December 4, 2025
In a complex federal court case in Delaware with far-reaching geopolitical significance, Managing Director Gary Kleinrichert’s expert financial valuation helped secure approval of a landmark $5.89 billion Citgo sale opinion that could help resolve billions of dollars in unpaid judgments against Venezuela and certain of its instrumentalities.
Citgo, the fifth-largest oil refiner in the United States, is owned indirectly by Venezuela’s state-owned oil company Petróleos de Venezuela SA (PDVSA) through PDV Holding Company (PDVH), a Delaware corporation. On November 25, 2025, U.S. Circuit Judge Leonard P. Stark approved the sale of PDVH shares to Amber Energy, an affiliate of the hedge fund Elliott Investment Management. The court agreed with Special Master Robert Pincus that Amber Energy’s bid offered the best combination of “price and certainty of closing” of any bid submitted.
Mr. Kleinrichert, a nationally-recognized and highly-credentialed forensic accounting expert with more than 30 years of business valuation experience, was retained as the valuation expert on behalf of one of the judgment creditors/bidders in support of the Special Master’s Updated Final Recommendation that the court approve the sale of PDVH shares to Amber Energy.
Mr. Kleinrichert’s valuation relied on both a discounted cash flow (DCF) analysis and a market multiples analysis to establish a fair market value range for the PDVH shares between $8.4 and $8.6 billion, before accounting for contingent liabilities (such as the claims associated with the 2020 Bondholders).1
Amber Energy’s winning bid offered $5.892 billion, plus a $2.125 billion Transaction Support Agreement (TSA) with 2020 Bondholders who hold a security interest in 50.1% of CITGO Holding. Judge Stark found Mr. Kleinrichert’s valuation to be “credible and persuasive”, citing, “Mr. Kleinrichert’s fulsome analysis, which is the product of multiple calculations and reasoned, well-supported, and standard methodological choices.”2 The court relied heavily on Mr. Kleinrichert’s analysis in approving the highly significant sale to Amber.
The Secretariat team supporting Mr. Kleinrichert included Chris Robinson, Jesse Ivory, Abby Williams, David Sastre, and Patrick Sorensen.
Appeals of the ruling have been filed.
Read the opinion in full here, and see Law360 coverage of the matter here (subscription may be required).
Secretariat Named Arbitration Expert Firm of the Year at 2025 Lexology Index Awards
Secretariat is delighted to announce that we were named as the Arbitration Expert Firm of the Year at the prestigious 2025 Lexology Index Awards Ceremony, held at Merchant Taylors’ Hall in London. We are honored to be recognized by clients and peers as the foremost experts leading and shaping the global arbitration community.
Secretariat has earned significant recognition in the 2026 Lexology Index Arbitration Report, with 52 experts named in the prestigious listing, including the most combined Thought Leaders (7) and Global Elite Thought Leaders (10).
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