F.I.F.A. – Camera di Risoluzione delle Controversie (2014-2015) – controversie di lavoro – ———- F.I.F.A. – Dispute Resolution Chamber (2014-2015) – labour disputes – official version by www.fifa.com – Decision of theDispute Resolution Chamber passed in Zurich, Switzerland, on 19 February 2015, in the following composition: Thomas Grimm (Switzerland), Deputy Chairman Joaquim Evangelista (Portugal), member Theodoros Giannikos (Greece), member on the claim presented by the player, Player A, from country B as Claimant against the club, Club C, from country D as Respondent regarding an employment-related dispute arisen between the parties

F.I.F.A. - Camera di Risoluzione delle Controversie (2014-2015) - controversie di lavoro - ---------- F.I.F.A. - Dispute Resolution Chamber (2014-2015) - labour disputes – official version by www.fifa.com – Decision of theDispute Resolution Chamber passed in Zurich, Switzerland, on 19 February 2015, in the following composition: Thomas Grimm (Switzerland), Deputy Chairman Joaquim Evangelista (Portugal), member Theodoros Giannikos (Greece), member on the claim presented by the player, Player A, from country B as Claimant against the club, Club C, from country D as Respondent regarding an employment-related dispute arisen between the parties I. Facts of the case 1. On 12 June 2012, the player from country B, Player A (hereinafter: the Claimant), and the club from country D, Club C (hereinafter: the Respondent), signed an employment contract (hereinafter: the contract), valid as from 2 July 2012 until 30 June 2014, i.e. 2 years. 2. According to the contract, the Respondent undertook to provide the Claimant, inter alia, with the following: a) Art. III.2.: “monthly basis within the amount of EUR 10,000 net, not later than 25th day of the month following the month the remuneration refers to”. b) Art. III.2.: “during the contract signing – EUR 30,000 net, until 31.01.2013 – EUR 30,000 net, until 31.07.2013 – EUR 30,000 net, until 31.01.2014 – EUR 30,000 net”. c) Art. X.1.: “apartment for the period of the current contract”. 3. In addition, the parties agreed upon the following clauses: a) Article IV.2.2.: “[Rights and obligations of the Claimant] To take part in all football matches and events of the [Respondent]; in the training sessions-team or individual sessions, in all activities comprising preparation for football matches or competitions. This shall also apply in case the [Claimant] is not enlisted in the team for a given match as a titular or a substitution.” b) Article IX.1.: “The contract between the [Respondent] and the [Claimant] shall be terminated under the provisions of the Labour Code”. c) Article X.3.: “In case of any disputes between both parties shall be applied the Regulations of FIFA and Court of Arbitration.” d) Art. XIII.2.: “Any issues that are not provided herein shall be governed by the provisions of the Labour Code, the regulations of the Football Association from country D and the legislation of country D”. 4. On 17 December 2012, the Claimant unilaterally terminated the contract based on the Respondent’s alleged failure to pay him his first four salaries, corresponding to July until October 2012, in the total amount of EUR 40,000. 5. On 15 January 2013, the Claimant lodged a claim for breach of contract in front of FIFA against the Respondent, requesting the payment of the total amount of EUR 332,400, plus 5% interest p.a. as well as legal and procedural costs, broken down as follows: a) EUR 10,000, corresponding to his salary of July 2012, plus 5% interest p.a. as from 25 August 2012; b) EUR 10,000, corresponding to his salary of August 2012, plus 5% interest p.a. as from 25 September 2012; c) EUR 10,000, corresponding to his salary of September 2012, plus 5% interest p.a. as from 25 October 2012; d) EUR 10,000, corresponding to his salary of October 2012, plus 5% interest p.a. as from 25 November 2012; e) EUR 10,000, corresponding to his salary of November 2012, plus 5% interest p.a. as from 25 December 2012; f) EUR 6,111.11, corresponding to his salary for the period between 1 and 16 December 2012, plus 5% interest p.a.; g) EUR 2,400, as reimbursement of accommodation costs (cf. point I.7. below); h) EUR 273,888.89 as compensation, corresponding to the residual value of the contract (i.e. the Claimant’s salaries as from 17 December 2012 until 30 June 2014 and EUR 90,000 pursuant to art. III.2. of the contract, cf. point I.2.a) and b) above). 6. In his claim, the Claimant explains that the Respondent only paid him his sign-on fee in the amount of EUR 30,000 (cf. point I.2.b) above). “Despite of the numerous invitations addressed to the [Respondent]”, the Claimant terminated the contract on 17 December 2012 (cf. point I.4. above) and invited the Respondent to pay his outstanding remuneration as well as his salary of November 2012 “until 25 December 2012 at [the] latest”. 