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

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

A forum article examining how managers and allies can better support underrepresented attorneys in law firms, featuring insights from Sequor Law's Gregory Grossman. Forum: The critical role of managers and allies in the legal profession Open In the News Open June 23, 2021 4 minutes read Sequor Law In the corporate world, managers of diverse employees have significant influence over their employees’ success and play a major role in retaining and developing those employees. While the same is true in the legal industry, it is harder to determine who is the diverse attorney’s manager. Most associates work with a variety of partners, even at smaller law firms, so it is more difficult to say which partner wears the label of “manager.” Unfortunately, this often means that it becomes less clear who is responsible for developing, supporting and promoting diverse attorneys. However, it is the underrepresented – people of color, women, LGBTQ+ persons, individuals with disabilities and veterans – who need effective advocates in the workplace beyond their manager. And these advocates are the courageous allies in society that work to create more equitable and inclusive experiences and workplaces. All law firms have their own distinct structure, and this structure determines who is responsible for guiding a diverse associate on their path to success. Obviously, the partner who assigns work should be the first advocate for the attorney’s career. Second, practice area leaders (or similar positions) may not interact with diverse attorneys regularly but are responsible for the overall success of all the attorneys under their purview. In some cases, firms also have a person in an administrative role who oversees work assignments, evaluations and feedback – another good candidate to be an advocate. And finally, formal and informal mentors play a role. In the legal world, all the above-mentioned leaders should act as “manager” in an effort to positively impact diverse associates’ career trajectories and enhance the firm’s retention. Issues arise, however, when none, or only one, of these people step up and accept the responsibility. Ensuring that diverse attorneys have access to formalized work assignments, professional development opportunities, mentoring programs and sponsorship commitments does not happen without a concerted effort. Firm leaders should focus on these four areas to make sure advocacy happens within the firm: Building relationships Wesley Bizzell, senior assistant general counsel of Altria Client Services and president of the National LGBT Bar Association, notes that “time is a challenge,” whether in a corporate law department or a law firm, but that “plain old-fashioned listening” is vital to a manager’s role in supporting diverse attorneys. Creating relationships with diverse attorneys shows the manager is making an investment in attorney careers. The key is to create a “sincere relationship with people because it will pay off in the long term,” says Ronald Jordan, senior principal director at Carter-White & Shaw. “It is an investment.” Providing opportunities It is critical for diverse attorney success that managers be conscious of how and to whom they assign work and the quality of those assignments. “It’s important to be thoughtful about high-profile work across the team,” explains Bonnie Lau, partner at Morrison & Foerster and alumni chair of the Leadership Council on Legal Diversity. “It is common knowledge that partners tend to rely on their choice colleagues, which often excludes underrepresented diverse attorneys.” Ensuring a pipeline of work Developing key legal competencies is vital for all attorneys, and work assignments are the primary mechanism in how attorneys gain that skill and knowledge. No matter who controls the pipeline, “just getting diverse attorneys noticed and valued so that they gain access is what is important,” says Gregory Grossman , partner at Sequor Law. Managers, however defined in a law firm, need to ensure their diverse attorneys get the experience necessary to stay on track at their firms, and there are many ways managers can do this. For example, to ensure the firm’s work was equitably distributed, Jenner & Block piloted a new work assignment process to create “more oversight and insight starting with the new associates,” notes Courtney Carter, Jenner & Block’s director of diversity and inclusion. Promoting allyship An ally is an individual who helps to create work cultures that attract and retain the highest quality attorneys. These allies commit to diversity, equity and inclusion in meaningful and lasting ways to best support the advancement of underrepresented attorneys. An ally also must demonstrate courage and agree to risk their political capital for underrepresented attorneys. This includes “offering to introduce colleagues from underrepresented groups to influential people within your network,” says Keyonn Pope, partner at Reed Smith. Being an ally What does it mean to be an ally within a legal organization? Senior attorneys who hold positions of influence often act as allies to those with less access, taking responsibility for implementing changes that will enable underrepresented attorneys’ success. “Being an ally, or accomplice, requires a commitment to use one’s personal and professional platform to create positive change,” says Daniel L. (D.L.) Morriss, diversity, equity and inclusion (DEI) partner at Hinshaw & Culbertson. Indeed, an ally can perform powerful acts such as recommending newer colleagues for high-profile work, stretch assignments and learning opportunities. Allies can also demonstrate support by creating a safe space for attorneys to be their authentic selves, normalizing mental health and wellness issues, and suggesting diverse attorneys to be speakers or panelists. “There are people who support DEI and want to be allies,” explains Taylor Wilson, managing partner of Haynes and Boone, adding it’s important to “empower them to use their voices and privilege to better advocate for change.” Allies also seek to create systemic change within the organization, not just remove barriers for specific underrepresented attorneys. This can be done through resource funding, salary review, inclusive hiring practices, inclusive employee benefit plans, nursing rooms, wellness rooms, prayer rooms, venue accessibility and all-gender restrooms. Ultimately, allies must give honest and constructive feedback and overcome fears that the receiver will not accept the feedback. Studies have found that African American lawyers receive extra scrutiny from supervising attorneys, which can lead to poor performance reviews, lower bonuses, less visible assignments and job loss. The feedback should be specific. When pinpointing something negative, offer assistance and highlight ways and resources to improve. The key is to tie all feedback to business goals. In the legal field, diversity of thought and perspective are critical to servicing clients at the highest level. Managers and allies will help law firms move the needle forward in creating an environment in which all underrepresented communities are afforded equal access to quality work and opportunities. Remember, the ultimate goal of a diverse workforce is to promote a stronger cross section of perspectives, experiences and insights to solve clients’ legal challenges. This should be the goal of every attorney and law firm leader. To see the original article, click here. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..

