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set aside the judgment of the General Court (Grand Chamber) of 2 October 2024 in Case T-828/22;

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give a final ruling in the matter and uphold the claims of the intervener, now the appellant, in the proceedings at first instance; that is to say:

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in the alternative, set aside the judgment and refer the case back to the General Court;

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order the Council of the European Union to pay the costs of both sets of proceedings.

1.

Error of law in so far as the judgment under appeal wrongly found that the Council had fulfilled its obligation to state reasons.

2.

Error of law in so far as the judgment under appeal wrongly found that M. Rodríguez Jiménez was relying on new grounds for annulment, whereas he was relying on infringement of Article 15 of the Charter of Fundamental Rights of the European Union and implicitly his right to property, and that those arguments must therefore be rejected.

3.

Error of law in so far as the judgment under appeal wrongly found that there was no breach of the right of lawyers to be provided with legal advice.

4.

Error of law in so far as the judgment under appeal wrongly found that M. Rodríguez Jiménez raised new grounds for annulment by relying on the breach of the principle of legal certainty.

5.

Error of law in so far as the judgment under appeal wrongly found that there had been no infringement of Article 52(1) of the Charter of Fundamental Rights of the European Union.