Summary

Petitioner, UNION GLORY LIMITED ("Petitioner" or "Owner"), by and through its undersigned attorneys, Clyde & Co US LLP, alleges as follows in support of its Petition for entry of an Order, pursuant to 9 U.S.C. § 207 and 9 U.S.C. § 9, (a) confirming and recognizing the Arbitral Award dated April 14, 2023 ("First Partial Award"), the Addendum thereto dated May 31, 2023 ("Addendum to the First Partial Award"); and the Second Partial Award in Relation to Costs dated June 24, 2024 ("Costs Award"), issued by sole Arbitrator, Mr. Sean O'Sullivan, KC (collectively, the "Awards"), under the United Kingdom Arbitration Act 1996, in the matter of the arbitration styled, "Union Glory Limited (Claimant) -and- PDVSA PETROLEO S.A. (Respondent), MT "ST JAMES" C/P dd. 13.07.17" (the "Arbitration"); (b) registering the Judgment entered on the First Partial Award and Addendum to the First Partial Award by the U.S. District Court for the District of Delaware dated January 31, 2024 (the "Delaware Judgment")4, pursuant to 28 U.S.C. § 1963; (c) entering judgment in favor of Petitioner against PDVSA Petroleo S.A. ("Petroleo") in the amount of the First Partial Award, the Addendum to the First Partial Award and the Costs Award, with interest and costs as provided therein, plus the costs of this proceeding, pursuant to 9 U.S.C. § 13; and (d) awarding Petitioner such other and further relief as the Court deems just and proper: