just a squirrel trying to get a nut
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if he plays his cards right(everything to lose) he just might get to keep the violin(but that's it the rest goes to FRAZ)
and I would imagine it would be a tune he would play often
the judge would never allow it to proceed this far unless there
was compelling Prima Face evidence ....
so far the billionaires response is akin
to child like tantrum (Red Handed IMO)
Yes that is the one
//Re-Cap// Kozyak Tropin & Throckmorton based the $792 million damages estimate on Banco Nuñez’s $7.8 million worth at the time, plus 6% annual interest and triple damages under the Helms-Burton Act, a 1996 federal law.
https://investorshub.advfn.com/boards/read_msg.aspx?message_id=150333080
Admittedly I like the way they do the math the above referenced case has no bearing on FRAZ other than for Calculus of how the Helms Burton
is applied to value
Kozyak Tropin & Throckmorton is the same teem now handling Francisco Industries INC. ( AKA Francisco Sugar Company )
So What's $53.4M million worth at the time, plus 6% annual interest and triple damage ...? is it 9 or 10 figures ...
Go FRAZ
I think we have discussed possibility that the Chain as a Technology is were the 'real value' is and not as a currency and that 'value backed' tokens might be where the gravy is? just saying
TSLA WKEY IBM $BTC
GO FRAZ
PCHM
REV $9.9M Q2 2021 UP Rev $3.2 per-share 1yr-trailing up from $3.05
Revenue Q1 2020 reported in Feb 2021
9,4M
REVENUE Q4 2020
8.84M
REVENUE Q3 2020
8.48M
REVENUE Q2 2020
8.13M
TRCK BLOZF PCHM PMD
FRAZ
came across this article https://floridianpress.com/2021/05/florida-crystals-dismisses-false-allegation-that-they-violated-cuban-embargo/
the article didn't say much(that I hadn't already read elsewhere) till I read the comments section that was the best part LOL
have you ran the numbers how do you calculate the grand total as out lined in the Helms Burton act title III private right of action
what 9/10 digit sum do you arrive at
strictly for entertainment purposes only
I think anyone reading would understand actual results may vary
TRCK trying for a new 52week high despite market rout
GO PCHM
Go FRAZ
Total Revenue up 21%, Record Quarterly Operating Income, Adjusted EBITDA up 77%, Continued Net Loss Turnaround
PR Newswire
NAPERVILLE, Ill., May 11, 2021
NAPERVILLE, Ill., May 11, 2021 /PRNewswire/ -- Track Group, Inc. (OTCQX: TRCK), a global leader in offender tracking and monitoring services, today announced financial results for its second quarter ended March 31, 2021 ("Q2 FY21"). In Q2 FY21, the Company posted (i) total revenue of $9.9 million, an increase of approximately 21% over total revenue for the same period last year ("Q2 FY20"); (ii) operating income of $1.7 million, representing an increase of 601% compared to Q2 FY20 operating income of $0.2M; (iii) adjusted EBITDA of $2.9 million in Q2 FY21, up 77% compared to $1.6 million for Q2 FY20; and (iv) net income attributable to common shareholders of $2.2M in Q2 FY21 compared to a net loss of $1.7 million in Q2 FY20.
"Again, we were able to continue the Company's strong performance over the past twelve months with a record performance for the quarter ended March 31, 2021. So far, we have managed to successfully navigate the challenges brought on by the Coronavirus by working closely with our customers and partners. We are excited about the future and the continued evolution of our technologies to support our customers' programs in the years ahead." said Derek Cassell, Track Group's CEO.
FINANCIAL HIGHLIGHTS
Strong quarterly total revenue of $9.9 million in Q2 FY21, up 21% compared to Q2 FY20 total revenue of $8.1 million as the significant increase in monitoring revenue of approximately 22% was offset by a nominal decline in product sales. Revenue for the 6 months ended March 31, 2021 ("6M FY21") of $19.3 million was up approximately 16% compared to revenue of $16.6 million for the 6 months ended March 31, 2020 ("6M FY20").
Gross profit of $5.4 million in Q2 FY21 was up 23% compared to Q2 FY20 gross profit of $4.4 million. Gross profit for the 6M FY21 was $10.6 million, or up 17% compared to gross profit of $9.1 million for 6M FY20.
