Forbes quoted Sequor Law’s Tara J. Plochocki on the 2016 South China Sea ruling and why enforcing international arbitration awards against sovereigns is hard. China’s Defiance Over South China Sea Shows Limits of International Courts Open In the News Open July 12, 2016 2 minutes read Sequor Law The Philippines left The Hague in July 2016 with a sweeping win. A tribunal at the Permanent Court of Arbitration found that China had broken international law by building artificial islands to push its territorial claims hundreds of miles into the South China Sea. China's answer was just as blunt. It would not abide by the ruling, it had refused to take part in the proceedings, and it denied that the tribunal held any authority over what it called a territorial dispute. Forbes asked the obvious follow-up: what is a paper victory worth when the losing side refuses to recognize it? Tara J. Plochocki — today a Partner at Sequor Law and head of the Washington D.C. office — was quoted throughout the piece. The absence of China's consent, she noted, had been visible "from 14 years away": Beijing had signed a 2002 framework to resolve these disputes through negotiation, and it never agreed to let a tribunal decide questions of sovereignty. The whole story hinges on consent. Nations routinely agree to international arbitration in commercial matters and must live by the outcome. They are reluctant to agree to such arbitration when a dispute touches sovereignty. As the article notes, the United States has done the same thing China did, brushing off the International Court of Justice in the 1980s over Nicaragua and again in the 2000s in a death-penalty case involving a foreign national. Beijing is not the only sovereign to refuse to honor an unfavorable ruling. For businesses, Plochocki drew a practical line rather than a political one. China, she said, "is not an unreasonable place to do business — you can sign a contract there and have it enforced." Her caveat travels well beyond this case: companies contracting with state-owned enterprises should decide in advance on a dispute-resolution forum those enterprises have actually honored before. A favorable award means little if it lands somewhere the other side can ignore. Her closing observation captured the distance between winning and collecting. The Hague, she said, often serves as the court of international opinion; enforcing its judgments is a separate fight. The full Forbes article is here: "China's Defiance Over South China Sea Shows Limits Of International Courts." That distance is the center of Plochocki's work today. At Sequor Law she concentrates on international arbitration and on enforcing arbitral awards and foreign judgments, including against sovereigns and state-owned enterprises that would rather not pay. The South China Sea ruling is the dramatic version of a problem her clients face in quieter forms every day: a judgment is only as good as your ability to enforce it. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open 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.. 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...

Who's Who Legal recognizes Sequor Law's Edward H. Davis Jr. as one of the foremost asset recovery lawyers, praised for identifying key issues and strategic thinking in complex financial disputes. Thought Leaders Global Elite – Asset Recovery (GIR 2019) Open Awards & Recognition Open September 5, 2019 1 minute read Sequor Law Who’s Who Legal says: Edward Davis Jr is one of the foremost lawyers in our research this year. Sources note, “He is particularly strong at identifying key issues and strategizing in ways that take those key issues into consideration.” Read the full article below or click here Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open 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.. 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...

Judge David Jones takes under advisement motions to convert MatlinPatterson Chapter 11 cases to Chapter 7, examining whether the debtors' wind-down constitutes a species of rehabilitation. Court Takes Under Advisement Motions to Convert MatlinPatterson Cases to Chapter 7, Says Decision Turns on Whether Wind-Down of Debtors’ Businesses Counts as ‘Species of Rehabilitation’ Open In the News Open April 8, 2022 3 minutes read Sequor Law At a hearing today in the MatlinPatterson Global Opportunities Fund debtors’ chapter 11 cases, Judge David Jones took under advisement the chapter 7 conversion motions filed by the foreign representative in the chapter 15 case of Varig Logistica SA, or VarigLog, and litigation plaintiff Gol Linhas Aéreas SA, referred to by its predecessor name, VRG. Judge Jones informed the parties that he would issue a decision on the conversion motions in the near term. HJDK Aerospacial S/A, which has asserted a $17.5 million claim against the debtors for failure of a portfolio company to repay certain loans in Brazilian civil courts, had also filed a statement in support of the conversion motion. Debtors’ counsel disputed the amount of HJDK’s claim at today’s hearing, saying that HJDK has only a $4.5 million claim. Judge Jones opened the hearing by informing the parties that his primary focus in considering the motions was whether the debtors had a “reasonable likelihood of rehabilitation” under the relevant provision of the Bankruptcy Code. Given the nature of the debtors’ business as investment vehicles for private equity investors, Judge Jones questioned whether using chapter 11 to wind down the investment vehicles by “clearing” the foreign litigation claims order to make payouts to investors and otherwise implement their business model was a “species of rehabilitation.” Judge Jones also said he would take into consideration whether staying in chapter 11 would result in a “substantial or continuing loss to or diminution” of the debtors’ estates. Judge Jones commented that it was “hard to see” how the administrative burn rate in the cases did not constitute some form of diminution, given the absence of revenues coming into the estates. Gregory Grossman of Sequor Law, counsel for the VarigLog foreign representative, said that the chapter 11 cases amounted to a “preplanned dissolution” of the debtors, and although that might be part of the debtors’ business model, this could not constitute a “rehabilitation” under the Bankruptcy Code. Grossman argued that treating