1. It is an issue of profound national importance that
a Bankruptcy Trustee seeks to recover property not in
a Debtor's estate when such real property, located in a
foreign nation (Ireland), was never owned by the Debtor
as a matter of foreign (Irish) law. Under the rulings
below, no property established in a trust by any United
States citizen or any person who relocates to reside in the
United States is safe from illegal seizure by a Bankruptcy
Trustee.

2. It is an issue of profound national importance that
a Trust created in Ireland in 2005 for the benefit of estate
planning is ignored in 2015 in order to assert a fraudulent
conveyance claim years after the statute of limitations
period for such a claim has expired ( i.e. a 2015 claim cannot
look back to 2005 or 2006 to challenge trusts created at
that time). Under the rulings below, any trust created
at any point in time in the United States or worldwide is
now exposed to seizure from a trustee in bankruptcy in
the United States and the limitations period under the
Bankruptcy Code and state law is illusory.

3. A District Court should not leave key questions
of legal or beneficial ownership and trusteeship of real
property in Ireland to a lay jury. Such questions of Irish
law should be determined by the Court pursuant to
Federal Rule of Civil Procedure 44.1.

4. It is an issue of profound national importance that
the District Court and the Court of Appeals failed to apply
the principle of comity to the Irish courts' determination
that Sean Dunne did not own any portion of Walford
after July 2005 and similarly failed to apply the Act of
State doctrine to the determination of the Irish Revenue
Commissioners, Irish High Court, and Irish Court of
Appeals that Dunne never owned Walford.

Whether a bankruptcy trustee can recover property not in a debtor's estate when such real property, located in a foreign nation, was never owned by the debtor as a matter of foreign law