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grant the applicant compensation for the non-material prejudice suffered, as detailed in the present action, estimated, ex aequo et bono, at EUR 100 000;

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annul the decision of the director of the European Union Agency for Fundamental Rights (FRA) of 19 November 2018 rejecting the applicant’s request under Article 90(1) of the Staff Regulations;

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if need be, annul the decision of the FRA director of 12 June 2019, rejecting the applicant’s complaint under Article 90(2) of the Staff Regulations directed by the applicant against the abovementioned decision of 19 November 2018;

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order the defendant to pay all the costs.

1.

First plea in law, alleging that the defendant did not hear the applicant and did not adopt a decision pursuant to Article 3 of Annex IX to the Staff Regulations following the judgment of 8 October 2015 of the Civil Service Tribunal in Joined Cases F-106/13 and F-25/14, DD v European Union Agency for Fundamental Rights (EU:F:2015:118).

2.

Second plea in law, alleging that the administrative enquiry and the initial disciplinary proceedings were opened irregularly.

3.

Third plea in law, alleging that the defendant failed to compensate the applicant in respect of the non-material prejudice resulting from the decision of reprimand annulled by the Civil Service Tribunal in the abovementioned judgment.

4.

Fourth plea in law, alleging that the defendant failed to implement the abovementioned judgment of the Civil Service Tribunal and conduct the pre-disciplinary procedure within a reasonable time and with due diligence.

5.

Fifth plea in law, alleging that the opening and the conduct of the administrative inquiry violated Regulation (EC) No 45/2001, (1) the EU Staff Regulations and the right to private life (Article 7 of the Charter of Fundamental Rights of the European Union).

6.

Sixth plea in law, alleging that the defendant repeatedly made unfounded, defamatory and offensive statements about the applicant which amount to violations of the principle of res judicata, of the presumption of innocence and of the duty of care.