Sequor Law Shareholder Leyza B. Florin paneled the "Attack the Sham" session on asset recovery toolkits at the ThoughtLeaders4 FIRE International conference in Vilamoura, Portugal. Thought Leaders 4 Fire: FIRE International Vilamoura, Portugal May 19, 2022 Open Events & Speaking Open May 24, 2022 1 minute read Sequor Law Sequor Law Shareholder Leyza B. Florin was a panelist at ThoughtLeaders4 FIRE International where she participated on the Attack the Sham panel about asset recovery toolkits along with co-panelists Hannes Arnold , Senior Partner – GASSER PARTNER Attorneys at Law , William Redgrave, Partner – Baker & Partners , Simon Jerrum , Partner – HFW . Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open 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.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.

Six Sequor Law attorneys are recognized in the 2023 SuperLawyers guide. Christopher A. Noel is named a Rising Star, honoring the top up-and-coming lawyers in the United States. Various Attorneys Recognized by SuperLawyers 2023 Open Awards & Recognition Open June 26, 2023 1 minute read Sequor Law Sequor Law is proud to announce that six attorneys have been recognized in the 2023 edition of SuperLawyers, a guide to the top lawyers in the United States. Congratulations to Christopher A. Noel Noel for being named a Rising Star, an honor given to the top up-and-coming lawyers in the country. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open 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.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.

Sequor Law's Arnoldo "Arnie" Lacayo, AIJA Litigation Commission President, and Juan Mendoza attend the 60th Annual AIJA Congress in Singapore, building key international connections. Arnoldo “Arnie” Lacayo and Juan Mendoza Attend 60th Annual AIJA Congress in Singapore Open Events & Speaking Open August 31, 2022 1 minute read Sequor Law See photos from Juan Mendoza and AIJA Litigation Commission President Arnoldo “Arnie” Lacayo’s recent trip to attend the 60th Annual AIJA Congress in Singapore where they reconnected with old and new contacts. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open 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.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.

Sequor Law's Leyza B. Florin and Christopher Noel analyze how US courts are adopting the Judicial Insolvency Network's framework for cross-border coordination in international insolvency matters. Asset recovery column: Globalisation catches up with the US insolvency courts Open Legal Insights Open September 17, 2019 5 minutes read Sequor Law Shareholder Leyza B. Florin and attorney Christopher Noel from Sequor Law in Miami discuss recent developments in coordination and communication between courts handling cross-border insolvencies. In today’s ever-globalized world, courts are progressively recognizing the need for cross-border coordination and cooperation when dealing with insolvency matters. Earlier this summer, the US Bankruptcy Court for the District of Delaware adopted the Judicial Insolvency Network’s (JIN) Modalities of Court-to-Court Communication (the Modalities ). The Delaware court’s adoption of the Modalities followed its February 2017 promulgation of Part X: Guidelines for Communication and Cooperation Between Courts in Cross-Border Insolvency Matters (the Guidelines ). The Guidelines and Modalities represent an unprecedented attempt at creating a unified framework for coordination and cooperation, and in some cases, joint hearings. In the past, coordination and cooperation among US bankruptcy judges and courts abroad was based on section 1525 of the US Bankruptcy Code (Cooperation and direct communication between the court and foreign courts or foreign representatives), and it was accomplished on an basis, which was ultimately left up to the specific judges handling the cross-border insolvency matter. This article examines the lead-up to the District of Delaware’s adoption of the Modalities, the Modalities’ goals in facilitating cross-border communication in insolvency matters, and forecasts the implications of the Modalities upon – and assuming – their addition to the District of Delaware Local Rules of Civil Practice and Procedure. The beginnings of global cooperation The District of Delaware and the Supreme Court of Singapore announced the formal implementation of the Guidelines on 1 February 2017. The Guidelines are the result of work by judges around the world – judges in Australia, Bermuda, the British Virgin Islands, Canada, the Cayman Islands, England and Wales, Singapore, and the United States all contributed to their development beginning at the 2016 JIN meeting in Singapore. To date, they have been adopted by some of the busiest bankruptcy and insolvency tribunals around the world (see list at foot of article). The goal of adopting the Guidelines was “to improve in the interests of all stakeholders the efficiency and effectiveness of cross-border proceedings relating to insolvency or adjustment of debt opened in more than one jurisdiction by enhancing coordination and cooperation amongst courts”. Ultimately, the Guidelines are meant to benefit all stakeholders in cross-border insolvencies, by improving efficiency in the insolvency process and reducing litigation costs. The Guidelines comprise an introduction setting forth objectives, 14 enumerated guidelines providing guidance on protocols, and an appendix addressing joint hearings. Delaware moves the ball On 25 July 2019, the JIN announced its adoption of the Modalities. On the same day, Judge Christopher Sontchi , chief judge of the US Bankruptcy Court for the District of Delaware, entered an order adopting the Modalities on an interim