Issue link: https://mbozikis.ufcontent.com/i/1422521
231 comity. 128 11 U.S.C. § 1507(b). An example of additional relief that a court has granted under Section 1507 is an order to enforce a foreign court's order in U.S. bankruptcy courts. See In re Agrokor d.d., 591 B.R. 163 (Bankr. S.D.N.Y. 2018) (enforcing settlement in Croation insolvency proceeding that restructured English-law debt, even though to do so denied comity to English law); In re Sino-Forest Corp., 501 B.R. 655 (Bankr. S.D.N.Y. 2013) (enforcing third-party releases approved in a foreign proceeding even though such releases may not be approved in a U.S. Court); but see, In re PT Bakrie Telecom Tbk, 628 B.R. 859 (Bankr. S.D.N.Y. 2021) (refusing to enforce non-consensual third-party releases granted in an Indonesian insolvency proceeding where the record of the foreign proceeding did not disclose the basis for the releases or establish the procedural fairness of the underlying process). 2. Relief Outside the Chapter 15 Proceeding In addition to the relief noted above, recognition also provides a foreign representative with (i) the ability to (A) commence an involuntary U.S. bankruptcy case against the debtor or (B) in the case of a foreign main proceeding only, commence a voluntary U.S. bankruptcy case for the debtor, and (ii) standing in a plenary U.S. bankruptcy case for the debtor to initiate certain actions to avoid acts detrimental to creditors (most notably, the exercise of avoiding powers). 11 U.S.C. §§ 1511, 1523. Furthermore, once recognition is granted, the foreign representative (a) has the capacity to sue and be sued in a U.S. court and (b) may apply directly to a U.S. court for appropriate relief. 11 U.S.C. § 1509(b)(1)–(2). The foreign representative may also "intervene in any proceedings in a State or Federal court in the United States in which the debtor is a party" and is entitled 128 The U.S. Supreme Court has defined comity as the "recognition which one nation allows within its territory to the legislative, executive or judicial acts of another nation, having due regard both to international duty and convenience, and to the rights of its own citizens or of other persons who are under the protection of its laws." Hilton v. Guyot, 159 U.S. 113, 164 (1895).