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- Tyneside jeweller failed to disclose US assets, joint trustees say| Sequor Law
A Florida court grants emergency Chapter 15 relief to Grant Thornton trustees after UK jeweller Darren McCormick failed to disclose his US property portfolio in his British bankruptcy. Tyneside jeweller failed to disclose US assets, joint trustees say Open In the News Open November 20, 2019 2 minutes read Sequor Law A Florida court has recognised a British jeweller’s bankruptcy after his joint trustees Grant Thornton found he had lied about his US property portfolio before an English court. In an order on 15 November Judge Catherine McEwen , at the US Bankruptcy Court for the Middle District of Florida, granted emergency relief to Grant Thornton partner Nicholas Wood and director Colin Diss , who were appointed as joint trustees of Darren McCormick in May this year. McCormick is a jewellery distributor based in Newcastle-upon-Tyne, a city in the UK’s north-east England region. He is the director and shareholder of locally incorporated company Darren McCormick Jewellery. Hong Kong-based watch company Zero Time Product Design International filed for a petition for McCormick’s bankruptcy in December 2018, after he failed to pay a debt he owed to them. McCormick failed to appear at the bankruptcy hearing and in April 2019 District Judge Michelle Temple, in the County Court of Newcastle-upon-Tyne, declared him bankrupt. The court appointed Diss and Wood the following month. In their petition before the Florida court the trustees said McCormick had transferred £83,000 (US$107,000) from two UK pension funds to his US bank account in Florida in January. In a signed declaration before the Newcastle court in July, McCormick said the withdrawals from the pension funds were, “to fund a dental cosmetic treatment and cell injection therapy” he had been receiving in the US and denied owning property in the US. But an investigation by the joint trustees found that he in fact owns a property in Rockwood, Tennessee, and had recently owned two in St Petersburg, Florida. One of the properties McCormick had owned in Florida, which he claimed he sold for US$236,000, had in fact been sold for US$255,000. It found he had sold the second to DMJ Trading, a Florida company he owned, for US$10. Diss told the court the third property was valued at US$349,600. The joint trustees deduced that McCormick had lied about his US property assets to thwart their ability to realise his US assets. Based on these findings the joint trustees said “we know that the Debtor’s sworn declaration, stating that he owned no property in the United States, is false”. In March, after McCormick learned that bankruptcy proceedings were pending against him, he transferred ownership of his primary residence in Newcastle to his ex-wife, although he continued to live in the property rent-free with her permission. McCormick then transferred £14,000 (US$18,000) from his US bank account to another one of his creditors American Express. Diss told the court he had later transferred his controlling interest in two companies to a third party “for no apparent consideration”. He said that following Chapter 15 recognition he expected to be able to identify additional assets belonging to McCormick in the US. In the US Bankruptcy Court Middle District of Florida Tampa Division In Darren Bernard McCormick [Case 8:19-bk-10768-CPM] Counsel to Foreign Representative Sequor Law Shareholder Leyza B. Florin in Miami Joint trustees and foreign representatives Grant Thornton Director of asset and recovery team Colin Diss and partner Nicholas Wood in London County Court at Newcastle Upon Tyne District Judge Michelle Temple To view the original article, click here. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..
- Leyza Florin Blanco Makes D&I North America Shortlist| Sequor Law
Sequor Law Shareholder Leyza B. Florin is named a finalist at the Chambers Diversity & Inclusion Awards: North America 2022, honoring her dedication to advancing D&I in the legal field. Leyza Florin Blanco Makes D&I North America Shortlist Open Awards & Recognition Open April 13, 2022 1 minute read Sequor Law We are delighted to announce Sequor Law Shareholder, Leyza B. Florin as a finalist at the Chambers Diversity & Inclusion Awards: North America 2022. These awards celebrate the fantastic achievements of firms, companies and individuals who are furthering the advancement of diversity and inclusion across the USA and Canada. Congratulations Leyza, and thank you for your endless dedication to promote diversity and inclusion in all you do! Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..
- Sequor Law Empowers Women to Lead| Sequor Law
Sequor Law sponsors the IWIRC Annual Fall Conference in Orlando, with Shareholder Leyza B. Florin and Counsel Nyana Miller championing women's leadership in the insolvency profession. Sequor Law Empowers Women to Lead Open Events & Speaking Open October 21, 2022 1 minute read Sequor Law Shareholder Leyza B. Florin and Counsel Nyana Miller showed what it means to Be a Lead her while they attended the IWIRC Annual Fall Conference in Orlando, Florida. As a longtime supporter of this network, Sequor Law was an event sponsor, gifting all attendees with branded pouches empowering women to be leaders. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..