Total operating expense for Q2 FY21 of $3.8 million was down 10% versus Q2 FY20's total operating expense of $4.2 million. The decline in quarterly operating expense when combined with the favorable increase in gross profit led to operating income in Q2 FY21 of $1.7 million compared to operating income of $0.2 million for Q2 FY20, representing an improvement of 601%. Similarly, for 6M FY21, operating income was $3.1 million compared to operating income of $0.5 million, representing an increase of 473%.
Adjusted EBITDA for the Q2 FY21 was $2.9 million, an increase of nearly 77%, compared to $1.6 million for Q2 FY20. Adjusted EBITDA in Q2 FY21 as a percentage of revenue also increased to 29.1%, compared to 19.9% for Q2 FY20. Adjusted EBITDA for 6M FY21 was $5.5 million compared to the Adjusted EBITDA for 6M FY20 of $3.4 million, representing an improvement of approximately 63%. Similarly, Adjusted EBITDA for the 6M FY21 as a percentage of revenue also increased to 28.7%, compared to 20.5% for the 6M FY20.
The cash balance of $6.7 million at March 31, 2021 was down only 1% compared to $6.8 million at September 30, 2020 reflecting significant capital investments made by the Company of approximately $2.7 million in the 6M FY21 to build additional monitoring devices and software to accommodate increased customer demand. Capital investments for the 6M FY21 were up 78% compared to the same period last year.
Net income attributable to common shareholders in Q2 FY21 was $2.2 million compared to a net loss of $1.7 million in Q2 FY20, a change principally attributable to the Company's strong operating performance and the increase in other Income. Net income attributable to common shareholders for the 6M FY21 was $3.5 million, up significantly compared to the net loss of nearly $2.0 million for the 6M FY20.
https://www.otcmarkets.com/stock/TRCK/news/Track-Group-Reports-2nd-Quarter-Fiscal-2021-Financial-Results?id=302434
TRCk PCHM BLOZF PMD
flash back Feb 4, 2014 & September 19, 2016
Sugar Baron Alfonso Fanjul Open to Doing Business in Cuba; Diaz-Balart and Rubio Rip Back https://www.miaminewtimes.com/news/sugar-baron-alfonso-fanjul-open-to-doing-business-in-cuba-diaz-balart-and-rubio-rip-back-6554150
Have a Great day all!!
very eventful day Sweet' the saga continues
more to follow stay tuned
bottom of the 1st
this is clearly someone trying to take advantage of the under informed
the market cap $3.6M is so low and SS 574K is very tiny and the size of the claim is ginormous $B double digits is a no brainer IMO!
https://investorshub.advfn.com/boards/read_msg.aspx?message_id=163729039
Go FRAZ
PCHM
yes there are 3 case numbers the one that's moving forward 1:21-cv-21679
Go FRAZ GO GO GO GOOOOOOOOOOOOOOOOOOOOOOOOOOO
this has not hit the newswire yet the Bloomberger of WSJ may very well pick up on this story
it had to be two tens the first came with steep learning curve
the second is with experience TY
having problems with my calculator can't figure out how much
$53.4 million x3 trebling and associated interest for 60 years at 6%
works out to boy there is a lot of digits and only 547,484K shares
GO FRAZ
in all my working on other things I failed to mention there was new form
144 on 05/04/2021 for PCHM same person again that's some sweet ROI
Go FRAZ
92 page complaint FRAZcisco VS ASR Group International INC.
https://static1.squarespace.com/static/563a4585e4b00d0211e8dd7e/t/609a8b34ba4a615b8fde3301/1620740922302/merged_95440_-1-1620731595.pdf
9th Largest Certified Claimant Sues Billionaire Fanjul Family-Controlled Company For Trafficking In Sugar From Cuba To UK. This Lawsuit Could Be A Brawl.
May 11, 2021
On 2 May 2021, Summit, New Jersey-based Francisco Sugar Company (OTCPK: FRAZ) is the 9th largest Certified Claimant (US$53,389,438.37) filed a Libertad Act Title III lawsuit against West Palm Beach, Florida-based ASR Group International, Inc. (2019 revenues approximately US$500 million) relating to a shipment of sugar from the Republic of Cuba to the United Kingdom. ASR Group International is a part of the commercial holdings of the Fanjul brothers (estimated net worth US$8.2 billion)- Alfonso "Alfy" Fanjul Jr., José "Pepe" Fanjul, Alexander Fanjul, and Andres Fanjul.
