Lovati v. Petroleos De Venezuela, S.A.

CourtDistrict Court, S.D. New York
DecidedMarch 28, 2025
Docket1:19-cv-04799
StatusUnknown

This text of Lovati v. Petroleos De Venezuela, S.A. (Lovati v. Petroleos De Venezuela, S.A.) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lovati v. Petroleos De Venezuela, S.A., (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK RUDI LOVATI and ALESSANDRA LOVATI, Plaintiffs, -against- 1:19-cv-04799 (ALC) (HJR) OPINION & ORDER PETRÓLEOS DE VENEZUELA, S.A., Defendant. ANDREW L. CARTER, JR., District Judge: Plaintiffs Rudi Lovati and Alessandra Lovati commenced this breach of contract action against Defendant Petróleos de Venezuela, S.A. (“PDVSA”), seeking recovery for payments allegedly due under notes issued by PDVSA. Both parties move for summary judgment pursuant to Federal Rule of Civil Procedure 56. For the reasons that follow, both motions are DENIED. BACKGROUND I. Factual History The Court presumes the parties’ familiarity with the underlying facts in this case. A more complete summary of the facts can be found in this Court’s September 30, 2020 Opinion and Order

denying PDVSA’s motion to dismiss. ECF No. 37. PDVSA is a state-owned oil company of Venezuela. ECF No. 140 ¶ 2.1 On November 17, 2011, PDVSA entered into an Indenture, pursuant to which it issued a series of notes (“Notes”) to

1 A majority of the factual record is undisputed. This factual history is taken from Defendant’s submitted Statement of Material Facts pursuant to Local Civil Rule 56.1 (“ECF No. 140”), Plaintiffs’ submitted Statement of Material Facts (“ECF No. 132”), Plaintiffs’ Counterstatement of Material Facts (“ECF No. 145”), Defendant’s Counterstatement of Material Facts (“ECF No. 149”), Defendant’s memorandum of law in support of its motion for summary judgment (“ECF No. 141”), Plaintiffs’ memorandum of law in support of their motion for summary judgment (“ECF No. 134”), Plaintiffs’ memorandum of law in opposition to Defendant’s motion (“ECF No. 144”), and Defendant’s memorandum of law in opposition to Plaintiffs’ motion (“ECF No. 148”). Plaintiffs Rudi Lovati and Alessandra Lovati, and others. Id. ¶ 23. On their issue date, the aggregate principal amount of the Notes delivered under the Indenture was $2,394,239,600. Id. The principal amount of the Notes owned by Plaintiffs was $55,455,000. ECF No. 132 ¶ 23. Pursuant to the terms of the Indenture, PDVSA operates as the guarantor; Wilmington

Trust Company as the trustee; Citibank, N.A., as registrar, transfer agent, and principal paying agent; and Dexia Banque Internationale à Luxembourg, Société Anononyme, as Luxembourg listing agent and paying agent. ECF No. 132 ¶ 2. In 2016, Citibank resigned and the Delaware Trust Company (“Delaware Trust,” “Principal Paying Agent,” or “Agent”) became the registrar, transfer agent, and principal paying agent. ECF No. 140 ¶ 28. The nominal owner of the Notes is the Depository Trust Company, while Plaintiffs Rudi Lovati and Alessandra Lovati are two of many beneficial owners. ECF No. 132 ¶ 3. Each Note bears a 9% interest rate per annum, with the principal due in three installments on November 17, 2019, November 17, 2020, and November 17, 2021, the maturity date. Id. ¶¶ 8– 12. Section 2.08(b) of the Indenture provides that the Notes impose semi-annual interest payment

