Labour Disputes
Texto da decisão
Decis ion of the
Dis pute Res olution Cham ber
passed in Zurich, Switzerland, on 14 June 2019,
in the following composition:
on the matter between the player,
Play er A, Country B
as Claimant / Counter-Respondent
and the club,
Club C, Country D
as Respondent / Counter-Claimant
and the club,
Club E, Country B
as second Counter-Respondent
regarding an employment-related dispute
arisen between the parties
I.
Facts of the cas e
1.
On 11 June 2015, the Player of Country B, Player A (hereinafter; the player or the
Claimant/Counter-Respondent) and the Club of country D, Club C (hereinafter; the
club or the Respondent/Counter-Claimant) entered into an employment contract valid
as of the date of signature until 15 June 2018.
2.
The contract provided for a salary payable to the player in the total amount of EUR
12,000,000 broken down as follows:
- EUR 4,500,012 as “advance payment” payable in three equal instalments of EUR
1,500,004 on 30 August of 2015, 2016 and 2017 respectively;
- EUR 208,333 as monthly salary payable at the end of the month from “July 2015
through June 2018”.
3.
Art. 5.2 of the contract stipulates certain bonuses to which the player was entitled, in
particular, the following:
- If the player participates “in over 50% of the matches of the Tournament X on
the then current season, in the event Club C becomes the winner…” the player
was entitled to USD 200,000 payable on 30 June of “the then current year”
provided that, at that point, the player is “employed by Club C”;
- If the player participates “in over 80% of Club C’s official matches of the Country
D Sports Season 2015/2016, Club C shall, on 30 July 2016, pay to the player a onetime bonus of EUR 200,000”. The same conditional bonus applied for the seasons
2016/2017 and 2017/2018, however increased to EUR 300,000 for the former
(payable on 30 July 2017) and to EUR 400,000 for the latter (payable on 30 June
2018).
4.
Furthermore, art. 5.4 stipulated that the club “will provide reasonable suitable
furnished” accommodation to the player.
5.
According to art. 11.2 of the contract, both parties were entitled to terminate the
contract “upon 15 days-notice in writing for just cause according with the FIFA
Regulations”.
6.
Pursuant to art. 11.5 “…the Parties hereby expressly and irrevocably agree that in the
event that Club C terminates this contract with just cause (…) and/or the player
terminates this contract without just cause (…), the player shall promptly pay to Club
C, as compensation for the breach, the amount of EUR 9,000,000”. Furthermore, art.
11.6 reads: “In the event that Club C terminates this contract without just cause (…)
Club C shall be liable to pay to the player, as full and final breach of contract
compensation, the remaining value of the contract”.
Player A, Country B / Club C, Country D/ Club E, Country B
Page 2 of 13
7.
Art. 13.1 provides that “Any notice given by any of the parties hereto shall be
sufficient only if in writing and delivered in person, by facsimile or through courier
with acknowledgement of delivery to the address of the recipient”.
8.
On 22 March 2016, the player addressed a letter to the club explaining that the day
before he was asked to sign a confirmation letter in which it was stated that the club
owed him the amount of EUR 750,002 as part of the advance payment due on 30
August 2015 (“the first advance payment”), which was going to be paid on 1 August
2016.
9.
The player further claimed in said letter that the confirmation had been signed
“under duress” “in the locker room”. As such, the player put the club in default of
payment of the outstanding part of the first advance payment, as well as his salaries
for the months of January and February 2016 in the amount of EUR 208,333 each.
10.
On the same date, the club replied arguing that the salary of January 2016 had been
already paid, that the one of February was “under process” and that the part of the
first advance payment “will be paid as per the confirmation letter”.
11.
A further letter was sent by the player on the same date acknowledging receipt of
the payment of his January 2016 salary.
12.
On 3 June 2016, the player sent a second default notice to the club alleging that, in
addition to part of the first advance payment, his salaries for the months of March,
April and May 2016 were outstanding. The player gave the club a deadline until 9
June 2016 to remedy the default.
13.
