Partners Jeff Recher, Andy Rosenberg and Paul Paterson were recognized in The American Lawyer’s “Litigation Daily” column for securing a significant Second Circuit victory for an ad hoc group of holders of defaulted bonds issued by Venezuelan state-owned oil company Petróleos de Venezuela, S.A. (PDVSA).
On October 27, a unanimous Second Circuit panel affirmed a September 2025 district court summary judgment finding that the approximately $3 billion in notes are valid and enforceable. The Second Circuit agreed that the Venezuelan National Assembly’s approval was not required to validate PDVSA’s 2016 exchange offer and rejected PDVSA’s argument that the act-of-state doctrine required U.S. courts to defer to the National Assembly’s declarations that the notes were invalid.
Counsel Conrad Scott and associates Joshua Altman and Austin Piatt were also named in the article.