Labour Disputes
Texto da decisão
Decision of the
Dispute Resolution Chamber
passed in Zurich, Switzerland, on 10 April 2015,
in the following composition:
Thomas Grimm (Switzerland), Deputy Chairman
Jon Newman (USA), member
John Bramhall (England), member
Taku Nomiya (Japan), member
Mario Gallavotti (Italy), member
on the claim presented by the player,
Player A, country B,
as Claimant
against the club,
Club C, country D,
as Respondent
regarding an employment-related dispute arisen between the parties
I.
Facts of the case
1.
On 3 December 2012, the player from country B, Player A (hereinafter: the
Claimant), and the club from country D, Club C (hereinafter: the Respondent),
concluded an employment contract (hereinafter: the contract) valid as of 1 January
2013 until 31 May 2014. In addition, on 5 December 2013, both parties entered into
an agreement for the purchase of image rights (hereinafter: the agreement)
constituting “an additional and inextricable part of the contract of employment
dated 03/12/2012”.
2.
According to art. 2 of the contract, the Claimant was entitled to receive the
following remuneration:
- For the period 1 January 2013 – 31 May 2013: EUR 10,000 net payable in five equal
monthly instalments of EUR 2,000, “beginning on the 31/01/2013 and ending
31/05/13”;
- For the period 1 June 2013 – 31 May 2014: EUR 20,000 net, payable in ten equal
monthly instalments of EUR 2,000 “beginning on the 30/8/2013 and ending on
31/05/2014”.
3.
Moreover, the Exhibit 1 to the agreement provides for the following amounts:
- For the period 1 January 2013 – 31 May 2013: EUR 45,000 net payable as follows:
o “An advance of payment of EUR 20,000 payable until the 15th January 2013;
o 5 monthly instalments of EUR 4,000 net the first payable on the 30/01/2013 and
the remaining at the end of each following month until full payment;
o 5 monthly instalments of EUR 1,000 net the first payable on the 31/01/2013 and
the remaining at the end of each following month until full payment.”
- For the period 1 June 2013 – 31 May 2014: EUR 90,000 net as “Annual Image Rights
fee”.
4.
The contract contains the following stipulations:
“B. [The Claimant] is an experienced football player from country B.
C. [The Respondent] undertakes to register [the Claimant] as an EU football player
with the Football Association of country D according to FIFA and/or UEFA rules
applicable at the time of signing the present agreement.”
5.
In addition, art. 2 of the agreement stipulates that “[the Claimant] agrees to assign
to [the Respondent] all his image rights for all the period of this employment by [the
Respondent]”.
6.
Furthermore, art. 7 of the agreement states that “[the Respondent] will pay [the
Claimant] the sums, benefits and bonuses included in Exhibit 1 that is attached
hereto. It is agreed that the sums mentioned in Exhibit 1 will be paid with 90 days
grace period.”
Player A, country B / Club C, country D
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7.
On 30 January 2013, the Claimant sent a correspondence to the Respondent to
inform the latter that an amount of EUR 22,000, corresponding to the salary for
January and the advance of payment provided by the agreement, were
outstanding. In the same correspondence, the Claimant pointed out that he was
obliged to train isolated from the first team in unprofessional conditions, that the
Respondent prevented him from going to country E in order to see his newborn
child and that the disciplinary sanction imposed on him for unprofessional
behaviour on 28 January 2013 should be annulled for violation of his right to be
heard. Finally, the Claimant requested the Respondent to inform him whether he
was registered at the Football Association of country D.
8.
On 31 January 2013, the Respondent proposed the Claimant to terminate the
contract in exchange of a payment of EUR 15,000.
9.
On 6 February 2013, the Claimant refused the Respondent’s proposal. He also stated
that the Respondent forced him to train despite an injury and that the Respondent
authorised him to travel to country E but refused to deliver a written authorisation.
Therefore, he did not travel for fear of being deemed as being absent without
authorisation.
10.
On 7 February 2013, in its reply to the Claimant’s correspondence, the Respondent
acknowledged that the Claimant was never registered at the Football Association of
country D. In addition, the Respondent asserted that the Claimant signed a receipt
on 18 January 2013 confirming the payment of the advance of EUR 20,000 and
pointed out that the amounts set in the agreement are to be paid within a 90-day
grace period. Finally, the Respondent considered that it provided the Claimant with
professional training conditions and medical treatment.
11.
