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[This monograph compares the key characteristics of the laws of four representative legal systems on provisional measures with two interlinked goals. It not only aims to canvass the main comparative advantages or disadvantages of the observed systems but it also tries to answer the ultimate...
[The object of the second chapter of this monograph is to examine the differences between the law and procedure of England and France in relation to provisional measures to arrest assets or order a party to refrain from disposing of his assets. Such measures are commonly sought by parties to...
[Notwithstanding their common origins, English and US law on provisional measures are different today and they may be conceived as two developed yet distinct contemporary regulatory models. Consequently, it is worthwhile to juxtapose the two not only for this reason but also because of the...
[The law on provisional measures is far from being the same in those countries of the former socialist-block that have acceded to the European Union during the first two decades of the 21st century. We cannot present all of them here, to a great extent because the related English (or other...
[Proper assessment of the utility of the Mareva Injunction and the Saisie Conservatoire would not be possible without casting a few words on one of the most recent European developments: the availability of the European Account Preservation Order (hereinafter: EAPO) since 18 January 2017 when...
[This article has examined the provisional measures relating to freezing assets of two major common law jurisdictions and two important civil law systems. The authors were in particular guided by the cautionary words of the concurring and dissenting Justices of the US Supreme Court in the 1999...
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