BVI liquidators of three funds linked to the 1MDB fraud seek Chapter 15 recognition in Miami to pursue US discovery and recover billions allegedly stolen from Malaysia's sovereign wealth fund. BVI funds linked to 1MDB fraud seek recognition in Miami Open In the News Open April 11, 2022 3 minutes read Sequor Law Ben Clarke The joint liquidators of three British Virgin Islands funds that were allegedly part of a huge fraud perpetrated against Malaysian sovereign wealth fund 1MDB have sought recognition in Miami to further their investigations. In a 5 April filing in the US Bankruptcy Court for the Southern District of Florida, the joint liquidators of SRC International (Malaysia) (SRC BVI) and two subsidiaries sought Chapter 15 recognition of their appointments in the BVI to help recover some of the billions of dollars allegedly stolen from 1MDB. One of the joint liquidators, BVI-based Helen James of Hyperion Risk Solutions, said in court filings that the joint liquidators need to obtain discovery in the US to help with their recovery efforts and investigations into the debtors’ business activities. Authorities have been investigating 1MDB and an entity it established in Malaysia, SRC International (SRC Malaysia), since 2015 over allegations of fraud and money laundering. As part of the scheme, James said numerous entities and individuals formed a network to divert and distribute funds to fraudsters who diverted or siphoned off US$8.5 billion from 1MDB and SRC Malaysia, which is the parent of the three BVI funds. According to James, most investigation attempts in Malaysia were thwarted by the Malaysian government because the country’s Prime Minister, Najib Razak, was the driving force behind the creation of 1MDB. But Najib was removed from office in 2018 and, with other co-conspirators, was subject to criminal and civil proceedings in Malaysia and elsewhere in relation to misappropriation of 1MDB funds. Local authorities later sought cooperation with global law enforcement agencies, including the United States Department of Justice (DOJ), which has actively investigated multiple parties and seized assets in relation to the fraud over the last six years. Last week, a Brooklyn federal court convicted former Goldman Sachs banker Roger Ng for his role in the scandal, which saw Goldman Sachs secure bond transactions worth US$6.5 billion. But James said the DOJ has focused its efforts on 1MDB and not SRC Malaysia, despite the latter losing about US$1.15 billion. The joint liquidators of the three BVI funds – James, Quantuma’s Caribbean head Angela Barkhouse in the Cayman Islands, and chief executive Carl Jackson in the UK – have brought civil proceedings against other companies in multiple jurisdictions since they were appointed in July and August last year. But James said the joint liquidators suspect there are companies and trusts related to the fraud that are yet to be uncovered. “[T]he full extent of the fraud is unknown,” she said. “The liquidation of the debtors forms parts of an international effort to trace and recover funds misappropriated through SRC Malaysia.” James said that throughout its existence SRC BVI has been principally used by fraudsters to misappropriate funds. She also claimed one of the other debtors, Bright Oriande (BOL), is believed to have had no legitimate business activity and was established solely to divert funds from 1MDB and SRC Malaysia. BOL’s existence was apparently concealed from SRC Malaysia’s board. Through their investigations, the joint liquidators have identified a series of suspicious transactions involving the three debtor companies, including over US$1 billion of funds that were transferred from SRC Malaysia to SRC BVI accounts in Hong Kong and Switzerland. The joint liquidators suspect that some of the millions of dollars that are still unaccounted for in relation to the fraud may be in the US. Jones said they need to obtain discovery relating to various transactions to help them trace estate assets and other entities related to the three BVI funds. Judge Robert Mark has listed a recognition hearing for 18 May. 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 James 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 attorney Juan Mendoza in Miami In the British Virgin Islands Commercial Division Joint liquidators of SRC International (Malaysia) et al Hyperion Risk Solutions Group head of finance Helen James 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 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 Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..

Sequor Law's Ed Davis, Leyza Florin, and Juan Mendoza examine the challenges of seeking US recognition of individual debtors' foreign insolvency proceedings and COMI determination under Chapter 15. Asset recovery column: Recognition of an individual debtor’s insolvency proceeding – beware the perils Open Legal Insights Open March 27, 2019 5 minutes read Sequor Law Ed Davis, Leyza B. Florin and Juan Mendoza Shareholders Edward Davis Jr and Leyza B. Florin , and attorney Juan Mendoza from Sequor Law in Miami discuss the things to watch out for when seeking recognition of an individual debtor’s foreign insolvency proceedings in the US. Recognition of a foreign insolvency proceeding in the United States allows the use of an arsenal of asset recovery weapons for a cross-border practitioner, including the opportunity to obtain discovery relating to the financial condition of the debtor, and to commence actions to collect property and liquidate claims. This arsenal may be particularly effective in situations where an individual debtor flees the jurisdiction of his or her pending bankruptcy case to the United States. Such a change of circumstances may disturb the debtor’s ties with the jurisdiction of the pending insolvency, however, and alter the foreign trustee’s ability to obtain recognition of the foreign insolvency in the United States. This column discusses the nuances a practitioner must consider when pursuing recognition of an individual debtor’s foreign insolvency under Chapter 15. To obtain recognition of a “foreign main proceeding” under Chapter 15 – the United States’ analogue to the Model Law on Cross-Border Insolvency – a foreign representative of the foreign insolvency proceeding must show, among other things, that the foreign proceeding is pending in the country where the debtor has his or her centre of main interests (COMI). An individual debtor’s COMI is defined as the debtor’s “habitual residence”. The foreign representative may also obtain recognition of the foreign proceeding