Souveränität und Verfahrensrecht

How can a plaintiff sue effectively to obtain his rights when the defendant resides abroad and the defendant's assets and/or the necessary evidence are also situated in another country? Which court has jurisdiction, what consequences could this have for legal assistance and which rules govern discovery proceedings? These matters are generally regulated by national law. However it is often maintained that limits to extraterritorial jurisdiction can be derived from international law and the concept of sovereignty. The author attempts to define those limits stemming from governmental practice and applies them to the procedural laws of England, the USA and Germany, arriving at a result which is more Anglo-American than German. He deals with a variety of procedural institutions, among which are the Mareva injunctions, Anton Piller orders, American and English pretrial discoveries and their German equivalents.