Rose Hall Ltd. v. Chase Manhattan Overseas Banking Corp.

How later courts describe this case

• applying Rule 63 to allow a successor judge who did not preside at trial to decide a motion for judgment notwithstanding the verdict, so long as the successor judge is not required to evaluate the credibility of witnesses
• error for trial judge to deny motion for reconsideration where plaintiff’s fourth amended complaint only minimally intruded into events involving the act of state doctrine
• hearsay basis for opinion excluded