as a foreign non-main proceeding if the debtor has an “establishment” in the country where the foreign proceeding is pending. “Establishment” is defined as a place of operations where a debtor carries out non-transitory economic activity. As the determination of an individual debtor’s COMI or establishment is a fact-intensive inquiry, the operative date for the determination of COMI or establishment could be pivotal in obtaining recognition. US courts are split on the operative date for the determination of the COMI. Some courts have noted that the operative date to determine the COMI is the date on which the Chapter 15 petition was filed. However, several US courts have held that the operative date for determining a debtor’s COMI or establishment is the date on which the foreign insolvency commenced. Though this split of authority is yet to be specifically addressed in the text of Chapter 15, UNCITRAL’s revision to the Guide to Enactment and Interpretation of the UNCITRAL Model Law on Cross-Border Insolvency in 2013 clarified that the date of the commencement of the foreign proceeding is the operative date to determine the COMI. It would be up to the US Congress to pass an amendment to Chapter 15 to conform it to this development, which to date remains an open issue for US courts. In a situation where an individual debtor moves to the United States after the commencement of the initial insolvency proceeding and establishes residence and financial ties in the US, the determination of the COMI or establishment – and possibility of recognising the foreign insolvency proceeding – is a function of whether the operative date for the determination of COMI or establishment is the date of the filing of the initial proceeding or the Chapter 15 proceeding. If the operative date were the commencement of the foreign proceeding, as clarified by the Guide to the Model Law, the individual debtor’s habitual residence would likely be located in the foreign jurisdiction. This would likely result in the finding that the debtor’s COMI or establishment was the jurisdiction of the foreign proceeding. The opposite is true if the operative date is the date of the Chapter 15 filing, as the individual debtor may have developed close ties to the United States, such as changing address, opening new bank accounts and establishing other signs of permanency. Once the operative date is established, the court must analyse the debtor’s circumstances to determine the debtor’s COMI or establishment. As habitual residence is not defined by the bankruptcy statute, it raises yet another level of uncertainty. Though there is no definition for the term habitual residence, courts seem to equate habitual residence with domicile, a concept typically used in the bankruptcy context in the analysis of venue and exemptions to discharge. Like domicile, habitual residence refers to both an individual debtor’s physical presence, or residency, and the debtor’s intent to remain at that residence. The former consideration may seem like a straightforward one since it is hard to dispute a debtor’s physical presence. Yet situations arise where a debtor travels between two separate countries, which makes the analysis of physical presence more difficult. The latter consideration of intent requires an inquiry relating to the debtor’s state of mind, which involves both objective and subjective considerations. To assist with the analysis of the debtor’s state of mind, courts consider the location of a debtor’s family, the debtor’s reasons for moving, the length and continuity of the debtor’s residence, the stability and continuity of the debtor’s employment, and apparent intentions to remain at his or her residence. Courts also consider documents filed with governmental agencies, such as immigration documents, to discern whether a debtor intended to remain in a certain place. As every individual has different circumstances, the factual scenarios regarding the debtor’s habitual residence are endless. Consider the following examples: a businessperson who travels between offices in different countries with family in both countries; a couple that move to the United States on an investor visa but leave their children in their home country; and a person with no family who moves to the United States as a permanent resident but is incarcerated for a significant period. Each scenario would entail a unique analysis regarding the debtor’s state of mind. A Florida decision displays the factual complexity that may complicate an individual debtor’s Chapter 15 COMI analysis. In Richardson, the court analysed the habitual residence of an individual debtor who was in the process of moving to Florida from the UK under an investor visa, shortly after the commencement of an insolvency proceeding against him in the UK. Analysing the debtor’s COMI as of the commencement of the UK insolvency proceeding, the bankruptcy court noted that as of that date, the debtor no longer owned a home in the UK or operated a business in the UK, but retained his UK passport, UK pension account, UK email address, and immediate and extended family in the UK. Importantly, the court emphasised the debtor’s investor visa documentation, which contained a sworn statement that he fully intended to return to Great Britain upon the expiration of his visa term. Accordingly, the court held that the UK was the debtor’s habitual residence and COMI, and granted recognition of the debtor’s UK insolvency proceeding. Practitioners must be aware of the uncertainty in the case law with respect to the operative date for the determination of an individual debtor’s COMI or establishment, and the lack of uniformity presently employed by US courts in assessing an individual debtor’s habitual residence. Most importantly, practitioners must be prepared to make factual assessments of the debtor’s circumstances and face challenges presented by such factors required to prove an individual debtor’s habitual residence. References Guide to Enactment and Interpretation of the UNCITRAL Model Law on Cross-Border Insolvency (2013 revision), section 141. In re Richardson, Case No. 9:14-bk-04875-FMD, DE 120 (Bankr. M.D. Fla. 1 June 2016). In re Loy, 380 B.R. 154 (Bankr. E.D. Va. 2007). In re Ran, 607 F.3d 1017 (5th Cir. 2010). In re Kemsley, 489 B.R. 346 (Bankr. S.D.N.Y. 2012). United Nations Commission on International Trade Law (UNCITRAL), Model Law on Cross-Border Insolvency, 10, U.N. Gen. Assembly, UNCITRAL 30th Sess., U.N. Doc. A/CN.9/442 (1997), is available at their website . Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..