basis, pending the District Court’s annual review of its Local Rules. This means the District of Delaware will now follow the Modalities when dealing with cross-border insolvency matters, even before they are formally adopted into the Local Rules. The Modalities include guidance concerning the designation of a so-called facilitator, the initiation of communications between judges, arrangements for those communications, and the actual communications between judges. Each of these areas of guidance will be discussed below. Laying the groundwork The Modalities apply to all direct communications between courts in cross-border insolvency proceedings. They also govern the mechanics of communication between courts in parallel proceedings, such as a Chapter 15 proceeding in the US where there is a simultaneous foreign main proceeding abroad. In general, the Modalities anticipate that a judge in a matter with cross-border elements (the initiating judge) will attempt to communicate with other judges and courts considering the same insolvency matter (the receiving judge). To accomplish this objective, courts are now requested to publish information regarding facilitators so that there is a clear line of communication. Among the information in the facilitator, publication will be the facilitator’s identity (the District of Delaware has identified its clerk of court to act in this role) and the language for the initial communication, as well as what technology is available to facilitate communication. This basic information was not necessarily easily obtained in the past, and a clear designation of with whom to communicate and how those communications should be made, will alone facilitate greater coordination and cooperation among those involved in cross-border insolvencies. Saying hello Once the groundwork for communication is established, and there is a clear line of communication with a court’s facilitator, the judges involved in parallel cross-border insolvency proceedings should exchange relevant information to keep the line of communication open. The initiating judge should provide basic information to the receiving judge, such as the facilitator’s contact information, the initiating judge’s contact information, information concerning the matter before the initiating judge, the nature of the matter, whether the parties before the initiating judge have consented to the communication, and the specific issues upon which communication is sought. Once this initial communication is accomplished, then the facilitator should step in and assist with coordinating between the initiating and the receiving judges. Setting a date After a line of communication is open, the initiating and receiving judges’ facilitators are free to communicate and arrange for the two judges to speak, with or without the presence of counsel or the parties. The initiating and receiving judges have great leeway in how communication is made, and the Modalities provide only that the two judges should be satisfied with the arrangements, including appropriate translation services and protocols to communicate confidential information via a secure method. The first meeting and ongoing discussions. After the necessary protocols are in place, the Modalities suggest that the initiating and receiving judges communicate in accordance with the Guidelines. Additionally, the Modalities provide that, should the two judges so wish, they may discontinue the use of their respective facilitators to allow for an efficient line of direct communication. This may also be done without the presence of counsel or the parties. Ultimately, the Modalities’ goal is to allow easy, efficient, and productive communication between the initiating and receiving judges so as to improve efficiency. A globalized world Now that the District of Delaware has, at least initially, adopted the Modalities, it is foreseeable that other US Bankruptcy courts will follow suit. The number of cross-border insolvency proceedings that could (and will) benefit from increased coordination and cooperation across borders is ever growing. All parties – creditors, debtors, bankruptcy estates, and insolvency tribunals – stand to benefit from the Modalities when handling cross-border insolvencies. Moving forward, the potential impact on cross-border insolvency practice is great. Both insolvency courts and practitioners alike will need to work together to implement the Modalities and Guidelines so that all involved are familiar and comfortable working with this new framework. Additionally, through ongoing efforts, cross-border insolvency matters should become more streamlined and efficient. The free flow of information will take much of the uncertainty out of cross-border situations where multiple parallel proceedings are involved. In sum, the Modalities and Guidelines now facilitate the insolvency practice’s ongoing evolution in an ever-more-globalised world. Courts Adopting the Guidelines for Communication and Cooperation Between Courts in Cross-Border Insolvency Matters The US Bankruptcy Court for the District of Delaware The Supreme Court of Singapore The US Bankruptcy Court for the Southern District of New York The Supreme Court of Bermuda The Chancery Division of England & Wales The Eastern Caribbean Supreme Court The Supreme Court of New South Wales The US Bankruptcy Court for the Southern District of Florida The Seoul Bankruptcy Court The Grand Court of the Cayman Islands The Commercial List Users’ Committee of the Superior Court of Justice – Ontario (Commercial List) The District Court Midden-Nederland, in the Netherlands 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 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.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.

