Team 002

IN THE INTERNATIONAL COURT OF JUSTICE

2019

The Case Concerning the Evacuation of a Foreigner

during an Outbreak of Malignant Influenza

The State of Armis

Applicant
v.
The State of Recho
Respondent

MEMORIAL FOR RESPONDENT

 TABLE OF CONTENTS

CONTENT PAGE NO.

Cover Page ……………………….. 1

Table of Contents ……………………….. 2

Index of Authorities ……………………….. 3

Statement of Jurisdiction ……………………….. 5

Questions Presented ……………………….. 6

Statement of Facts ……………………….. 7

Summary of Pleadings ……………………….. 9

Pleadings:

 On Procedural Issue ……………………….. 12

 On Substantive Issues

o Breach of Treaties ……………………….. 13

o Breach of Customary Law ……………………….. 17

Conclusion and Prayer for Relief ……………………….. 23

Page 2 of 24
 INDEX OF AUTHORITIES

Conventions and Other International Instruments Page No.

Statute of the International Court of Justice, United Nations, 18 April
5
1946, available at bit.ly/2SM2ykC
Treatises
Convention on the Elimination of All Forms of Discrimination Against
14
Women, United Nations, Treaty Series, vol. 1249, p. 13
Convention on the Rights of the Child, United Nations, Treaty Series, vol.
16,
1577, p. 3
Responsibility of States for Internationally Wrongful Acts, November
17
2001, Supplement No. 10 (A/56/10), chp.IV.E.1
International Covenant on Civil and Political Rights, United Nations,
14, 17
Treaty Series, vol. 999, p. 171
Termination of Employment Convention, ILO, 22 June 1982, C158 15, 19
Vienna Convention on the Law of Treaties, United Nations, Treaty Series,
13
vol. 1155, p. 331
Cases
L. F.H. Neer and Pauline E. Neer (United States.) v. United Mexican
States. 14 March 1927. Reports on International Arbitral Awards. UN. 20
Vol IV p. 138
Mavrommatis Palestine Concessions (Greece v. U.K.), 1924 P.C.I.J. (ser.
12
B) No. 3 (Aug. 30).
Books
M. Cherif Bassiouni. (Autumn 1996) "International Crimes: 'Jus Cogens'
and 'Obligatio Erga Omnes'." Law and Contemporary Problems. Vol. 59, 18
No. 4, Pg. 68
Norms of Jus Cogens and International Labor Law, L.N. Leonidovich,
17
Page 1, ISSN: 1729-5920
Introduction to Public International Law by Joaquin Bernas. (2009) 15, 16
Yoram Dinstein. 2004. The Conduct of Hostilities under the Law of
International Armed Conflict, pp. 5. Cambridge: Cambridge University 18
Press
Journals
David Leys. (2016). Diplomatic Protection and Individual Rights: A
12, 13
Complementary Approach. Harvard International Law Journal. Vol. 57
M. Borchard Edwin. (2019). Minimum Standard Of The Treatment Of
19
Aliens. Michigan Law Review. Vol. 38, p 445
Other Authorities
Adriana Sánchez Mussi, “International Minimum Standard of
19
Treatment”, 2000, Pg. 4. Can be accessed at: https://bit.ly/2T3HmXp
Armed Activities on the Territory of the Congo (Democratic Republic of
20
the Congo vs. Uganda), December 2005, Paragraph no. 215, p. 78

Page 3 of 24
Business Performance and Family-Friendly Policies. Journal of General
14
Management, 24(4), 22–37
Ferstman, Carla. “The International Court of Justice and the Question of
Reparations”, Regarding Rights, accessed 15 March 2019. Accessed
21
from: http://asiapacific.anu.edu.au/regarding-rights/2015/07/17/the-
international-court-of-justice-and-the-question-of-reparations/
Norms of Jus Cogens and International Labor Law, L.N. Leonidovich,
18
Page 1, ISSN: 1729-5920
United Nations, Draft articles on Diplomatic Protection, Article 1, 2006,
12
available at: https://www.refworld.org/docid/525417fc4.html
United Nations Human Settlements Programme. Fact Sheet No. 25/Rev.1 14
USLegal Legal definition. Freedom to Contract 14

Page 4 of 24
 STATEMENT OF JURISDICTION

The Government of Armis (Applicant) filed the case against the Government of Recho

(Respondent) pursuant to Article 36 paragraph 2 of the Statute this Court.1 Both countries are

parties to the treaties involved in the present dispute about the evacuation of a foreigner during an

outbreak of a malignant influenza. The Government of Armis and Recho agrees to settle the

controversy and all issues involved in accordance with Article 36 paragraph 1 of the Court’s

Statute. Hence, the case is submitted to this Court, pursuant to Article 40 paragraph 1 of the Court’s

Statute. Parties agree that the judgment of this Court shall be treated as final and binding and each

party shall execute it in good faith.

