Extrajudicial to EPO with notification to FIFA and UEFA they sent 24 former footballers, who are asking not to license ten PAEs, among them AEK, Aris and OFIif their claims are not paid or settled.
Here is the extrajudicial:
BEFORE ANY COMPETENT COURT,
PRIVATE AND DOMESTIC OR INTERNATIONAL
FOOTBALL INSTRUMENT
EXTERNAL STATEMENT – PROTEST – COMPLAINT – INVITATION WITH RESERVATION OF RIGHTS
1. By Christos Bourbous,
2. By Matias Ricardo VERON,
3. Of Alexandros PEROGAMBRAKIS,
4. Of Efthimios KOULOUCHERIS,
5. Of Konstantinos KAPETANOS,
6. By Michael KYRGIA,
7. Stylianos Tsoukani,
8. By Emmanuel PAPASTERIANOU,
9. By Grigoriou PAPAZACHARIAS,
10. By Ricardo FATY,
11. Pantelis Cafe,
12. Nikolaos ARABATZIS,
13. Of Lambros KEFALOUKOS,
14. By Marcello DAMIANO,
15. By Diogo SISTON,
16.By Kwame FRIMPONG,
17. Of Minas IOSIPOU,
18. Stylianos ILIADIS,
19. Vassiliou ANGELOPOULOU,
20. By Ronaldo GUIARO,
21. By Anastasios TRIANTAFYLLOU
22. Of Vassiliou BLETSA,
23. Stylianos TSOUKANI and
24. By Ioan Bogdan MARA.
of all former professional footballers, members of the KEP, residents for performance, 47 Favierou, Athens
AGAINST
1. The President of the EPO as Supervisor and Head of the Licensing Department of the EPO,
Mr. Panagiotis BALTAKOU,
2. The Head of the EPO Licensing Department,
Mr. Vasiliou SARAKIS
COMMUNICATION TO:
1. COMMITTEE FOR EMERGENCY ISSUES OF THE EPO,
2. EPO EXECUTIVE COMMITTEE,
3. CONTROL, GOVERNANCE AND COMPLIANCE COMMITTEE OF THE EPO,
4. EPO FOOTBALL ARBITRATION COURT,
5. UEFA
6. GENERAL SECRETARY OF FIFA,
Mrs. Fatma SAMURA,
7. HEAD OF REGULATORY ENFORCEMENT, FIFA, mr. Jacques BLONDIN
Mister President,
In continuation of our previous requests and because we still have not received a response to our request for your actions to the Licensing Department of the EPO, we submit our present joint request, in order to obtain at least internal enforceability of the decisions of the IPC.
BECAUSE the 1st to the 17th, as well as the 23rd of us, have issued decisions by the Single-Member Composition of the ICC, which, although in their ruling rejected the disciplinary part of our requests, through their reasoning they DIAGNOSED AND ACKNOWLEDGED THE EXISTENCE OF ATHLETIC SUCCESSION BETWEEN OF THE OLD AND NEW PAE (OFI-ARIS-AEK-PAS-LARISA-IONIKOS-AGALEONIK-VOLOS), CONSIDERING AT THE SAME TIME THAT THEY SERVED AS SUCCESSORS TO 50% OF THE DEBT, WHICH THEY ARE OBLIGATED TO PAY US!
BECAUSE the 18th-19th – 20th and 21st of us have issued corresponding decisions by the Three-Member Composition of the ICC, with exactly the same operative and reasoning as those of the Single-Member Composition on our applications against PAE POT O HERACLIS, PAE ARIS and PAE DIAGORAS.
BECAUSE the 20th and 22nd of us have issued exactly the same decision by the Five-member Composition of the ICC on our applications against PAE ARIS and PAE PAS GIANNINA.