On 10 February 2013, the Claimant recognised having signed the aforementioned
receipt but sustained not having received the money. Furthermore, the Claimant
stressed that the lack of registration constituted a violation of the obligations
contained in the contract and requested the Respondent to regularise the situation.
12.
Subsequently, the Claimant addressed several correspondence to the Respondent
and the Football Association of country D requesting his registration; however, to
no avail. The Respondent only replied that it would continue to honour its
contractual obligations.
13.
On 2 March 2013, the Claimant lodged a claim against the Respondent before FIFA
requesting the following:
- the contractual relationship to be deemed as terminated with just cause;
- EUR 9,000 net as outstanding remuneration, composed of:
o EUR 2,000, plus 5% p.a. as of 31 January 2013 until the date of effective
payment, as outstanding monthly salary for January 2013 in accordance with
the contract;
Player A, country B / Club C, country D
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o EUR 2,000, plus 5% p.a. as of 28 January 2013 [sic] until the date of effective
payment, as outstanding monthly salary for February 2013 in accordance with
the contract;
o EUR 5,000, plus 5% interest as of 28 February 2013 until the date of effective
payment, as outstanding remuneration due in accordance with the agreement;
- EUR 131,000 net, plus 5% interest as of the due date until the date of effective
payment, as compensation, broken down as follows:
o EUR 26,000 corresponding to the residual value of the contract, i.e. salary from
March 2013 until May 2014;
o EUR 105,000 corresponding to the residual value of the agreement, i.e.
remuneration from March 2013 until May 2014.
- Sporting sanction to be imposed.
14.
In his claim, the Claimant first of all stresses that the Respondent failed to pay him
the salary for January and February 2013 as well as the remuneration due on 28
February 2013 in accordance with the agreement. Additionally, the Claimant states
that he was threatened and therefore forced to return the advance of payment of
EUR 20,000 but does not claim it due to a lack of evidence.
15.
Furthermore, the Claimant maintains that he did not benefit from professional
training conditions in spite of having been hired as “a professional football player”.
16.
In addition, the Claimant recalls that the Respondent refused to deliver him a
written authorisation to go back to country E.
17.
Moreover, the Claimant asserts that the Respondent’s behaviour showed its
intention of ending the contractual relationship. In this regard, the Claimant points
out the proposal to terminate the contract dated 31 January 2013. Then, the
Claimant refers to the fine imposed on him for an alleged unprofessional behaviour
before a game and questioned the basis of the fine since he could not have played
said game for lack of registration. In this respect, the Claimant also insists that
together with the notification of the fine, the Respondent informed him that the
Board of Directors would discuss whether his unprofessional behaviour should lead
to the termination of the contract. Finally, the Claimant sustains that the refusal to
register him clearly evidenced that the Respondent never counted on him, in
particular considering the content of the stipulation referred to in point 3 above.
18.
In light of the foregoing, the Claimant considers that he had a just cause to
terminate the contract.
19.
In its response, as a preliminary observation, the Respondent states that the claim
has to be dismissed since the event triggering the cause of action, i.e. the
termination, never occurred.
Player A, country B / Club C, country D
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20.
The Respondent further emphasises the Claimant’s failure to comply with his
obligations. In this regard, the Respondent asserts that the Claimant refused to train
with the reserve team, behaved unprofessionally by drinking alcohol very late at
night and showed complete disrespect to the Respondent’s officials. According to
the Respondent, the foregoing elements justified the fine imposed on the Claimant
and, since they demonstrated the Claimant’s will to leave the Respondent, justified
the proposal made on 31 January 2011.
21.
In continuation, the Respondent refers to its financial obligations and considers that
at the time of the claim, an amount of EUR 2,000, i.e. salary for January 2013, was
outstanding. According to the Respondent, it paid the advance of EUR 20,000 and
therefore, rejected the allegations of threats. Moreover, the Respondent states that
the amounts provided by the agreement were not yet due since the latter stipulates
that “It is agreed that the sums mentioned in Exhibit 1 will be paid with 90 days
grace period.”
22.
As concerns the alleged refusal to allow his return to country E, the Respondent
insists that it never did so and that in any case, such a decision is to be left to the
Respondent’s discretion.
23.
Subsequently, the Respondent asserts that the Claimant was treated as a
professional and further adds that the Claimant benefited from the same training
conditions as any of the Respondent’s professional players.
24.
