Duval v. Major

By the standards of either New York or English law, the plain language of the parties’ agreement, as set forth in the financial order issued by the London High Court of Justice on May 26, 2006, reflects the parties’ intention that English law govern an application by either party for modification of the maintenance provision of the agreement and that any application for a modification be made to the English court (see Vermont Teddy *577Bear Co. v 538 Madison Realty Co., 1 NY3d 470, 475 [2004]; Ditta Estasis Salotti di Colzani Aimo e Gianmario Colzani v Ruwa Polstereimaschinen GmbH, 1976 ECR 1831,…