CDR Créances S.A.S., as Successor to Société de Banque Occidentale v. Maurice Cohen, , Defendants CDR Créances…

Summary

The New York Court of Appeals affirmed the lower court’s sanctions against the Cohens for fraud on the court, adopted a clear‑and‑convincing evidentiary standard for such fraud, vacated the default judgment against Sonia Cohen, and remanded for further proceedings. The court also held that no hearing on damages was required because the amount was determinable from the French judgments.