As to the registration of the Claimant, the Respondent points out that it was agreed
during the contractual negotiations that as soon as the Claimant would have the
skills and experience to play officials games, he would be registered; however
during the 2012/2013 season, he still lacked the required abilities. Additionally, at
the time of the first Claimant’s correspondence, the deadline for registering new
players had already expired.
25.
Finally, the Respondent sustains that the Claimant left the country in February 2013
without notice and signed an employment contract with another club.
26.
Alternatively, should the DRC hold it liable for breach of contract, the Respondent
requests the Chamber to mitigate the compensation by considering the new
contract signed by the Claimant with Club F and the alleged offer made to it on 18
February 2013 by the club from country I, Club H, which consisted in a loan until 31
May 2013 with a monthly salary of EUR 7,000.
27.
In his replica, and in addition to his previous arguments, the Claimant rejects all the
allegations regarding his unprofessional behaviour and calls the evidence provided
by the Respondent into question, in particular the witness statements.
Player A, country B / Club C, country D
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28.
Additionally, the Claimant maintains that he put the Respondent in default several
times by means of the aforementioned correspondence and that the Respondent
was aware that he had left the country since he left the same day as he lodged the
claim.
29.
Finally, the Claimant states that the Respondent never informed him of the offer
received from the club from country I.
30.
In its duplica, the Respondent mainly refers to its previous argumentation while
clarifying some elements.
31.
Firstly, the Respondent asserts that until the date the Claimant decided to abandon
the Respondent, it had paid EUR 25,000, leaving EUR 9,000 outstanding. However,
out of the EUR 9,000, an amount of EUR 5,000 was due in accordance with the
agreement and therefore could be paid within a 90-day grace period. Additionally,
the Respondent considers that the fine of EUR 3,000 has to be deducted from the
outstanding remuneration.
32.
Moreover, the Respondent sustains that the Claimant breached the contract and the
agreement by leaving the country without previously terminating said agreements
and that it informed him about the offer received from the club from country I but
he refused it.
33.
Finally, the Respondent states that in case the DRC deems that it is to be held liable
for breach of contract, no sporting sanction should be imposed.
34.
On 8 March 2013, the Claimant and the club from country G, Club F, concluded an
employment contract, valid as of the date of signature until 1 December 2013 and
according to which the Claimant received a total remuneration of EUR 17,500. On
17 January 2014, the Claimant entered into an employment contract with the club
from country K, Club J, valid as of 22 January 2014 until 30 June 2014 and entitling
him to a total remuneration of 108,360. However, according to the Claimant, Club J
only paid him 20,000 for January and February 2014 and therefore, on 23 June 2014,
they decided to mutually terminate the contract. In accordance with the mutual
termination, Club J undertook to pay the Claimant an amount of 50,000 as follows:
- 25,000 on 31 July 2014;
- 25,000 on 31 August 2014.
II.
Considerations of the Dispute Resolution Chamber
1.
First of all, the Dispute Resolution Chamber (hereinafter referred to as the DRC
or the Chamber) analysed whether it was competent to deal with the matter
at stake. In this respect, it took note that the present matter was submitted to
Player A, country B / Club C, country D
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FIFA on 2 March 2013. Consequently, the 2012 edition of the Rules Governing
the Procedures of the Players’ Status Committee and the Dispute Resolution
Chamber (hereinafter: the Procedural Rules) is applicable to the matter at
hand (cf. art. 21 of the Procedural Rules).
2.
Subsequently, the members of the Chamber referred to art. 3 par. 1 of the
Procedural Rules and confirmed that in accordance with art. 24 par. 1 in
combination with art. 22 lit. b) of the Regulations on the Status and Transfer
of Players (edition 2015), the Dispute Resolution Chamber is competent to deal
with the matter at stake, which concerns an employment-related dispute with
an international dimension between a player from country B and a club from
country D.
3.
Furthermore, the Chamber analysed which regulations should be applicable as
to the substance of the matter. In this respect, it confirmed that in accordance
with art. 26 par. 1 and 2 of the Regulations on the Status and Transfer of
Players (edition 2015), and considering that the present claim was lodged in
front of FIFA on 2 March 2013, the 2012 edition of said Regulations
(hereinafter: Regulations) is applicable to the matter at hand as to the
substance.
4.
In continuation, with regard to the claimed payments in connection to the
image rights agreement apparently signed by the parties, the Chamber also
had to verify whether, for formal reasons, it was competent to deal with this
specific component or not. In fact it remains that this part of the claim could
possibly not be considered due to the Chamber lacking competence to deal
with disputes related to image rights.
