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Case No. VENEZUELA-2018-357535-1
Kara Bombach
Greenberg Traurig, LLP
2101 L Street, N.W.
Washington, DC 20037
Dear Ms. Bombach:
This responds to your application dated October 18, 2018 to the Office of Foreign Assets Control (OFAC) (the “Application”), on behalf of Greenberg Traurig LLP, and your clients Rafael Alfredo Sarria Diaz, 11420 Corp., Noor Plantation Investments LLC, and SAI Advisors Inc., requesting authorization to take all actions ordinarily incident to negotiation and entry into settlement agreement(s) related to civil case no.:8:09-CV-2308-RAL-MAP in the Middle District of Florida (Tampa Division) and civil case no. 18-13696 in the 11th Circuit Court of Appeals.
As you know, Executive Order 13692 of March 8, 2015, “Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Venezuela” (“E.O. 13692”), as administered pursuant to the Venezuela...
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1) Negotiations to Settle U.S.-based Lawsuits Focusing on Blocked Property
The context of this license and cover letter is an attachment proceeding in which a U.S. person law firm represents certain persons—including blocked U.S.-incorporated entities—that were blocked pursuant to EO 13692 whose U.S.-based blocked property was the subject of a Terrorism Risk Insurance Act (TRIA)-based writ of execution. The blocked property was scheduled to be sold pursuant to the writ of execution soon after the issuance of the license.
As of the time of the issuance of the license, the VSR contained the standard legal services GL (591.506). The GL authorized the representation of the blocked persons in the attachment proceeding, but contained the standard carveout excluding the “[e]ntry into a settlement agreement or the enforcement of any lien, judgment, arbitral award, decree, or...