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 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.

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Alejandro Rodriguez Vanzetti joins Sequor Law, enhancing its global asset recovery team with his expertise in cross-border litigation. Sequor Law Welcomes Attorney Alejandro Rodriguez Vanzetti to Its Growing International Asset Recovery Team Open Firm News Open April 15, 2025 2 minutes read Sequor Law Miami, Florida – April 15, 2025 Sequor Law is pleased to announce that Alejandro Rodriguez Vanzetti has joined the firm as an attorney, further strengthening its global capabilities in asset recovery, cross-border commercial litigation, and international judgment enforcement. Alejandro brings a valuable combination of federal court and international litigation experience. Having previously served as a judicial law clerk to U.S. Magistrate Judge Lisette M. Reid in the U.S. District Court for the Southern District of Florida, where he supported civil and criminal proceedings, including drafting substantive orders and reports and recommendations and supporting courtroom proceedings such as evidentiary hearings and discovery hearings. Prior to joining the firm as an attorney, Alejandro gained hands-on experience at Alejandro Rodriguez Vanzetti joins Sequor Law, enhancing its global asset recovery team with his expertise in cross-border litigation. Discover more!Sequor Law as a law clerk, where he contributed to complex matters involving Chapter 15, financial fraud, and cross-border asset recovery. He also interned for U.S. District Judge Jose E. Martinez and previously worked at Kobre & Kim LLP, where he supported global litigation and government enforcement defense efforts. Alejandro earned his J. D. magna cum laude from Florida International University College of Law, where he served as the Executive Submissions and Comments Editor for the FIU Law Review . He also holds a B.A.’s in International Politics and Journalism from the Pennsylvania State University and has previously interned with the U.S. Department of State and Department of Defense. “Alejandro’s international background, analytical strength, and litigation experience make him a tremendous asset to our growing team.,” said Edward H. Davis Jr., Founding Shareholder of Sequor Law. “He brings a sharp legal mind and the cross-border perspective that defines our practice.” Admitted to practice in Florida, Alejandro is fluent in English and Spanish, with working knowledge of Italian. “I am thrilled to join Sequor Law, a firm at the forefront of international asset recovery and cross-border litigation,” said Alejandro “I look forward to contributing to our clients’ successes alongside such a dynamic and accomplished team.” For more information, visit: www.sequorlaw.com *** Sequor Law is an international law firm focusing on representing victims of financial fraud, including sovereign governments and state-owned enterprises, public and non-public companies, insolvency practitioners, and all manner of clients in the areas of asset recovery, financial fraud, cross-border insolvency, and international litigation and arbitration. www.sequorlaw.com . Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.

Sequor Law is recognized in Global Restructuring Review’s GRR 100 guide as a leading cross-border restructuring and insolvency law firm. Sequor Law Listed Among World’s Top 100 Cross-Border Restructuring and Insolvency Law Firms Open Awards & Recognition Open August 11, 2017 1 minute read Sequor Law Sequor Law is proud to be listed among the world’s 100 top cross-border restructuring and insolvency law firms in the Global Restructuring Review’s "GRR 100," a new annual guide. The guide recognizes our firm for its representation of insolvency estates and receiverships for international banks, sovereign governments and government institutions, multi-national corporations, and individuals where it represents insolvency practitioners from around the world, both in the United States and overseas multi-jurisdictional insolvencies around the world. The guide also recognizes Sequor Law for making over 20 Chapter 15 filings in the U.S. to recognize insolvency proceedings in diverse jurisdictions worldwide, filing more Chapter 15s than any other U.S. law firm. Firm co-founders Edward Davis and Greg Grossman are noted for many achievements in the guide, ranging from filing the first Chapter 15 bankruptcy petition in Florida to representing the joint liquidators of Stanford International Bank to recover assets for a $7 billion Ponzi scheme, the second-largest Ponzi scheme in the world. During the research period for the guide, the firm was instructed as counsel to the court-appointed liquidator and foreign representative of bankrupt Chilean investment firm Onix Capital, seeking to recover assets in excess of $100 million* from an alleged Ponzi scheme operated by Onix’s CEO. Our sincere thanks to our clients and colleagues for the opportunity to do what we love and earn so many distinguished awards and recognitions along the way. Indeed, Sequor Law derives its name from the Latin word “to pursue, to chase, to attain,” and signifies our core values: the agile, aggressive, and relentless pursuit of assets and success on behalf of our clients. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.

