Sequor Law's Leyza B. Florin chairs the Lawyers Advisory Committee for the Southern District of Florida Bankruptcy Court, linking judges and practitioners to improve bankruptcy practice across the district. Lawyers Advisory Committee Open Awards & Recognition Open September 16, 2019 3 minutes read Sequor Law By: Guest Contributor Leyza B. Florin , Chair Lawyers Advisory Committee The Lawyers Advisory Committee (LAC) for the Southern District of Florida Bankruptcy Court was formed in 2018 to provide a forum for communication, feedback, and resources between the judges and the bar. Its purpose includes regularly soliciting the bar for commentary regarding bankruptcy practice and receiving requests from the court to consider issues arising from the practice of law before the Court. The LAC may recommend changes in the practice and procedures throughout the district and also acts as a liaison between the Court and the practitioners. In addition, the LAC is charged with the development, implementation, and maintenance of bankruptcy-related programs in the district as requested by the Court. To view samples of issues addressed by the LAC, please visit the LAC web page to view meeting minutes. The LAC is only as successful as the bankruptcy bar makes it. We are dependent on you to contact LAC members with any concerns or suggestions that you might have about bankruptcy practice in our district. The success of our bankruptcy practice in the Southern District of Florida is our absolute priority. If you have any recommendations which will improve the Court’s administration of justice, please reach out to a member of the LAC or contact us at LAC@flsb.uscourts.gov . We encourage you to participate by submitting feedback for consideration and assist the LAC in making our bankruptcy practice in the Southern District of Florida the best it can be. BANKRUPTCY RULES AND FORMS ARE AMENDED EFFECTIVE 12/1/19 Amendments to the federal rules and forms scheduled to take effect 12/1/19 and can be reviewed at the U.S. Courts website at these links: Pending Rules and Forms Amendments Pending Changes in Bankruptcy Forms If any of the above amendments necessitate changes in this court’s local rules, local forms, court guidelines, clerk’s instructions or any other local documents, notice will be provided prior to the December 1, 2019, effective date of the bankruptcy rules and forms amendments. COURT GUIDELINES FOR ATTORNEYS FOR CHAPTER 13 DEBTORS AMENDED Please take notice that the “Guidelines for Compensation for Professional Services or Reimbursement of Expenses by Attorneys for Chapter 13 Debtors Pursuant to Local Rule 2016-1(B)(2)(a)” have been amended to reflect an increase in the compensation fee that an attorney may charge without application to the court. The “no-look” fee will increase from $3,500 to $4,500 for all cases filed under or converted to chapter 13 on or after September 1, 2019. A Public Notice and amended “Guidelines” are currently posted on the court website. PROPOSED AMENDMENT TO THE FEDERAL RULES PUBLIC COMMENT PERIOD CLOSES FEBRUARY 19, 2020 On August 19, 2019, the Judicial Conference Advisory Committees on Appellate, Bankruptcy, and Civil Rules published proposed amendments to their respective rules and forms and requested that the proposals be circulated to the bar and public for comment. Appellate Rules: 3, 6, 42, and Forms 1 and 2; Bankruptcy Rules: 2005, 3007, 7007.1, and 9036; Civil Rule: 7.1 The proposed amendments, rules committee reports explaining the proposed changes, and instructions on how to submit comments are posted on the U.S. Courts website at: Proposed Amendments Published Comments The public comment period closes on February 19, 2020. If approved, the amendments would become effective December 1, 2021. Click here to read the full article. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.