- The Effect of the General Data Protection Regulation on Discovery in the United States| Sequor Law
Sequor Law's Amanda E. Finley examines how the EU's General Data Protection Regulation (GDPR) affects document discovery obligations in US litigation and insolvency proceedings. The Effect of the General Data Protection Regulation on Discovery in the United States Open Legal Insights Open December 8, 2020 4 minutes read Sequor Law By Amanda E. Finley , Miami The European Union implemented the General Data Protection Regulation (GDPR), and it became effective on 25 May 2018. 1 The GDPR enforces privacy requirements to protect EU citizens. 2 “The GDPR applies to the processing of ‘personal data,’ which is defined as any information related to an ‘identified or identifiable natural person,’” who can be directly or indirectly identified by the data produced. 3 The GDPR purports to have extraterritorial effect by applying “regardless whether the processing takes place in the EU or elsewhere.” 4 The GDPR allows imposition of penalties and sanctions that “significantly increase[d] the maximum fine to €20 million, or 4% of annual worldwide turnover, whichever is greater.” 5 Further, “[t]he GDPR provides an individual with access to the courts to seek a judicial remedy” in addition to any administrative remedy. 6 Essentially, any production of documents that contain information about EU citizens could cause serious consequences and large fines for a GDPR violation. The early cases in the United States suggest that the GDPR may have a profound impact on discovery in the United States. The GDPR may provide for targets subject to the jurisdiction of courts in the United States to object to discovery with the purpose (or possibly under the guise) of protecting EU citizens’ privacy. Defendants may object to production as a whole, request significant redaction of the discovery, request a strict confidentiality agreement, request to produce anonymized data that does not identify any EU citizen, or any combination thereof. There is limited case law on the implications of the GDPR on U.S. discovery because it is a relatively new regulation. So far, U.S. courts have taken divergent approaches on how to address and resolve objections to discovery based on the GDPR. Overall, it appears that most courts are allowing production of the discovery in some form, over a defendant’s GDPR objection. U.S. Courts’ Historical Response to Discovery Objections Based on Foreign Privacy Statutes or Secrecy Laws Historically, U.S. courts have been unwilling to allow a foreign privacy statute to preclude the production of responsive documents that were otherwise discoverable in U.S. litigation. As the Supreme Court stated, “[i]t is well settled that such statutes do not deprive an American court of the power to order a party subject to its jurisdiction to produce evidence even though the act of production may violate that statute.” 7 The Court further noted that the French “blocking statute” was “originally ‘inspired to impede enforcement of United States antitrust laws,’ and that it did not appear to have been strictly enforced in France,” which further undercut U.S. courts’ interest in enforcing that foreign privacy statute over the American interest of full disclosure in discovery. 8 Prior and subsequent courts similarly ruled that foreign privacy statutes are not dispositive on production of discovery in U.S. cases, although the statutes may be relevant to the issue of whether sanctions should be imposed for failure to comply with U.S. discovery orders. 9 Likewise, U.S. courts deemed foreign bank secrecy laws insufficient to preclude discovery in U.S. litigation. 10 Therefore, generally, courts in the United States overwhelmingly have held that full disclosure in discovery outweighs any interest in enforcing foreign privacy or secrecy laws. A Chronological Review of U.S. Courts’ Approaches to GDPR Discovery Disputes and Other Foreign Privacy Statutes On 5 October 2018, the first published ruling on GDPR in U.S. litigation involved a defendant, Microsoft, raising a GDPR objection to discovery based on the undue burden and cost of producing the discovery due to “the alleged tension with GDPR.” 11 The court did not significantly analyze the GDPR issue, but stated that “the court [wa]s not persuaded by Microsoft’s arguments concerning undue burden” and required the production of documents. 12 On 17 December 2018, the first substantive ruling by a U.S. court to address an objection to discovery based on GDPR was in the context of a 28 U.S.C. § 1782 application to obtain discovery for use in a foreign proceeding. 13 The court “grant[ed] the application with respect to documents held by foreign custodians only to the extent that the Applicants (1) assume the costs of the document production, including the costs of compliance with the GDPR or other applicable European data privacy laws and (2) indemnify Respondents against any potential breaches of European data privacy laws.” 14 Although the court granted production of the documents over the GDPR objection, this ruling has serious adverse consequences for parties seeking discovery in U.S. litigation if the GDPR is implicated because it required unknown and potentially multimillion-dollar indemnification liability on the party receiving the documents. The approach in Hansainvest of requiring indemnification of the discovery target “against any potential breaches of European data privacy laws” is a serious deterrent to any party seeking discovery. 15 It would be unusual and highly unlikely that any party would knowingly accept such an open-ended and potentially large financial risk given the large fines for a GDPR violation. If courts routinely adopted this approach, it would have a significant chilling effect on U.S. discovery when the GDPR is implicated. Hansainvest is the only U.S. court, thus far, to rule that indemnification of any GDPR liability is a condition precedent to production of the documents. In later rulings, U.S. courts have taken less drastic approaches to GDPR objections to discovery. Click here to read the full article in the Spring 2020 International Law Quarterly (page 16) and the Business Law Section. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..
