The Correlation between Personal Jurisdiction and Foreign Judgments
(A Comparative Law Study about Canada, the UnitedStates and Mexico)
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This work discusses the correlation between theassumption of personal jurisdiction over non-residentdefendants (when the defendant has not appearedbefore the court, has challenged its jurisdiction orhas not expressly submitted to such jurisdiction) andthe enforcement of foreign judgments in the threeNorth American countries.Canada, the United States and Mexico offer a veryinteresting legal microcosm.Canada is a Constitutional Monarchy while the U.S.and Mexico are Presidential Republics. All of themare federal States, but federalism works quitedifferently in each one of them.Mexico's legal syst...
This work discusses the correlation between theassumption of personal jurisdiction over non-residentdefendants (when the defendant has not appearedbefore the court, has challenged its jurisdiction orhas not expressly submitted to such jurisdiction) andthe enforcement of foreign judgments in the threeNorth American countries.Canada, the United States and Mexico offer a veryinteresting legal microcosm.Canada is a Constitutional Monarchy while the U.S.and Mexico are Presidential Republics. All of themare federal States, but federalism works quitedifferently in each one of them.Mexico's legal system belongs to the Romano-GermanicTradition; but most of the U.S. and Canada belong tothe tradition of the Common Law.However, there are provinces on both the US andCanada where the Common Law and the Civil Law haveto harmoniously coexist and interact with eachother.Focusing on the correlation between personaljurisdiction and the enforcement of foreign judgmentsthis work probes on the many lessons that may belearned from this interaction in terms of legalparadigms, approach, concepts, structures,procedures, and actual everyday practice of law.
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