obligations upon PDVSA, with payments being due every May 17 and November 17 until the principal has been paid. Id. ¶ 10. The Indenture requires PDVSA to make payments directly to the Agent in New York City. ECF No. 140 ¶¶ 33, 40. PDVSA has not made any principal or interest payments on the Notes since May 2017. ECF No. 132 ¶¶ 13-14. The total amount of missed principal and interest payments on Plaintiff Rudi Lovati’s Notes is $85,316,000. Id. ¶ 34. The total amount of missed principal and interest payments on Plaintiff Alessandra Lovati’s Notes is $84,700. Id. ¶ 35. PDVSA argues that its defaults are an unavoidable consequence of the U.S. response to the Maduro regime in Venezuela. ECF No. 141 at 15. Specifically, PDVSA argues that banks, in an effort to avoid U.S. sanctions imposed against Venezuela-related entities, refused to process its payments on the Notes. Id.; ECF No. 148 at 3. Initially, PNC Bank had processed payments made to the Agent, but on June 29, 2017, it alerted the Agent that it would no longer do so. ECF No. 140 ¶ 97. In the following months, neither

the Agent nor PDVSA could locate a qualifying bank to accept payments from PDVSA on behalf of the Agent. ECF No. 148 at 5. “The[y] approached numerous banks, including (i) U.S. Bank, N.A., (ii) JPMorgan Chase Bank, N.A. (“JPMorgan”), (iii) MUFG Union Bank, N.A., (iv) Santander Bank, (v) Dinosaur Merchant Bank, (vi) BBVA Compass Bank, (vii) BNP Paribas Bank, (viii) Société Générale Bank, (ix) China Citic Bank, and (x) Bank of China New York.” Id. A representative for the Agent testified that every qualified bank contacted was unwilling to process PDVSA’s deposits on the Notes. Id. Unable to find a replacement bank, the Agent concluded it was unable to execute its functions under the Indenture due to circumstances beyond its reasonable control, and resigned. Id. at 6. Plaintiffs argue that PDVSA had alternative options to make payments on the Notes beyond

these efforts, offering evidence that “PDVSA made payments of interest and principal on [other] Notes in the latter part of 2017, all of 2018, and the early part of 2019.” ECF No. 132 ¶ 38. Additionally, Plaintiffs highlight that after PNC Bank refused to process payments, PDVSA was still able to, “on several occasions, . . . transfer funds to DTCC, the nominal owners of the bonds, by transmitting funds from a PDVSA bank account to JP Morgan Chase, which functioned as DTCC’s bank.” Id. ¶¶ 43, 45. On November 17, 2017, for the first time in six years, PDVSA missed a payment on the Notes. ECF No. 140 ¶¶ 116-117. Despite demands for payment, PDVSA has failed to make any payments on the Notes since then. ECF No. 132 ¶ 16. II. Procedural History On May 23, 2019, Plaintiffs filed this breach of contract action. See ECF No. 1 (“Compl.”). Defendant filed a motion to dismiss the complaint, which the Court denied on September 30, 2020. See ECF No. 37. Defendant later filed a motion for judgment on the pleadings, which the Court

denied on December 13, 2021. See ECF No. 68. In that opinion, the Court granted Plaintiffs’ leave to amend their complaint. Id. Plaintiffs did and filed the amended complaint on January 3, 2022. See ECF No. 72 (“AC”). Following discovery, the parties filed cross motions for summary judgment on September 1, 2023. See ECF Nos. 126 (Plaintiffs’ motion), 135 (Defendant’s motion). Both motions are fully briefed. See ECF Nos. 134 (Plaintiffs’ memorandum in support), 141 (Defendant’s memorandum in support), 144 (Plaintiffs’ opposition), 148 (Defendant’s opposition), 151 (Plaintiffs’ reply), 153 (Defendant’s reply). The parties jointly move to file portions of their supporting exhibits under seal. 2 ECF No. 125. Plaintiffs move for summary judgment on their breach of contract claim and Defendant’s

impossibility defense. See generally ECF No. 134. Defendant only contests Plaintiffs’ motion as to its impossibility defense, which also forms the basis of its own motion for summary judgment. See generally ECF Nos. 141, 148.

2 The Court recognizes that there is a strong First Amendment presumption of public access to judicial documents and proceedings. See Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119–20,123–24 (2d Cir. 2006). However, court documents may be sealed if “specific, on the record findings are made demonstrating that ‘closure is essential to preserve higher values and is narrowly tailored to serve that interest.’” Press-Enterprise Co. v. Superior Court, 478 U.S. 1, 13–14 (1986) (quoting Press-Enterprise Co. v.

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