Sequor Law Shareholder Leyza B. Florin paneled the "Attack the Sham" session on asset recovery toolkits at the ThoughtLeaders4 FIRE International conference in Vilamoura, Portugal. Thought Leaders 4 Fire: FIRE International Vilamoura, Portugal May 19, 2022 Open Events & Speaking Open May 24, 2022 1 minute read Sequor Law Sequor Law Shareholder Leyza B. Florin was a panelist at ThoughtLeaders4 FIRE International where she participated on the Attack the Sham panel about asset recovery toolkits along with co-panelists Hannes Arnold , Senior Partner – GASSER PARTNER Attorneys at Law , William Redgrave, Partner – Baker & Partners , Simon Jerrum , Partner – HFW . Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..

Sequor Law welcomes Alain M. Acanda, an attorney with experience in commercial litigation, § 1782 discovery proceedings, and international arbitration, strengthening the firm's asset recovery practice. Sequor Law Welcomes Attorney Alain M. Acanda to Its Expanding Asset Recovery Team Open Firm News Open May 12, 2025 2 minutes read Sequor Law Miami, Florida – May 13, 2025 – Sequor Law, a leading international firm in asset recovery and cross-border litigation, is pleased to announce the addition of Alain M. Acanda as an attorney, further strengthening the firm’s capabilities in asset recovery, creditors’ rights, and complex commercial litigation. Alain joins Sequor Law with a strong background in litigation from both state and federal court, with experience that includes drafting motions and pleadings in commercial and institutional arbitration and 28 U.S.C. § 1782 discovery proceedings. Before joining Sequor Law, Alain worked with specialist litigation firms where he handled matters involving commercial and international disputes and intellectual property. Alain earned his J.D. cum laude from Florida International University College of Law, where he was an active member and judge for the Moot Court team and served as vice president of both the Hispanic Law Student Association and the Caribbean Student Bar Association. He also received recognition as Best Respondent Brief and Quarterfinalist at the 2023 Billings, Exum & Frye National Moot Court Competition. “We continue to attract top-tier talent to meet the increasing demand for our services worldwide,” said Edward H. Davis Jr., Founding Shareholder of Sequor Law. “Alain brings exceptional research and writing skills, along with a sharp understanding of asset recovery frameworks.” “His addition reflects our commitment to growing a deep bench of multilingual, globally-minded litigators,” added Gregory S. Grossman, Sequor Law Founding Shareholder. Admitted to practice in Florida and the U.S. District Court for the Southern District of Florida, Alain is fluent in both English and Spanish, enhancing the firm’s ability to serve a diverse and international client base. This appointment marks another milestone in Sequor Law’s strategic growth as it continues to represent sovereign governments, insolvency practitioners, financial institutions, and corporations across jurisdictions. For more information, visit: www.sequorlaw.com *** Sequor Law is an international law firm focusing on representing victims of financial fraud, including sovereign governments and state-owned enterprises, public and non-public companies, insolvency practitioners, and all manner of clients in the areas of asset recovery, financial fraud, cross-border insolvency, and international litigation and arbitration. www.sequorlaw.com . Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..

After a 2018 due process win, the government invoked the state secrets privilege to dismiss Tara J. Plochocki’s client’s targeted-killing challenge in 2019. U.S. Invokes State Secrets Privilege to Block American Journalist’s Challenge to Alleged Spot on Drone ‘Kill List’ Open In the News Open September 24, 2019 2 minutes read Sequor Law A U.S. citizen asked a simple question: was his own government trying to kill him? In September 2019, a federal court decided he was not entitled to an answer. The plaintiff was Bilal Abdul Kareem, an American journalist who said five near-miss airstrikes in Syria suggested he had been placed on a U.S. targeted-killing list. His case had already cleared a hurdle that few claims of its kind survive. In 2018, U.S. District Judge Rosemary M. Collyer had ruled that Kareem, as a citizen, could press a due-process challenge to his alleged inclusion on that list. That opening did not last. After settlement talks between Kareem's lawyers and the government collapsed, the government invoked the state secrets privilege, arguing that even confirming or denying his presence on any list would expose intelligence sources and methods and might help a target evade capture. Collyer agreed the government's authority to withhold that information was "absolute," and she dismissed the suit in a 14-page opinion. She named the tension directly, asking what constitutional right could be more essential than due process before the government takes a life, then concluding that federal courts hold only limited authority to resolve such questions, even when they touch constitutional rights. Tara J. Plochocki , today a partner at Sequor Law, represented Kareem and pushed the matter as far as the doctrine allowed. Her reaction drew the line plainly: "For the first time ever, a United States federal court ruled that the government may kill one of its citizens without providing him the information necessary to prove that he is being wrongly targeted." An early win recognized the right to be heard. The state-secrets dismissal then left that right unenforceable. Secrecy, in other words, can decide a case before a court ever reaches its merits. That collision between a citizen's claim and the executive's classification powers is the kind of problem Plochocki has built a career around, litigating where constitutional rights, international law, and national security meet. Her work at Sequor Law runs on the same instinct: securing evidence that adversaries would rather keep hidden, and pressing claims through federal courts and on appeal. Cross-border asset recovery and financial fraud both turn on prying loose concealed information. The Kareem case is a stark reminder of what is at stake when a court cannot compel its disclosure. The full account appeared in The Washington Post . Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..

