Christina G. Hioureas

Partner, Chair, United Nations Practice Group - New York

Christina Hioureas

Contact Information

646.927.5507

646.927.5599

chioureas@foleyhoag.com Download vCard

Christina Hioureas is chair of the firm’s United Nations practice group and a partner in the firm's International Litigation & Arbitration practice. Christina represents States, private and State-owned entities, and individuals on international disputes and public international law matters and advises States on matters before the United Nations and its bodies. She also serves as arbitrator in international commercial disputes.

Described as a “dominant force in the international arbitration community,” Hioureas has been recognized for her “particularly impressive knowledge of energy and investment arbitration.” (Who’s Who Legal, 2021). Hioureas is a ranked arbitrator and counsel with Chambers & Partners - Global and USA: Arbitrators, Arbitration Counsel and Public International Law, respectively (2020-21) and noted as a "key lawyer" in Legal 500 USA: Dispute Resolution: International Arbitration and International Litigation, respectively. She is experienced in matters involving the Balkans, the Mediterranean, Europe, the Caucasus, Southeast Asia, the Middle East, Africa and Latin America. More specifically:

  • As counsel in international commercial arbitration  (ICC, ICDR, AAA, SIAC, LCIA, UNCITRAL and Swiss Rules) and investment treaty disputes (ICDR, UNCITRAL) ranging from construction matters to energy pricing and supply and solar power disputes under EPC contracts, sale and purchase agreements, power purchase agreements, offtake agreements, long-term lease agreements, among others. 
  • As Sole Arbitrator, Co-Arbitrator and Emergency Arbitrator in disputes under UNCITRAL, ICC, ICDR, LCIA, and AAA Rules arising from a broad range of contracts including construction, energy, hospitality, franchise, supply chain, technology, and cyber security. She is also a CEDR-certified mediator. 
  • As counsel to States on matters before the United Nations and in proceedings before regional human rights tribunals and the International Court of Justice.
  • As counsel in claims before U.S. courts under the Alien Tort Statute, Torture Victim Protection Act, Foreign Sovereign Immunities Act, and sanctions regimes. 
More »

Education:

  • The Hague Academy of International Law, 2011
  • University of California Berkeley School of Law Boalt Hall, J.D., American Jurisprudence Award - International Law, 2007
  • University of California, Berkeley, B.A., highest honors, 2004

Languages:

English, Greek, Spanish

Representative Experience

Commercial Arbitration (ICC, ICDR, AAA, SIAC, LCIA UNCITRAL, Swiss Rules)

  • Counsel to an Asian state-owned entity in an UNCITRAL arbitration administered by SIAC arising from drilling and exploration agreements of natural gas reserves. 
  • Counsel to an Asian state-owned entity in an UNCITRAL arbitration arising from a change in gas market fundamentals. 
  • Counsel to Latin-American energy company in a force majeure contractual dispute in connection with the effects of COVID-19 on a petroleum storage and throughput agreement and related reallocation and refurbishment agreements.
  • Counsel to an Asia state-owned entity in ICC arbitration involving a large-scale solar power project. 
  • Counsel to State-owned entity in ICSID commercial arbitration relating to the purported res judicata effect of an ICC award.
  • Counsel to Latin-American energy company in a potential LCIA arbitration involving changing market fundamentals in pricing. 
  • Counsel to Greek State-owned entity in an ICC arbitration arising from changing market fundamentals in connection with the decoupling of oil and gas pricing and claims regarding gas shortages claims. 
  • Counsel to Greek entity in an ICC arbitration arising from a gas sale and purchase agreement and related interconnector pipeline treaty. 
  • Counsel to a US-based energy company in an arbitration under the Swiss Rules in a dispute arising out of power plant construction projects in Russia.
  • Counsel to various Silicon Valley tech companies in four interrelated ICDR and ICC international arbitration disputes alleging breach of contract and fraud.
  • Counsel to private entity in an international mediation before the ICC Dispute Resolution Board regarding a Ugandan project.
  • Counsel to European State-owned energy entity in a set aside proceeding before the Svea Court of Appeals.

