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 Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit...

Sequor Law's Edward H. Davis Jr. co-hosts the C5 Fraud, Asset Tracing & Recovery Miami conference (Jan 24-25, 2022), with Daniel Coyle presenting on crypto asset fraud. C5 Fraud, Asset Tracing & Recovery Open Events & Speaking Open November 22, 2021 1 minute read Sequor Law C5 Fraud, Asset Tracing & Recovery January 24-25, Miami Fraud, Asset Tracing & Recovery Miami | American Conference Institute 🔗 Sequor Law’s Edward H. Davis, Jr. will once again be co-hosting this much anticipated event together with Tameka Davis, Martin Kenney, and Keith Oliver. Don’t miss Sequor Law’s Daniel Coyle , as he discusses Crypto Asset fraud as an Existential Threat. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit...

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 Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit...

Edward H. Davis Jr. discusses cross-border financial fraud, asset tracing, and modern asset recovery challenges in his WWL Thought Leaders Global Elite Q&A. WWL Thought Leaders Global Elite - Edward H. Davis Jr. Q&A Open Awards & Recognition Open August 25, 2022 2 minutes read Sequor Law In the complex world of cross-border financial fraud and asset tracing , experience and strategic insight are essential. In his ThoughtLeaders interview (featured in the Sequor Law article PDF), Founding Shareholder Edward H. Davis Jr. shares his perspective on what drives modern asset recovery practice and the evolving challenges practitioners face as fraudsters exploit increasingly sophisticated structures and technologies. Davis’s reflections are grounded in more than three decades of international litigation and investigative work representing victims of fraud , corruption , Ponzi schemes and other misappropriations of funds around the globe . The article weaves together Ed’s professional journey with grounded commentary on the issues shaping asset recovery today. He explains why he chose this practice area — to make a measurable difference in people’s lives by unravelling the complex legal and factual webs fraudsters set up to conceal assets. He also describes the kinds of cases that regularly come across his desk, noting that while traditional investment and corporate fraud remain core concerns, crypto-asset and internet-based frauds are increasingly front and center. A recurring theme of the piece is the interplay between legal systems and global reality. Davis identifies jurisdictional hurdles — including the reluctance of some legal systems to treat information as an asset recoverable in a tracing exercise — as among the greatest obstacles in international practice. This observation underscores the fact that asset recovery is as much about navigating foreign legal cultures and procedural norms as it is about understanding the underlying wrongdoing. The interview also touches on how technological tools are reshaping the practice. Davis points out that while emerging technologies are not yet “game changers,” they are helping practitioners uncover bank relationships and other data that were previously more difficult to access — leveling the playing field in key respects. Finally, Davis offers practical career insights for young lawyers interested in the field, emphasizing that direct experience and mentorship are irreplaceable for mastering the judgment and tactical skills required in high-stakes, highly international disputes . For a frontline look at the mindset and practical considerations of one of the field’s most experienced asset recovery lawyers , we encourage you to read the full interview in the PDF below. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit...

An investigative report on how a US church, offshore shell companies, and rapper Flo Rida became entangled in a web of offshore banking schemes revealed in the #29Leaks investigation. A church, its shell companies and a plan to have rapper Flo Rida plug high-end bubbly Open In the News Open December 20, 2019 11 minutes read Sequor Law By Kevin G. Hall and Shirsho Dasgupta The middleman was ecstatic. An American archbishop was not only looking to move some money offshore, he was looking to move his finances abroad. “He says he feels he can swing his council or synod to establishing his whole banking empire as he envisions it and he wants to set up also an insurance company, various offshore companies,” wrote Michael O’Mara in a Sept. 8. 2015, email to a London-based offshore services provider. “I am trying also to sell him some of the recent companies you sent me with bank accounts to act as his holding companies.” It’s not every day that a church, enjoying tax-exempt status in the United States, is seen as a viable candidate to buy offshore shell companies with their own bank accounts, which can give the appearance of a longstanding business. The COO of one of those church-affiliated offshore businesses at one time had reached out to none other thanFlo Rida, the Miami-born rap artist, trying to swing a deal to have him invest in a brand of high-end champagne calledBillionaires Row. Flo Rida’s lawyer said no and the plan fizzled. But more on that in a bit. The emailabout the archbishop’s offshore shell companiesis part of a giant leak of more than a million documents from Formations House, a London-based financial services firm with clients across the globe, including some in the United States. Other leaked documents show that Archbishop Timothy Paul, the senior pastor of the Christian Cathedral in Springfield, Mass., purchased an official-looking insurance company, a Swedish investment trust and even a faux bank — one in name only — in Gambia. In interviews, he acknowledged spending tens of thousands ofchurch dollars on offshore companies — but says he never used the shell companies. Emails show O’Mara, who works out of an English seaside hotel room on behalf of Mediterranean Corporate Services, tried to sell the archbishop on religious-sounding names for his offshore entities — names like Alliance Parish Banking Ltd. or Alliance Congregational Bank & Trust Co. But the archbishop settled on Dominion Global Investment Capital Trust, serving as its president and taking the name, he said, from the book of Genesis. Dominion Global had a COO, William Benson, a brash New Yorker with a love of the limelight and a trail of unhappy business associates. They describe Benson as a frequent name-dropper, who boasted of his relationship with an archbishop, with Flo Rida and with the socialite Paris Hilton. Dominion Global wasn’t a bank of the conventional sort, with checking accounts, tellers and the like. Nor did it grant commercial loans to real-estate developers. When McClatchy and the Miami Herald called to check its operational hours, the call was put through to a man with a thick New York accent who said it wasn’t “that kind of bank.” Anyways, he said, the bank itself is in London. When a reporter visited the bank’s listed address in lower Manhattan, in a swank high-rise glass tower