Summary

Petitioner Société Nationale d'Opérations Pétrolières de la Côte d'Ivoire ("Petroci"), by and through its attorneys, alleges as follows in support of its petition (the "Petition") for entry of an order recognizing and enforcing, pursuant to the United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards, 21 U.S.T. 2517 (the "New York Convention" or the "Convention") and Chapter 2 of the Federal Arbitration Act, 9 U.S.C. § 201 et seq. (the "FAA"), the Final Award dated March 24, 2021 (the "Award"), as amended by the Addendum to the Final Award dated June 21, 2021 (the "Addendum"), in the arbitration (the "Arbitration") between Petroci and Respondent MRS Holdings Ltd ("MRSH"). The Arbitration was captioned Société Nationale d'Opérations Pétrolières de la Côte d'Ivoire (Ivory Coast) v. MRS Holdings Ltd (Nigeria), ICC Case No. 23221/DDA and was conducted in Paris, France, under the Rules of Arbitration of the International Court of Arbitration (the "ICC Court") of the International Chamber of Commerce (the "ICC Rules"). Petroci respectfully seeks an order (1) entering judgment in favor of Petroci and against MRSH; (2) awarding Petroci post-judgment interest at the applicable statutory rate; and (3) awarding Petroci such further relief as the Court deems just and proper.