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Plaintiff Pro Se
LJILJANA SEGEDIN, AT-3730 EGGENBURG,
HORNERSTRASSE 2/8.,
REPUBLIC AUSTRIA EU
[email protected]
004306607211027

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

20. May 2026.

ORDERED, that the Plaintiff's Motion is GRANTED; and it is further

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PLAINTIFF'S MOTION TO DENY FOREIGN SOVEREIGN IMMUNITY PURSUANT TO THE EXPROPRIATION, COMMERCIAL ACTIVITY, AND NON-COMMERCIAL TORT EXCEPTIONS (28 U.S.C. §§ 1605(a)(1), 1605(a)(2), 1605(a)(3), AND 1605(a)(5)) NOW COMES

the Plaintiff, Ljiljana Segedin, appearing *pro se* before this Honorable United States Federal Court, and respectfully requests an Order denying Defendant, the Republic of Croatia, any right to foreign sovereign immunity. Plaintiff formally requests that the attached Complaint be accepted for adjudication on the merits pursuant to the Foreign Sovereign Immunities Act (FSIA), 28 U.S.C. § 1605.

I. JURISDICTIONAL AND FACTUAL FOUNDATIONS: MAJORITY CREDITOR STATUS AND ECONOMIC IMPACT WITHIN THE UNITED STATES

This dispute does not arise from legitimate, sovereign public acts of state (jure imperii), but rather from a profound institutional and processual fraud executed by the Defendant.

Through a fabricated and groundless corporate bankruptcy framework, the Defendant executed a predatory expropriation and commercial liquidation and of the Plaintiff's private permanent capital assets and verified corporate equity portfolio (including the valuation basis of Villa Münz, the Brižac Estate, and related properties in Rijeka, Buzet, and Moravice). These assets were not mere real estate holdings, but constituted fixed permanent capital, fundamentally structured as the primary, non-depreciating financial value of the enterprise. The Plaintiff's claim is strictly limited to the monetary indemnification of this lost permanent capital value, as the Defendant's predatory liquidation effectively converted this fixed equity into liquidated cash This Motion rests upon the following uncontroverted, documented facts that establish a direct legal and financial nexus to the United States:"

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1. Lawfully Established Majority Creditor Status and Exclusion Rights: The High Commercial Court issued a final judgment vacating bankruptcy, declaring Plaintiff the majority creditor due to the fraud in the process. Subsequently, the Plaintiff, acting as sole shareholder, executed the exclusion of her entire asset portfolio. In flagrant defiance of its own highest commercial judicial authority and statutory shareholder protection laws, the Defendant's state apparatus and its bankruptcy trustee intentionally ignored these rulings and proceeded with the forced commercial liquidation of the assets.

2. Internationally Authenticated Ownership of U.S. Permanent Capital: The Plaintiff's ownership rights over the business shares and permanent capital were legally registered, verified, and certified by the Federal Ministry for European and International Affairs (BMEIA) of the Republic of Austria in 2017. This official public document of a sovereign European state was further notarized and authenticated by a U.S. Notary Public in Vienna, establishing an unbroken international legal continuity of ownership over an asset structure originating from exclusive U.S. sources, under a fixed capitalization ratio dictating that exactly one (1) share of corporate equity equals $0.70 USD. (with the underlying capital denominated in Croatian Kuna and converted at the 2017 official rate of 0.13 EUR per 1 HRK). This capital was maintained strictly as U.S. permanent investment capital, intended for long-term growth within the Plaintiff's global investment portfolio.

3. Direct and Catastrophic Economic Effect Inside the United States:

The Defendant's continuous predatory, extrajudicial, and criminal conduct in Croatia directly forced the systematic, distressed, and non-discretionary liquidation and sale of the Plaintiff's

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domestic corporate stock portfolios and partnership equities held within the territory and financial system of the United States. This forced divestment of U.S. assets was the sole operational means to mitigate ongoing foreign damages and cover the costs of the state-sponsored terror, thereby causing an immediate, destructive, and compounding economic hemorrhage and asset conversion directly inside the United States financial territory

II. STATUTORY ANALYSIS OF THE FORFEITURE OF IMMUNITY UNDER THE FSIA (28 U.S.C. § 1605)

The Defendant has entirely forfeited its right to invoke foreign sovereign immunity because its conduct directly triggers multiple independent statutory exceptions codified under 28 U.S.C. § 1605.

1. The Expropriation Exception (28 U.S.C. § 1605(a)(3)) The FSIA mandates that a foreign state is not entitled to immunity in any case where rights in property taken in violation of international law are in issue

2. Violation of International Law Standards: The forced commercialization and sale of the Plaintiff's private shares and real estate—in a context where the Plaintiff is the judicially confirmed majority creditor, where a final judgment documents the underlying criminal falsification of the dockets, and where the state explicitly defied the exclusion order of the High Commercial Court—constitutes a textbook, eklatant violation of international law and the minimum standards of justice.

3. Hostile Commercial Motive and Exploitation:

Utilizing the pretext of a corporate bankruptcy shell whose nominal founding capital was a mere 20,000 HRK (approximately $2,857 USD), the Defendant unlawfully absorbed a

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private foreign asset pool whose baseline value was initially established at $8,680,000.00 USD (€7,000,000.00 EUR) and expanded to $14,351,000.00 USD (€12,700,000.00 EUR) by 2017. Driven by the aggressive real estate market growth since 2017, the true current valuation of this portfolio under Western standards features compounding growth exceeding $43,000,000.00 USD (tripling the 2017 baseline).

