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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 Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..

Sequor Law's Arnoldo Lacayo, Daniel Coyle, and Alejandro Anselmi explore how traditional asset recovery instruments can be adapted to trace and recover cryptocurrency assets globally. Global: An Introduction to Asset Tracing & Recovery (Law Firms) Open Legal Insights Open August 10, 2021 11 minutes read Sequor Law By Arnoldo B. Lacayo , Daniel M. Coyle , Alejandro Anselmi Facing the Cryptocurrency Challenge With Existing Asset Recovery Instruments: Give Us the Tools and We Will Finish the Job The coronavirus pandemic has caused extreme damage between 2020 and 2021. The human toll itself is staggering: the United States recently surpassed six hundred thousand COVID-19 deaths. In other parts of the world, 1.2 million lives lost across Europe, over 500,000 in South-East Asia, and more than 100,000 in Africa have contributed to an approximate worldwide total of over 4 million deaths since the beginning of the pandemic. Moreover, the genesis of new variants on different continents threatens the amazing progress made on the development of vaccines and the mass distribution of these scientific wonders throughout the world’s populations. Even though healthcare workers, medical practitioners, and the scientific community must be praised for facing the viral threat in several hundred million infections and engineering at least six different vaccines to combat a novel virus, the community of legal practitioners has addressed the secondary effects of the world’s shut-down: battered economies and economic sectors and increased opportunities for fraudulent practices. This article will endeavour to provide a bird’s eye view of two of the most significant challenges that have emerged from the changed landscape of the post-COVID world economy: the growing ubiquity of cryptocurrencies and corresponding opportunities for their misuse. However, considering that the impacts of the catastrophes the world experienced in 2020 and 2021 are still playing out today, the consequences of economic contraction and recovery and the role of cryptocurrencies for U.S.-based legal practitioners are anything but clear and will depend largely on the motivations of a wide array of actors, ranging from federal and state governments, the ordinary consumer, and potential fraudsters seeking opportunities from the uncertainties of a changed world. Insolvencies and Stock Market Disappointments in Early 2020 Benefitted Cryptocurrencies The economic crisis spurred by the shutdowns in 2020 abruptly ended the longest economic expansion in U.S. history, which had been ongoing since the passing of the Emergency Economic Stabilization Act of 2008 and the American Recovery and Reinvestment Act of 2009. As a result, public company bankruptcy filings reached their highest level in the past decade, with corporations in the service and oil and gas industries leading the drive in these numbers. Moreover, given the dive in stock prices during March 2020, investors of all kinds flocked to the cryptocurrency market, while banks, money managers, and other financial entities more readily embraced digital assets like cryptocurrencies. Despite the astounding rebound in the stock market by December 2020, to say nothing about the elemental disconnect between success stories on Wall Street and the pain felt by most on Main Street, digital currencies like Bitcoin and Ether saw their value exponentially increased, 300% and 470% respectively. These sharp increases in value, albeit unstable, further incentivized the use of these virtual currencies for everything from purchasing a sandwich at Subway and for more nefarious purposes, like facilitating ransomware payments, scamming and defrauding amateur investors, money laundering, financing terrorism, or drug trafficking on the dark web. International asset recovery and insolvency practitioners must study these trends and develop effective strategies to better serve their clients and help combat fraudulent practices worldwide. However, considering that traditional cash assets were already highly mobile, the decentralized nature of many cryptocurrencies facilitating the unregulated movement of these at even larger scales will make the illegitimately achieved gains from criminal enterprises or fraudulent transfers exponentially more difficult to find and recover. Typically, the victims of fraudulent transfers or other criminal enterprises that succeed in recovering their lost assets depend on both the ability of asset recovery practitioners to analyse, identify, and attach stolen assets within existing legal frameworks in disparate jurisdictions where scammers and fraudsters decide to hold or hide their ill-gotten gains. As has become well known, the biggest challenge for insolvency and asset recovery lawyers in cases involving digital assets like cryptocurrencies involves the dual challenge of discovering where these assets may be hidden, plus the second challenge of deploying either untested or poorly adapted legal mechanisms available throughout the world to freeze these assets. The Cryptocurrency Angle: Still Relatively New, But Already Wreaking Havoc Currently, many regulations acting on the exchange and use of cryptocurrencies are found at the state level. Some states, like Wyoming, have moved to facilitate the use and transaction of digital assets. For instance, the Wyoming legislature created a new type of “bank” that will serve businesses by allowing investors to deposit their digital assets. Other states have exempted cryptocurrencies from state securities laws and accepted the payment of taxes in cryptocurrency. Other jurisdictions remain apprehensive about the use of digital currencies and have either altogether prohibited the use of cryptocurrencies when paying for government services or simply warned their citizens about the risks of investing in cryptocurrency. The federal government in the United States has yet to comprehensively address the regulation of cryptocurrency, despite apparent recognition that embracing cryptocurrencies will prove important for the nation’s future infrastructure and its role in the vanguard of the market’s development worldwide. On one hand, apprehension or unwillingness to act on cryptocurrencies is best illustrated by the Securities Exchange Commission’s (“SEC”) recent announcement that it will not address virtual currency regulation in the short term despite their meteoric rise in value and transactions. On the other hand, the Anti-Money Laundering Act of 2020 (“AML Act”) made several changes to the Bank Secrecy Act (“BSA”), through which it modified the BSA’s definitions to encompass regulation of cryptocurrency and other digital assets. The AML Act achieved these modifications by referring to cryptocurrency and digital assets as “value that substitute for currency or funds,” perhaps to cast as wide a net as possible in recognition of the highly fungible nature of the market for digital assets and cryptocurrency. Similarly, administrative action through federal agencies, like the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”), has resulted in proposed rulemaking in 2020 and 2021. For instance, FinCEN’s proposed regulation, pursuant to the aims of the BSA, seeks to establish requirements for banks and money services businesses transacting virtual currencies and other digital assets with legal tender status. New requirements under the proposed regulation would demand banks and money service businesses to submit reports, maintain records, and verify the identities of customers involved in transactions of virtual currencies and digital assets. However, FinCEN’s proposed regulation has not yet cleared the requisite administrative procedures to come into force. Meanwhile, the U.S. House of Representatives approved a bipartisan effort to legislate digital assets. If approved by the Senate and signed by the President, the Eliminate Barriers to Innovation Act of 2021 would establish a working group, composed of members of the SEC and the Commodity Futures Trading Commission (“CFTC”), tasked with facilitating collaboration between the government and the private sector and clarifying when the SEC has jurisdiction over digital assets as securities or when the CFTC would have authority when digital assets are categorized as commodities. Nonetheless, some policymakers worry that suddenly promoting too much regulation will eliminate incentives for investors and consumers to develop the market. In the meantime, what was once a trickle of queries and consultations for asset recovery specialists relating to losses associated with digital assets (or where ill-gotten gains may have been converted into digital assets) has grown to a steady stream and portends to grow even further. To be sure, for some victims the losses are material and are causing real financial pain and damage. What Can Courts and Practitioners Do? Mechanisms to recover digital currencies are limited because of the very nature of cryptocurrencies. Digital currencies were created with the singular purpose of avoiding the influence of any central or official authority. For instance, cryptocurrencies are designed as a peer-to-peer electronic cash system. Cryptocurrency traders on decentralized exchanges benefit from the lack of an official entity that regulates all digital currency transactions because there is no need to confirm the credentials of other traders with a payment processor when conducting a transaction. On decentralized platforms, only a particular owner may access and dispose of their digital asset because no central authority exists that can exercise control over a particular cryptocurrency wallet to preserve or help recover ill-gotten proceeds. Meanwhile, cryptocurrency wallets hosted on centralized exchanges may be subject to government regulatory oversight, requiring wallet owners to provide identifying information. Public addresses, the equivalent of bank accounts in the digital currency world, can only be accessed and controlled by private keys linked to that address. As long as the owner of the cryptocurrency maintains their private key secret, no one and no governmental authority is able to access their funds, even in official proceedings. Consequently, the only way to access funds that have been converted into crypto assets is to gain access to the owner’s digital asset wallet with a private key. The U.S. Federal Trade Commission (“FTC”) reports that the allure of increased anonymity in cryptocurrency transactions (as opposed to traditional cash deals) has led to a rise in scams since October 2020. According to the FTC, approximately 7,000 people have reported losses totalling more than $80 million, nearly twelve times the number of reported cases in 2019. Another increasingly popular tool in the repertoire of fraudsters and online criminals that have adopted cryptocurrency is the utilization of ransomware attacks against companies and institutions with weak IT systems. Cybersecurity has become more difficult to maintain during the coronavirus pandemic because many workers are working from home, using personal internet connections to access delicate institutional mainframes. Coupled with the benefits of decentralized digital currencies, cybercriminals are more easily able to attack weak security systems and evade law enforcement and other financial regulations when they demand payment in cryptocurrency, providing a blueprint for white-collar criminals seeking to hide assets including during and after judicial proceedings. The Colonial Pipeline ransomware attack during May 2021 was a wakeup call for both cybercriminals and asset recovery practitioners. After Colonial paid $4.4 million in Bitcoin, the Department of Justice was able to trace the ransom money through blockchain analysis. The FBI was able to recover approximately $2.3 million of the original payment, demonstrating to the legal community that it is possible to recover assets criminally taken, even if in cryptocurrency form. Nonetheless, while clearly a victory for law enforcement, it still presents a challenge for asset recovery specialists practising primarily through civil process. It is still unclear precisely how the FBI was able to retrieve the funds from the cryptocurrency wallet containing them because the government has not revealed how it was able to obtain the private key. In private civil proceedings, insolvency and asset recovery lawyers dealing with fraudulent transfers likely will not have the international cooperation, technical resources or subpoena power available to the FBI to quickly uncover information or to freeze the cryptocurrency, much less to access cryptocurrency wallets to obtain an injunction or once a court order or judgment against fraudulent transferors has been issued. At the pre-trial stage, asset recovery efforts face two significant challenges. First, cryptocurrency wallets on decentralized exchanges are identified only by the public address and there is no way to discover the identity of the owner of the wallet unless the exchange is required to—and does—maintain “Know Your Customer” information. Therefore, those seeking to recover stolen assets converted into digital currency and “hidden” must first conduct blockchain analysis, like the DOJ’s Ransomware and Digital Extortion Task Force efforts during the Colonial Pipeline investigation. A blockchain analysis involves reviewing the public ledger, where all cryptocurrency exchanges are recorded, to trace the transactions of the ransom payment and subsequent transactions the fraudsters use to attempt to secrete the digital assets that are the proceeds of the fraud or theft. The analysis identifies suspicious transactions that are linked with the fraudster’s attempts to disguise the flow of the cryptocurrencies. This step might prove costly for some practitioners who might not have in-house access to the necessary quality of cyber and forensics teams available to the government, forcing some practitioners dealing with a cryptocurrency hunt to outsource blockchain investigations to third-party commercial entities. Further complicating issues for international asset recovery practitioners there is a stark absence of internationally recognized rules governing the collection and handling of digital evidence. This greatly benefits cyber-criminals and fraudsters because the speed with which private asset recovery specialists and law enforcement are able to trace and gather required evidence to litigate or prosecute (as opposed to simply recovering ransom pay, like in the Colonial Pipeline situation) is likely to be slower than criminals and debtors can move and hide their assets. This is especially true given that cryptocurrency is truly global in nature, and cross-border asset recovery is dependent upon principles of comity where domestication/recognition of non-final orders may be non-existent and domestication/recognition of final orders is time-consuming and expensive. However, as with other asset recovery efforts, not all hope is lost when confronted with a sophisticated fraudster or criminal. The key thing is to identify the institutions and entities that can be compelled to produce evidence, which will allow for the trace or forensic review. This is where knowledgeable professionals and courts can assist victims seeking to uncover and recover digital assets. Second, ensuring that a court preserves its jurisdiction over a defendant (i.e., preventing flight or further transfer and secreting of assets) and avoiding judgment-proofing tactics through unmonitored transactions presents a wholly different set of challenges for practitioners. Luckily, insolvency and asset recovery specialists can seek preliminary injunctive relief to prevent debtors from judgment-proofing tactics by inhibiting the movement of assets or can seek equitable remedies such as the naming of a trustee, receiver, or other disinterested third-party office holder to take control of a vehicle used to hold an asset or perpetuate a fraud. Additionally, courts can issue different kinds of orders, like various injunctions, worldwide freezing orders, and Spartacus orders, which can help prevent wrongdoers from further transacting ill-gotten gains. Furthermore, the availability of these judicial tools largely depends on applicable law, which is an issue further complicated by the nature of digital assets, which makes it so that victims of cyber-criminals have a more limited ability to prevent an absconding defendant from secreting the digital assets beyond the jurisdiction with the most effective legal tools. Perhaps this area most strongly requires an international effort to recognize cross-border asset recovery operations involving cryptocurrencies. A legislative approach like the Model Law on Cross-Border Insolvency (UNCITRAL), which has promoted a coordinated legal regime that facilitates cooperation between nations in international insolvency cases, may be what is required to afford victims and asset recovery practitioners an effective way to tackle the novel practicalities of dealing with digital currency recoveries. At the post-judgment stage, some of the instruments to recover stolen cryptocurrency assets (or those converted into digital currencies) are writs of execution, replevin, and levy as well as in personam orders compelling individuals to act with certain assets under pain of contempt However, while these tools may be powerful to recover properties and enforce money judgments, these mechanisms are difficult to use where judgment creditors are not in possession of private keys necessary to access cryptocurrency wallets or where the debtor has absconded the court’s jurisdiction with digital assets and the private keys to access them. Even where judgment debtors are threatened with contempt of court for failure to comply with judicial orders, judgment debtors fleeing U.S. jurisdictions with large amounts of digital assets may not be sufficiently motivated to comply given the ease with which they can easily move, transfer, and otherwise hide their digital wealth abroad. Amendment of statutory provisions and tools for post-judgment recovery to better address crypto-assets must be considered in the immediate future. The Uncertainties of the Mission Require Even More Preparation While it appears that cryptocurrencies are here to stay, providing bona fide investment opportunities to professional and amateur traders alike, as well as a regulation and law enforcement evasion tool for cybercriminals, their stability and value in the long run remains uncertain. In late May 2021, a widespread cryptocurrency crash eliminated approximately $1 trillion in market value, with Bitcoin losing close to 30% of its value. The causes of the crash, statements from Tesla’s CEO Elon Musk and crackdowns in China over use of digital currencies, strongly suggest that the market remains exceedingly sensitive to pop-culture and regulatory influences. While cryptocurrencies have increasingly become more mainstream, they are still relegated to the edges of financial systems because they are still not widely accepted as legal tender and are limited to private transactions between individuals online. However, more and more nation-states and municipalities are voicing openness to potentially accepting these digital currencies for official business. Whether cryptocurrencies will become the main form of payment for all transactions in the future is an altogether different question that remains to be comprehensively answered and may also depend on the environmental impact of the mining of cryptocurrency, which is notoriously energy-intensive. However, that does not mean that insolvency and asset recovery practitioners can afford to wait for the question to be settled. Given the current trends seen regarding the prevalence of cybercrime and its preferred method of payment, lawyers at the vanguard of fraud and cross-border asset recovery must contribute to the development of judicial tools and legislative frameworks that promote international cooperation and facilitate digital asset recovery. Developing these tools will allow the law and the courts to modernize with the times, placing cyber-crime victims, creditors, and practitioners on equal footing with online criminals, debtors, and the Internet. 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 Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..

Sequor Law promotes Joseph Rome to Counsel, recognizing his expertise in asset recovery, anti-corruption, international litigation, and cross-border insolvency across global jurisdictions. Sequor Law Announces Promotion of Attorney Joseph Rome to Counsel Open Firm News Open April 2, 2024 2 minutes read Sequor Law Miami, FL – April 2, 2024 – Sequor Law is proud to announce the promotion of Joseph Rome to the position of Counsel. Joseph, a talented attorney with the firm, has significantly contributed to Sequor Law, especially in the areas of asset recovery, corruption, proceeds of crime, international commercial litigation, and the enforcement of domestic and international judgments and arbitral awards. Joseph has represented a broad spectrum of clients, ranging from individuals and governments to entities involved in domestic and international judgment collection matters, cross-border insolvency proceedings under Chapter 15 of the U.S. Bankruptcy Code, actions to collect evidence for use in foreign proceedings under 28 U.S.C. § 1782, and various other commercial disputes. His practice encompasses a wide range of jurisdictions, showcasing his ability to navigate complex legal challenges across global landscapes. Before joining Sequor Law, Joseph served as an “A” level prosecutor for the Miami-Dade State Attorney’s Office, focusing on serious cases, including attempted murders, gun crimes, and serious sexual assaults. He has also worked for two AmLaw 200 law firms in New York and Miami, handling high-stakes litigation and arbitration matters for international corporations and high-net-worth individuals. Additionally, Joseph has contributed his expertise to externships with the Orleans Public Defenders and the U.S. Attorney’s Office for the Eastern District of New York, and a summer fellowship at the United Nations International Law Commission in Geneva. A graduate of New York University School of Law, Joseph has demonstrated a commitment to excellence throughout his career. He is fluent in English, Spanish, Mandarin, and Japanese, further enhancing his ability to serve a diverse clientele. Joseph is admitted to practice law in New York, Florida, S.D.N.Y, and the U.S. Courts of Appeals for the 1st, 5th, 6th, 9th, and 11th circuits. “Joseph’s promotion to Counsel reflects his outstanding legal expertise, dedication to our clients, and the substantial contributions he has made to the field of international law. He represents the high standards of professionalism and excellence we uphold at Sequor Law,” said Edward Davis, founding shareholder. Sequor Law’s commitment to fostering the growth and development of its attorneys is exemplified through Joseph’s progression within the firm. “His remarkable work ethic and comprehensive legal knowledge will continue to be tremendous assets to our firm and our clients,” added Founding Shareholder Gregory Grossman. For more information about Joseph B. Rome and Sequor Law, please visit www.sequorlaw.com. ****** Sequor Law is a Miami-based international law firm representing financial institutions, sovereign governments and state-owned enterprises, public and non-public companies, insolvency practitioners and individual clients in the areas of asset recovery, financial Fraud, Insolvency and financial services litigation. More information is available at www.sequorlaw.com Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..

Sequor Law's Arnoldo Lacayo represents the administrator of bankrupt Brazilian magazine publisher Minuano in a Chapter 15 filing in Florida to uncover assets hidden in the US by its former owners. Brazilian magazine group enters Chapter 15 in Florida Open In the News Open October 7, 2019 2 minutes read Sequor Law By Declan Bush The administrator of a bankrupt Brazilian magazine publishing company has filed for Chapter 15 protection to search for assets its old owners may have stashed in the US. Four entities – Minuano Comunicações e Produções Editorias, Diário de São Paulo Comunicações, Editora Fontana and Cereja Serviços de Midia Digital – filed a slew of documents before the US Bankruptcy Court for the Southern District of Florida dated 25 September. Arnoldo Lacayo , a partner at Sequor Law specialising in financial fraud and asset recovery cases, is the debtors’ counsel in Miami. In a declaration to the US court filed on 1 October, Brazilian administrator Joice Ruiz Bernier , of São Paulo firm AJ Ruiz Consultaria Empresarial, said the Minuano companies were part of a publishing group owned by Spanish businessman Mario Florencio Cuesta and his ex-wife Giane Viana Cuesta. The Cuestas divorced in 2012. Minuano was a big magazine publisher started in Brazil in 2004, which grew to include assets including longstanding newspaper Diario de São Paulo. The first of Minuano companies went bankrupt in São Paulo in April 2017 after a creditors’ petition seven months before, the court was told. The other debtors were added to the Brazilian proceeding in January 2018 when it emerged they were run out of the same office and had commingled funds. The debtors appealed the extension of the bankruptcy, but the Brazilian Court of Appeals in São Paulo affirmed it in June 2018. As further entities and individuals were brought into the bankruptcy proceedings, the court made an order freezing the Cuesta’s assets, and those of five others and four of their companies on 8 October 2018. By that stage, Bernier had already seized assets including a helicopter owned by the newspaper for the bankruptcy estate. Bernier said her investigations had revealed the Cuestas were the debtors’ ultimate beneficial owners and had instructed the group’s directors on how to proceed, despite not being identified as shareholders. “The Cuestas financed a lavish lifestyle through the use of the debtors’ assets, monetary and physical,” Bernier has told the US court in her declaration. “Investigations into the Debtors suggest that assets were diverted overseas to banks in Miami and New York.” She says she intends to investigate the nature and extent of any of the debtors’ activities and assets in the US, as well as any assets bought with their funds. A hearing has been set for 13 November. In the US Bankruptcy Court for the Southern District of Florida Minuano Comunicações e Produções Editorias, Diário de São Paulo Comunicações, Editora Fontana and Cereja Serviços de Midia Digital, case 19-23184-LMI Judge Laurel Isicoff Counsel to Minuano Sequor Law Partner Arnoldo Lacayo and attorney Bruno de Camargo in Miami In the Second Bankruptcy Court for the State of São Paulo Judge Marcelo Barbosa Sacramone Administrator to Minuano AJ Ruiz Consultoria Empresarial* Partner Joice Ruiz Bernier in São Paulo *Formerly Satiro e Ruiz Advogados Associados To view the original article, click here. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..

Sequor Law's Daniel Coyle explains how judgment creditors can recover assets by seizing a judgment debtor's own claims (choses in action) when other enforcement methods are unavailable. Your Recovery Is Mine: Enforcement of Judgments via a Judgment Debtor’s Claims Against Third Parties Open Legal Insights Open December 1, 2020 5 minutes read Sequor Law Authored By: Daniel M. Coyle – Sequor Law Introduction Asset Recovery and Judgment Satisfaction demands access to broad remedies and creative thinking. A Judgment Creditors’ efforts to enforce a judgment may be stymied by property exemptions, wage-garnishment exemptions, trusts, multi-member LLCs, and/or because the Judgment Debtor’s property is held by a tenancy-by-the-entireties (if this manner of holding property is recognized in the state). Judgment Creditors and their counsel should look to other assets that are available, such as claims (also called choses in action) held by Judgment Debtors against others. Black’s Law Dictionary (rev. 4th Ed. 1968) defines a chose in action as: A personal right not reduced into possession, but recoverable by a suit at law . . . A right to receive or recover a debt, demand, or damages on a cause of action ex contract or for a tort or omission of a duty. Seizure of Claims. In Florida, for instance, a Judgment Creditor may reach such property via Florida’s Proceedings Supplementary statute, Fla. Stat. §56.29. Subsection (6) of that statute provides that “a court may order any property of the judgment debtor, not exempt from execution, or any property, debt, or other obligation due to the judgment debtor, in the hands of or under the control of any person subject to the Notice to Appear, to be levied upon and applied toward the satisfaction of the judgment debt.” Thus, if a Judgment Debtor has sued a third party, the Judgment Creditor may seize the claim under Fla. Stat. § 56.29. Myd Marine Distrib., Inc. v. Int’l Paint Ltd., 201 So. 3d 843, 845 (Fla. 4th DCA 2016). See also Gen. Guar. Ins. Co. of Fla. v. DaCosta, 190 So. 2d 211, 213–14 (Fla. 3d DCA 1966) (decided under predecessor statute). Other states also permit Judgment Creditors to execute and levy upon these types of assets. See, e.g., Holt v. Stollenwerck, 56 So. 912, 913 (Ala. 1911); Wittenauer v. Kaelin, 15 S.W.2d 461, 462-63 (Ky. Ct. App. 1929); Rucks-Brandt Const. Corp. v. Silver, 151 P.2d 399, 400 (Okla. 1944); Lynn v. Int’l Bhd. of Firemen & Oilers, 90 S.E.2d 204, 206 (S.C. 1955); Maranatha Faith Ctr., Inc. v. Colonial Tr. Co., 904 So. 2d 1004, 1010 (Miss. 2004); Reynolds v. Tufenkjian, 136 Nev. Adv. Op. 19 (2020). Once the Judgment Creditor seizes or attaches the claim, the Judgment Creditor now becomes the plaintiff, or potential plaintiff, as if the claim had been voluntarily assigned to it. The Judgment Creditor thus has full discretion in how to manage litigation of the claim, including full settlement discretion, but also must fund litigation of the claim. Seeking an Equitable Lien on Claims for Personal Torts. However, in Florida, a Judgment Creditor may not levy and execute on a claim under section 56.29 if the claim is one for a “personal” tort or the claim is not assignable. Shaughnessy v. Klein, 687 So. 2d 43 (Fla. 2d DCA 1997). Personal torts are those claims that are personal to the plaintiff and that the plaintiff cannot assign, due to the personal relationship of the claim to the victim. Such torts include, but are not limited to, assault and battery, fraud, medical malpractice, (most) legal malpractice, intentional infliction of emotional distress, slander, and malicious prosecution. Forgione v. Dennis Pirtle Agency, Inc., 93 F.3d 758, 760 (11th Cir. 1996), certified question accepted, 689 So. 2d 1069 (Fla. 1997), and certified question answered, 701 So. 2d 557 (Fla. 1997); 21 C.J.S. Creditors’ Suits s 29. YOUR RECOVERY IS MINE: ENFORCEMENT OF JUDGMENTS VIA A JUDGMENT DEBTOR’S CLAIMS AGAINST THIRD PARTIES. ThoughtLeaders4 Fire Magazine • ISSUE 3 44 Other courts also recognize the same limitation. See, e.g., Certified Grocers of California, Ltd v. San Gabriel Valley Bank, 197 Cal. Rptr. 710, 715 (Ct. App. 1983); Blackmore v. Dunster, 274 P.3d 748, 752 (Mont. 2012); Reynolds v. Tufenkjian, 136 Nev. Adv. Op. 19 (2020). While a Judgment Creditor may not levy and execute upon these types of claims, a Judgment Creditor may use proceedings supplementary to request the Court to craft alternative relief: awarding the Judgment Creditor an