Patricia, a New York citizen, was injured while on a guided…
Patricia, a New York citizen, was injured while on a guided tour during her vacation in Hawaii when a car lost control and collided with her Segway. Once home in New York, she filed a lawsuit in New York State court against the driver of the car (a citizen of Hawaii) alleging that the driver was negligent in his operation of the vehicle. Patricia hired a local process server to serve the summons and complaint on the driver at his home in Hawaii. If you represented the driver, which of the following motions to dismiss would most likely be successful?