U.S. Discovery in German Arbitration A Gamechanger – U.S. Supreme Court’s decision in the cases “ZF Automotive US, Inc. v. Luxshare, Ltd.” and “AlixPartners, LLC v. Fund for Protection of Investors‘ Rights in Foreign States“

The U.S. Legal System and the German Continental Law System couldn’t be more different in one aspect. This is the matter of discovery. Under German Law there are only very limited instruments for a document production and more­over German courts a very reluctant to allow a “fishing expedition”. Under German civil proceedings the parties shall […]