7. Additionally, the Claimant argues that, although the Respondent undertook to provide him with an apartment, he paid 4,693.99 for accommodation as from 14 July 2012 until 23 December 2012. 8. In its response, the Respondent claims that FIFA is not competent to hear the present dispute based on litispendence as there is allegedly an identical proceeding pending before the District Court in country D. 9. Alternatively, the Respondent also claims that FIFA is not competent to hear the present dispute based on the alleged competence of the Arbitration Court of the Football Association from country D. 10. As to the substance, the Respondent states that the contract was terminated by mutual agreement at the end of July 2012. The Respondent further states that the Claimant did not render any services as from 31 July 2012 and did not sign the relevant termination documents. Likewise, the Respondent affirms that the Claimant never complained of his salary arrears or formally warned the Respondent before terminating the contract. 11. In addition, the Respondent explains that whereas the Claimant was entitled to a proportion of his sign-on fee equivalent to EUR 1,250 plus his salary of July 2012, which amounts to EUR 11,250, it paid him a sum of EUR 30,000, clearly in excess to what he was entitled to as of the termination date. 12. In connection with the accommodation expenses until the alleged termination date, the Respondent affirms that it owes nothing to the Claimant because he spent July 2012 abroad with the Respondent’s team on pre-season preparation camps. Additionally, the Respondent claims that the accommodation invoices provided by the Claimant bear no signature and no letterhead and, therefore, they constitute inadmissible evidence. 13. Regarding the requested compensation, the Respondent further claims that it is not due “since both parties were responsible for the non-execution of the contract” and, alternatively, that, according to law in country D (i.e. art. 221 pars. 1 and 4 of the Labour Code of country D), it shall be calculated “for the period during which the employee was unemployed”, which ended on 1 January 2013, when the Claimant signed a new employment contract (cf. point I.22. below). 14. In his replica, the Claimant rejects the existence of litispendence. In this sense, the Claimant submitted a decision issued by the District Court in country D declaring the Respondent’s claim as inadmissible. 15. Regarding the alleged competence of the Arbitration Court of the Football Association from country D, the Claimant rejects it based on the non-existence of an explicit arbitration clause in favour of the Arbitration Court of the Football Association from country D and, additionally, on the fact that the Arbitration Court of the Football Association from country D would not comply with the requisites set forth in art. 22 b) of the Regulations on the Status and Transfer of Players. 16. As to the substance, the Claimant argues that he actually rendered his services and was under the Respondent’s orders until 17 December 2012. 17. As to an alleged termination agreement, the Claimant rejects the existence of such. 18. The Claimant explains that the contract was terminated according to art. 327 par. 2 of the Labour Code of country D, which establishes that “the worker or employee may terminate the employment contract without prior notice in the event that the employer delays the payment of the remuneration under the said contract or of a compensation under this Labour Code or the Social Security Law.” 19. In this sense, the Claimant argues that he was entitled to terminate the contract without prior warning to the Respondent based on a single outstanding remuneration. However, he explains that the termination of the contract was based on four outstanding remunerations. 20. The Claimant also submitted signed receipts issued by the hotel where he stayed (cf. point I.7. above). 21. In spite of being invited to do so, the Respondent did not provide its final comments to the present dispute. 