Member Voices: Mélanie Goutelle & Robert Boneczko
Mélanie Goutelle
Soulier Bunch (France) –> Faegre Drinker (Illinois, USA) |
Robert Boneczko
Sołtysiński Kawecki & Szlęzak (Poland) –> Arias (Costa Rica)
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What's one similarity or difference between your home and host jurisdictions that surprised you?
MG: The most striking difference concerns contract drafting philosophy: US drafting is highly detailed and exhaustive, seeking to anticipate and cover every possible scenario within the contract itself, whereas French law relies more heavily on a default statutory framework and a degree of trust in judicial interpretation in the event of a dispute. This difference in approach—maximum contractual anticipation versus a legal safety net—has concrete implications for the length of negotiations, the volume of the documents, and the very role of the lawyer in structuring a transaction. Conversely, I was surprised by the underlying similarities in certain corporate governance reflexes and deal structuring practices, despite the significant differences between the two legal systems.
RB: One interesting observation is that, despite the differences between our jurisdictions and legal systems, many of the challenges faced by clients are remarkably similar, such as dealing with lengthy litigation proceedings. At the same time, it has been fascinating to see the extent to which local business culture influences legal practice in Costa Rica.
What's one lesson, skill, or insight you'll take back to your home firm?
MG: First and foremost, I intend to bring greater rigor to contractual anticipation—more systematically building in, from the drafting stage, scenarios and hypotheses that French practice sometimes leaves to judicial discretion. I also want to bring back a culture of responsiveness and more frequent client reporting, which strengthens trust and smooths the relationship throughout a matter. Finally, this experience allowed me to step back from my usual practice and gain confidence in my ability to operate in a different legal environment—a confidence I intend to leverage to develop, in time, a transatlantic client base and caseload within my firm.
RB: Seeing how Arias operates as one integrated team has reinforced the importance of investing in a strong firm culture alongside legal expertise. It has also shown me how much can be achieved when collaboration and knowledge-sharing are embedded in the firm's day-to-day operations.