the allegation that politics and bureaucrats may have played a role in these companies mentioned in the Investment Agreement as a means of concealing their own interests or illicit activities gives the impression that what has been revealed is merely the tip of the iceberg.

b. Florida Court's Lack of Personal Jurisdiction and Violations of Due Process

As a textbook rule, if a foreign judgment was obtained without giving the defendant adequate notice of the legal proceeding, or if the defendant was not given a fair opportunity to argue in his defense, then the defendant's due process rights may have been violated.

As explained above, here in Tatlici v. Tatlici, not only the improper notice of the lawsuit against the international treaties (the Hague Service Convention) but also the lack of personal jurisdiction itself will likely be found as a due process violation.

c. Violations of Public Policy

If a judgment violates the fundamental principles of justice or morality of the state where the enforcement is sought, then it is generally accepted that the violation of public policy ground for the non-enforcement is justified. For example, if a foreign judgment violates the fundamental rights of the parties involved, such as the judgment being based on fraud, corruption, or other illegal activities, its enforcement may be denied on the grounds of public policy. Potentially, a due process violation can lead to a public policy violation because the right to a fair and impartial hearing is considered a fundamental principle of justice in most modern legal systems.

The case of Tatlici v. Tatlici seems to be a cocktail of possible non-enforcement grounds that can also be raised as a violation of public policy. The Florida court's exorbitant jurisdiction, the lack of proper notice, the default judgment entered in the absence of Ugur Tatlici, leaving him without the opportunity to be heard, and fraud claims fall under the violation of public policy ground and allowing the enforcement of the Florida courts' judgment could be seen as contrary to the basic principles of justice and fairness, and the enforcement may be denied on the grounds of public policy.

E. CONCLUSION

Tatlici v. Tatlici has the potential to be a casebook example.

It shows why and how enforcing U.S. judgments abroad, especially in civil law countries, including Turkey, can be challenging for a few reasons. Although a U.S. jury may have found such a judgment is just, given the due process violations and fraud claims, neither appellate courts nor the foreign enforcing courts would easily uphold or enforce the Florida court's judgment. It was critical for Mehmet Tatlici to ensure that all procedural requirements are met to make sure that any resulting judgment would be enforceable both domestically and internationally.

Because the case is currently pending the appellate court's review, Mehmet Tatlici may not seek the enforcement of the judgment yet. But, when he can, the judgment will likely face numerous essential grounds for non-enforcement, creating another debate topic for legal scholars and lawyers.

Av. Doğukan AŞAR

--------------

[1] Mehmet Tatlici v. Ugur Tatlici (50-2018-CA-002361-XXXX-MB), Palm Beach, Florida (“ Tatlici v. Tatlici ”)

[2] D.E. 11, 26, 105 and 329 Tatlici v. Tatlici

[3] See, for example, Article 4(1) of the Rome II Regulation (Regulation (EC) No 864/2007 of the European Parliament and of the Council of 11 July 2007 on the law applicable to non-contractual obligations

[4] D.E. 48 Tatlici v. Tatlici

[5] D.E. 48 and 329 Tatlici v. Tatlici

[6] See International Shoe Co. v. Washington, 326 U.S. 310 (1945); Venetian Salami Co. v. Parthenais, 554 So.2d 499, 502 (Fla. 1989); Internet Solutions Corp. v. Marshall, 39 So.3d 1201, 1207 (Fla. 2010)

[7] Kevin M. Clermont & John R. Palmer, Exorbitant Jurisdiction , 58 Me. L. Rev. 473 (2006).

[8] Faruk Kerem Giray, “Forum Shopping-Forum Non Conveniens Kavramları ile Anti-suit Injunction Kararlarının Türk Milletlerarası Usul Hukukundaki Görünümleri”, in Gürler, Sercan (ed.) Adalete Yönelmiş Bir Toplumsal Düzen Olarak Hukuk: Prof. Dr. Yasemin Işıktaç Armağanı, Sümer Kitabevi, 869-890 (2020).

[9] Markus Petsche, What's Wrong with Forum Shopping - An Attempt to Identify and Assess the Real Issues of a Controversial Practice, 45 Int'l L. 1005 (2011)

[10] Mary Garvey Algero, In Defense of Forum Shopping: A Realistic Look at Selecting a Venue, 78 Neb. L. Rev. (1999)

[11] Apple Inc. v. Samsung Elecs. Co. - 786 F.3d 983 (Fed. Cir. 2015)

[12] Hani Albasoos & Nabil Al Musallami, The conflict between Apple and Samsung over patents and copyrights , Bussecon Review of Social Sciences, Bussecon International Academy, vol. 2(3), pages 1-17, (2020).

[13] See Algero, In Defense of Forum Shopping, p.102.

[14] D.E. 105 Tatlici v. Tatlici

[15] Narina Nunez et al., The Impact of Emotions on Juror Judgments and Decision-Making in Brian H. Bornstein & Monica K. Miller (eds), Advances in Psychology and Law, vol 2. Springer (2016).