22. Finally, the Claimant informed FIFA that he signed a contract with Club E, country D, valid from 5 January 2013 until 30 June 2014, for a monthly salary of EUR 8,000, a sign-on fee of EUR 10,000 and accommodation costs “up to EUR 500”. II. Considerations of the Dispute Resolution Chamber 1. First of all, the Dispute Resolution Chamber (hereinafter also referred to as Chamber or DRC) analysed whether it was competent to deal with the matter at hand. In this respect, it took note that the present matter was submitted to FIFA on 15 January 2013. Consequently, the 2012 edition of the Rules governing the procedures of the Players’ Status Committee and the Dispute Resolution Chamber (hereinafter: Procedural Rules) are applicable to the matter at hand (cf. art. 21 par. 1 and par. 2 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 2012 and 2014), the Dispute Resolution Chamber would, in principle, be 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. However, the Chamber acknowledged that the Respondent contested the competence of FIFA’s deciding bodies, firstly, on the basis of litispendence and, alternatively, on the basis of art. X.3 of the contract, highlighting that the parties had agreed that “in case of any disputes between both parties shall be applied the Regulations of FIFA and Court of Arbitration” (cf. point I.3.c) above). 4. In this regard, the Chamber noted that the Claimant rejected such position and insisted that FIFA has jurisdiction to deal with the present matter. 5. In continuation, the members of the Chamber analysed the basis of the allegation of litispendence raised by the Respondent in light of the statement of claim lodged by the Respondent in front of the District Court in country D, which may be found on file. In this sense, the DRC noted, in the first place, that such statement of claim was submitted on 13 February 2013, whereas the present matter was submitted to FIFA one month earlier, specifically on 15 January 2013. The DRC further noted that the object of the aforesaid statement of claim was the declaration of country D as the only competent jurisdiction for the resolution of any dispute between the Claimant and the Respondent and of law in country D as the only applicable one. However, the present dispute refers to an alleged breach of an employment contract. Additionally, the Chamber took due note that the District Court in country D issued a decision declaring the Respondent’s claim as inadmissible (cf. point I.14. above). 6. Accordingly, the members of the DRC concluded that, in the case at stake, the requirements of the defence of litispendence are not met since the proceeding in front of the District Court in country D, initiated by the Respondent on 13 February 2013, is subsequent to the present dispute, which was submitted to FIFA on 15 January 2013 and, more important, is not currently pending. Moreover, the DRC pointed out that the proceeding in country D had a completely different object to the subject of this procedure, which is another reason to reject the allegation of litispendence in the present dispute. 7. In connection with the second ground upon which the Respondent contested FIFA's jurisdiction, the DRC referred to article X.3 of the contract. According to said article, “in case of any disputes between both parties shall be applied the Regulations of FIFA and Court of Arbitration.” 8. Hence, the Chamber outlined that the content of the relevant article does not correspond to an arbitration clause but rather to a provision related to the applicable law in case of a dispute between the parties. In this sense, said clause does not explicitly refer to the competent national dispute resolution chamber or similar arbitration body in the sense of art. 22 lit. b) of the aforementioned Regulations but it actually refers to “the Regulations of FIFA and Court of Arbitration”. Therefore, the Claimant was not in a position to know at the moment of signing the contract to which body the potential disputes related to his employment relationship were to be submitted, not to mention that there is no reference at all to the “Arbitration Court of the Football Association from country D”. 9. In view of all the above, the DRC concluded that, in line with its constant jurisprudence, the Respondent's objections to the competence of FIFA to deal with the present matter have to be all rejected and that the DRC is competent, on the basis of art. 22 lit. b) of the Regulations on the Status and Transfer of Players, to consider the present matter as to the substance. 10. In continuation, 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 (editions 2012 and 2014), and considering that the present claim was lodged on 15 January 2013, the 2012 edition of said regulations (hereinafter: Regulations) is applicable to the matter at hand as to the substance. 11. The competence of the Chamber and the applicable regulations having been established, the DRC entered into the substance of the matter. In this respect, the Chamber started by acknowledging all the above-mentioned facts as well as the arguments and the documentation submitted by the parties. However, the DRC 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. 