Sequor Law's Leyza B. Florin and Daniel Coyle analyze the emerging minority view on delivering subpoenas under FRCP Rule 45(b)(1) and its impact on cross-border asset recovery. Asset recovery column: emerging minority view on delivery of subpoenas under FRCP 45 Open Legal Insights Open March 25, 2020 5 minutes read Sequor Law Sequor Law shareholder Leyza B. Florin and attorney Daniel Coyle in Miami discuss the emerging trend in US federal and bankruptcy courts regarding service of subpoenas under rule 45(b)(1) of the Federal Rules of Civil Procedure (FRCP). The language of rule 45(b) establishes the method for serving a subpoena upon the subpoena target. Previously, despite differences in the text between rule 45(b) and rule 4, governing service of original process, courts required subpoenas to be served on the subpoena target exclusively by hand delivery under the methods specified in rule 4. However, rule 45(b) jurisprudence is evolving to a more liberal standard that is both more in line with the text of rule 45(b) and more advantageous to the asset recovery practitioner, and client, seeking third-party discovery – especially from discovery targets in cross-border cases who maintain multiple residences or a more transient presence in the United States. Service of a subpoena versus service of process— what is the difference and why is there a difference? First and foremost, service of a subpoena under rule 45 is accomplished by “delivery”, and specifically, “delivering a copy [of the subpoena] to the named person”. Juxtapose this language with the text of rule 4, specifically subsections “e” and “f” specifying the method for service of process of natural persons, which is also applicable for service of process of artificial persons, in and outside of the US and it is clear that the standards are notably different. Noticeably absent from the text of rule 45 are the words “personally”; “hand” delivery; or “abode” service. References to rule 4, and state rules of service of process are also missing. Thus, based upon a plain meaning of the rules, the method of service of a subpoena is not the same as service of process. In the bankruptcy context, construing rule 45 to require personal service or even abode service of a subpoena leads to an even more bizarre result since, under rule 7004(b), service of process of an adversary proceeding may be validly accomplished by first class mail. The distinction between the method of service of a subpoena and service of process was crucial to Judge A. Jay Cristol’s reasoned opinion in the 2008 case of Falcon is not the only case to analyze the distinctions between rule 45(b) and rule (4), but it provides an insightful exposition of several cases from various courts as well as an insightful analysis of the language of both rules to explain why the method of accomplishing service under each rule is different. Judge Cristol analysed several judicial decisions from both inside and outside Florida, each of which determined that the service of a subpoena upon the recipient by a means other than personal service was valid. Moving to a statutory construction analysis, Judge Cristol determined that the term “delivering” was ambiguous and should be considered in the context of other parts of rule 45, “as well as other federal rules.” Judge Cristol stated that a reading of rule 45(b)(1) as requiring the subpoena to be personally served, would render the language of rule 45(b)(4) regarding the “manner of service”, and the language of rule 4(e)(2)(A) and 4(f)(2)(C)(i) requiring the process be delivered “personally”, as “superfluous” and “pure surplusage.” Construing rule 45(b) to require personal service would thus run afoul of the Surplusage Canon (). Dubbing this approach the “better-reasoned, modern, emerging minority position,” Judge Cristol applied it to the facts of the case before him. Other factors are also germane to determining that service is valid. The public policy underlying the service requirement is ensuring the receipt of the subpoena so that the subpoena target has notice of both the subpoena, and what is required/requested from the subpoena target. Thus, the purpose of the service requirement is actual receipt, which the courts accord significant weight to. Courts also focus on equitable considerations when determining validity, such as attempts by subpoena targets to subvert the purpose of the rules by hyper-technically construing them as an artifice to evade service. For instance, in the 2000 case of , the US Bankruptcy Court for the Southern District of New York found rule 45 allows for service of a subpoena by certified mail on a deponent who rebuffed attempts at personal service and whose doorman restricted a process server’s access to a deponent’s apartment. What is “delivery” and what constitutes “delivery” under the emerging minority position? Delivery under this approach was defined in as serving the subpoena in a manner that reasonably insures actual receipt of the subpoena by the witness. Some courts, adopting the emerging minority position, have fleshed out this standard by providing that service may be accomplished by mailing the subpoena to the subpoena target’s known address in the US or abroad. Other courts have established that sending the subpoena by common carrier is sufficient. In the case, the court determined that substitute service on another member of the household constitutes valid service, even though the subpoena target did not reside at the address where the subpoena was delivered. At least one court has ruled that delivering the subpoena to the subpoena target’s agent is sufficient, and other courts have upheld service on domestic workers. Indeed, in a recent ruling in the case of in the US Bankruptcy Court for the Southern District of Florida, Judge Robert Mark held that service of the subpoena by delivering it to a non-resident domestic worker at the address where the subpoena target’s family lived was sufficient. The emerging minority position should continue to gain adherents and traction The so-called emerging minority position is consistent with the text of rule 45(b) and consistent with the canons of statutory construction. It is also consistent with the policy aims of the service rule: ensuring actual receipt. The emerging minority position also establishes a more liberal standard that serves another laudable public policy goal: easing the discovery of information that will increase the likelihood of recovering assets while simultaneously discouraging the corruption of the rules of civil procedure by swindlers as a ruse to avoid valid service and valid discovery. The advantage of this more liberal standard for the asset-recovery attorney seeking discovery from discovery-targets in cross-border cases is clear. A lower threshold for effecting service eases the burden of attempting to serve discovery-targets who maintain a presence both inside and outside of the United States and lowers the likelihood of having to pursue discovery in foreign jurisdictions under the slow and cumbersome procedures of the Hague Convention or through a letter rogatory in a non-member state. References Federal Rules of Civil Procedure, rule 45(b) Federal Rules of Civil Procedure, rule 4 To view the original article, click here. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.