Selective Arbitral Appointments (ICC, UNCITRAL, ICDR, AAA, LCIA)

  • Sole, emergency, and co-arbitrator in international and domestic arbitrations, including under UNCITRAL, ICC, ICDR, AAA, and LCIA Rules; admitted to the panel of arbitrators for the AAA, ICDR, DIS, CPR, LCIA, Asia International Arbitration Centre, and USCIB/ICC. 
  • Sole arbitrator in a series of related AAA arbitrations involving the technology and hospitality sectors. 
  • Co-arbitrator in LCIA dispute alleging breach of a sale and purchase agreement. 
  • Sole arbitrator in an ICC arbitration involving the pharmaceutical sector.
  • Emergency arbitrator in an ICDR arbitration involving an alleged Ponzi scheme and related request for an injunction involving parties in China and the U.S.   
  • Sole arbitrator in AAA dispute involving questions of cybersecurity in connection with the removal of a CEO; choice of law – New York.
  • Sole arbitrator in AAA arbitrations arising from breach of contract claims in the hospitality sector; choice of law - California.  
  • Co-arbitrator in an ICC arbitration arising from an aerospace purchase agreement involving parties in the U.S., Germany, and Panama; choice of law – New York.  
  • Co-arbitrator in an ICDR arbitration involving breach of contract and fraud claims arising from a joint venture agreement and related agreements involving parties in the U.S., the Ukraine, and Cyprus; choice of law – New York substantive and Cypriot procedural law. 
  • Sole arbitrator in an UNCITRAL arbitration arising from the termination of a North-South American franchise agreement and related intellectual property rights; choice of law – Liechtenstein and Netherlands. 

International Investment Arbitration

  • Raiffeisen Bank International AG and Raiffeisen Bank Austria d.d. v. Republic of Croatia. Counsel to Croatia in an UNCITRAL arbitration under the Croatia-Austria BIT arising from alleged investments in Croatia’s financial sector.
  • Adria Group B.V. and Adria Group Holding B.V. v. Republic of Croatia. Counsel to Croatia in an ICSID arbitration under the Croatia-Netherlands BIT arising from alleged investments in a retail enterprise in Croatia.
  • Indian Investor v. African State: Counsel to African State in an ad hoc arbitration pursuant to UNCITRAL rules and administered by the PCA brought by an Indian investor relating to the commercial termination of a land development agreement. 
  • Niko Resources Ltd. v. Bapex and Petrobangla. Counsel to Bangladesh and two State entities concerning the causes and impact of two natural gas blowouts.
  • Niko Exploration (Block 9) Ltd. v. Bangladesh and Bangladesh Oil and Gas Mineral Corp. Counsel to Bangladeshi State-owned oil and gas company in a contract-based ICSID arbitration proceedings.
  • Wuxi T. Hertz Technologies Co. Ltd. and Jetion Solar Co. Ltd. v. Hellenic Republic. Counsel to Greece in an UNCITRAL arbitration under the Greece–China BIT involving alleged investments in a photovoltaic project in Greece.
  • Talal Al Awamleh and others v. State of Qatar. Represented Qatar in an ICSID arbitration under the Qatar – Jordan bilateral investment treaty arising from contracts relating to a cable television franchise. The case was settled and discontinued pursuant to ICSID Arbitration Rule 43. 
  • Baymina Enerji Anonim Şirketi v Boru Hatları ile Petrol Taşıma Anonim Şirketi. Counsel to French-based energy company in ICSID arbitration initiated against a Turkish State-owned entity relating to breach of contract with respect to plant function and gas sales.
  • Koch Minerals Sarl and Koch Nitrogen International Sarl v. Bolivarian Republic of Venezuela. Counsel to private entity in an ICSID arbitration involving the expropriation of a plant and related offtake agreement. 
  • OI European Group B.V. v. Bolivarian Republic of Venezuela. Counsel in ICSID arbitration under the Netherlands-Venezuela BIT related to the expropriation of a glass plant.
  • Karmer Marble Tourism Construction Industry and Commerce LLC v. Georgia. Counsel in an ICSID arbitration involving issues of expropriation of a toll road and casino hotel services concession.
  • European Entity v. Eastern European State. Counsel to energy company in an investment arbitration claim relating to expropriation of energy storage facilities.
  • U.S. Company v. North American State. Advised on NAFTA claim involving due process claims with respect to an acquisition and related court actions.
  • Spanish Company v. Latin American State. Served as secondary counsel on an ICSID claim regarding expropriation of an airline.
  • Asian Company v. Middle Eastern State. Served as secondary counsel on an ICSID claim regarding expropriation of an oil refinery plant.