Sequor Law partners Leyza B. Florin, Edward H. Davis Jr., Gregory Grossman, and Arnoldo Lacayo named to the inaugural Lawdragon 500 Leading US Bankruptcy & Restructuring Lawyers guide. The 2020 Lawdragon 500 Leading U.S. Bankruptcy & Restructuring Lawyers Open Awards & Recognition Open July 24, 2020 1 minute read Sequor Law 24 July 2020 Sequor Law Partners Leyza B. Florin , Edward H. Davis, Jr. , Gregory S. Grossman and Arnoldo “Arnie” Lacayo were named to the inaugural Lawdragon 500 Leading US Bankruptcy & Restructuring Lawyers guide. Included in the Global guide are lawyers with leading cross-border practices that “bring remarkable skills in financing, structuring, litigating and creating a pathway forward” for their clients. Open the article here Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open 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.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.

Attorney Spotlight – Get to Know Alain M. Acanda Open Attorney Spotlight Open January 29, 2026 2 minutes read Sequor Law 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as a child. Growing up I wanted to change the relationship I had with the law and use the legal field to build myself and my community up. 2. Why did you choose the areas of law that you practice? I chose the areas of law I practice because it allows me to take advantage of Miami’s unique position as a hub for the exchange of culture, business, and legal work. Practicing in areas like cross border insolvency and arbitration allows me to gain a broad range of perspectives from clients across the globe. 3. What skills do you draw upon when it comes to your specific practice areas? The skills I draw upon in my practice areas are understanding how all the moving pieces of a case fit together and being flexible in order to deliver results for the client. Being able to understand how these pieces fit together keeps a case moving forward and being flexible permits adapting to changing circumstances in order to still deliver for a client. 4. What is the most rewarding part about your job? The most rewarding part of the job is being able to deliver for a client. 5. Tell us about a mentor who made an impact on your career. A mentor who had an impact on my career was my high school AP European History teacher. He also served as my coach for the international debate club which was where I first became interested in international law which has carried on until today. 6. If you weren’t practicing law, what would you be doing? If I wasn’t practicing law, I’d either be a history professor or restoring classic American cars. 7. What might people be surprised to learn about you? People might be surprised to learn that I love to cook. Whether it be cooking steaks on a grill or making pasta from scratch, I enjoy trying new recipes and making different dishes. 8. What is a good book or article you read recently? A good book I read recently was : Cuba, An American History by Ada Ferrer. It explores the rich shared history between the two nations which can be often overlooked beyond the Castro-regime years. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open 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.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.

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 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.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.

