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Procedural Posture
This document is a declaration submitted under penalty of perjury by Marko Kraljevic, counsel for Petitioner Union Glory Limited, in support of a Petition to Recognize, Confirm, and Enforce a Foreign Arbitration Award. The filing was submitted to the United States District Court for the District of Delaware in connection with enforcement proceedings against Respondent PDVSA Petroleo S.A.
Principal Content and Exhibits
The declaration serves the evidentiary purpose of authenticating key documents from the underlying London-seated arbitration, which was conducted pursuant to the United Kingdom Arbitration Act 1996. The declarant formally introduces and authenticates the First Partial Award issued by the sole arbitrator on April 14, 2023, alongside an Addendum to the award dated May 31, 2023.
In addition to the arbitral decisions, the declaration authenticates the underlying Charter Party dated July 13, 2017, which formed the jurisdictional basis for the dispute. Finally, it introduces correspondence demonstrating that the Respondent was afforded procedural extensions and opportunities to participate in the arbitral proceedings, thereby establishing the procedural fairness of the underlying arbitration for the purposes of enforcement under the New York Convention.
