page 18 note 1. In this connection it is worth-while mentioning that the United States Court of Appeals for the Second Circuit reversed a lower judgment that had upheld a subpoena against Canadian banks for the production of records physically located in Canada (August 10, 1960, in re Clement J. Ings et al. v. Murray Ferguson, trustee of Equitable Plan Company, see New York Law Journal of 11 17, 1960).Google Scholar

page 22 note 1. In addition to these Grand Jury investigations, orders for the production of documents located inside and outside the United States have recently been issued against national and foreign companies also by the Federal Maritime Board. The same governments as mentioned in the text, this time joined by that of Yougoslavia, have again launched diplomatic protests in support of the judicial fight of their national companies against those orders, viz. in the Montship case. No final decision in this case has as yet been given by the U.S. courts.