5.
While analysing whether it was competent to hear this part of the claim, the
Chamber, without entering into any discussion regarding the actual wording
of art. 2 of the agreement nor its title itself, which undoubtedly defines the
agreement as an image rights agreement, wished to highlight that said
agreement contained further elements which led to believe that it was not in
fact an image rights agreement but rather a separate agreement to the
employment contract, i.e. directly linked to the services of the Claimant as a
player.
6.
As a general rule, if there are separate agreements, the DRC tends to consider
the agreement on image rights as such and does not have the competence to
deal with it. However, such conclusion might be different if specific elements
of the separate agreement suggest that it was in fact meant to be part of the
actual employment relationship. In the case at hand, such elements appear to
exist. In particular, art. 1 of the agreement states that “the parties agree that
this agreement shall be an additional and inextricable part of the contract of
employment dated 3/12/2012”.
Player A, country B / Club C, country D
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7.
In view of all the above, the Chamber established that the image rights
agreement is to be considered, meaning that it is in a position to take it into
consideration when assessing the Claimant’s claim.
8.
The competence of the DRC and the applicable regulations having been
established, the DRC entered into the substance of the matter. In doing so, it
started by acknowledging the abovementioned facts of the case as well as the
documentation contained in the file. However, the Chamber emphasised that
in the following considerations it will refer only to the facts, arguments and
documentary evidence, which it considered pertinent for the assessment of the
matter at hand.
9.
In this respect, the members of the Chamber acknowledged that the Claimant
and the Respondent had signed an employment contract on 3 December 2012,
valid as of 1 January 2013 until 31 May 2014 and according to which the
Claimant was entitled to a monthly salary of EUR 2,000. In addition, the
members of the Chamber took note that on 5 December 2012, the parties
entered into an agreement entitling the Claimant to a global amount of EUR
135,000.
10.
Moreover, the DRC observed that none of the parties expressly terminated the
employment relationship; however, the members of Chamber concurred that
by lodging on 2 March 2013 a claim in front of FIFA against the Respondent,
for breach of contract and requesting the contract and the agreement to be
deemed as terminated with just cause, the Claimant de facto terminated the
contractual relationship. In view of the above, the Chamber held that 2 March
2013 must be considered as date of termination.
11.
In continuation, the Chamber noted that the Claimant lodged a claim against
the Respondent maintaining that the Respondent had breached the contract
by showing no interest in his services. In particular, the Claimant outlines that
the Respondent failed to pay him two monthly salaries as well as the
instalment due on 28 February 2013 in accordance with the agreement,
refused to register him at the federation, imposed on him an unjustified fine
and did not provide him with professional training conditions.
12.
Thereafter, the members of the Chamber took note of the reply of the
Respondent, which acknowledges not having registered the Claimant but
alleges that it would have done so as soon as the Claimant would have the
skills and experience to play official games. In addition, the DRC observed that
the Respondent asserts that the fine was justified by the unprofessional
behaviour of the Claimant. Finally, the Chamber noted that the Respondent
considers that it is actually the Claimant who breached the contract and the
agreement by leaving the country without notice.
Player A, country B / Club C, country D
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13.
Subsequently, the Chamber recalled that the Claimant had on various
occasions requested the Respondent to comply with its obligation of
registering him. However, and in spite of these requests, the members of the
Chamber observed that the Respondent acknowledged that it had never
registered the Claimant at the Football Association of country D but justified it
by his lack of skills and abilities.
14.
In this respect, the Chamber referred to stipulation C of the contract which
provides that “[t]he Respondent] undertakes to register [the Claimant] as an
EU football player with the Football Association of country D according to FIFA
and/or UEFA rules applicable at the time of signing the present agreement”.
15.
In light of the above, the members of the Chamber considered important to
point out, as has been previously sustained by the DRC, that among a player’s
fundamental rights under an employment contract, is not only his right to a
timely payment of his remuneration, but also his right to access training and to
be given the possibility to compete with his fellow team mates in the team’s
official matches.
16.
This led the Chamber to conclude that by refusing to register the Claimant, in
spite of its express commitment to do so, the Respondent is effectively barring,
in an absolute manner, the potential access of the Claimant to competition
and, as such, is violating one of his fundamental rights as a football player.
17.
