Procedural Posture

This document is a pro se Complaint filed by Ljiljana Segedin against the Republic of Croatia in the United States District Court for the District of Columbia. The Plaintiff seeks to recover a purported liquidated debt of over $2.2 billion, alleging unlawful expropriation of a U.S.-sourced investment and systematic violations of international law.

Jurisdictional Basis and Allegations

The Plaintiff asserts that the Court has subject-matter jurisdiction over Croatia, a foreign state, under the Foreign Sovereign Immunities Act (FSIA). She argues that Croatia waived its sovereign immunity pursuant to the 1996 U.S.-Croatia Bilateral Investment Treaty (BIT). The Complaint further invokes several statutory exceptions to sovereign immunity under the FSIA, including the expropriation exception (28 U.S.C. § 1605(a)(3)), the commercial activity exception (§ 1605(a)(2)), and the non-commercial tort exception (§ 1605(a)(5)). The Plaintiff claims standing as a recognized U.S. Co-Investor and surviving business partner of her late husband, a U.S. citizen, whose joint commercial investments were allegedly targeted by the Croatian state.

Substantive Claims

The Complaint articulates three primary counts. Count I alleges unlawful expropriation in violation of international law, asserting that the Plaintiff's assets were seized without public purpose or just compensation through fraudulent in absentia judicial proceedings and the actions of an unlicensed, state-appointed bankruptcy trustee. Count II claims that Croatia engaged in continuous commercial activity by managing and liquidating the Plaintiff's real estate assets, thereby stripping itself of sovereign character. Count III alleges non-commercial tortious acts, framing the state's conduct as a pattern of transnational racketeering under the RICO Act. The predicate acts cited include institutional coercion, arson, physical violence, and intimidation designed to force the abandonment of the investment.

Relief Sought

The Plaintiff requests a judgment for the total claimed debt of $2,222,151,876.24, which she characterizes as conceded due to Croatia's alleged failure to respond to prior notices. In addition to monetary damages, she seeks declaratory relief to invalidate Croatian judicial proceedings against her, punitive damages for malicious conduct, and extensive injunctive relief. The requested injunctions include a permanent anti-suit order to prevent parallel proceedings and a global asset freeze against the Republic of Croatia to secure enforcement of a potential judgment.