Procedural Posture

This document is a motion filed by a pro se plaintiff, Ljiljana Segedin, before the United States District Court for the District of Columbia. The plaintiff seeks an order denying the defendant, the Republic of Croatia, any right to foreign sovereign immunity and requests that the court accept the complaint for adjudication on the merits.

Plaintiff's Arguments for Forfeiture of Immunity

The plaintiff contends that Croatia has forfeited its sovereign immunity under multiple exceptions to the Foreign Sovereign Immunities Act (FSIA), 28 U.S.C. § 1605. The motion is predicated on allegations of a "predatory expropriation and commercial liquidation" of the plaintiff's private capital assets and corporate equity portfolio in Croatia, which she claims originated from U.S. sources.

The motion invokes the expropriation exception (§ 1605(a)(3)), alleging that Croatia's forced liquidation of assets through a "fabricated" corporate bankruptcy constitutes a taking of property in violation of international law. It further relies on the commercial activity exception (§ 1605(a)(2)), asserting that Croatia engaged in commercial acts (jure gestionis) by managing and marketing the plaintiff's properties as a private market participant. The plaintiff also pleads the non-commercial tort exception (§ 1605(a)(5)), alleging severe torts, including arson and institutional violence by state agents. Finally, the plaintiff argues that Croatia waived its immunity under § 1605(a)(1) through the dispute resolution provisions of the 1996 U.S.-Croatia Bilateral Investment Treaty (BIT) and by allegedly defaulting in a prior arbitration proceeding initiated before the American Arbitration Association.

Jurisdictional Nexus and Relief Sought

The plaintiff establishes a jurisdictional nexus by claiming that Croatia's conduct forced the liquidation of her U.S.-based assets, causing a direct economic effect in the United States. Asserting a total denial of justice in both Croatian and Austrian courts, the plaintiff characterizes the U.S. court as the "Forum of Last Resort."

The plaintiff requests that the court deny Croatia's sovereign immunity and retain jurisdiction to enter a final judgment for a liquidated debt of $2,222,151,876.24.