equitable lien on the Judgment Debtor’s potential recovery. Although section 56.29 does not contain a specific provision addressing a Judgment Creditor’s right to an equitable lien on a Judgment Debtor’s claim, 56.29(6) states: The court may enter any orders, judgments, or writs required to carry out the purpose of this section, …”. Cases in Florida have already determined that a judgment creditor may obtain an equitable lien on a Judgment Debtor’s homestead property. Zureikat v. Shaibani, 944 So. 2d 1019, 1022 (Fla. 5th DCA 2006); Whigham v. Muehl, 511 So. 2d 717, 718 (Fla. 1st DCA 1987). Moreover, the case law interpreting section 56.29 states that Proceedings Supplementary “are equitable in nature and should be liberally construed” to provide the broadest relief to the creditor. Ferguson v. State Exchange Bank, 264 So.2d 867, 868 (Fla. 1st DCA 1972); Regent Bank v. Woodcox, 636 So.2d 885, 886 (Fla. 4th DCA 1994). Trial courts also have discretion in crafting appropriate relief for the benefit of the creditor. Myd Marine Distrib., Inc. v. Int’l Paint Ltd., 201 So. 3d 843, 844 (Fla. 4th DCA 2016). Thus a Judgment Creditor’s argument for an equitable lien on the proceeds of a lawsuit for a personal tort stands on solid ground. Other states have recognized similar concepts. See, e.g., Blackmore v. Dunster, 274 P.3d 748, 752 (Mont. 2012) (“Blackmore could petition the court to assign to Blackmore any proceeds from Dunster’s tort action in satisfaction of the judgment debt.”). Once the Court awards the equitable lien, similarly to an attorney’s charging lien, the Judgment Creditor must file the lien in the docket of the Judgment Debtor’s lawsuit to provide notice to the Court presiding over the Judgment Debtor’s lawsuit as well as the third party of the Judgment Creditor’s interest in the potential recovery. In contrast to the Judgment Creditor’s seizure of the claim, the filing of an equitable lien leaves the management of the claim, including the discretion on settlement decisions, with the Judgment Debtor. The Judgment Debtor also retains the obligation to fund the litigation. A potential drawback is that these factors, combined with the fact that some, most or all of the recovery will flow to the Judgment Creditor may result in the Judgment Debtor losing interest in pursuing the claim, and/or abandoning it entirely. A potential alternative to the equitable lien would be to monitor the lawsuit, and to timely serve a writ of garnishment upon the third party after the verdict. However, this has the drawback of increased administrative costs due to the need to constantly monitor proceedings, the need to coordinate with a potentially a third party who has nothing to gain by such cooperation and whose interests are still adverse to the Judgment Creditor and the need to time the writ of garnishment (with potential service requirement issues as the writ must be served on the third party, not its attorney in the case). Click here to read the original PDF Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..

Sequor Law's Christopher A. Noel speaks on international trends and high net worth matrimonial asset recovery at the 27th USMBA Annual Conference in Houston, Texas. Christopher A. Noel to Speak at the 27th USMBA Annual Conference Open Events & Speaking Open October 7, 2021 1 minute read Sequor Law Christopher A. Noel will be speaking on the International Trends and Family Law panel focusing on high net worth matrimonial asset recovery at the 27th USMBA Annual Conference in Houston, Texas on October 20th. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..

Sequor Law's Greg Grossman and Francis Curiel analyze the Eleventh Circuit's broad discovery ruling under Section 1782 in support of foreign bankruptcy proceedings, comparing it to Chapter 15. Eleventh Circuit Gives Green Light to Broad Discovery in Aid of Foreign Bankruptcies Open Legal Insights Open October 21, 2020 5 minutes read Sequor Law By Greg Grossman and Francis Curiel , Miami The Eleventh Circuit recently affirmed a district court’s broad grant of discovery for use in five foreign bankruptcy proceedings to which the discovery applicant was a creditor-party. This article will briefly examine how the (relaxed) standard set forth by this Section 1782 proceeding compares to the (less relaxed) standard set forth by two notable Chapter 15 cases. In re Petroforte, by now a well-known Chapter 15 case, involved the liquidation of one of Brazil’s largest gas and ethanol distributors. During the liquidation, the Brazilian trustee found evidence of fraudulent transfers made to several entities, which led the Brazilian court to extend the bankruptcy case to include the transferees. The Brazilian trustee commenced a Chapter 15 proceeding in the Southern District of Florida to seek discovery to assist the Brazilian liquidation. The discovery targets objected, arguing that the subpoenas sought broad financial information about the non-debtor targets that exceeded the limits of discovery under Section 1521(a)(4) and Rule 2004. When the court interpreted the scope of “debtor” under Section 1521(a)(4), it held, in part, that the entities that were subject to the Brazilian bankruptcy extension order were “debtors subject to Section 1521’s discovery powers; however, with regard to any third parties who were not subject to the extension order, the trustee was entitled to broad discovery only when the debtor was a majority stockholder in the non-debtor discovery target. In re SAM likewise dealt with a Chapter 15 proceeding stemming from a Brazilian bankruptcy, wherein the debtor concealed corporate interests by transferring property to family members. The foreign representative sought documents relating to non-debtors who the foreign representative alleged were relevant to his investigation and potential recovery of assets of the foreign estate. The court focused on whether the foreign representative exceeded the proper scope of Rule 2004 discovery. It found that the foreign representative was entitled to discovery relating to (1) the transferees and (2) the non-debtor corporate entities in which the debtor had a majority interest or in those entities already found by the Brazilian courts to have participated in the debtor’s asset concealment scheme. The foreign representative was not entitled to discovery relating to the non-debtor entities whose connections to the debtor had not yet been established in the Brazilian courts. The court further noted that the foreign representative’s inquiries of non-debtors were to be narrowly tailored. Notably, courts have analogized discovery under Chapter 15 with discovery under 28 U.S.C. § 1782. An incongruity may now exist when comparing Petroforte and In re SAM to the Eleventh Circuit’s recent case, In re Victoria. In March 2018, Victoria, LLC (Victoria) filed a § 1782 application in the Southern District of Florida, seeking discovery for use in five pending Russian bankruptcy proceedings to which Victoria was a creditor. The bankruptcy proceedings pertained to either (1) Iliya Likhtenfeld (the Debtor) or (2) his Russian companies. Victoria planned to object to the dischargeability of debt, but first needed proof that the Debtor failed to disclose his U.S. assets in the Russian bankruptcies. To do so, Victoria requested testimony and documents relating to corporate governance, banking, financing, money transfers, business transactions, accounting practices, and the like, from (1) the Debtor; (2) Florida banks with which the Debtor did business; (3) Florida entities that the Debtor allegedly owned or was affiliated with; and (4) individuals affiliated with the Florida entities. To support the existence of these affiliations, Victoria submitted Sunbiz corporate records. Some of these records showed that a woman—who lived at the same address as the Debtor—acted as (either current or former) manager and registered agent of two of the target Florida entities. Notably, the Debtor’s name appeared nowhere on the corporate records of these two Florida entities. Discovery was nonetheless granted for use in the Russian bankruptcies. The shared residence between the Debtor and the manager of these entities proved connection enough. Moreover, in support of its allegations that the subpoena targets were “closely related” to the Debtor, and that the targets “should have documents and knowledge of assets tied to the Russian [bankruptcies],” Victoria created and submitted a chart showing that many of the Florida entities shared the same address, principals, and registered agents. The entities were thus alleged to be interrelated to each other, although not all directly related to the Debtor himself. Victoria also submitted two noteworthy declarations in support of its Section 1782 application. The first declarant alleged “upon information and belief” that the Debtor had (1) caused his Russian companies to enter loan agreements with no intention of repaying; (2) failed to repay the borrowed money; and (3) transferred the borrowed money directly or indirectly to his family members or trusted representatives. Ultimately, the declarant “believed” that the borrowed funds found their way into the United States and were used, in part, to support the Debtor’s luxurious lifestyle in Florida. Neither the declarant nor Victoria submitted any other evidence to support these allegations or the connection between the borrowed funds and the Florida corporations. The second declarant stated that the Debtor had not disclosed any of his U.S. assets to the Russian bankruptcy court even though, “based on the [Sunbiz corporate records],” the Debtor owned and/or held officer positions in several Florida entities. Despite the tenuous connections between the Debtor and some subpoena targets, the court granted the broad financial discovery request with few limitations. The aforementioned evidence (or lack thereof) was enough for this grant of discovery to survive through the Eleventh Circuit, which upheld the district court’s ruling. The disconnect between the above cases poses a noteworthy question—is the Petroforte limitation too narrow in light of the In re Victoria grant of discovery? Victoria, as a creditor seeking discovery assistance for use in foreign bankruptcy proceedings, was granted wide-ranging discovery relating to (1) the Debtor; (2) the Debtor’s banks; (3) non-debtor associates; and (4) non-debtor entities, some of which showed little to no relation to the Debtor besides a shared address with the entities’ manager. The court did not inquire into the Debtor’s ownership interests (or transfer thereof). Nor did it probe into the foreign courts’ findings. Rather, the grant of discovery was based largely on uncorroborated beliefs and bare allegations. More so, it was based on reasonable suspicion that these target individuals and non-debtor entities were involved in the Debtor’s transfer of assets to the detriment of his creditors. In re Victoria has introduced a more relaxed standard that loosens the restrictions placed on discovery requests for use in foreign bankruptcies. In light of this recent development, perhaps it is time to reassess the scope of discovery in Chapter 15 cases, too. Click here to read the original PDF . Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..