12. The members of the Chamber acknowledged that it was undisputed by the parties that they were contractually bound by means of the contract signed between them, valid as from 2 July 2012 until 30 June 2014, and that the only payment made by the Respondent in favour of the Claimant was in the amount of EUR 30,000. 13. In addition, the DRC noted that the parties did not dispute the validity of art. XIII.2. of the contract, which sets forth that “any issues that are not provided [in the contract] shall be governed by the provisions of the Labour Code, the regulations of the Football Association from country D and the legislation of country D” (cf. point I.3.d) above). 14. The Chamber further noted that the Claimant, on the one hand, lodged a claim against the Respondent for breach of contract, arguing that he terminated the contract with just cause on 17 December 2012 based on the non-payment of his first four salaries, corresponding to July until October 2012. 15. The Chamber also noted that the Respondent, on the other hand, argued that the contract was terminated by mutual agreement at the end of July 2012 and would owe nothing to the Claimant. 16. Having established the aforementioned, the Chamber deemed that the underlying issue in this dispute, considering the claim of the Claimant and the allegations of the Respondent, was to determine whether the employment relationship had been mutually or unilaterally terminated, and which party was responsible for the early termination of the contractual relationship in question, if any. The DRC also underlined that, subsequently, if it were found that the employment relationship had been breached by one of the parties without just cause, it would be necessary to determine the consequences for the party that caused the unjust breach of the relevant employment relationship. 17. In view of the above, the Chamber first of all would have to establish the type of termination and the contract’s termination date in view of the allegation of the Respondent regarding an alleged mutual termination of the contract and the claim of the Claimant as to an alleged unilateral termination of the same with just cause. 18. At this stage, the DRC considered it appropriate to refer the parties to art. 12 par. 3 of the Procedural Rules, which stipulates that “any party claiming a right on the basis of an alleged fact shall carry the burden of proof”. 19. In this sense, the DRC observed that the Respondent did not submit any proof to evidence the alleged termination of the contract by mutual agreement at the end of July 2012. Likewise, the Respondent did not submit any proof to evidence its allegation regarding the Claimant not rendering services as of 31 July 2012. 20. Subsequently, and taking into account the termination notice sent by the Claimant to the Respondent on 17 December 2012, a copy of which may be found on file, the Chamber concluded that the employment relationship between the parties was to be considered as terminated by the Claimant on such date. 21. Having established the fact that the contract was unilaterally terminated by the Claimant on 17 December 2012, the Chamber went on to analyse whether this termination had been with or without just cause. 22. In view of the above, 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”. 23. 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. 24. In accordance with point I.2. above, the Respondent was obliged to pay to the Claimant at the time the employment relationship terminated, i.e. 17 December 2012, the amount of EUR 10,000 due on 25 August 2012, the amount of EUR 10,000 due on 25 September 2012, the amount of EUR 10,000 due on 25 October 2012 and the amount of EUR 10,000 due on 25 November 2012, as salaries for the months of July 2012 until October 2012, in addition to EUR 30,000 due on 12 June 2012. 25. However, the DRC, still bearing in mind the wording of art. 12 par. 3 of the Procedural Rules, observed that the Respondent undisputedly paid the Claimant the amount of EUR 30,000 due on 12 June 2012, but failed to prove that it paid to the Claimant the abovementioned salaries, amounting to a total of EUR 40,000. 26. In this sense, the DRC recalled that, although the Claimant did not inform the Respondent of its default before terminating the contract on 17 December 2012, it remains uncontested that the Respondent failed to pay to him his four first monthly salaries. Thus, taking into account such an important delay in payment, the members of the Chamber deemed that the Claimant could in good faith believe that, in spite of a hypothetical notice informing about its default, the Respondent would have persisted on the noncompliance with the financial terms of the contract. 