EXHIBIT A 

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 1:21-cv-23103-BLOOM/OTAZO-REYES

CASA EXPRESS CORP, as Trustee of

CASA EXPRESS TRUST,

Judgment Creditor,

v.

BOLIVARIAN REPUBLIC OF 

VENEZUELA,

Judgment Debtor.

/

[PROPOSED] PARTIAL DEFAULT FINAL JUDGMENT

THIS CAUSE is before the Court upon Plaintiff and Judgment Creditor Casa Express 

Corp’s, as Trustee of Casa Express Trust (“Plaintiff”), Motion for Default Final Judgment Against 

Impleaded Defendant Alejandro Andrade Cedeno and the Bolivarian Republic of Venezuela 

(“Venezuela”), ECF No. [149], filed on January 30, 2023. Pursuant to Federal Rule of Civil 

Procedure 58, the Court enters PARTIAL FINAL JUDGMENT in favor of Plaintiff against

Venezuela as follows:

1. The following declaratory judgment is entered in favor of the Plaintiff pursuant to 

28 U.S.C. § 2201:

a. Plaintiff established that the fiscal agency agreements (“FAAs”), which govern the 

debt securities that form the basis of Plaintiff’s underlying judgment against Venezuela, contain a 

provision entitled “Waiver of Immunity” that Venezuela expressly adopted in the FAAs. It 

provides:

To the extent that the Issuer [Venezuela] or any of its revenues, assets or properties 

shall be entitled . . . with respect to any suit, action or proceeding at any time 

brought solely for the purpose of enforcing or executing any Related Judgment in 

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any jurisdiction in which any Specified Court or Other Court is located, to any 

immunity from suit, from the jurisdiction of any such court, from attachment prior 

to judgment, from attachment in aid of execution of judgment, from execution of a 

judgment or from any other legal or judicial process or remedy, and to the extent 

that in any such jurisdiction there shall be attributed such an immunity, the Issuer 

irrevocably agrees not to claim and irrevocably waives such immunity to the fullest 

extent permitted by the laws of such jurisdiction (including, without limitation, the 

Foreign Sovereign Immunities Act of 1976 of the United States) . . . .

ECF No. [60-24] § 14(d) (emphasis added); ECF No. [60-25] § 14(d) (same). 

b. Plaintiff established that the District Court for the Southern District of New York 

interpreted the “Waiver of Immunity” provisions in the underlying action against Venezuela. The 

District Court for the Southern District of New York ruled that Venezuela “expressly waived its 

sovereign immunity” in the FAAs. Casa Express Corp. as Tr. of Casa Express Tr. v. Bolivarian 

Republic of Venezuela, 492 F. Supp. 3d 222, 229 (S.D.N.Y. 2020) (“In the fiscal agency 

agreements governing the bonds at issue in these actions, Defendant expressly waived its sovereign 

immunity”) (citing FAAs at § 14). 

c. Plaintiff established that the eight real properties1 that are the subject of this 

proceeding are located in the United States. 

d. The Court reserves jurisdiction to award any attorneys’ fees and costs that may 

accrue in this proceeding to Plaintiff against Venezuela after a final disposition on the merits of 

the case. Fla. Stat. § 56.29(8).

ORDERED AND ADJUDGED this _____ day of ______________, 2023, in Chambers 

at Miami, Florida.

UNITED STATES DISTRICT JUDGE

1 See ECF No. [60] at Statement of Facts ¶ 29 (listing the eight real properties). 

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Copies provided to: 

Counsel of Record

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