No. I'm sure I didn't. My husband (who is also a US attorney) drafted everything, but I'm almost 100% positive that the loan documents and mortgage note would have been subject to Pennsylvania law
Its good news.Any money Judgment in the USA can not be enforced in the UK.
The law relating to this is considered in:
The Administration of Justice Act 1920
Foreign Judgments (Reciprocal Enforcement)Act 1933
The Brussels Regulation
The USA is not a member states of these conventions which means that regular money Judgments can not be enforced from the USA in the UK.
Sadly the same applies here if we want to issue proceedings for a money claim for someone in the USA.
We can get Judgment in the UK but it is not going to be enforced in the USA.
Therefore without a valid Court order in the UK they are not likely to get money here in the UK.
That is why I asked which law governed it, if it was the law of England and Wales then yes they would be able to, but if US lawapplies then they would have great difficulty.
Can I clarify anything for you today Rachael about this please?
What a fabulous service this is!
One does try :)
I am super-relieved. I will double check the agreement, but I'm sure it's PA law.
Obviously I can't advise on US law being an English lawyer.
I will let you know if I need any further clarification.
Thank you so much,
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