Eight of his former footballers filed a complaint with the EPO Mars requesting that his participation in the league not be allowed and that the transfers and new Sports Identity Cards of his professional footballers not be approved by the EIP/EPO, citing debts and court decisions. In addition, they state that if their request is not accepted, they will report the EPO to FIFA and will appeal to the civil courts.
His application-complaint, which is shared with many recipients, states the following:
TO
1. THE EXECUTIVE COMMITTEE OF THE EPO,
2. THE EPO COMMITTEE OF EMERGENCY ISSUES,
3. THE FOOTBALL PLAYERS QUALIFICATIONS COMMITTEE OF THE EPO.
COMMUNICATION TO:
1. PROFESSIONAL FOOTBALL COMMITTEE OF THE EPO,
2. EPO FOOTBALL ARBITRATION COURT,
3. LICENSING DEPARTMENT OF THE EPO,
4. PROFESSIONAL SPORTS COMMITTEE OF GA,
5. SUPER LEAGUE 1,
6. PSAPP
A I T I S H – K A T A G G E L I A
1. Of Efthimios Kouloucheris,
2. Of Konstantinos KAPETANOS,
3.Grigoriou PAPAZACHARIA,
4. By Emmanuel PAPASTERIANOU,
5. Stylianos Tsoukani,
6. By Michael KYRGIA,
7. By Ricardo FATY,
8. By Ronaldo GUIARO,
All former professional football players, members of the KEP,
residents for performance, Favierou 47, Athens
K A T A
The Sports Successor Football Joint-Stock Company with the name “THESSALONIKI SPORTS ASSOCIATION O ARIS PAE” which is based in Thessaloniki and is legally represented.
Mr. President – Honorable members,
As you know, we are former professional football players of PAE ARIS, having even played in the team for the SUPER LEAGUE championship before being relegated to amateur football.
Because our contract was violated, we appealed to your arbitration committees and although we were vindicated, under the responsibility of the EPO, we could not execute their decisions.
Unfortunately, a number of our out-of-court and judicial actions, in which we proceeded through our attorneys, had the same fate.
But it seems that the Divine Trial by Themis of the Round Goddess, led both the FIFA Disciplinary Committee, and the renewed “Football Areopagus”, the Areopagite Football Arbitration Court, to restore Justice and Legitimacy to the long-suffering area of ​​the professional football.
In particular, these two football bodies, in a series of decisions, RECOGNIZED THE SPORTING SUCCESSION AND OBLIGED THE PAE ARIS, IRAKLIS, PANACHAIKI, ASPROPYRGOS, VEROIA, IONIKOS, OFI, etc. TO PAY THE OBLIGATIONS OF THE OLD PAE TO ITS FORMER FOOTBALL PLAYERS S.
And while with regard to the decisions of FIFA, despite the non-compliance of the EPO and its bodies, PAE ARIS and ASPROPYRGOS were forced to pay the footballers after the imposition of severe disciplinary penalties, on the contrary with regard to the decisions of the Court of Arbitration for Football of the EPO, the PAE ARIS refuses to execute them.
For your full information, we refer you to the decisions of the Football Arbitration Court of the EPO that were issued on our requests, which did not accept our request to impose the penalty of points deduction, but accepted that:
A. THE NEW PAE (ARIS) IS A SPORTS SUCCESSOR OF THE OLD PAE!
B. THE NEW PAE (ARIS ) SERVES AT 50% LEGAL INTEREST ON THE DEBT OF THE OLD PAE AND IS OBLIGED TO PAY THE FOOTBALLER!
C. THE TIME LIMIT OF THE 2016-2017 PERIOD OF ARTICLE 111 OF LAW 2725 WHICH WAS LATER ADOPTED BY THE CAP AND THE LICENSING REGULATION DOES NOT AVOID THE ATHLETIC SUCCESSION!
BECAUSE the juggling trick of Abusiveness was invented by professionals – thieves of the football system which unfortunately under the tolerance of the previous administrations of the EPO WAS IMPOSED ON THE MAJORITY OF THE CLAIMS AND APPELLANTS of the previous compositions of the ITP to serve the then favored PAE.
BECAUSE after the 24.9.2023 amendment of the EPO Licensing Regulation at the behest of UEFA, in accordance with articles 71-73, the previous decisions of the ICC that recognized the sports succession, even if they were rejected as abusive, are essentially recognized as valid and enforceable applications for the imposition of penalties.
BECAUSE the EIP/EPO in the ad hoc case of the football players of PAE AO KAVALA recommended us to appeal to the Executive Committee of the EPO and the Committee of Extraordinary Issues for the implementation of article 66 par.17 of the EPO Statute.
BECAUSE several of our colleagues KONTOVAS-TRIANTAFYLLAKOS- WANGA- APOSTOLAKIS-MARA etc. have already been vindicated and received their earnings in Greece) and abroad SISTON, UBIDES etc., which constitutes unacceptable UNEQUAL TREATMENT OF US, according to CAS jurisprudence!
BECAUSE the above rationales of the REASONER of the irrevocable arbitral decisions of the ICC/EPO, according to the standing jurisprudence of the Supreme Court, PRODUCE JUDGMENT AND ARE BINDING ON THE PAE AND THE EPO!
BECAUSE the competent body, the Licensing Directorate of the EPO, despite our applications, complaints and announcements, REFUSES TO EXECUTE THE IRREVOCABLE DECISIONS OF THE ITC AND TO IMPLEMENT THE LICENSING REGULATION, IF WE DO NOT ALSO ISSUE A NEW RECOGNITION DECISION OF THE ITC.
