The lesson here is that regardless of the size or procedural status of a legal claim for money, any money judgment based on bad service is attackable. In this case (anonymity requested), our client was being sued for an alleged debt that arose in another country. Without proper notice, she was sued in that foreign country, so she consequently defaulted.
The plaintiff then attempted to turn that foreign judgment into an enforceble one here in New York.
That plan failed when the plaintiff failed to carry out proper service (delivery of the summons and complaint). The plaintiff's attorneys represented on its summons that venue (proper court) was based on our client's "actual place of employment." That representation was false and possibly subjected the plaintiff's attorneys to Fair Debt Collection Practices Act ("FDCPA") liability for misrepresenting a material statement of law while possibly committing another FDCPA violation for suing our client in the wrong state.
New York State allows a lawsuit to take place in a county where at least one party resides, or in a county where the parties contractually agree, neither of which were present here.
Aside from the venue defect here, the action against our client was defective because she was not served properly under the law. Here, the plaintiff alleges to have served her at a New York branch of a large corporation when in fact she had no connection to that branch -- she worked (and lived) in New Jersey.
Under certain circumstances, a defendant may be served legal papers (summons and complaint) at his or her "actual place of business." New York courts construe "actual place of business" to include a place where a defendant regularly transacts business, or an establishment that the defendant owns or operates. In this case, the plaintiff could not meet either definition so its case (and its large judgment) were vulnerable to challenge from the outset.