Explore how the 9th Circuit's decision impacts the Foreign Discovery Statute. Learn about the expansive use of the Foreign Discovery Statute. 9th Circuit Greenlights Expansive Use of Discovery Statute, Law360, Aug. 13, 2025 Open In the News Open August 13, 2025 1 minute read Sequor Law Open the full article here Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open 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 13, 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.

A practical analysis of asset sales under § 363 in Chapter 15 bankruptcy cases, addressing cross-border insolvency challenges and the role of foreign representatives in U.S. courts. Selling Assets in Chapter 15 Matters: Practical Considerations in Cross- Border Insolvencies Open Legal Insights Open August 26, 2019 9 minutes read Sequor Law Asset sales under § 363 of the U.S. Bankruptcy Code [1] have become a critical component of the bankruptcy practitioner’s arsenal, and a preferred avenue of monetizing a debtor’s assets. The process is generally straightforward, and the Bankruptcy Code provides the framework of how sales should proceed. U.S. practitioners have become well versed in the § 363 sale process and how to address recurring issues; however, chapter 15 of the Bankruptcy Code [2] adds an additional layer of complexity that must be observed and resolved carefully. When the U.S. adopted chapter 15, it codified the Model Law on Cross-Border Insolvency of the United Nations Commission on International Trade Law (“Model Law”). [3] Chapter 15 aimed to facilitate U.S. recognition of foreign insolvency proceedings and increase international cooperation among courts in cross-border insolvency cases. [4] However, the Model Law is a generic template for countries around to world to incorporate into their existing insolvency laws. [5] Therefore, chapter 15’s adoption has created both conflicts and gaps as to how practitioners utilize the Bankruptcy Code to aid and facilitate cross-border insolvencies. This article highlights how the application of and compliance with § 363 is an example of these conflicts and gaps, and it provides some thoughts on what to look out for and how to address some of these issues. First: Is Relief Under § 363 Available? Chapter 15 proceedings fork into two paths: one for foreign main proceedings and the second for foreign non-main proceedings. [6] Under § 1520 of the Bankruptcy Code, foreign main proceedings automatically obtain rights under a number of other Bankruptcy Code sections immediately upon recognition. [7] Section 1520, however, only applies to foreign main proceedings; foreign non-main proceedings do not receive any sort of automatic applications. One of the sections automatically applied to foreign main proceedings is the right to sell property under § 363. [8] Therefore, if your proceeding is a foreign main proceeding, you are automatically entitled to utilize § 363 wherever and whenever appropriate. Although § 363 is not automatically applied to non-main proceedings, it is still available, but it requires additional steps. Specifically, once a foreign non-main proceeding is recognized, relief must be sought from the court to authorize the application of § 363 to the proceedings. This request for relief is presented to the court under § 1521. Once the court grants the requested relief, the § 363 sale process becomes available to the non-main proceeding. Section 1521 is a broad section of chapter 15 that allows the court, upon recognition of the proceedings, to provide additional relief to the foreign representative subject to limitations of the Bankruptcy Code and U.S. laws. [9] As such, the section can be used to utilize other provisions of the Bankruptcy Code that are not explicitly adopted or automatically applied in chapter 15, if that is necessary to assist the foreign representative. Second: Which Assets Can Be Sold, and Which Court Approves the Sale? Section 541 of the Bankruptcy Code is largely inapplicable in a chapter 15 proceeding. [10] An estate is never created in a typical chapter 15 proceeding. Section 363 contemplates the sale of property of the estate, so which assets are allowed to be sold under § 363 in chapter 15 proceedings? [11] Section 1520’s adoption of § 363 modifies the section so that it applies to transfers of any interest of the debtor in property that is within the territorial jurisdiction of the U.S. to the same extent that the section would apply to property of an estate. [12] Therefore, the assets that can be sold under chapter 15 appear to be broader than in other bankruptcy contexts because it is not limited to the estate. Could this mean that a foreign representative could sell property of the debtor in the U.S., even if the debtor would have claimed it exempt, if the case were a domestic case? To date, there do not appear to be any cases deciding this point. In Fairfield Sentry, [13] the Second Circuit analyzed