On 6 September 2016, a third default notice was sent. In this letter, the player
requested the payment of part of the first advance payment, the entire advance
payment due on 30 August 2016 ("the second advance payment”) as well as certain
bonuses provided in art. 5.2 of the contract; all for a total amount of EUR 2,450,004
and USD 200,000. A further letter was sent by the player on 16 December 2016
granting the club 10 days to cure the default.
14.
On 2 January 2017, the player notified the club of his decision to terminate the
contract allegedly with just cause. The player based the termination on the amount
that was outstanding at that point, namely, EUR 3,168,004 and USD 200,000
comprised of (part of) the first advance payment, the second advance payment, his
salaries for the months of October, November and December 2016, bonuses and
“housing costs”.
Player A, Country B / Club C, Country D/ Club E, Country B
Page 3 of 13
15.
On 17 February 2017, the player lodged a claim in front FIFA against the club
maintaining that the club shall be held liable for the early termination of the contract
and requested payment of the following monies:
- EUR 750,002 corresponding to half of the first advance payment;
- EUR 1,500,004 corresponding to the second advance payment;
- EUR 624,999 corresponding to the salaries as of October until December 2016;
- EUR 200,000 as bonus related to match appearances during the 2015/2016 season;
- USD 200,000 as bonus related to the victory of the Tournament X in 2016;
- EUR 95,430 as reimbursement of accommodation costs;
- EUR 9,000,000 as compensation for breach of contract as per art. 11.5 and 11.6 of
the contract or alternatively EUR 5,249,994 as compensation corresponding to the
residual value of the contract.
In addition, the player requested 5% interest p.a. as of the respective due dates
on the outstanding remuneration.
16.
In his claim, the player maintained that he terminated the contract with just cause
due to the club’s nonfulfillment of its financial obligations. In this context, the player
pointed out that the amount of EUR 3,302,437 remained outstanding. The player
underlined that said amount corresponds to “almost ten monthly salaries”.
17.
Furthermore, the player held that he put the club in default and granted it 17 days to
remit the outstanding receivables before terminating the contract.
18.
In support of his claim regarding the reimbursement of the accommodation costs in
the total amount of EUR 95,430, the player submitted a “Tenancy Agreement” dated
25 February 2016, according to which the player needed to pay the total amount of
375,000 (approx. EUR 93,000) for the period of 12 months. In this context, and in
connection with art. 5.4 of the contract, the player held that the club failed to pay his
rent although he was contractually entitled to such reimbursement.
19.
The player also referred to art. 11.5 and 11.6 of the contract and requested
compensation for breach of contract in the total amount of EUR 9,000,000, as he
deems that art. 11.5 of the contract shall be applied reciprocally.
20.
In the alternative, the player requested compensation in the amount of EUR
5,249,994 corresponding to the residual value of the contract.
21.
In its reply, the club rejected the player’s claim and requested the payment of
compensation for breach of contract in the amount of EUR 9,000,000.
22.
Furthermore, the club requested that the Club of Country B, Club E (hereinafter; Club
E) shall be held jointly and severally liable for the payment of compensation and that
sporting sanctions shall be imposed on the player as well as on Club E.
Player A, Country B / Club C, Country D/ Club E, Country B
Page 4 of 13
23.
In particular, the club held that the player terminated the contract without just cause
by signing a contract with Club E, alleging that all the notifications sent by the player,
including the termination of the contract, were “irregular” and therefore “null and
void”.
24.
In particular, the club argued that the player’s notifications were not in accordance
with the formal requirements of art. 13.1 of the contract. Moreover, the club
maintained that the player did not comply with art. 11.2 of the contract as he only
gave a 10 instead of a 15 days’ notice.
25.
Alternatively, in case the DRC would decide that the notices sent by the player were
in line with the contract, the club argued that the player had no just cause to
terminate since the player failed to “produce any evidences that late payments could
severely endanger his position and existence”.
26.