An overview of 28 U.S.C. § 1782, one of the most powerful discovery tools available to foreign litigants, allowing evidence gathering in US federal courts for use in international proceedings. Section 1782 Remains One of the Most Powerful Discovery Tools as Appellate Courts Uphold its Use in Aid of Private Commercial Arbitration Open Legal Insights Open June 10, 2020 4 minutes read Sequor Law 28 U.S.C. § 1782, known colloquially as “Section 1782,” is a federal statute that allows foreign litigants and interested persons to request judicial assistance from U.S. federal courts to obtain evidence for use in a proceeding in a foreign or international tribunal. Section 1782 is highly relevant to a wide array of legal practitioners, both within and outside the U.S., as federal courts have concluded that evidence obtained through Section 1782 may be used in civil, criminal, probate, bankruptcy, marital, administrative, and regulatory cases. In short, if your client is not using Section 1782 as part of its litigation strategy, there is a good chance that your client’s opponent is using it to your client’s disadvantage. Section 1782 is an alternative to the slower, and oftentimes cumbersome, cross-border discovery mechanisms such as letters rogatory and diplomatic or consular channels, because it can be pursued directly by the litigant or interested party without the involvement of the foreign court or tribunal or of the governmental authorities making up the traditional channels. Section 1782 was enacted decades ago and was revised extensively in 1964, but its widespread use did not take off until after the U.S. Supreme Court’s 2004 ruling in Advanced Micro Devices, Inc. against Intel Corp. , or “Intel” as the seminal decision is widely known. In the Intel case, the Supreme Court clarified the statutory requirements that an applicant has to satisfy to obtain evidence using Section 1782 as well as a number of discretionary factors courts should also consider. If the applicant is successful, it can obtain U.S.-style discovery from persons or entities located where the application is filed (in the form of site inspections, requests for production of documents, or deposition testimony under oath) for use in the foreign proceeding. Typical Section 1782 subpoena targets include businesses (including affiliated companies and subsidiaries), financial institutions, professionals such as lawyers and accountants, brokers, escrow agents, art galleries and auction houses, former employees, and many more. This incredibly powerful tool can also be pursued on an ex parte basis (at least initially) and does not require the applicant to prove that she has exhausted her domestic evidence gathering tools in the foreign case or, significantly, that the evidence will be admissible in the foreign proceeding. One issue that has been contested since Intel was decided is whether Section 1782 can be used in support of a private commercial arbitration (as opposed to treaty-based arbitrations where the use of Section 1782 is clearly supported by the applicable case law). Recently, the Sixth Circuit and Fourth Circuit Courts of Appeals broke with the Second and Fifth Circuits and determined that interested parties may rely on Section 1782 to obtain evidence for use in a privately constituted international arbitration proceeding. In September 2019, the Sixth Circuit analyzed the definition and interpretation of the word “tribunal” at length (relying on the ordinary meaning of the word, several dictionary definitions, the use of the word in legal writing, and an examination of the statute’s text, context and structure) and held that the language of Section 1782 unambiguously “includes private commercial arbitral panels established pursuant to contract and having the authority to issue decisions and bind the parties.” Abdul Latif Jameel Transportation Co. Ltd. v. FedEx Corp. , 939 F.3d 710, 723 (6th Cir. 2019). A few months later, the Fourth Circuit followed. In March 2020, the Fourth Circuit agreed that private arbitral tribunals are “foreign tribunals” within the meaning of Section 1782, and rejected a litany of policy arguments advanced by the respondent. Servotronics, Inc. v. Boeing Co. , 954 F.3d 209 (4th Cir. 2020). Although district court decisions have been deeply divided on the issue since Intel, there is now strong momentum gathering at the appellate level favoring the use of Section 1782 in aid of private commercial arbitration. For example, California district courts had uniformly followed the Second and Fifth Circuits in holding that an applicant may not obtain evidence through Section 1782 for use in a private commercial arbitration—until recently. In February 2020, a federal court in the Northern District of California adopted the reasoning and conclusion of the Sixth Circuit’s decision regarding Section 1782’s application to private international arbitration. HRC-Hainan Holding Company, LLC v. Yihan Hu , No. 19-mc-80277, 2020 WL 906719 (N.D. Cal. Feb. 25, 2020). That case is now on appeal, and the Ninth Circuit is positioned to rule on the issue. In sum, the already powerful Section 1782 has seen its applicability bolstered by two of the highest courts in the U.S. indicating that Section 1782 will remain an indispensable tool in any international lawyer’s toolbox for the foreseeable future. About the authors: Arnie Lacayo ( alacayo@sequorlaw.com ) is a Shareholder and Cristina Vicens ( cvicens@sequorlaw.com ) is an Attorney at Sequor Law. Lacayo and Vicens focus their practices on investigations, financial fraud and corruption-related asset recovery cases, as well as cross-border insolvency. Both Lacayo and Vicens have extensive experience with the Section 1782 statute, including in some of the most-cited cases in the U.S. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open 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.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.