Sequor Law'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 Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..

Arnoldo B. Lacayo discusses international financial fraud, cross-border asset recovery, and crypto-related fraud in his WWL Thought Leader Global Elite Q&A. WWL Thought Leader Global Elite - Arnoldo B. Lacayo Q&A Open Awards & Recognition Open August 25, 2022 2 minutes read Sequor Law Navigating the evolving landscape of international financial fraud and asset recovery demands not only legal expertise, but a deep understanding of how fraudsters think and where they hide assets. In his ThoughtLeaders interview, Sequor Law Shareholder Arnoldo B. Lacayo offers a candid, experience-driven look at the challenges and strategic considerations that shape modern cross-border asset recovery work. Lacayo, whose practice focuses on financial fraud , asset recovery and cross-border insolvency , frames asset recovery as a discipline defined by its complexity and the ingenuity of adversaries. He explains that one of the greatest hurdles in this space is the boundless creativity of fraudsters and the sophisticated networks — including legal allies and financial professionals — they can deploy to shield assets and frustrate efforts by victims and creditors. A significant portion of the discussion centers on the global dimension of these disputes, particularly the flow of capital from regions like South America into the United States. Lacayo notes that political and economic pressures abroad often push disputed assets into U.S. jurisdictions , creating frequent and complex cross-border issues for litigants and counsel alike. The article also addresses how Sequor Law stays ahead of emerging trends, including crypto-related fraud . Lacayo emphasizes that the firm’s investigative and discovery strategies are constantly evolving as new technologies mature, even as crypto fraud continues to pose unique challenges. Lacayo reflects on some of the most intricate matters he has handled, from the Stanford International Bank Ponzi case to the largest bank failure in Brazilian history — each illustrating the multifaceted nature of asset concealment and recovery . His insights reinforce the importance of flexibility, innovation, and thorough preparation in formulating legal strategies across jurisdictions . Looking ahead, Lacayo stresses that staying “one step ahead” of those who conceal assets will require both legal innovation and judicial receptivity to new methods of discovery and relief. He also offers practical advice to aspiring asset recovery lawyers, underscoring the value of specialization, professional networking, and continual professional development in this demanding area of practice. For a deeper dive into Lacayo’s perspectives and professional experiences, we invite you to read the full interview in the PDF below. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..

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 Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..

Stay informed with the latest news-insights from our law firm. Explore our news-insights and filter by category for tailored updates. Filter by Category: Attorney Spotlight Firm News In the News Case Results Legal Insights Events & Speaking Awards & Recognition Search News & Insights Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. 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. Firm News Jan 12, 2026 2 minutes read Sequor Law Expands Washington, D.C. Office with Addition of David Short Sequor Law expands its Washington, D.C. office with the addition of David Short, strengthening its cross-border litigation, asset recovery. Firm News Jan 12, 2026 2 minutes read Sequor Law Expands Asset Recovery Practice With the Addition of Attorneys Michael Hanlon and Noah Rosenblum Sequor Law is pleased to announce that Michael Hanlon and Noah Rosenblum have joined the firm as attorneys further strengthening the firm’s. Attorney Spotlight Oct 9, 2025 2 minutes read Attorney Spotlight – Get to Know David Short 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. Firm News Sep 30, 2025 3 minutes read Sequor Law Promotes Juan J. Mendoza, Christopher A. Noel, and Joseph B. Rome to Partner Sequor Law is proud to announce the promotion of attorneys Juan J. Mendoza, Christopher A. Noel, and Joseph B. Rome to partners of the firm. In the News Aug 13, 2025 1 minute read 9th Circuit Greenlights Expansive Use of Discovery Statute, Law360, Aug. 13, 2025 9th Circuit Greenlights Expansive Use of Discovery Statute, Law360, Aug. 13, 2025 Attorney Spotlight Jul 22, 2025 2 minutes read Attorney Spotlight – Get to Know Alejandro Rodriguez Vanzetti 1. What inspired you to pursue a law career? In college, I found myself drawn to international politics and law, especially as they relate. Attorney Spotlight Jun 2, 2025 3 minutes read Attorney Spotlight – Get to Know Giovanni Angles 1. What inspired you to pursue a law career? When I was a kid, my dad used a memorable analogy to explain the law—he compared it to the. Firm News May 12, 2025 2 minutes read Sequor Law Welcomes Attorney Alain M. Acanda to Its Expanding Asset Recovery Team Miami, Florida – May 13, 2025 – Sequor Law, a leading international firm in asset recovery and cross-border litigation, is pleased to. Firm News Apr 25, 2025 2 minutes read Sequor Law Taps Recognized Arbitration Leader Giovanni Angles to Strengthen Global Practice Miami, Florida – April 25, 2025 – Sequor Law, a leading international disputes firm, proudly announces the addition of Giovanni Angles to. Events & Speaking Apr 17, 2025 1 minute read Sequor Law at Paris Arbitration Week: Enforcing Arbitral Awards Against Sovereigns Sequor Law joins Paris Arbitration Week to discuss enforcing arbitral awards against sovereigns, focusing on legal strategy, treaty. Firm News Apr 15, 2025 2 minutes read Sequor Law Welcomes Attorney Alejandro Rodriguez Vanzetti to Its Growing International Asset Recovery Team Miami, Florida – April 15, 2025 – Sequor Law is pleased to announce that Alejandro Rodriguez Vanzetti has joined the firm as an attorney. Firm News Apr 9, 2025 2 minutes read Sequor Law Celebrates National Pet Day with Donation to PAWS4you Rescue Miami, Florida— In honor of National Pet Day, Sequor Law has made a charitable contribution to PAWS4you Rescue, a Miami-based nonprofit. Attorney Spotlight Apr 8, 2025 5 minutes read Attorney Spotlight – Get to Know Tara J. Plochocki 1. What inspired you to pursue a law career? I had been leaning towards being a lawyer since I was young, probably because of subtle. Case Results Feb 21, 2025 1 minute read U.S. Court Orders Citibank to Comply with Financial Discovery in Kazakhstan Judgment Enforcement In a recent ruling that is of particular interest to parties seeking financial discovery relating to foreign sovereigns, Sequor Law, acting. Load More

