|
|
 |
|
Viewing report
|
|
|
|
The Correlation between Personal Jurisdiction and
Foreign Judgments. Edition No. 1
VDM Publishing House, Sep 2008, Pages: 284
This work discusses the correlation between the
assumption of personal jurisdiction over non-resident
defendants (when the defendant has not appeared
before the court, has challenged its jurisdiction or
has not expressly submitted to such jurisdiction) and
the enforcement of foreign judgments in the three
North American countries.
Canada, the United States and Mexico offer a very
interesting legal microcosm.
Canada is a Constitutional Monarchy while the U.S.
and Mexico are Presidential Republics. All of them
are federal States, but federalism works quite
differently in each one of them.
Mexico’s legal system belongs to the Romano-Germanic
Tradition; but most of the U.S. and Canada belong to
the tradition of the Common Law.
However, there are provinces on both the US and
Canada where the Common Law and the Civil Law have
to harmoniously coexist and interact with each
other.
Focusing on the correlation between personal
jurisdiction and the enforcement of foreign judgments
this work probes on the many lessons that may be
learned from this interaction in terms of legal
paradigms, approach, concepts, structures,
procedures, and actual everyday practice of law.
|
|
|
|