Sequor Law's Leyza B. Florin and Christopher Noel analyze the Second Circuit's evolving Section 1782 standard in the Euromepa and Gorsoan cases and its implications for global discovery. Asset recovery column: Euromepa and Gorsoan, oh my Open Legal Insights Open January 5, 2021 7 minutes read Sequor Law Sequor Law shareholder Leyza B. Florin and attorney Christopher Noel discuss the evolving standard to obtain Section 1782 assistance in the US Court of Appeals for the Second Circuit and beyond. The US Court of Appeals for the Second Circuit, which includes the states of Connecticut, New York, and Vermont within its jurisdiction, is currently tasked with addressing and deciding how far to extend an ever-narrowing standard applied to proceedings brought pursuant to Section 1782 of the United States Code. In out of the US District Court for the Southern District of New York, the Second Circuit has been asked to decide whether an application for judicial assistance to obtain discovery for use in aid of a foreign judgment meets the statutory requirements for relief to be granted pursuant to Section 1782. The ramifications of the Second Circuit’s decision are certain to resonate globally, as New York remains a hotbed for seeking US judicial assistance for foreign tribunals, both because of its geographic proximity to Europe and because of the myriad of global businesses that identify New York as their principal places of business. As many global restructuring and insolvency practitioners are aware, Section 1782 is the product of more than 150 years of effort from the US Congress to provide federal-level court assistance in gathering evidence in the US for use in a foreign tribunal. Generally, whether to grant this assistance is determined by a two-part inquiry: (1) whether a US District Court is to grant relief pursuant to Section 1782; and (2) whether a US District Court grant relief in its broad discretion. At issue before the Second Circuit is one of the statutory prongs examined when a US District Court is deciding whether it is authorised to grant relief –to wit, that the evidence sought must be “for use in a proceeding in a foreign or international tribunal.” The case began with an alleged US$25 million fraud, which caused a Cypriot court to issue a worldwide freezing injunction and asset disclosure order against dozens of defendants, including the Belarusian born, Florida-based socialite Janna Bullock. After Bullock refused to comply with the Cypriot court’s order, Gorsoan, a Cyprus company and fraud victim, sought assistance in the US District Court for the Southern District of New York, pursuant to Section 1782. Upon challenge in the Second Circuit, the appellate court affirmed the order granting judicial assistance and Bullock was required to produce the requested discovery. Much to the dismay of Gorsoan, and fellow fraud victim Gazprombank, Bullock failed to produce substantive discovery in response to Gorsoan’s requests. As a result, Gorsoan obtainedleave of court and a court order to take a second deposition of Bullock. At this second, court-supervised deposition, Bullock refused to answer questions by invoking her Fifth Amendment right against self-incrimination. Thereafter, Gorsoan led its second application for judicial assistance pursuant to Section 1782, seeking authorisation to subpoena Bullock’s children, mother, and other related persons. The District Court granted that application and Gorsoan’s subsequent motion to compel, which led to Bullock’s intervention and a motion to quash the subpoenas. In January of this year, the Southern District of New York denied Bullock’s defensive motions and granted Gorsoan’s motion to compel related to its subpoenas. Atpresent, the Southern District of New York’s decision remains on appeal at the Second Circuit. However, based upon its own prior precedent in , which broadly held that enforcement of a foreign judgment does not meet the “for use” prong required for Section 1782 relief, the Second Circuit may well further limit Section 1782’s use for obtaining discovery in the United States for use in foreign tribunals. In , the dispute stemmed from an insurance claim for approximately US$20 million in lost or stolen diamonds and other precious jewelry owned by jeweler Esmerian, Inc. and insured by Euromepa. Underlying the Section 1782 proceedings in the United States was a French action wherein the French trial court issued a judgment of approximately US$10 million in favor of Esmerian, which resulted from a finding of equal fault between Esmerian and Euromepa in the loss of the jewelry. Following the French trial court’s ruling, and after perfecting an appeal, Euromepa filed its Section 1782 petition in the Southern District of New York, seeking discovery of Esmerian regarding, among other items, proof of the jewelry’s ownership, proof of the jewelry’s insurance, and proof of the jewelry lost. Ultimately, Euromepa sought this discovery for use in its appeal of the French trial court’s ruling of equal fault among the parties. Upon review, the Southern District of New York denied Euromepa’s application, resulting in an appeal to the Second Circuit. In between appellate argument and the Second Circuit’s decision, the French appellate court favorably amended the French trial court’s judgment in Esmerian’s favor, holding Euromepa wholly liable for the US$20 million loss. As a result, Euromepa immediately sought protection in the French bankruptcy court. The Second