Article: Ninth Circuit finds that district court violated Act of State Doctrine when it pursued contempt and discovery proceedings against bank which had transferred funds to Philippine government pursuant to judgment of Philippine Supreme Court.

A class of plaintiffs obtained a large judgment against the Marcos estate in Hawaii district court for human rights violations suffered under the Marcos regime. The judgment also enjoined the estate and its abettors from transferring any of the estate's assets. These plaintiffs, however, were not the only ones looking for Marcos' money. The Republic of the Philippines itself was trying to bring about the forfeiture of the Marcos' estate because Marcos had purloined the assets from the Philippine government and its people.

The plaintiffs in the Hawaiian action eventually received an injunction from the court ordering those Swiss banks that held Marcos' funds to ...

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