The DRC further referred to art. 12 par. 3 of the Procedural Rules, in
accordance with which any party claiming a right on the basis of an alleged
fact shall carry the burden of proof, and pointed out that the Respondent had
failed to present documentation evidencing that it had paid the Claimant’s
salaries for January and February 2013.
18.
As far as the claimed instalment due in accordance with the agreement is
concerned, the Chamber deemed it fit to emphasise that clause 7 of the aforementioned agreement provides for a grace period of 90 days in order to
comply with the obligations set therein. In view of the foregoing, the DRC
concluded that the instalment due for February 2013 in accordance with said
agreement had not fallen due yet on the date of termination and was
therefore not outstanding when the Claimant de facto terminated the
contract, i.e. on 2 March 2013.
19.
Reverting to the Respondent’s request to set off the fine imposed on the
Claimant against his outstanding remuneration, the DRC referred to art. 12
par. 3 and 6 of the Procedural Rules and held that the Respondent did not
submit any reliable evidence proving that the Claimant had actually behaved
in such an unprofessional manner justifying a fine of EUR 3,000. Therefore, the
members of the Chamber decided to reject the Respondent’s request in this
regard.
Player A, country B / Club C, country D
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20.
In view of the above considerations, the Chamber concluded that an amount
of EUR 4,000, corresponding to the salaries for January and February 2013, was
outstanding on the date of termination, i.e. 2 March 2013.
21.
Furthermore, the DRC wished to highlight that on 31 January 2013, the
Respondent proposed to terminate the contract in exchange for the payment
of EUR 15,000.
22.
On account of all the above circumstances, and in particular considering the
failure to register the Claimant, the outstanding salaries as well as the
Respondent’s proposal to terminate the contract, the Chamber established
that the Respondent had no longer been interested in the Claimant’s services.
Such conduct constitutes, in the Chamber’s view, a clear breach of contract.
Consequently, the Chamber concurred the Respondent is to be held liable for
the early termination of the employment contact with just cause by the
Claimant.
23.
Having established that the Respondent is to be held liable for the early
termination of the employment contract with just cause by the Claimant, the
Chamber focused its attention on the consequences of such termination.
Taking into consideration art. 17 par. 1 of the Regulations, the Chamber
decided that the Claimant is entitled to receive from the Respondent an
amount of money as compensation for breach of contract in addition to any
outstanding salaries on the basis of the relevant employment contract.
24.
First of all, reverting to the Claimant’s financial claim, the DRC made reference
to its previous considerations and recalled that at the time of the termination,
i.e. on 2 March 2013, the salaries for January and February 2013 were
outstanding.
25.
Consequently, in accordance with the principle of pacta sunt servanda, the
Chamber decided that the Respondent is liable to pay the Claimant the
amount of EUR 4,000 as outstanding remuneration corresponding to the
salaries relating to January and February 2013.
26.
In addition, taking into consideration the Claimant’s claim, the Chamber
decided that the Respondent had to pay default interest at a rate of 5% as
follows:
-
27.
5% p.a. as of 1 February 2013 on the amount of EUR 2,000;
5% p.a. as of 1 March 2013 on the amount of EUR 2,000.
In continuation, the Chamber focused its attention on the calculation of the
amount of compensation for breach of contract in the case at stake. In doing
so, the members of the Chamber firstly recapitulated that, in accordance with
Player A, country B / Club C, country D
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art. 17 par. 1 of the Regulations, the amount of compensation shall be
calculated, in particular and unless otherwise provided for in the contract at
the basis of the dispute, with due consideration for the law of the country
concerned, the specificity of sport and further objective criteria, including, in
particular, the remuneration and other benefits due to the Claimant under the
existing contract and/or the new contract, the time remaining on the existing
contract up to a maximum of five years, and depending on whether the
contractual breach falls within the protected period.
28.
In application of the relevant provision, the Chamber held that it first of all
had to clarify as to whether the pertinent employment contract contains a
provision by means of which the parties had beforehand agreed upon an
amount of compensation payable by the contractual parties in the event of
breach of contract. In this regard, the Chamber established that no such
compensation clause was included in the employment contract at the basis of
the matter at stake.
29.
As a consequence, the members of the Chamber determined that the amount
of compensation payable by the Respondent to the Claimant had to be
assessed in application of the other parameters set out in art. 17 par. 1 of the
Regulations. The Chamber recalled that said provision provides for a nonexhaustive enumeration of criteria to be taken into consideration when
calculating the amount of compensation payable.