Circuit, without addressing the decision of the French appellate court, reversed and remanded the case for further proceedings. Contemporaneously, Euromepa sought review of the French appellate court’s decision with the French Supreme Court, which resulted in an affirmance of the lower appellate court’s opinion. Immediately following the French Supreme Court’s decision, the Southern District of New York dismissed Euromepa’s Section 1782 petition as moot because that decision effectively eliminated all pending proceedings in which Euromepa could use the discovery sought in the United States. Thereafter, Euromepa’s second appeal followed, arguing that the Southern District of New York failed to consider the pending French bankruptcy proceeding and a potential motion to reopen the judgment of the French appellate court, as bases to avoid the Court’s finding of mootness. Upon examination, the Second Circuit found that the French bankruptcy proceeding is not adjudicative within the meaning of Section 1782 because the merits of the dispute between Esmerian and Euromepa have already been adjudicated and would not be considered in the French bankruptcy proceeding, based upon French law. Further, the Second Circuit held that Euromepa’s argument concerning the potential motion to reopen the judgment of the French appellate court was meritless, because its conceded that such a petition was unlikely to be made absent newly discovered evidence. Accordingly, the Second Circuit held that the Southern District of New York did not abuse its discretion in dismissing Euromepa’s Section 1782 petition as moot. Applying this precedent to the appeal, it is entirely possible that theSecond Circuit will again hold that, because the adjudicative function of the foreign tribunal is complete, there is no basis under Statute 1782 to grant relief, thereby foreclosing Gorsoan’s ability to obtain discovery in the United States. All hope is not lost for obtaining discovery in the US, however. While the Second Circuit appears to be gradually narrowing the door for discovery pursuant to Section 1782, the Southern District of New York specifically recognised that “[n]one of the decisions [cited by Bullock in ] established a broad rule that asset discovery can never be adjudicative and is thus always impermissible under § 1782.” (435 F.Supp.3d at 598). Ultimately, the nuance lies in whether the discovery sought pursuant to Section 1782 could have an effect on the merits of the dispute being decided in the foreign tribunal. Moreover, District Courts around the US have sought to further clarify the holding in . For example, in , the US District Court for the District of Massachusetts held that “the court did not universally bar discovery in all bankruptcy proceedings, particularly where issues are being adjudicated.” Further, in , the US District Court for the Middle District of Tennessee held that “had not held that ‘all post-judgment proceedings are not adjudicative’.” Finally, even within theSouthern District of New York, there remains some dispute regarding how far the decision extends: in , the court cited for the limited proposition that Section 1782 discovery “is inappropriate where the merits of a controversy have already been decided by the foreign tribunal.” Ultimately, according to the Southern District of New York in , “adopting the proposed far-reaching rule against asset discovery would be incongruent with § 1782’s ‘underlying policy’ that, ‘[a]bsent specific directions to the contrary from a foreign forum, . . . district courts [should] provide some form of discovery assistance’.” (435 F.Supp.3d 589, 599). At some point later this year, the Second Circuit will likely decide whether Gorsoan will be permitted to obtain the discovery it seeks related to Bullock’s alleged involvement in the US$25 million fraud. At present, proceedings in the Southern District of New York have been stayed by court order, pending resolution of the appeal. Until resolution, and further clarity from the Second Circuit, practitioners should not wait to file their respective applications for judicial assistance pursuant to Section 1782. Instead, non-US practitioners should carefully consider the various jurisdictions where an application for Section 1782 assistance could be filed in the US (any district where the person from whom discovery is sought resides or is found), especially if that location is outside of the Second Circuit’s jurisdiction. Further, there are other litigation tools that counsel in the US may use to otherwise obtain the discovery needed for use in a foreign tribunal when there is already a judgment – one example is domestication of a foreign judgment pursuant to a variety of state laws allowing the enforcement of foreign judgments in the US. Although differing somewhat from state to state, most states have already adopted the Uniform Foreign Money-Judgments Recognition Act (UFMJRA) and have common law decisions that reinforce a foreign party’s ability to both domesticate and enforce foreign judgments within the US. Case references (2d Cir. Case No. 20-680, Filed 21 February 2020) , 154 F.3d 24 (2d Cir. 1998) , No. 15-mc-91509, 2018 WL 474999, at *4 (D. Mass. 2018) , No. 17-mc-5, 2018 WL 3872197, at *12 (M.D. Tenn. Aug. 15,2019) , 190mc-287 (LIS), 2019 WL 2743205, at *1 (S.D.N.Y. July 1,2019) 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 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.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.

