000 02895cam a2200385 i 4500
999 _c200435959
_d54171
001 200435959
003 TR-AnTOB
005 20200325103434.0
007 ta
008 160914s2017 enk b 001 0 eng
010 _a 2016953925
020 _a9781785365935
_q(cased)
020 _a9781785365959
_q(paperback)
020 _z9781785365942
_q(ebook)
035 _a(TR-AnTOB)200435959
040 _aDLC
_beng
_erda
_cDLC
_dTR-AnTOB
041 0 _aeng
042 _apcc
050 0 0 _aK7039
_b.C86 2017
090 _aK7039
_b.C86 2017
100 1 _aCuniberti, Gilles,
_eauthor
245 1 0 _aConflict of laws :
_ba comparative approach : text and cases /
_cGilles Cuniberti.
264 1 _aCheltenham, UK :
_bEdward Elgar Publishing,
_c2017.
300 _axxx, 487 pages ;
_c25 cm
336 _atext
_btxt
_2rdacontent
337 _aunmediated
_bn
_2rdamedia
338 _avolume
_bnc
_2rdacarrier
504 _aIncludes bibliographical references (pages 479-480) and index.
505 0 _aCompeting methodologies -- The choice of law process -- General rules -- Parallel litigation -- Choice of court agreements -- Foreign nation judgments -- Sister states judgments -- Jurisdiction in contractual matters -- Choice of law in contractual matters -- Choice of law in tort matters -- Validity of marriage -- Divorce.
520 _aThe conflict of laws, also known as private international law, is a field of the greatest importance in an increasingly globalized world. The analysis of any legal issue, in a case involving more than one country, must start with an assessment of which court could otentially hear the case and which law it would apply. Contrary to other manuals or casebooks, which focus on the law of one jurisdiction, this innovative casebook offers a comparative treatment of the field. On each issue, materials from several jurisdictions are discussed and compared. The approach centers on comprehending the common principles of the field, but also highlights the frundamental differences. The goal is to train lawyers who not only will kinow the law of their own jurisdiction, but also will have an understanding of the key differences existing between the main models, and will thus be able to interact usefully with clients from other jurisdictions. This casebooks systematically presents and compares the laws of four jurisdictions: the United States, the European Union, France and England (where left untouched by EU harmonization). It offers additional insight into rules applicable in China and Japan and also discusses remarkable solutions adopted in a wide range of jurisdictions such as Italy, Germany, the Netherlands, Canada and Tunisia. All materials from non-English speaking jurisdictions have been translated into English.
650 0 _aConflict of laws
_vCases
_9125180
942 _2lcc
_cBK