[16] Kermit L. Hall, Legal Services, Provision Of, in The Oxford Companion to American Law (2nd ed.). Oxford University Press.

[17] Legal Services, Provision Of , in The Oxford Companion to American Law

[18] D.E. 48 and 105 Tatlici v. Tatlici

[19] Ahmet Cemal Ruhi, Milletlerarasi Usul Hukukunda Tebligat, Oniki Levha Yayınları, 2019.

[20] Ali Gümrah Toker, 15 Kasım 1965 Tarihli “Hukukî Veya Ticarî Konularda Adlî Ve Gayri Adlî Belgelerin Yabancı Memleketlerde Tebliğine Dair Lahey Sözleşmesi” Uyarınca Tebligat Yapılması, Dokuz Eylül Üniversitesi Hukuk Fakültesi Dergisi Cilt: 13, Sayı: 2, s.107-152 (2013)

[21] Ali Gümrah Toker, 15 Kasım 1965 Tarihli “Hukukî Veya Ticarî Konularda Adlî Ve Gayri Adlî Belgelerin Yabancı Memleketlerde Tebliğine Dair Lahey Sözleşmesi” Uyarınca Tebligat Yapılması, p.109.

[22] T.C. Adalet Bakanlığı, Uluslararası Hukuk ve Dış İlişkiler Genel Müdürlüğünün 16.11.2011 Tarihli B.03.0.UİG.0.00.00.06/010.06.02/1-3 Sayılı, “Hukukî Alanda Uluslararası Adli Tebligat İşlemleri” Konulu, 63/3 No’lu Genelge

[23] See Water Splash, Inc. v. Menon , 137 S.Ct. 1504, 1510 (2017).

[24] See Ghazarian v. Republic of Turkey , 2020 WL 3643483 (C.D. Cal. March 30, 2020)

[25] D.E. 259 Tatlici v. Tatlici

[26] Although it was not discussed in the case, the dirty hands doctrine could have been invoked, which establishes that a party who acts improperly or unethically in a matter from seeking relief in court can be barred from the court's protection. Accordingly, Mehmet Tatlici, who successfully serves Ugur Tatlici in Turkey, could have been barred by the Florida courts from arguing that he cannot serve to Ugur Tatlici on the same address, or that Ugur Tatlici’s address for service of judicial document is unknown.

[27] D.E. 267 Tatlici v. Tatlici

[28] E.g., Moss v. Estate of Hudson by and through Hudson, 252 So.3d 785, 787 (Fla. 5th DCA 2018), citing McDaniel v. FirstBank P.R., 96 So.3d 926, 929 (Fla. 2d DCA 2012) (citing Napoleon B. Broward Drainage Dist. v. Certain Lands Upon Which Taxes Due, 160 Fla. 120, 33 So.2d 716, 718 (Fla. 1948))

[29] Quisenberry v. Bates, 2023 WL 1425292, ____ So.3d ____ (Fla. 4th DCA 2023)

[30] Personal Jurisdiction , Black's Law Dictionary (11th ed. 2019).

[31] Venetian Salami Co. v. Parthenais , 554 So.2d 499, 502 (Fla. 1989); Internet Solutions Corp. v. Marshall , 39 So.3d 1201, 1207 (Fla. 2010)

[32] D.E. 301 Tatlici v. Tatlici

[33] See generally Berger-Walliser, Gerlinde, Reconciling Transnational Jurisdiction: A Comparative Approach to Personal Jurisdiction Over Foreign Corporate Defendants in US Courts (November 31, 2018). Vanderbilt Journal of Transnational Law, Vol. 51, No. 5, 2018, University of Connecticut School of Business Research Paper No. 19-09.

[34] See Alex Mills, Exorbitant Jurisdiction and the Common Law , in Jonathan Harris, and Campbell McLachlan (eds), Essays in International Litigation for Lord Collins (Oxford, 2022; online edn, Oxford Academic, 20 Oct. 2022)

[35] Giuditta Cordero Moss, Between Private and Public International Law: Exorbitant Jurisdiction as Illustrated by the Yukos Case, Review of Central and East European Law 32, 1 (2007)

[36] E.g., Volker Behr, Enforcement of United States Money Judgments in Germany, 13 J.L. & COM. 211, 222 (1994)

[37] D.E. 183, 184 and 185 Tatlici v. Tatlici

[38] D.E. 183, 184 and 185 Tatlici v. Tatlici

[39] D.E. 110 Tatlici v. Tatlici

[40] D.E. 110 Tatlici v. Tatlici

[41] See Appraisal Report dated June 21, 2021 (on file with author)

[42] Appraisal Report dated June 21, 2021

[43] D.E. 110 Tatlici v. Tatlici

[44] D.E. 105 Tatlici v. Tatlici

NOTHING BUT A PIECE OF A PAPER? MEHMET TATLICI’S 740 MILLION DOLLARS U.S. JUDGMENT IN THE LIGHT OF NON-ENFORCEMENT GROUNDS

Hukuk Devleti Sosyal Teorisi (Social Theory of The Rule of Law)

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