On May 9, 2023, the First Department issued a decision in PJSC Natl. Bank Trust v. Pirogova, 2023 NY Slip Op. 02469, holding that a trial court did not abuse its discretion in deciding an issue of foreign law without expert evidence, explaining:
Supreme Court was within its discretion to consider the substantive issues raised on the motion without taking testimony from Russian law experts, as the record was adequate to allow for construction of the applicable Russian law without a testimonial hearing. The court also properly determined that plaintiff established its entitlement to recognition of the Russian judgments under CPLR article 53 by showing that they were final, conclusive, and enforceable when rendered.
(Internal citations omitted).