Summary

This is an independent action brought by Plaintiff Republic of Kazakhstan ("the Republic" or "Plaintiff"), through its undersigned counsel, pursuant to Federal Rule of Civil Procedure 60(d)(1) for relief from the judgment (the "Judgment") obtained by Defendants Anatolie Stati, Gabriel Stati, Ascom Group, S.A. ("Ascom"), and Terra Raf Trans Traiding Ltd ("Terra Raf") (collectively, the "Statis" or "Defendants") in Civil Action No. 1:14-cv-1638-ABJ (D.D.C.). In addition, the Republic seeks to set aside the Judgment pursuant to Federal Rule of Civil Procedure 60(d)(3) for fraud on the Court. In support thereof, the Republic alleges as follows: ...