The Defendant weaponized a fabricated domestic execution apparatus to seize this rapidly appreciating asset pool, utilizing its compounding value as the direct, hostile commercial motive for its predatory institutional attack.

4. The Commercial Activity Exception (28 U.S.C. § 1605(a)(2)) The Defendant, acting through its Commercial Court and a state-appointed bankruptcy trustee (who entirely lacked the mandatory statutory license and regulatory authority required to administer portfolios of this high financial value), completely abandoned its sovereign character (jure imperii).

5. The Defendant entered the marketplace as a private competitor (jure gestionis), routinely leasing, managing, and aggressively marketing the Plaintiff's private properties across global commercial digital networks and statutory auction systems (including e-Oglasna ploča, FINA, and ZIS), targeting international buyers in the exact manner of a private commercial broker. Because these acts are identical to those of a private real estate conglomerate, the Defendant cannot claim sovereign immunity

6. Integration of Extraterritorial Torts and Transnational Racketeering (28 U.S.C. § 1605(a)(5)) Jurisdiction is explicitly invoked pursuant to 28 U.S.C. § 1605(a)(5) in an indivisible conjunction with 28 U.S.C. § 1605(a)(3). The Plaintiff clarifies that the severe non-commercial torts and institutional violence deployed by state agents—including targeted arson and explosive devices (18 U.S.C. § 844(i)), state-sponsored bombings (18 U.S.C. §

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2332f), and a continuous pattern of extortion and public corruption analogous to the Civil RICO Act—are not presented for isolated extraterritorial criminal prosecution.

7. Institutional Duress as the Instrument of Expropriation: These substantive standards measure the gravity of the Defendant's violations of international law. The Defendant explicitly deployed physical violence, unlawful forced break-ins, and the weaponized, institutional containment and endangerment of the Plaintiff's family members (including the horrific 108-day confinement and psychological duress inflicted upon her daughter) as the direct operational mechanisms and coercive instruments. The explicit purpose of this transnational intimidation was to break the Plaintiff's physical resistance, force her flight and tax de-registration to Austria, and eliminate her judicial defense in order to finalize the unlawful expropriation of her permanent capital. These non-discretionary torts directly caused severe existential, personal, and compounding financial injuries.

8. Explicit and Implied Treaty Waiver (28 U.S.C. § 1605(a)(1)) Pursuant to 28 U.S.C. § 1605(a)(1), the Defendant waived its sovereign immunity through the explicit legal commitments and dispute resolution mechanisms established under the 1996 U.S.-Croatia Bilateral Investment Treaty (BIT). The Plaintiff exercised her forum selection rights and formally initiated arbitration proceedings before the American Arbitration Association (AAA). Backed by a U.S. Notary Public certification, the record establishes that the Defendant was properly served but totally defaulted (*bad faith conduct*), failing to answer or enter pre-trial settlement channels.

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III. ABSOLUTUTE ABSENCE OF AN ALTERNATIVE FORUM AND TOTAL DENIAL OF JUSTICE

The Plaintiff explicitly demonstrates to this Honorable Court that she is subjected to a total legal lock-out, and that this U.S. Federal Court in Washington D.C. represents the absolute Forum of Last Resort on Earth:

• Total Judicial Blockade in Croatia: The domestic executive apparatus is fundamentally captured by organized crime and systemic corruption, as the ruling political climate actively denies justice and ignores supreme legal mandates, rendering any domestic remedy completely illusory, hostile and futile.
• Formal EU Rejection Based on the U.S. Genesis of Capital: Following her total tax de-registration from Croatia, the Plaintiff sought legal protection and the activation of national indemnification laws within the European Union, through the competent authorities of the Republic of Austria (where she holds legal residency.

The Austrian authorities formally refused to adjudicate, issuing an explicit determination that this matter involves 100% U.S. Permanent Capital, and therefore, European national compensation statutes cannot be applied to an asset configuration whose financial genesis and legal source reside strictly within the United States. This official declaration by an EU sovereign power eliminates any forum non conveniens defense.

If this Court upholds the Defendant's immunity, it will create a permanent legal vacuum where a foreign state can deploy racketeering and arson to steal authenticated U.S. investments, leaving an individual in a permanent and absolute state of Denial of Justice.

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IV. CONCLUSION AND RELIEF SOUGHT

Based upon the uncontroverted material evidence and the certified tables of liquidated debt served upon the Defendant's Ministry of Justice—which stand as admitted and unrebutted material facts under 28 U.S.C. § 1608(e) due to the Defendant's default—the Plaintiff respectfully requests that this Honorable Court enter an Order denying the Republic of Croatia any claim to sovereign immunity, and retain absolute jurisdiction to enter a final judgment for the fixed liquidated debt in the amount of $2,222,151,876.24 USD (two billion, two hundred twenty-two million, one hundred fifty-one thousand, eight hundred seventy-six dollars and twenty-four cents).

On date 20.05.2026., Eggenburg, Austria

Plaintiff Pro se,

Signature

SignatureD.I. Ljiljana Segedin