A California court of appeal recently agreed with federal district courts that the Inter-American Convention On Letters Rogatory “does not authorize the issuance of a letter rogatory that has as its purpose the enforcement of a money judgment.” Landstar Global Logistics, Inc. v. Robinson & Robinson, Inc., No. D060829, (May 16, 2013). The Convention authorizes letters rogatory to aid in “[t]he performance of procedural tasks of a merely formal nature, such as service of process, summonses or subpoenas abroad,” but not “acts involving measures of compulsion.” The court found that efforts to enforce a judgment involve “measures of compulsion” because they seek “to alter the judgment debtor’s substantive rights by depriving it of money or other property sufficient to satisfy the judgment.” Thus, the trial court should not have issued a letter rogatory to request that the Mexican authorities register judgment liens Landstar had obtained against Robinson and Robinson, with the purpose of ensuring that Landstar would receive the proceeds of the sale of certain real property located in Mexico.