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Fg Hemisphere Associates, LLC v. Democratic Republic of Congo

Citation: Not availableDocket: Civil Action No. 2003-1315

Court: District Court, District of Columbia; March 20, 2009; Federal District Court

Original Court Document: View Document

Narrative Opinion Summary

The case involves FG Hemisphere Associates, LLC's motion for a civil contempt order and sanctions against the Democratic Republic of Congo (DRC) for failing to comply with court-ordered discovery obligations. The DRC was required to provide documents related to its assets outside the jurisdiction following a bifurcated discovery plan, which aimed to identify properties immune from execution under the Foreign Sovereign Immunities Act. Despite submitting a certification of efforts, the DRC did not fulfill its obligations, prompting the plaintiff to seek enforcement of the discovery orders. The court found the DRC in civil contempt for its noncompliance, necessitating a comprehensive search for the relevant documents and certification of completion. The court imposed a structured fine, initially $5,000 per week, doubling every four weeks up to $80,000 weekly, contingent on continued noncompliance. Additionally, the court mandated that the DRC cover the reasonable expenses and attorney fees incurred by the plaintiff due to the noncompliance. The DRC's appeal against the default judgment and attempt to stay discovery obligations were denied, and the plaintiff's motion was granted in part.

Legal Issues Addressed

Award of Costs and Attorney Fees for Discovery Noncompliance

Application: The Court ordered the DRC to pay the plaintiff's reasonable expenses, including attorney fees, due to its noncompliance with discovery orders.

Reasoning: Additionally, DRC is required to pay the plaintiff's reasonable expenses incurred due to its non-compliance, including attorney's fees, within 20 days of the plaintiff's itemized listing.

Civil Contempt for Noncompliance with Discovery Orders

Application: The Court found the Democratic Republic of Congo (DRC) in civil contempt for failing to comply with discovery orders requiring the production of documents regarding assets outside the jurisdiction.

Reasoning: DRC has been found in civil contempt for violating the Court's discovery orders dated February 12, 2007, and November 28, 2006.

Foreign Sovereign Immunities Act and Discovery Obligations

Application: The bifurcated discovery plan was initially focused on determining property immunity under the Foreign Sovereign Immunities Act, impacting the scope and timing of discovery compliance.

Reasoning: The bifurcated discovery plan's first phase was focused on determining the existence of properties immune from execution under the Foreign Sovereign Immunities Act.

Sanctions for Noncompliance with Discovery Orders

Application: The DRC must conduct a thorough search for documents related to its assets outside the District of Columbia and could face escalating fines for continued noncompliance.

Reasoning: If DRC fails to comply within the specified timeframe, it must show cause why it should not face a fine starting at $5,000 per week, which will double every four weeks until a maximum of $80,000 per week is reached.