The Trump Administration (2021-2021) on 2 May 2019 made operational Title III of the Cuban Liberty and Democratic Solidarity Act of 1996 (known as “Libertad Act”). Title III authorizes lawsuits in United States District Courts against companies and individuals who are using a certified claim or non-certified claim where the owner of the certified claim or non-certified claim has not received compensation from the Republic of Cuba or from a third-party who is using (“trafficking”) the asset.
Seeking Alpha (December 2016): “Francisco Industries (OTCPK:FRAZ). You thought there is no way to invest in Cuba? Think again. FRAZ allows you to buy a part of a Cuban land claim by what appears to be a business that used to run a sugar mill on the island until the Cuban revolution, during which many US business had their assets seized by the new government. Some of them launched a legal claim to get compensation, and FRAZ did the same. You can see the biggest verified claims in this Washington Post article, and the company is one of them.”
ASR Group International brands include Domino Sugar, C&H, Repath, Tate & Lyle, Sidul, SRB, Belize, Sugar, Ingenio San Nicolas, and Tellus. “Florida Crystals Corporation and Sugar Cane Growers Cooperative of Florida, two family-owned sugarcane farmers and millers, came together more than 20 years ago to form a strategic partnership to begin large-scale refining of their raw sugar. The collaboration laid the groundwork for what would quickly become the world's most successful and innovative cane sugar company: ASR Group. Florida Crystals Corporation was founded by the Fanjul family in South Florida, in the United States in 1960 as a sugarcane farming and milling company. Its first harvest of 4,000 acres in Palm Beach County yielded 10,000 tons of raw sugar. The family has a long tradition in sugarcane, dating back to 1850 in Cuba, and they understood the key to success meant expanding their land holdings in order to secure a supply of sugarcane for their mills. Today, the company farms more than 190,000 acres in Florida where it owns two sugar mills, a sugar refinery, a packaging and distribution center and a rice mill.” The company has substantial non-certified non-filed claims against the Republic of Cuba.
North American Congress on Latin America (February 2014): “The Washington Post made a splash Sunday with a long feature on Palm Beach, FL-based sugar magnate and Cuban exile Alfonso “Alfy” Fanjul. The headline: “Sugar tycoon...now open to investing in Cuba under the right circumstances.” The article brings to public light what has been an open secret for some time now: over the last few years, Fanjul- a once stalwart funder of anti-Castro causes and organizations like the Cuban American National Foundation and the U.S.-Cuba Democracy PAC (the pro-embargo lobby)- has travelled to Cuba at least twice [April 2012 and February 2013] as part of delegations organized by the Brookings Institution. On the island, he has met with Cuba’s Foreign Minister and apparently toured under-producing state-owned sugar mills with an eye to future investments.”
Francisco Industries, Inc. v. ASR Group International, Inc. [2:21-cv-14188]
Kozyak Tropin & Throckmorton PA (plaintiff)
Complaint Not Available (filed 5/2/21)
Francisco Industries, Inc. v. ASR Group International, Inc. [2:21-cv-14189]
Kozyak Tropin & Throckmorton PA (plaintiff)
Link To 92-Page Complaint (5/2/21)
Francisco Industries, Inc. v. ASR Group International, Inc. [1:21-cv-21679]
Kozyak Tropin & Throckmorton PA (plaintiff)
Link To 92-Page Complaint (5/2/21)
Excerpts:
ASR also had actual knowledge of Cuba’s confiscation of Francisco. ASR executive José F. Fanjul, Jr.’s father has owned 3,989 shares of Francisco for many years. José F. Fanjul, Jr.’s grandfather, Alfonso Fanjul, worked for Francisco prior to confiscation and 6 Through its wholly owned subsidiary Compañia Maritima Guayabal, S.A., Francisco was awarded the Port of Guayabal concession pursuant to Fulgencio Batista’s Presidential Decree No. 3,749, dated November 10, 1955. That Decree was published in La Gaceta de La Habana on November 15, 1955.
ASR violated Helms-Burton by purchasing Francisco-grown cane sugar and exporting that sugar from the Port of Guayabal to ASR’s refinery in London.
As just one example, on or about July 27, 2016, ASR knowingly and intentionally purchased a shipment of cane sugar that all presently known facts suggest derived from Francisco’s confiscated assets north of Guayabal. Francisco’s arable land, as well as sugar produced by that land, constitutes confiscated property as defined by the Helms-Burton Act.
