Summary

By this action, Petitioners by and through its undersigned attorneys, hereby bring this plenary action under Section 207 of the Federal Arbitration Act (the "FAA"), 9 U.S.C. § 207, and the United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards of June 10, 1958, 21 U.S.T. 2517, 330, U.N.T.S. 38 (the "New York Convention" or the "Convention") and its implementing legislation under Chapter 2 of the FAA, 9 U.S.C. § 201 et seq., for an order and judgment confirming, recognizing, and enforcing the final award dated September 9, 2022 (the "SCC Final Award") in SCC Arbitration V2018/039, Gardabani Holdings B.V., Inter RAO UES PJSC, and Telasi JSC v. Georgia, (the "SCC Arbitration"), conducted with legal seat in Stockholm, Sweden,1 pursuant to the 2010 Arbitration Rules of the Arbitration Institute of the Stockholm Chamber of Commerce (the "SCC"). In addition, Petitioners seek an order enforcing the pecuniary obligations imposed by the SCC Final Award by an entry of judgment in Petitioners' favor and against Georgia in the full amount of the SCC Final Award, including interest and costs as provided therein and with further interest to accrue pursuant to the SCC Final Award until the date of payment in full, in addition to the costs of this proceeding.