BECAUSE THE DECISION OF THE IPC ON DECLARING PAE ARIS AS AN ATHLETIC SUCCESSOR IS ALREADY ERGA OMNES, so essentially a new appeal to the IPC for the self-evident will simply burden us with new fees, fees and fees, while PAE will gain more time .
BECAUSE the fact that the IPC did not impose the disciplinary penalty of deducting three points, due to alleged abuse, in no way means that the disciplinary penalties provided by your Bylaws cannot be imposed by your statutory bodies against the non-compliant successor GO!
BECAUSE ACCORDING TO ARTICLE 66, PARAGRAPH 17, REGARDING INCOME OF YOUR STATUTES:
“BEFORE THE START OF THE CHAMPIONSHIPS AND TO PARTICIPATE IN THEM, ALL THE TEAMS MUST HAVE PAID ALL THEIR OBLIGATIONS BY FINAL DECISIONS OF THE COMPETENT BODIES OF FIFA, THE COURT OF ARBITRATION FOR SPORTS (CAS) OF LAUSANNE AND THE EPO, TO FOOTBALL PLAYERS, COACHES , OTHER GROUPS, INTER-ORGANIZATION AUTHORITIES AND THE EPO.
PROMOTION TO A HIGHER CATEGORY OF TEAMS THAT HAVE NOT FULFILLED THE ABOVE OBLIGATIONS IS PROHIBITED.
THE EPO BY DECISION OF THE COMMITTEE OF EMERGENCY ISSUES OR THE EXECUTIVE COMMITTEE MAY REVOCATE THE VALIDITY OF SPORTS IDENTITY CARDS FOR PAES OR ASSOCIATIONS THAT HAVE NOT FULFILLED THE ABOVE OBLIGATIONS UNTIL THEY ARE IN COMPLIANCE.”
BECAUSE our invoked decisions of the ICC have IMMEDIATE BINDING EFFECT, so you must first order the withdrawal of the football players’ cards of the successor PAE ARIS until it respects the decisions and satisfies our demands and then, if it continues to not comply, ban the participation of PAE ARIS in the next championship of the season 2024-2025!
BECAUSE PAE ARIS must pay us at least 50% of capital, interest and expenses, as follows:
1. To the first of us the amount of €224,469 with legal interest, based on decisions 929/2011 of the PEEOD, 50/2014 of the TDD and 143/2020 of the IDD,
2. To the second of us, the amount of €315,000 with legal interest, based on decisions 161/2013 of the PEEOD and 137/2020 of the IPC,
3. To the third of us, the amount of €79,646 with legal interest, based on the decisions 298/2014 of the PEEOD and 138/2020 of the IDP,
4. To the fourth of us, the amount of €163,000 with legal interest, based on decisions 425/2014 of the PEEOD and 129/2020 of the IDP,
5. To the fifth of us, the amount of €20,560 with legal interest based on the decisions 90/2015 of the PEEOD and 178/2021 of the IDP,
6. To the sixth of us, the amount of €93,994 with legal interest based on decision 368/2015 of the PEEOD and 72/2021 of the IDP,
7. To the seventh of us, the amount of €834,450 with legal interest, based on decision 450/2012 of the PEEOD and 136/2020 of the ITP,
8. To the eighth of us, the amount of €300,000 with legal interest based on the decisions 144/2013 of the PEEOD and 171/2023 of the ITP.
BECAUSE after the notification of the out-of-court statement of 23 members of the KEP (including the first 3 of us) frankly, as a legal ultimatum, we are sending you the last warning before we appeal to FIFA, where we remind you that you will be found as defendants before the Disciplinary Commission after the punishment imposed on you in the DURMISAI case (which you would have avoided if the then ICC had accepted the additional intervention of our colleagues and upheld the decision of the EIP!).
FOR ALL THESE REASONS
WE ARE ASKING YOU
1. DO introduce our present application as a matter of priority at the next meeting of the Executive Committee,
2. To implement without delay our decisions of the PEEOD and the Football Arbitration Court of the EPO,
3. THAT the Licensing Directorate of the EPO be required to IMMEDIATELY EXECUTE THEM in accordance with the international Licensing Regulation, without the made in Greece invention of the new application for recognition of the sports succession,
4. Do not approve, through the EIP, the transfers and the new Sports Identity Cards of the professional football players of PAE ARIS until the IRREVOCABLE decision of the EPO Football Court of Arbitration is complied with,
5. Do not allow the participation of PAE ARIS in the new SUPER LEAGUE 1 championship, until it complies with the IRREVOCABLE decision of the ICC/EPO.
Besides,
WE DECLARE THAT:
A. WE WILL REPORT YOU TO THE FIFA DISCIPLINARY COMMITTEE ASKING FOR DISCIPLINARY PROSECUTION BY THE EPO AS A SUBJECT FOR DISRESPECT OF DECISIONS AND REGULATIONS.
B. WE WILL SEEK PROVISION OF LEGAL PROTECTION FROM THE COMPETENT CIVIL AND CRIMINAL COURTS.
P.S. PLEASE notify us via our attorney’s email of the decision that will be taken by your competent statutory bodies.
ATHENS 8.8.2024
THE ATTORNEY ATTORNEY
GEORGIOS P. PANAGOPOULOS
AMDSA 14162,
47 FAVIEROU STREET, ATHENS
Source: Sport Fm
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