A Russian citizen married US citizen D., who worked in Moscow in one of the American firms. Their son was born in the United States and, in accordance with the laws of that country, became her citizen. In recent years, the couple lived with their son in Moscow. When there was a breakdown in family relations, the father took the child to the United States without the consent of his mother. Mother sued the Russian court for his return.
Is the Russian court entitled to consider this case in accordance with the rules of jurisdiction, and if so, what national law should it apply? What is the most appropriate solution to the situation, given that between Russia and the United States there is no agreement on legal assistance in civil and family matters?
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