what chapter 15 means by “transfer of an interest of the debtor in property that is within the territorial jurisdiction of the United States.” [14] Fairfield Sentry LLC was a BVI investment fund that filed customer claims in the SIPA liquidation of the Bernard L. Madoff Investment Securities LLC (BLMIS). Fairfield Sentry invested approximately 95 percent of its assets with BLMIS when Bernard Madoff’s Ponzi scheme became public. [15] As a consequence, Fairfield Sentry was placed into liquidation in the BVI in 2009, and in 2010 the U.S. Bankruptcy Court for the Southern District of New York recognized the foreign main proceeding. [16] Fairfield Sentry ultimately decided it would sell the SIPA claims and entered into an agreement with Appellee Farnum Place, LLC to sell the claims for 31.125 percent of their value. [17] However, days after the parties entered into the agreement, the trustee for the BLMIS liquidation announced that he had entered into a settlement agreement that would increase the value of Fairfield Sentry’s SIPA claims from 32 percent to 50 percent of the total amount claimed. [18] This substantial increase created tension between Fairfield Sentry’s liquidators and Farnum. The liquidators sought to cancel the sale, and Farnum sought to enforce it. The BVI court approved the sale over the liquidators’ objections, but instructed the liquidators to question the U.S. Bankruptcy Court as to whether § 363 applied and whether the section required disapproval of the sale. [19] Thereafter, the U.S. Bankruptcy Court rejected the liquidators’ application for disapproval of the proposed sale, and the district court affirmed. However, the Second Circuit reversed the decisions of the lower courts on appeal, finding that the “property” in this case was the SIPA claims and that the SIPA claims were located in New York, “where the property could be assigned or transferred,” [20] and therefore that § 363 applied. The Second Circuit made clear that a bankruptcy court’s “principal responsibility … is to secure for the benefit of creditors the best possible bid,” and the sale of the SIPA claims was ultimately disapproved. [21] Fairfield Sentry solidified that § 363 applies in chapter 15 whenever the asset to be sold is within the U.S. Moreover, Fairfield Sentry also set a line on the extent that comity will have in chapter 15 proceedings, and § 363 sales in particular. The Second Circuit rejected Farnum’s arguments that deference to the BVI decision was required, and the opinion makes clear that the court of the jurisdiction where the asset to be sold is located is the court with the ultimate approval of the sale. Third: How Do I Give Notice, and Where Are Objections Heard? One of the trickiest portions of utilizing § 363 in chapter 15 proceedings may be complying with the procedural requirements of the sale — specifically, notice to creditors and the hearing requirement. [22] Whereas a creditor matrix is easily accessible in domestic bankruptcy proceedings, it is not always the case in cross-border proceedings. Chapter 15 does not require any schedules, a creditor matrix or a claims register. A chapter 15 case requires nothing more than an application, statement identifying the foreign proceedings, and evidence of the existence of the foreign proceeding and appointment of the foreign representative. [23] In addition to the lack of traditionally relied-upon creditor information, some foreign jurisdictions make it difficult to locate the necessary creditor information. Also, the foreign representative might not always be the trustee of the foreign main proceedings, and therefore might not have direct access to the list of creditors. Every foreign jurisdiction is unique, and there are many factors that could lead to delays in utilizing § 363 in chapter 15 proceedings. You must prepare as best as possible to avoid any such delays. Complicating matters further, sometimes the notice requirements in the foreign main jurisdiction might not comply with the requirements of the U.S. How, then, does one go about notifying the creditors, and what is considered sufficient notice? In In re Banco Santos S.A., [24] a chapter 15 case filed in the Southern District of Florida, Hon. Laurel M. Isicoff addressed the issue of notice in the context of approving a settlement in a chapter 15 proceeding, which may be applied in the context of a § 363 sale. There were two separate instances where notice was required in Banco Santos. In the first instance, the foreign representative requested a bar order in favor of certain settling parties, and in the second instance, the foreign representative did not. [25] The court considered the nature and implications and the requests of the foreign representative for each instance. In the first instance (which requested a bar order), the court determined that directly mailing to each creditor in Brazil would be required, and in the second instance (which did not require a bar order), the court determined that notice via publication in the Brazilian Gazette, which is sufficient under Brazilian law, was sufficient despite the fact that notice by publication is generally insufficient in domestic proceedings. [26] Judge Isicoff highlights in Banco Santos that in a chapter 15, the court has the ability and duty to look at the requests made and the nature and implications of the requests before making a determination. Ultimately, the more burdensome the request, the more stringent the notice requirement should be. Similar to Fairfield Sentry, the property and assets to be sold in Banco Santos were located within the territory of the U.S. Therefore, to ensure compliance with the notice and hearing requirements of § 363, Judge Isicoff conditionally approved the pending sale and ordered any objections thereto be filed in the U.S. Judge Isicoff also ordered the foreign representative to request an order in the foreign main proceedings instructing any creditor with an objection to file them in the U.S. [27] This process created a simplified procedure to obtain approval of a sale while consolidating all objections into the appropriate jurisdiction. Fourth: Who Can Assist in the Sales Process? More often than not, professional persons need to be retained to assist in a sales process (an appraiser, auctioneer, realtor, etc.). The Bankruptcy Code lays out a clear process for how to go about hiring professional persons, and provides limitations on their compensation. [28] However, none of the relevant sections, including §§ 329 and 330, were adopted in chapter 15. What recourse does the foreign representative have in situations where they enter into a bad deal with a professional person? Is the court then authorized to disapprove any agreements or appointments? Ideally, § 1521 would allow the court to adopt any section of the Bankruptcy Code necessary, but what happens in a situation where the appointment of a professional person and their compensation is approved in the foreign main jurisdiction, but the appointment and compensation (while acceptable in the foreign main jurisdiction) would normally be considered unconscionable in the U.S.? It follows that the rationale in Fairfield Sentry will also apply here, but this is another situation that has not yet been challenged. There are many benefits to the adoption of the Model Law through chapter 15, and utilization of chapter 15 has been steadily increasing since the chapter was enacted. This article addresses some of the methods of dealing with the gaps and conflicts created by chapter 15 and the general requirements of the Bankruptcy Code in the context of § 363 sales, although the dueling nature of two insolvency proceedings arising in two separate jurisdictions necessitates that bankruptcy practitioners be twice as diligent in their cases. [1] Title 11 of the U.S. Code (the “Bankruptcy Code”). [2] 11 U.S.C. §§ 1501-1532. [3] 11 U.S.C. § 1501. [4] See generally 11 U.S.C. § 1501. Help Center [5] See www.uncitral.org/uncitral/en/uncitral_texts/insolvency/1997Model.html . [6] “Foreign main proceeding” means a foreign proceeding pending in the country where the debtor has the center of its main interests. 11 U.S.C. § 1502 (4). “Foreign non-main proceeding” means a foreign proceeding, other than a foreign main proceeding, pending in a country where the debtor has an establishment. 11 U.S.C. § 1502 (5). [7] See generally 11 U.S.C. § 1520. [8] 11 U.S.C. § 1520(a)(2)-(3). [9] See 11 U.S.C. § 1507(a); see also § 1521(a)-(b). [10] Section 541 is only discussed in chapter 15 in relation to concurrent proceedings and in authorizing a representative of a domestic bankruptcy to act abroad; see 11 U.S.C. §§ 1528 (commencement of a case after recognition of foreign main proceeding) and 1505 (authorization to act in foreign country). [11] 11 U.S.C. § 363(b)(1). (the “trustee, after notice and a hearing, may use, sell, or lease, other than in the ordinary course of business, property of the estate…” (emphasis added); see also infra footnote 14. [12] 11 U.S.C. § 1520(a)(2). [13] In re Fairfield Sentry Ltd., 768 F.3d 239 (2d Cir. 2014). [14] See Fairfield Sentry, 768 F.3d at 244; see also § 1520(a)(2). [15] Id. at 241. [ 16] Id. [17] Id. at 242. [18] Id. [19] Id. at 243. [20] Id. at 244. [21] Fairfield Sentry, 768 F.3d at 246-47, quoting In re Fin. News Network Inc., 980 F.2d 165, 169 (2d Cir. 1992). [22] 11 U.S.C. § 363(b)(1) (“The trustee, after notice and a hearing, may use, sell, or lease…”) (emphasis added). [23] 11 U.S.C. § 1515. [24] In re Banco Santos S.A., Case No. 10-47543-BKC-LMI. [25] Banco Santos, Case No. 10-47543-BKC-LMI [D.E. 170, 184, 185]. [26] Id. [27] Id. [D.E. 170, 185]. [28] 11 U.S.C. §§ 327, 328. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open 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 13, 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.