such a preplanned dissolution as a rehabilitation under the Code would lead to “mischief” because companies could, prior to filing for chapter 11, modify their corporate governance documents to require dissolution by a date certain in order to pre-emptively defeat chapter 7 conversion motions. Tyler Robinson of Simpson Thacher, counsel for the debtors, argued that the rehabilitative purpose of filing the chapter 11 cases is to carry out the “intended purpose” of the debtors’ businesses, which “first and foremost” is to return capital to their investors. Robinson explained that the foreign litigation claimants had frustrated those efforts, ultimately causing the debtors to file the chapter 11 cases. Robinson said that in order to maximize the value of the estates, the debtors needed a “centralized process” for determining which parties held valid claims in order to ratably distribute estate assets. Robinson warned that it would be a “dangerous proposition” for the court to find that private equity funds and hedge funds should not be able to use chapter 11 to wind down their affairs. Robinson also argued that U.S. Supreme Court precedent supports the proposition that liquidation is an appropriate use of the chapter 11 process and that other courts have found a confirmable liquidating plan to be sufficiently rehabilitative to defeat a motion to convert. Arthur Steinberg of King & Spalding, counsel for VRG, argued that the debtors’ prepetition conduct justified conversion. Steinberg alleged that the debtors had covertly collateralized all their assets in favor of a nondebtor insider and transferred assets out of the estates prior to filing. Steinberg added that the debtors had no assets to liquidate, no revenue, no employees and “no public interest to protect.” According to Steinberg, the estates needed an estate fiduciary who is not “fronting for equity in the case” and that installing a chapter 7 trustee would cure the issue of “faithless fiduciaries” and satisfy the need for an independent investigator. Ralph E. Preite of Koutsoudakis & Iakovou, counsel to HJDK, told the court that after a decision by a Brazilian appellate court entered on Nov. 19, 2021, the appeals process had been exhausted and that the claim was therefore “final.” Elizabeth Curran of Schulte Roth & Zabel, conflicts counsel for the debtors, disagreed with Preite’s view that the litigation was over. According to Curran, the November 2021 decision related to a jurisdictional argument, and an appeal of the “full merits” of the matter is still pending. Curran added that there were still at least two additional levels of appeals available to the debtors in the Brazilian courts. To read 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 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.. 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...

Get to know Sequor Law's David Short, an anti-corruption and anti-fraud attorney who shares his path into international law, his commitment to making the world better, and his practice approach. Attorney Spotlight – Get to Know David Short Open Attorney Spotlight Open October 9, 2025 2 minutes read Sequor Law 1. What inspired you to pursue a law career? I don’t think that it was a matter of inspiration, but of choice – I wanted a career that would allow me to make the world a better place, and law was one of the ways that I thought I might do so. 2. Why did you choose the areas of law that you practice? Like many lawyers, it wasn’t entirely purposeful. I started as a generalist and focused on opportunities that were both challenging and rewarding. This naturally led to anti-corruption and anti-fraud work, in part because of the firms I came to and the people I worked with. 3. What skills do you draw upon when it comes to your specific practice areas? Writing, more than anything. Being able to clearly communicate ideas and principles in an organized, digestible way that is tailored to the recipient or recipients – whether a client, opposing counsel, colleague, or a particular judge – is invaluable. But a key part of that is rewriting – being able to adapt and refine someone else’s writing while trying to preserve their voice as much as possible. 4. What is the most rewarding part about your job? There is a quietly and deeply satisfying feeling at the realization that something I thought about and wrote has become part of the common law in some way. This happens in winning, of course, at least if the judge both rules in your favor and does it for the reasons that you proposed. But it can happen even on a loss – you can at least guide the court away from adopting a particularly bad interpretation of a law, even if the outcome is not what you hoped for. 5. Tell us about a mentor who made an impact on your career. Janice Platt, a senior staff attorney at the sixth circuit, was relentless in helping me improve my writing skills. Endless, continuous, and tailored feedback to make me as effective in different styles as possible. That was the foundation I needed to find my own voice as a lawyer, and it made me much better at understanding why courts use certain words or phrases. 6. If you weren’t practicing law, what would you be doing? Likely scientific research. It was graduate school or law school, but law school presented better career opportunities for me. 7. What might people be surprised to learn about you? I used to create mods for video games. Only one set of mods really took off, and that was for a relatively niche game, but I poured a couple thousand hours into that hobby over several years between learning the relevant modding commands, researching the underlying ideas I wanted to implement, working on pixel art, and then implementing and testing my ideas until they were ready for release. 8. What is a good book or article you read recently? I’m currently working my way through The Wind’s Twelve Quarters, by Ursula LeGuin. She’s a wonderful writer. A common theme through the short stories is how culture informs perception – even when a narrator isn’t unreliable, they still might misapprehend something because a difference that someone else might find important doesn’t matter (or doesn’t even exist) from the primary narrator’s point of view. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open 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.. 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...