Explore Sequor Law's interactive case map tracking Chapter 15 cases, Section 1782 applications, and their international connections. Filter by jurisdiction and court Interactive Case Map Click on any of the Sequor shields to view our cases across the globe. Additional cases will be added on an ongoing basis. Chapter 15 Cases Section 1782 Cases List of Chapter 15 cases below Hide Sidebar Open Sidebar Currently Showing Representative U.S. Bankruptcy Chapter 15 Cases Filter by jurisdiction Filter by court No. Case Name Represented Recognition Date Court Jurisdiction Case Number Judge 114 In re: Conexión Ganadera Ltda., et al. Alfredo Ciavattone 29/07/2026 Bankr. S.D. Fla. Uruguay 26-17836 Scott M. Grossman 113 In re: Asociación Mutual Para Profesionales De La Fuerza E Infantes De Marina (Asomuffaa); Jorge Luis Penuela Soto; Samuel Castillo Robles; And Nayib Alberto Tapia Lian Rodolfo Andrés Yañez Otalora 24/07/2026 Bankr. S.D. Fla. Colombia 26-18292 Robert A. Mark 112 In re: Demar Instaladora Y Constructora, S.A. De C.V. Miguel Hernandez Quezada and Amada Josefa Ferrera Gunnersan 10/06/2026 Bankr. S.D. Texas Mexico 26-90523 Christopher Lopez 111 In re: San Agustin Energy Corp. Guillermo Antonio Tamayo Sanchez 13/05/2026 Bankr. S.D. Fla. Panama 26-14331 Corali Lopez-Castro 110 In re: RTI Limited (In Liquidation) Alan Roberts and James Pirie 10/04/2026 Bankr. S.D. Fla. Jersey 26-11695 Erik P. Kimball 109 In re: Rental Coins Tecnologia Da Informação Ltda. Átila Sauner Posse Sociedade de Advogados 22/12/2025 Bankr. S.D. Fla. Brazil 25-23659 Corali Lopez-Castro 108 In re: Tiner Empreendimentos e Participações S.A., et. al F. Rezende Consultoria e Administração Judicial 16/01/2026 Bankr. S.D. Fla. Brazil 25-22720 Peter D. Russin 107 In re: Banco Master, S.A., et. al Eduardo Felix Bianchini 08/01/2026 Bankr. S.D. Fla. Brazil 25-24568 Scott M. Grossman 106 In re: Panagiotis Stavropoulos a/k/a Peter Stavropoulos Grant Thornton Limited 07/01/2026 Bankr. S.D. Fla. Canada 25-24201 Mindy A. Mora 105 In re: Phoenix Global DMCC Ryan Jarvis and John Johnston 14/11/2025 Bankr. S.D. Fla. British Virgin Islands 25-21716 Laurel M. Isicoff 104 In re: Phoenix Pte. Ltd Ryan Jarvis and John Johnston 14/11/2025 Bankr. S.D. Fla. British Virgin Islands 25-21718 Laurel M. Isicoff 103 In re: Phoenix Commodities Pvt. Limited Ryan Jarvis and John Johnston 14/11/2025 Bankr. S.D. Fla. British Virgin Islands 25-21713 Laurel M. Isicoff 102 In re: Global Fidelity Bank Global Fidelity Bank 03/06/2025 Bankr. S.D. Fla. Cayman Islands 25-14799 Mindy A. Mora 101 In re: Allbank, Corp. AllBank, Corp. 12/05/2025 Bankr. S.D. Fla. Panama 25-13609 Robert A. Mark 100 In re: Rontan Eletro Metalúrgica Ltda., And Rontan Telecom Comércio De Telecomunicações Ltda Campi Serviços Empresariais Ltda. 13/03/2025 Bankr. S.D. Fla. Brazil 25-11421 Scott M. Grossman 99 In re: Natural Capital Ltd. Liquidators of Natural Capital Ltd. 26/02/2025 Bankr. S.D. Fla. Cayman Islands 25-10662 Mindy A. Mora 98 In re: Ojuolape Arcade Ltd. (In Liquidation) Jason Ainge, Paul Stanley, and Robert Armstrong 02/01/2025 Bankr. M.D. Fla. United Kingdom 24-06357 Tiffany P. Geyer 97 In re: Abayomi Adegbuyi-Jackson Jason Ainge, Paul Stanley, and Robert Armstrong 02/01/2025 Bankr. M.D. Fla. United Kingdom 24-06356 Tiffany P. Geyer 96 In re: Funmilayo Ojuolape Adegbuyi-Jackson Jason Ainge, Paul Stanley, and Robert Armstrong 02/01/2025 Bankr. M.D. Fla. United Kingdom 24-06355 Tiffany P. Geyer 95 In re: 1MDB Energy Holdings Limited Angela Barkhouse and Toni Shukla 29/03/2024 Bankr. S.D. Fla. British Virgin Islands 24-11469 Robert A. Mark 94 In re: Platinum Global Luxury Services Limit Angela Barkhouse and Toni Shukla 29/03/2024 Bankr. S.D. Fla. British Virgin Islands 24-11468 Robert A. Mark 93 In re: Aabar International Investments PJS Limited Angela Barkhouse and Toni Shukla 29/03/2024 Bankr. S.D. Fla. British Virgin Islands 24-11467 Robert A. Mark 92 In re: Blackrock Commodities (Global) Limited Angela Barkhouse and Toni Shukla 29/03/2024 Bankr. S.D. Fla. British Virgin Islands 24-11466 Robert A. Mark 91 In re: Alsen Chance Holdings Limited Angela Barkhouse and Toni Shukla 29/03/2024 Bankr. S.D. Fla. British Virgin Islands 24-11465 Robert A. Mark 90 In re: BWA BRASIL TECNOLOGIA DIGITAL LTDA Laspro Consultores Ltda. 01/02/2024 Bankr. S.D. Fla. Brazil 23-19826 Mindy A. Mora 89 In re: ISAK HENRY GABAY Kevin John Hellard, Nicholas William Nicholson, and Prashan Patel 19/01/2024 Bankr. S.D.N.Y. United Kingdom 23-11871 Michael E. Wiles 88 In re: Gam Empreendimentos E Participações S.A., And Florida Paulista Açúcar E Etanol S.A., Nexgenesis Holdings Ltda., Gencomm Financial Services do Brasil Ltda., Gencomm Internet Services do Brasil Ltda., and Gencomm Logistics Services do Brasil Ltda. 17/01/2024 Bankr. S.D.N.Y. Brazil 23-20364 Scott M. Grossman 87 In re: AAX SINGAPORE PRIVATE LIMITED Angela Barkhouse and George Kimberley Leck 30/06/2023 Bankr. S.D. Fla. Cayman Islands ,Singapore 23-14347 Peter D. Russin 86 In re: AAX ASIA PRIVATE LIMITED Angela Barkhouse and George Kimberley Leck 30/06/2023 Bankr. S.D. Fla. Cayman Islands ,Singapore 23-14346 Peter D. Russin 85 In re: ATOM HOLDINGS, Angela Barkhouse and George Kimberley Leck 30/06/2023 Bankr. S.D. Fla. Cayman Islands ,Singapore 23-14343 Peter D. Russin 84 In re: PJSC PLATINUM BANK Victor Volodymyrovich Novikov 05/05/2023 Bankr. S.D. Fla. Ukraine 23-12421 Scott M. Grossman 83 Tinto Holding Ltda.: (Brazil) Brazilian Liquidators 07/04/2023 Bankr. S.D. Fla. São Paulo (Brazil) 23-11719 Mindy A. Mora 82 In re: Anatoly Leonidovich Motylev Kevin Hellard, Robert Starkins, and Nick Nicholson 28/03/2023 Bankr. S.D. Fla. United Kingdom 23-10717 Scott M. Grossman 81 In re: Mirror Trading International (PTY) LTD, Chavonnes Badenhorst St Clair Cooper 20/03/2023 Bankr. S.D. Fla. South Africa 23-11046 Peter D. Russin 80 In re: Tonon Bioenergia S.A., Tonon Holding S.A., and Tonon Luxembourg S.A. Orlando Geraldo Pampado 06/03/2023 Bankr. S.D. Fla. São Paulo (Brazil) 23-10878 Erik P. Kimball 79 In re: Envestio SI OÜ Andres Hermet 02/02/2023 Bankr. S.D. Fla. Estonia 22-19961 Mindy A. Mora 78 In re: Chapeco Companhia