Is “running away” a legally sound strategy? If so, Rudy Giuliani is killing it.

The disgraced former-New York City mayor had a 2020 to remember: he got punk’d by Borat, black goo leaked from his scalp, farted during a public hearing, and his client, Donald Trump, lost the presidential election. His 2021 isn’t going much better, however. Giuliani is being sued by Dominion Voting Systems for $1.3 billion for spreading misinformation, “and apparently they had a heck of a time serving him with papers,” as host Jimmy Kimmel said during Tuesday’s episode of Jimmy Kimmel Live! He’s referring to a New York Daily News report about how “after not responding to requests to waive service, Mr. Giuliani evaded in-person service of process for nearly a week,” an attorney for Dominion told the newspaper. “It took numerous attempts, at both his home and office, before we were able to successfully serve Mr. Giuliani” earlier this month.