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Welcome to the additional readings page of the No-Nonsense Divorce Handbook. Available at Amazon.

International Divorce​

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Some content is in French

 

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Is my marriage in a foreign country valid in the U.S.?

The below article uses Italy as an example.  One of the last paragraphs indicates a general rule (with its exceptions):  That a marriage abroad, if it doesn’t violate U.S. Law, is valid in the U.S., especially if the marriage certificate has an Apostille.

 

https://it.usembassy.gov/u-s-citizen-services/marriage/

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Divorce in two countries is double the trouble.

Article that provides a very high-level view of the complications around international divorce.

 

https://www.reuters.com/article/us-divorce-citizenship-dual/divorce-in-two-countries-is-double-the-trouble-idUSBRE89N10V20121024

 

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A Lawyer’s Handbook for Enforcing Foreign Judgments in the United States and Abroad.

This is a resource that you may provide to your counsel.  Google provides a robust preview of the content.

 

https://books.google.com/books?id=4KQNkLiYc3sC

 

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Faire reconnaître un divorce prononcé à l’étranger.

Different from the Exequatur (which makes enforceable a court order regarding possession, assets, etc.),  the « Vérification d’opposabilité » is the usual process to have France acknowledge the enforceability and validity of a divorce Decree in a country other than France.

 

https://www.diplomatie.gouv.fr/fr/services-aux-citoyens/etat-civil-et-nationalite-francaise/etat-civil/article/les-divorces-a-l-etranger

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Cases Involving Foreign Nationals (requirements for enforcement and recognition in the United States of a judgment rendered abroad).

You will have in your hands a rather technical paper, part of an “Advanced Family Law Course.”  That being said, Section IX is worth reading.

 

The document provides information about what Texas requires to recognize judgments from a foreign country. 

 

http://www.texasbarcle.com/Materials/Events/9198/120827.pdf

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La Séparation / Le Divorce au Delà des Frontières.

If you got married in France, and want to file divorce in a different country, this is a good place to start.

 

https://notairesdugrandparis.fr/fr/la-separation-le-divorce-au-dela-des-frontieres/le-divorce-au-dela-des-frontieres

 

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Divorce et Nationalité: Quel est le Tribunal Compètent? Quelle Loi s’appliquera à votre divorce?

A document that discusses choice of law and Jurisdiction.

 

https://www.village-justice.com/articles/DIVORCE-NATIONALITE-TRIBUNAL-COMPETENT,13818.html

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Prenuptial Agreements: US Law, Thailand Law and EU Law Compared.

Useful for those trying to figure out what their prenuptial agreement entails.

 

http://www.thailawforum.com/articles/international-prenuptial.html

 

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Convention of 14 March 1978 on the Law Applicable to Matrimonial Property Regimes.

This read will be useful to identify risks and opportunities.  Several countries are part of the Hague Conference.

 

https://www.hcch.net/en/instruments/conventions/full-text/?cid=87

 

Not all countries sign all the documents that the Convention generates.  The below link shows a map of the countries that are part of the Convention.

 

https://www.hcch.net/en/states/hcch-members

 

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New York High court Upholds French Prenup.

Useful to get a glimpse of how the prenuptial battles take place.

 

https://cityroom.blogs.nytimes.com/2008/12/18/new-york-high-court-upholds-french-prenup/

Disclaimer: While the information on this site is about legal issues, it is not legal advice or legal representation. We make no warranty or guarantee of the accuracy or reliability of information contained herein or at other sites to which we link. We assume no responsibility for any information, advice or services provided by any site to which we link.

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