AZCUBA, an alter ego of the Cuban government, maintains a monopoly on all aspects of the sugar business in Cuba. AZCUBA is as trafficker according to Helms-Burton because it “possesses”, “manages”, “uses” or “holds an interest in” Francisco’s sugar growing land, and it engaged in “a commercial activity using or otherwise benefitting from confiscated property” when it sold Francisco-grown sugar. The Francisco-grown sugar was shipped from the Port of Guayabal on July 27, 2016, and delivered to ASR’s London refinery on August 16, 2016.
h ttps://www.cubatrade.org/blog/2021/5/11/a2ii6657qt774f2e6dsr8qwgz6ehg8
I don't think we came this far not to go all the way IMO
Go FRAZ
looks good I see nothing adverse it's on
just read the May 6 order this is going forward
the May 6 order is about procedure
To efficiently, expeditiously, and economically resolve this
dispute, it is ORDERED as follows:
then it goes on to sets the stage rules of engagement rules of engagement and conduct that the judge would like
at this point ASR Group has might not even have been served
FRAZ FRAZ FRAZ 574K O/S if you haven't already now is a great time >>> https://investorshub.advfn.com/boards/read_msg.aspx?message_id=162664753
Game on! these are our guys GO FRAZcisco
Evan Stroman
Kozyak Tropin And Throckmorton
Javier Asis Lopez
Kozyak Tropin & Throckmorton PA
Jorge Luis Piedra
https://kttlaw.com/
could not sleep BANG! worth the wake up in the middle of the night!
an Idea who's time has finally come oh ya!
I would imagine ASR is the lowest hanging fruit there has to be others
https://en.wikipedia.org/wiki/American_Sugar_Refining
transactions shipping resale and the other assets that I have mentioned as well
ARISE FRAZ AWAKEN the giant
Increasable PCHM $VOLUME unlike anything ever seen before
Go FRAZ
someone just invested $5M into it I don't think they want to lose...
Institutional investors ?? that is for sure not retail IMO
Go PCHM
Steptoe & Johnson LLP handling 3 Certified Claim's 'Going for the Gusto'
they don't get paid unless they win ...!
I don't think they do charity work in these kinds of lawsuits.
Good news( Payday) for them, is good news for FRAZcisco (a Time and a Place for everything)
EXXON XOM
https://investorshub.advfn.com/boards/read_msg.aspx?message_id=163377108
Steptoe & Johnson LLP
TEXAS RANCH
https://www.pacermonitor.com/public/case/38743238/KING_RANCH,_INC_v_EMPRESA_AGROPECUARIA_NUEVITAS_et_al
Steptoe & Johnson LLP
Castanedo Escalon et al v. Trafigura Trading LLC et al
https://www.pacermonitor.com/public/case/38659412/Castanedo_Escalon_et_al_v_Trafigura_Trading_LLC_et_al
Steptoe & Johnson LLP
Steptoe & Johnson LLP New Ruling Serves as Guidepost for Future Claims Involving Cuban Agencies and Instrumentalities
https://investorshub.advfn.com/boards/read_msg.aspx?message_id=163633941
Steptoe & Johnson LLP now handling 3 Certified Claim cases they don't get paid unless they win! I don't think they do charity work in these kinds of lawsuits good news( Payday) for them is good news for FRAZcisco (a Time and a Place for everything)
EXXON XOM
https://investorshub.advfn.com/boards/read_msg.aspx?message_id=163377108
TEXAS RANCH
https://www.pacermonitor.com/public/case/38743238/KING_RANCH,_INC_v_EMPRESA_AGROPECUARIA_NUEVITAS_et_al
Castanedo Escalon et al v. Trafigura Trading LLC et al
https://www.pacermonitor.com/public/case/38659412/Castanedo_Escalon_et_al_v_Trafigura_Trading_LLC_et_al
Steptoe & Johnson LLP New Ruling Serves as Guidepost for Future Claims Involving Cuban Agencies and Instrumentalities
https://investorshub.advfn.com/boards/read_msg.aspx?message_id=163633941
Steptoe & Johnson LLP now handling 3 Certified Claim cases they don't get paid unless they win! I don't think they do charity work in these kinds of lawsuits good news( Payday) for them is good news for FRAZcisco (a Time and a Place for everything)
EXXON XOM
https://investorshub.advfn.com/boards/read_msg.aspx?message_id=163377108
TEXAS RANCH
https://www.pacermonitor.com/public/case/38743238/KING_RANCH,_INC_v_EMPRESA_AGROPECUARIA_NUEVITAS_et_al
Castanedo Escalon et al v. Trafigura Trading LLC et al
https://www.pacermonitor.com/public/case/38659412/Castanedo_Escalon_et_al_v_Trafigura_Trading_LLC_et_al
Steptoe & Johnson LLP New Ruling Serves as Guidepost for Future Claims Involving Cuban Agencies and Instrumentalities
https://investorshub.advfn.com/boards/read_msg.aspx?message_id=163633941
AAL, ABNB, AMZN, BUD, CAT, CCL, COHN, CVX, FDX, FRAZ, GOOG, JBLU, LUV, NCLH, NFLX, NSRGY, PCHM, PTE, PURA, RCL, RUTH, SAVE, SHERF, TECK, TMUS, TRVG, UAL, XOM SCGLF BNPQF MA V
I almost certain it was you who mentioned the GOLD and Silver
and I could say with most certainty they all did or doing or going to be doing well
Enjoy the week end ...
