Case 2:19-ap-01383-SK Doc 99 Filed 04/01/20 Entered 04/01/20 … · 2020. 4. 7. · Case 2:19-ap-01383-SK Doc 99 Filed 04/01/20 Entered 04/01/20 11:47:25 Desc Main Document Page 2

OBJECTION TO TRUSTEE’S MOTION FOR ALTERNATE SERVICE

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Daniel T. Moss (pro hac vice) [email protected] David S. Torborg (pro hac vice) [email protected] JONES DAY 51 Louisiana Avenue, N.W. Washington, D.C. 20001-2113 Telephone: (202) 879-3939 Facsimile: (202) 626-1700 Joshua M. Mester (SBN 194783) [email protected] JONES DAY 555 South Flower Street Fiftieth Floor Los Angeles, CA 90071.2452 Telephone: (213) 489-3939 Facsimile: (213) 243-2539

Attorneys for Minsheng Financial Leasing Co., Ltd.

UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA

LOS ANGELES DIVISION

In re:

ZETTA JET USA, INC., a California corporation,

Debtor.

Lead Case No. 2:17-bk-21386-SK

(Jointly administered with 2:17-bk-21387-SK)

Chapter 7 Cases

Adv. Proc. No. 2:19-ap-01383-SK

In re:

ZETTA JET PTE LTD., a Singaporean corporation,

Debtor.

OBJECTION OF MINSHENG FINANCIAL LEASING CO., LTD. REGARDING MOTION FOR ALTERNATIVE SERVICE ON DEFENDANTS LI QI AND MINSHENG FINANCIAL LEASING CO., LTD. UNDER FED. R. CIV. P. 4(f)(3) AND 4(h)(2); OR, IN THE ALTERNATIVE, FOR A FINDING THAT LI QI HAS ALREADY BEEN SERVED UNDER FED. R. CIV. P. 4(f)(2)(A), OR FOR THE COURT TO DIRECT ITS CLERK TO FEDEX THE LI QI SERVICE PAPERS UNDER 4(f)(2)(C)(ii) Date: May 13, 2020 Time: 9:00 a.m. (PDT) Place: Courtroom 1575 255 East Temple Street Los Angeles, Ca 90012 Judge: Hon. Sandra R. Klein

JONATHAN D. KING, solely in his capacity as Chapter 7 Trustee of Zetta Jet USA, Inc. and Zetta Jet PTE, Ltd.,

Plaintiff,

v. YUNTIAN 3 LEASING COMPANY LIMITED DESIGNATED ACTIVITY COMPANY f/k/a YUNTIAN 3 LEASING COMPANY LIMITED, YUNTIAN 4

Case 2:19-ap-01383-SK Doc 99 Filed 04/01/20 Entered 04/01/20 11:47:25 DescMain Document Page 1 of 9

OBJECTION TO TRUSTEE’S MOTION FOR ALTERNATE SERVICE 2

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LEASING COMPANY DESIGNATED ACTIVITY COMPANY f/k/a YUNTIAN 4 LEASING COMPANY LIMITED, MINSHENG FINANCIAL LEASING CO., LTD., MINSHENG BUSINESS AVIATION LIMITED, EXPORT DEVELOPMENT CANADA, LI QI, UNIVERSAL LEADER INVESTMENT LIMITED, GLOVE ASSETS INVESTMENT LIMITED, and TRULY GREAT GLOBAL LIMITED,

Defendants.



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INTRODUCTION

The Court should deny the Trustee’s Motion for Alternative Service on Defendants Li Qi

and Minsheng Financial Leasing Co., Ltd. under Fed. R. Civ. P. 4(f)(3) and 4(h)(2); Or, in the

Alternative, For a Finding that Li Qi Has Already Been Served Under Fed. R. Civ. P. 4(f)(2)(a),

or For the Court to Direct its Clerk to FedEx the Li Qi Service Papers Under 4(f)(2)(c)(ii) (the

“Motion” or “Mot.”) for the simple reason that it is premature.

