I chose the case of the day, Starski v. Kirzhnev (D. Mass. 2011), because it involves an area of international judicial cooperation we haven’t yet considered, namely, proof of the authenticity of a foreign official document so that it can be admitted in evidence in US proceedings. Vietnam owed a debt to Russia. Starski had connections in the Vietnamese government, and Kirzhnev had contracts in the Russian government. Starski’s claim was that he had a contract with Kirzhnev under which Kirzhnev was to use his contacts to facilitate a debt-swap transaction between the two countries. Upon the occurrence of the transaction, Kirzhnev was to pay Starski a commission. The transaction went through, but Starski alleged that Kirzhnev never paid. He sued him for breach…

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