110 414 FEDERAL SUPPLEMENT, 3d SERIES court in order to obtain default judgment provides foreign sovereigns a special protection before a court reaches default judgment. 28 U.S.C.A. § 1608(e). 6. International Law O518 Neither the federal civil procedural rule governing default judgments against the United States government nor the parallel requirement for default judgment under the Foreign Sovereign Immunities Act (FSIA) relieves the sovereign from the duty to defend cases. 28 U.S.C.A. § 1608(e); Fed. R. Civ. P. 55(d). 7. International Law O518 Uncontroverted factual allegations that are supported by admissible evidence are taken as true in determining whether a plaintiff establishes his claim or right to relief by evidence satisfactory to the court in order to obtain default judgment against a foreign sovereign under the Foreign Sovereign Immunities Act (FSIA) or against the United States government. 28 U.S.C.A. § 1608(e); Fed. R. Civ. P. 55(d). 8. International Law O518 Default judgments under the Foreign Sovereign Immunities Act (FSIA), which require a plaintiff to establish his claim or right to relief by evidence satisfactory to the court, may rely on the plaintiffs’ affidavits and declarations and on public record evidence because so long as the evidence itself is admissible, the uncontroverted evidence’s form or type is irrelevant as to whether the plaintiffs have satisfied their burden of production. 28 U.S.C.A. § 1608(e). 10. International Law O431 United States courts lack subject matter jurisdiction over claims against foreign states unless certain exceptions under the Foreign Sovereign Immunities Act (FSIA) apply. 28 U.S.C.A. § 1604. 11. International Law O475 If a plaintiff satisfies his burden of production that an exception to a foreign state’s presumed immunity under the Foreign Sovereign Immunities Act (FSIA) applies and the defendant fails to present any evidence in rebuttal, then jurisdiction attaches. 28 U.S.C.A. § 1604. 12. International Law O446 For purposes of requirement under terrorism exception to Foreign Sovereign Immunities Act (FSIA) that a plaintiff have afforded the foreign state defendant a reasonable opportunity to arbitrate the claim in accordance with the accepted international rules of arbitration, the offer to arbitrate need not precede the complaint. 28 U.S.C.A. § 1605A(a)(2)(A)(iii). 13. Constitutional Law O3965(11) International Law O506 Foreign states are not persons protected by the Fifth Amendment, leaving no need to conduct a minimum contacts analysis in determining personal jurisdiction in a Foreign Sovereign Immunities Act (FSIA) case. U.S. Const. Amend. 5; 28 U.S.C.A. § 1604. 9. International Law O475 14. International Law O446 Foreign Sovereign Immunities Act (FSIA) claims against state sponsors of terrorism are federal causes of action that do not depend on state law. 28 U.S.C.A. § 1605A. The court begins with a presumption of immunity for foreign states in Foreign Sovereign Immunities Act (FSIA) cases. 28 U.S.C.A. § 1604. 15. International Law O447 To assess a plaintiff’s theories of ‘‘personal injury’’ under the Foreign Sovereign Immunities Act (FSIA), for purposes of

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