at 17 State Street, Suite 4000, on the Hudson River, that suite wasn’t an actual bank either. The guard there pulled out clipped-together paperwork listing hundreds of companies that together share the suite’s office space under a flat monthly fee. Two young women answer the phones, the guard offered, but there isn’t anyone else there. It was a virtual office, a fancy address that gives the aura of a real brick-and-mortar company. PIERCING THE VEIL The archbishop’s offshore business was among the intriguing narratives found in 10 years worth of Formations House records obtained by the anti-secrecy group Distributed Denial of Secrets and shared with investigative journalists, including those at McClatchy and the Miami Herald. Journalists collaborated for months and on Dec. 4 began publishing under the #29Leaks hashtag, a reference to Formation House’s tony address at 29 Harley Street in London. Reporters found Iranian oil companies dodging sanctions, a Miami resident busted in a DEA sting and a plan for industrial-scale cannabis farming in Cameroon. Formations House chief Charlotte Pawar said in emailed responses to questions that the leaked records were stolen and that she was subjected to extortion but did not provide evidence of that. The leak, combined with the recent Panama Papers and Paradise Papers leaks, gives added momentum to legislation now in the U.S. Senate that would end anonymity by requiring greater disclosure of the true ownership of shell companies in the United States. “99.99 percent of Americans don’t own offshore companies but the few that do try to tell you how legitimate it is,” said Edward H. Davis Jr ., an asset-recovery lawyer with Sequor Law in Miami. “The reality is the entire offshore system is designed to avoid detection of the existence and movement of wealth.” The Formations House leak adds a new wrinkle to the global debate, in part because it was based in London, not Panama or the faraway Seychelles, another haven for companies seeking tax avoidance. And it went beyond offering shell companies, but also faux banks that mimicked financial institutions butweren’t regulated or required to have a minimum amount of cash on hand. These bank-named shells can issue loans, mortgages to their members and even credit cards as if they were a normal bank, according to promotional materials. The Formations House documents provide insight into how these financial instruments are used. One email referenced a giant global gemstone wholesaler “sitting on a huge pile”, who sought three “banks” for internal operations, insisting on the humorous names Tightwad International Bank Ltd., Tightwad Bank International Co. Ltd. and Tightwad Global Bank Ltd. SHELL COMPANIES FOR GOD Archbishop Paul is not an archbishop in the Roman Catholic Church or the Anglican Church, the common associations with that rank of clergy. Paul said that 20 years ago he adopted the name of St. Paul when he was consecrated as an archbishop. He leads a freestanding Christian denomination that voted him archbishop and patriarch of the International Holy Communion of Churches , which he said involves roughly 700 churches that together count 4.6 million followers. Like the Russian or Greek orthodox churches, he said, the denomination follows the original interpretations of the early apostles. “We brought orthodoxy to African Americans,” he explained. Until recently, Paul was also president of Epiphany Development Corp., which converted a historic Springfield building into a Holiday Inn Express. Paul, 53, insisted there was nothing untoward about his church having offshore companies. “We wanted to fund missions and do things,” he said, noting he hoped to expand the reach of his church. “They sell offshore banks, so we thought this was a legitimate means to have an offshore bank for our ministries that we were going to be project-funding for.” The interest in going offshore began with an email solicitation, he said, and eventually the representative from Mediterranean Corporate Services came across the Atlantic to see him. Paul said he has foreign outreach in Gambia, India, Kenya and Zambia. His church website makes no mention of this. Asked about specific projects, he offered that the Swedish investment trust was established for that purpose but has yet to invest in projects. “That would be for the real-estate projects we’re going to do,” he said, suggesting they were raising capital to build a foreign supermarket. “It’s almost like a real-estate trust.” The Swedish daily Dagens Nyheter, a #29Leaks partner, reported that Russian middlemen and Swedish offshore services providers had discovered and exploited a loophole in Sweden’s banking laws that gave the appearance that bank-named trusts were regulated when in fact those belonging to non-Swedes are not. Swedish documents shared with McClatchy and the Miami Herald show Paul signing the trust registration on Feb. 20, 2017. He said he used another consultant called Global Money Consultants to create that company. Paul also purchased a “bank” in Gambia, the smallest country on the African mainland but one with a large corruption problem, for years run by dictator Yahya Jammeh. Formations House chief Charlotte Pawar’s late father, Nadeem Khan, had convinced Jammeh to create an enterprise zone, which allowed the London firm to fashion a line of business registering offshore companies there. In an email to #29Leaks partners, O’Mara said he’d created more than 150 such banks in the Gambian offshore zone since 2013 for “wealthy families who want to handle their own finances.” The church doesn’t fit that description but O’Mara declined to discuss Paul’s offshore entities. Even though the Gambian enterprise zone was never fully authorized by the legislature there, banks sold for about $33,000 apiece today’s exchange rates, a price Paul didn’t dispute. Archbishop Paul created Global Dominion, but insisted the related “bank,” Dominion Bank & Trust Company Ltd., was never used. “We haven’t even operated from the Mediterranean Gambian license,” he said. “We paid a lot of money for it, but it was not something we used.” He later established Dominion Bank and Trust Company in the tax haven of the Comoros Islands in the Indian Ocean between Mozambique and Madagascar. It too hasn’t been used, he said . Paul purchased from Formations House a pre-existing shell company called Global Mortgages Ltd. British corporate registration documents show Paul as the main shareholder in 2017 but in 2018 and 2019 the company was threatened with dissolution. Global Mortgages Ltd. was going to be used as a vehicle to purchase real estate in Africa, he said, but the shell company was abandoned. “It was an idea that was kicked around” but never got off the ground, Paul said. Also registered under Paul’s name in Gambia was Dominion International Insurance Company. The idea, he said, was to create a captive insurer ⁠— an insurance company controlled by the insured. For larger companies, these are used to reduce costs by self-insuring a project while enjoying some tax