EXHIBIT A 

Case 1:21-cv-23103-BB Document 196-1 Entered on FLSD Docket 05/15/2023 Page 1 of 4
1

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] 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 (“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 FINAL JUDGMENT in favor of Plaintiff 

against Andrade Cedeno as follows:

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

28 U.S.C. § 2201:

a. Plaintiff established a breach of fiduciary duty claim against Andrade Cedeno. As the 

National Treasurer of Venezuela, Andrade Cedeno owed a fiduciary duty to Venezuela 

to oversee the management of sovereign funds deposited in accounts of the Venezuelan 

National Treasury. He breached his fiduciary duty to Venezuela by accepting bribes 

from regime insiders that were derived from sovereign funds in exchange for allowing 

Case 1:21-cv-23103-BB Document 196-1 Entered on FLSD Docket 05/15/2023 Page 2 of 4
2

the insiders to misappropriate Venezuelan funds with impunity. Andrade Cedeno’s 

breach of duty directly and proximately caused damages to Venezuela. 

b. Plaintiff established an unjust enrichment claim against Andrade Cedeno. Venezuela 

conferred a benefit to Andrade Cedeno by appointing him as the National Treasurer, 

which charged him with the fiduciary responsibility to administer and protect sovereign 

funds deposited in accounts of the Oficina Nacional del Tesoro (“ONT”).

1 Andrade 

Cedeno knowingly and voluntarily accepted the benefit and served as the National 

Treasurer, gaining access to ONT accounts. Andrade Cedeno utilized his official 

position for his own pecuniary gain by accepting and retaining bribes from regime 

insiders that were derived from sovereign funds at the expense of Venezuela. It would 

be inequitable and unjust to allow Andrade Cedeno to retain the misappropriated 

Venezuelan funds (or the properties that were purchased with those funds).

c. Plaintiff established that Andrade Cedeno’s conduct satisfies the elements necessary 

for the imposition of a constructive trust. Andrade Cedeno promised to Venezuela that 

he would manage the ONT, which charged him with the fiduciary responsibility to 

administer and protect sovereign funds deposited in ONT accounts. In reliance of his

express promise, Venezuela granted Andrade Cedeno access to sovereign funds 

deposited in ONT accounts. Andrade Cedeno and Venezuela were in a confidential 

relationship since he acted as an official of the Venezuelan government and a 

department and agency of the Venezuelan government. Andrade Cedeno breached his 

express promise by accepting bribes from regime insiders and allowing them to 

1 The ONT is the Venezuelan National Treasury. 

Case 1:21-cv-23103-BB Document 196-1 Entered on FLSD Docket 05/15/2023 Page 3 of 4
3

misappropriate sovereign funds deposited in ONT accounts. Andrade Cedeno was 

unjustly enriched at the expense of Venezuela. 

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

Copies provided to: 

Counsel of Record

Case 1:21-cv-23103-BB Document 196-1 Entered on FLSD Docket 05/15/2023 Page 4 of 4