In this regard, the club acknowledged a debt towards the player in the amount of
EUR 1,983,095, but insisted on being late 5 months only and not 1.5 years as argued
by the player. What is more, according to the club, the second advance payment
should not be considered as being due on a specific date but rather it is to be
understood as an advance payment payable throughout the second year of the
contract.
27.
The club further argued that the player terminated the contract in bad faith, since
the club “has done everything to find solutions” during the Christmas holidays in
order to avoid a termination and that a meeting with the player’s agent was
scheduled for 2 January 2017. Instead, the player decided to terminate the contract
and to sign a new contract with Club E.
28.
“Very alternatively”, in case the DRC concludes that the player had just cause to
terminate the contract, the club requested to reduce the compensation claimed by
the player. In this regard, the club held that there is no provision in the contract
defining the compensation for the player in case of a breach by the club.
29.
In this context, the club requested to reject the player’s claim for compensation in the
amount EUR 9,000,000 and to deduct the remuneration he earned according to the
new contract.
30.
In his reply to the counterclaim, the player first highlighted that the club
acknowledged owing him half of the advance payment due on 1 August 2015, the
salaries as of October until December 2016, the bonus related to match appearances
during the 2015/2016 season as well as the bonus related to the victory of the
Player A, Country B / Club C, Country D/ Club E, Country B
Page 5 of 13
Tournament X in 2016. As such, the player considered that the counterclaim lodged
by the club is completely illegitimate and should thus be dismissed.
31.
Furthermore, the player emphasised that the club did not challenge having received
his default notices and replied to some of them. Therefore, the allegation that the
default notices are to be disregarded is without merit.
32.
Finally, the player reiterated all the arguments of his reply.
33.
In its reply to the counterclaim, Club E stressed that “it is beyond any doubt that the
club failed to pay the player a substantial amount…”. Club E emphasised that the
club recognised owing “more than 49.5% of the total remuneration due to the
player” in accordance with the contract.
34.
As to the termination of the contract, Club E emphasised that the player gave the
club a de facto deadline of 17 days.
35.
On account of the above, Club E requested the rejection of the counterclaim
36.
Upon request, the player informed FIFA that his contract with Club E was valid as of 5
January 2017 until 31 December 2019 and that he was entitled to a monthly salary of
300,000 until December 2017 (approx. EUR 88,000) and as of January 2018 of 395,000
(approx. EUR 120,000).
II.
Cons iderations of the Dis pute Res olution Cham ber
1.
First, the Dispute Resolution Chamber (hereinafter also 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 FIFA on 17 February
2017. Consequently, the 2017 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 (editions 2016, 2018
and 2019), 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 of Country B, a Club of Country D and a Club of Country
B.
Player A, Country B / Club C, Country D/ Club E, Country B
Page 6 of 13
3.
In this respect, the Chamber was eager to emphasize that contrary to the information
contained in FIFA’s letter dated 7 June 2019, sent on 12 June 2019, by means of which
the parties were informed of the updated composition of the Chamber, the members
Johan van Galen and Stefano La Porta refrained from participating in the
deliberations in the case at hand, as the member Johan van Galen was unable to
attend the meeting due to certain personal circumstances. In order to comply with
the prerequisite of equal representation of club and player representatives, also
the member Stefano La Porta refrained from participating in the meeting and thus
the Dispute Resolution Chamber adjudicated the case in presence of three members
in accordance with art. 24 par. 2 of the Regulations.
4.
In continuation, the Chamber analysed which edition of the Regulations on the Status
and Transfer of Players should be applicable as to the substance of the matter. In this
respect, the Chamber confirmed that in accordance with art. 26 par. 1 and 2 of the
Regulations on the Status and Transfer of Players (editions 2016, 2018 and 2019), and
considering that the Claimant’s claim was lodged on 17 February 2017, the 2016
edition of the aforementioned regulations (hereinafter; the Regulations) is applicable
to the matter at hand as to the substance.
5.
The competence of the Chamber and the applicable regulations having been
established, and entering into the substance of the matter, the Chamber started by
acknowledging the above-mentioned facts 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.
6.
