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Torts manuscript and correspondence. [1] (1940)

handle is hein.ali/hrbor605616 and id is 1 raw text is: Notes on Reading Rabel Torts - Begun Ann Arbor Nov. 2, 1940.* (Down to bottom of page 6) 1. The different Ideas of the law governing a tort are very clearly put as well as their rationale, but I am uncertain what rule pertains in a given country except France and England and I am uncertain how much they adhere to their respective rules. Under a given combination of circum- stances I might guess, but would not know the right answer even in those countries. 2 (under (I)) I assume, but am not sure, that he is talking exclusively of where the lex loci prevails. When I completed reading II classification I think I began to see a fundamental question, namely; unless we should analyze and explain -Conflict of Laws questions from a general juristic point of view and then show the differences of approach and answers in the U.S. and-in Europe (This seems to me what Rabel inclines to dof or whether we should assume in the reader a knowledge of American law and state simply the difference in Europe of the approach and answers, neither' method, of course, leading to specific answers to the constantly repeated question - What is the corresponding law to each section of the Conflict of Laws in the U.S. among the principal European countries.

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