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find and declare that the European Central Bank (ECB), represented by the President Christine Lagarde, is non-contractually liable:

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order the ECB, in the person of the President for the time being, to provide to the applicant compensation for financial loss (comprising actual loss and loss of profit), the non-financial loss outlined above and a loss of opportunity, assessed according to the criteria set out in the relevant chapters and paragraphs of the application, by making payments in the following amounts (i) EUR 1 538 808,12 for financial loss, (ii) EUR 500 000,00 for non-material loss and (iii) and, therefore, a total amount of EUR 2 038 808,12;

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in the alternative, order the ECB, in the person of the President for the time being, to pay to the applicant compensation for the categories of loss listed above, in amounts different from those above, established in the course of proceedings, to the extent deemed fair, including by having recourse to an expert’s report commissioned by the Court, pursuant to Article 70 of the Rules of Procedure of the General Court of the European Union;

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order the EBC to pay the amount which the Court assesses, according to its own unbiased assessment, in respect of the loss of opportunity;

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order the EBC to pay default interest to be calculated from 12 March 2020, the date of the event that gave rise to the loss, to the date on which the compensation is actually paid;

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order the defendant to pay the legal costs.

1.

First plea in law, alleging that the ECB is liable under the third paragraph of Article 340 TFEU and Article 2043 of the Codice civile (Italian Civil Code) for the financial and non-material loss suffered by the applicant and indicating the amounts of those sums.

2.

Second plea in law, indicating the significance of the financial loss, non-material loss and loss of opportunity allegedly suffered by the applicant and explaining the principles applied to determine them.

3.

Third plea in law, referring to principles established in the case-law of the European Union, in particular in the judgments of 28 October 2021, Vialto Consulting v Commission (C-650/19 P, EU:C:2021:879), of 9 February 2022, QI and Others v Commission and ECB (T-868/16, EU:T:2022:58) and of 21 January 2014, Klein v Commission (T-309/10, EU:T:2014:19).

The applicant claims that the conditions for an EU institution to incur non-contractual liability vis-à-vis an EU citizen have been satisfied, as supported by a sworn statement provided by a technical consultant and annexed to the application, in accordance with the EU legislation governing the ECB, its bodies and their functions. The applicant alleges infringements by the ECB of primary and secondary EU law and infringements and abuse of power by the President of the ECB.

The applicant alleges that, on 12 March 2020, the ECB, acting through its President, infringed Article 127 TFEU under Chapter 2, which is headed ‘Monetary Policy’, Articles 3, 10, 11, 12, 13 and 38 of the Statute of the European System of Central Banks and of the ECB, and Article 17.2 and 17.3 of the Rules of Procedure adopted by a decision of the ECB on 19 February 2004. (1)

4.

Fourth plea in law, concerning the characterisation of, reasons for and documentation of the financial loss suffered by the applicant (actual loss and loss of profit).

5.

Fifth plea in law, concerning the characterisation of, reasons for and documentation of psychological harm and damage to reputation and personal and professional identity.

6.

Sixth plea in law, concerning the explanation of, reasons for and evidence of the presumption of and the calculation of the likelihood of loss of opportunity and a request that this be calculated on equitable principles.

7.

Seventh plea in law, concerning the principles established in the EU case-law concerning non-financial loss caused by the EU institutions vis-à-vis EU citizens in particular in the judgment of 12 September 2007, Combescot v Commission, (T-250/04, EU:T:2007:262).