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declare the action for annulment to be admissible and well-founded;

—

declare Council Decision (CFSP) 2023/1094 of 5 June 2023 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine to be inapplicable to the applicant on grounds of unlawfulness;

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declare Council Implementing Regulation (EU) 2023/1098 of 5 June 2023 implementing Regulation (EU) 2020/1998 concerning restrictive measures against serious human rights violations and abuses to be inapplicable to the applicant on grounds of unlawfulness;

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order the annulment in part of Council Decision (CFSP) 2023/1767 of 13 September 2023 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, in so far as it concerns the applicant;

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order the annulment in part of Council Implementing Regulation (EU) 2023/1765 of 13 September 2023 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, in so far as it concerns the applicant;

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order the Council of the European Union to pay all the costs and expenses of the proceedings;

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reserve to the applicant all other rights, entitlements, pleas and actions.

1.

First plea, raising a plea of illegality.

2.

Second plea, alleging a manifest error of assessment.

3.

Third plea, alleging a failure to observe the principle of proportionality.

4.

Fourth plea, alleging a failure to observe the principle of legal certainty.