A Panamanian corporation lends money to a Turkish enterprise, which issues a promissory note. The loan contract specifies that payment on the interest and principal shall be made to the Chemical Bank of New York City, where both parties maintain accounts.
The loan contract contains no choice of law designation, but the Panamanian and Turkish companies have referred to the Chemical Bank in New York as their ‘‘legal address.''
As a result of a contractual performance dispute, the Turkish company suspends payments on the loan. The Panamanian corporation then brings suit in the United States to recover the balance of the payments due. What possible options for choice of law apply?