In-house Director of Investigations. Experience triggering Pentagon IG and FBI probes. Vetted network for asset tracing, litigation support, and intelligence Complementary Resources Investigations Integrating World-Class Investigation and Intelligence Into the Full Lifecycle of Every Case Sequor Law’s in-house investigative team integrates the discreet collection of intelligence and admissible evidence into the legal analysis throughout the life cycle of every matter. The team leverages proprietary databases, relationships with leading corporate intelligence firms, and a far-reaching network of local investigators, journalists, and former law enforcement contacts around the world to close critical information gaps, shape strategy, and prove the case. Led by a specialist in fraud-related asset tracing, Sequor Law’s investigations practice draws on deep experience to identify decisive patterns and extract critical inferences hidden in document productions and public records that many practitioners overlook. That specialized focus gives the firm a meaningful edge over both competitors and evasive counterparties. Fraud-Specialist Leadership and Investigative Depth Few Firms Can Match Key contacts Key Contacts Investigations William T. Nichols Director of Investigations wnichols@sequorlaw.com (+1) 305 372-8282 Open

Global Restructuring Review features Sequor Law as counsel to the foreign representatives in proceedings related to crypto exchange AAX's parent Atom Holdings and its subsidiaries. Crypto exchange AAX’s Cayman liquidators and Singaporean JM secure US recognition Open In the News Open July 19, 2023 1 minute read Sequor Law Read the latest article in the Global Restructuring Review featuring Sequor Law’s role as counsel to the foreign representatives involved in the proceedings related to Atom Holdings and its subsidiaries. Click here to read the full article online. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.

Get to know Sequor Law Founding Shareholder Gregory S. Grossman, Chambers Band 2-ranked expert in international insolvency, cross-border asset recovery, and creditors' rights. Attorney Spotlight: Get to Know Shareholder Gregory S. Grossman Open Attorney Spotlight Open September 20, 2022 2 minutes read Sequor Law You’ve been ranked Band 2 by Chambers & Partners multiple years; what did it take to get there? An individual acknowledgment of me is really a reflection of being surrounded by a consistently great team, long term. It may seem cliché to say so, but I have been fortunate to, first, have had hard-working professional colleagues in my early days, and later, to have had a hand in building up a team of first-rate attorneys, paraprofessionals, and staffers to do high-level work. As a subject-matter expert, you routinely deliver presentations on international insolvency matters, creditors’ rights, enforcement of judgments (both domestic and foreign), assorted bankruptcy topics, workouts and secured transactions. How do you prepare for these presentations? I am admittedly a legal information junkie, so I am constantly consuming articles, advance sheets, webinars, and the like. If you stay on top of new developments it is far easier to prepare for a presentation. As far as the actual delivery of the information, I try to find a way to explain the material in a conversational way and give examples that are likely to occur. Why do you think it is important for attorneys like yourself to get involved in public speaking related to their subject-matter expertise? There are two benefits about speaking on topics you know well. Firstly, it is an opportunity to practice the methods of conveying that information to a captive audience. Today, you may present to a room of conference attendees, and tomorrow it might be the judge in your most important case. Secondly, for litigators, this kind of public speaking creates credibility both in the market for clients, as well as interactions with the other participants in the case. When did you know you wanted to practice law? Was it something you always aspired to do? I thought about law school and practicing law while in my undergraduate studies. I was working toward my finance degree, took a class in business law and it just made complete sense. I had no lawyers in my family, so the joke was that my struggles with calculus led me to the law. Who has had the biggest influence on your law career? In both my legal career and my life, I have been most influenced by my wife. She is a brilliant health care lawyer and she is the best sounding board for me. What advice would you give to young lawyers who are deciding what type of law they want to practice? My first piece of advice is to be brutally honest with yourself. I mean your real self, not the person you want to be or the person your friends or family think you are or want you to be. For instance, if you detest confrontation, it will be a hard lift to be a successful trial lawyer. A process of elimination can also come in handy, such as litigation versus transactional. Even within litigation, can you project yourself working in an area dominated by statutes and regulations (think tax, health care, bankruptcy, environmental), or would you be better suited for a more fact-intensive litigation area (think negligence, injury, and other torts)? Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.

Sequor Law's Gregory Grossman speaks at OffshoreAlert's vGlobal 2021 Asset Recovery Day, a virtual conference on intelligence, investigations, and recovery in international finance. Offshore Alert vGlobal 2021 Conference Open Events & Speaking Open November 30, 2021 1 minute read Sequor Law December 6-10 A virtual conference on intelligence, investigations, & recovery for everyone in high-value international finance. Sequor Law’s Founding Shareholder, Gregory Grossman will be sfopeaking at OffshoreAlert’s vGlobal Asset Recovery Day on December 8th. Sequor Law Counsel, Daniel Coyle will be speaking at OffshoreAlert’s vGlobal Crypto Day on December 9th. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.

