Latin Events LLC v. Junta Central Electoral De La Republica Dominicana

Background

Latin Events LLC filed the action on April 4, 2025. It submitted an affidavit stating that service was personally accepted on behalf of Junta Central Electoral De La Republica Dominicana (JCE) at JCE’s office at 1501 Broadway in Manhattan. JCE did not answer or otherwise appear. The Clerk of Court entered a Certificate of Default on October 29, 2025.

Latin Events moved for default judgment under Federal Rule of Civil Procedure 55(b)(2) and Local Civil Rule 55.2. The complaint alleged that, on or about October 30, 2023, JCE agreed to pay Latin Events $1,000,000 for services related to a voter-registration drive directed at residents of New York and neighboring states. The services included a three-day baseball event at Citi Field, 20,000 lunch meals at four restaurants in New York and New Jersey, and radio, television, and online publicity. The agreement also required JCE to pay applicable sales, use, and similar taxes.

Latin Events stated that it performed its obligations but received only partial payment. The court found that the submitted agreement and invoices showed an unpaid principal balance of $770,000 and New York sales tax of $68,337.50, for total claimed damages of $838,337.50.

Subject-Matter Jurisdiction

Because JCE is an agency or instrumentality of the Dominican Republic, it is generally protected by foreign sovereign immunity. The court held, however, that the commercial-activity exception in the Foreign Sovereign Immunities Act applied. That exception removes immunity when an action is based on commercial activity carried on in the United States by a foreign state.

The court concluded that JCE’s agreement to purchase tickets and services for a baseball event, meals, and a publicity campaign was the type of commercial transaction in which a private party could engage. The voter-registration purpose did not change the commercial character of those activities. The court therefore concluded that it had subject-matter jurisdiction.

Default Judgment and Contract Liability

A default admits well-pleaded allegations, but it does not automatically require entry of a default judgment. Before entering judgment, the court must determine whether the allegations establish the defendant’s legal liability.

The court found that Latin Events established the elements of breach of contract: a contract existed, Latin Events performed, JCE failed to perform its payment obligations, and Latin Events suffered damages. The court relied on the October 30, 2023 document titled “Receipt of Tickets,” which stated that JCE agreed to purchase the tickets and additional services for a total of $1,000,000. Latin Events also submitted an affidavit from Felix Cabrera and two invoices supporting its claim that JCE had not paid the full amount.

The court concluded that Latin Events established liquidated damages of $838,337.50. It awarded prejudgment interest under New York law at 9% per year from April 4, 2025, the date the action was filed, through the judgment period, totaling $48,370.93. The court also stated that JCE was liable for post-judgment interest under 28 U.S.C. § 1961(a).

The court did not address the unjust-enrichment and implied-covenant claims because Latin Events pleaded them as alternatives to, and duplicative of, its breach-of-contract claim.

Disposition

Judge P. Castel granted Latin Events’ motion for default judgment. The Clerk was directed to enter judgment for Latin Events in the principal amount of $838,337.50, plus $48,370.93 in prejudgment interest and post-judgment interest. The court denied Latin Events’ request for $405 in costs because Latin Events did not identify the costs or provide supporting documentation. The Clerk was directed to terminate the motion and close the case.