LexBerg was instructed in 2020 following the death of a German national who had been a dual resident of Frankfurt and the Bordeaux wine region of France for the final twenty-two years of his life. The estate comprised a commercial property portfolio in Frankfurt valued at approximately €1.9 million, a French vineyard estate valued at €1.1 million, and investment accounts held in Luxembourg totalling a further €200,000. The deceased had left a handwritten will prepared under German law, but had not taken any steps to address the French and Luxembourg assets under the succession laws applicable in those jurisdictions.

The matter was further complicated by conflicting claims to the French estate: from the deceased's son from his first marriage, who relied on German succession rules, and from a surviving partner with whom the deceased had lived in France for fifteen years but to whom he was not married. French law granted the surviving partner certain protective rights to the shared home that German law would not have recognised. LexBerg was instructed by the Frankfurt estate executor and was required to navigate the intersection of German, French, and Luxembourg succession law, including the EU Succession Regulation (No. 650/2012) which governs which country's law applies to the estate as a whole.

The key legal question was whether the handwritten will — drafted without awareness of the EU Succession Regulation — could be read as a valid law choice under Article 22, bringing the entire estate under German law while still respecting the French protective provisions that applied as a matter of mandatory law. LexBerg's analysis concluded that it could, and this became the foundation of the entire estate administration strategy.

LexBerg coordinated parallel proceedings in Germany, France, and Luxembourg, with the goal of administering the entire estate as a coherent whole rather than three separate fragmented processes — preventing costly duplication and preserving the vineyard's commercial operation throughout.

• A detailed analysis of the EU Succession Regulation established that Germany had the stronger claim as the habitual residence at death under Article 21, and that the handwritten will's implicit choice of German law was capable of being read as a valid Article 22 election.
• French notarial counsel was engaged to manage the French estate proceedings in parallel, preserving the vineyard's operational continuity and preventing the forced sale threatened by the surviving partner.
• A negotiated settlement between the son and the surviving partner provided a lifetime right of residence in the French property in exchange for relinquishing all claims to the Frankfurt portfolio, which passed intact to the son as sole beneficiary.
• A European Certificate of Succession issued by the Frankfurt Probate Court was recognised in both France and Luxembourg, enabling the Luxembourg accounts to be transferred without additional local probate proceedings.

The estate was fully administered within eleven months of instruction — well within the three-year timeline that cross-border estates of this complexity typically require. The Frankfurt commercial property portfolio transferred to the son free of dispute. The French vineyard estate continued to operate under the surviving partner's lifetime arrangement, preserving the commercial relationships the deceased had built over two decades. The Luxembourg accounts were transferred via the European Certificate without any additional local proceedings. LexBerg's estate planning team has since been retained to assist the son in establishing a proper succession structure for the Frankfurt portfolio to prevent similar complications arising in the next generation.