Bitter, Anna-Kristina Vollstreckbarerklärung und Zwangsvollstreckung ausländischer Titel in der Europäischen Union |
Anna-Kristina BitterVollstreckbarerklärung und Zwangsvollstreckung ausländischer Titel in der Europäischen Union[The Declaration of Enforceability and Compulsory Execution of Foreign Titles in the European Union.]Published in German. Anna-Kristina Bitter deals with a topic which is of current interest but which had received little attention until now. In this work, she describes the declaration of enforceability under the Brussels I Regulation and illustrates the problems in terms of enforcing foreign judgements in Member States. It is the enforcement authorities of the Member States in particular who need to know if the Brussels I Regulation obligates them to enforce a foreign judgement. This can cause practical difficulties if the state of origin refuses to enforce the judgement or has chosen a different way of execution. The author also deals with the question of whether or not German authorities can enforce a German judgement which refers to another Member State, for example when a legally justifiable action has to be performed in another country. |