breaks. But the IRS last year warned taxpayers about so-called micro-captive structures, popular with wealth planners and offshore services providers that “lack many of the attributes of genuine insurance.” Paul said his insurance company, referenced in the Swedish trust documents that he signed, was also never put into function. “Since we didn’t use the bank, we didn’t need that,” he said. BOLD CLAIMS Paul’s public profile isn’t — or wasn’t — completely accurate. In a LinkedIn page, he claims to have a Ph.D in education from American University. The school has no record of that. “My Ph.D is in street-ology,” he quipped when asked about the degree. Why was it on his LinkedIn profile? Someone else did the page for him, he said, “when you become the patriarch, things like that happen.” The LinkedIn references to a Ph.D in education and American University were subsequently removed. On his relationship with William Benson, Paul said he tapped Benson for his expertise and insight, well after the efforts had begun to expand church operations abroad. They were introduced through a friend working on a project involving Liberia, he said. Benson, 34, runs Billionaires Row, a champagne company that touts the high life. A seemingly strange bedfellow for an archbishop, Benson marketed a playboy image, boasted of his friendship with Hilton and associates say he claimed to have worked for Goldman Sachs. The investment bank hasno record of Benson having worked there. “We don’t have any involvement. I want to make that very clear. We don’t engage in any of those secular or non-humanitarian projects,” Paul said during a first interview together with Benson. Speaking of Benson, Paul added, “His primary role with the trust was to offer his expertise and help us obtain the necessary funding.” Funding that apparently did not happen, for use in offshore vehicles that were never actually used. In a subsequent interview without Benson, Paul acknowledged that he was aware of complaints against Benson. “We found that he didn’t work for Goldman Sachs. We found [that] he did not have the knowledge that he professed,” Paul said, adding that “we were the cleanest vehicle for him to attach himself.” ENTER FLO RIDA Flo Rida attorney Reginald Mathis confirmed that in November 2014 Benson and his Billionaires Row offered a deal. An ex-business associate familiar with the deal said it involved Flo Rida mentioning the imported champagne in a song and doing a promotional tour. “Things just never seemed to check out,” said Mathis, adding that, “he tried to put something together in 2015 with the Super Bowl, which never materialized. Flo advised that he was given product at some point, but he hasn’t had contact with Benson in years.” In an interview, Benson denied ever having extended a contract offer to Flo Rida or any other celebrity. “We don’t need any artist to do a song. We have many celebrities that promote the brand for free,” he said, adding that no celebrity “has invested a dime in the company.” The archbishop said he’d never heard of Flo Rida, whose real name is Tramar Lacel Dillard. The pitch to Flo Rida came before Benson got involved with Dominion. Paul said that he was unaware of Benson’s actions or his alleged outside sales pitches on behalf of Dominion to would-be investors. But on July 17, the website www.bankdominion.com issued a warning that Benson had no authority to “represent or bind” Dominion Bank and Trust, Ltd. “William Benson does not have authority to enter into contracts that bind the Dominion Bank and Trust, Ltd or create obligations on the part of the Dominion Bank and Trust, Ltd. without final approval of our compliance department,” read a notice on the home page. That page today is password protected. Benson said in the interview that it was he who ended ties with Paul after first getting offered the job of CEO of Dominion Bank. “I saw things that I didn’t want to be part of, so I stepped back,” he said, noting he broke with the archbishop last April or May. He declined to discuss what he saw that was worrisome and added he worked with Paul just for eight months and after the offshore entities were created. He also denied saying he worked at Goldman Sachs, noting he had worked at a division that was purchased by the giant bank. Several people claim Benson ripped them off. “He took $15,000 from me promising he could provide a lot of funding,” said Joseph Clarke, a real-estate investor and entrepreneur in Louisville, Kentucky, who hoped to develop a beachfront project in Honduras and mostly got a website and press release out of the effort. That money, which he said disappeared in 2014, was part of a wrongful death settlement after the death of his son, Clarke said. “It really left a bad taste in my mouth,” he said, adding, “I really wanted to see him fry.” Benson denied anything improper, saying that “I sent him an invoice and he paid it. I don’t work for free.” Jeremiah Patterson was stationed at Patrick Air Force Base near Cocoa Beach, Florida, when he was approached by Benson in 2013, who offered to invest in his prototype touch-screen technology. “He made it sound like he was a big tycoon,” said Patterson, noting that “he did mention offshore accounting and how he was looking to be part of an international banking corporation.” Patterson gave him a stake in the company, Taptl , in exchange for marketing and fundraising, and gave him a corporate American Express card. Soon afterward, Benson ran up the bills, he said, failing to even pay the card’s initiation fee. “I didn’t end up losing as much money as some other folks but it did set my business back by a year and a half,” said Patterson, now stationed in Georgia. “Keep in mind, I am a psychological specialist for the Air Force. I put him through the ringers and he had me convinced. That’s not an easy thing to do.” Benson denied running up credit card bills and provided an October 2014 Ohio court injunction against Patterson that prevented further disparagement. Patterson said his start-up couldn’t afford to appeal. A South Florida man who fell out with Benson shared a 15-page application for a corporate account with Bank Dominion and an unsigned letter of credit from Dominion Global, with its London address, promising $1.5 million with a lending rate of 4 percent . The man recalled briefly being introduced by phone to the archbishop in the middle of 2018, something Paul steadfastly denied. “He hopped on one call, said ‘hi’ for a moment,’ he said. “When they said archbishop, I assumed they meant the Catholic Church.” Emails viewed by McClatchy and the Herald show a New York FBI agent was made aware last summer of several complaints about Benson. An FBI spokesman in New York City declined to comment. Told about that, Benson provided what he said was a video of a recently videotaped conversation with former U.N. Ambassador Nikki Haley at the United Nations, and said it showed he was not under a legal cloud. 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 Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit...