In so doing, the members of the Chamber first noted that on 11 June 2015 the player
and the club concluded an employment contract valid as from the date of signature
until 15 June 2018.
7.
Subsequently, the Chamber acknowledged that the contract was terminated by the
player in writing on 2 January 2017.
8.
The members of the Chamber then took note of the player’s claim who argues having
terminated the contract with just cause on 2 January 2017. In particular, the player
claims that in spite of his default notices, on the date of termination the club owed
him the total amount of EUR 3,170,435 and USD 200,000 as outstanding
remuneration, corresponding to half of the first advance payment, the entire second
advance payment, his salaries as of October until December 2016, bonuses related to
match appearances during the 2015/2016 season and to the victory of the
Tournament X in 2016, as well as the reimbursement of accommodation costs. Thus,
in addition to his outstanding remuneration, the player claims from the club the
payment of compensation for breach of contract.
Player A, Country B / Club C, Country D/ Club E, Country B
Page 7 of 13
9.
The members of the Chamber equally took note of the argumentation of the club,
which acknowledged owing most of the amounts requested by the player, while
explicitly objecting to the payment of the second advance payment, which it deems
to be payable not on a specific date but throughout the duration of the contract. In
spite of acknowledging a great part of the debt, the clubs deems that the player
terminated the contract without just cause, as the default notices were not made in
accordance with clauses 11.2 and 13.1 of the contract and must therefore be
disregarded. Finally, the club lodged a counterclaim against the player and his new
club, Club E, for breach of contract without just cause and inducement to breach,
respectively, claiming from both parties the payment of compensation.
10.
Finally, the Chamber took note of Club E’s position, which deems that the player
terminated the contract with just cause, pointing out specifically that the club
acknowledged owing “more than 49.5% of the total remuneration due to the
player” and that the termination was made in accordance with the terms of the
contract.
11.
On account of all the above, the Chamber highlighted that the underlying dispute in
the present matter was to determine whether the employment contract had been
prematurely terminated with or without just cause by the player. In so doing, the
Chamber proceeded with an analysis of the circumstances surrounding the present
matter, the parties’ arguments as well the documentation on file, bearing in mind 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.
12.
The members of the Chamber equally deemed appropriate to remark the general
principle that contracts ought to be respected, as otherwise, consequences have to be
assumed by the relevant party. Further, the DRC took into consideration the content
of art. 14 of the Regulations, which provides that “a contract may be terminated by
either party without consequences of any kind (either payment of compensation or
imposition of sporting sanctions) where there is just cause”.
13.
The Chamber stressed that the definition of just cause and whether just cause exists
shall be established in accordance with the merits of each particular case.
14.
Furthermore, the Chamber recalled its longstanding and well established
jurisprudence which indicates that only a breach or misconduct which is of a certain
severity justifies the termination of a contract. In other words, only when there are
objective criteria which do not reasonably permit to expect a continuation of the
employment relationship between the parties, a contract may be terminated
prematurely. A premature termination of an employment contract can only ever be
an ultima ratio measure.
Player A, Country B / Club C, Country D/ Club E, Country B
Page 8 of 13
15.
With the above-mentioned principles in mind, the Chamber first stressed that the club
acknowledges owing the player outstanding remuneration in the amount of EUR
1,983,095, however it deems that the termination of the contract and the default
notices have to be disregarded as they were not made in accordance with clauses 11.2
and 13.1 of the contract. At this point, the DRC deemed it appropriate to refer to the
content of the aforementioned clauses. According to art. 11.2 of the contract, both
parties were entitled to terminate the contract “upon 15 days-notice in writing for
just cause according with the FIFA Regulations”. Art. 13.1 provides that “Any notice
given by any of the parties hereto shall be sufficient only if in writing and delivered in
person, by facsimile or through courier with acknowledgement of delivery to the
address of the recipient”.
16.
