Roman Frenkel v Arkadiy Lyampert

The 2017 California Judgment is enforceable at common law in England as it is final, conclusive, and for a definite sum; disputes as to quantum or set-off do not defeat enforceability where the sum due is arithmetically ascertainable and sufficient undisputed debt exists to permit set-off against the English costs order.

Parties: Claimant: Roman Frenkel; Defendant: Arkadiy Lyampert
Jurisdiction: England and Wales
Judgment Date: 19 January 2026
Procedural Posture: Civil Enforcement of Foreign Judgment / Summary Judgment Application
Outcome: Claimant's application for summary judgment granted, limited to set-off against the Tipples Costs Order.
Legal Topics: Enforcement of Foreign Judgments, Set Off, Limitation of Actions, Costs

Private International Law Civil Procedure Enforcement of Foreign Judgments Set Off Limitation of Actions Costs

Case Brief

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Parties

Roman Frenkel

Claimant

Arkadiy Lyampert

Defendant

Procedural Posture

Civil Enforcement of Foreign Judgment / Summary Judgment Application

Legal Issues

1 Whether the 2017 California Judgment is enforceable in England at common law
2 Whether the Second Renewal Order affects enforceability or quantum
3 Whether set-offs and costs orders have been properly accounted for in the sum claimed

Ratio Decidendi

Court Disposition

Claimant's application for summary judgment granted, limited to set-off against the Tipples Costs Order.

Orders

Claimant permitted to set off the sum due under the 2017 California Judgment against the Tipples Costs Order assessed at £560,138.29.
Interest due on the costs to the date of judgment in this court.