The Trustee rushed to file the Motion a mere one-and-a-half months and three-and-a-half

months after he says he served the Chinese Central Authority, the Ministry of Justice, with the

materials required to serve defendants Li Qi and Minsheng Financial Leasing Co., Ltd.

(“Minsheng Financial”), respectively, under the Hague Convention. The Motion was filed well

before the six-month period contemplated by the Hague Convention and the Federal Rules of

Civil Procedure (the “Federal Rules”) for motions seeking alternative methods of service. As

explained below, there are no extenuating or other circumstances that justify truncating the

timeframes to complete service contemplated by the Hague Convention and the Federal Rules.

Nor has the Trustee alleged or suggested that Minsheng Financial has taken any actions to

evade service of process. As explained herein, Minsheng Financial is acting consistent with

applicable laws, rules, and regulations promulgated by the Peoples Republic of China (“PRC” for

the sole purpose of this Objection, excluding the laws of the Hong Kong Special Administrative

Regions, Macau Special Administrative Regions and Taiwan) regarding service on PRC entities

in the PRC by foreign parties. Minsheng Financial’s adherence with applicable law cannot be

construed as evading the Trustee’s service efforts.

The real issues here are that Trustee is unsatisfied with the normal timeframe necessary to

effectuate service in the PRC under the Hague Convention and suggests, without basis, that a

signatory to the Hague Convention will not honor its commitment. The Trustee’s preferred

timing, however, is not sufficient justification for this Court to exercise discretion and authorize

the Trustee to effectuate service outside the Hague Convention.



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I. THE COURT SHOULD ALLOW SUFFICIENT TIME FOR THE DESIGNATED HAGUE CONVENTION PROCESS TO OCCUR.

The Trustee acknowledges that the Hague Convention and applicable PRC laws, rules,

and regulations are the proper means to effectuate service in the PRC. See Mot. at. 4. The “mere

fact that service of process abroad is ‘expensive and time consuming is generally not sufficient to

demonstrate that the facts and circumstances necessitate the district court’s intervention.’” Tart

Optical Enterprises, LLC v. Light Co., No. LACV1608061JAKMRWX, 2017 WL 5957728, at *6

(C.D. Cal. Sept. 27, 2017). “[S]ome measure of delay in litigating” a case similarly does not

warrant alternative service, especially where the requirements of the Hague Convention are in

place. Blue Underground Inc v. Caputo, No. CV 14-1343-GW(PJWX), 2014 WL 12573679, at

*4 (C.D. Cal. Sept. 8, 2014); compare U.S. Aviation Underwriters, Inc. v. Nabtesco Corp., No.

C07-1221RSL, 2007 WL 3012612, at *1–2 (W.D. Wash. Oct. 11, 2007) (alternative service

denied but court indicated that such service may be appropriate when there is a “failure of a

country’s Central Authority to effect service within the six-month period provided by the Hague

Convention”) with In re S. African Apartheid Litig., 643 F. Supp. 2d 423, 437 (S.D.N.Y. 2009)

(alternative service permitted when “over six years after plaintiffs transmitted the necessary

documents to the Central Authority” and service remained outstanding).

Both the Hague Convention and the Advisory Committee Notes to Federal Rule 4

contemplate that alternative methods of services may be appropriate if (1) six months or more

have passed since a plaintiff sent its letter of request to a foreign country’s Central Authority or

(2) in “cases of urgency” where “convention methods will not permit service within the time

required by the circumstances.” See Fed. R. Civ. P. 4, Notes of Advisory Committee on Rules—

1993 Amendment (“The Hague Convention does not specify a time within which a foreign

country’s Central Authority must effect service, but Article 15 does provide that alternate

methods may be used if a Central Authority does not respond within six months.”).

Here, the Trustee allegedly mailed the required documents to the Chinese Central

Authority on November 4, 2019 and January 15, 2020 for Minsheng Financial and Li Qi,

respectively. See Mot. at 5, 7. The Trustee filed the Motion on February 24, 2020, two-and-a-



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half and four-and-a-half months prior to the presumptive six-month period contemplated by the

Hague Convention and the Federal Rules. The Trustee identifies no extenuating circumstances

requiring alternative service prior to that time period nor provides any evidence that the PRC will

not honor its obligations as a signatory to the Hague Convention.