Sequor Law's Joseph B. Rome wins ThoughtLeaders4 FIRE's 2nd Future Thought Leaders Essay Competition, with his essay on the future of fraud, insolvency, and asset recovery in 2023. Joseph B. Rome Wins ThoughtLeaders4 FIRE Essay Competition Open Awards & Recognition Open January 19, 2023 1 minute read Sequor Law Congratulations to our very own Joseph B. Rome who was selected by ThoughtLeaders4 FIRE as the winner of its 2nd Edition of the Future Thought Leaders Essay Competition ! His essay, which will be published in an upcoming issue of the magazine, addresses the topic of where the industry is headed in 2023 by focusing on N Click the image below to read his full essay. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open 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 13, 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.

Sequor Law Counsel Nyana Abreu Miller shares insights on being a trilingual woman in international law, her promotion, IWIRC leadership, and her commitment to empowering women in the legal profession. Attorney Spotlight: Nyana A. Miller Open Attorney Spotlight Open March 22, 2022 5 minutes read Sequor Law Nyana Abreu Miller , recently appointed Counsel at Sequor Law, shares insights on the benefits of being a trilingual woman in the international law industry and her efforts to empower women in law. In 2021, you were promoted to Counsel. How did the promotion change your role as an attorney? The promotion grew my responsibilities both within and outside of Sequor, changing the way I am perceived and providing me with new opportunities for professional growth, such as increased public speaking engagements. Within the firm, my position as Counsel entails significant managerial duties, such as supervising the Junior Associates. How has your role as New Network and Regional Development Co-Director of IWIRC benefitted you as a Sequor Law Counsel? The role provides a great opportunity to network and get to know other women in the insolvency space. Our committee works to launch International Women’s Insolvency & Restructuring Confederation (IWIRC) networks in places that do not have a professional development group for women in insolvency. This has provided a platform for me to learn about the insolvency industry in different countries and to bring something new to the table. Working together with other motivated professionals on a project that we are passionate about helps to grow deeper professional relationships. When business opportunities arise within those relationships, we are not mere acquaintances who met at a conference, we are colleagues who have been collaborating on a passion project for years. How does IWIRC help to empower women in law? For me, personally, it has been transformational to connect with other women who are succeeding and striving to grow in the same industry. At each IWIRC event, I am inspired by the many different role models that I encounter, and I find them to be very approachable and candid about what it has taken for them to succeed. These experiences have been essential in my ability to shape my own path. You’re regularly invited to speak on topics related to international asset recovery. How have the opportunities impacted your role as a trilingual attorney? I was born in Brazil and raised in the U.S., with English being my second language after Portuguese. I learned to speak Spanish in the U.S. as a third language. Since I work in Latin America a great deal, my language skills have opened many doors for me. Early in my career, I was invited to speak at events where there was no budget for translators or translations, so my multilingual capabilities gained me invaluable exposure. For example, I was a guest lecturer at the Federal Judicial College in Mexico City. It was an excellent opportunity to discuss the use of insolvency as an asset recovery tool with students of the Judicial College, and it would not have been possible to do in English. Of course, I also participate in larger conferences that do have simultaneous translation, such as the OffshoreAlert Conference, but where English is not the common language for all panelists and most of the audience, sometimes it is more convenient to conduct the panel in the local language. Given your tenure as an asset recovery attorney, what is the most important thing you have learned? The most important thing I learned is to follow my instincts and study the fact patterns as they relate to people in the cases. Our cases ultimately come