1
Statute of the International Court of Justice

Page 5 of 24
 QUESTION PRESENTED

The Government of Recho presents the following questions to the Court:

1. Whether the Government of Armis has the capacity to represent Ms. Shunzette and her

child.

2. Whether the Government of Recho breached the treaties to which Armis and Recho are

parties.

3. Whether the Government of Recho breached international customary law.

4. Whether the Government of Recho is obligated to provide reparations to Ms. Shunzette

and her child.

Page 6 of 24
 STATEMENT OF FACTS

Background

In March 2010, a malignant influenza was going around Megoose which borders Recho.

As a response to the outbreak, the Government of Megoose ordered the inhabitants living within

the 30-kilometer radius from where the influenza was greatly affected not to move in and out of

the area. This prompted The Government of Armis to order all the residents living in Recho to

evacuate the latter’s country at once. Recho however borders Megoose at a 50 kilometer distance

from the area where the influenza was the most serious.

Ms. Shunzette works in the National Research Institute of Recho since March 2009 under

a 3 year contract. The company is funded by the Government and is situated at a distance of 60

kilometers from the area where the malignant influenza in Megoose was described as the most

serious. She was the only female Armis researcher employed in the company and unlike the rest

of the researchers who are Armis citizens; she is the only employee who lives with her child, the

male Armis national researchers had to live apart from their family

Termination from Employment of Ms. Shunzette .

Prior to the completion of her 3-year contract, Ms. Shunzette – who was one of the 30

percent Armis nationals who followed the instruction of the Armis Government – decided to return

to Armis together with her child at the time of the outbreak of the malignant influenza. Her

departure however was without any notice to her employer.

When Armis lifted its order on June 2010, Ms. Shunzette flew back to Recho to continue

her employment to the company. During this time, she could be considered absent without any

Page 7 of 24
official leave for four months spanning March to June 2010. Upon her return, she discovered that

she has been dismissed as a punishment. As a consequence of her dismissal, her rental lodge in the

company’s campus has been cancelled. Dismissal as a punishment – embodied in their

employment contract – disqualifies her for reemployment.

Suit Against The Government of Recho

Ms. Sunzette, had no choice but to leave Recho and return to Armis. She filed a suit against

the Government of Recho, and demanded the revocation of her dismissal. The case was heard by

the district court which had jurisdiction over the matter but it decided in favor of the government.

The court accepted the government’s contention that her dismissal was the consequence of Ms.

Shunzette’s action of failing to ask permission from her employer regarding her absence at work.

The district court’s decision prompted Ms. Shunzette to seek the assistance of the

Government of Armis requesting the latter to exercise its right of diplomatic protection. The

Government of Armis sought the revocation of Ms. Sunzette’s dismissal to which The Government

of Recho declined. Further negotiations ensued but were unsuccessful so both agreed to present

the dispute to the International Court of Justice.

The defendant over this case, the Government of Recho, prays that the International Court

of justice declare: The Government of Recho breached no treaties to which Armis and Recho are

parties or any international customary law in relation to the spread of the malignant influenza in

Megoose in March 2010.

The applicant, Government of Armis, prays that the International Court Justice decides

otherwise.

Page 8 of 24
 SUMMARY OF PLEADINGS

I.

Armis cannot invoke its right of diplomatic protection. Pursuant to the Mavrommatis

judgment, the discretionary right of the State to invoke diplomatic protection must comply with

several requisites – one of which is that a rule of international law must have been violated.

However, it is questionable whether a rule of international law has been violated. Recho was

acting within the limits of international law and did not violate any rights of Ms. Shunzette or her

child.

II.