Sequor Law's Leyza B. Florin, Andrew Dawson, and Greg Grossman examine how Florida's bankruptcy courts have become leaders in Chapter 15 asset recovery, published in Asset Recovery Magazine. Asset Recovery Magazine – Florida Leads the Way in Development of Chapter 15 Jurisprudence Open Legal Insights Open August 30, 2019 9 minutes read Sequor Law By Leyza B. Florin , Andrew B. Dawson and Greg S. Grossman Chapter 15 of the Bankruptcy Code has become a powerful asset recovery tool, and the Florida bankruptcy courts have been leading the way in this development. The Southern District of Florida has seen more Chapter 15 lings than any court other than the Southern District of New York, and many of these Florida Chapter 15 cases have been focused on assisting foreign trustees and liquidators track down and recover assets in the United States. Our team at Sequor Law in Miami has alone led over forty chapter 15 cases. While Chapter 15 is not a new tool—it is approaching its fourteenth birthday—it is, like many a teenager, under-appreciated and at times misunderstood. This is in part because Chapter 15 is not really “bankruptcy” in the sense that it does not create a bankruptcy estate or appoint a trustee. Instead, Chapter 15 provides a procedure to assist trustees administer foreign insolvency cases whose cross- border estates reach into the United States. The underappreciation also stems in part because Chapter 15’s substantive contours remain unknown, as it is primarily a procedural vehicle with minimal substantive constraints. Finally, because Chapter 15 requires U.S. bankruptcy courts to interface with foreign insolvency proceedings, there has been a great deal of uncertainty as to how open courts would be to cooperating with foreign insolvency proceedings, particularly when those foreign proceedings involve insolvency laws that are importantly different from U.S. bankruptcy law in substance and process. One common concern when Chapter 15 was rst enacted in 2008 was that U.S. bankruptcy courts might be reluctant to cooperate with foreign proceedings—or that they would cooperate inconsistently—in the face of foreign insolvency laws. Florida bankruptcy courts have in recent years played a key role in the development of Chapter 15. It is perhaps no surprise that courts here have been leaders in this arena, particularly as to cross-border insolvencies originating from Latin and South America. These courts have played important roles in establishing precedent for inter- American cooperation and assistance in this still-developing area of law. This article will discuss three recent decisions that highlight developments that may be of particular interest in asset recovery efforts. Chapter 15: A Bankruptcy without a Bankruptcy Estate Chapter 15 of the U.S. Bankruptcy Code provides a powerful tool kit for bankruptcy trustees and liquidators, but it is not itself a “bankruptcy” case. It does not open a full bankruptcy proceeding or create an estate, as would happen in a typical corporate bankruptcy case. Instead, Chapter 15 creates a process to assist the representative of a foreign proceeding, whether that be a debtor- in-possession, trustee, monitor, or other official. Chapter 15 permits that foreign representative to open a case in the bankruptcy court in order to seek assistance within the United States, with that assistance ranging from discovery orders to asset turnover orders. The bankruptcy court’s threshold function is to determine whether to recognize foreign proceeding, either a foreign main proceeding (i.e., one led where the debtor has its “center of main interests”) or foreign nonmain proceeding (i.e., one led where the debtor has an establishment). The court then has discretion to fashion assistance. Thus, there is no actual “debtor” in the Chapter 15 case and no estate is created. Whereas a traditional bankruptcy case can be a cost-intensive and disruptive endeavor—trustees are appointed, claims must be processed, assets liquidated and distributed, etc. —Chapter 15, in contrast, is not a traditional bankruptcy case. Rather, it is an ancillary case in aid of the foreign bankruptcy proceeding. It is thus more exible and less onerous than a traditional bankruptcy case. The main questions in these ancillary cases concern what aid is available to the trustees of the foreign insolvency cases. Chapter 15 provides some very speci c procedures designed to facilitate that cross-border assistance, e.g., authorizing judge-to-judge communications, and it provides a non-exclusive list of relief the U.S. bankruptcy court can grant to the foreign representative. As with any relatively new legislation, there is a lot of uncertainty as to the extent of that relief and to the standards for granting that relief. The uncertainty in Chapter 15 has an additional complicating factor due to its cross-border nature: would U.S. bankruptcy courts extend relief to foreign bankruptcy proceedings that differ from U.S. bankruptcy law and procedures? Three Florida cases brought by Sequor Law on behalf of foreign representatives, illustrate these issues and show how the Florida bankruptcy courts have helped fashion answers and standards. Who is the Foreign “Debtor”: In re Petroforte The first case is by now well known in the cross-border insolvency world so will receive only a cursory treatment; however, it would be remiss to exclude the case altogether as it has had important rami cations throughout the Chapter 15 jurisprudence. Petroforte was one of Brazil’s largest gas and ethanol distributors before entering bankruptcy. That liquidation had uncovered evidence of fraudulent transfers made to several entities, which provided the basis for the Brazilian court to enter ex parte an order extending the bankruptcy case to include the transferees. The Brazilian trustees commenced a Chapter 15 proceeding in the Southern District of Florida to seek discovery to assist the Brazilian liquidation. Some of these discovery targets objected on two main grounds: first, the argued that the Chapter 15 court should refuse to recognize the Brazilian extension order on public policy grounds; second, they argued that the foreign representative could not use Chapter 15 to order discovery against the transferees because they were not “debtors”. In what is now a widely-cited case (In re Petroforte Brasileiro de Petroleo Ltda. , 542 B.R. 899 (Bankr. S.D. Fla. 2015)), Judge Robert Mark rejected the first argument. He noted that U.S. courts grant a similar type of relief under the equitable remedy of substantive consolidation, and thus the Brazilian extension order was not substantively offensive as a matter of public policy. As to the ex parte nature of the proceedings, he acknowledged that this differs from U.S. procedure, which would have provided the remedy of substantive consolidation only upon an open hearing; however, he noted that the parties had the opportunity to be heard at the appellate level in Brazil. Consequently, the Brazilian proceeding did not offend U.S. public policy. As to the scope of discovery assistance under Chapter 15, the court had to interpret the scope of “debtor” under section 1521(a)(4), which provides that a court may authorize the “the examination of witnesses, the taking of evidence or the delivery of information