Proceedings before the International Court of Justice and Regional Tribunals

  • Legal Consequences of the Separation of the Chagos Archipelago from Mauritius in 1965 (request for Advisory Opinion). Counsel to Mauritius in advisory opinion proceedings before the International Court of Justice on whether the decolonization of Mauritius was lawfully completed in light of the United Kingdom’s excision and retention of the Chagos Archipelago.
  • Guyana v. Venezuela (Case Concerning the Arbitral Award of 3 October 1899). Counsel to Guyana in case brought to confirm the international boundary between the two States as determined by an arbitral award whose validity Venezuela has challenged.
  • Pilav v. Bosnia and Herzegovina (European Court of Human Rights). Counsel to an intervening party in a claim before the ECtHR regarding the Dayton Accord power sharing Constitutional structure and the right to run for office and vote.
  • Prosecutor v. Im Chaem (Extraordinary Chambers in the Court of Cambodia). Counsel to an intervening party in a case involving crimes against humanity, torture, cruel treatment, and extrajudicial killings.
  • Balkan Entity v. Balkan State (European Court of Human Rights). Counsel to consortium of companies in a claim before the European Court of Human Rights involving the unlawful tender of a public works contract and the right to a fair trial.

International Litigation in U.S. Courts 

  • Doe v. Chiquita Brands Int.’l, Inc. (U.S. Supreme Court). Counsel to NGO in amicus curiae brief before the U.S. Supreme Court regarding the legal standards for lifting protective orders, particularly in cases involving survivors of torture and other grave international crimes. 
  • Newman v. Permanent Mission of the Republic of Bulgaria to the United Nations (SDNY). Represented the Republic of Bulgaria in a tort claim before the Southern District of New York under the Foreign Sovereignty Immunities Act.
  • Ahmed v. Magan (SD Ohio). Counsel to the Legal Adviser to the President of Somalia in an arbitrary detention and torture claim brought under the Alien Tort Statute/Torture Victims Protection Act against a former member of the Siad Barré dictatorship. 
  • Jara v. Barrientos (MD Fla). Counsel to the family of the late folk musician, Victor Jara, in an Alien Tort Statute/Torture Victim Protection Act claim involving crimes against humanity, extrajudicial killing, torture, cruel treatment, arbitrary detention against a former member of the Pinochet dictatorship.
  • BG v. Argentina (U.S. Supreme Court). Counsel to the USCIB in amicus curiae brief on preconditions to international investment arbitration.
  • In re Hammond (Ca). Argued a petition for habeas corpus and the secured release of a victim of intimate partner battering and its effects who was wrongfully convicted of second-degree murder.
  • California Association of Mental Health Patients’ Rights Advocates v. California. Counsel in a disability discrimination claim against California.

UN Advisory and Other Sovereign Representation

  • Greek Orthodox Archdiocese of America: Counsel to the Archdiocese in UN advisory matters in connection with the protection of cultural property, the freedom of expression, and protection of religious minorities. 
  • African State: Advised State on the preparation of a General Assembly resolution and supporting memoranda in support of seeking an advisory opinion before the International Court of Justice.
  • Middle Eastern State: Advised State on human rights UN advisory matter.
  • Asian State: Advised Asian State on various human rights matters before the UN Security Council.
  • Various States: Advised various States on matters before UNCITRAL WGs II/ III.
  • Federal Republic of Somalia: Advised Somalia on questions of international law and the draft Provisional Constitution.
  • Middle Eastern State: Advised a Middle Eastern state on sovereign immunity and international human rights law as part of capacity-building training.
  • Asian State: Advised an Asian state on claims to hydrocarbon royalty by a provincial government and questions of law of the sea.
  • European State: Advised a State on potential claims relating to state succession and unlawful expropriation.
     