Grant Thornton liquidators of three BVI companies linked to an alleged $200M fraud by a former São Paulo mayor file for Chapter 15 recognition in Miami after pooling their proceedings. Pooled BVI liquidations seek US recognition Open In the News Open December 12, 2019 3 minutes read Sequor Law The liquidators of three British Virgin Islands companies tied up in an alleged US$200 million fraud conducted by a former mayor of São Paulo have filed for US recognition, days after a local court authorised the pooling of their liquidations. Grant Thornton director Matthew Richardson , who is joint liquidator alongside partner Kevin Hellard of BVI companies Durant International, Kildare Finance, and MacDoel Investment, filed for recognition of the three companies’ liquidations before the US Bankruptcy Court for the Southern District of Florida on 11 December. Kildare and Durant have been in liquidation in the BVI since November 2017, and MacDoel since April of this year. The BVI High Court ordered the liquidations to be pooled on 5 December after finding the movement of monies between the three of them “would have no practical advantage”, in the first written ruling of its kind in the jurisdiction. Richardson told the Florida court that the three companies had “no legitimate purpose” and were nothing more than vehicles to launder the proceeds of “wide-scale frauds” allegedly committed against the city of São Paulo by their controller, the city’s former mayor Paulo Maluf and members of his family. Maluf, a right-wing populist and member of Brazil’s Progessives party, served as mayor from 1969 to 1971 and 1993 to 1997. He is now under house arrest after being convicted of fraud in 2017 and sentenced to seven years’ imprisonment. It is alleged that during his latter term around US$200 million was misappropriated from public funds through “bribes, secret commissions and other fraudulent payments” in connection with the construction of the city’s Avenida Agua Espraiada, which divides the districts of Itaim Bibi and Campo Belo. The boulevard is now known as Avenida Jornalista Roberto Marinho following a 2003 renaming. Richardson says Brazilian authorities became aware of the fraud in 1999 when they received inquiries from police in Jersey after the submission of a suspicious transaction report to the island territory’s money laundering authorities. The governments of Brazil and São Paulo sought to prove the fraud in the Jersey courts by reference to a month’s sample of transactions flowing through Kildare and Durant. Based on those samples the Royal Court of Jersey found a constructive trust for US$10.5 million against the companies in 2012, and then the following year gave judgment against them for US$28.3 million in favour of the governments. Although the governments recovered US$3.44 million from Kildare and Durant’s Jersey accounts, the companies made no attempt to pay the balance, leading the governments to seek the appointment of liquidators in the BVI. Richardson said MacDoel had also played a role in the fraud as a conduit for funds, identifying just over US$4 million in Kildare’s books that it had paid to the company without consideration or evidence of repayment. The pair obtained MacDoel’s liquidation after it failed to pay a statutory demand for that amount in April. But Richardson said the money from the Jersey judgment “represents only a very small part of the total funds derived from the fraud”, because the judgment reflected only one month’s worth of transactions. He said the total amount of money derived from the frauds was “in the region of US$200 million” and claims against the three estates amount to at least US$172 million. He said he was as yet unable to determine the total value or location of the companies’ assets, but said he had learned they “may be concealed in the United States” and foreign tax havens, under the names of Maluf’s relatives. Richardson said he hopes to make recoveries by asserting proprietary claims in the US and possibly by bringing tracing claims against third parties. In the US Bankruptcy Court for the Southern District of Florida (19-26542) (19-26545) (19-26547) Counsel to Grant Thornton Sequor Law Partner Gregory Grossman in Miami In the High Court of Justice of the British Virgin Islands, Commercial Division Justice Adrian Jack Joint liquidators of Durant, Kildare and MacDoel Grant Thornton Partner Kevin Hellard in London and director Matthew Richardson in the British Virgin Islands Counsel to the joint liquidators Maples and Calder Partner Alex Hall Taylor , of counsel David Welford and associate Scott Tolliss in the British Virgin Islands 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 Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit...

An overview of 28 U.S.C. § 1782, one of the most powerful discovery tools available to foreign litigants, allowing evidence gathering in US federal courts for use in international proceedings. Section 1782 Remains One of the Most Powerful Discovery Tools as Appellate Courts Uphold its Use in Aid of Private Commercial Arbitration Open Legal Insights Open June 10, 2020 4 minutes read Sequor Law 28 U.S.C. § 1782, known colloquially as “Section 1782,” is a federal statute that allows foreign litigants and interested persons to request judicial assistance from U.S. federal courts to obtain evidence for use in a proceeding in a foreign or international tribunal. Section 1782 is highly relevant to a wide array of legal practitioners, both within and outside the U.S., as federal courts have concluded that evidence obtained through Section 1782 may be used in civil, criminal, probate, bankruptcy, marital, administrative, and regulatory cases. In short, if your client is not using Section 1782 as part of its litigation strategy, there is a good chance that your client’s opponent is using it to your client’s disadvantage. Section 1782 is an alternative to the slower, and oftentimes cumbersome, cross-border discovery mechanisms such as letters rogatory and diplomatic or consular channels, because it can be pursued directly by the litigant or interested party without the involvement of the foreign court or tribunal or of the governmental authorities making up the traditional channels. Section 1782 was enacted decades ago and was revised extensively in 1964, but its widespread use did not take off until after the U.S. Supreme Court’s 2004 ruling in Advanced Micro Devices, Inc. against Intel Corp. , or “Intel” as the seminal decision is widely known. In the Intel case, the Supreme Court clarified the statutory requirements that an applicant has to satisfy to obtain evidence using Section 1782 as well as a number of discretionary factors courts should also consider. If the applicant is successful, it can obtain U.S.