Contingency and hybrid fee arrangements for complex cases. Close relationships with leading litigation funders. Also representing funders evaluating investments Complementary Resources Alternative Fee Arrangements & Litigation Funding Support Contingency, Hybrid, and Funded Solutions for Complex International Disputes Creative Fee Solutions and Funder-Market Expertise to Level the Playing Field Sequor Law understands that even strong claims can be difficult to pursue when clients face financial constraints or well-resourced adversaries. In appropriate matters, the firm offers alternative fee arrangements, including full contingency and hybrid structures, to help clients move forward without bearing the full cost of litigation at the outset. Where contingency arrangements are not feasible, for example because a matter requires significant resources, spans multiple jurisdictions, or must be litigated in places that prohibit contingency fees, Sequor Law assists clients in securing third-party litigation funding. The firm maintains close relationships with many of the world’s leading litigation funders and understands which funders are best aligned with a particular matter based on claim type, jurisdiction, pricing, expertise, and risk profile. Sequor Law also regularly represents litigation funders in evaluating potential investments, giving the firm unique insight into how funders assess value, risk, and recovery potential. That perspective helps the firm guide clients efficiently through the funding process and position matters for the best possible outcome.

Sequor Law announces the promotion of Nyana Abreu Miller and Daniel M. Coyle to Counsel, recognizing their contributions to asset recovery, bankruptcy, and cross-border insolvency matters. Sequor Law Promotes Two Attorneys to Counsel Open Firm News Open February 8, 2021 2 minutes read Sequor Law February 8 th , 2021 Miami, Florida – Sequor Law, a boutique, Miami-based international law firm working in the areas of asset recovery, financial fraud, insolvency and financial services litigation, both domestically and cross-border, announced today that two attorneys have been named to new roles within the firm, effective February 8 th , 2021. Sequor Law is delighted to announce that Nyana Abreu Miller and Daniel Matthias Coyle have been promoted to Counsel at Sequor Law. “We are exceptionally pleased that Nyana and Daniel have accepted this new role,” said Founding Shareholder Edward H. Davis Jr. “With their focus on building relationships and winning strategies for clients, Nyana and Dan have been tremendous assets on some of our firm’s most high-profile and challenging cases. This promotion is a reflection of their ability as well as our commitment to developing and recognizing talent.” Daniel joined the firm over ten years ago and has focused his practice on bankruptcy, creditors’ rights, secured transactions, collections, executions, asset recovery and cross-border insolvency, routinely representing financial institutions and other creditors in bankruptcy, federal and state court litigation. Daniel is on the international committee for NAFER, recently joined the International Law Committee of the American Bankruptcy Association’s Business Law section and was named Rising Star by Super Lawyers consecutively from 2016-2018. Daniel received his J.D. from the University of Miami School of Law in 2008 and was a Magna Cum Laude Graduate and Order of the Coif. Nyana has focused her practice on international asset recovery and financial fraud. Nyana has worked on cases brought under Chapter 15 of the U.S. Bankruptcy Code on behalf of foreign trustees seeking to take discovery, administer property and bring claims against third parties. Currently serving as the Latin America Regional Director for the International Women’s Insolvency and Restructuring Federation (IWIRC), she was awarded 2020 Rising Star by IWIRC International and 2020 Emerging Leader by IWIRC’s Florida Network. Nyana received her J.D. from the University of Miami School of Law in 2011, where she was valedictorian of her class. “Nyana’s and Dan’s accomplishments since joining the firm seven and eleven years ago respectively, have exceeded the expectations we had for them,” said Founding Shareholder Gregory Grossman . “They both have achieved success in their careers because they demonstrate tremendous ability, consistent dedication to our clients providing the highest standards of service. This commitment and energy help drive their achievement and benefits both our clients and our firm.” ****** 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 . Click here for Nyana’s headshot and Daniel’s headshot . Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.