Industrial de Alimentos S.A. Chapter 15 and S.A. Industria e Comercio Chapeco Brazilian Liquidators 28/12/2022 Bankr. S.D. Fla. Santa Catarina (Brazil) 22-18876 Peter D. Russin 77 In re: Brazen Sky Limited BVI Joint Liquidators 05/10/2022 Bankr. S.D. Fla. British Virgin Islands 22-16802 Robert A. Mark 76 In re: Aabar Investments PJS Limited BVI Joint Liquidators 05/10/2022 Bankr. S.D. Fla. British Virgin Islands 22-16802 Robert A. Mark 75 In re: Tanore Finance Corporation BVI Joint Liquidators 05/10/2022 Bankr. S.D. Fla. British Virgin Islands 22-16803 Robert A. Mark 74 In re: Blackstone Asia Real Estate Partners Limited BVI Joint Liquidators 05/10/2022 Bankr. S.D. Fla. British Virgin Islands 22-16805 Robert A. Mark 73 In re: Vasco Investment Services SA BVI Joint Liquidators 05/10/2022 Bankr. S.D. Fla. British Virgin Islands 22-16808 Robert A. Mark 72 In re: Selune Limited BVI Joint Liquidators 05/10/2022 Bankr. S.D. Fla. British Virgin Islands 22-16810 Robert A. Mark 71 In re: Pacific Rim Global Growth Limited BVI Joint Liquidators 05/10/2022 Bankr. S.D. Fla. British Virgin Islands 22-16812 Robert A. Mark 70 In re: Affinity Equity International Partners Limited BVI Joint Liquidators 05/10/2022 Bankr. S.D. Fla. British Virgin Islands 22-16815 Robert A. Mark 69 In re: Bridge Global Absolute Return Fund SPC Cayman Joint Liquidators 05/10/2022 Bankr. S.D. Fla. Cayman Islands 22-16816 Robert A. Mark 68 In re: Nexgenesis Holdings LTDA., et al Brazilian Liquidators 17/06/2022 Bankr. S.D. Fla. São Paulo (Brazil) 22-14043 Laurel M. Isicoff 67 In re: SRC Strategic Resources Limited BVI Joint Liquidators 19/05/2022 Bankr. S.D. Fla. British Virgin Islands 22-12654 Robert A. Mark 66 In re: Bright Oriande Limited BVI Joint Liquidators 19/05/2022 Bankr. S.D. Fla. British Virgin Islands 22-12655 Robert A. Mark 65 In re: SRC International (Malaysia) Limited BVI Joint Liquidators 19/05/2022 Bankr. S.D. Fla. British Virgin Islands 22-12656 Robert A. Mark 64 In re: Dingway Investment Limited Hong Kong Joint Liquidators 02/03/2022 Bankr. S.D. Fla. Hong Kong 22-10648 Laurel M. Isicoff 63 In re: Leonardo Rozenblum Trosman and Fabian Elias Rozenblum Gorel Uruguayan Joint Liquidators 08/10/2021 Bankr. S.D. Fla. Uruguay 21-18199 Laurel M. Isicoff 62 In re: Motociclo, S.A. Uruguayan Joint Liquidators 08/10/2021 Bankr. S.D. Fla. Uruguay 21-18193 Laurel M. Isicoff 61 In re: Oceanroad Global Services Limited, Holdwave Trading Limited (jointly administered) UK Joint Liquidators 05/08/2021 Bankr. S.D. Fla. United Kingdom 21-16133 Laurel M. Isicoff 60 In re: KG Manhattan 126 Finance Limited BVI Joint Liquidators 14/07/2021 Bankr. S.D.N.Y. British Virgin Islands 21-11080 Michael E. Wiles 59 In re: Exential Investments, Inc. BVI Joint Liquidators 30/06/2021 Bankr. S.D. Fla. British Virgin Islands 21-15203 Robert A. Mark 58 In re: FCI Markets Inc. BVI Liquidator 11/06/2021 Bankr. S.D. Fla. British Virgin Islands 21-14743 A. Jay Cristol 57 In re: Talal Qais Abdulmunem Al Zawawi UK Joint Trustees 06/05/2021 Bankr. M.D. Fla. United Kingdom 21-01251 Lori V. Vaughan 56 In re: Performance Insurance Company SPC Cayman Islands Joint Liquidators 15/04/2021 Bankr. S.D. Fla. Cayman Islands 21-12609 A. Jay Cristol 55 In re: PJSC Bank Finance and Credit Ukrainian Foreign Representative 08/12/2020 Bankr. S.D. Fla. Ukraine 20-22241 A. Jay Cristol 54 In re: Magazine Incorporações S.A., et al. (M. Grupo) Brazilian Judicial Administrator 08/10/2020 Bankr. S.D. Fla. Brazil 20-19746 Laurel M. Isicoff 53 In re: Trium Bank & Trust Limited Antigua & Barbuda Receiver 02/10/2020 Bankr. S.D. Fla. Antigua and Barbuda 20-19637 A. Jay Cristol 52 In re: Aircraft Solutions Lux V-B SARL Luxemburg Bankruptcy Administrator 20/04/2020 Bankr. S.D. Fla. Luxembourg 20-12589 Laurel M. Isicoff 51 In re: MacDoel Investment Ltd. BVI Liquidators 21/01/2020 Bankr. S.D. Fla. British Virgin Islands 19-26547 A. Jay Cristol 50 In re: Kildare Finance Ltd. BVI Liquidators 21/01/2020 Bankr. S.D. Fla. British Virgin Islands 19-26545 A. Jay Cristol 49 In re: Durant International Corp. BVI Liquidators 21/01/2020 Bankr. S.D. Fla. British Virgin Islands 19-26542 A. Jay Cristol 48 In re Darren Bernard McCormick UK Joint Trustees 27/12/2019 Bankr. M.D. Fla. Newcastle Upon Tyne (UK) 19-10768 Catherine Peek McEwen 47 In re: Ji-Chuen Jason Tsai UK Trustee 16/12/2019 Bankr. S.D. Fla. Leeds (UK) 19-25250 Robert A. Mark 46 In re: Changtel Solutions UK Limited UK Liquidator 16/12/2019 Bankr. S.D. Fla. Leeds (UK) 19-25248 Robert A. Mark 45 In re: Brasagro Fertilizantes Minerais Ltda. and Petrocal Industria e Comercio de Cal S A Brazilian Judicial Administrator 10/12/2019 Bankr. S.D. Fla. Mato Grosso (Brazil) 19-23832 A. Jay Cristol 44 In re: Minuano Comunicações e Produções Editorias Ltda., et al. Brazilian Judicial Administrator 18/11/2019 Bankr. S.D. Fla. São Paulo (Brazil) 19-23184 Laurel M. Isicoff 43 In re: São Fernando Açúcar e Álcool Ltda., et al. Brazilian Judicial Administrator 20/09/2019 Bankr. S.D. Fla. São Paulo (Brazil) 19-21256 A. Jay Cristol 42 In re: Schahin Holdings, S.A., et al. Brazilian Judicial Administrator 21/08/2019 Bankr. S.D. Fla. São Paulo (Brazil) 19-19932 Robert A. Mark 41 In re: Knijnik Participações S.A., et al. Brazilian Judicial Administrator 20/08/2019 Bankr. S.D. Fla. São Paulo (Brazil) 19-19817 Robert A. Mark 40 In re: Hans Werner Bachman German Insolvency Liquidator 20/08/2019 Bankr. M.D. Fla. Karlsruhe (Germany) 19-02092 Michael G. Williamson 39 In re: Smar Equipamentos Industrias, Ltda., et al. Brazilian Judicial Administrator 28/03/2019 Bankr. S.D. Fla. São Paulo (Brazil) 19-12734 Robert A. Mark 38 In re: Silisten Trading Limited BVI Joint Liquidators 22/03/2019 Bankr. S.D. Fla. British Virgin Islands 19-13723 Laurel M. Isicoff 37 In re: Marangoni Tread Latino America Industria e Comercio de Artefatos de Borracha Ltda. Brazilian Judicial Administrator 13/03/2019 Bankr. S.D. Fla. Minas Gerais (Brazil) 19-12070 Laurel M. Isicoff 36 In re: Viação Itapemirim S.A. et al. Brazilian Judicial Administrator 28/12/2018 Bankr. S.D. Fla. São Paulo (Brazil) 18-24871 Robert A. Mark 35 In re: SAM Industrias S.A., et al. Brazilian Judicial Administrator 06/12/2018 Bankr. S.D. Fla. Rio de Janeiro (Brazil) 18-23941 Robert A. Mark 34 In re: Privilege Wealth Management Limited Gibraltarian Joint Liquidators 09/10/2018 Bankr. S.D. Fla. Gibraltar 18-20346 Laurel M. Isicoff 33 In re: Privilege Wealth One Limited Partnership UK Joint Liquidators 15/09/2018 Bankr. S.D. Fla. London (UK) 18-19845 