uabb domain was triggered too early. This is usually an indicator for some code in the plugin or theme running too early. Translations should be loaded at the init action or later. Please see Debugging in WordPress for more information. (This message was added in version 6.7.0.) in /var/www/sites/lawfirmbackup_200125/wordpress/wp-includes/functions.php on line 6131There are issues on which the Israeli courts refer to foreign legal opinions<\/a>. A South-African legal opinion is referred to in cases involving labor law, real estate law, wills and inheritances, enforcement of foreign judgments, and more, relating to South-African law.<\/p>\n Foreign Expert Legal Opinion – Labor Law<\/strong><\/p>\n For example, in Choppy Sea Treading Ltd v Sivan Tabachnik (NLA 4372-11-16)<\/a>, the National Labor Court discussed a request to delay the execution of the Tel-Aviv regional court\u2019s judgment accepting the respondents\u2019 claim for work payment and other rights. The request was made by the owner of a small business in South Africa selling goods in kiosks, where the respondents worked.<\/p>\n The regional court had stated that, according to the business-owner\u2019s testament, the respondents did not receive paid vacation days or any payment whatsoever for days during which they did not work. Therefore, it was determined that each of the respondents is entitled to vacation pay, in accordance with the foreign legal opinion given by the South-African law expert on the matter.<\/p>\n In the request filed with the National Labor Court it was argued that the judgment contained various errors justifying its annulment. Among other things, it was argued that the tribunal did not discuss the contention that the foreign legal expert opinion on which the judgment was based was invalid; according to the petitioners, the opinion does not apply to vacation pay for the specific type of work in question, on a percentage basis and given the situation of the respondents.<\/p>\n Judge Leah Glicksman stated that the business owner did not contradict the foreign law expert regarding the 21 days of vacation to which workers are eligible in South Africa, did not submit a counter-opinion, and even admitted to not paying the respondents for the vacation days that they deserved.<\/p>\n After examining all the allegations, it was concluded that there is room for a partial delay in the execution of the judgment.<\/p>\n This case demonstrates the great importance of foreign law in Israeli courts and tribunals and shows that, if no foreign legal counter-opinion is brought before the court, it is not very likely that the allegations will be accepted.<\/p>\n When a request for enforcement of a foreign judgment<\/a> is submitted to the court, the court requests the opinion of a foreign law expert on whether the foreign judgment is enforceable in Israel, in accordance with the Foreign Judgments Enforcement Law<\/a>, 5718-1958 (hereinafter: the Enforcement Law).<\/p>\n In the legal opinion submitted to court, the law expert must examine whether the foreign judgment meets the following conditions of the Enforcement Law (Section 3):<\/p>\n In originating motion (Tel Aviv) 20092-06\/16 <\/a>, the court ruled that the business owner failed to prove compliance with Section 3(1) of the Enforcement Law (mentioned above) through the Sierra Leone (a West African country) expert legal opinion; that is, it was not proved that the court that gave the judgment in Sierra Leone was authorized to do so according to Sierra Leone law.<\/p>\n The court stated that proving compliance with Section 3(1) is an essential step, which is intended to convince the court in Israel that the foreign court was authorized to give the judgment according to the foreign law. According to the court, the fact that the judgment was given by a foreign court does not automatically render it valid \u2013 the foreign law expert must clarify the basis for the foreign court\u2019s authority to give the judgment according to the foreign law.<\/p>\n The court further stated that the foreign legal opinion must meet the minimum expectations from a foreign law expert.<\/p>\n This case demonstrates that the court does not automatically accept any foreign law expert\u2019s opinion; it examines the opinion carefully, as well as the expertise of the ostensible foreign expert.<\/p>\n Therefore, the question arises as to who is considered to be a foreign law expert.<\/p>\n According to the case of Jacob Berg and Sons (Furniture) Ltd v Berg East Imports Inc (CA 6796\/97), PD 54(1) 697<\/a>, there is no one single definition of who is considered to be a foreign law expert, but it can be said that any lawyer or jurist who deals with the relevant foreign law through practice, academia, or otherwise, may be considered an expert.<\/p>\n The court further stated that a foreign law expert must meet the following conditions set by Prof. Menachem Shawa:<\/p>\n Another area in which foreign legal expert opinions are often used is succession and wills.<\/p>\n
<\/p>\nEnforcement of a Foreign Judgment<\/strong><\/h4>\n
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Foreign Law Expert<\/strong><\/h4>\n
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Foreign Legal Opinion Concerning Succession<\/strong><\/h4>\n