The treaties that the Government of Recho entered into have not been breached when a

malignant influenza spread in a neighboring countries’ territory. It cannot also be said that Recho

violated Ms. Shunzette’s rights to security in her employment. Her termination from work was not

due to Recho’s discrimination of her work but because of her employer’s initiative to remove

employees who had been absent for a long period of time without notice. The terms and conditions

of her employment was voluntarily entered into by Ms. Shunzette. Moreso, Recho also did not

violate any right to which the Ms. Shunzette and her child is entitled such as protection to health

and welfare. It could not be said that Recho was safe from the malignant influenza, considering

the fact that it was only 50 kilometers away from the most affected area. Recho was able to conduct

safety precautions to protect its own nationals, including Ms. Shunzette who was regarded as an

alien yet considered as national under the doctrine of national treatment, from such epidemic in

Mengoose.

Page 9 of 24
 III.

There was no breach of customary international obligations of Recho on the following:

(1) freedom of movement as embodied in the ICCPR; (2) respect for labor rights; and (3) respect

for the right of another state for self-determination.

Freedom of movement

The State of Recho did not, in any way, prevent Ms. Shuzette and her child to leave the

country under their own volition.

Respect for labor rights

By the non-performance of Ms. Shuzette of her obligations to do in her employment

contract with NRIR her dismissal is valid under the well accepted principle of facio ut des in

civil law. Severance pay is not a matter of right in case there was no stipulation of such in the

employment contract.

Respect for the right of another state for self-determination

Recho refrained from inquiring the reason behind the instruction of Armis to its nationals

to evacuate at once. This is in compliance with its customary international obligation to observe

that all states are equal and sovereign. However, tolerance on the part of Recho with the said

instruction is not a justification for it to be held liable in damages resulting to the negligent act of

Armis.

Page 10 of 24
 IV.

Recho is not liable for any kind of reparation as the mistake is not directly attributable to

it. Armis anchored its reasoning to the influenza outbreak which in fact not a risk to the health and

life of Ms. Shunzette and her child. Moreover, the Court does not usually determine reparations

owed to the parties.

Page 11 of 24
 PLEADINGS

I. THE GOVERNMENT OF ARMIS HAS NO CAPACITY TO REPRESENT MS.

SHUNZETTE WHO REQUESTED THE RIGHT OF DIPLOMATIC

PROTECTION

“Diplomatic protection consists of the invocation by a State, through diplomatic action or

other means of peaceful settlement, of the responsibility of another State for an injury caused by

an internationally wrongful act of that State to a natural … person that is a national of the former

State.” 2 It authorizes the state to act in order to enforce the substantive rights of its nationals in

the eyes on international law.3 It is however inapplicable to the case of Ms. Shunzette because in

order to invoke the classical application of the right or diplomatic protection, it must comply with

the requisites laid down by the Mavrommatis judgment.

The Mavrommatis judgment has set several long standing features of diplomatic protection.

One such feature is that diplomatic protection is the discretionary exercise of a substantial and

procedural state right.4 This right of the State, discretionary as it may be, is not absolute as it

accepts several limitations, one of which is that a rule of international law must have been violated.
5

2
United Nations, Draft articles on Diplomatic Protection, Article 1, 2006, available at:
https://www.refworld.org/docid/525417fc4.html
3
Mavrommatis Palestine Concessions (Greece v. U.K.), 1924 P.C.I.J. (ser. B) No. 3 (Aug. 30).
4
Ibid.
5
David Leys. (2016). Diplomatic Protection and Individual Rights: A Complementary Approach.
Harvard International Law Journal. Vol. 57

Page 12 of 24
 In this case, Armis cannot invoke its diplomatic protection as it is questionable whether a

rule of international law has been violated. Recho was acting within the limits of international law

and did not violate any rights of Ms. Shunzette. Assuming that Armis can validly exercise its right

of diplomatic protection, this does not mean that the rights of that compensation to the individual

is guaranteed.6

II. RECHO DID NOT VIOLATE ANY TREATIES TO WHICH ARMIS AND RECHO

ARE PARTIES IN RELATION TO THE SPREAD OF THE MALIGNANT

INFLUENZA IN MEGOOSE

A material breach of a treaty consists in the violation of a provision essential to the

accomplishment of the object or purpose of the treaty.7 There is no showing that the Government

of Recho has violated any treaties to which Armis and Recho are parties.

A. The Government of Recho did not breach any treaties with regard to Ms.

Shunzette’s employment contract

Ms. Shunzette left for Armis, under the instructions of its government, prior to the lapse

of her 3-year contract. As an employee, she had the obligation to seek the permission of her

employers to be absent from her responsibilities.

