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'Daimler' Mostly Resolves New York's 'Separate Entity' Dispute

, New York Law Journal

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Brian Rosner and Natalie A. Napierala, shareholders of Carlton Fields Jorden Burt, write: The lower federal and state courts disagree on the meaning of 'Koehler'. Faced with conflicting applications of New York state law, and unclear as to the correct rule, the U.S. Court of Appeals for the Second Circuit, in 'Motorola Credit v. Standard Chartered Bank', has certified again to the New York Court of Appeals the issue of the extraterritorial reach of the New York state garnishment statute.

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