CVG Ferrominera Orinoco, C.A. v. Commodities & Minerals Enterprise Ltd.
1. Did the Second Circuit err in holding service of a Summons pursuant to Rule 4 of the Federal Rules of Civil Procedure, Fed. R. Civ. P. 4, upon a party covered by the Federal Sovereign Immunities Act ("FSIA"), 28 U.S.C. § 1608, is not required in the context of a petition to confirm an arbitration award pursuant to the Federal Arbitration Act, 9 U.S.C. § 201 et seq.?
2. Did the Second Circuit err in holding that allowing enforcement of an arbitration award on a contract was not contrary to United States public policy, pursuant to Article V(2)(b) of the New York Convention, where the agreement was procured by means of a scheme of criminal bribery, corruption, and fraud already adjudicated and confirmed by the Venezuelan courts prior to the issuance of the arbitration award?
Did the Second Circuit err in holding service of a Summons pursuant to Rule 4 of the Federal Rules of Civil Procedure, Fed. R. Civ. P. 4, upon a party covered by the Federal Sovereign Immunities Act ('FSIA'), 28 U.S.C. § 1608, is not required in the context of a petition to confirm an arbitration award pursuant to the Federal Arbitration Act, 9 U.S.C. § 201 et seq.?