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annul the decision dated 15 May 2020 by which the ECB refused to take over direct supervision and give instructions to the Competent Person so as to ensure that the Bank is no longer denied access to its offices, information, systems, files, documents, staff and resources;

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order the defendant to pay the costs.

1.

First plea in law, alleging that the ECB erroneously assumed that the requested action is beyond the competence of the ECB and also did not provide an adequate statement of reasons for its decision.

2.

Second plea in law, alleging that the contested decision violates the applicant’s right pursuant to Article 47 of the Charter of Fundamental Rights of the European Union.

3.

Third plea in law, alleging that the ECB violated the applicant’s right pursuant to Article 41 of the Charter of Fundamental Rights of the European Union.

4.

Fourth plea in law, alleging that the ECB violated the applicant’s right pursuant to Article 17 of the Charter of Fundamental Rights of the European Union.

5.

Fifth plea in law, alleging that the ECB violated the applicant’s right pursuant to Article 16 of the Charter of Fundamental Rights of the European Union.

6.

Sixth plea in law, alleging that the ECB violated its obligations pursuant to Art. 6(5)(b) of Council Regulation (EU) No 1024/2013 (1) and Article 67 of the Regulation (EU) No 468/2014 (2) of the European Central Bank.

7.

Seventh plea in law, alleging that the ECB violated the principle that the ECB has to act in a manner that makes compliance with regulatory obligations possible.

8.

Eighth plea in law, alleging that the ECB committed an abuse of power (détournement de pouvoir).