Enforcing large judgments and arbitral awards for Fortune 500 companies, global banks, and sovereigns. Pursuing nominees, alter egos, and facilitators of concealment Judgment & Arbitral Award Enforcement Sequor Law represents Fortune 50 companies, global banks, large foreign corporations, and government entities in judgment and arbitral award collection matters. Decades of Experience Enforcing Complex Judgments & Awards Worldwide Sequor Law has decades of experience enforcing large judgments and arbitral awards rendered in the United States and abroad, including against large corporations and sovereigns. The firm represents Fortune 500 companies, global banks, major foreign corporations, and government entities in judgment and arbitral award collection matters. Sequor Law uses cash-flow analysis and asset tracing methods to expose concealed assets. The firm has substantial experience in post-judgment evidence gathering and recovery methods, including garnishments, freeze orders, sequestration orders, and writs of execution. In addition to identifying debtor assets, Sequor Law vigorously pursues nominees, alter egos, and others who improperly received money or property from the debtor. Where accountants, attorneys, or other asset protection specialists participate in concealment schemes, Sequor Law pursues conspiracy and aiding-and-abetting claims against those facilitators. Post-judgment and post-award enforcement has become a highly sophisticated and specialized practice, which is why leading litigators and litigation funders in the United States and abroad refer hard-earned judgments to Sequor Law for enforcement. Tracing Assets, Piercing Schemes, & Pursuing Every Responsible Party Representative Representative Cases Representation of Decedent’s Estate in Judgment Collection Sequor Law represented the personal representative of a decedent’s estate in a New York probate matter enforcing a high-value judgment against a family member who misappropriated estate assets and misused a limited power of attorney. The matter began with domestication of the New York judgment under the Florida Enforcement of Foreign Judgments Act. Brazilian Judgment Holder in Recognition and Enforcement of Foreign Judgment Sequor Law represented the holder of a high-value Brazilian Judgment in obtaining recognition under Florida’s Uniform Out-of-Country Money Judgment Act, defeating arguments that the Brazilian orders were not final because they arose from a homologated settlement. The case included depositions and trial testimony from Brazilian law experts. Defense of Regional Bank Against Customer Claims Regarding PPP Loans Sequor Law successfully defended Ocean Bank against allegations that the bank failed to properly administer PPP loan processes in connection with a forgiveness request. Defense of Regional Bank Against Assignee Regarding Overdraft Fees Sequor Law successfully defended Ocean Bank against allegations by an assignee in an assignment for the benefit of creditors that the bank improperly assessed overdraft fees and charges. Representation of Barclays Bank in Letter of Credit Dispute Sequor Law obtained summary Judgment establishing that, under UCC Article 5 and applicable law, a letter of credit issuer had no preferred rights to proceeds paid under the letter of credit. Open Edward H. Davis, Jr. Founding Shareholder edavis@sequorlaw.com (+1) 305-372-8282, Ext. 228 Open Leyza B. Florin Shareholder lflorin@sequorlaw.com (+1) 305-372-8282, Ext. 300 Open Tara J. Plochocki Partner tplochocki@sequorlaw.com (+1) 202-900-8740, Ext. 310 Open Open Key contacts Key Contacts

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An original UNCITRAL Model Law draftsman responds to proposals regarding the Centre of Main Interests (COMI) framework in cross-border insolvency proceedings. Model Law draftsman responds to COMI proposals Open Legal Insights Open September 15, 2023 1 minute read Sequor Law An original UNCITRAL Model Law draftsman responds to proposals regarding the Centre of Main Interests (COMI) framework in cross-border insolvency proceedings. 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.