Professional Experience

  • Teaching Staff, University of Piraeus, Department of International & European Studies - Energy Strategy, Law & Economics Program (2018-2020)
  • Adjunct Associate Professor of Law, Fordham University (2013-2016)
  • Graduate Student Instructor, UC Berkeley, Peace & Conflict Studies and Political Science Departments (2004-2007)
  • "Climate, State, and Sovereignty: Self-Determination and Sea Level Rise," (co-authored with Alejandra Torres Camprubí), Liechtenstein Institute on Self-Determination at Princeton University (2021)
  • “Legal and Political Considerations with respect to the Disappearance of States,” (co-authored with Alejandra Torres Camprubi), in New Knowledge and Changing Circumstances in the Law of the Sea (Brill, 2020).
  • “Law and Practice,” Chambers Global Practice Guide – International Arbitration, Second Edition (2019) (with D. Schimmel). 
  • “The Singapore Convention on International Settlement Agreements Resulting from Mediation: A New Way Forward?”, Berkeley J. Int’l L (2019).
  • Chambers Global Practice Guide: International Commercial Arbitration, authored chapter on arbitration under U.S. law (2019) (with D. Schimmel). 
  • "A New Legal Framework for the Enforcement of Settlement Agreements Reached Through International Mediation: UNCITRAL Concludes Negotiations on Convention and Draft Model Law,"  EJIL Talk, (2018) (with S. Tewarie). 
  • "Framework Agreement between the Government of the Republic of Cyprus and the Government of the Arab Republic of Egypt Concerning the Development of Cross-Median Line Hydrocarbons Resources," International Maritime Boundaries, 1-15 (2017) (with B. Guthrie).
  • NATURAL RESOURCES AND THE LAW OF THE SEA, Juris Publishing (2017) (co-editor (with L. Martin and C. Salonidis)
  • "Sovereignty Disputes and Offshore Development of Oil and Gas," Journal of Energy and Natural Resources Law (2017) (with B. Guthrie).
  • “International Commercial Arbitration: Greece,” Global Arbitration Review (2016 and 2018).
  • “International Commercial Arbitration: Cyprus,” Global Arbitration Review (2016).
  • “Potential Legal Implications Arising from ‘Brexit,” Foley Hoag (2016).
  • "Kiobel v. Royal Dutch Petroleum: Is Corporate Liability Under the Alien Tort Statute On its Way Out?," Berkeley J. Int’l L. Publicist, Vol. 9, (2011).
  • "Transatlantic Environmental Regulation-Making," in Handling Environmental Global Challenges: California, the United States and the European Union, Leuven Centre for Global Governance Studies (2010), republished in Transatlantic Regulatory Cooperation: The Shifting Roles of the EU, the US and California, Edward Elgar Publications (2011) (with B.Cain).
  • "Glamis Gold, Ltd v. United States: A Case Study on Disclosure Procedure in International Arbitration," 2 World Arb & Mediation Rev 3 (2008) (with V. Camerer).
  • "US Discovery in Aid of International Legal Proceedings: Developments Since the Intel Decision Under Section 1782," 4 Deutsch-Amerikanische Juristen-Vereinigung 177, (2006) (with P. Thompson).
  • "Behind the Scenes of Protocol No. 14: Politics in Reforming the European Court of Human Rights," 24 Berkeley J. Int’l L 718 (2006).

Foley Hoag Alerts & Updates

Honors

  • Legal 500 USA – Dispute Resolution: International Arbitration and International Litigation (2021) 
  • Who's Who Legal in International Arbitration (2018-2021) (a “dominant force in the international arbitration community”, recognized for her “particularly impressive knowledge of energy and investment arbitration.”).
  • Chambers & Partners – Global: Public International Law (2020-21) ("She is able to think like a lawyer, state representative, and a business person all at the same time and this is very unique and refreshing.").
  • Chambers & Partners – USA: Arbitrators (“Up and Coming") (2020-21) ("She has deep expertise in public international law but seems equally at home in purely commercial disputes. Her international background and close attention to detail are real assets to the tribunal.").
  • Legal 500  and Legal 500 Latin America (2015).
  • Center for Justice & Accountability “Partners in Justice Award” (2015) for Jara v. Barrientos, which brought to light atrocities committed in Chile during the Pinochet regime; and (2013), for Ahmed v. Magan, holding Somalia's notorious National Security Service accountable for human rights violations.
  • Greek America Foundation's “40 Under 40” Award (2015).

