Letters Blogatory

The Blog of International Judicial Assistance | By Ted Folkman of Folkman LLC

Posts tagged “conflict of laws

Interesting Issue of the Day: Recognition of Remote Civil Marriages In Israel

Posted on January 25, 2021

The Forward and friend of Letters Blogatory Eugene Volokh have both written about an interesting case before the Israeli Supreme Court. In Israel, which kept the old Ottoman laws on personal status after independence, all marriages must be contracted in a religious ceremony; there is no civil marriage. This law makes it impossible for some Jews to marry in Israel, for example, because the Chief Rabbinate does not recognize one of the spouses as Jewish. Many Israelis in this situation have gone to Cyprus to have a civil marriage, and under ordinary rules of private international law Israeli courts do recognize such marriages as valid (because they were valid where contracted). But COVID travel restrictions have made that avenue difficult. Enter Utah, which allows…

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Case of the Day: Germaninvestments AG v. Allomet Corp.

Posted on June 10, 2019

The case of the day is Germaninvestments AG v. Allomet Corp. (Del. Ch. 2019). Allomet is a Delaware corporation in the business of manufacturing metal powders for coating industrial products. Fobio Enterprises, Ltd., a Hong Kong company, owned the majority of Allomet’s shares. In 2016, it became the sole owner by purchasing shares from the Estate of Richard Toth. Fobio’s beneficial owner was Hannjörg Hereth, a Swiss national. Allomet was facing financial difficulties. In 2017, it had a debt of more than $40 million to Fobio and more than $20 million in net operating loss carryforwards. Hereth met with Richard Herrling, a German national residing in Switzerland, about the possibility of forming a joint venture to raise capital for Allomet. (Germaninvestments, one of the…

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