-style discovery from persons or entities located where the application is filed (in the form of site inspections, requests for production of documents, or deposition testimony under oath) for use in the foreign proceeding. Typical Section 1782 subpoena targets include businesses (including affiliated companies and subsidiaries), financial institutions, professionals such as lawyers and accountants, brokers, escrow agents, art galleries and auction houses, former employees, and many more. This incredibly powerful tool can also be pursued on an ex parte basis (at least initially) and does not require the applicant to prove that she has exhausted her domestic evidence gathering tools in the foreign case or, significantly, that the evidence will be admissible in the foreign proceeding. One issue that has been contested since Intel was decided is whether Section 1782 can be used in support of a private commercial arbitration (as opposed to treaty-based arbitrations where the use of Section 1782 is clearly supported by the applicable case law). Recently, the Sixth Circuit and Fourth Circuit Courts of Appeals broke with the Second and Fifth Circuits and determined that interested parties may rely on Section 1782 to obtain evidence for use in a privately constituted international arbitration proceeding. In September 2019, the Sixth Circuit analyzed the definition and interpretation of the word “tribunal” at length (relying on the ordinary meaning of the word, several dictionary definitions, the use of the word in legal writing, and an examination of the statute’s text, context and structure) and held that the language of Section 1782 unambiguously “includes private commercial arbitral panels established pursuant to contract and having the authority to issue decisions and bind the parties.” Abdul Latif Jameel Transportation Co. Ltd. v. FedEx Corp. , 939 F.3d 710, 723 (6th Cir. 2019). A few months later, the Fourth Circuit followed. In March 2020, the Fourth Circuit agreed that private arbitral tribunals are “foreign tribunals” within the meaning of Section 1782, and rejected a litany of policy arguments advanced by the respondent. Servotronics, Inc. v. Boeing Co. , 954 F.3d 209 (4th Cir. 2020). Although district court decisions have been deeply divided on the issue since Intel, there is now strong momentum gathering at the appellate level favoring the use of Section 1782 in aid of private commercial arbitration. For example, California district courts had uniformly followed the Second and Fifth Circuits in holding that an applicant may not obtain evidence through Section 1782 for use in a private commercial arbitration—until recently. In February 2020, a federal court in the Northern District of California adopted the reasoning and conclusion of the Sixth Circuit’s decision regarding Section 1782’s application to private international arbitration. HRC-Hainan Holding Company, LLC v. Yihan Hu , No. 19-mc-80277, 2020 WL 906719 (N.D. Cal. Feb. 25, 2020). That case is now on appeal, and the Ninth Circuit is positioned to rule on the issue. In sum, the already powerful Section 1782 has seen its applicability bolstered by two of the highest courts in the U.S. indicating that Section 1782 will remain an indispensable tool in any international lawyer’s toolbox for the foreseeable future. About the authors: Arnie Lacayo ( alacayo@sequorlaw.com ) is a Shareholder and Cristina Vicens ( cvicens@sequorlaw.com ) is an Attorney at Sequor Law. Lacayo and Vicens focus their practices on investigations, financial fraud and corruption-related asset recovery cases, as well as cross-border insolvency. Both Lacayo and Vicens have extensive experience with the Section 1782 statute, including in some of the most-cited cases in the U.S. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit...

Partner. Former Miami-Dade prosecutor. Admitted to 6 U.S. Circuit Courts of Appeals. Prior experience at two major international law firms Joseph B. Rome Partner jrome@sequorlaw.com (+1) 305-372-8282, Ext. 210 vCard Practice Areas International Commercial Litigation Asset Recovery Judgment & Arbitral Award Enforcement International Arbitration Corruption & Proceeds of Crime Recovery High-Net-Worth Disputes Financial Fraud Joseph B. Rome Partner jrome@sequorlaw.com (+1) 305-372-8282, Ext. 210 vCard Education New York University School of Law, J.D. (2013) Jessup International Moot Court, International Round 2013, 32nd top oralist out of 500+ competitors Journal of International Law & Politics, Senior Developments Editor OUTLaw, Co-Chair; Asia Law Society, Vice-President Alternative Spring Break internship with Orleans Public Defenders, New Orleans, Louisiana Civil litigation externship clinic at U.S. Attorney’s Office for the Eastern District of New York Columbia University, M.A. (2010) Regional East Asian Studies with Chinese History focus Columbia University, B.A. (2007) Double major in Architecture and East Asian Studies Admissions New York Florida U.S. District Court for the Southern District of New York U.S. District Court for the Eastern District of New York U.S. District Court for the Southern District of Florida U.S. District Court for the Middle District of Florida U.S. District Court for the Northern District of Florida U.S. Courts of Appeals for the 1st Circuit U.S. Courts of Appeals for the 2nd Circuit U.S. Courts of Appeals for the 5th Circuit U.S. Courts of Appeals for the 6th Circuit U.S. Courts of Appeals for the 9th Circuit U.S. Courts of Appeals for the 11th Circuit Associations & Memberships Vice-Chair, Anticorruption Committee, International