Defendant's Motion to Set Aside Default Judgment - Center for ...

person, property, or risk, contract, obligation, or agreement located, executed, or to be performedwithin the District of Columbia or anywhere else in the United States. Lumintang Dec. at 1 8. Hehas never engaged in a persistent course of conduct, or any course of conduct for that matter, in theDistrict of Columbia or anywhere else in the United States or derived revenue from goods orservices used, consumed or rendered in the District of Columbia or anywhere else in the UnitedStates. J.g.Lt. Gen. Lumintang is not and has never been a resident of the District of Columbia, oranywhere else in the United States for that matter, and he has not engaged in any of the activitiesenumerated in the District of Columbia long-arm statute.Therefore, the Court does not havepersonal jurisdiction over him. Nevertheless, even if the literal terms of the long-arm statute couldbe satisfied, it still must be established that the exercise of personal jurisdiction over the LieutenantGeneral is within the permissible bounds of the Due Process Clause of the U.S. Constitution. QIENew Media Service Inc., 199 F.3d at 1347.10 This cannot be shown.2.The "Minimum Contacts" StandardIn order to satisfy the Constitutional due process standards for personal jurisdiction, it mustbe established that there were "minimum contacts" between the defendantt Lt. Gen. Lumintangt andthe forum, the District of Columbia, establishing that "the maintenance of the suit does not offendthe traditional notions of fair play and substantial justice." GTE New Media Service Inc., 199 F .3dat 1347, Quoting, International Shoe Co. v. Washin2ton, 326 U.S. 310,316 (194S)(internal quotation10 Additionally, because the District of Columbia long-arm statute reaches as far asthe Due Process Clause of the U.S. Constitution, personal jurisdiction would be satisfied if theCourt's exercise of jurisdiction complied with Constitutional due process.14