Daniel Coyle of Sequor Law analyzes Florida's adoption of the Uniform Commercial Real Estate Receivership Act (UCRERA) — receiver powers, procedures, key differences from the Model Act Florida’s New Commercial Real Estate Receivership Act Open Legal Insights Open September 30, 2020 1 minute read Daniel M. Coyle Florida’s New Commercial Real Estate Receivership Act By Daniel Coyle In July, Florida became the ninth state to adopt the Uniform Commercial Real Estate Receivership Act (“UCRERA”). 1 The timing could not be better, given the near-universal prediction that defaults on commercial loans will skyrocket due to the COVID-19 pandemic once foreclosure moratoriums end and the growing suspicion that many borrowers will not reflexively file for bankruptcy. Those with experience as federal equity receivers and Chapter 7 trustees will find they are well suited to creatively and effectively use the greater powers receivers enjoy under UCRERA to achieve better and more fruitful outcomes. Drafted in 2019 by the Uniform Law Commission, UCRERA significantly broadens the powers of state receivers of commercial real property while also establishing a standard set of rules governing the reasons authorizing appointment and the procedures for seeking appointment. 2 UCRERA’s passage is a welcome event for receivers, trustees, fiduciaries, lenders and other parties involved with commercial real estate along with their counsel. This article will analyze Florida’s UCRERA as well as to point out some key differences between Florida’s version and the Model Act. I. Florida’s Receivership Scheme Prior to UCRERA In Florida, prior to UCRERA’s enactment, receivers were generally appointed as an equitable remedy to preserve the status quo of the real estate and to collect the rents and profits. 3 Appointment was difficult to obtain because: (1) it was in derogation of the common law, and; (2) it divested the property owner of the owner’s right to manage and control the property. 4 Consistently with this, the applicant also had to meet a high burden by demonstrating a serious and significant ongoing loss, usually, but not always, in the form of waste, even if the applicant had a right to appointment in a mortgage. 5 The waste could take the form of ongoing damage or disrepair of the real property, failing to pay property taxes, or failure to turn over rents. 6 Once appointed, the ultimate rights, duties and liabilities of the receiver were solely determined from the language of the order of appointment. In other words, they were left completely up to the court. One might think this discretion could result in robust powers but case law curtailed these powers significantly. For instance, it was improbable, if not impossible, to obtain an appointment order empowering the receiver to sell the real property 7 because appointment does not affect the title to property or deprive the owner of rights to the property. 8 Instead, receivers were limited to managing the property in the ordinary course of business. II. UCRERA’s Scheme A. The Receiver’s Powers under UCRERA UCRERA broadens the powers of a receiver significantly, to the degree that the receiver obtains many of the same powers as a Chapter 7 trustee in bankruptcy. The receiver is given the status of lien creditor under Florida’s recording statute chapter (Ch. 695 Fla . Stat .) and Florida’s enactment of the UCC pertaining to secured transactions (Ch. 679 Fla. Stat. ), similarly to 11 U.S.C. §544 as to receivership property or fixtures. 9 Thus, the receiver may now pursue avoidance/clawback actions regarding the property as a Chapter 7 Trustee or Debtor-in-Possession would. 10 Similarly to 11 U.S.C. §542, the receiver is entitled to turnover of receivership property. Persons owing debts that constitute receivership property must pay those debts to the receiver. 11 One of the most significant improvements is that the receiver is authorized to sell the property before or after judgment. The receiver is now authorized to sell the receivership assets outside of the ordinary course of business before judgment and with the approval of the owners, 12 or after judgment and with court approval 13 , much like the bankruptcy process under 11 U.S.C. §365. As in a bankruptcy “363 sale,” this is a sale of the asset “free and clear” of liens on the property, with the liens attaching to the proceeds. 14 Good faith purchasers are protected from reversal or modification on appeal of an order approving the sale. 15 The receiver also has the power to accept or reject executory contracts relating to the property with court approval. 16 This power may be used even if the appointment of the receiver constitutes a breach under the contract. 17 Also, the receiver's performance of an executory contract before court approval of its adoption or rejection does not preclude the receiver from later seeking approval to reject the contract. 18 Similarly to a section 362 stay in bankruptcy, the court may enter an order providing for a stay of acts relating to the property to protect against misappropriate or waste. 19 This order must describe in reasonable detail the act or acts restrained. 20 With court approval, the receiver may incur debt outside of the ordinary course of business, make improvements to the receivership property, make a distribution of receivership property, and take the other actions described above regarding selling the property, adopting or rejecting executory contracts. 21 In addition to those innovative provisions, the receiver also has the more typical powers to collect, control, manage and perfect the property, operate the business, incur unsecured debt and pay expenses in the ordinary course of business, assert rights, claims and defenses relating to the property, and engage professionals. 22 Regarding its duties, the receiver must prepare and retain appropriate records, including a record of each receipt, disbursement and disposition of the property, account for the proceeds of all dispositions, file a copy of the order of appointment and disclose any fact arising which would disqualify the receiver. 23 The receiver’s powers and duties may be expanded, modified or limitedby court order. 24 To further the goal of standardization of appointments and broaden the receiver’s powers, UCRERA contains two provisions that seek to homogenize processes across state lines . The court may appoint a receiver already appointed in another state or even the nominee of that receiver as an ancillary receiver of property located within the state, so long as the person would be eligible for appointment under the standards of UCRERA. 