Law Section, American Bar Association Languages English Spanish Chinese Japanese Location Miami Favorite Quote: “La verdad adelgaza y no quiebra, y siempre anda sobre la mentira como el aceite sobre el agua. ” - Miguel de Cervantes Saavedra Bio Publications & Presentations Representative Matters Media Joseph Rome, a partner at Sequor Law, focuses his practice on international arbitration and litigation, judgment and arbitral award collection, asset recovery, corruption and proceeds of crime recovery, and financial fraud. Prior to joining Sequor Law, Joseph was an “A” level prosecutor for the Miami-Dade State Attorney’s Office focusing primarily on attempted murders, gun crimes, and serious sexual assaults from the investigation stage through trial. He was also a member of the Police Accountability and Integrity Task Force, Hate Crimes Unit, and Traffic Homicide Unit. Joseph previously worked for two large, international law firms in New York and Miami. He represented international corporations and high-net-worth individuals in a broad range of high-stakes litigation and arbitration matters. Joseph earned his Juris Doctorate from New York University School of Law. During law school, he was a Jessup International Moot Court member, an editor of the Journal of International Law & Politics, and did externships with both the Orleans Public Defenders and the U.S. Attorney’s Office for the Eastern District of New York. He also did a summer fellowship at the United Nations International Law Commission in Geneva, where he drafted speeches and statements for the Japanese representative. Sequor Law Promotes Juan J. Mendoza, Christopher A. Noel, and Joseph B. Rome to Partner Sequor Law bankruptcy courtroom victory DISH case Sequor Law Announces Promotion of Attorney Joseph Rome to Counsel Attorney Spotlight: Joseph Rome Joseph B. Rome Wins ThoughtLeaders4 FIRE Essay Competition Sequor Law continues to grow, adding another attorney to the team Published Decisions Novalpina Capital Partners I GP S.A.R.L v. Read , 149 F.4th 1092, 1095 (9th Cir. 2025) In re Exch. Union Co. , No. 24-mc-91645-ADB, 2025 U.S. Dist. LEXIS 257485, at *1 (D. Mass. Dec. 12, 2025) Dailane Invs. Ltd. v. Hig Capital LLC , No. 25-cv-20568-ALTMAN/LETT, 2025 LX 528597 (S.D. Fla. Oct. 24, 2025) Ex parte Klein , No. 1:23-mc-24630-CMA, 2025 LX 428674 (S.D. Fla. Oct. 17, 2025) In re Exch. Union Co ., No. 4:24-mc-80289-YGR, 2025 LX 321418 (N.D. Cal. July 22, 2025) Orion Engineered, GmbH Carbons v. Shufang Qin, No. 8:24-cv-02409-MRA-DFM, 2025 LX 333118 (C.D. Cal. Aug. 1, 2025) In re Dailane Invs. Ltd., No. 1:22-cv-23619-ALTMAN/Reid, 2025 LX 379457 (S.D. Fla. May 5, 2025) In re Exch. Union Co. , No. 24-mc-91645-ADB, 2025 LX 150252 (D. Mass. Mar. 24, 2025) Orion Engineered Carbons, GmbH v. Shufang Qin , No. 24-CV-02409-MRA-DFM, 2025 LX 202051 (C.D. Cal. Feb. 21, 2025) Stati v. Republic of Kazakhstan , No. 1:19-MC-00382-PAE, 2025 LX 491175 (S.D.N.Y. Jan. 28, 2025) Stati v. Republic of Kazakhstan , No. 24-2198, 2025 LX 231162 (2d Cir. Jan. 27, 2025) Frasers Grp. PLC v. Stanley , 95 F.4th 54 (2d Cir. 2024) In re Exchange Union Co. , No. 4:24-MC-80289-YGR, 2024 LX 127523 (N.D. Cal. Dec. 18, 2024) In re Pinewood Techs. Asia Pac. Ltd. for Judicial Assistance Pursuant to 28 U.S.C. § 1782 , No. 24-60119-CIV-DIMITROULEAS/HUNT, 2024 U.S. Dist. LEXIS 211317 (S.D. Fla. Nov. 19, 2024) Orion Engineered Carbons, GmbH v. Shufang Qin , No. 8:24-cv-02409-MRA-DFM, 2024 LX 151210 (C.D. Cal. Nov. 18, 2024) Stati v. Republic of Kazakhstan , 2024 U.S. Dist. LEXIS 127325 (S.D.N.Y. July 17, 2024) In re Vinmar Overseas, Ltd. , 2024 U.S. Dist. LEXIS 98217 (S.D.N.Y. May 30, 2024) SEC v. Waldman , 2019 U.S. Dist. LEXIS 60665 (S.D.N.Y. Feb. 14, 2019) Latta v. Otter, 779 F.3d 902 (9th Cir. 2015) De Leon v. Abbott , 791 F.3d 619 (5th Cir. 2015) Latta v. Otter , 771 F.3d 496 (9th Cir. 2014) Brenner v. Armstrong , Nos. 14-14061-AA, 14-14066-AA, 2014 U.S. App. LEXIS 24725 (11th Cir. Dec. 3, 2014) Latta v. Otter , Nos. 14-35420, 14-35421, 2014 U.S. App. LEXIS 16057 (9th Cir. May 20, 2014) Tanco v. Haslam , No. 14-5297, 2014 U.S. App. LEXIS 22051 (6th Cir. Apr. 25, 2014) Publications Florida Bar International Section, International Judgment Recognition in an Age of North American Disunity , 41 International Law Quarterly 18-19, 56-57 (Fall 2025). New Tools in New Places: Digital Assets and a New Chinese Frontier (winning entry of FIRE’s Future Thought Leaders Essay Competition). Co-author, Chapter 3: Section 1782’s “For Use” Statutory Requirement in Obtaining Evidence for Use in International Tribunals under 28 U.S.C. § 1782 (Edward M. Mullins & Lawrence W. Newman eds., 2020). Presentations Digital Assets and Enforcement: Background, Challenges and the Adaptation of Court and Practitioner Strategies , Panelist, ThoughtLeaders4 FIRE, March 23, 2026 Strategies for Favorable Judgments: The Path to Success , Moderator, Offshore Alert Bangkok, March 11, 2026 The Art of the Collect: Mastering Judgment Enforcement , Panelist, Offshore Alert Bangkok, March 11, 2026 Cross-Border Asset Recovery Product Launch & Overseas Recovery Seminar , Keynote Speaker, Yingke Law Firm, Beijing, March 5, 2026 Cross-Border Recovery Seminar on Non-Performing Assets , Keynote Speaker, Hylands Law Firm, Shenzhen, March 2, 2026 29th Dacheng Criminal Forum - Asset Protection from a Global Perspective: Practical Exchange on Investment Disputes and Property Crime Recovery , Keynote Speaker, Dentons Beijing, September 25, 2025 Court Orders and Tools for Investigations and Freezing of Assets in Cross-Border Asset Recovery , ICC Fraudnet Seminar, Shanghai, September 20, 2025 International Investigations & Asset Recovery , Panelist Offshore Alert Bangkok, March 6, 2025 Litigating in Florida: Spotting International Issues from Beginning to End , Moderator, February 7, 2025 FIRE Starters Essay Competition Winner Presentation , Moderator, FIRE Starters Global Summit: Dublin, February 23, 2024 Decrypting Crypto: Reading the Runes , Panelist, London International Disputes Week, May 17, 2023 FIRE Starters Essay Competition Winner Presentation, FIRE Starters Global Summit: Dublin, February 24, 2023 Legal Prowess. Global Impact.

