Don Kirkman wrote:
> It seems to me I heard somewhere that Kevin Gowen wrote in article
> <44fdff39$0$19602$88260bb3@free.teranews.com>:
> 
>> declan_murphy@hotmail.com wrote:
>>> jwb@csse.monash.edu.au wrote:
>>>> The European civil-law notary (and the Japanese 公証人) really
>>>> has no equivalent in Australia. I am at one with KG on this.
> 
>>> Is there a reasonably widely accepted translation into English of
>>> 公証人?
> 
>> You could say "notary public", but that would not be very good at all.
>> The notary of the civil-law jurisdictions is an elite class of lawyer.
>> There is no equivalent in the common law jurisdictions, although Florida
>> and Alabama have statutes that have created similar offices. In most
>> civil law states, transactions such as wills, land transfers, adoptions,
>> and so on must go through a notary to be legally effective. Japan is
>> different in that the only transaction that requires a notary is a
>> corporation's articles of incorporation. (See 会社法, 第30条1項).
> 
> In California a notary public primarily confirms the signatures and
> identification of parties to a transaction; 

As well as in all other states. They can also administer oaths and
certify copies of documents. In a few states, they can even marry
people. Florida has both a notary public statute and a civil law notary
statute.

> ISTM the most common place
> to find a working notary is in a real estate office.  

Or a Kinko's. With over 1% of the American public being notaries public,
just about any office is bound to have at least one.

> The law office I'm
> most familiar with (a public agency) has notaries, but they are among
> the clerical and secretarial staff, not the legal staff.

Yes, I am a notary public as well. The Anglo-American notary public is a
very different animal than the civil law notary. That is why in many
American states, it is illegal for a notary public to translate the
title "notary public" into another language, as it may confuse a person
into thinking that the notary public is the equivalent profession of
their own country.

- Kevin

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