concerning the debtor’s assets, affairs, rights, obligations or liabilities.” Judge Mark held that the entities that were subject to the Brazilian extension order were “debtors” subject to section 1521’s discovery powers. As to third parties who were not subject to the Brazilian extension order, the bankruptcy court in Petroforte held the trustee may be entitled to broad discovery to the extent the debtor is a majority stockholder in the non-debtor discovery target. Such broad discovery “allows the Trustee to determine whether the stock, which is an asset of the estate, has sufficient value to induce the Trustee to take control of the entity, and attempt to derive value by selling or liquidating the entity.” Broad Discovery Relief: In re SAM Industrias, S.A. In re SAM Industrias, S.A ., 2019 WL 1012790 (Bankr. S.D. Fla. March 1, 2019), built upon the foundation laid in Petroforte. In Petroforte, Judge Mark also suggested an alternative basis for ordering broad investigation into third party transactions in situations in which the third parties were actually involved in the fraudulent transfer or had otherwise engaged in wrongdoing: “The Trustee’s Supplemental Response failed to establish any actual involvement in the Plant Transaction or any wrongdoing by any of the Third Party Targets.” The court, though, did not further discuss this alternative ground. The issue arose in SAM Industrias when the foreign representative of the Brazilian liquidation led a Chapter 15 in the Southern District of Florida to investigate potential fraudulent transferees identified by the Brazilian courts. The Brazilian courts had found that the debtor had undisclosed interests in certain corporate entities, which he had concealed by transferring to family members. The foreign representative, accordingly, sought the Chapter 15 court’s assistance in examining these family members, who were not themselves debtors in Brazil, and in examining certain non-debtor corporate entities. The debtor objected to this assistance, arguing that the requested discovery assistance falls outside the scope of Chapter 15’s relief because the discovery targets were not debtors in Brazil. As to the family members, the Chapter 15 court examined the Brazilian court record carefully and concluded that discovery was appropriate as to those family members identified as transferees of the debtor’s property. The foreign representative, accordingly, was entitled to discover information related to the transferees’ corporate and financial affairs. As to the non-debtor corporate entities, the foreign representative was entitled to broad discovery not only as to those entities in which the debtor had a majority interest but also in those entities found to have participated in the debtor’s asset concealment scheme. Again, in defining the scope of relief available to the foreign representative, the Chapter 15 court examined the findings of the Brazilian courts. The Brazilian courts had found that the debtor had concealed assets through certain corporate pass- throughs owned and controlled by the debtor. The foreign representative was thus entitled to discovery related to these corporate pass-throughs. The foreign representative, though, was not entitled to discovery related to the non-debtor entities whose connections to the debtor had not yet been established in the Brazilian courts. Accordingly, the court concluded that the foreign representative is not entitled to “carte-blanche in his inquiries of non-debtors,” but that he is entitled to obtain information narrowly tailored “to discover ‘the legal entities created in purely fictional form’ which are part of a ‘complex corporate structure’ obscuring” the debtor’s ownership of corporate assets. The Foreign Revenue Rule: In re Dixon In re Dixon (Case No. 16-bk-02453, M.D. Fla. March 23, 2016) illustrates Chapter 15’s exibility, as it required the court to consider a novel application of the Foreign Revenue Rule to a Canadian trustee’s request for assistance. The Canadian debtors commenced proceedings in Canada under the Bankruptcy and Insolvency Act. The foreign representative subsequently led a Chapter 15 proceeding in the Middle District of Florida, seeking discovery assistance related to the debtor’s assets in the United States. When the foreign representative sought authorization to sell the debtors’ U.S. property in aid of the Canadian liquidation, the debtors led their own bankruptcy case under Chapter 13 of the Bankruptcy Code and later sought to dismiss the Chapter 15 proceedings. They argued that the Chapter 15 petition would violate the Foreign Revenue Rule. The Foreign Revenue Rule is “a long- standing common law rule that prevents the courts of one sovereign from enforcing or adjudicating tax claims from another sovereign.” Here, the debtors’ principal obligations were unpaid tax debts owed in Canada. Republic of Honduras vs. Philip Morris Companies, Inc., 341 F.3d 1253, 1260 (11th Cir. 2003). The issue, as urged by the debtors, was whether a Chapter 15 court could order to liquidate U.S. property for the purpose of satisfying Canadian tax claims. Judge Caryl Delano noted that the application of the Foreign Revenue Rule in the Chapter 15 context was a matter of first impression. Traditionally, in non- chapter 15 contexts, courts would refuse to permit a U.S. proceeding (whether in bankruptcy or not) to adjudicate tax claims under foreign laws. Section 1513(b)(2)(A) states that the language in subsection (a) and paragraph (1) “do not change or codify present law as to the allowability of foreign revenue claims or other foreign public law claims in a proceeding under this title.” Section 1513(b)(2)(B) goes on to say “[a]llowance and priority as to a foreign tax claim or other foreign public law shall be governed by any applicable tax treaty of the United States, under the conditions and circumstances specified therein.” The bankruptcy court ruled that the Revenue Rule did not apply because it was not being asked to “adjudicate or rule upon the validity or priority of the Canadian taxing authorities’ claims.” That matter, the court noted, would have to be decided in the Canadian proceeding. Second, the court noted that as a general matter, Chapter 15 courts are not in the business of adjudicating the validity of foreign claims. Finally, the court held that the case did not touch on any fundamental U.S. public policies, as it was simply a dispute as between the debtors and the foreign representative. In fact, the court found that it was promoting the public policies underlying not only Chapter 15 but the U.S.-Canada tax treaty. As an aside, the court noted that, to the extent the Canadian case involved more than just tax claims, that would further support its conclusion that the Foreign Revenue Rule does not apply. Conclusion These three Florida case descriptions illustrate how Chapter 15 of the Bankruptcy Code has elements of both bankruptcy law and more traditional asset recovery tools. When considering whether Chapter 15’s toolbox could help in the asset recovery effort, it appears the sun is shining in Florida’s bankruptcy courts. 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 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.. 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...