down to people. It’s important to develop a sense of who the target is, their character, preferences and habits. An asset recovery case is only half legal strategy and the rest is about being able to anticipate and catch up to the target. Does speaking three languages facilitate your work on cases? Absolutely! For cases that are document-intensive, being able to read the primary document myself is a game-changer. Translation takes time, costs money and is imperfect. When an important document is discovered or a decision is entered by the foreign court, I can immediately review the document myself and engage in a meaningful discussion about it. I still lean on the local council to assist in interpreting legal documents in Portuguese and Spanish, but at least I can participate in the brainstorming that takes place as events develop and significant documents are discovered. What advice would you give to young female attorneys? I advise young women to look not only for a variety of mentors and role models but also for sponsors within their organization. A sponsor is someone who will help channel good work and opportunities to you, and it is a person who will support you even when you make a mistake. Everyone makes mistakes but it is how they are perceived by leadership that is critical. When people in management feel that the mistake is relatable or perhaps reminds them of something that happened to them, the employee who made the mistake will simply get another chance. And when you are a working mom or the only woman in an organization, you don’t want a simple mistake to be interpreted as a lack of commitment or some deeper problem. It’s important to have someone in the management room to vouch for you and help everyone else to put things into the proper perspective. How does Sequor Law distinguish itself from competitors in the market? Because of the size and strength of our team, we are very nimble. We are not a shop of generalists that tries to be all things to all people. Each of our professionals has deep knowledge of asset recovery and significant practical experience. We vigilantly monitor developments in our area of practice and we are able to draw on our depth of knowledge when we advise clients and help them craft the best recovery strategy for their case. The focus of an asset recovery case may change very quickly, and we need to be able to deploy investigative, analytical and legal resources wherever the target may pop up. We have capabilities in-house to be able to steer the ship. However, one very important aspect of our identity as a boutique firm is that we maintain a strong network of asset recovery professionals that we can rely on throughout the globe. So if the target buys an asset in a new offshore jurisdiction, we can phone a friend who will spring to action as part of our team. What inspired you to study law? As a child, I read all the Nancy Drew books. Although my heroine was a girl detective, when I actually got old enough to think about a career, I realized that I enjoyed the reading a bit more than I would enjoy driving around and chasing criminals. I realized that after a case was solved it had to be tried. My grandfather was a state court judge in Kansas, so he was a great role model and ambassador for the law. When I was in high school, he took me to the courthouse for a motion calendar and I decided that law was the path for me! Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open 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 13, 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.

Sequor Law's Nyana Abreu Miller presents a Portuguese-language comparison of US Bankruptcy Code Chapters 11 and 15 to Brazilian insolvency experts at the Center for Women in Business Restructuring. Chapter 11 – Procedimento, Requisitos E Benefícios Open Events & Speaking Open July 22, 2020 1 minute read Sequor Law Sequor Law attorney Nyana Abreu Miller shared a presentation, in Portuguese, comparing chapters 11 and 15 of the US Bankruptcy Code on an all-star panel of Brazilian insolvency experts for the Center for Women in Business Restructuring (CMR Empresarial). Click here to view the webinar . Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open 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 13, 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.

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 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 13, 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.