25 The ancillary receiver has the same rights, powers, and duties as a receiver appointed under the statute. 26 Additionally, the Court may domesticate an order entered in another state appointing or directing a receiver. 27 The Act also provides that decisions of other states interpreting UCRERA’s provisions are persuasive authority. 28 A court may award a receiver the reasonable and necessary fees and expenses of performing its duties and exercising the receiver's powers from the revenue generated by the property. 29 Or, the court may order either the person who requested the appointment or the person whose conduct justified the appointment to pay the reasonable and necessary fees and expenses of the receivership. 30 B. Sufficient Cause for Appointment UCRERA provides grounds for authorizing an appointment prior to a judgment and grounds for authorizing an appointment after entry of a judgment. 31 A court may appoint a receiver before judgment if the property or its revenue-producing potential: (1) is subjected to waste, loss, substantial diminution in value, dissipation, or impairment or (2) has been, or is about to be, the subject of a voidable transaction. 32 After judgment, a court may appoint a receiver:(a) to the judgment or (b) to preserve the property pending appeal or when an execution has been returned unsatisfied and the owner refuses to apply the property in satisfaction of the judgment. 33 UCRERA also provides a non-exhaustive list of factors to be considered in ruling on a request for appointment based upon a mortgage, which include many of the same themes discussed previously (e.g., protection from waste, loss, diminution in value, etc.). C. Procedure for Appointment The Florida provision governing appointments 34 was significantly augmented from the Model Act because the Florida Rule of Civil Procedure governing appointments provides significant due process protections with which Florida's version of UCRERA had to harmonize. An appointment requires notice and opportunity for hearing, except that the court may issue an order without notice if immediate and irreparable injury, loss or damage will result to the applicant or that waste, dissipation, impairment, or substantial diminution in value will result before any adverse party can be heard. 35 The person seeking appointment without prior notice or hearing must provide security for the payment of damages, reasonable attorney fees, and costs incurred or suffered by any person if the court later concludes that the appointment was not justified. 36 ENDNOTES 1 Oregon, Utah, Nevada, Tennessee, Michigan, Arizona, Maryland, and North Carolina are the others. Connecticut has introduced a bill to enact the law. 2 According to section 714.04(1), UCRERA applies to a receivership initiated in a court of Florida for an interest in real property and any incidental personal property related to or used in operating the real property. The insertion of the term “incidental” was to make clear that the Act does not apply to personal property broadly, but instead only to personal property connected with or associated with commercial real property (e.g., fixtures). Property is defined broadly and expansively in section 714.02(13) to include all “right, title, and interest, legal and equitable … and includes proceeds, products, offspring, rents, and profits.” 3 U.S. Bank Nat. Ass'n v. Cramer , 113 So. 3d 1020, 1023 (Fla. 2d DCA 2013). 4 Twinjay Chambers P'ship v. Suarez , 556 So. 2d 781, 781 (Fla. 2d DCA 1990). 5 Boyd v. Banc One Mortg. Corp., 509 So. 2d 966 (Fla. 3d DCA 1987). 6 Smith v. State Life Insurance Company , 153 So. 842 (1934); Smith v. DuPuis , 157 So. 491 (1934); ( Carr v. Marion Mortg. Co ., 128 So. 12 (1930). 7 See, e.g., Shubh Hotels Boca, LLC v. Fed. Deposit Ins. Corp. , 46 So. 3d 163, 167 (Fla. 4th DCA 2010). 8 Eppes v. Dade Developers Inc. , 170 So. 875 (1936). 9 Fla. Stat. §714.09. III. Conclusion UCRERA is a significant and welcome step in both standardizing the rights, powers, duties, and procedures related to state receivers of commercial real property. With the moratoriums on foreclosures in multiple states ending or coming to an end and the expected increase in commercial loan defaults, Florida’s enactment of UCRERA is timely, and more states should consider passing their own versions of the Act. END About the Author : Daniel Coyle is an attorney with Sequor Law in Miami. His practice focuses on bankruptcy , creditors’ rights , secured transactions, collections , executions, asset recovery and cross-border insolvency . dcoyle@sequorlaw.com 10 One limitation to this is that under Fla. Stat. §714.10, appointment does not affect the validity of a pre-receivership perfected security interest or property acquired post-receivership under a perfected floating lien. 11 Fla. Stat. §714.11. 12 Fla. Stat. §714.16(2). 13 Fla. Stat. §714.16(3). 14 Fla. Stat. §714.16(4). 15 Fla. Stat. §714.16(6). 16 Fla. Stat. §714.17. 17 Fla. Stat. § 714.16(4). 18 Fla. Stat. §714.17(3). Also, under Fla. Stat. §714.17(5), if the executory contract is rejected, it is treated as if it were breached as of the day before the date the receiver was appointed so that the aggrieved party may assert rejection damages against the receivership estate. 19 Fla. Stat. §714.14. 20 Fla. Stat. §714.14(3). The permissive nature of this stay and the description requirements in the order are different than the Model Act, which provides that the appointment automatically provides for a such a stay. A person affected may apply for relief from the stay and the court must hear the motion within five (5) days or at such time as the court determines is reasonable and appropriate. Fla. Stat. §714.14(4). 21 Fla. Stat. §714.12(2). 22 Fla. Stat. §714.12(1). 23 Fla. Stat. §714.12(3). 24 Fla. Stat. §714.12(4). 25 Fla. Stat. §714.24(1)(a). 26 Fla. Stat. §714.24(3). 27 Fla. Stat. §714.24(2). 28 Fla. Stat. §714.26. 6 | P a g e 29 Fla. Stat. §714.21(1). 30 Fla. Stat. §714.21(2). 31 Fla. Stat. §714.06. 32 Fla. Sta. §714.06(1)(a). 33 Fla. Sta. §714.06(1)(b). 34 Fla. Stat. §714.03. 35 Fla. Stat. §714.03(2). 36 Fla. Stat. §714.06. Subsection 714.06(3) also provides that, if and when the Court determines the appointment was justified, and the order of appointment becomes final and no longer subject to appeal, the court will release the bond or other security. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..