6
David Leys. (2016). Diplomatic Protection and Individual Rights: A Complementary Approach.
Harvard International Law Journal. Vol. 57
7
Vienna Convention on the Law of Treaties, Article 60 ¶3

Page 13 of 24
 After returning to Armis, absent any notice to her employer, Ms. Shunzette was deemed

to have been absent without leave for four months. As a consequence thereof, she was dismissed

from work.

There was however no prosecution and imprisonment on the basis of her breach of the

employment contract.8 Her punishment on the other hand was in accordance with the stipulations

of their employment contract freely entered into by both parties. 9 There is no precedent that would

allow an order of the government to nullify the stipulations of an employment contract freely

entered into by the employee and the employer. It therefore does not follow that when the

Government of Armis ordered Ms. Shunzette to return, she is allowed to set aside her duties as an

employee.

If an employee can freely leave her work without prior notice to the company, the

company’s productivity and business interests will be adversely affected.10

In addition, it is only proper that her rental lodge in the campus be cancelled as a result of

her dismissal.11 At the time of the cancellation, she was no longer an employee of the company.

Her benefits as an employee which includes shelter is automatically revoked along with the

revocation of her employment.12

8
International Covenant on Civil and Political Rights, Article 11 [hereinafter ICCPR]
9
Freedom to Contract. USLegal Legal definition.
10
Business Performance and Family-Friendly Policies. Journal of General Management. June 1,
1999
11
ICCPR, Article 17 ¶1
12
United Nations Human Settlements Programme. Fact Sheet No. 25/Rev.1. Forced Evictions

Page 14 of 24
 Furthermore, she was not prevented by the Government of Recho from appealing her

termination to a competent court. It is provided that “[a] worker who considers that his employment

has been unjustifiably terminated shall be entitled to appeal against that termination to an impartial

body…”13 Such right to due process was afforded to Ms. Shunzette when her case was heard by a

competent court of Recho.

B. The Government of Recho did not place Ms. Shunzette’s life and her child’s

health at prejudice

States protect aliens within their jurisdiction in the expectation that their own nationals will

be properly treated when residing or sojourning abroad.14 Under the doctrine of “national

treatment”15, aliens are treated in the same manner as nationals of the state where they reside. This

means that aliens enjoy the same benefits as local nationals. The Government of Recho therefore

has the responsibility protect their inhabitants – both national and alien alike – from any disease

such as malignant influenza as this case is about. However, adducing that there exists no public

health issue that would adversely affect its citizens, as well as foreigners residing in their country,

Recho cannot be said to have prejudice the health of Ms. Shunzette and her child.

The restriction imposed by The Government of Megoose is only at 30-kilometer radius

from where the spread of influenza was serious. However, it can be gleamed from the facts of the

case that – although it borders Megoose – Recho was 50 kilometers away from the aforementioned

13
Termination of Employment Convention, Article 8
14
Public International Law by Joaquin G. Bernas, p. 223
15
Ibid, p. 225

Page 15 of 24
area seriously affected by the spread of influenza. The government of Recho can logically infer

that the country will not be adversely affected from the spread of influenza. Furthermore, the

Research Institute of Recho which Ms. Shunzette worked as a researcher is situated at a distance

of 60 kilometers from the aforementioned area.

There is also no showing of any violations to the Conventions of the Rights of the Child.

Under the convention, The Government of Recho should ensure that Ms. Shunzette’s child is

protected and cared for, taking into account the rights of her parent. 16 In line with this, the State –

in respecting the right of Ms. Shunzette to take her daughter back to Armis on the reason of public

health and safety – allowed the mother and daughter to leave the country. In doing so, Recho has

shown that it respects the right of the parent in accordance with the convention. It is also a well-

entrenched principle that States protect aliens – this would include children – within their

jurisdiction.17

C. Recho did not discriminate Ms. Sunzette and her 5-year old daughter

All inhabitants of the territory were equally treated and there exists no preferential

treatment for the citizens over the foreign workers or vice versa. In compliance to their obligations

to the convention,18 there is even no showing of any acts from the Government of Recho that the

daughter of Ms. Shunzette was discriminated against. They were – both mother and daughter –

subject to the same rights and benefits enjoyed by the nationals of Recho at that time. It cannot

16
Convention on the Rights of the Child, Article 3
17
Public International Law by Joaquin G. Bernas, p. 223
18
Convention on the Rights of the Child, Article 2

Page 16 of 24
even be said that Ms. Shunzette was discriminated against because she was not denied of due

process19 since her case was heard by a competent court of Recho.20 Hence, there was no violation

in the obligations under ICCPR, CEDAW, and Convention on the Rights of the Child.

