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annul in whole the Decision of the Secretary-General of the European Parliament dated 21 December 2020,

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annul in whole the Debit Note addressed to the Applicant, for the amount of 196 199,84 Euros, No 7010000021, dated 15 January 2021 and

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order the European Parliament to pay the applicant’s costs in the proceedings.

1.

First plea in law, alleging that the European Parliament acted without regard to Article 137 of Staff Regulations of Officials and the Conditions of Employment of Other Servants the European Economic Community and the European Atomic Energy Community. (1)

2.

Second plea in law, alleging that the European Parliament misdirected itself in law and failed to apply the correct standard of ‘undue payment’ under Articles 32 and 68 of Decision of the Bureau of 19 May and 9 July 2008, concerning implementing measures for the Statute for Members of the European Parliament. (2)

3.

Third plea in law, alleging that the European Parliament failed to have regard to a Member’s right to freedom and independence, under Articles 2 and 21 of the Statute for Members of the European Parliament. (3)

4.

Forth plea in law, alleging failure to give reasons under Article 296 TFEU in dismissing sixty eight out of seventy eight documents submitted by the Member, as ‘inadmissible’ evidence, failure to give reasons for considering that the whole salary was ‘unduly paid’, even though only six months of the thirty month contract were fully investigated, and failure to give reasons for contradicting OLAF’s findings, which exonerated the Applicant of any dishonesty.

5.

Fifth plea in law, alleging manifest errors of fact.