Go FRAZ PCHM Gold & Silver
Wayne is the man ...
https://www.marketscreener.com/quote/stock/EXXON-MOBIL-CORPORATION-4822/news/Exxon-Mobil-nbsp-New-Ruling-Serves-As-Guidepost-For-Future-Claims-Involving-Cuban-Agencies-And-Ins-33176857/
Exxon Mobil : New Ruling Serves As Guidepost For Future Claims Involving Cuban Agencies And Instrumentalities 05/06/2021 | 06:11am EDT
FRAZ https://investorshub.advfn.com/boards/read_msg.aspx?message_id=162664753
no there has not! that's the headline right there 'no Selling no one is departing in any significant way'
also there may be lots of liquidity events coming up for non compliant?
as for the compliant might be extra good cause most have been in hiding for so long debts may have expired not collectable so the values of the Shell or companies just for the listing might be worth multiples
I think it would be safe for my most important one incorporated in NJ 1899
NJ / NY Statues of limits after 60years nothing should exist
State Written contracts Promissory notes Open-ended accounts Judgments
New Jersey 6 years 6 years 6 years 20years
New York 6 years 6 years 6 years 20years
King Ranch Of Texas, 67th Largest Certified Claimant
Case 1:21-cv-00594 https://www.pacermonitor.com/public/case/38743238/KING_RANCH,_INC_v_EMPRESA_AGROPECUARIA_NUEVITAS_et_al
they too are being represented by same as Exxon
Steptoe & Johnson LLP
1330 Connecticut Avenue, NW
Washington, DC 20036
READ THIS HERE >>> LINK To Complaint whole thing very good read
https://static1.squarespace.com/static/563a4585e4b00d0211e8dd7e/t/6093e8dab30c6f27fca0fd65/1620306139500/merged_77320_-1-1620300797.pdf
Quote:
56. King Ranch has never settled the outstanding certified claim or received any payment from any entity with respect to the principal or interest due on its certified claim.
The Cuban Liberty and Democratic Solidarity (LIBERTAD) Act of 1996
57. Section 302 of the Act provides the following civil remedy:
SEC 302: (a) Civil Remedy.—
(
1) Liability for trafficking.--(A) Except as otherwise provided in this section, any person that, after the end of the 3-month period beginning on the effective date of this title, traffics in property which was confiscated by the Cuban Government on or after January 1, 1959, shall be liable to any United States national who owns the claim to such property for money damages . . . 22 U.S.C. § 6082(a)(1).
58. Section 302 implements a key purpose of the Act, which is to permit U.S. nationals to bring claims against Cuban ministries and state-owned enterprises that engage in unlawful trafficking. For example:
a. Congress found that trafficking in property confiscated from U.S. nationals benefits “the current Cuban Government” and “undermines the foreign policy of the United States.” 22 U.S.C. § 6081(6).
b. Regarding remedies, Congress found that “[t]he international judicial system … lacks fully effective remedies” thereby permitting unjust enrichment “by governments and private entities at the expense of the rightful owners of the property.” Id. § 6081(8).
c. Congress further recognized the U.S. Government’s “obligation to its citizens to provide protection against wrongful confiscations by foreign nations and their citizens, including the provision of private remedies.” Id. § 6081(10).
