WARMBIER v. DEMOCRATIC PEOPLE’S REPUBLIC OF KOREA Cite as 356 F.Supp.3d 30 (D.D.C. 2018) ing that [Otto] had not contracted botulism while in North Korea that would have caused respiratory failure.’’ Id. ¶ 18. That Otto would die from this brain injury was also reasonably foreseeable. According to Mr. Hawk, North Korea released Otto ‘‘just before he would have died in detention,’’ H’rg Tr. (Rough) at 98 (Expert David Hawk), deciding it ‘‘needed to get him out of the country before he [died] in detention, which would be harder for [North Korea] to explain,’’ id. at 104. With respect to the second element, North Korea deliberately caused Otto’s brain damage, which resulted in his death. North Korea’s torture methods ‘‘pose a substantial danger to human life,’’ and North Korea ‘‘routinely withholds medical care from those in its custody, with such frequency that it amounts to an intentional act.’’ Hawk Expert Decl. ¶ 40; see also id. ¶ 25 (explaining denial of food rations and imposition of hard labor are also ‘‘common’’ intentional acts resulting in death); Kanter Decl. ¶ 15 (‘‘Because the [brain] injury was so extensive, it was unlikely that [Otto] was with medical personnel who were willing and able to intervene to resuscitate him when the injury occurred.’’). The expert’s conclusions are ‘‘more than sufficient’’ evidence that North Korea deliberately caused Otto’s death. Kim, 774 F.3d at 1050; see also id. at 1051. Moreover, the fact that North Korea continued to detain Otto in this severely compromised condition for over a year, rather than send him home earlier to obtain medical care, compounds the deliberate nature of that totalitarian state’s brutal treatment of Otto. See F.W. Decl. ¶ 12. Finally, as for the third element, Otto’s death was not authorized by a ‘‘regularly constituted court affording all the judicial guarantees which are recognized as indispensable by civilized peoples.’’ 28 U.S.C. § 1350 (note). The North Korean criminal 53 judgment against Otto was illegitimate because North Korea does not have an independent judiciary, fabricated Otto’s ‘‘confession,’’ and put on a ‘‘show trial.’’ H’rg Tr. (Rough) at 100–01 (Expert David Hawk); Collins Expert Decl. ¶ 14 (‘‘[T]he judiciary and prosecutors are thus highly controlled by the same entity that controls all other party and state apparatuses.’’); id. ¶ 27 (concluding Otto’s ‘‘speech at the press conference purporting to confess to the alleged crime was most likely dictated to him in advance and the product of torture’’). Further, even if North Korea’s judiciary were legitimate, Otto’s sentence authorized 15 years of hard labor, not death. Hatch. Decl., Ex. E (KCNA Article on Otto’s ‘‘Trial,’’ titled ‘‘American Student Sentenced to 15 Years of Hard Labor in DPRK’’). B. Personal Jurisdiction To impose judgment on a foreign state under the FSIA, this Court must have personal jurisdiction. Personal jurisdiction over North Korea, as a foreign state, depends on whether ‘‘service has been made under section 1608 of this title.’’ 28 U.S.C. § 1330(b) (defining limits of personal jurisdiction over foreign states). Service may be effected under 28 U.S.C. § 1608 in one of four ways: (1) by ‘‘special arrangement for service between the plaintiff and the foreign state,’’ (2) ‘‘in accordance with an applicable international convention on service of judicial documents,’’ or, if the first two options are not applicable, (3) by ‘‘sending a copy of the summons and complaint and a notice of suit, together with a translation of each into the official language of the foreign state, by any form of mail requiring a signed receipt, to be addressed and dispatched by the clerk of the court to the head of the ministry of foreign affairs of the foreign state concerned,’’ or, if service cannot be made under the third option, (4) by requesting the Clerk of the

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