III. RECHO DID NOT VIOLATE ANY INTERNATIONAL CUSTOMARY LAW IN

RELATION TO THE SPREAD OF THE MALIGNANT INFLUENZA IN

MEGOOSE

There is a breach of an international obligation by a State when an act of that State is not

in conformity with what is required of it by that obligation, regardless of its origin or character21

as well as when conduct attributed to a State as a subject of international law amounts to a failure

by that State to comply with an international obligation incumbent upon it. 22

A. Recho did not place any restrictions on Ms. Shunzette and her child from leaving

the country

The government of Recho did not impose any restrictions that would adversely affect Ms.

Shunzette’s right to liberty of movement, in fact Recho allowed the departure of Ms. Shunzette

and her child from the country without delay. This is a clear manifestation of compliance by Recho

to its international obligation to respect the freedom of movement of Ms. Shunzette and her child.

19
ICCPR, Article 26
20
Ibid, Article 14
21
Responsibility of States for Internationally Wrongful Acts (2001)
22
Responsibility of States for Internationally Wrongful Acts – General Commentaries, p. 97

Page 17 of 24
 B. Recho Court respected Ms. Shunzette’s labor and human rights

The Local Court failed to discuss her legal arguments but even so, it did not in any way

resulted to a violation of labor and human rights of Ms. Shuzette and her child.

(i) Jus cogens in International Labor Law

On the basis of decisions of international courts the held legitimacy of jus cogens norms in

international labor law can be stated with respect to the prohibition of discrimination, as well as

the prohibition of slavery as the extreme form of forced labor23. Thus, in international labor law

the following are the only ones which forms part of jus cogens: (1) prohibition against slavery; (2)

prohibition against child labor; and (3) prohibition against discrimination.

(ii) Non-payment of severance pay is valid only if there is stipulation stating such

Separation or dismissal pay is only valid when there is stipulation indicating such. The

reason, is that in international law the concept of severance pay as a right of an employee has yet

to be a part of jus cogens. The contract between NRIR and Ms. Shunzette specifically stipulated

that in case the employee is dismissed by the employer for punishment the former shall not receive

any dismissal payment and is barred for re-employment.

(iii) The principle of facio ut des as a legitimate justification for dismissal by

punishment

23
Norms of Jus Cogens and International Labor Law, L.N. Leonidovich, Page 1, ISSN: 1729-
5920

Page 18 of 24
 Contrary to claims of Ms. Shunzette that her dismissal was due to her “departure” as a

result of the instruction of Armis is a violation of her freedom of movement, respondent, would

like to correct this narrative. Respondent contends that her dismissal is due to consecutive absences

of more or less four (4) months resulting to non-performance of her obligation in her contract. The

concept of facio ut des – which occurs when a man agrees to perform anything for a price, either

specifically mentioned or left to the determination of the law – forms part of international custom

in conformity with Article 38, Paragraph 1 (b), of ICJ Statute. Breaching her employment contract

gives her employer the right to punish her in accordance to the stipulations of their contract. Her

absence from work without due notice gave her employer valid justifications for her dismissal.24

C. The Government of Recho has complied with the minimum standard of the

treatment of aliens as prescribed by customary law

The principle of equality between nationals and foreigners posits that when a foreigner who

voluntarily moves to a country in search of a personal benefit accepts both the advantages which

he is going to enjoy and the risks to which he may find himself exposed.25 Under the Calvo

Doctrine, the responsibility of governments toward foreigners cannot be greater than that which

these Governments have towards their own citizens. 26

24
Termination of Employment Convention, Article 4
25
M. Borchard Edwin. (2019). Minimum Standard Of The Treatment Of Aliens. Michigan Law
Review. Vol. 38, p 445
26
Adriana Sánchez Mussi, “International Minimum Standard of Treatment”, 2000, Pg. 4. Can be
accessed at: https://bit.ly/2T3HmXp

Page 19 of 24
 In the case of Neer vs United Mexican States, this court ruled that to constitute an act or

omission as the violation of the minimum standard of treatment of aliens, there should be an

intentional neglect of duty, malicious intention or a paucity of the governmental action that would

be reasonable to be termed as a violation of the international standards of treatment, to a man of

prudence. 27

The absence of convincing proof in the Government Armis’ claim that the Government of

Recho showed intentional neglect of duty and malicious intention, means that Recho cannot have

violated the minimum standard of treatment of aliens.

