In article <[email protected]>, Alan Mackenzie <[email protected]> wrote: > > This may help you out: > > > <http://www.dr-hoek.de/EN/beitrag.asp?t=Conflict-of-law-real-estate-mortg > > age> > > Eh? I don't need "helping out", and the page you've cited is a long, > theoretical, abstract tome, whose relevance to the pertinent question is > at best problematical. Just for emphasis, that question is the ability > of a court in one country to administer the laws of a different country. > It's not about "conflicts of law". That page is also tedious in the > extreme to somebody like me who isn't fascinated by legal niceties for > their own sake. > > I'm putting it to you, in a polite but firm manner, you are simply > mistaken with the notion that a German court could and would settle a > dispute under Californian law. That this applies for fairly comprehensive > values of "Germany" and "California". > > If you can't stump up the evidence, you should admit your mistakenness. > > Does the page you've cited contain a pertinent concrete example somewhere > within it? If so, please point it out.
These two links might make things clear. The first discusses how German courts decide what law applies in a contract case. The second discusses how German courts go about determining an applying foreign law. 1. <http://books.google.com/books?id=TAHtXWpA9soC&pg=PT86&lpg=PT86&dq=contra ct+choice+of+law+germany&source=bl&ots=yI-D_EnoIV&sig=29DnNn_DNS9z1Das0-T 0_koK3Ug&hl=en&ei=Vv6NSqKHFYrQtAPas8iECw&sa=X&oi=book_result&ct=result&re snum=3#v=onepage&q=&f=false> > <http://books.google.com/books?id=TAHtXWpA9soC&pg=PT86&lpg=PT86&dq=contract+choice+of+law+germany&source=bl&ots=yI-D_EnoIV&sig=29DnNn_DNS9z1Das0-T0_koK3Ug&hl=en&ei=Vv6NSqKHFYrQtAPas8iECw&sa=X&oi=book_result&ct=result&resnum=3#v=onepage&q=&f=false> 2. <http://www.iuscomp.org/gla/literature/foreignlaw.htm> -- --Tim Smith _______________________________________________ gnu-misc-discuss mailing list [email protected] http://lists.gnu.org/mailman/listinfo/gnu-misc-discuss
