Summary

Petition to Recognize and Confirm Arbitral Award

Petitioner Álya Construtora S.A. ("Petitioner"), by and through undersigned counsel, hereby petitions this Court for entry of an order and judgment pursuant to 9 U.S.C. § 207 (i) recognizing and confirming the partial final arbitral award dated July 25, 2023 (the "Award") in the arbitration between Petitioner, and PDVSA Petróleo S.A. and Petróleos de Venezuela S.A. (collectively, "PDVSA" or "Respondents") captioned ÁLYA CONSTRUTORA S.A. (formerly, CONSTRUTORA QUEIROZ GALVÃO S.A.) v. PDVSA PETROLEO S.A. and PETROLEOS DE VENEZUELA S.A. (ICC Case 24306/JPA/AJP) (the "Arbitration"); (ii) entering judgment in Petitioner's favor against PDVSA in the amount of $52,319,825.60-- $51,869,218.00 as principal (the "Principal") plus $450,607.61 for the costs of the Arbitration--plus interests on the Principal amount of $51,869,218.00 at a 6% annual rate and interest on the cost of Arbitration in the amount of $450,607.61 from the date of notification of the Award to be calculated up to the date of payment, the amount owed in interest on the Principal amount of $51,869,218.00 as of April 18, 2024 being $1,918,450.53; and (iii) awarding Petitioner such other and further relief as the Court deems just and proper.

TDM: Alya Construtora SA (Construtora Queiroz Galvão SA) v PDVSA Petroleo SA and Petroleos de Venezuela SA - Laudo Final - Final Award - ICC Arbitration 24306-JPA-AJP - 25 July 2023