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Vol 23 No 5 May/June 2018

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Cover of Drafting Commercial Agreements

Drafting Commercial Agreements

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Anglo-American Perspectives on Private International Law

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ISBN13: 9780773467378
ISBN: 0773467378
Published: October 2003
Publisher: The Edwin Mellen Press Ltd
Country of Publication: UK
Format: Hardback
Price: £109.95

Despatched in 14 to 16 days.

This monograph examines conflict of laws in the areas of family law, tort jurisdiction, choice of laws, and recognition and enforcement of foreign judgments. It provides an account of the common themes, related jurisprudence, and theoretical underpinnings that have guided Anglo-American traditions.

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Marriage capacity - essential validity of marriage - the application of interest analysis and depecage to Anglo-American choice of law rules; divorce and financial provision - transnational non-judicial divorces - a comparative analysis of recognition and financial relief under English and US jurisprudence; forum non conveniens - to be or not to be - the forum non conveniens performance acted out on Anglo-American courtroom states; tort jurisdiction - multistate tort jurisdiction - a comparative analysis of prevailing jurisprudence in the United States and the European Union; choice of law in tort - the Anglo-American revolution in tort choices of law principles - paradigm shift or Pandora's box?; recognition and enforcement of foreign judgments - a new model of jurisdictional propriety for Anglo-American foreign judgment recognition and enforcement - something old, something borrowed, something new?.