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Year 2012 x

Elena Alina Ontanu
Both authors are doctoral candidates in the Department of Private International and Comparative Law at the Erasmus School of Law, Erasmus University Rotterdam. The authors wish to thank Prof. Xandra Kramer for her constructive remarks, as well as Laura van Bochove and the peer reviewers for their comments on the first draft of this paper. The usual disclaimer applies.

Ekaterina Pannebakker
Both authors are doctoral candidates in the Department of Private International and Comparative Law at the Erasmus School of Law, Erasmus University Rotterdam. The authors wish to thank Prof. Xandra Kramer for her constructive remarks, as well as Laura van Bochove and the peer reviewers for their comments on the first draft of this paper. The usual disclaimer applies.

Christoph A. Kern
Dr. Christoph A. Kern, LL.M. (Harvard), professor, chair of Private Law, Private International Law, Comparative Law and Procedural Law at EBS Law School, Wiesbaden. The author wishes to express his gratitude to MaƮtre Anne-Caroline Urbain, LL.M. (Harvard), admitted to the bars of Paris and New York, for her support in researching the current situation in France, as well as PD Dr. Alexander Brunner, Commercial Judge, Zurich, for his support in researching the situation in Switzerland. Remaining errors are the sole responsibility of the author.
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