Courts in this Circuit have recognized that “the Hague Convention exists for a reason,”

Blue Underground Inc., 2014 WL 12573679, at *4, and have, accordingly, denied motions for

alternative service when, as here, the plaintiff has failed to explain why awaiting service under the

Hague Convention is not feasible. See, e.g., Ulysses GmbH & Co. KG v. UlyssesWindows.com,

No. 2:18-CV-00202-RAJ, 2019 WL 3413211, at *3 (W.D. Wash. July 29, 2019) (denying motion

for alternative service upon Chinese and Brazilian individuals and finding allegations that service

under international protocols can be “problematic” and “fruitless” to be “insufficient to justify

alternative service under Rule 4(f)(3)”; rather, the plaintiff must “demonstrate that the facts and

circumstances of the present case necessitate[] the district court’s intervention”) (internal citation

and quotation omitted); Keck v. Alibaba.com, Inc., 330 F.R.D. 255, 259 (N.D. Cal. 2018)

(denying motion for alternative service upon Chinese individual, noting that a “plaintiff’s request

to use Rule 4(f)(3) because ‘it will be much faster … by itself is not sufficient justification for the

Court to authorize service by alternative method.’”) (internal citations and quotations omitted);

U.S. Aviation Underwriters, Inc. 2007 WL 3012612, at *2 (denying motion for alternative service

upon Japanese corporation, reasoning that the “requirements for due process and respect for

international law outweigh plaintiffs desire to proceed expeditiously….”). The Court should do

the same here because there is no evidence that the Trustee’s service actually has been delayed.1

Alternatively, Minsheng Financial respectfully suggests that the Court should reserve

1 Notwithstanding the Trustee’s thinly supported contentions that “[s]ervice of process on defendants is nearly impossible without a court’s intervention,” Mot. at 1, in the experience of Minsheng Financial’s PRC Counsel, Xin Wu of Zhong Lun Law Firm, service on a PRC entity through the Ministry of Justice typically takes 6 to 12 months. Declaration of Xin Wu, attached hereto as Exhibit A (“Wu Dec.”) at ¶ 9. Further, based on publicly available data from 2013 (the most recent data located) the PRC, out of a total of 1,943 requests for service, executed approximately 1,017 (or 52%) requests for service in less than six months, 263 (or 13%) in six to twelve months, and (a mere) 40 (or about 2%) took more than 12 months to execute. See Response of China to Questionnaire of November 2013 relating to the Hague Convention, at 6, https://assets.hcch.net/upload/wop/2014/2014sc_14cn.pdf (last visited March 30, 2020).



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ruling on the Motion until after it rules on the fully-briefed motions to dismiss that are scheduled

for oral argument on July 22, 2020. The Court’s rulings on those motions will materially impact

the course of the Trustee’s complaint against Minsheng Financial and Li Qi (given the overlap of

key issues, such as the extraterritorial application of the Bankruptcy Code to foreign entities and

the sufficiency of the Trustee’s allegations to support his legal claims). Requiring that Minsheng

Financial and Li Qi respond to the Complaint before the Court rules on the pending motions to

dismiss would be a waste of party and judicial resources.

II. MINSHENG FINANCIAL HAS NOT EVADED SERVICE OF PROCESS.

Under Rule 4(f)(3), a court analyzes the “particularities and necessities of a given case” to

determine whether alternative service of process is appropriate. Tart Optical Enterprises, 2017

WL 5957728, at *6 (quoting Rio Properties, Inc. v. Rio Int'l Interlink, 284 F.3d 1007, 1016 (9th

Cir. 2002)). Further, the Court must take an approach that “minimized offense to foreign law”

when exercising discretion based upon the particularities and necessities of the case. Moldex

Metric, Inc. v. Swedsafe AB, No. CV 18-3502-JFW(AGRX), 2018 WL 6137578, at *2 (C.D. Cal.