IV. RECHO IS NOT LIABLE FOR ANY KIND OF REPARATIONS

A. Judgments imposing an obligation to give reparations are only given against a party

from which harm is directly attributable to the same. But even so, the Court does

not casually give specific amount or kinds of award for reparation

The Court does not simply look whether damage exists in a given issue rather it looks into

acts which are directly attributable against the respondent.28 This method by the Court ensures that

a party from which reparation is demanded is also not injured from the sole reason that there is

damage incurred by the applicant. Thus the Court observed great caution against unjust

enrichment. Moreover it is good to note that according to Ms. Carla Ferstman of Regarding Rights:

27
L. F.H. Neer and Pauline E. Neer (United States.) v. United Mexican States. 14 March 1927.
Reports on International Arbitral Awards. UN. Vol IV p. 138
28
Armed Activities on the Territory of the Congo (Democratic Republic of the Congo vs.
Uganda), December 2005, Paragraph no. 215, p. 78

Page 20 of 24
 “. . . It is a rare occasion for the ICJ to determine reparations owed to the parties.

Usually, aside from setting out general principles, the specifics are resolved

between the parties at the end of the merits proceedings. It is only very rarely that

the parties fail to agree the quantum and quality of reparations on their own. This

laissez-faire approach has meant that the ICJ’s jurisprudence on quantum and

quality of reparations is limited…”29

B. Arbitrary declaration of emergency or withdrawal of citizens of a state with no

factual basis does not bind other states to be liable

The general principle that almost all states observe is the idea that “a party shall not be held

liable due to fault or negligence of another”. In this case, Armis unilaterally instructed all of their

nationals living in Recho to evacuate at once on the basis that there is a spread of malignant

influenza. Although respondent admits that Ms. Shuzette had no choice in staying as her departure

may be considered as a compulsory action resulting from the instruction of her government, the

respondent still strongly contends that it must not be held liable to whatever damages she suffered.

Recho only allowed the departure of the nationals of Armis under its customary international

obligation to observe that all states are equal and sovereign. Thus, respondent did not inquire on

the basis of such instruction.

However, respondent avers that Armis is negligent on its part to instruct its nationals to

depart from Recho because:

Ferstman, Carla. “The International Court of Justice and the Question of Reparations”,
29

Regarding Rights

Page 21 of 24
 1. The Government of Megoose already implemented a no departure order to

avoid further spreading of virus;

2. The State of Recho is 50 kilometers away from the area where the spread is

most serious;

3. In the State of Recho, there was no mass panic or public hysteria regarding

the influenza outbreak and still conducts business as usual.

Thus, Armis had no justifiable factual basis whatsoever in giving instruction to evacuate

its nationals. But in doing so, Armis negligently exposed its nationals in various foreseeable

pecuniary and non-pecuniary damages. The damages suffered by Ms. Shuzette and her child, if

any, is a result of negligence of its State – Armis. Henceforth, Recho cannot be held liable to the

fault or negligence of Armis.

Page 22 of 24
 CONCLUSION AND/OR PRAYER FOR RELIEF

The Government of Recho respectfully requests this Court to adjudge and declare:

I.

That no international treatises or customary laws were violated when the Government of

Recho’s courts ruled in favor of the dismissal of Ms. Shunzette in accordance with her

employment contract with her employer

II.

That the health and safety of Ms. Shunzette and her child were never prejudiced

III.

That no restrictions or limitations were imposed on Ms. Shunzette and her child’s right to

liberty of movement in accordance with international law

IV.

That there were no discrimination against Ms. Shunzette and her child when the

Government of Recho supported the dismissal of Ms. Shunzette as adjudged by Recho’s

national court

Page 23 of 24
 V.

That the Government of Recho is not liable for any kind of reparations

Respectfully Submitted,

Agents of the Government of the Recho

Page 24 of 24