International asset recovery law firm Sequor Law strengthens its practice with new attorneys. Red more about their expanded expertise in asset recovery. Sequor Law Expands Asset Recovery Practice With the Addition of Attorneys Michael Hanlon and Noah Rosenblum Open Firm News Open January 12, 2026 2 minutes read Sequor Law Miami – January 13, 2026 – Sequor Law is pleased to announce that Michael Hanlon and Noah Rosenblum have joined the firm as attorneys further strengthening the firm’s asset recovery, cross-border insolvency, and financial fraud practices. Michael Hanlon focuses on asset recovery, cross-border insolvency, and financial fraud litigation. He has worked on complex Chapter 15 bankruptcy matters involving the recovery of hundreds of millions of dollars hidden through layered international structures. He earned his Juris Doctor, cum laude, from the University of Miami School of Law, where he served as a Dean’s Fellow for a First Year Contracts Course and was active in several organizations such as, the Brazilian Law Student Association and the Fashion Law Society. He is fluent in English, Spanish, and Portuguese. Noah Rosenblum concentrates his practice on international commercial litigation, asset recovery, and financial fraud. While in law school, he served as a judicial intern for Judge Miller of the Florida Third District Court of Appeal and as a student clinician in the University of Miami Bankruptcy Clinic. He earned his Juris Doctor, cum laude, from the University of Miami School of Law, where he received the Patricia Redmond Scholarship and co-authored a published article in the International Law Quarterly addressing Section 1782 judicial assistance in international arbitration. Both attorneys were recently sworn into The Florida Bar in a ceremony officiated by the Honorable Corali Lopez-Castro, United States Bankruptcy Judge. “Michael and Noah bring exceptional academic credentials, international perspective, and strong litigation instincts,” said Edward H. Davis, Jr., Founding Shareholder of Sequor Law. “They strengthen our ability to pursue complex, cross-border recoveries and deliver results in high-stakes matters.” Sequor Law continues to expand its global presence and develop the next generation of leaders in asset recovery, cross-border insolvency, and international litigation and arbitration. For more information, visit: www.sequorlaw.com *** Headquartered in Miami and with an office in Washington, D.C., Sequor Law is an international law firm focusing on representing victims of financial fraud, including sovereign governments and state-owned enterprises, public and non-public companies, insolvency practitioners, and all manner of clients in the areas of asset recovery, financial fraud, cross-border insolvency, and international litigation and arbitration. www.sequorlaw.com . Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open 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 13, 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.

Sequor Law highlights recovered artworks from Banco Santos president Edemar Cid Ferreira’s collection—including 95 pieces seized by U.S. authorities in a $10 million money-laundering case that may be auctioned. Trove of Missing Art Heads to Auction Open In the News Open October 28, 2017 3 minutes read Sequor Law A Henry Moore sculpture and a Rufino Tamayo painting are among recovered art works that may be auctioned at Sotheby’s By Kelly Crow Former Banco Santos president Edemar Cid Ferreira once covered the walls of his São Paulo home with Man Ray photographs, Louise Bourgeois prints and paintings by Jean-Michel Basquiat, Francis Picabia and others. But when Brazilian authorities arrested Mr. Ferreira in 2006 for an alleged $1 billion money-laundering scheme, the walls were bare. The vanished collection set off a global scavenger hunt, with investigators and creditors chasing leads long after Mr. Ferreira was convicted of money – laundering and sentenced in federal criminal court in Brazil to 21 years in prison. Mr. Ferreira has appealed the case and declined, through his lawyer, to comment. Mr. Ferreira, the president of Banco Santos, during the World Economic Forum in Davos, Switzerland in 2004. More art once owned by him has been recovered. Photo: Daniel Ackern/Bloomberg News. This month, U.S. authorities announced a breakthrough, saying they had rounded up 95 works Mr. Ferreira once owned that together are worth at least $10 million. The art was in warehouses across France, Panama, England and the Netherlands, according to the U.S. Attorney’s Office for the Southern District of New York. Two paintings in the group were in galleries in New York. Joon Kim, the Acting U.S. Attorney, who said Mr. Ferreira’s art had been “used to mask an audacious criminal scheme,” signed documents turning the trove over to a Brazilian judicial administrator handling the estate of Banco Santos, which failed in 2005. The bank’s estate, which is seeking to compensate creditors, plans to enlist Sotheby’s to auction some of the works, said Arnoldo Lacayo, a lawyer with Sequor Law, a Miami firm helping the bank’s estate track down Mr. Ferreira’s assets. A Sotheby’s spokeswoman confirmed that the auction house has