June 1, 2018) (quoting 1993 Advisory Committee Notes, subdivision (f)). Here, the Trustee

relies upon cases authorizing alternative service where the foreign defendant was deliberately

evading service or was difficult to locate. See, e.g., Rio Properties, Inc. v. Rio Int'l Interlink, 284

F.3d 1007, 1016 (9th Cir. 2002) (“Rio needed only to demonstrate that the facts and

circumstances of the present case necessitated the district court’s intervention. Thus, when RIO

presented the district court with its inability to serve an elusive international defendant, striving to

evade service of process, the district court properly exercised its discretionary powers to craft

alternative means of service.”).2 Some courts in the Ninth Circuit have held that the Trustee’s

line of authority is limited to cases where the defendant is purposefully evading service. See, e.g.,

2 See also de Leon v. Abudawood, No. 818CV01030JLSJDE, 2018 WL 6321632, at *4 (C.D.

Cal. Oct. 23, 2018); E.L.V.H. Inc. v. Bennett, No. 218CV00710ODWPLA, 2018 WL 6131947, at *2 (C.D. Cal. May 2, 2018); Toyo Tire & Rubber Co. v. CIA Wheel Grp., No. 15-0246-DOC (DFMX), 2016 WL 1251008, at *3 (C.D. Cal. Mar. 25, 2016); Brown v. China Integrated Energy, Inc., 285 F.R.D. 560, 562 (C.D. Cal. 2012); Williams-Sonoma Inc. v. Friendfinder Inc., No. C06-06572 JSW, 2007 WL 1140639, at *2 (N.D. Cal. Apr. 17, 2007); In re Barkats, No. 14-00053, 2014 WL 4437483, at *2 (Bankr. D.D.C. Sept. 8, 2014); Lexmark Int'l, Inc. v. Ink Techs. Printer Supplies, LLC, 291 F.R.D. 172, 175 (S.D. Ohio 2013).



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Fujitsu Ltd. v. Belkin Int’l, Inc., 782 F. Supp. 2d 868, 879–81 (N.D. Cal. 2011) (finding that “the

facts at issue in Rio Properties d[id] not support Fujitsu’s request for court ordered service” upon

U.S. counsel because Fujitsu did “not present[] any facts to suggest that D-Link Corp. and

ZyXEL Corp. are evading service”).

Here, there is no basis to suggest (nor is there even an assertion by the Trustee) that

Minsheng Financial is deliberately evading service or is difficult to locate. The Trustee concedes

that Minsheng Financial and Li Qi “had the right to refuse to waive service.” Mot. at 10. The

PRC has a process for parties to effectuate service in accordance with the Hague Convention. In

particular, Article 277 of the PRC Civil Procedure Law requires that “judicial assistance shall be

carried out via the channels stipulated in the international treaty concluded or participated by the

People's Republic of China.” Wu Dec. at ¶ 7 and Schedule 2. The PRC Civil Procedure Law

further states that “[e]xcept for [those prescribed in an international treaty or through diplomatic

channels], no foreign agency or individual shall carry out service of documents [on the defendant]

in the People's Republic of China without the consent by the relevant administrative authorities of

the People's Republic of China.” Id. Further, an official notice jointly released by the People’s

Supreme Court of China, the Ministry of Foreign Affairs, and the Ministry of Justice reinforces

the fact that the only prescribed means through which service can be effected is through the

Ministry of Justice. Wu Dec. at ¶ 7 and Schedule 3. There is no other process sanctioned under

the Hague Convention or PRC law.

Minsheng Financial’s right to not waive service and its expectation that the Trustee would

comply with PRC law and the Hague Convention cannot serve as evidence that Minsheng

Financial is somehow evading service such that this Court should exercise discretion and grant

the Motion. See, e.g., Fujitsu Ltd., 782 F. Supp. 2d at 880.

