In the winter of 2005, a charter bus carrying the Ontario Women’s Hockey Team slammed into the rear end of a tractor-trailer parked on the road’s shoulder near Geneseo, N.Y. Four people died in the crash, including the tractor-trailer driver and three of the bus passengers. Several other bus passengers were seriously injured.

The lawsuits that ensued1—by passengers and their representatives against the bus company, tractor-trailer driver and related parties to each—were brought in the Livingston County Supreme Court, and the Court of Appeals recently decided an appeal in the case.2 The divided Court’s opinions include much important discourse on difficult conflicts of law issues, but both the majority and dissenters agree that a failure to comply with CPLR 3016(e) will not preclude judicial notice of the law of a foreign jurisdiction.

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