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

A Florida court grants Chapter 15 recognition to BVI liquidators of three 1MDB-linked funds. Sequor Law's Juan Mendoza represents the liquidators seeking US discovery to recover stolen assets. Liquidators of BVI Funds Linked to 1MDB Win Recognition in Florida Open In the News Open May 18, 2022 4 minutes read Sequor Law Ben Clarke 18 May, 2022 The joint liquidators of three 1MDB-linked British Virgin Islands funds have secured recognition of their appointments in Miami, pledging to obtain discovery in the US to help with their recovery efforts. In an oral ruling on 18 May, Judge Robert Mark in the US Bankruptcy Court for the Southern District of Florida recognized the BVI liquidations of SRC International (Malaysia) (SRC BVI) and subsidiaries SRC Strategic Resources and Bright Oriande. The judge also granted a motion to jointly administer the proceedings. While Judge Mark agreed to recognize the liquidators’ appointments, he questioned the draft order provided – particularly a clause that would have blocked any party from bringing a claim against the joint liquidators in any US court without first obtaining leave of the bankruptcy court. Counsel to the liquidators, Sequor Law’s Juan Mendoza , said the clause was included to enforce the Barton doctrine, established by the Supreme Court to require any party wishing to bring a claim against a receiver to first obtain the leave of the court that appointed the receiver. He said the clause was actually “Barton-lite” because they were not requesting potential litigants gain approval from the BVI courts to launch an action against the joint liquidators in the US. The judge said he would take the clause out but would include it in an amended order if he is provided with the relevant authorities. He said he didn’t fault the purpose or intent of the clause, to prevent the potential harassment of the joint liquidators, but he considered it “pretty sweeping relief” that pre-empts unknown future events. Fraud scheme The rulings come after the joint liquidators, BVI-based Helen Janes of Hyperion Risk Solutions and Quantuma’s Angela Barkhouse in the Cayman Islands and Carl Jackson in the UK, filed Chapter 15 proceedings last month in an effort to recover some of the billions of dollars allegedly stolen from Malaysian sovereign wealth fund 1MDB. Various authorities around the world have been investigating 1MDB and an entity it established in Malaysia, SRC International (SRC Malaysia), for the last seven years over a huge fraud that saw about US$8.5 billion diverted from them to numerous entities and individuals. During the short recognition hearing, Mendoza highlighted some of the suspicious transactions the joint liquidators have identified involving the three debtor companies – including over US$1 billion of funds transferred from SRC Malaysia to SRC BVI bank accounts in Hong Kong and Switzerland, and about US$60 million transferred to SRC Strategic Resources. Mendoza noted SRC BVI invested almost US$250 million into three funds of segregated portfolio company Asia Momentum Fund, which only ended up with a balance of about US$17 million. He also highlighted about US$652 million of investments in two BVI companies between 2011 and 2014, which he said “basically evaporated” as a result of redemptions that left no trace. Janes said in court filings last month that most investigation attempts in Malaysia were thwarted by the Malaysian government because the country’s Prime Minister, Najib Razak, was the force behind the creation of 1MDB. But Najib was removed from office in 2018 and has faced criminal and civil proceedings with other co-conspirators in relation to the misappropriation of 1MDB funds. While the US Department of Justice has also investigated multiple parties, and last month secured a conviction against former Goldman Sachs banker Roger Ng for his role in the scandal, Janes said it has focused its efforts on 1MDB and not SRC Malaysia, the parent of the three BVI funds. The joint liquidators have issued proceedings against companies in multiple jurisdictions since they were appointed last Summer, but Janes said they suspect there are other entities related to the fraud that are yet to be uncovered. According to Janes, SRC BVI has been principally used by fraudsters throughout its existence to misappropriate funds, and Bright Oriande is believed to have been established solely to divert funds from 1MDB and SRC Malaysia. With recognition of their appointments, the joint liquidators intend to obtain discovery relating to transactions involving the debtors so they can take steps to potentially realize assets for creditors. In the US Bankruptcy Court for the Southern District of Florida Judge Robert Mark Foreign representatives of SRC International (Malaysia) et al Hyperion Risk Solutions Group head of finance Helen Janes in the British Virgin Islands Quantuma Caribbean head Angela Barkhouse in the Cayman Islands and chief executive Carl Jackson in Southampton, UK Counsel to joint liquidators of SRC International (Malaysia) et al Sequor Law Shareholder Gregory Grossman and attorneys Juan Mendoza and Jennifer Mosquera in Miami In the British Virgin Islands Commercial Division Joint liquidators of SRC International (Malaysia) et alJoint liquidators of SRC International (Malaysia) et al Hyperion Risk Solutions Group head of finance Helen Janes in the British Virgin Islands Quantuma Caribbean head Angela Barkhouse in the Cayman Islands and chief executive Carl Jackson in Southampton, UK Counsel to joint liquidators of SRC International (Malaysia) et alCounsel to joint liquidators of SRC International (Malaysia) et al Emery Cooke Partner Andrew Emery in the British Virgin Islands To read the original article click here . Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open 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.