III. JONES DAY CANNOT AND SHOULD NOT BE VIEWED AS THE DOMESTIC SERVICE AGENT FOR FOREIGN DEFENDANTS.

Jones Day is not authorized to accept service on behalf of Minsheng Financial.3 Further,

Jones Day cannot and should not be viewed as the domestic service agent for foreign defendants,

3 In any event, Rule 4(f)(3) cannot provide the Trustee with the relief he seeks with respect to



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particularly where such defendants are not purposefully evading or thwarting service efforts. See

Fujitsu Ltd., 782 F. Supp. at 881 (“Thus, because the circumstances of Rio Properties . . . are not

present here, the Court finds it inappropriate to order service on D–Link Corp. and ZyXEL Corp.

through their U.S. counsel.”). As such, allowing the Trustee to serve Minsheng Financial through

Jones Day would be improper and unwarranted.4

IV. RESERVATION OF RIGHTS

Should the Court grant the Motion, Minsheng Financial intends to fully participate in this

case and assert all available defenses in response to the Trustee’s Complaint, including, but not

limited to, improper and insufficient service of process under the Hague Convention and lack of

personal jurisdiction,5 failure to plausibly state a claim for relief, and the defenses set forth in the

Yuntian Entities’ and Minsheng Business’ motions to dismiss. See Dkt. Nos. 32 & 44. Minsheng

Financial also intends to raise the issue that any judgment rendered against it by this Court would

be unenforceable under PRC law.6 Accordingly, nothing stated herein constitutes, or shall be

deemed to waive (1) Minsheng Financial’s rights to have final orders in any non-core matters

entered only after de novo review by a U.S. District Court, (2) Minsheng Financial’s rights to trial

by jury in any proceeding so triable in these cases or any case, controversy, or proceeding related

thereto, (3) Minsheng Financial’s rights to have the U.S. District Court withdraw the reference in

any matter subject to mandatory or discretionary withdrawal, (4) Minsheng Financial’s consent to service upon an attorney at Jones Day in Washington, D.C. The plain text of Rule 4(f) provides for service executed in a foreign country, not within the United States.

4 Principals of comity for signatories to the Hague Convention also suggest denying the Motion: just as U.S. courts would expect foreign courts to adhere to the strictures of the Hague Convention for serving U.S. citizens in the United States where such citizens are parties to litigation in foreign courts, here too this Court should not facilitate the Trustee’s attempt to bypass the Hague Convention by means not proscribed by the Hague Convention. Countenancing the Trustee’s Motion may serve as evidence in foreign court proceedings that it is acceptable to ignore the Hague Convention and deem service on such U.S. citizens satisfied by means that are not permitted under U.S. law.

5 Other than as required to file this Objection in the above-captioned adversary proceeding, Minsheng Financial has not filed a notice of appearance or any pleadings in this case or the underlying chapter 7 cases and has not filed a proof of claim.

6 See, e.g., Fed. R. Civ. P. 4, 1993 Advisory Committee Notes, subd. (i)(1) (“The enforcement of a judgment in the foreign country in which the service was made may be embarrassed or prevented if the service did not comport with the law of that country.”)



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the jurisdiction of the U.S. Bankruptcy Court for the Central District of California with respect to

any proceeding commenced in these cases against or otherwise involving Minsheng Financial, (5)

Minsheng Financial’s rights or jurisdictional defenses under the U.S. Bankruptcy Code, the laws

of the People’s Republic of China, or any other applicable law, or (6) Minsheng Financial’s

rights, claims, actions, defenses, setoffs, or recoupments, as appropriate, to which Minsheng

Financial is or may be entitled, either in law or in equity, under any agreements; all of which

rights, consents, claims, actions, defenses, setoffs, and recoupments are hereby expressly

reserved.

Dated: April 1, 2020 JONES DAY _/s/ Daniel T. Moss_________ Daniel T. Moss (pro hac vice) [email protected] David S. Torborg (pro hac vice) [email protected] JONES DAY 51 Louisiana Avenue, N.W. Washington, D.C. 20001-2113 Telephone: (202) 879-3939 Facsimile: (202) 626-1700 Joshua M. Mester (SBN 194783) [email protected] JONES DAY 555 South Flower Street Fiftieth Floor Los Angeles, CA 90071.2452 Telephone: (213) 489-3939 Facsimile: (213) 243-2539


EXHIBIT A

Case 2:19-ap-01383-SK Doc 99-1 Filed 04/01/20 Entered 04/01/20 11:47:25 DescExhibit A Page 1 of 16
















This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California.

