In Roda Golf & Beach Resort (Area of Freedom, Security & Justice) [2009] EUECJ C-14/08, the Advocate General of the European Court of Justice has issued an Opinion on the meaning of "extrajudicial documents" in Council Regulation (EC) No 1348/2000 on the service in member states of judicial and extrajudicial documents (the 2000 Service Regulation).

In the view of Advocate General Ruiz-Jarabo Colomer of the ECJ, the definition of extrajudicial documents includes not only those documents on the case file, but extends to those documents which are required to be served regardless of whether proceedings have been commenced. The Advocate General gave further detailed guidance, concluding that it is for national courts to determine whether a particular document is an extrajudicial document in light of the requirements he identified.