Sequor Law's Leyza B. Florin and Christopher Noel analyze the Second Circuit's evolving Section 1782 standard in the Euromepa and Gorsoan cases and its implications for global discovery. Asset recovery column: Euromepa and Gorsoan, oh my Open Legal Insights Open January 5, 2021 7 minutes read Sequor Law Sequor Law shareholder Leyza B. Florin and attorney Christopher Noel discuss the evolving standard to obtain Section 1782 assistance in the US Court of Appeals for the Second Circuit and beyond. The US Court of Appeals for the Second Circuit, which includes the states of Connecticut, New York, and Vermont within its jurisdiction, is currently tasked with addressing and deciding how far to extend an ever-narrowing standard applied to proceedings brought pursuant to Section 1782 of the United States Code. In out of the US District Court for the Southern District of New York, the Second Circuit has been asked to decide whether an application for judicial assistance to obtain discovery for use in aid of a foreign judgment meets the statutory requirements for relief to be granted pursuant to Section 1782. The ramifications of the Second Circuit’s decision are certain to resonate globally, as New York remains a hotbed for seeking US judicial assistance for foreign tribunals, both because of its geographic proximity to Europe and because of the myriad of global businesses that identify New York as their principal places of business. As many global restructuring and insolvency practitioners are aware, Section 1782 is the product of more than 150 years of effort from the US Congress to provide federal-level court assistance in gathering evidence in the US for use in a foreign tribunal. Generally, whether to grant this assistance is determined by a two-part inquiry: (1) whether a US District Court is to grant relief pursuant to Section 1782; and (2) whether a US District Court grant relief in its broad discretion. At issue before the Second Circuit is one of the statutory prongs examined when a US District Court is deciding whether it is authorised to grant relief –to wit, that the evidence sought must be “for use in a proceeding in a foreign or international tribunal.” The case began with an alleged US$25 million fraud, which caused a Cypriot court to issue a worldwide freezing injunction and asset disclosure order against dozens of defendants, including the Belarusian born, Florida-based socialite Janna Bullock. After Bullock refused to comply with the Cypriot court’s order, Gorsoan, a Cyprus company and fraud victim, sought assistance in the US District Court for the Southern District of New York, pursuant to Section 1782. Upon challenge in the Second Circuit, the appellate court affirmed the order granting judicial assistance and Bullock was required to produce the requested discovery. Much to the dismay of Gorsoan, and fellow fraud victim Gazprombank, Bullock failed to produce substantive discovery in response to Gorsoan’s requests. As a result, Gorsoan obtainedleave of court and a court order to take a second deposition of Bullock. At this second, court-supervised deposition, Bullock refused to answer questions by invoking her Fifth Amendment right against self-incrimination. Thereafter, Gorsoan led its second application for judicial assistance pursuant to Section 1782, seeking authorisation to subpoena Bullock’s children, mother, and other related persons. The District Court granted that application and Gorsoan’s subsequent motion to compel, which led to Bullock’s intervention and a motion to quash the subpoenas. In January of this year, the Southern District of New York denied Bullock’s defensive motions and granted Gorsoan’s motion to compel related to its subpoenas. Atpresent, the Southern District of New York’s decision remains on appeal at the Second Circuit. However, based upon its own prior precedent in , which broadly held that enforcement of a foreign judgment does not meet the “for use” prong required for Section 1782 relief, the Second Circuit may well further limit Section 1782’s use for obtaining discovery in the United States for use in foreign tribunals. In , the dispute stemmed from an insurance claim for approximately US$20 million in lost or stolen diamonds and other precious jewelry owned by jeweler Esmerian, Inc. and insured by Euromepa. Underlying the Section 1782 proceedings in the United States was a French action wherein the French trial court issued a judgment of approximately US$10 million in favor of Esmerian, which resulted from a finding of equal fault between Esmerian and Euromepa in the loss of the jewelry. Following the French trial court’s ruling, and after perfecting an appeal, Euromepa filed its Section 1782 petition in the Southern District of New York, seeking discovery of Esmerian regarding, among other items, proof of the jewelry’s ownership, proof of the jewelry’s insurance, and proof of the jewelry lost. Ultimately, Euromepa sought this discovery for use in its appeal of the French trial court’s ruling of equal fault among the parties. Upon review, the Southern District of New York denied Euromepa’s application, resulting in an appeal to the Second Circuit. In between appellate argument and the Second Circuit’s decision, the French appellate court favorably amended the French trial court’s judgment in Esmerian’s favor, holding Euromepa wholly liable for the US$20 million loss. As a result, Euromepa immediately sought protection in the French bankruptcy court. The Second Circuit, without addressing the decision of the French appellate court, reversed and remanded the case for further proceedings. Contemporaneously, Euromepa sought review of the French appellate court’s decision with the French Supreme Court, which resulted in an affirmance of the lower appellate court’s opinion. Immediately following the French Supreme Court’s decision, the Southern District of New York dismissed Euromepa’s Section 1782 petition as moot because that decision effectively eliminated all pending proceedings in which Euromepa could use the discovery sought in the United States. Thereafter, Euromepa’s second appeal followed, arguing that the Southern District of New York failed to consider the pending French bankruptcy proceeding and a potential motion to reopen the judgment of the French appellate court, as bases to avoid the Court’s finding of mootness. Upon examination, the Second Circuit found that the French bankruptcy proceeding is not adjudicative within the meaning of Section 1782 because the merits of the dispute between Esmerian and Euromepa have already been adjudicated and would not be considered in the French bankruptcy proceeding, based upon French law. Further, the Second Circuit held that Euromepa’s argument concerning the potential motion to reopen the judgment of the French appellate court was meritless, because its conceded that such a petition was unlikely to be made absent newly discovered evidence. Accordingly, the Second Circuit held that the Southern