With that in mind, the Chamber noted that the ratio behind the formal requirements
outlined in the aforementioned clauses was to ensure that any of the parties was
effectively made aware of possible violations of their contractual obligations and
given the opportunity to, in a reasonable period of time, remedy the default and
preserve the employment relationship. In this respect, the Chamber pointed out that
it is undisputed that the default notices of the player – as well as the termination –
have been received by the club, which even replied to some of them. Furthermore, a
considerable amount of remuneration has remained outstanding for several months,
given that the first default notice was issued on 22 March 2016 and that the contract
was terminated by the player on 2 January 2017. Considering that the club had a
reasonable time and opportunity to remedy its default and pay the explicitly
acknowledged outstanding remuneration, it is evident that the club’s argument
regarding the formal non-compliance of the default notices with the contract must
be disregarded.
17.
As to the club’s objection to pay the player the second advance payment, the
Chamber deemed it appropriate to refer the parties to the wording of the contract,
which clearly stipulates a specific pay date for said amount, i.e. 30 August 2016. Thus,
it is clear that the second advance payment has a specific due date and therefore was
entirely due on that date. As such, the argument of the club that the second advance
payment was to be paid throughout the duration of the contract is without merit and
cannot be upheld.
18.
Consequently, it can be established that at the time of the termination a considerable
amount of remuneration – consisting of at least the undisputed part of the first
advance payment and the player’s monthly salaries for October to December 2016, as
well as of the second advance payment, which the Chamber just concluded was
equally due – was outstanding for a significant period of time and that the club was
therefore in material breach of the contract. As such, the DRC concluded that the
Player A, Country B / Club C, Country D/ Club E, Country B
Page 9 of 13
player had just cause to terminate the contract on 2 January 2017, due to the club’s
unjustified breach.
19.
Prior to establishing the consequences of the breach of contract without just cause by
the club in accordance with art. 17 par. 1 of the Regulations, the Chamber held that it
had to address the issue of the unpaid remuneration at the moment the contract was
terminated by the player and establish its exact amount and composition.
20.
In this respect, the Chamber recalled that part of the first advance payment in the
amount of EUR 750,002, the entire second advance payment in the amount of EUR
1,500,004 as well as the player’s monthly salaries for October until December 2016 in
the total amount of EUR 624,999 clearly remained outstanding by the time the
contract was terminated.
21.
In addition, the Chamber noted that also the amounts of EUR 200,000 as bonus
related to match appearances during the 2015/2016 season and USD 200,000 as bonus
related to the victory of the Tournament X in 2016, were to be added to the amount
of outstanding remuneration, as not only the club explicitly acknowledged these
debts, but also the player provided substantial evidence of the fulfilment of their
conditions precedent.
22.
As to the EUR 95,430 claimed by the player as reimbursement of accommodation
costs, the Chamber deemed that such request must be rejected, as the relevant
contract does not contain a specific amount due by the club to the player as
accommodation costs and the player failed to prove that the club agreed to
reimburse the amounts as per the tenancy agreement presented.
23.
Therefore, in accordance with the general legal principle of “pacta sunt servanda”,
the Chamber concluded that the club has to pay to the player the total amounts of
EUR 3,075,005 and USD 200,000 plus 5% interest p.a. over the aforementioned
amounts as from the respective due dates, considering the request of the player as
well as the DRC’s well-established jurisprudence.
24.
In continuation, the Chamber decided that, taking into consideration art. 17 par. 1 of
the Regulations, the player is entitled to receive from the club compensation for
breach of contract in addition to any outstanding remuneration on the basis of the
relevant employment contract.
25.
The Chamber turned to the calculation of the amount of compensation payable to
the player by the club in the case at stake. In doing so, the members of the Chamber
firstly recapitulated that, in accordance with 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
Player A, Country B / Club C, Country D/ Club E, Country B
Page 10 of 13
law of the country concerned, the specificity of sport and further objective criteria,
including in particular, the remuneration and other benefits due to the player 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.
26.
In application of the relevant provision, the Chamber held that first of all, it had to
clarify as to whether the pertinent employment contract contained 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.
27.
