Tiana A. Bey's practice includes international arbitration related to bilateral investment treaties, arbitration award enforcement proceedings, contract disputes, and family law implicating international issues. With 18 years of legal experience, her positions as a paralegal and now attorney have given Tiana a unique and advanced perspective on any case that comes her way. Tiana has performed all aspects of litigation from case intake through final disposition at trial. She has a wide array of litigation experience including appearing as lead counsel for hearings and trials; interviewing fact and expert witnesses; preparing witnesses for deposition and trial testimony; taking depositions; issuing and responding to discovery; researching potential claims; presenting legal strategy recommendations to partners and clients; counseling clients on likely outcomes; and drafting a wide variety of trial court motions and briefs and appellate briefs in state and federal courts.
- In defense of SDNY action to enforce Malaysian arbitration award, the team successfully obtained vacatur of U.S. Court’s $71M judgment confirming the award: Provided analysis and drafted trial court and appellate briefs related to a variety of issues, including obtaining a Rule 60(b) vacatur of judgment on NY Convention grounds; recognizing foreign judgment on grounds concerning conflicting judgments, international comity, and collateral estoppel; and defending against post-judgment discovery of a foreign sovereign’s assets under the Foreign Sovereign Immunities Act (FSIA) and the Vienna Convention on Diplomatic Relations.
- In defense of SDNY action to enforce UK monetary judgment enforcing an arbitration award, the team successfully obtained vacatur of default judgment and dismissal of the case: Provided analysis and drafted trial court and appellate briefs on a variety of issues, including case dismissal on grounds of insufficient service under FSIA; vacatur of entry of default due to the foreign sovereign’s immunity; and the foreign sovereign’s defenses to recognition under the NY Convention and NY Civil Practice Law Rules, due to the preeminence of a Malaysian primary jurisdiction judgment setting aside the award over a UK secondary jurisdiction judgment enforcing the award.
In defense of ICSID arbitrations related to bilateral investment treaties (Laos/PRC and Laos/Netherlands), the team successfully settled a $1.5B investment dispute against a foreign government with no money paid by the government defendant: Attended arbitration and prepared witnesses for arbitration testimony. Provided analysis of a variety of issues, including “moving treaty frontiers” doctrine; internationally accepted rules of evidence; doctrines of Lis Pendes and Res Judicata and standard for staying parallel arbitration proceedings under ICSID and UNCITRAL; requirements for allowance of adverse inference of bribery; customary international law concerning compound prejudgment interest; and sovereign immunity implications under ICSID Convention, Singapore International Arbitration Act, and Singapore Sovereign Immunities Act.
Other Career Experience
- Lawyer, King Branson LLC (2012-2016)
- Paralegal, Kirkland & Ellis LLP (1995-2012)