The Hague Evidence Convention: Practice in the Netherlands

1989 ◽  
Vol 2 (2) ◽  
pp. 155-166
Author(s):  
Eric P. A. Keyzer ◽  
Marion Th. Nijhuis
Keyword(s):  
United States ◽  
The Netherlands ◽  
Supreme Court ◽  
International Law ◽  
The United States ◽  
European Countries ◽  
Private International Law ◽  
Differences Of Opinion ◽  
The Subject ◽  
The Hague

The Hague Evidence Convention – officially the Convention On the Taking of Evidence Abroad in Civil or Commercial Matters – was realized in 1970 by The Hague Conference for Private International Law. The Convention gave rise to several differences of opinion between Europe and the United States. The European countries and the United States, in particular, disagree about the (optional or obligatory) character of the convention-procedures. This article will, among other things, deal with the consequences to be expected in The Netherlands of a recent American Supreme Court judgement on this issue: The Aérospatiale case1. The subject will be treated in five sections: 1.The Hague Evidence Convention; 2.The Netherlands and The Hague Evidence Convention; 3.Consequences of the Aérospatiale-case for The Netherlands; 4.Consequences of the Aérospatiale-case for Dutch parties involved in litigation in the UnitedStates; 5.Aérospatiale and conclusion.

scholarly journals PRIVATE INTERNATIONAL LAW IN BRAZIL: A BRIEF OVERVIEW

2018 ◽  
Vol 1 (1) ◽  
pp. 11-37
Author(s):  
Carmen Tiburcio
Keyword(s):  
United States ◽  
International Law ◽  
The United States ◽  
Private International Law ◽  
The Status ◽  
Rules And Principles ◽  
The Subject

The paper is intended to provide an overview of Private International Law in Brazil. With this purpose, it presents in broad lines the subject matters of the discipline, undertaking, whenever possible, comparisons with the contours given to it in the United States. In sum, the text deals with the acquisition of Brazilian nationality, the status of aliens, the determination of the applicable legislation to legal relationships with international connections – which includes the exam of Brazilian connecting rules and principles of Private International Law – and the exercise of Brazilian jurisdiction.

Should Great Britain and the United States be Represented at the Hague Conferences on Private International Law

1913 ◽  
Vol 7 (4) ◽  
pp. 774-780
Author(s):  
Arthur K. Kuhn
Keyword(s):  
United States ◽  
Great Britain ◽  
International Law ◽  
The United States ◽  
Private International Law ◽  
British Government ◽  
The Hague

At the Antwerp meeting of the International Law Association in 1903, a paper was presented by Mr. Justice Phillimore indicating the desirability of having Great Britain participate in the Hague Conferences on Private International Law. At the same meeting, a resolution was adopted on the motion of Mr. Justice Kennedy to the effect that the Association “should take steps respectfully to lay before the British Government the points dealt with in that paper” with a view to its participation in the conferences. Although not referring in terms to America, the resolution was seconded by Dr. Gregory, an American member, and the discussion showed plainly that it was the sense of the meeting that the resolution was intended to apply also to the United States.

Foreign Relations and the Judiciary

2002 ◽  
Vol 51 (3) ◽  
pp. 485-510 ◽  
Author(s):  
Lawrence Collins
Keyword(s):  
United States ◽  
International Law ◽  
Foreign Relations ◽  
The United States ◽  
Company Law ◽  
Private International Law ◽  
Public International Law ◽  
International Lawyer ◽  
The Subject ◽  
The Relationship

It is not generally appreciated that Francis Mann was not an international lawyer at all by training. His thesis at Berlin University was in company law. It was only after he had been in England for some time that he began to write about private international law,1 and his interest in public international law was developed as a result of his friendship with Sir Hersch Lauterpacht. It was not until 1943 that he published anything about public international law, and in that year he published a substantial article in two parts on the relationship between national law and international law, in which he built on the previous work on Judicial Aspects of Foreign Relations by Louis Jaffe2 and on acts of state by Sir William Holdsworth.3 Subsequently he came to make this subject his own, at least in England,4 where the subject has never attracted the attention which it has attracted in the United States.5

scholarly journals PRIVATE INTERNATIONAL LAW IN BRAZIL: A BRIEF OVERVIEW

2018 ◽  
Vol 1 (1) ◽  
pp. 11-37
Author(s):  
Carmen Tiburcio
Keyword(s):  
United States ◽  
International Law ◽  
The United States ◽  
Private International Law ◽  
The Status ◽  
Rules And Principles ◽  
The Subject

The paper is intended to provide an overview of Private International Law in Brazil. With this purpose, it presents in broad lines the subject matters of the discipline, undertaking, whenever possible, comparisons with the contours given to it in the United States. In sum, the text deals with the acquisition of Brazilian nationality, the status of aliens, the determination of the applicable legislation to legal relationships with international connections – which includes the exam of Brazilian connecting rules and principles of Private International Law – and the exercise of Brazilian jurisdiction.

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