been asked to review the works for potential sale. Major pieces include Henry Moore’s “Woman,” a life-size bronze figure that had been stored in France, as well as Rufino Tamayo’s abstract view of a couple, “Casal de Marcianos 1975 (Two Figures),” which was stored in Florida. There also is a Lucite cube sculpture by Anish Kapoor and works by Brazilian mainstays Adriana Varejão, Vik Muniz and Jac Leirner. Among the older works is an etching by Eugène Delacroix. The fate of Helen Frankenthaler’s 1965 blue-and-gold abstract, “Sea Strip,” offers a glimpse into the circuitous path of some of the art. Mr. Ferreira paid Christie’s $197,900 for “Sea Strip” in late 2004 —a year before his bank failed and a time when authorities said he was starting to ship crates of art to warehouses in Europe for safekeeping. Later, a friend of his wife sold “Sea Strip” to Edward Tyler Nahem Fine Art in New York for an undisclosed sum. John Cahill, a lawyer for the gallery, said Mr. Nahem had been told that the painting was from a corporate collection. Once alerted to its true origins, Mr. Nahem got into a title dispute with the bank’s estate, Mr. Cahill and Mr. Lacayo said, because the dealer had bought the work in good faith. Both sides said they have since reached a settlement to sell the work jointly. Right now, the Frankenthaler is the only recovered work that isn’t immediately headed to Sotheby’s, Mr. Cahill said. Before this month, only a handful of works from Mr. Ferreira’s collection had been found and returned—including a Roman statue and Basquiat’s 1982 “Hannibal,” a skull portrait on an orange background. The work, with its dark slashes, spiky lines and splotches of bright color, is considered a signature piece by Basquiat, who started out as a graffiti artist. Mr. Ferreira bought the painting in 2003 and had it shipped from the Netherlands to a New York warehouse in 2007 after his conviction, authorities said. U.S. Customs took a closer look when the work arrived because its declared value was $100. Jean-Michel Basquiat, ‘Hannibal,’ 1982 Photo: Interpol Washington Last fall, Sotheby’s helped the bank’s estate sell “Hannibal” to Japanese billionaire Yusaku Maezawa for $13 million. “Hiding illicit proceeds in art happens all the time,” said Mr. Lacayo of the asset-recovery firm helping the bank’s estate. “At least in this case we’re unraveling it.” Click to view full article. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open 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 13, 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.

Sequor Law's Edward H. Davis Jr. joined ICC FraudNet leaders at the ThoughtLeaders4 FIRE International conference in Vilamoura, Portugal on May 19, 2022. Thought Leaders 4 Fire: FIRE International Vilamoura, Portugal May 19, 2022 Open Events & Speaking Open May 19, 2022 1 minute read Sequor Law Incoming ICC FraudNet Co-Executive Director Rodrigo Callejas with Strategic Partner James Pomeroy and former Executive Director Edward H. Davis in Cyprus for the FraudNet Spring meeting. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open 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 13, 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.

Sequor Law partners Leyza B. Florin, Edward H. Davis Jr., Gregory Grossman, and Arnoldo Lacayo named to the inaugural Lawdragon 500 Leading US Bankruptcy & Restructuring Lawyers guide. The 2020 Lawdragon 500 Leading U.S. Bankruptcy & Restructuring Lawyers Open Awards & Recognition Open July 24, 2020 1 minute read Sequor Law 24 July 2020 Sequor Law Partners Leyza B. Florin , Edward H. Davis, Jr. , Gregory S. Grossman and Arnoldo “Arnie” Lacayo were named to the inaugural Lawdragon 500 Leading US Bankruptcy & Restructuring Lawyers guide. Included in the Global guide are lawyers with leading cross-border practices that “bring remarkable skills in financing, structuring, litigating and creating a pathway forward” for their clients. Open the article here Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight 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 13, 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.

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 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 13, 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.

Sequor Law Attorney Maria Jose Cortesi authors "Navigating the Extraterritorial Tightrope in the Bankruptcy Code" for the American Bankruptcy Trustee Journal, Vol. 40, Issue 02. Navigating the Extraterritorial Tightrope in the Bankruptcy Code Open Legal Insights Open October 22, 2024 1 minute read Sequor Law Read the insightful article Maria Jose Cortesi contributed to the American Bankruptcy Trustee Journal on page 15, titled “Navigating the Extraterritorial Tightrope in the Bankruptcy Code.” This article was written for and originally appeared in Volume 40, Issue 02 of the American Bankruptcy Trustee Journal, a publication of the National Association of Bankruptcy Trustees (“NABT”), and is being reproduced with the consent of the NABT and the author. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open 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 13, 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.