Thomas Watret

Latham & Watkins LLP

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What Rules Will Apply to Jurisdiction and the Enforcement of Judgments After Brexit? Part Five

Will the UK join the Lugano Convention 2007? Conflicting reports have emerged in recent days as to whether the EU will approve the UK’s application to join the Lugano Convention 2007, the UK’s preferred regime for...more

4/15/2021 / Court of Justice of the European Union (CJEU) , Enforcement of Foreign Judgments , EU , European Commission , European Economic Area (EEA) , Foreign Judgments , Jurisdiction , Member State , UK , UK Brexit

What Rules Will Apply to Jurisdiction and the Enforcement of Judgments After Brexit? Part Two

Four recent developments highlight the benefit of arbitration clauses amidst uncertainty about choice of court clauses. Introduction - With the end of the Brexit transition period on 31 December 2020 fast approaching,...more

10/12/2020 / Arbitration , Contract Disputes , Cross-Border Transactions , Enforcement , Foreign Judgments , Mandatory Arbitration Clauses , Member State , UK , UK Brexit

Enforcement of Foreign Judgments 2021

Is your country party to any bilateral or multilateral treaties for the reciprocal recognition and enforcement of foreign judgments? What (in general terms) is the country’s approach to entering into these treaties and what...more

9/18/2020 / Arbitration , Arbitration Agreements , Arbitration Awards , Foreign Judgments , Hague Convention , International Arbitration , Jurisdiction , Personal Jurisdiction

English Commercial Court: Foreign Judgment Did Not Establish Issue Estoppel

Parties may struggle to establish issue estoppel based on a foreign judgment, even when they agreed exclusive jurisdiction of English courts. MAD Atelier International BV v. Manès [2020] EWHC 1014 (Comm) considers key...more

6/1/2020 / Commercial Court , Estoppel , Foreign Judgments , UK

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