Summary

Introduction

1. The Claimant, Addax Energy SA ("Addax"), claims US$2,761,408.78 from the Defendant, Petro Trade Inc. ("PT") together with contractual interest in respect of four unpaid invoices for petroleum products delivered to PT in Liberia, namely:

(1) One invoice under a gasoil sales contract dated 25 August 2016 ("the Gasoil Contract") for the balance due in respect of gasoil held at China Union since 2016, totalling US$532,506.86 [G/3381]; and

(2) Three invoices under the Term Agreement dated 3 January 2018, and put into writing on 20 November 2018 ("the Term Agreement"), totalling US$2,228,901.92 which fell due for payment on 4 December 2020.

2. Addax is a Swiss company that trades a variety of oil products (refined and unrefined) and PT, in the words of its CEO Marwan Hindawi, is "one of the main importers of petroleum and derivative products into the Liberian market. It also owns and operates a number of gas stations over Liberia" (first witness statement, para. 8). The petroleum products that give rise to the claim here are mogas (motor gasoline) and gasoil (diesel fuel).

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