59. Given these findings, Section 302 of the Act unsurprisingly includes Cuban governmental entities within its scope.
60. Specifically, the definition of a “person” who may be liable for trafficking includes “any person or entity, including any agency or instrumentality of a foreign state” as defined by the FSIA, 28 U.S.C. § 1603(b). See 22 U.S.C. § 6023(1), (11).
61. A person is liable for trafficking in confiscated property under the Act “if that person knowingly and intentionally—
i. sells, transfers, distributes, dispenses, brokers, manages, or otherwise disposes of confiscated property, or purchases, leases, receives, possesses, obtains control of, manages, uses, or otherwise acquires or holds an interest in confiscated property,
ii. engages in a commercial activity using or otherwise benefiting from confiscated property, or
iii. causes, directs, participates in, or profits from, trafficking (as described in clause (i) or (ii)) by another person, or otherwise engages in trafficking (as described in clause (i) or (ii)) through another person, without the authorization of any United States national who holds a claim to the property.” 22 U.S.C. § 6023(13).
62. Since King Ranch has never authorized any person to engage in the activities covered by the Act’s definition of trafficking with respect to the Confiscated Property, Section 302 provides King Ranch with a private right of action against any person—including Cuba’s stateowned enterprises—that has trafficked in the Confiscated Property.
The Act’s Presumption in Favor of Certified Claims
63. Section 302(d) of the Act mandates a presumption in favor of King Ranch’s certified claim:
There shall be a presumption that the amount for
which a person is liable . . . is the amount that is certified
[by the FCSC under the International Claims Settlement Act of
[1949]. 22 U.S.C. § 6082(a)(2) (emphasis added).
64. The Act’s presumption in favor of certified claims extends not only to the amount of liability, but also to the claimant’s ownership and entitlement to treble damages. According to Section 303(a)(1), which deals with the “conclusiveness of certified claims,” in any action
brought under Title III, “the court shall accept as conclusive proof of ownership of an interest in property a certification of a claim to ownership of that interest that has been made by the [FCSC
under Title V of the International Claims Settlement Act of 1949].” 22 U.S.C. § 6083(a)(1) (emphasis added).
65. Under Section 302(a)(3) of the Act, “[a]ny person that traffics in confiscated property for which liability is incurred” shall be liable for treble damages if a U.S. national owns a certified claim to that property. 22 U.S.C. § 6082(a)(3)(A) & (3)(C).
66. Congress intentionally conferred these entitlements on certified claims. The utilization of the certified claim process was viewed as a positive feature of the Act.
The Conference Report from the Committee of Conference states that “courts shall give a strong presumption to the findings of the FCSC.” The Conference report continued: The committee of conference recognizes the importance of a decision by the Foreign Claims Settlement Commission in certifying a claim and, accordingly, believes that no court should dismiss a certification in an action brought under [Title III]. The committee of conference also notes the recognized special expertise of
the FCSC in determining the amount and validity of claims to confiscated
properties overseas. H.R. Rep. 104-468, at 63 (1996).
67. Under the text of the Act and in accordance with the intent of Congress, King Ranch’s certified claim is entitled to (i) a presumption of accuracy with regard to its amount; (ii) be treated as conclusive proof with regard to King Ranch’s ownership of the Confiscated Property;
and (3) a judgment on the claim that includes treble damages.
DEMAND FOR RELIEF
WHEREFORE, Plaintiff respectfully requests that judgment be entered in its favor and against Defendants:
a. Awarding Plaintiff actual damages in the amount of $3,216,084.97;
b. Awarding Plaintiff pre-judgment interest at the rate of 6% per annum from November 1, 1960, as set forth in the FCSC’s award;
c. Awarding Plaintiff treble damages pursuant to 22 U.S.C. § 6082(a)(3);
d. Ordering Defendants to pay Plaintiff’s reasonable attorney’s fees and costs incurred in this action pursuant to 22 U.S.C. § 6082(a);
e. Awarding Plaintiff post-judgment interest; and
f. Granting all other relief at law or in equity that the Court deems just and proper.
Date: March 5, 2021 Respectfully submitted,
By: /s/ Steven K. Davidson
Steven K. Davidson (DC Bar #407137)
Jared R. Butcher (DC Bar #986287)
STEPTOE & JOHNSON LLP
1330 Connecticut Ave NW
Washington, DC 20036
Telephone: 202-429-3000
Facsimile: 202-429-3902
sdavidson@steptoe.com
jbutcher@steptoe.com
Counsel for Plaintiff