BECAUSE the fact of the rejection of all 23 applications as ABUSIVE, in no way means that THE REASONING OF ALL THE DECISIONS WHICH ACKNOWLEDGED THE ATHLETIC SUCCESSION IS NOT BINDING ERGA OMNES and especially towards the services of the EPO, as it is obvious that the alleged abuse is imputable only in the specific remedy and disciplinary request of the imposition of penalties only to the ICC and cannot be extended to other means of execution that are addressed to other bodies through other appeals!
BECAUSE, as is well known, the 24th of us, even though he was fully vindicated by the Three-Member Composition of the ICC with the historic decision 41/2023, HE WAS NOT FULLY AND COMPLETELY PAID by the Sports Successor of PAE POT HERAKLIS and has asked you to NOT LICENSE THE PAE!
BECAUSE it is legally unthinkable for the Licensing Department and its Head, who has been a prominent member of the EPO’s Legal Service for years, to question the decisions of the Supreme Body of the EPO, the IPC and to demand new trials with new arguments between the same parties for the same cases on which a CONVICTION has been produced.
(And in fact at the expense of former footballers, like the 5th of us who has not only paid 4 times in fees but HAS ALREADY BEEN RECOGNIZED WITH 2 DECISIONS OF THE ATHLETIC SUCCESSION OF PAE ARIS and is unable to pay again, because recently even his house was confiscated of!)
BECAUSE articles 71-73 et seq. of the Licensing Regulation must be applied fairly and correctly and the Licensing Department must be obliged not to license PAE SUCCESSORS who have not paid off the debts to former footballers of previous PAEs, because the IPC has so far refused to issue acts that confirm that our existing decisions have created res judicata, regarding the existence of sports succession, and therefore it is in vain required to reintroduce them to the ICC with the same request and even with the payment of a new fee.
BECAUSE Mr. SARAKIS himself, recently representing the EPO as its attorney before the Athens Court of Appeal during the hearing of the Actions for Annulment of the decisions of the Arbitration Court submitted by Petros KANAKOUDIS and Ronaldo GUIARO, CONCLUDED THAT THE EPO AND ITS BODIES ONLY APPLY THEMSELVES INTERNATIONAL FOOTBALL REGULATIONS WHICH OVERCOME THE GREEK LAWS IN EACH CASE, concealing that in its regulations it has included in violation of the international regulatory framework OPPOSITE PROVISIONS OF THE SPORTS LAW with which it misleads the regular judges of the ICC.
BECAUSE the EIP / EPO itself with its decision number 245/2023 on the case of debts to 11 members of the KEP of the successor union of AO KAVALA which is pending before the Court of Appeals, ruled exactly the opposite of the official position it formulates in the courts, Mr. SARAKIS as her lawyer, considering that on the one hand the provisions of the EPO regulations and the sports law apply and not the international provisions, and on the other hand that according to article 66 par.17 of the EPO Statute “ALL TEAMS BEFORE THE START OF THE CHAMPIONSHIPS AND IN ORDER TO PARTICIPATE IN THEM, THEY MUST HAVE PAID ALL THEIR OBLIGATIONS FROM FINAL DECISIONS. THE EPO, BY DECISION OF THE EMERGENCY COMMITTEE OR THE EXECUTIVE COMMITTEE, MAY REVOCATE IT VALIDITY OF SPORTS IDENTITY CARDS FOR PAYE OR CLUB WHICH THEY HAVE NOT FULFILLED THE ABOVE FINANCIAL OBLIGATIONS UNTIL THEY ARE IN COMPLIANCE.”
BECAUSE a few days ago, the Athens Magistrates’ Court, following the footsteps of the Amarousi Magistrates’ Court, overruled the case law of the Areopagits of the ICC by acquitting 10 members of the KEP against PAE PANACHAIKI (for a case in fact where the ICC’s decision is also awaited), recognizing the sports succession even for debts of 2003 and rejecting the plea of ​​abusiveness!
WHEREAS, in the event that you grant our present request, it will be avoided to discuss all these cases again before the ICC.
