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This document constitutes a Motion for Default Judgment filed by the petitioner against the respondent State before the United States District Court for the District of Columbia. The procedural filing is brought pursuant to Federal Rule of Civil Procedure 55(b)(2) and the Foreign Sovereign Immunities Act (28 U.S.C. § 1608(e)), seeking the judicial confirmation and enforcement of a final arbitral award.
The underlying arbitral award was rendered on November 7, 2018, in International Chamber of Commerce (ICC) Arbitration No. 22370/DDA. Through this motion, the petitioner formally requests that the federal court enter a default judgment against the respondent State in the principal amount of $619,270,111.62. Furthermore, the petitioner seeks pre-judgment interest at a rate of 5.03%, compounded annually from the date of the arbitral award until the entry of judgment, alongside post-judgment interest calculated in accordance with the statutory rate specified in 28 U.S.C. § 1961.