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Replies to post #404 on -Top Gainer - DD// - (deet)
DEMAND FOR JURY TRIAL
Pursuant to Rule 38 of the Federal Rules of Civil Procedure, American Sugar demands a
trial by jury in this action of all issues so triable.
PRAYER FOR RELIEF
WHEREFORE, American Sugar respectfully requests that judgment be entered in its
favor and against DSV:
1. Awarding American Sugar actual damages in the amount of the certified claim, namely
$97,373,414.72;
2. Awarding American Sugar pre-judgment compounded interest pursuant to 22 U.S.C.
§ 6082(a)(1)(B) accruing from the relevant dates of confiscation;
3. Awarding American Sugar treble damages pursuant to 22 U.S.C. § 6082(a)(3);
4. Ordering DSV to pay American Sugar’s reasonable attorneys’ fees and costs incurred in this
action pursuant to 22 U.S.C. § 6082(a)(1)(A)(ii);
5. Awarding American Sugar post-judgment interest pursuant to 28 U.S.C. § 1961; and
6. Granting all other relief that the Court deems just and proper.
UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
NORTH AMERICAN SUGAR INDUSTRIES INC.,
Plaintiff,
v.
DSV AIR & SEA INC.,
Defendant.
Civil Action No. 2:21-cv-00080
COMPLAINT AND DEMAND FOR A JURY TRIAL
Plaintiff North American Sugar Industries Inc. (“American Sugar”), a New Jersey
corporation with its principal place of business in New York, New York, for its complaint
against defendant DSV Air & Sea Inc. (“DSV”), a Delaware corporation with its principal place
of business located at 100 Walnut Avenue, Suite 405, Clark, New Jersey 07066, in the abovecaptioned action, alleges on information and belief as follows:
The United States government retains broad discretion to negotiate a settlement on behalf of the claims certified by the United States Foreign Claims Settlement Commission (USFCSC) within the United States Department of Justice. There exists a pre-positioned constituency among the certified claimants in support of a prompt resolution.
Unknown is whether within the Biden Administration exists a confidence that direct negotiations to resolve the certified claims can develop independent of a resolution for other bilateral issues with the Republic of Cub/a.
The issue of the certified claims has survived one century to the next century, seven decades, and twelve (12) presidencies: Eisenhower Administration, Kennedy Administration, Johnson Administration, Nixon Administration, Ford Administration, Carter Administration, Reagan Administration, G.H.W. Bush Administration, Clinton Administration, G.W. Bush Administration, Obama Administration, and Trump Administration. Thirteen is considered by some an unlucky number.
Structure Of A Resolution
A certified claims settlement should be based upon the payment of 100% of the value of each certified claim. Even with a full settlement based upon principal and interest, the annual rate of inflation has substantially diminished the value of each certified claim.
Opportunities for settlement include, but are not limited to, 100% compensation, debt-for-equity swaps, and substitution investments (one structure for another; one piece of land for another, etc.).
Portions of monies owed could be transformed into tradable equity positions which a certified claimant could use or could redirect or could market to a third-party.
In combination with or separately from compensation formats, the Republic of Cuba could provide transferable values to the certified claimants including:
Income Tax Holidays
Import duty exemptions
Reduced energy rates
Property tax credits
Earned income tax credits
Issuance of commercial paper
Resolution is the means to the goal in whatever form such resolutions may take for the largest United States corporate claimants (e.g., debt-for-equity swaps for new direct foreign investment opportunities, or property restitution combined with re-investment in once-owned properties, or the sale of development rights to third parties, United States-based or non-United States-based). The goal is closure.