Involvement

  • Board of Directors (Alternate Board Member), New York International Arbitration Center (NYIAC) 
  • Panel of arbitrators: AAA, ICDR, DIS, Asia International Arbitration Centre, and USCIB/ICC, and CPR Panel of Distinguished Neutrals (Energy, Oil and Gas; Banking and Financial Services; Franchise; and General Commercial Panels) 
  • New York International Arbitration Center, Member
  • ICC Commission on Arbitration & ADR, U.S. Member
  • Council on Foreign Relations, Elected Term Member
  • Atlantic Council, Elected Member
  • American Society of International Law (ASIL), Executive Council
  • American Bar Association and International Bar Association
  • “Missed Opportunities in Approaching Arbitration Cases,” (New York State Bar Association, 2021).
  • “State Defenses and Counterclaims,” Executive Course on International Investment Law and Arbitration, (Queen Mary University of London, School of International Arbitration, 2021).
  • “The Singapore Convention – Two Years Later,” (New York State Bar Association, 2021).
  • “Innovative Defense Strategies in Investor-State Dispute Settlement,” (Uzbek Arbitration Week (Tashkent, 2021).
  • “Strengthening Atrocity Crime Cases with Digital Evidence: New International Standards on Digital Open Source Investigations,” (Virtual, 2021).
  • “Sierra Leone’s Landmark Accession to the New York Convention: Significance, Opportunities, Challenges and the Next Steps,” (Virtual, 2021). 
  • “Recent Developments in the Protection of Cultural Heritage,” (Virtual, 2021).
  • “Mediation the World Over,” Third Annual Schiefelbein Global Dispute Resolution Conference (Virtual, 2021).
  • “State Control of Internet Access during Atrocity Situations,” Nineteens Session of the Assembly of States Parties to the Rome Statute of the International Criminal Court (Virtual, 2020). 
  • “Push for Parity: Practical Tools for Emerging Arbitrators,” ERA Pledge (2020).
  • “The Evolution of the Alien Tort Statute and the Implications for International Human Rights Law,” Berkeley Law (Virtual, 2020).
  • “Structural Racism, Police Violence and the Right to Protest,” UN Event (2020).
  • “ASIL Midyear Meeting: Practitioner’s Forum,” Co-Chair (Virtual, 2020). 
  • “Climate, State and Sovereignty: Self-Determination and Sea-Level Rise,” Liechtenstein Institute on Self-Determination at Princeton University (2020). 
  • “Ensuring Efficiency in Complex Technology Arbitrations,” Silicon Valley Arbitration and Medication Center (Virtual, 2020).  
  • “Representing States and State-owned Entities,” 35th Annual Joint Symposium of Arbitrators, Queen Mary University of London and ICC Institute of World Business Law (London, 2020). 
  • “The Potential Impact of Expert Witnesses on Arbitrator Impartiality and Independence,” 13th Annual ICDR Practice Moot and Lecture Series (NY, 2020). 
  • “Welcome to the Hotel California (Consumer Privacy Act): You can check out any time you’d like, but you may still be liable,“  Podcast: Volume One (2019). 
  • “Gentle Force of Compromise: Mediation,” Asia ADR Week, (Kuala Lumpur, Malaysia, 2019).
  • “Efficiencies and Alliances in Public-Private Partnerships: Regulatory and Institutional Factors for Dispute Resolution Hubs,” Singapore Convention Signing Ceremony & Conference (Singapore, 2019).   
  • “Technology and Arbitral Players,” Young ICCA-ICC YAF (Mexico City 2019).
  • "Tribunal Dynamics: Selection of Arbitral Tribunal from the Counsel and Arbitrator Perspective," American Arbitration Association (New York, 2019). 
  • “Parallel Proceedings in Arbitration,” New York State Bar Association (2019).
  • “The Singapore Convention on Mediation: Expert Perspectives on its Significance for the Future of Dispute Resolution,” UNCITRAL WG III event (New York, 2019).
  • “Technology and Arbitral Players,” ICCA and ICC Conference (Mexico City, 2019).
  • The Singapore Convention on the Enforcement of Agreements Achieved Through International Mediation: A New Way Forward?” The Elegance of International Law: In Commemoration of Professor David D. Caron (Berkeley, 2018).
  • “Practicing at the Intersection of Public and Private International Law” USC Gould School of Law (Los Angeles, 2018). 
  • “Introduction to International Dispute Resolution,” Yeosu Academy of International Law (Yeosu, Republic of Korea, 2017).