- WWL Thought Leaders Global Elite - Edward H. Davis Jr. Q&A| Sequor Law
Edward H. Davis Jr. discusses cross-border financial fraud, asset tracing, and modern asset recovery challenges in his WWL Thought Leaders Global Elite Q&A. WWL Thought Leaders Global Elite - Edward H. Davis Jr. Q&A Open Awards & Recognition Open August 25, 2022 2 minutes read Sequor Law In the complex world of cross-border financial fraud and asset tracing , experience and strategic insight are essential. In his ThoughtLeaders interview (featured in the Sequor Law article PDF), Founding Shareholder Edward H. Davis Jr. shares his perspective on what drives modern asset recovery practice and the evolving challenges practitioners face as fraudsters exploit increasingly sophisticated structures and technologies. Davis’s reflections are grounded in more than three decades of international litigation and investigative work representing victims of fraud , corruption , Ponzi schemes and other misappropriations of funds around the globe . The article weaves together Ed’s professional journey with grounded commentary on the issues shaping asset recovery today. He explains why he chose this practice area — to make a measurable difference in people’s lives by unravelling the complex legal and factual webs fraudsters set up to conceal assets. He also describes the kinds of cases that regularly come across his desk, noting that while traditional investment and corporate fraud remain core concerns, crypto-asset and internet-based frauds are increasingly front and center. A recurring theme of the piece is the interplay between legal systems and global reality. Davis identifies jurisdictional hurdles — including the reluctance of some legal systems to treat information as an asset recoverable in a tracing exercise — as among the greatest obstacles in international practice. This observation underscores the fact that asset recovery is as much about navigating foreign legal cultures and procedural norms as it is about understanding the underlying wrongdoing. The interview also touches on how technological tools are reshaping the practice. Davis points out that while emerging technologies are not yet “game changers,” they are helping practitioners uncover bank relationships and other data that were previously more difficult to access — leveling the playing field in key respects. Finally, Davis offers practical career insights for young lawyers interested in the field, emphasizing that direct experience and mentorship are irreplaceable for mastering the judgment and tactical skills required in high-stakes, highly international disputes . For a frontline look at the mindset and practical considerations of one of the field’s most experienced asset recovery lawyers , we encourage you to read the full interview in the PDF below. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..
