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declare the present action admissible and well founded;

—

annul the decision of the EIB of 11 October 2018 by which the applicant was denied family benefits (including in particular day care and CPE costs unduly deducted by the EIB from the salary of the applicant until November 2019) and derived financial rights (including in particular tax reliefs and reimbursement of the medical expenses of the applicant’s dependent children);

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if necessary, annul the letter/decision of 7 January 2019 rejecting all of the applicant’s requests;

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if necessary, annul the decision of the EIB dated 30 July 2020 noting the lack of reconciliation and confirming the decision of 11 October 2018;

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provide compensation for the material and non-material harm suffered by the applicant;

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order the defendant to pay the entirety of the costs.

1.

First plea in law, alleging infringement of the right to be heard.

2.

Second plea in law, alleging breach of the obligation to state reasons.

3.

Third plea in law, alleging a manifest error of assessment. In the alternative, the applicant raises a plea of illegality in respect of the administrative provisions relating to family allowances, on the ground that they are contrary to the principles of equal treatment and proportionality.

4.

Fourth plea in law, alleging, first, infringement of Article 3(4) of Regulation (EEC, Euratom ECSC) No 260/68 of the Council of 29 February 1968 laying down the conditions and the procedure for applying the tax for the benefit of the European Communities (OJ L 56, p. 8) and, second, a manifest error of assessment.

5.

Fifth plea in law, alleging infringement of Article 4(1) of Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data, and repealing Regulation (EC) No 45/2001 and Decision No 1247/2002/EC (OJ 2018, L 295, p. 39), infringement of Article 12 of the Staff Regulations and infringement of the principle of sound administration and of the duty of care. In support of that plea, the applicant argues that his personal data were accessed illegally, that the defendant refused to open an investigation and that the latter unduly supported his ex-spouse.

6.

Sixth plea in law, alleging infringement of Article 41 of the Staff Regulations, of the principle of sound administration and of the duty of care.