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annul the decision of the ECB Executive Board of 7 May 2019 imposing the disciplinary dismissal without notice;

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annul the decision of the ECB Executive Board of 25 June 2019 refusing to reopen the disciplinary proceedings further to the closure of criminal proceedings;

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as a consequence, order the full reinstatement of the applicant as of 11 May 2019 with all related financial entitlements and with the appropriate publicity in order to restore his good name;

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in any case, order the compensation of the non-material harm allegedly suffered by the applicant, evaluated ex aequo et bono at EUR 20 000:

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order the defendant to reimburse all the costs.

1.

First plea in law, alleging lack of competence of the author of the contested measures.

2.

Second plea in law, alleging breach of Article 8.3.2 of the ECB Staff Rules. It is alleged that the disciplinary proceedings were initiated while time-barred.

3.

Third plea in law, alleging breach of the principle that disciplinary proceedings arising out of a criminal offence must await the outcome of the criminal trial, together with breach of the principle of good administration and of the duty of care.

4.

Fourth plea in law, alleging that the Disciplinary Committee exceeded its mission. It is alleged that Article 8.3.7 of the ECB Staff Rules was breached, along with the principle of impartiality as embodied in Article 41 of the Charter of Fundamental Rights of the EU.

5.

Fifth plea in law, alleging manifest errors of assessment.

6.

Sixth plea in law, alleging violation of the presumption of innocence. It is alleged that Article 48 of the Charter of Fundamental Rights of the EU was breached.

7.

Seventh plea in law, alleging violation of the principle that disciplinary proceedings be conducted within a reasonable period and violation of the duty of care.

8.

Eighth plea in law, alleging violation of the duty to state reasons.

9.

Ninth plea in law, alleging, on a subsidiary basis, violation of the principle of proportionality.