Sequor Law's Leyza B. Florin, BLS Chair, announces a new CLE Diversity Policy requiring underrepresented group representation on all Florida Bar Business Law Section panels. Business Law Section to Diversify its Education Program Panels Open In the News Open September 8, 2020 2 minutes read Sequor Law By Jim Ash Underscoring its commitment to diversity, the Business Law Section will soon mandate that its CLE program professional panels include members from underrepresented groups. The new BLS “CLE Diversity Policy,” approved by the executive council on September 4, will apply to all CLE programs sponsored or co-sponsored by the section after January 1, according to BLS Chair Leyza B. Florin . The new policy was developed jointly by members of the section’s Inclusion, Mentoring, and Fellowship Committee and The Florida Bar Diversity and Inclusion Committee, Florin said. “Our Inclusion Mentoring Fellowship Committee did extensive work reviewing similar policies for organizations around the U.S. in developing this policy,” Florin said. Under the policy, individual programs with a “faculty” of three or four-panel participants, including the moderator, would require at least one diverse member, and panels with five to eight members, including the moderator, would require at least two diverse members. Panels with nine or more members, including the moderator, would require three diverse members. “The BLS will not sponsor, co-sponsor, or seek CLE accreditation for any program failing to comply with this policy unless an exception or appeal is granted,” the policy states. The policy will be enforced by the IMF Committee. An exception would be granted if “previously confirmed diverse speakers or moderators withdraw or become unable to attend,” and “insufficient time exists to replace them and maintain a diverse panel.” The only other exemption would apply if, “After a diligent search and inquiry, the proponents of the CLE have affirmed they have been unable to obtain the participation of the requisite diverse members of the CLE panel.” To implement the policy, the IMF Committee has been directed to create a “Diverse Speakers Directory.” According to the policy, the directory will include a database of legal experts that “self-identify from a race, ethnicity, gender and gender identity, sexual orientation, disability and multicultural perspective.” Click here to read the original article . Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open 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.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.

Attorney Spotlight: Sequor Law Shareholder Fernando J. Menendez Jr. shares insights on bankruptcy strategy, the impact of COVID-19 on businesses, and his approach to the legal industry. Attorney Spotlight: Fernando J. Menendez Jr. Open Attorney Spotlight Open October 7, 2021 3 minutes read Sequor Law On this month’s Attorney Spotlight, we interviewed Sequor Law Shareholder, Fernando J. Menendez Jr. , who provided his insights on the legal industry. What advice would you give to those firms facing bankruptcy due to the pandemic? However unpleasant the prospect of bankruptcy may be, it is important to get advice early. There are undoubtedly abrupt changes in circumstances that may make it necessary for an entity to seek bankruptcy relief with little or no time to prepare, but, to the extent there is even a small window of time to consider the options, make the most of it. In bankruptcy, as in most things, luck favors the prepared. The options in a potential restructuring can vary greatly depending on a variety of factors, including a firm’s capital structure; whether its secured debts have been properly perfected; the status of its executory contracts; its cash flow and pro forma; the nature and status of pending legal actions against it, to name just a few. To what extent has covid-19 affected your work and the nature of disputes you encounter? I would say that the most pronounced change hasn’t been in the nature of the disputes we’ve encountered, but—more practically—in the way we practice. In that regard, we all owe a great debt to our courts, which have responded to the tremendous challenge of this pandemic by making it possible to hold hearings on significant contested matters through Zoom and other video conferencing platforms and, thereby, kept our cases moving forward. Given your tenure as a leading bankruptcy attorney, what is the most important thing you have learned? In solving difficult problems, you have to be creative and keep going back to the drawing board until you’ve found the right answer. Edison said it best: “When you have exhausted all possibilities, remember this — you haven’t.” What advice would you give to aspiring bankruptcy lawyers? In everything you do, ask yourself—how would I want someone to do this for me if I was in need of an attorney? How would I want