Entwicklung transnationaler Modellregeln für Zivilverfahren

Fairness and efficiency are two paramount objectives of procedural law. However, in international civil litigation the implementation of these objectives falls significantly behind the standard that has been achieved in domestic proceedings. Stefan Huber identifies the deficiencies of court proceedings in international disputes and establishes the need for transnational harmonization of procedural law. He develops a theory underlying this harmonization, and, on that basis, suggests a set of transnational principles and rules for the disclosure of documents. His conclusions are supported by a comparative in-depth analysis of the English, French, German and US legal systems that reveals a surprising degree of convergence.