District of New York did not abuse its discretion in dismissing Euromepa’s Section 1782 petition as moot. Applying this precedent to the appeal, it is entirely possible that theSecond Circuit will again hold that, because the adjudicative function of the foreign tribunal is complete, there is no basis under Statute 1782 to grant relief, thereby foreclosing Gorsoan’s ability to obtain discovery in the United States. All hope is not lost for obtaining discovery in the US, however. While the Second Circuit appears to be gradually narrowing the door for discovery pursuant to Section 1782, the Southern District of New York specifically recognised that “[n]one of the decisions [cited by Bullock in ] established a broad rule that asset discovery can never be adjudicative and is thus always impermissible under § 1782.” (435 F.Supp.3d at 598). Ultimately, the nuance lies in whether the discovery sought pursuant to Section 1782 could have an effect on the merits of the dispute being decided in the foreign tribunal. Moreover, District Courts around the US have sought to further clarify the holding in . For example, in , the US District Court for the District of Massachusetts held that “the court did not universally bar discovery in all bankruptcy proceedings, particularly where issues are being adjudicated.” Further, in , the US District Court for the Middle District of Tennessee held that “had not held that ‘all post-judgment proceedings are not adjudicative’.” Finally, even within theSouthern District of New York, there remains some dispute regarding how far the decision extends: in , the court cited for the limited proposition that Section 1782 discovery “is inappropriate where the merits of a controversy have already been decided by the foreign tribunal.” Ultimately, according to the Southern District of New York in , “adopting the proposed far-reaching rule against asset discovery would be incongruent with § 1782’s ‘underlying policy’ that, ‘[a]bsent specific directions to the contrary from a foreign forum, . . . district courts [should] provide some form of discovery assistance’.” (435 F.Supp.3d 589, 599). At some point later this year, the Second Circuit will likely decide whether Gorsoan will be permitted to obtain the discovery it seeks related to Bullock’s alleged involvement in the US$25 million fraud. At present, proceedings in the Southern District of New York have been stayed by court order, pending resolution of the appeal. Until resolution, and further clarity from the Second Circuit, practitioners should not wait to file their respective applications for judicial assistance pursuant to Section 1782. Instead, non-US practitioners should carefully consider the various jurisdictions where an application for Section 1782 assistance could be filed in the US (any district where the person from whom discovery is sought resides or is found), especially if that location is outside of the Second Circuit’s jurisdiction. Further, there are other litigation tools that counsel in the US may use to otherwise obtain the discovery needed for use in a foreign tribunal when there is already a judgment – one example is domestication of a foreign judgment pursuant to a variety of state laws allowing the enforcement of foreign judgments in the US. Although differing somewhat from state to state, most states have already adopted the Uniform Foreign Money-Judgments Recognition Act (UFMJRA) and have common law decisions that reinforce a foreign party’s ability to both domesticate and enforce foreign judgments within the US. Case references (2d Cir. Case No. 20-680, Filed 21 February 2020) , 154 F.3d 24 (2d Cir. 1998) , No. 15-mc-91509, 2018 WL 474999, at *4 (D. Mass. 2018) , No. 17-mc-5, 2018 WL 3872197, at *12 (M.D. Tenn. Aug. 15,2019) , 190mc-287 (LIS), 2019 WL 2743205, at *1 (S.D.N.Y. July 1,2019) To view the original article, click here . Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..

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

Sequor Law welcomes Jennifer Mosquera as Associate Attorney. A bilingual attorney and former judicial law clerk, she strengthens the firm's growing Miami-based legal team. Sequor Law adds Attorney Jennifer Mosquera to Team Open Firm News Open February 14, 2022 2 minutes read Sequor Law Miami, Florida- Sequor Law is pleased to announce the addition of Ms. Jennifer Mosquera to the firm as an Associate Attorney effective February 14, 2022. Jennifer joins an already impressive roster of talented, hard-working award-winning attorneys. The addition of Jennifer confirms the firm’s ongoing dedication to growth and its commitment to the development of new attorneys. “We are eager to have Jennifer, a talented bi-lingual attorney who will strengthen our firm by adding to the high caliber of skill and integrity we have at Sequor Law. She brings with her the expertise, knowledge and commitment that our clients expect,” said founding shareholder Gregory S. Grossman. “Jennifer is the second attorney added to our roster in the last six months. Our ongoing growth is directly tied to our strategic plan.” Prior to joining Sequor Law, Jennifer served as a law clerk to the Hon. Judge Mark W. Klingensmith at the Florida Fourth District Court of Appeal. She worked on a variety of complex issues within foreclosures, breach of contract claims, and fraud-based disputes among other civil cases. Jennifer received her J.D. graduating magna cum laude in 2019 from Florida State University College of Law. An award-winning student, Jennifer was on the Dean’s List, was a merit scholarship recipient and was on the board of both the Florida State Law Review and the Florida State University College of Law Moot Court Team. During her time in law school, Jennifer interned for multiple judges, clerked for the Consumer Protection Division of the Office of the Florida Attorney General, and held a summer associate position with an Am Law 200 firm. She obtained her B.A. in Political Science and her B.A. in Philosophy from Florida International University in 2016. Jennifer Mosquera’s practice is focused on asset recovery, bankruptcy and insolvency, financial fraud, international commercial litigation and judgement, and arbitral award collection as well as corruption and proceeds of crime recovery. She is fluent in English and Spanish and is admitted to practice in Florida. “The addition of Jennifer adds strength and depth to our capabilities, and I look forward to working with her to continue to deliver comprehensive, top-tier service to our clients.” said Shareholder Leyza B. Florin. ****** Sequor Law is a Miami-based international law firm representing financial institutions, sovereign governments and state-owned enterprises, public and non-public companies, insolvency practitioners and individual clients in the areas of asset recovery, financial fraud, insolvency, and financial services litigation. More information is available at www.SequorLaw.com . Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more..