it done for a parent or a sibling? Now, do that! How does Sequor Law distinguish itself from competitors in the market? If I had to use a single word, I would say it’s passion. A passion for what we do; for doing it right; for getting it right; for meeting our client’s objectives. What is specific to Sequor Law? The team at Sequor has a breadth of knowledge and experience that gives us unique advantages in assisting our clients. Specifically, because we routinely act as counsel in domestic and cross-border insolvency cases, and are frequently engaged in commercial litigation and international asset recovery matters, we are able to provide advice that is not only reactive, but proactive. Given our experience and day-to-day work, we have a good sense of where a case is likely to go after a judgment has been obtained, and begin working to anticipate those eventualities well before many others may have considered them. What should clients look for when selecting a bankruptcy attorney or firm? In this age of endless marketing, it’s easy to get distracted by keywords on a website. Obviously, a referral from someone who has worked with the attorney in the area is a good touchstone for assessing experience and expertise. Absent that, you want to focus on whether the attorney seems to truly understand your problem. Have they dealt with something like it before? Are they asking the right questions? Are they raising issues you had not considered? Are they challenging you or just agreeing with everything you say? This last one may take a bit longer to get to, but, in my experience, is quite possibly the best indication that you have the right lawyer. What do you enjoy most about working in bankruptcy? Without question, the fact that it moves fast—at least relative to most standard commercial litigation. Given the exigency of bankruptcy, and the surrounding statutory framework—which is geared towards getting parties to some form of resolution as quickly as possible—you don’t have to wait years before a client’s major issues/claims are resolved. For better or worse, you’ll have your answer (in an ideal world, the right one!) quickly. What is a book or article that you consider a must-read? Collier on Bankruptcy! For those in the mood for something a little more plot-driven, you can’t go wrong with All The Light We Cannot See and The Nickel Boys, both of which are heart-wrenching and amazing. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open 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.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.

Latinvex's Latin America's Top 100 Lawyers ranking features Sequor Law among the leading international law firms engaged in Latin American legal matters across 12 practice categories. Latin America’s Top 100 Lawyers Open Awards & Recognition Open June 23, 2021 2 minutes read Sequor Law Latinvex singles out the top foreign lawyers in Latin America. BY LATINVEX STAFF The editorial and research staff of Latinvex has selected the leading attorneys from international law firms that are involved in the legal business in Latin America. The ninth annual ranking includes 100 attorneys from 58 law firms — major firms as well as boutique firms — and spans 12 categories, including arbitration & litigation, banking & finance, capital markets, corporate/M&A, energy, FCPA & fraud and project finance. The criteria used was a combination of factors, including recent track record on major deals and business, prominence of firm in Latin America and rankings by third parties such as Chambers and Partners, Legal 500 and Refinitiv. Latinvex used data from our annual survey of international firms as well as publicly-available information. This year, 14 attorneyswere new compared with last year’s list. Keywords: Allen & Overy, Arent Fox, Arnold & Porter, Baker Botts, Beveridge & Diamond, Brown & Rudnick, Cassels Brock, Chaffetz Lindsey, Cleary Gottlieb, Conyers, Covington & Burling, Crowell & Moring, Davis Polk, Debevoise & Plimpton, Diaz Reus, Foley Hoag, Freshfields, Fridman Fels & Soto, Gowling WLG, Haynes and Boone, Herbert Smith Freehills, Hogan Lovells, Holland & Knight, Hughes Hubbard, Hunton Andrews Kurth, Jenner & Block, Jones Day, K&L Gates, Latham & Watkins, Littler Mendelson, Mayer Brown, McDermott Will & Emery, Milbank, Miller & Chevalier, Morgan, Lewis & Bockius, Morrisson & Foerster, Nelson Mullins, Paul Hastings, Proskauer Rose, Quinn Emanuel, Reed Smith, Ropes & Gray, Sequor Law , Shearman & Sterling, Sheppard Mullin, Sidley Austin, Simpson Thacher, Skadden, Squire Patton Boggs, Sullivan & Cromwell, Thompson & Knight, Vinson & Elkins, Wasserman West, White & Case, Willkie, Wilson Sonsini, Winston & Strawn and Winston Legal Group. To see 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 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.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.