The case of the day, Delizia Ltd. v. Eritrea (S.D.N.Y. 2012), is a short, fun decision. Delizia had a contract to sell $12 million dollars of equipment to the Eritrean Ministry of Defense. The Ministry stopped making payments. The contract had an agreement to arbitrate, so Delizia commenced an arbitration in Sweden. Eritrea did not participate in the arbitration, and an award entered in Delizia’s favor. Delizia sought confirmation of the award. Eritrea defaulted, and the judge entered a default judgment against it. Delizia owned a commercial condominium unit in New York City (one of the tenants was the Marshall Islands’ permanent mission to the United Nations). Delizia sought to attach the Marshall Islands mission’s rent payments to Eritrea. Although Eritrea did not oppose…

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