Meet Sequor Law Attorney Jennifer Mosquera, an asset recovery specialist who discusses her passion for international law, her approach to complex cases, and her path to the legal profession. Attorney Spotlight: Jennifer Mosquera Open Attorney Spotlight Open September 25, 2023 2 minutes read Sequor Law What inspired you to pursue a law career? When I was in high school, I became heavily involved in mock trial, moot court, and debate. My senior year I had the honor of arguing before the Florida Supreme Court and winning the Florida State Moot Court Finals. Participating in these programs showed me all of the ways the law was dynamic and interesting, and it helped me realize that I wanted to be a lawyer. What skills do you draw upon when it comes to your specific practice areas? The most important skills I employ in my asset recovery practice are critical thinking and consistency. A lot of times, the best solutions require not only creativity, but additional follow through to make sure the desired results are achieved. Why did you choose those areas of law? I practice in the asset recovery space because I have an interest in international law and the challenges found therein. I enjoy keeping up with and learning about changes in the international law area, and thinking of the best ways to apply them to my practice. You are heavily involved in many industry organizations. What do you enjoy most about your memberships? I enjoy fostering relationships with other attorneys and business leaders, both in South Florida and around the world. Nurturing these connections means that I learn more and have a deeper understanding of others perspectives, which is critical to improving my practice. I especially enjoy when this leads to opportunities to give back to the broader community — for example, I am involved with the Legal Services of Greater Miami, which provides legal counsel to low income individuals in South Florida. Tell us about a mentor who made an impact on your career? Judge Lynn Quimby-Pennock was one of the first mentors I had in the legal field and she mentored me throughout law school and beyond. While I was completing my studies, she and I would have lunch together at least once a month, where we would talk not only about the challenges of legal practices, but also issues of integrity and honesty. She taught me that to be a good lawyer you have to maintain good moral character both in and out of the courtroom. If you weren’t practicing law, what would you be doing? I’d likely work in something relating to paleography. I’ve always been interested in ancient manuscripts and rare books. What might people be surprised to learn about you? For many years, I made sculptures predominantly using clay as my preferred medium. Some of my pieces were showcased in local amateur art exhibitions. What is a good book you read recently or your favorite book? Wild by Cheryl Strayed is a recent favorite. I don’t typically favor memoirs, but this one really stuck with me. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.

Attorney Spotlight – Get to Know Alain M. Acanda Open Attorney Spotlight Open January 29, 2026 2 minutes read Sequor Law 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as a child. Growing up I wanted to change the relationship I had with the law and use the legal field to build myself and my community up. 2. Why did you choose the areas of law that you practice? I chose the areas of law I practice because it allows me to take advantage of Miami’s unique position as a hub for the exchange of culture, business, and legal work. Practicing in areas like cross border insolvency and arbitration allows me to gain a broad range of perspectives from clients across the globe. 3. What skills do you draw upon when it comes to your specific practice areas? The skills I draw upon in my practice areas are understanding how all the moving pieces of a case fit together and being flexible in order to deliver results for the client. Being able to understand how these pieces fit together keeps a case moving forward and being flexible permits adapting to changing circumstances in order to still deliver for a client. 4. What is the most rewarding part about your job? The most rewarding part of the job is being able to deliver for a client. 5. Tell us about a mentor who made an impact on your career. A mentor who had an impact on my career was my high school AP European History teacher. He also served as my coach for the international debate club which was where I first became interested in international law which has carried on until today. 6. If you weren’t practicing law, what would you be doing? If I wasn’t practicing law, I’d either be a history professor or restoring classic American cars. 7. What might people be surprised to learn about you? People might be surprised to learn that I love to cook. Whether it be cooking steaks on a grill or making pasta from scratch, I enjoy trying new recipes and making different dishes. 8. What is a good book or article you read recently? A good book I read recently was : Cuba, An American History by Ada Ferrer. It explores the rich shared history between the two nations which can be often overlooked beyond the Castro-regime years. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.

Sequor Law's March 2021 quarterly newsletter featuring the latest news, updates, and developments from the firm. March 2021 – Quarterly Newsletter Open Firm News Open March 11, 2021 1 minute read Sequor Law Click below to view Sequor Law’s latest news and updates, and make sure to join our email list to receive future newsletters. Read the original article here . Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.