BECAUSE WE HAVE ALREADY BEEN LISTED WITH THE LICENSING DEPARTMENT BY SUBMITTING UNTIL THE LEGAL DEADLINE OF 2/28/2024 OUR PETITIONS AND IRREVOCABLE ARBITRATION DECISIONS, IN ACCORDANCE WITH THE PROVISIONS OF THE CURRENT REGULATION.
BECAUSE YOU KNOW VERY WELL THAT IN CASE OF DOUBT, THE CORRESPONDING PROVISIONS OF THE INTERNATIONAL LICENSING REGULATION PREVAIL.
BECAUSE YOU ARE OBLIGATED TO IMPLEMENT FROM 1.3.2024 THE NEW FIFA REGULATIONS, AS WELL AS THE CIRCULARS OF THE GENERAL SECRETARY OF FIFA Mr. SAMURA WHICH YOU HAVE DILIGENTLY HIDDEN.
BECAUSE with your actions and omissions you violate the principle of equal treatment, since as you know all our foreign colleagues are not only vindicated by the competent bodies of FIFA but also collect 100% of their accrued legal interest, as required by the international regulation and for us.
BECAUSE you are hiding the recent decisions of FIFA and CAS that obliged even the amateur founding associations as successors to pay 100% of the debts of PAE AO KAVALA and RHODES to foreign individuals and legal entities.
BECAUSE according to an express provision of the new FIFA Disciplinary Code, IF YOU DO NOT IMPLEMENT THE REGULATIONS AND EXECUTE THE EXISTING DECISIONS WITHIN THREE MONTHS OF RECEIVING THIS, OUR AFFAIRS WILL AUTOMATICALLY BE TRANSFERRED TO THE COMPETENT BODIES OF FIFA.
FOR ALL THESE REASONS
And without prejudice to all our legal rights
WE PROTEST for the umpteenth time for your fraudulent acts and omissions by which you violate the Licensing Regulation by FAILING TO RESPECT THE DECISIONS OF THE IPC and
WE CALL YOU
1. To accept our present application,
2. To decide that the RECOGNITION OF ATHLETIC SUCCESSION HAS BEEN IRREVOCABLY DECIDED BY PAE OFI (for the 1st-3rd), PAE ARIS (for the 4th-10th and 20th), PAE AEK (for the 11th), PAE LARISA ( for the 12th), GO IONIKOS (for the 13th-15th), GO AEGALEO (for the 16th-17th) GO POT O HERACLES (for the 18th-19th and 24th), GO PAS (for the 22nd), GO DIAGORAS (for on the 21st) and PAE NIKI VOLOU (for the 23rd), which, based on sub. nos. 129/2020-138/2020-136/2021-36/2021-26/2021-131/2020-17/2021-132/2021-66/2021-25/2021-140/2021-152/2021-129/ 2021-130/2021-150/2021-144/2021-123/2021-108/2021-145/2021-107/2021-112/2021-40/2023-170/2023-171/2023, 172/2023 and 41/2023, have paid at least 50% of the debt towards us and are obliged to pay it to us.
3. DO NOT LICENSE THE PAE OFI-ARIS-AEK-AEL-IONIKOS-AEGALEO-POT HERAKLIS – PAS – NIKI VOLOU and DIAGORAS, if our demands are not paid or settled and
4. To communicate your decision to the EPO Licensing Department, the EPO Legal Service, the EPO Executive Committee and SUPER LEAGUE 1 and 2,
otherwise,
WE NOTIFY YOU that we will report you to the relevant international bodies requesting their immediate intervention, in accordance with the current international regulations and at the same time
WE WILL FILE LAWSUITS AND LAWSUITS AGAINST THE PRESIDENT OF THE EPO, THE CHIEF OF THE DEPARTMENT OF LICENSING AND AGAINST ANY OTHER OFFICIAL OF THE EPO WHO GUARANTEELY DAMAGED OUR PROPERTY RIGHTS.
Athens 26.4.2024
The Legal Advisor of KEP
and Attorney General
Georgios P. PANAGOPOULOS
Source: Sport Fm
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