Michael Hanlon of Sequor Law on cross-border asset recovery and financial fraud — and why curiosity is the most essential skill for unraveling complex cases. Attorney Spotlight – Get to Know Michael Hanlon Open Attorney Spotlight Open May 9, 2026 2 minutes read Sequor Law 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more to the kind of work it allows you to do — untangling complicated situations where the facts aren't obvious and the stakes are real. 2. Why did you choose the areas of law that you practice? Asset recovery and financial fraud work felt like a natural fit because it's part legal analysis and part investigation. It takes problem solving to a new level: you're reconstructing stories from incomplete information, often against the odds. Beyond that, the work is inherently cross-border, which blends my passions for languages and the law into one. 3. What skills do you draw upon when it comes to your specific practice areas? At the forefront of the skills I draw on for asset recovery and financial fraud matters is curiosity, along with being comfortable with the unknown. Navigating the unknown in a way that is calculated and driven by a desire to unravel what really happened is essential to crafting a plan — and to deviating from that plan when the situation calls for it. 4. What is the most rewarding part about your job? The most rewarding part of my job is getting clarity — or rather, fighting to uncover clarity where there initially wasn't any. It's the moment when something that looked opaque starts to make sense, and you can actually do something with that understanding. 5. Tell us about a mentor who made an impact on your career. One of my many mentors taught me, through action and inaction, that in order to grow, you have to be willing to be wrong and even more willing to be corrected. 6. If you weren't practicing law, what would you be doing? Given my love of languages, I would probably be an interpreter and/or translator. 7. What might people be surprised to learn about you? I have lived in Spain, Brazil, and Italy, and I speak Spanish and Portuguese fluently. 8. What is a good book or article you read recently? O beijo do rio by Stefano Volp. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit...

Sequor Law's Leyza B. Florin represents the joint trustees of jailed Taiwanese-British businessman Ji-Chuen Jason Tsai in a Chapter 15 petition in Miami to track and recover US real estate assets. Miami Chapter 15 for jailed Taiwanese-British IT executive Open In the News Open November 14, 2019 4 minutes read Sequor Law The joint trustees of Ji-Chuen Jason Tsai, a “thoroughly dishonest” bankrupt Taiwanese-British businessman, have applied for Chapter 15 recognition to track his real estate assets in the US. On 11 November Tsai’s joint trustees, Begbies Traynor partners Nicholas Reed and Julie Palmer , filed two Chapter 15 petitions before the US Bankruptcy Court for the Southern District of Florida – one under his own name and another under the name of Changtel Solutions UK (Changtel), his former company. Leyza B. Florin , a shareholder at Sequor Law in Miami, is acting for the joint trustees. Fraud and freezing The UK’s tax authority, HMRC, sought Changtel’s winding-up in 2013 after challenging its VAT returns and alleging a shortfall of £15.5 million (US$20 million). It accused Changtel, a company which distributed computer hardware and software within the UK and ostensibly exported goods to the rest of the European Union, of carousel fraud over the shortfall. Although the English High Court initially rejected the winding-up petition, the Court of Appeal eventually found that Changtel had “misled” a tax tribunal and judge into thinking that it was solvent “when in fact it had been running down its business since mid-2013”. A tribunal later determined that a fabricated scheme for VAT evasion had been established within the company. The High Court then appointed Reed and Palmer as joint liquidators over Changtel in June 2015. Later, in May 2019, Reed was appointed as Changtel’s bank trustee along with fellow Begbies Traynor partner Joanne Wright . The liquidators’ investigations determined that Tsai committed fraud of an approximate value of £38 million (US$49 million). The English High Court found that Tsai had used “cheque fraud” to extract funds from Changtel – fabricating cheques made out to his sister from a fake Taiwanese supplier, and signed by Tsai himself, to the amount of £3.5 million (US$4.5 million). Tsai’s own bankruptcy came in 2018, after he was jailed for 18 months for contempt of court after breaching a freezing order , and failed to pay a consequential interim payment order. In a July 2017 ruling, Mrs. Justice Vivien Rose in the English High Court found Tsai guilty of 30 out of an alleged 52 breaches of the freezing order. The court found that, although Tsai’s UK passport had been confiscated under the freezing order, he kept hold of a Taiwanese passport which he used to travel to Taiwan. There he arranged for his wife to move £8.6 million (US$11 million) from a DBS bank account in Singapore to a Taipei Fubon bank account in Hong Kong. In delivering her verdict, Mrs Justice Rose described Tsai as a “thoroughly dishonest witness”, and issued with him with the interim payment order. He was adjudged bankrupt in May 2018 after failing to pay the order. Asset recovery In their Chapter 15 application the liquidators said they had discovered several real estate assets in the United States – including five in Las Vegas and one in Los Angeles – that might beneficially belong to either Tsai or Changtel through local companies. They also found evidence that funds had been misappropriated from Changtel and transferred to US bank accounts in the names of Tsai and other family members. They told the Miami court they are attempting to recover £9.95 million (US$ 12.2 million) in post-liquidation payments Changtel made to Entanet International, another Tsai company, to which all Changtel business was transferred prior to liquidation. The liquidators said Tsai’s international assets had been unearthed after a litany of contradictory disclosures of assets on his part. Although in his initial February 2017 disclosure Tsai claimed to have under £1 million (US$1.3 million) he admitted to further assets the further month after retaining counsel from London firm Brett Wilson. But in May that year, after terminating that firm in favor of Neil Davies & Partners, he retracted his previous disclosure, which he said he had admitted to on the basis of erroneous advice from Brett Wilson. “In doing so,” the liquidators said, “Tsai inadvertently waived privilege in his communications with Brett Wilson”, which showed his disclosures had not in fact been based on erroneous advice. As well as the Las Vegas and Los Angeles properties, the liquidators said the English court had found Tsai to hold misappropriated funds in Hong Kong and Singaporean accounts as well as owning three properties in the UK city of Birmingham and one in Telford, Shropshire under his sister’s name. In the US Bankruptcy Court for the Southern District of Miami In re Changtel Solutions UK Limited In re Ji-Chuen Jason Tsai [Case 19-25250] Foreign Representative Sequor Law Shareholder Leyza B. Florin in Miami In the High Court of Justice (Chancery Division) Mrs Justice Vivien Rose Joint liquidators of Changtel Begbies Traynor Regional managing partner Julie Palmer in Salisbury and Nicholas Reed in Leeds Counsel to the joint liquidators Stephen Robins of counsel, South Square Chambers Instructed by: Walker Morris Counsel to Ji-Chuen Jason Tsai Andrew Young of counsel Instructed by: Neil Davies & Partners 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 Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit...

