Law
Clemens Trautmann
Europäisches Kollisionsrecht und ausländisches Recht im nationalen Zivilverfahren
[European Private International Law and Foreign Law in National Civil Proceedings.]
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Published in German.
The europeanisation of private international law is supposed to ensure that the same national law applies to a given case irrespective of the Member State in which an action is brought. Clemens Trautmann shows to which extent the heterogeneous procedural rules of the Member States for the application and ascertainment of foreign law conflict with this objective and provides a critical analysis of their compatibility with European Union law.