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UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

PLAINTIFF'S EMERGENCY MOTION FOR A TEMPORARY RESTRAINING ORDER
AND PRELIMINARY INJUNCTION

Plaintiff Ljiljana Segedin, appearing pro se, respectfully moves this Court pursuant to Federal Rule of Civil Procedure 65(b) and 18 U.S.C. § 1964 for an Emergency Temporary Restraining Order (TRO) and Preliminary Injunction against the Defendant, the Republic of Croatia.

In support of this Motion, Plaintiff states as follows:

Grounds for Emergency Relief: In direct retaliation for the Plaintiff's multi-billion-dollar federal action and her invocation of international arbitration, the Defendant's state apparatus is actively exerting aggressive legal and administrative pressure on the authorities of the Republic of Austria to force an involuntary cross-border extraction and surrender of the Plaintiff. To engineer this international pressure, the Defendant has systematically manipulated trans-European mechanisms by falsifying obsolete domestic addresses dating back more than ten years. These

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bad-faith actions constitute severe Obstruction of Justice, explicitly calculated to forcefully interfere with the Plaintiff's physical security and permanently block her access to this Court.

Cease and Desist Order Requested: Plaintiff respectfully requests an immediate Order commanding the Defendant, including its Ministry of Justice, State Attorney's Office (DORH), and Ministry of Interior, to cease and desist from initiating, maintaining, or advancing any administrative or judicial demands for the forced surrender, relocation, or passport cancellation of the Plaintiff and her daughter, Nadja Thea Segedin Schmitt.

Formal Notice to the Republic of Austria: To guarantee the safety of the Plaintiffs and preserve the integrity of these federal proceedings, Plaintiff moves this Court to formally transmit a certified copy of this Protective Order to the Federal Ministry of Justice and the Federal Ministry of the Interior of the Republic of Austria. This notice will formally advise the Austrian authorities under principles of international comity that the Plaintiffs are under the active legal protection of the United States Federal Judiciary, thereby estopping the Defendant from utilizing outdated domestic data to apply pressure for a cross-border surrender.

Conclusion: Plaintiff has a high probability of success on the merits based on uncontested notarized debt admissions and has no other adequate remedy at law to guarantee her personal liberty, freedom of movement, and physical security.

WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant this Emergency Motion without delay.

Dated: June 16, 2026

Respectfully submitted,

Signature

Ljiljana Segedin. Plaintiff Pro Se

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