The Good, the Bad and the Ugly: Intersection of Civil Law and Common Law Deposition Styles In Cross-Border Matters

"Stéphane de Navacelle intervenes on ""The Good, the Bad and the Ugly: Intersection of Civil Law and Common Law Deposition Styles In Cross-Border Matters"" to compare and highlight the differences between common law and civil law systems regarding the taking of oral testimony at ABA Section of International Law Spring Meeting in New York. The panel discusses through the use of a hypothetical the procedural issues specific to the US, Germany and France, the differences between arbitration procedures and in criminal/civil procedures and give practical tips on the taking of evidence abroad (Hague convention, MLATs, US consulates, etc.). Relying on factual examples, panelists covers a wide range of issues including: civility problems during depositions, court Intervention, sanctions for misconduct, appointment of a Judge or Master to oversee the procedure and the issues faced by the courts in dealing with international law and enforcement internationally of court orders regarding depositions."