Sequor Law's Leyza B. Florin, Chair of the Florida Bar's Business Law Section, leads an update to the Section's Pro Bono Best Practices Guide, highlighting attorneys' responsibility to serve. Business Law Section Updates Pro Bono Guide Open In the News Open August 7, 2020 4 minutes read Sequor Law If Spider-Man can do it, then so can the Business Law Section and other Florida lawyers. That’s the logic of section Chair Leyza B. Florin , explaining the section’s long-standing web of support for pro bono activities, just reinforced with the new revision of its Pro Bono Best Practices Guide. “It goes back to the Peter Parker principle, ‘with great power comes great responsibility,’” Florin said. But there are also hard numbers and practical reasons. The section’s mission is “to promote business-friendly initiatives” and pro bono falls squarely into that mission, she said, because studies have shown each dollar of civil legal services provided to low-income clients yields $7.19 of economic benefits. Carlos Sardi, chair of the section’s Pro Bono Committee, said the new guide covers the Supreme Court’s 2017 approval of Bar Rule 4-6.6, which addresses conflicts of interest affecting short-term pro bono representations. The Pro Bono Best Practices Guide has been posted for free on the Florida Business Law website . “One of the things that we’re trying to instill not only in our members but to all of our colleagues is there are tools out there that can help” in providing pro bono, Sardi said. “It’s a starting point for such efforts or to retool and rethink their pro bono policy to encourage their colleagues to do the right thing and provide pro bono services to the most-needy members of our community. “This tool provides the mechanisms all the way from intake to representation, even if it’s on a short term based on the safe harbor in Rule 4-6.6.” The updating is the first freshening of the guide since 2014, Sardi said, and was prompted in part by the Supreme Court’s adoption in 2017 of Bar Rule 4-6.6. “It provides a safe harbor for those who provide short-term, limited legal services [such as at a legal clinic]…for them to be able to provide services on a short term without being on the hook for representing a client,” he said. “We included that new rule into our guide basically for our members to be aware of the impact it has on your internal checking and intake mechanism that you use to run conflict searches.” According to a November 15, 2017, Bar News column by Assistant Ethics Counsel Hey-Yen Cam Bailey the rule “applies to lawyers who provide short-term limited legal services through a program sponsored by a nonprofit organization, court, government agency, bar association, or ABA-accredited law school. Although attorney-client relationships are still established through these programs, neither the lawyer nor client expect the relationship to last beyond that short-term representation. Under the rule, a lawyer participating in these programs will only be subject to Rules 4-1.7 and 4-1.9(a), conflict of interest rules regarding current and former clients, if the lawyer knows that the representation involves a conflict of interest.” The guide addresses intake, initial interviews, engagement letters, opening a file, deciding what is pro bono, the safe harbor in Rule 4-6.6, how pro bono credit is determined, using nonlawyer employees for pro bono cases, determining if costs will be charged, and dividing fees, costs, and awards that may come from a pro bono case. Also covered are having law firm staff dedicated to pro bono work to satisfy the guidelines in Rule 4-6.1(c) and getting such plans approved by circuit pro bono committees. Aside from presenting the considerations in outline form, there is also extensive commentary on important points and issues. Working with legal aid offices and pro bono circuit committees is important, Sardi said, because “you can always be more sensitive to the immediate pro bono needs in your community. “The pro bono needs may be completely different in northern Florida than in the southern part of our state. Obviously that connectivity with the local area is very important in setting your pro bono firm-wide policy.” Support for pro bono is in the DNA of the section, as shown by the handbook and other efforts. “I’ve been an active member of the Business Law Section since 2006. I don’t remember a time where the Pro Bono Committee was not present and pro bono services were not promoted,” Sardi said. “One of the missions of the Pro Bono Committee is to achieve 100% participation of our members. Last year, when we took on the task of reviewing how well we are doing, well over 60% of our members in one way or another provided pro bono services. It’s a work in progress but it’s a fantastic achievement by our members. We continue to promote our pro bono heroes and services.” Members may also take to heart Florin’s point that effective pro bono is good for the business community. She cited a 2016 study, Economic Impacts of Civil Legal Aid Organization in Florida conducted by The Resource for Great Programs, which found that in 2015 civil legal aid had garnered for Floridians $120.6 million in Social Security benefits, $70.7 million in Medicare and Medicaid payments, and $2.7 million in veterans benefits. That in turn boosted business income by $274.8 million, created 2,243 jobs and avoided $2.9 million in emergency shelter costs, $50.6 million in foreclosure costs, and $6.9 million in domestic violence costs. “Pro bono work provides a benefit to the Florida legal community that may not otherwise be available,” Florin said. “The members of our section have skills that are in short supply and in great need.” 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 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.. 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...