Sequor Law Partner Daniel Coyle secures a significant courtroom win for DISH Network in a bankruptcy case involving copyright infringement through illegal Arabic TV streaming "black boxes." Sequor Law bankruptcy courtroom victory DISH case Open Case Results Open August 2, 2024 2 minutes read Sequor Law Sequor Law partner Daniel M. Coyle, with assistance from Daniel J. Halperin and Joseph Rome, secured a significant win before Judge Delano last month when she gave her oral ruling in Gaby Fraifer’s bankruptcy case on Sequor’s client DISH Network L.L.C.’s second renewed motion to dismiss or convert, and objection to the confirmation of the Third Amended Plan. The debtor violated DISH’s copyright by selling what the laity would call ‘black boxes’ with apps that broadcast Arabic language television through content delivery networks, boosting the quality of the signal with encoders. DISH obtained a judgment in the MD of Fla. supported by a memorandum opinion detailing the factual findings supporting the judgment of direct copyright infringement. Sequor was retained to pursue discovery in aid and satisfaction of the judgment. Soon after seeking charging orders, the debtor filed a Sub. V petition under Chapter 11 of the Bankruptcy Code. The debtor’s main assets were a 10% legal interest in three LLCS, two of which owned real property and one of which owned a promissory note secured by a mortgage. The two properties were leased to tenants paying Triple Net Leases (whereby they pay most of the expenses on the property). Despite that the debtor’s wife was purportedly the owner of 90% of the interest in the LLCs, the LLCs were managed and solely run by the debtor and the debtor provided documents in which he, as manager, had reserved the right to revise the ownership percentages of the LLCs at any time. The original operating agreements were nowhere to be found, and the only documentation supporting the debtor’s narrative regarding the ownership of the LLCs post-dated DISH’s lawsuit against the debtor. The debtor proposed three plans whereby he would contribute his distributions and salary to the plans, along with income of his wife. The plans involved significant educational expenses to debtor’s adult children, along with other significant living expenses. The debtor also attempted to demonstrate a reduction of the income generated by the LLCs by subtracting the expenses paid for by the tenants and refusing to fully lease up the properties or invest the funds generated by the LLCs. The Court saw through all of the debtor’s machinations and denied each of the debtor’s proposed plans, which required two separate trials. Before the second trial, the team mediated over a period of six months before Judge Brown, including numerous joint and single zoom sessions and a two-day in person session. Joseph Rome assisted at the first trial in May 2023 on the initial motion to dismiss or convert and objection to plan, and this evidence was judicially noticed for purposes of the most recent trial. Daniel J. Halperin assisted at the second trial in April 2024 and elicited key testimony from the expert witness to undermine the debtor’s testimony. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit...

Sequor Law's Leyza B. Florin chairs the Lawyers Advisory Committee for the Southern District of Florida Bankruptcy Court, linking judges and practitioners to improve bankruptcy practice across the district. Lawyers Advisory Committee Open Awards & Recognition Open September 16, 2019 3 minutes read Sequor Law By: Guest Contributor Leyza B. Florin , Chair Lawyers Advisory Committee The Lawyers Advisory Committee (LAC) for the Southern District of Florida Bankruptcy Court was formed in 2018 to provide a forum for communication, feedback, and resources between the judges and the bar. Its purpose includes regularly soliciting the bar for commentary regarding bankruptcy practice and receiving requests from the court to consider issues arising from the practice of law before the Court. The LAC may recommend changes in the practice and procedures throughout the district and also acts as a liaison between the Court and the practitioners. In addition, the LAC is charged with the development, implementation, and maintenance of bankruptcy-related programs in the district as requested by the Court. To view samples of issues addressed by the LAC, please visit the LAC web page to view meeting minutes. The LAC is only as successful as the bankruptcy bar makes it. We are dependent on you to contact LAC members with any concerns or suggestions that you might have about bankruptcy practice in our district. The success of our bankruptcy practice in the Southern District of Florida is our absolute priority. If you have any recommendations which will improve the Court’s administration of justice, please reach out to a member of the LAC or contact us at LAC@flsb.uscourts.gov . We encourage you to participate by submitting feedback for consideration and assist the LAC in making our bankruptcy practice in the Southern District of Florida the best it can be. BANKRUPTCY RULES AND FORMS ARE AMENDED EFFECTIVE 12/1/19 Amendments to the federal rules and forms scheduled to take effect 12/1/19 and can be reviewed at the U.S. Courts website at these links: Pending Rules and Forms Amendments Pending Changes in Bankruptcy Forms If any of the above amendments necessitate changes in this court’s local rules, local forms, court guidelines, clerk’s instructions or any other local documents, notice will be provided prior to the December 1, 2019, effective date of the bankruptcy rules and forms amendments. COURT GUIDELINES FOR ATTORNEYS FOR CHAPTER 13 DEBTORS AMENDED Please take notice that the “Guidelines for Compensation for Professional Services or Reimbursement of Expenses by Attorneys for Chapter 13 Debtors Pursuant to Local Rule 2016-1(B)(2)(a)” have been amended to reflect an increase in the compensation fee that an attorney may charge without application to the court. The “no-look” fee will increase from $3,500 to $4,500 for all cases filed under or converted to chapter 13 on or after September 1, 2019. A Public Notice and amended “Guidelines” are currently posted on the court website. PROPOSED AMENDMENT TO THE FEDERAL RULES PUBLIC COMMENT PERIOD CLOSES FEBRUARY 19, 2020 On August 19, 2019, the Judicial Conference Advisory Committees on Appellate, Bankruptcy, and Civil Rules published proposed amendments to their respective rules and forms and requested that the proposals be circulated to the bar and public for comment. Appellate Rules: 3, 6, 42, and Forms 1 and 2; Bankruptcy Rules: 2005, 3007, 7007.1, and 9036; Civil Rule: 7.1 The proposed amendments, rules committee reports explaining the proposed changes, and instructions on how to submit comments are posted on the U.S. Courts website at: Proposed Amendments Published Comments The public comment period closes on February 19, 2020. If approved, the amendments would become effective December 1, 2021. Click here to read the full article. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit...