Question juridique clé
Whether the federal complaint was filed within the statutory time limit
Solution extraite
No; the complaint period began on 2008-11-15 and ended on 2008-12-15, so the filing on 2009-01-14 was late.
Motifs extraits
The challenged judgment was deemed served on 2008-11-14 under Art. 44 para. 2 BGG because the appellant had to expect service while his own case was pending.