Sequor Law welcomes Robert B. Kearney to its Washington, D.C. office. A former judicial clerk and U.S. Senate staffer, he focuses on asset recovery, bankruptcy, and creditors' rights. Sequor Law Welcomes Attorney Robert B. Kearney to Its Washington, D.C. Office Open Firm News Open November 19, 2024 2 minutes read Sequor Law Sequor Law, a distinguished international law firm specializing in international litigation, asset recovery, representing victims of financial fraud, and cross-border insolvency, proudly announces the addition of Robert B. Kearney to its team. Based in the firm’s Washington, D.C. office, Robert’s experience in corporate bankruptcy, commercial litigation, and insolvency further strengthens Sequor Law’s commitment to providing high-caliber legal services to its clients. Robert joins Sequor Law following clerkships with the Honorable James J. Tancredi at the U.S. Bankruptcy Court for the District of Connecticut and the Honorable Erik S. Atas at the Maryland Circuit Court for Baltimore City. His impressive background includes a tenure with the U.S. Senate Committee on the Judiciary, where he assisted on key legal and policy issues. Robert’s practice will focus on asset recovery, bankruptcy, and creditors’ rights, bringing an added depth to Sequor Law’s expanding capabilities in these areas. “Robert’s impressive experience in both bankruptcy courts and on the policy front adds a valuable perspective to our firm,” said Tara J. Plochocki, Partner in charge of Sequor Law’s Washington, D.C. office. “We are excited to welcome him and look forward to the contributions he will make to our clients and our team.” Gregory S. Grossman, a Founding Shareholder of Sequor Law, echoed this enthusiasm, stating, “Robert exemplifies the traits that are the hallmarks of the lawyers at Sequor Law. Our motto — relentless, global, pursuit – is a perfect description of what Robert will bring to our growing DC office and the clients of the firms.” **** Sequor Law is an international law firm focusing on representing victims of financial fraud, including sovereign governments and state-owned enterprises, public and non-public companies, insolvency practitioners, and all manner of clients in the areas of asset recovery, financial fraud, cross-border insolvency, and international litigation and arbitration. www.sequorlaw.com. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open 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.. 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...

Sequor Law's Cristina Vicens Beard and Andrew Dawson examine the Second Circuit's ruling on Madoff trustee clawback actions against non-US entities and international comity principles. Asset recovery column: The long arm of the liquidating trustee – Madoff trustee reaches offshore transferees Open Legal Insights Open June 13, 2019 1 minute read Sequor Law Christina Vicens Beard and Andrew Dawson / Sequor Law June 13, 2019 Sequor Law attorney Cristina Vicens Beard and of counsel Andrew Dawson consider the implications for non-US entities of the US Second Circuit’s recent ruling that international comity principles should not stop clawback actions by the trustee of Bernie Madoff’s investment firm. Read full article here Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open 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.. 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...

Sequor Law adds renowned international arbitration practitioner Giovanni Angles to its team. With experience in ICSID, ICC, and UNCITRAL forums, he strengthens the firm's global dispute resolution capabilities. Sequor Law Taps Recognized Arbitration Leader Giovanni Angles to Strengthen Global Practice Open Firm News Open April 25, 2025 2 minutes read Sequor Law Miami, Florida – April 25, 2025 – Sequor Law, a leading international disputes firm, proudly announces the addition of Giovanni Angles to its expanding International Arbitration practice. Angles’ arrival marks another milestone in the firm’s dynamic growth and further strengthens its deep bench of cross-border dispute resolution professionals. The firm’s team includes the highest number of Florida Bar board-certified attorneys in one firm in International Litigation and Arbitration in the state. A seasoned international arbitration practitioner, Angles has represented sovereigns, multinational corporations, and high-net-worth individuals in complex arbitrations across multiple forums, including ICSID, ICC, ICDR, and UNCITRAL. Fluent in English and Spanish, he brings a strategic and multicultural lens to every matter, with a focus on business torts, investor-state claims, treaty interpretation, and multijurisdictional enforcement of awards. In addition to his legal acumen, Angles is recognized globally for his leadership in the field. He is a Past President of the International Arbitration Commission at AIJA (International Association of Young Lawyers) and sits on the Board of Directors of the Miami International Arbitration Society (MIAS), reflecting both his credibility and commitment to advancing the profession. “Giovanni’s arrival is both a reflection of where we are and where we’re headed,” said Edward H. Davis Jr., Founding Shareholder of Sequor Law. “His depth of experience and leadership in the international arbitration space amplifies our capabilities and reinforces our position as a forward-thinking firm leaning into its growing international arbitration practice.” Angles will take a lead role in driving Sequor Law’s International Arbitration practice, further strengthening the firm’s global footprint in cross-border matters and strategic dispute resolution. His joining comes during a period of sustained growth for the firm, which is widely regarded for its innovative approach and trailblazing work in asset recovery, financial fraud, cross-border insolvency, multijurisdictional disputes, and international litigation and arbitration. To learn more about Sequor Law and its internationally recognized team, visit www.sequorlaw.com *** Headquartered in Miami and with an office in Washington, D.C., Sequor Law is an international law firm focusing on representing victims of financial fraud, including sovereign governments and state-owned enterprises, public and non-public companies, insolvency practitioners, and all manner of clients in the areas of asset recovery, financial fraud, cross-border insolvency, and international litigation and arbitration. www.sequorlaw.com . Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open 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.. 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...

Sequor Law welcomes Alain M. Acanda, an attorney with experience in commercial litigation, § 1782 discovery proceedings, and international arbitration, strengthening the firm's asset recovery practice. Sequor Law Welcomes Attorney Alain M. Acanda to Its Expanding Asset Recovery Team Open Firm News Open May 12, 2025 2 minutes read Sequor Law Miami, Florida – May 13, 2025 – Sequor Law, a leading international firm in asset recovery and cross-border litigation, is pleased to announce the addition of Alain M. Acanda as an attorney, further strengthening the firm’s capabilities in asset recovery, creditors’ rights, and complex commercial litigation. Alain joins Sequor Law with a strong background in litigation from both state and federal court, with experience that includes drafting motions and pleadings in commercial and institutional arbitration and 28 U.S.C. § 1782 discovery proceedings. Before joining Sequor Law, Alain worked with specialist litigation firms where he handled matters involving commercial and international disputes and intellectual property. Alain earned his J.D. cum laude from Florida International University College of Law, where he was an active member and judge for the Moot Court team and served as vice president of both the Hispanic Law Student Association and the Caribbean Student Bar Association. He also received recognition as Best Respondent Brief and Quarterfinalist at the 2023 Billings, Exum & Frye National Moot Court Competition. “We continue to attract top-tier talent to meet the increasing demand for our services worldwide,” said Edward H. Davis Jr., Founding Shareholder of Sequor Law. “Alain brings exceptional research and writing skills, along with a sharp understanding of asset recovery frameworks.” “His addition reflects our commitment to growing a deep bench of multilingual, globally-minded litigators,” added Gregory S. Grossman, Sequor Law Founding Shareholder. Admitted to practice in Florida and the U.S. District Court for the Southern District of Florida, Alain is fluent in both English and Spanish, enhancing the firm’s ability to serve a diverse and international client base. This appointment marks another milestone in Sequor Law’s strategic growth as it continues to represent sovereign governments, insolvency practitioners, financial institutions, and corporations across jurisdictions. For more information, visit: www.sequorlaw.com *** Sequor Law is an international law firm focusing on representing victims of financial fraud, including sovereign governments and state-owned enterprises, public and non-public companies, insolvency practitioners, and all manner of clients in the areas of asset recovery, financial fraud, cross-border insolvency, and international litigation and arbitration. www.sequorlaw.com . Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open 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.. 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...

Chambers & Partners ranked firm with Band 1 attorneys in Asset Recovery and Bankruptcy Litigation. ICC FraudNet member. Board-certified in international litigation. Relentless. Global. Pursuit. Sequor Law is an 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. 25 25 25 years years years After years of experience in powerhouse firms, Founding Shareholders Edward H. Davis Jr. and Gregory S. Grossman recognized a distinct need in the international Asset Recovery and Cross-Border Insolvency market for more specialized legal services. In 2000, they founded the specialized international firm now known as Sequor Law. The firm grew quickly, bringing together an award-winning, multilingual team that serves as thought leaders in the field. With a proven record of success, Sequor Law represents fraud victims, court-appointed fiduciaries, domestic and international corporations and financial institutions, and government entities. The firm also draws on a powerful global network of professionals and resources that work relentlessly for our clients. Certified Fraud Examiner (CFE) since 2004 Issued by Association of Certified Fraud Examiners (ACFE): Certified Fraud Examiners understand how fraud is committed, detected, and prevented. Individuals who have obtained the CFE credential understand the underlying factors that motivate people to commit fraud and are trained to identify red flags that indicate evidence of fraud and fraud risk. They are able to trace fraudulent transactions, interview suspects to obtain information and confessions, write investigation reports, advise clients on their findings, and testify at trial. Global Restructuring Review Sequor Law is proud to be recognized in Global Restructuring Review’s GRR 100, featuring the world’s leading firms for cross-border restructuring and insolvency matters. The Florida Bar - International Litigation and Arbitration Sequor Law has become the Florida firm with the most attorneys who are board certified in International Litigation and Arbitration . Approved by the Florida Supreme Court in 2020, International Litigation and Arbitration is a new certification program that recognizes attorneys’ special knowledge, skills, and proficiency in various areas of law, professionalism, and ethics in practice. Chambers and Partners Chambers provides insights into the world’s leading lawyers, based on extensive research and interviews with clients, attorneys, and