In this regard, the Chamber recapped that pursuant to art. 11.5 “…the Parties hereby
expressly and irrevocably agree that in the event that Club C terminates this contract
with just cause (…) and/or the player terminates this contract without just cause (…),
the player shall promptly pay to Club C, as compensation for the breach, the amount
of EUR 9,000,000”. Furthermore, art. 11.6 stipulated that “In the event that Club C
terminates this contract without just cause (…) Club C shall be liable to pay to the
player, as full and final breach of contract compensation, the remaining value of the
contract”.
28.
From the aforementioned, the members of the Chamber noted that clause 11.6 of the
contract constitutes a liquidated-damage clause in favour of the player. The Chamber
also pointed out that the contract also contains a clause in favour of the club,
establishing the amount of compensation due to it in case of an unjustified breach by
the player. When analysing the consequences of the application of the clauses, the
DRC concluded that the principles of parity and equal repartition of rights are met
and, as such, clause 11.6 should be applied to establish the amount of compensation
due by the club to the player.
29.
The relevant clause provides that the player should be entitled to receive the
remaining value of the contract, which corresponds to EUR 5,249,998. This amount
comprises the advance payment for the year 2017 as well as 18 monthly salaries
corresponding to the month of January 2017 until June 2018. No interest was
requested by the player over the amount of compensation.
30.
The members of the Chamber concluded their deliberations by partially accepting the
claim of the player and fully rejecting the counterclaim of the club.
Player A, Country B / Club C, Country D/ Club E, Country B
Page 11 of 13
***
III.
Decision of the Dis pute Res olution Cham ber
1.
The claim of the Claimant/Counter-Respondent, Player A, is partially accepted.
2.
The Respondent/Counter-Claimant, Club C, is ordered to pay to the Claimant/CounterRespondent, w ithin 30 day s as from the date of notification of this decision,
outstanding remuneration in the amounts of EUR 3,075,005 and USD 200,000 plus 5%
interest as follows:
a. 5% interest p.a. on the amount of USD 200,000 as of 1 July 2016 until the
date of effective payment;
b. 5% interest p.a. on the amount of EUR 200,000 as of 1 August 2016 until the
date of effective payment;
c. 5% interest p.a. on the amount of EUR 750,002 as of 2 August 2016 until the
date of effective payment;
d. 5% interest p.a. on the amount of EUR 1,500,004 as of 1 September 2016
until the date of effective payment;
e. 5% interest p.a. on the amount of EUR 208,333 as of 1 November 2016 until
the date of effective payment;
f. 5% interest p.a. on the amount of EUR 208,333 as of 1 December 2016 until
the date of effective payment;
g. 5% interest p.a. on the amount of EUR 208,333 as of 1 January 2017 until the
date of effective payment.
3.
In the event that the amount plus interest due to the Claimant/Counter-Respondent
in accordance with number 2. above is not paid within the stated time limit, the
present matter shall be submitted, upon request, to the FIFA Disciplinary Committee
for consideration and a formal decision.
4.
The Respondent/Counter-Claimant is ordered to pay to the Claimant/CounterRespondent, w ithin 30 day s as from the date of notification of this decision,
compensation for breach of contract in the amount of EUR 5,249,998.
5.
In the event that the amount due to the Claimant/Counter-Respondent in accordance
with number 4. above is not paid within the stated time limit, interest at the rate of
5% p.a. will fall due as of expiry of the aforementioned time limit and 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/ Club E, Country B
Page 12 of 13
6.
Any further claim lodged by the Claimant/Counter-Respondent is rejected.
7.
The counterclaim of the Respondent/Counter-Claimant is rejected.
8.
The Claimant/Counter-Respondent is directed to inform the Respondent/CounterClaimant and the second Respondent, immediately and directly, of the account
number to which the remittance is to be made and to notify the Dispute Resolution
Chamber of every payment received.
*****
Note relating to the m otiv ated decision (legal remedy):
According to article 58 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:
Emilio García Silvero
Chief Legal & Compliance Officer
Encl.: CAS directives
Player A, Country B / Club C, Country D/ Club E, Country B
Page 13 of 13