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Considering the Libel of Review, the agent of a foreign principal is formed whenever you have diversity of citizenship. The issue still arises from lack of proper notice - through the laws of the US - that any foreign agent is to come to a man on the land through the district courts. In light of what Michael Joseph posted though, I think it favorable to view the trust as the endorsement signature, or better, the lack of it (demand for lawful money).
When there is diversity - there is a party that is foreign to the other party.
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