- Lawyers Advisory Committee| Sequor Law
Sequor Law's Leyza B. Florin chairs the Lawyers Advisory Committee for the Southern District of Florida Bankruptcy Court, linking judges and practitioners to improve bankruptcy practice across the district. Lawyers Advisory Committee Open Awards & Recognition Open September 16, 2019 3 minutes read Sequor Law By: Guest Contributor Leyza B. Florin , Chair Lawyers Advisory Committee The Lawyers Advisory Committee (LAC) for the Southern District of Florida Bankruptcy Court was formed in 2018 to provide a forum for communication, feedback, and resources between the judges and the bar. Its purpose includes regularly soliciting the bar for commentary regarding bankruptcy practice and receiving requests from the court to consider issues arising from the practice of law before the Court. The LAC may recommend changes in the practice and procedures throughout the district and also acts as a liaison between the Court and the practitioners. In addition, the LAC is charged with the development, implementation, and maintenance of bankruptcy-related programs in the district as requested by the Court. To view samples of issues addressed by the LAC, please visit the LAC web page to view meeting minutes. The LAC is only as successful as the bankruptcy bar makes it. We are dependent on you to contact LAC members with any concerns or suggestions that you might have about bankruptcy practice in our district. The success of our bankruptcy practice in the Southern District of Florida is our absolute priority. If you have any recommendations which will improve the Court’s administration of justice, please reach out to a member of the LAC or contact us at LAC@flsb.uscourts.gov . We encourage you to participate by submitting feedback for consideration and assist the LAC in making our bankruptcy practice in the Southern District of Florida the best it can be. BANKRUPTCY RULES AND FORMS ARE AMENDED EFFECTIVE 12/1/19 Amendments to the federal rules and forms scheduled to take effect 12/1/19 and can be reviewed at the U.S. Courts website at these links: Pending Rules and Forms Amendments Pending Changes in Bankruptcy Forms If any of the above amendments necessitate changes in this court’s local rules, local forms, court guidelines, clerk’s instructions or any other local documents, notice will be provided prior to the December 1, 2019, effective date of the bankruptcy rules and forms amendments. COURT GUIDELINES FOR ATTORNEYS FOR CHAPTER 13 DEBTORS AMENDED Please take notice that the “Guidelines for Compensation for Professional Services or Reimbursement of Expenses by Attorneys for Chapter 13 Debtors Pursuant to Local Rule 2016-1(B)(2)(a)” have been amended to reflect an increase in the compensation fee that an attorney may charge without application to the court. The “no-look” fee will increase from $3,500 to $4,500 for all cases filed under or converted to chapter 13 on or after September 1, 2019. A Public Notice and amended “Guidelines” are currently posted on the court website. PROPOSED AMENDMENT TO THE FEDERAL RULES PUBLIC COMMENT PERIOD CLOSES FEBRUARY 19, 2020 On August 19, 2019, the Judicial Conference Advisory Committees on Appellate, Bankruptcy, and Civil Rules published proposed amendments to their respective rules and forms and requested that the proposals be circulated to the bar and public for comment. Appellate Rules: 3, 6, 42, and Forms 1 and 2; Bankruptcy Rules: 2005, 3007, 7007.1, and 9036; Civil Rule: 7.1 The proposed amendments, rules committee reports explaining the proposed changes, and instructions on how to submit comments are posted on the U.S. Courts website at: Proposed Amendments Published Comments The public comment period closes on February 19, 2020. If approved, the amendments would become effective December 1, 2021. Click here to read the full article. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..
- A Twenty-First Century Prisoner Exchange: The Case of the Isaías Brothers| Sequor Law
This article examines the Isaías Brothers case as a modern prisoner exchange between Ecuador and the United States, exploring press freedom, Edward Snowden asylum politics, and campaign finance. A Twenty-First Century Prisoner Exchange: The Case of the Isaías Brothers Open Legal Insights Open September 3, 2014 1 minute read Sequor Law Two brothers from Latin America are pitting the United States and Ecuador against each other in a battle over the freedom of the press, Edward Snowden, and campaign finance rules. Open article here Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..
- Sequor Law at Paris Arbitration Week: Enforcing Arbitral Awards Against Sovereigns| Sequor Law
Sequor Law partner Tara Plochocki joined Archipel at Paris Arbitration Week to discuss enforcing arbitral awards against sovereigns, treaty interpretation, and creditor coordination. Sequor Law at Paris Arbitration Week: Enforcing Arbitral Awards Against Sovereigns Open Events & Speaking Open April 17, 2025 1 minute read Sequor Law Sequor Law Partner Tara Plochocki was honored to join Jacques-Alexandre Genet and the team at Archipel during Paris Arbitration Week for a panel discussion on the enforcement of arbitral awards against sovereigns. The conversation explored the gap between legal obligations and state conduct, and how that divide might be narrowed. Panelists emphasized the importance of consistent interpretation of treaties and statutes by the courts—highlighted by recent decisions from the D.C. Circuit recognizing intra-EU ECT awards against Spain and Zhongshan’s free trade zone-related award against Nigeria. Thomas Eymond-Laritaz underscored the vital role of political pressure, particularly in light of potential shifts in the U.S. administration’s approach to proceedings against foreign sovereigns. Yasmin Mohammad offered valuable insight into the risks posed by EU laws that prohibit enforcement, while Paul H. shed light on the complexities and benefits of creditor coordination. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..