30.
Bearing in mind the foregoing as well as the claim of the Claimant, the
Chamber proceeded with the calculation of the monies payable to the
Claimant under the terms of the contract and the agreement until 31 May
2014, taking into account that the Claimant’s remuneration which had fallen
due up until 2 March 2013 is included in the calculation of the outstanding
remuneration. Therefore, the Chamber held that the remuneration due as of
March 2013 until 31 May 2014 should be taken into consideration to figure out
the amount due as a compensation for breach of contract. In view of the
above, the Chamber concluded that the amount of EUR 136,000 shall serve as
the basis for the final determination of the amount of compensation for
breach of contract
31.
In continuation, the Chamber verified as to whether the Claimant had signed
an employment contract with another club during the relevant period of time,
by means of which he would have been able to reduce his loss of income.
According to the constant practice of the DRC, such remuneration under a new
employment contract shall be taken into account in the calculation of the
amount of compensation for breach of contract in connection with the player’s
general obligation to mitigate his damages.
Player A, country B / Club C, country D
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32.
The Chamber noted that according to the Respondent’s declarations and the
documentation submitted, the Claimant concluded two employment contracts
in the relevant period, according to which the Claimant received a total
remuneration of EUR 34,300, i.e. EUR 17,500 plus 70,000, which corresponds to
EUR 16,800.
33.
In accordance with the constant practice of the Dispute Resolution Chamber
and the general obligation of the player to mitigate his damages, such
remuneration under the new employment contract shall be taken into account
in the calculation of the amount of compensation for breach of contract.
34.
In view of all of the above, the DRC decided that the Respondent must pay the
amount of EUR 101,700 to the Claimant, which is considered by the DRC to be
a reasonable and justified amount as compensation for breach of contract.
35.
In addition, taking into account the Claimant’s request, the Chamber decided
that the Respondent must pay to the Claimant interest of 5% p.a. on the
amount of compensation as of the date on which the claim was lodged, i.e. 2
March 2013, until the date of effective payment.
36.
The Dispute Resolution Chamber concluded its deliberations in the present
matter by establishing that any further claim lodged by the Claimant is
rejected.
**********
III.
Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Player A, is partially accepted.
2.
The Respondent, Club C, has to pay to the Claimant, within 30 days as from the
date of notification of this decision, outstanding remuneration in the amount of
EUR 4,000 plus 5% interest p.a. until the date of effective payment as follows:
a. 5% p.a. as of 1 February 2013 on the amount of EUR 2,000;
b. 5% p.a. as of 1 March 2013 on the amount of EUR 2,000.
3.
The Respondent has to pay to the Claimant, within 30 days as from the date of
notification of this decision, compensation for breach of contract amounting to
EUR 101,700 plus 5% interest p.a. on said amount as from 2 March 2013 until the
date of effective payment.
4.
In the event that the amounts plus interest due to the Claimant in accordance
with the above-mentioned points 2. and 3. are not paid by the Respondent within
the stated time limits, the present matter shall be submitted, upon request, to the
FIFA Disciplinary Committee for consideration and a formal decision.
Player A, country B / Club C, country D
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5.
Any further claim lodged by the Claimant is rejected.
6.
The Claimant is directed to inform the Respondent immediately and directly of the
account number to which the remittances are to be made and to notify the
Dispute Resolution Chamber of every payment received.
*****
Note relating to the motivated decision (legal remedy):
According to art. 67 par. 1 of the FIFA Statutes, this decision may be appealed
against before the Court of Arbitration for Sport (CAS). The statement of appeal
must be sent to the CAS directly within 21 days of receipt of notification of this
decision and shall contain all the elements in accordance with point 2 of the
directives issued by the CAS, a copy of which we enclose hereto. Within another 10
days following the expiry of the time limit for filing the statement of appeal, the
appellant shall file a brief stating the facts and legal arguments giving rise to the
appeal with the CAS (cf. point 4 of the directives).
The full address and contact numbers of the CAS are the following:
Court of Arbitration for Sport
Avenue de Beaumont 2
1012 Lausanne
Switzerland
Tel: +41 21 613 50 00
Fax: +41 21 613 50 01
e-mail: [email protected]
www.tas-cas.org
For the Dispute Resolution Chamber:
Markus Kattner
Acting Secretary General
Encl. CAS directives
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