in the English Court, and did not dispute its jurisdiction over him, but did raise numerous defenses during the English Action. The English Court ruled against Mullin on each of the defenses he asserted against his obligation to pay the Equitas Premium, and entered judgment in Lloyd’s favor on March 11, 1998 (the “English Judgment”). To date, the English Judgment remains unsatisfied, and led to the instant matter. On March 8, 2002, Lloyd’s filed its Complaint in this Court, seeking enforcement of the English Judgment against Mullin. Lloyd’s moved for summary judgment thereafter, and the motion is now ripe for a decision. This Court’s jurisdiction is premised on diversity of citizenship, and Pennsylvania law governs. See 28 U.S.C. § 1332; Choi v. Kim, 50 F.3d 244, 248 n. 7 (3d Cir.1995) (<HOLDING>). II. STANDARD OF REVIEW ON SUMMARY JUDGMENT
holding that in diversity cases federal courts are to apply state substantive law and federal procedural law holding that federal courts must apply state substantive law in diversity cases holding that state substantive rules of decision apply in federal diversity cases holding in diversity cases without any federal question state law governs district courts determination of whether to recognize a foreign country judgment holding that the declaratory judgment act as opposed to state law governs cases removed on the basis of diversity jurisdiction under an erie analysis