- New ‘Substantial Doubt’ Standard for Foreign Judgment Enforcement in Fla.| Sequor Law
Sequor Law analyzes Florida's new 'substantial doubt' standard for recognizing foreign judgments and its implications for creditors seeking enforcement in Florida courts. New ‘Substantial Doubt’ Standard for Foreign Judgment Enforcement in Fla. Open Legal Insights Open August 7, 2018 3 minutes read Sequor Law A recent change to a state law concerning the recognition and enforcement of foreign judgments in Florida may make it easier to avoid payment of valid debts. By Arnoldo B. Lacayo, Juan J. Mendoza and Andres H. Sandoval Left to right: Juan Mendoza, Andres Sandoval and Arnoldo B. Lacayo, Sequor Law A recent change to a state law concerning the recognition and enforcement of foreign judgments in Florida may make it easier to avoid payment of valid debts. An amendment to the Uniform Out-of-Country Foreign Money- Judgment Recognition Act (the act) adds two further grounds for denial of recognition of foreign country money-judgments, potentially making it harder to recognize and enforce foreign judgments in the Sunshine State, a jurisdiction already viewed domestically and abroad as a debtor’s haven due to its generous exemptions. On March 19, House Bill No. 623 was signed into law and, per Article III, Section 9 of the Florida Constitution, went into effect on May 9. The bill adds two discretionary grounds to Section 55.605(2), Fla. Stat., to challenge recognition of a foreign money-judgment. Under these additional grounds, a Florida court need not recognize a foreign money-judgment if the judgment was rendered in circumstances that “raise substantial doubt about the integrity of the rendering court” or “the specific proceeding in the foreign court leading to the judgment was not compatible with the requirements of due process of law.” These new grounds apply only to judgments of other countries and not to judgments of other U.S. states, territories or commonwealths. Enacted in Florida in 1994, the act largely follows the 1962 version of the Uniform Foreign Money-Judgments Recognition Act (the Uniform Act), promulgated by the National Conference of Commissioners on Uniform State Law (the NCCUSL). The act applies to final, conclusive, and enforceable money-judgments of other countries. Generally, such judgments are entitled to recognition under the act; however, there are several mandatory and discretionary grounds set forth in Section 55.605, Fla. Stat., upon which a court may deny recognition. While the purpose of the act is to “provide a speedy and certain framework for recognition of foreign judgments,” Laager v. Kruger, 702 So. 2d 1362, 1363 (Fla. 3d DCA 1997), in practice, this may not be the case. At first glance, the new amendment may seem unnecessary as the act already provides avenues to challenge recognition of a foreign judgment if it is “rendered under a system which does not provide impartial tribunals or procedures compatible with the requirements of due process of law,” or if it is “obtained by fraud.” The official comment to the Uniform Act draws a distinction between the new and existing grounds by stating that the focus of these two new grounds is on the integrity and procedure of the specific court that rendered the judgment, rather than on the judicial system of the foreign country. Nevertheless, one potential concern is that the amendment invites a case-by-case review of foreign judgments, rather than further the “speedy and certain framework” the act intended to establish. This concern is compounded by the uncertainty as to the application of the nebulous “substantial doubt” standard when evaluating the “integrity” of the foreign court. Based on this language, some may argue that a debtor need only present enough evidence to raise substantial doubt in the mind of the trier of fact rather than affirmatively demonstrating fraud. Thusly, at face value, the amendment appears to welcome the enterprising debtor to argue the interpretation and limits of these new provisions in an effort to delay and possibly frustrate the recognition and enforcement of a legitimate foreign judgment. Though the “substantial doubt” standard appears broad and ambiguous, it should in fact be narrowly interpreted. The NCCUSL explains that the standard is tantamount to “a showing of corruption in the particular case that had an impact on the judgment that was rendered.” At least two courts have followed the NCCUSL’s guidance in this respect. See In re Carmona, No. 16-50155, 2018 WL 889358, at *13 (Bankr. S.D. Tex. Jan. 19, 2018); Savage v. Zelent, 243 N.C. App. 535, 545 (2015). Neither found “substantial doubt” as to the integrity of the foreign court. In short, the new amendment may leave room for abuse if courts do not adhere to the guidance of the Uniform Act and the interpretation of other courts. If so, the nebulous “substantial doubt” standard should have minimal impact for experienced creditor’s rights and asset recovery lawyers seeking to enforce valid foreign judgments entitled to recognition in Florida. Click to view full article. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..
