WSG Article: An American Abroad: The Divergent Worlds Of U.S. And U.K. Insurance Arbitrations, Mealey’s International Arbitration Report - Hunton Andrews Kurth LLP
Hunton Andrews Kurth LLP
January 1, 2014 - Virginia
An American Abroad: The Divergent Worlds Of U.S. And U.K. Insurance Arbitrations, Mealey’s International Arbitration Report
Introduction - Rooted in the common beginnings, the American and United Kingdom legal systems are cousins with may similarities. As with most relatives perched on opposing branches of a family tree, however, there are numerous and significant differences. One example of how the two legal systems diverge exists in the realm of insurance arbitration. This article focuses on some of the procedural and substantive concerns that arise in arbitrating insurance disputes in the U.K. (and Bermuda) relative to what one might expect when arbitrating in the U.S. To provide the American lawyer a frames of reference, and where appropriate, the article discusses these concerns by highlighting the differences and similarities between U.S. and U.K. insurance arbitration with an eye toward providing some practical guidance to the American lawyer arbitrating an insurance dispute in the U.K.
Read full article at: http://www.hunton.com/files/Publication/28bf0bca-3132-48bf-ad93-0b13a382cc53/Presentation/PublicationAttachment/d5daa9e4-8d2a-46aa-90da-0fe7715b7001/An_American_Abroad.pdf