  • “International Water Conflict and Cooperation: Grappling with the Allocation of Freshwater Between States in the Face of Climate Change,” 95th Annual Meeting of the American Branch of the International Law Association, International Law Weekend (New York, 2017).
  • “The Potential Effects of Rising Sea Levels,” 18th Open-Ended Informal Consultative Process on Oceans and the Law of the Sea, The Effects of Climate Change on Oceans, United Nations Headquarters (New York, 2017). 
  • "Climate Change Arbitration: The Key to 'Climate Justice for All' After the Paris Agreement,” ABA Section of International Law, (Washington, D.C., 2017)
  • “New Frontiers in the Law of the Sea,” Universidad del Pacífico (Chile, 2017).
  • "Defense of Land and Water as a Strategy to Eradicate Poverty,” UN Headquarters (New York, 2017).
  • “Recent Developments in Investment Treaties and Dispute Settlement Systems: Efforts by U.N. Member States for a More Balanced Way Forward,” New York Bar Association, Committee on the United Nations (New York, 2017).
  • “Transboundary Groundwater and International Law: Water, Peace, and Security.” Protection and Management of Transboundary Groundwater: Legal Issues and the Human Right to Water, UN Headquarters (New York, 2016).
  • “Recent Developments in Investment Arbitration,” New York Bar Association, JAMS Mediation, Arbitration, ADR Services (New York, 2016).
  • “Silk Road Energy Projects - Oil & Gas, Nuclear, Renewables,”  The Silk Road Summit - 1st Annual Conference: Exploring Business, Trade & Investment Opportunities on the New Silk Road, (Washington, D.C., 2016).
  • “Beauty and the Beast: From Populism to Orthodoxy, Foreign Investment in Latin America,” Latin Lawyer 7th Annual Private Equity Conference (New York, 2016).
  • “Legal Issues Related to Energy Transportation,” 3rdAnnual Int'l Seminar on Energy and Shipping, Institute of Energy for South-East Europe (Greece, 2016).
  • “Emerging Frontiers in the South China Sea,” Panel Chair, Annual Meeting of the American Society of International Law (Washington, D.C., 2016).
  • “Transparency in International Investment Arbitration,” ICC Forum on “In Defense of International Commercial Arbitration: Lessons to Be Learned from Investor-State Arbitration (New York, 2015)
  • “Post-Conflict Security in Somalia: A Case Study in U.S. Federal Court,” NYU Center for Global Justice and Human Rights (New York, 2015).
  • Year in Review: Key Decisions and Developments in Investor-State Arbitration,(New York, 2015).
  • “Multilateral Home State Efforts to Regulate Foreign Investment,” Columbia Law School (New York, 2014).
  • "Eastern Mediterranean LNG to the EU from Israel and Cyprus: Prospects and Challenges," 5th Annual Mediterranean Oil & Gas Conference (Limassol, Cyprus, 2014).
  • "Transforming the Investment Treaty System through Joint Termination and Amendment," Vale Columbia Center on Sustainable International Investment, Columbia Law School (New York, 2013).
  • "Disputes and the Regime of Islands and Rocks Under UNCLOS," Panel Chair, American Branch of the International Law Association, International Law Weekend (New York, 2013).
  • "Between Diplomacy and Adjudication: 'Energy Diplomacy' as a Peace Building Tool," International Law Association Conference - Imperium Juris: Governance, Trade, and Resources (Athens, Greece, 2013).
  • "Risk Reduction in Oil & Gas Exploration: Strategies for States and Investors," 4th Annual Mediterranean Oil & Gas Conference (Athens, Greece, 2013).
  • "The Extra-Territorial Application of European Court of Human Rights Jurisprudence," University of Montenegro (Podgorica, Montenegro, 2012).
  • "Individual Accountability for Human Rights Violations Before U.S. Courts," Center for Cultural Diplomacy (London, 2012).
  • "Transatlantic Environmental Strategies," Centre for European Policy Studies, the European Commission Directorate-General for External Relations with the US and Canada (Brussels, 2009).
  • "International Environmental Policy: Climate Change, Water Policy, Chemicals Regulation, and Biosafety," University of California Washington Center, Institute of Governmental Studies (Washington, D.C., 2009).
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Bar Admissions

  • New York
  • California
  • England and Wales

Court Admissions

  • U.S. Supreme Court
  • U.S. Court of Appeals for the Ninth Circuit
  • U.S. Court of Appeals for the Eleventh Circuit
  • U.S. District Court for the Southern District of New York
  • U.S. District Court for the Northern District of California