“The question of the reception of foreign legal institutions is not a question of nationality, but simply one of expediency, of need. No one will fetch a thing from abroad when he has as good or better at home; but only a fool will reject the bark of the cinchona because it did not grow in his vegetable garden.” Jhering, Geist des römischen Rechts, Part I (9th ed. 1955) at 8–9.