Holger Siegwart’s Answers

Holger Siegwart

Burlingame International Law Attorney.

Contributor Level 6
  1. Can my husband held reliable for the funeral cost of his mother?

    Answered 9 months ago.

    1. Daniel Lee O'Neil
    2. Robert Werner von Dohlen
    3. Alan James Brinkmeier
    4. Holger Siegwart
    4 lawyer answers

    I am licensed to practice law in Germany. Under German heirs are liable for funeral costs pursuant to Section1968 BGB (German Civil Code). Decedent's children are heirs by default (intestate succession) unless provisions in decedent's last will disinherit them explicitly, or implicitly by leaving everything to other persons. It is important to understand that you can inherit and become personally liable for decedent's debts under German law. In order to avoid this result you must disclaim...

    1 lawyer agreed with this answer

  2. What is "Convention Abolishing the Requirement of Legalization for Foreign Documents"?

    Answered about 1 year ago.

    1. David Paul Morgan
    2. Luca Cristiano Maria Melchionna
    3. Mark J. Sadoff
    4. Holger Siegwart
    5. David Samuel Willig
    5 lawyer answers

    San Francisco Superior Court Local Rule 14.32 ("Proving Foreign Wills") makes reference to the Hague Convention of October 5, 1961 Abolishing the Requirement of Legalization for Foreign Public Documents. The full text of the Hague Convention can be found here http://www.hcch.net/upload/conventions/txt12en.pdf Under Local Rule 14.32 a petition to probate a foreign will must have attached to it a certified copy of the will and the order or decree admitting it to probate outside of this...

    1 person marked this answer as helpful

  3. I own my own business and sold merchandise to a small company in Germany. They did not pay!

    Answered about 2 years ago.

    1. Charles C. Rainey
    2. Luca Cristiano Maria Melchionna
    3. J Scott Scarbrough
    4. Todd Matthew Heine
    5. Holger Siegwart
    5 lawyer answers

    As a U.S. based company you can sue the debtor company in Germany. Since the amount in dispute appears to be moderate filing suit in Germany may be the most cost-efficient option. In order to make that determination counsel should be familiar with the legal systems in both the U.S. and Germany Other commentators already pointed out that filing suit in the U.S. against the German company, properly serving the the opposing party in Germany, obtaining a judgment in the U.S., and then...