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Case of the Day: National Asset Loan Management v. McCann

The case of the day is National Asset Loan Management, Ltd. v. McCann (Pa. Super. Ct. 2015). NALM sued John McCann in the Irish High Court. McCann resided in Northern Ireland, so NALM sought to serve him with process via the Northern Ireland courts. When that failed, he obtained an order from the Irish courts for substituted service on McCann’s solicitors in Ireland. After NALM effected the substituted service, McCann appeared in the Irish action and moved to set aside the order for substituted service. The court denied the motion, and McCann then defaulted. The High Court entered a default judgment. McCann moved to set the default judgment aside, but the High Court denied the motion; McCann’s appeal in Ireland is still pending. NALM then sought recognition of the judgment in the Court of Common Pleas in Philadelphia. The court recognized the judgment, and McCann appealed, arguing that the judgment should not have been recognized because the Irish court had lacked personal jurisdiction over him. (There were some other issues, too, which I am not going to cover).
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Case of the Day: Standard Chartered Bank v. Ahmad Hamad Al Gosaibi & Bros.

Update (10/9/14): I think Greg Shill’s new post about this case may require a rethink on my part, so check back in!

The case of the day is Standard Chartered Bank v. Ahmad Hamad Al Gosaibi & Bros. (Pa. Super. Ct. 2014). Friend of Letters Blogatory Greg Shill brought it to my attention—thanks, Greg! I have written about the case three times before, once in connection with an action in New York for recognition and enforcement of a Bahraini judgment, and twice in connection with § 1782 proceedings. Today’s case was an action for recognition and enforcement of the New York judgment in Pennsylvania. So the case raises some of the issues Greg wrote about in his article on judgment arbitrage.
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Case of the Day: Louis Dreyfus Commodities Suisse v. Financial Software Systems

The case of the day is Louis Dreyfus Commodities Suisse S.A. v. Financial Software Systems, Inc. (Pa. 2014). Dreyfus had obtained a judgment in the English High Court for $717,733.12 for breach of contract against FSS. It sought to collect in Pennsylvania, though as we shall see it made an elementary mistake.
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