Conflict of laws (or private international law) is a set of procedural rules that determines which legal system and which jurisdiction's applies to a given dispute. The rules typically apply when a legal dispute has a "foreign" element such as a contract agreed to by parties located in different countries, although the "foreign" element also exists in multi-jurisdictional countries such as the United Kingdom, the United States, Australia and Canada.
The term conflict of laws itself originates from situations where the ultimate outcome of a legal dispute depended upon which law applied, and the common law courts manner of resolving the conflict between those laws. In civil law, lawyers and legal scholars refer to conflict of laws as private international law. Private international law has no real connection with public international law, and is instead a feature of local law which varies from country to country.
The three branches of conflict of laws are
Its three different names – conflict of laws, private international law, and international private law – are generally interchangeable, although none of them is wholly accurate or properly descriptive. The term conflict of laws is primarily used in jurisdictions of the Common Law legal tradition, such as in the United States, England, Canada, and Australia. Private international law (droit international privé) is used in France, as well as in Italy, Greece, and the Spanish- and Portuguese-speaking countries. International private law (internationales Privatrecht) is used in Germany (as well as Austria, Leichtenstein and Switzerland), Russia and Scotland.
Peter Háy, is the son of Gyula Háy, and is the author of over a dozen books, including an anecdote book series for Oxford University Press, a history of MGM, MGM: When the Lion Roars and Ordinary Heroes: Chana Szenes and the dream of Zion the story of Hannah Senesh, the Hungarian Jewish poet and heroine of World War II.
Born in Budapest in 1944, Hay was educated at Haileybury and Imperial Service College and read classics and literature at Merton College, Oxford.
Háy emigrated to Canada in 1967 and taught at Simon Fraser University and Western Washington University. Before moving to Southern California in 1980, he founded the play publishing arm of Talonbooks, a Canadian cultural publisher, and was responsible for publishing the plays of dozens of Canadian playwrights.
After working in the professional theatre world, including as the first dramaturg of the Vancouver Playhouse Theatre Company, he was a dramaturg at the O'Neill Playwrights Conference in Waterford, Connecticut, and at the early Sundance Institute Playwrights Workshops in the early '80's. While teaching in Los Angeles at USC and UCLA, he, together with Didi Conn, Ethan Phillips, and Virginia Morris, co-founded First Stage, a Hollywood non-profit organization that helps writers develop new scripts for the stage and screen, and for which he holds the title of Founding Artistic Director.
Kenneth Kermit Roosevelt I MC (October 10, 1889 – June 4, 1943) was a son of U.S. President Theodore Roosevelt. He was an explorer on two continents with his father, a graduate of Harvard University, a soldier serving in two world wars, with both the British and U.S. Armies, a businessman, and a writer. He fought a lifelong battle with depression and alcoholism, and eventually committed suicide.
Kenneth Kermit Roosevelt was born at the family residence Sagamore Hill in Oyster Bay, New York, the second son born to Theodore Roosevelt and his second wife, Edith Kermit Carow Roosevelt. As a child, his nickname was Kermit and as a grown-up, he adopted the name. He had an elder brother, Theodore Jr., and three younger siblings: Ethel, Archibald, and Quentin. His older half sister was Alice, from his father's first marriage to Alice Roosevelt.
As a child, he had little resistance to illness and infection. He had a flair for language, however, and was an avid reader. He showed a talent for writing that led to recording his experiences in World War I in a book.