- Sequor Law continues to grow, adding another attorney to the team| Sequor Law
Sequor Law announces the addition of multilingual attorney Joseph Rome to its Miami team in September 2022, reinforcing its commitment to excellence in asset recovery and financial fraud litigation. Sequor Law continues to grow, adding another attorney to the team Open Firm News Open October 20, 2022 2 minutes read Sequor Law October 20, 2022, Miami, Florida – Sequor Law, a Miami-based international law firm working in the areas of asset recovery, financial fraud, insolvency, and financial services litigation, both domestically and across borders, announced today that attorney Joseph Rome has been added to the firm effective September 2022, joining an already impressive roster of talented, award-winning attorneys. The addition of Joseph Rome is part of the firm’s ongoing growth and confirms Sequor Law’s ongoing commitment to the development of new attorneys. “We are delighted to have Joseph, a talented, multilingual attorney. He possesses just the sort of unique skills, high level of integrity, and strong commitment to justice that our clients expect,” said founding shareholder Gregory S. Grossman. “Our ongoing growth and careful recruitment directly supports our strategic plan for the firm.” Joseph earned his Juris Doctorate from New York University School of Law. He was the co-chair of Outlaw and the vice-president of the Asia Law Society. In addition, he was a member of the Jessup International Moot Court team and a top oralist of the 2013 International Round competition. Prior to joining Sequor Law, Joseph was an “A” level prosecutor for the Miami-Dade State Attorney’s Office focusing primarily on attempted murders, gun crimes, and serious sexual assaults from the investigation stage through trial. He was also a member of the Police Accountability and Integrity Task Force, Hate Crimes Unit, and Traffic Homicide Unit. Joseph previously worked for two AmLaw 200 law firms in New York and Miami. He represented international corporations and high-net-worth individuals in a broad range of high-stakes litigation and arbitration matters. In addition, Joseph did externships with both the Orleans Public Defenders and the U.S. Attorney’s Office for the Eastern District of New York. He also did a summer fellowship at the United Nations International Law Commission in Geneva, where he drafted speeches and statements for the Japanese representative. Joseph Rome focuses his practice on asset recovery, corruption and proceeds of crime, international commercial litigation, domestic and international judgment and arbitral award enforcement, and financial fraud. He represents individuals, governments, and other entities in domestic and international judgment collection matters; cross-border insolvency proceedings under Chapter 15 of the U.S. Bankruptcy Code; actions to collect evidence for use in foreign proceedings under 28 U.S.C. § 1782; and other commercial disputes. Joseph is admitted to practice Law in New York, Florida, S.D.N.Y and the U.S. Courts of Appeals for the 1st, 5th, 6th, 9th and 11th circuits. He is Fluent in English, Spanish, Mandarin and Japanese. We look forward to working with Joseph to help him continue to develop his practice and consistently deliver comprehensive, top-tier service to our clients,” said founding shareholder Edward H. Davis, Jr. ****** Sequor Law is a Miami-based international law firm representing financial institutions, sovereign governments and state-owned enterprises, public and non-public companies, insolvency practitioners, and individual clients in the areas of asset recovery, financial fraud, insolvency, and financial services litigation. More information is available at www.SequorLaw.com. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..
- U.S. Court Orders Citibank to Comply with Financial Discovery in Kazakhstan Judgment Enforcement| Sequor Law
Sequor Law obtains a U.S. court order compelling Citibank to comply with financial discovery under the FSIA to enforce a judgment against the Republic of Kazakhstan, a key asset recovery win. U.S. Court Orders Citibank to Comply with Financial Discovery in Kazakhstan Judgment Enforcement Open Case Results Open February 21, 2025 1 minute read Sequor Law In a recent ruling that is of particular interest to parties seeking financial discovery relating to foreign sovereigns, Sequor Law, acting as part of a global enforcement team along with Astraea Group Ltd and Hillmont Partners, sought and obtained an Opinion and Order in the United States District Court for the Southern District of New York compelling Citibank N.A. and various affiliated entities (together, “Citi”) to respond to financial discovery in furtherance of Petitioners’ efforts to enforce their judgment against the Republic of Kazakhstan. A copy of the Court’s Opinion and Order, which reaffirmed various core principles governing the rights of creditors to obtain discovery under the Foreign Sovereign Immunities Act (the “FSIA”), can be accessed below. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..
