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forum), penal laws (law of the forum), purely fiscal and administrative matters, when application poses
injustice to the citizens of the forum, when it involves contrary to security and national interest, involves real
and personal property that is situated in the forum.
conflicts problem
l
jurisdiction
/
\
yes
/
Assume
no
\
dismiss
\
refuse
/
1. characterization
2.determine what law will apply
/
\
Lex fori
Rule provides
Foriegn law is not properly pleaded and proved
Falling under the exception
\
FNC
lex causae
pleaded
proved
not one of the exception