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admit the present action and declare it to be well founded;

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annul the decision of 22 September 2014;

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in the alternative, order the joinder of the present case with Musso v European Parliament (register No 633447, case No T-589/14) of 8 August 2014;

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in the further alternative, annul the decision of 22 September 2014, resulting from the decision of 26 June 2014, which itself is liable to be annulled in the action of 8 August 2014 (Musso v European Parliament, register No 633447, Case No T-589/14);

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reserve to the applicant all other rights, remedies, pleas and actions;

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order the defendant to pay all the costs of the proceedings.

1.

First plea in law, alleging infringement of the principle of reasonable time affecting the exercise of the rights of the defence, in that the decision of 22 September, that is to say, the contested debit note, was issued 12 years after the Parliament established its book debt in respect of the applicant.

2.

Second plea in law, alleging a formal irregularity in the contested debit note in that the Parliament’s book debt is neither certain nor correct for the purposes of Article 81 of Delegated Regulation (EU) No 1268/2012 (1) and is, moreover, unverifiable.

3.

Third plea in law, alleging a formal irregularity in the decision of 26 June 2014, as a result of which the contested debit note was issued, in that, that decision was not signed by the President of the Parliament in accordance with the Parliament's Rules of Procedure.

4.

Fourth plea in law, alleging infringement of the applicant’s rights of the defence, in that the decision of 17 July 1996, which served as a basis for the decision of 26 June 2014, was not published, in breach of Article 28 of the Parliament's Rules of Procedure.

5.

Fifth plea in law, alleging infringement of the principle of audi alteram partem.

6.

Sixth plea in law, alleging that the decision of 26 June 2014 contains an inadequate statement of reasons.

7.

Seventh plea in law, alleging infringement of the principle of reasonable time, in that the Parliament waited eight years before beginning the recovery procedure against the applicant.

8.

Eighth plea in law, alleging infringement of the principle of the vested right, in that the decision of 26 June 2014, as a result of which the contested debit note was issued, prejudices the pension entitlements which the applicant acquired on 3 August 1994.