- Trove of Missing Art Heads to Auction| Sequor Law
Sequor Law highlights recovered artworks from Banco Santos president Edemar Cid Ferreira’s collection—including 95 pieces seized by U.S. authorities in a $10 million money-laundering case that may be auctioned. Trove of Missing Art Heads to Auction Open In the News Open October 28, 2017 3 minutes read Sequor Law A Henry Moore sculpture and a Rufino Tamayo painting are among recovered art works that may be auctioned at Sotheby’s By Kelly Crow Former Banco Santos president Edemar Cid Ferreira once covered the walls of his São Paulo home with Man Ray photographs, Louise Bourgeois prints and paintings by Jean-Michel Basquiat, Francis Picabia and others. But when Brazilian authorities arrested Mr. Ferreira in 2006 for an alleged $1 billion money-laundering scheme, the walls were bare. The vanished collection set off a global scavenger hunt, with investigators and creditors chasing leads long after Mr. Ferreira was convicted of money – laundering and sentenced in federal criminal court in Brazil to 21 years in prison. Mr. Ferreira has appealed the case and declined, through his lawyer, to comment. Mr. Ferreira, the president of Banco Santos, during the World Economic Forum in Davos, Switzerland in 2004. More art once owned by him has been recovered. Photo: Daniel Ackern/Bloomberg News. This month, U.S. authorities announced a breakthrough, saying they had rounded up 95 works Mr. Ferreira once owned that together are worth at least $10 million. The art was in warehouses across France, Panama, England and the Netherlands, according to the U.S. Attorney’s Office for the Southern District of New York. Two paintings in the group were in galleries in New York. Joon Kim, the Acting U.S. Attorney, who said Mr. Ferreira’s art had been “used to mask an audacious criminal scheme,” signed documents turning the trove over to a Brazilian judicial administrator handling the estate of Banco Santos, which failed in 2005. The bank’s estate, which is seeking to compensate creditors, plans to enlist Sotheby’s to auction some of the works, said Arnoldo Lacayo, a lawyer with Sequor Law, a Miami firm helping the bank’s estate track down Mr. Ferreira’s assets. A Sotheby’s spokeswoman confirmed that the auction house has been asked to review the works for potential sale. Major pieces include Henry Moore’s “Woman,” a life-size bronze figure that had been stored in France, as well as Rufino Tamayo’s abstract view of a couple, “Casal de Marcianos 1975 (Two Figures),” which was stored in Florida. There also is a Lucite cube sculpture by Anish Kapoor and works by Brazilian mainstays Adriana Varejão, Vik Muniz and Jac Leirner. Among the older works is an etching by Eugène Delacroix. The fate of Helen Frankenthaler’s 1965 blue-and-gold abstract, “Sea Strip,” offers a glimpse into the circuitous path of some of the art. Mr. Ferreira paid Christie’s $197,900 for “Sea Strip” in late 2004 —a year before his bank failed and a time when authorities said he was starting to ship crates of art to warehouses in Europe for safekeeping. Later, a friend of his wife sold “Sea Strip” to Edward Tyler Nahem Fine Art in New York for an undisclosed sum. John Cahill, a lawyer for the gallery, said Mr. Nahem had been told that the painting was from a corporate collection. Once alerted to its true origins, Mr. Nahem got into a title dispute with the bank’s estate, Mr. Cahill and Mr. Lacayo said, because the dealer had bought the work in good faith. Both sides said they have since reached a settlement to sell the work jointly. Right now, the Frankenthaler is the only recovered work that isn’t immediately headed to Sotheby’s, Mr. Cahill said. Before this month, only a handful of works from Mr. Ferreira’s collection had been found and returned—including a Roman statue and Basquiat’s 1982 “Hannibal,” a skull portrait on an orange background. The work, with its dark slashes, spiky lines and splotches of bright color, is considered a signature piece by Basquiat, who started out as a graffiti artist. Mr. Ferreira bought the painting in 2003 and had it shipped from the Netherlands to a New York warehouse in 2007 after his conviction, authorities said. U.S. Customs took a closer look when the work arrived because its declared value was $100. Jean-Michel Basquiat, ‘Hannibal,’ 1982 Photo: Interpol Washington Last fall, Sotheby’s helped the bank’s estate sell “Hannibal” to Japanese billionaire Yusaku Maezawa for $13 million. “Hiding illicit proceeds in art happens all the time,” said Mr. Lacayo of the asset-recovery firm helping the bank’s estate. “At least in this case we’re unraveling it.” Click to view full article. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..