third-party experts. Chambers and Partners’ USA and Litigation Support Guides ranked the firm: Band 2 – Bankruptcy Litigation , 2020, 2021, 2022, 2023, 2024, 2025. Band 2 – Asset Tracing & Recovery (Global-Wide) , 2020, 2021, 2022, 2023, 2024. Band 1 – Asset Tracing & Recovery (Global-Wide) , 2025. Individual Achievements: Gregory S. Grossman : Bankruptcy Litigation Leyza B. Florin: Bankruptcy Litigation and Bankruptcy Restructuring Fernando J. Menendez, Jr .: Bankruptcy Litigation Edward H. Davis, Jr. : Bankruptcy Litigation Who's Who Legal Who’s Who Legal recognized Sequor attorneys and professionals as: Thought Leaders Global Elite – Asset Recovery, 2020, 2021, 2022, 2023, 2024, 2025. Expert – Asset Recovery, 2020, 2021, 2022, 2023, 2024, 2025. Thought Leaders and Experts are selected based on client and peer recommendations, the attorney’s track record, and a rigorous evaluation process. No more than 5% of practitioners in any WWL global practice area guide are selected as Global Elite Thought Leaders. Latinvex Top Latin American Law Firms Latinvex 2022 and 2021 Top Latin American Law Firms named Sequor Law among the top 50 firms and ranked the firm #3 in Litigation . Shareholder Leyza Florin Blanco was also named among the Top 100 Female Lawyers in Latin America by Latinvex in the 2022, 2023, 2024, and 2025 Editions. Nyana Abreu Miller was also named among the Top 100 Female Lawyers in Latin America in the 2023 Edition. Based on an exclusive Latinvex survey, these annual rankings are determined using a combination of factors, including value, prominence and scope of work, and references among clients and peers. Super Lawyers - Rising Stars Lists Ten Sequor attorneys have been selected to the Super Lawyers or Rising Stars lists . Most recently, Christopher A. Noel was named a Rising Star in the 2023 and 2025 editions of Super Lawyers, as well as Juan J. Mendoza in the 2025 edition. Selection is based on a careful nomination and vetting process using peer evaluations and independent research. Only lawyers in the top 5% of their state are selected as Super Lawyers, and only 2.5% of top lawyers, who are 40 years old or younger or in practice for 10 years or less, are selected as Rising Stars. Best Lawyers® - Best Law Firms Sequor Law earned 11 rankings across several of the firm’s key practice areas in the U.S. News’ 2020 and 2025 edition of “Best Lawyers®” “Best Law Firms”. U.S. News’ “Best Lawyers®” “Best Law Firms” is a leading survey of lawyers worldwide that ranks firms in 75 practice areas nationally. A tiering system is used to rank overall scores based on quantitative and qualitative data Best Lawyers® Sequor Law is pleased to announce that more than four of the firm's partners were recognized in multiple categories in the 2025 32nd Edition of The Best Lawyers of America®. Founding Shareholder Edward Davis was recognized in Bet-the-Company Litigation , Commercial Litigation , International Arbitration – Commercial and Litigation – Banking and Finance , Founding Shareholder Gregory Grossman was recognized in Bankruptcy and Creditor Debtor Rights / Insolvency and Reorganization Law and Litigation – Bankruptcy , Shareholder Leyza B. Florin was recognized in Commercial Litigation and Litigation – Bankruptcy and Shareholder Fernando Menendez was recognized in Bankruptcy and Creditor Debtor Rights / Insolvency and Reorganization Law . Leyza Florin Blanco was also recognized as one of Florida’s Top 100 Lawyers and Top 50 Women Lawyers in 2023. LawDragon 500 Since 2020, four Sequor shareholders have been recognized in the Lawdragon 500 Leading U.S. Bankruptcy and Restructuring Lawyers . Edward H. Davis, Jr. was recognized in the areas of Creditors’ Rights, Asset Recovery, and Financial Fraud Litigation; Gregory S. Grossman, was recognized in the areas of Bankruptcy & Insolvency Litigation, including Cross-Border matters; Leyza Florin Blanco was recognized in the areas of Bankruptcy & Financial Restructuring, particularly in litigation; and Arnoldo “Arnie” Lacayo was recognized in the areas of Financial Fraud, Asset Recovery, and International Insolvency Litigation. Lawdragon’s 2020 U.S. guide recognized 294 U.S.-based lawyers in the Global guide due to their work in cross-border cases and 500 U.S. all-stars, whose focus was primarily national. Latin Lawyer Edward H. Davis, Jr. was named among 100 Leading Lawyers by LatinLawyer in 2023. LatinLawyer is the definitive source of news, analysis, and research for the regional legal community. South Florida Legal Guide South Florida Legal Guide named Sequor Law’s shareholders among the region’s Top Lawyers and Up and Comers in 2021 . Top Lawyers are nominated by their peers based on their extensive experience and outstanding record of success. Also peer-nominated, Up and Comers are distinguished as the next generation of leaders in the South Florida legal communities with a minimum of 10 years in their practice. Accolades Sequor Law attorneys are regularly recognized nationally and internationally for our extensive experience and global network within the industry. The following are some awards and distinctions Sequor Law and our attorneys have been honored to receive: We cross borders.

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 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.. 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...