June 2012 F 9013-3.1.PROOF.SERVICE

PROOF OF SERVICE OF DOCUMENT I am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business address is:

JONES DAY, 901 Lakeside Avenue, Cleveland, Ohio 44114 A true and correct copy of the foregoing document entitled (specify): OBJECTION OF MINSHENG FINANCIAL LEASING CO., LTD. REGARDING MOTION FOR ALTERNATIVE SERVICE ON DEFENDANTS LI QI AND MINSHENG FINANCIAL LEASING CO., LTD. UNDER FED. R. CIV. P. 4(f)(3) AND 4(h)(2); OR, IN THE ALTERNATIVE, FOR A FINDING THAT LI QI HAS ALREADY BEEN SERVED UNDER FED. R. CIV. P. 4(f)(2)(A), OR FOR THE COURT TO DIRECT ITS CLERK TO FEDEX THE LI QI SERVICE PAPERS UNDER 4(f)(2)(C)(ii) will be served or was served (a) on the judge in chambers in the form and manner required by LBR 5005-2(d); and (b) in the manner stated below: 1. TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF): Pursuant to controlling General Orders and LBR, the foregoing document will be served by the court via NEF and hyperlink to the document. On (date) April 1, 2020, I checked the CM/ECF docket for this bankruptcy case or adversary proceeding and determined that the following persons are on the Electronic Mail Notice List to receive NEF transmission at the email addresses stated below: [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] Service information continued on attached page 2. SERVED BY UNITED STATES MAIL: On April 1, 2020, I served the following persons and/or entities at the last known addresses in this bankruptcy case or adversary proceeding by placing a true and correct copy thereof in a sealed envelope in the United States mail, first class, postage prepaid, and addressed as follows. Listing the judge here constitutes a declaration that mailing to the judge will be completed no later than 24 hours after the document is filed. Service information continued on attached page 3. SERVED BY PERSONAL DELIVERY, OVERNIGHT MAIL, FACSIMILE TRANSMISSION OR EMAIL (state method for each person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling LBR, on April 1, 2020, I served the following persons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing to such service method), by facsimile transmission and/or email as follows. Listing the judge here constitutes a declaration that personal delivery on, or overnight mail to, the judge will be completed no later than 24 hours after the document is filed. Service information continued on attached page I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. 04/01/2020 Monika T. Barrios /s/ Monika T. Barrios Date Printed Name Signature

Case 2:19-ap-01383-SK Doc 99-2 Filed 04/01/20 Entered 04/01/20 11:47:25 Desc Proof of Service Page 1 of 2

This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California.

June 2012 F 9013-3.1.PROOF.SERVICE

2. SERVED BY UNITED STATES MAIL: Ron Maroko Office of the United States Trustee 915 Wilshire Boulevard, Suite 1850 Los Angeles, California 90017 Minsheng Financial Leasing Co., Ltd. Haidian District, Beijing Zhongguancun South Street Beijing Friendship Hotel Guest House 1 2-6 010-68489378 Li Qi c/o Tiffany M. Ikeda, Esq. Arnold & Porter Kaye Scholer LLP 777 South Figueroa Street 44th Floor Los Angeles, CA 90017-5844 3. SERVED BY EMAIL [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] SERVED BY OVERNIGHT MAIL Honorable Sandra R. Klein United States Bankruptcy Court Central District of California Edward R. Roybal Federal Building and U.S. Courthouse 255 East Temple Street Los Angeles, CA 90012

Case 2:19-ap-01383-SK Doc 99-2 Filed 04/01/20 Entered 04/01/20 11:47:25 Desc Proof of Service Page 2 of 2

Documents

Case 2:19-ap-01383-SK Doc 99 Filed 04/01/20 Entered 04/01/20 … · 2020. 4. 7. · Case 2:19-ap-01383-SK Doc 99 Filed 04/01/20 Entered 04/01/20 11:47:25 Desc Main Document Page 2