Citigroup, which has operations in both New York and in Argentina, was caught in the middle, being required to conform to both New York and Argentine law, an international conflict of law. The trial court has granted temporary relief to the bank, allow payment of a few of the interest payments due to holdout bondholders, but the obligation to repay all holdouts as the cost of continuing to service Argentine bonds had resulted in a decision to terminate its Argentine debt servicing operation absent legal relief.