Laurel M. Isicoff 32 In re: R.R. Donnelley Argentina, S.A. Argentine Liquidator 25/01/2018 Bankr. S.D. Fla. Buenos Aires (Argentina) 18-10862 Robert A. Mark 31 In re: Junie Conrad Omari Bowers UK Liquidator 09/01/2018 Bankr. S.D. Fla. London (UK) 18-10298 Robert A. Mark 30 In re: Andrew Nathaniel Skeene UK Liquidator 09/01/2018 Bankr. S.D. Fla. London (UK) 18-10301 Robert A. Mark 29 In re: World Financial Group, Inc. (Denied) BVI Joint Liquidators 24/10/2017 Bankr. S.D. Fla. British Virgin Islands 17-22869 A. Jay Cristol 28 In re: Mabe Brasil Eletrodomesticos Ltda. Brazilian Judicial Administrator 29/09/2017 Bankr. S.D. Fla. São Paulo (Brazil) 17-21906 A. Jay Cristol 27 In re: Alberto Samuel Chang Rajii Chilean Liquidator 25/08/2017 Bankr. S.D. Fla. Santiago (Chile) 17-20788 Laurel M. Isicoff 26 In re: GFI Consultants Limited UK Liquidator 07/08/2017 Bankr. S.D. Fla. London (UK) 17-20003 A. Jay Cristol 25 In re: MMX Sudeste Mineração S.A. Brazilian Judicial Administrator 12/06/2017 Bankr. S.D. Fla. Minas Gerais (Brazil) 17-16113 Robert A. Mark 24 In re: Companhia Albertina Mercantil e Industrial; Ventura Energetica Ltda., Santuario Participacoes Ltda., and Luzeiro Agroindustrial Ltda. Brazilian Judicial Administrator 28/04/2017 Bankr. S.D. Fla. São Paulo (Brazil) 17-15463 Robert A. Mark 23 In re: Banca Turco Romana S.A. Romanian Judicial Administrator 06/04/2017 Bankr. S.D. Fla. Bucharest (Romania) 17-12995 A. Jay Cristol 22 In re: Onix Capital S.A. Chilean Liquidator 02/12/2016 Bankr. S.D. Fla. Santiago (Chile) 16-26082 Laurel M. Isicoff 21 In re: Cinque Terre Financial Group, Limited BVI Liquidator 27/04/2016 Bankr. S.D.N.Y. British Virgin Islands 16-11086 James L. Garrity, Jr. 20 In re: Douglas Dixon Canadian Trustee 23/03/2016 Bankr. M.D. Fla. Quebec City (Quebec) 6-02453 Caryl E. Delano 19 In re: Viação Area São Paulo S.A. Brazilian Judicial Administrator 02/07/2015 Bankr. S.D. Fla. São Paulo (Brazil) 15-22091 Robert A. Mark 18 In re: Probank S.A., Probank Participações S.A., Via Telecom S.A., Via Participações S.A. Brazilian Judicial Administrator 23/12/2014 Bankr. S.D. Fla. Minas Gerais (Brazil) 14-37790 A. Jay Cristol 17 In re: Banco Cruzeiro Do Sul S.A. Brazilian Judicial Administrator 04/06/2014 Bankr. S.D. Fla. São Paulo (Brazil) 14-22974 Laurel M. Isicoff 16 In re: Industria de Alimentos Nilza S.A. Brazilian Judicial Administrator 30/05/2014 Bankr. S.D. Fla. São Paulo (Brazil) 14-22549 Robert A. Mark 15 In re: Mark Charles Richardson UK Joint Liquidators 30/04/2014 Bankr. M.D. Fla. London (UK) 14-04875 Carle E. Delano Currently Showing Applications for Judicial Assistance Under 28 U.S.C. § 1782 Select jurisdiction Select court No. Case Name Foreign Jurisdiction Date Obtained Court 43 In re: Frasers Group plc United Kingdom 21/11/2023 S.D.N.Y. 42 In re: Frasers Group plc United Kingdom 20/09/2023 S.D.N.Y. 41 In re: Anatolie Stati Moldova 05/12/2022 S.D.N.Y. 40 In Re: Application Of B. High House International Pte Ltd Singapore 21/01/2022 M.D. Fla. 39 In Re Application Of Diamond Family Foundation Zurich 23/12/2022 S.D.N.Y. 38 In Re Application Of Vinmar Overseas, Ltd Indonesia 12/08/2020 S.D.N.Y. 37 In re Application of BITO Storage Solutions US, Inc. Duisburg (Germany) ,Hamburg (Germany) ,Lueneburg (Germany) 31/07/2020 S.D.N.Y. 36 In re YS GM MARFIN II LLC, et al. Malaysia ,London (UK) 07/04/2020 S.D.N.Y. 35 In re Application of Newbrook Shipping Corporation, et. al. South Africa,Nevis 27/03/2020 D. Md. 34 In Re Application of Inmobiliaria Tova, S.A. and Mini Depositos Denpar Venezuela 31/01/2020 S.D. Fla. 33 In re Application of Motransa S.A. Ecuador 21/01/2020 S.D. Fla. 32 In re Application of Nicholas James Poulton, et. al. Cayman Islands 18/12/2019 M.D. Fla. 31 In re: Mario Mena Marqua Guatemala 06/12/2019 S.D. Fla. 30 In re Application of Tianrui (International) Holding Company Limited Cayman Islands 26/11/2019 S.D.N.Y. 29 In re Application of Geribá Participações SPE-1 Ltda. Brazil 09/09/2019 S.D.N.Y. 28 In re: Maria Fernanda Rigail Pons Ecuador 13/08/2019 S.D. Fla. 27 In re Application of Vinicius Coutinho Consultoria e Perícia S/S Ltda., Judicial Administrator of the Sao Fernando Group Mato Grosso do Sul (Brazil) 12/04/2019 D. Kan. 26 In re Application of Monica Maria Mellao Silveira Mello São Paulo (Brazil) 30/11/2018 S.D. Fla. 25 In re: Application of Maria Esther Tabak Argentina 31/05/2018 S.D.N.Y. 24 In re Application of William McKeeva Bush Cayman Islands 12/04/2018 S.D. Fla. 23 In re Application of Diana M. Gonzalez Venezuela 13/02/2018 S.D. Fla. 22 In re Application of Attorney General of Trinidad and Tobago Trinidad and Tobago 26/10/2017 S.D. Fla. 21 In re Application of Attorney General of Trinidad and Tobago Trinidad and Tobago 28/09/2017 S.D.N.Y. 20 In re Application of Cozumel Caribe S.A. de C.V. Mexico 12/06/2017 D. Minn. 19 In re Application of GD Holdings, et al. Guatemala 20/12/2016 S.D. Fla. 18 In re Application of Albert John Martin Abela, et al. United Kingdom 29/09/2016 S.D.N.Y. 17 In re Application of Mohammad Awar Fared Al-Saleh United Kingdom ,Bahamas ,Switzerland ,Jordan ,Dominican Republic 11/12/2015 N.D. Tex. 16 In re Application of Andrea A. Abrams Venezuela 10/09/2015 S.D. Fla. 15 In re Application of Clarice Oliveira Tavares Argentina 10/07/2015 S.D. Fla. 14 In re Application of Kenichi Machida Japan 30/04/2015 S.D. Fla. 13 In re Application of Lisa Armoyan Canada ,Other Jurisdictions 16/04/2015 S.D.N.Y. 12 In re Application of Novoship UK Limited, et al. United Kingdom ,Switzerland 19/03/2015 S.D.N.Y. 11 In re Application of Mohammad Awar Fared Al-Saleh Canada ,United Kingdom ,Jordan ,The Bahamas,Dominican Republic 03/03/2015 S.D.N.Y. 10 In re Application of Ana Lucia Pedriali Nobrega Brazil 01/08/2013 S.D. Fla. 9 In re Application of Sendas Comercio Exterior, S.A. Brazil 30/05/2013 S.D. Fla. 8 In re Application of Sociedad Militar Seguro de Vida Curacao 26/03/2013 N.D. Ga. 7 In re Application of Alfredo Carlos Pott Argentina 04/03/2013 S.D. Fla. 6 In re Application of Jurema Dimas de Melo Pimenta Brazil 08/11/2012 S.D. Fla. 5 In re Application of Innovative Group Capital Corp. S.A Mexico 11/10/2011 S.D. Tex. 4 In re Aplication of Petroforte Brasileiro de Petróleo Ltda. Brazil 05/11/2010 S.D. Fla. 3 In re Application of Consorcio Ecuatoriano de Telecomunicaciones S.A. Guayaquil (Ecuador) 27/07/2010 S.D. Fla. 2 In re Application of DVLP LLC, et. al. Anguilla (UK) 28/06/2010 M.D. Fla. 1 OJSC Ukrnafta v. Carpatsky Petroleum Corp Stockholm (Sweden) 27/08/2009 D. Conn.