Summary

Petitioner Unicon Limited ("Unicon" or "Petitioner"), by and through undersigned counsel, hereby files its Petition and states:

NATURE OF THE ACTION

1. Arising from a World Bank funded project to provide supervision, quality assurance, and technical support for the construction of a gas pipeline from Sheberghan to Mazar- e-Sharif, Petitioner Unicon brings this action to confirm an arbitral award dated February 17, 2023 (the "Award") in the amount of US$1,313,138.11 plus interest, against the Ministry of Energy and Water of the Islamic Republic of Afghanistan ("Respondent"). The two parties are collectively referred to as "the Parties". The Award was rendered in Petitioner Unicon's favor at the conclusion of arbitral proceedings conducted in Dubai, United Arab Emirates, pursuant to the United Nations Commission on International Trade Law ("UNCITRAL") Arbitration Rules.

2. To date, Respondent has paid no portion of the Award.

3. Pursuant to the Convention on the Recognition and Enforcement of Foreign Arbitral Awards, June 10, 1958 (the "New York Convention"), as implemented at 9 U.S.C. §§ 201-208, Unicon petitions the Court to (i) enter an order enforcing the Award in the same manner as a final judgment issued by a court in the United States; (ii) enter judgment in Unicon's favor and against Respondent in the amount of the Award, with interest and costs as provided therein, as set out in the Prayer below; and (iii) grant such other and further relief as the Court deems just and proper.

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