27. Additionally, the DRC pointed out that art. 327 par. 2 of the Labour Code of country D allows for an employee to terminate his employment contract without prior notice if the employer delays the payment of his remuneration and, in this case, the payment delay refers to four remunerations (cf. point I.18. above). In this sense, the members of the DRC took due note that the Respondent did not dispute the validity of art. XIII.2. of the contract (cf. point II.13. above). 28. In summary, the Chamber established, in accordance with its well-established jurisprudence, that on 17 December 2012 the Claimant terminated the contract with just cause based on the Respondent’s failure to pay him his first four monthly salaries. 29. In view of the foregoing, the DRC concluded that, in accordance with art. 17 par. 1 of the Regulations and its long-standing jurisprudence, the Respondent is liable for the termination of the contract on 17 December 2012 and, consequently, must pay an amount of compensation to the Claimant. 30. In continuation, prior to establishing the consequences of the breach of contract by the Respondent 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 Claimant. 31. Indeed, the DRC noted, once again, that the Respondent failed to pay to the Claimant his four first monthly salaries. Likewise, the Chamber drew its attention to the fact that the Claimant’s salaries fell due on the “25th day of the month following the month the remuneration refers to”. Thus, considering that he terminated the contract on 17 December 2012, his salaries from July until October 2012 were due at that time. Furthermore, the Chamber noted that the Respondent did not contest the fact that said salaries were not paid but acknowledged having paid to the Claimant EUR 30,000 only (cf. point I.11. above). 32. Consequently, the Chamber took into account that, on the contract's termination date, the Respondent had not paid to the Claimant the total amount of EUR 40,000 in salaries. 33. In accordance with the principle pacta sunt servanda, the Chamber decided that the Claimant is, therefore, entitled to outstanding remuneration in the total amount of EUR 40,000 pursuant to art. III.2. of the contract, which corresponds to his monthly salaries from July until October 2012. 34. In addition, taking into account the Claimant's request as well as the constant practice of the Dispute Resolution Chamber in this regard, the members of the Chamber decided to award the Claimant interest at the rate of 5% p.a. on the outstanding amount of EUR 40,000 until the date of effective payment as follows: a. 5% p.a. as of 26 August 2012 on the amount of EUR 10,000; b. 5% p.a. as of 26 September 2012 on the amount of EUR 10,000; c. 5% p.a. as of 26 October 2012 on the amount of EUR 10,000; d. 5% p.a. as of 26 November 2012 on the amount of EUR 10,000. 35. Equally, as regards to the Claimant's claim pertaining to the reimbursement of accommodation expenses, on the basis of art. X.1. of the contract and the hotel bills evidencing that he paid 4,693.99 for accommodation as from 14 July 2012 until 23 December 2012 –copy of which may be found on file– (cf. point I.7. and 20. above), the Chamber decided that the Respondent must pay to the Claimant the amount of 4,693.99 as reimbursement of accommodation expenses. 36. Having stated the above, 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 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. 37. 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. 38. 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 non-exhaustive enumeration of criteria to be taken into consideration when calculating the amount of compensation payable. Therefore, other objective criteria may be taken into account at the discretion of the deciding body. 39. The members of the Chamber then turned their attention to the remuneration and other benefits due to the Claimant under the existing contract and/or the new contract, which criterion was considered by the Chamber to be essential. The members of the Chamber deemed it important to emphasise that the wording of art. 17 par. 1 of the Regulations allows the Chamber to take into account both the existing contract and the new contract in the calculation of the amount of compensation. 40. Bearing in mind the foregoing, the Chamber proceeded with the calculation of the monies payable to the Claimant under the terms of the employment contract as from its date of termination with just cause by the Claimant, i.e. 17 December 2012, until 30 June 2014, and concluded that the Claimant would have received in total EUR 290,000 as remuneration, had the contract been executed until its expiry date. Consequently, the Chamber concluded that the amount of EUR 290,000 serves as the basis for the final determination of the amount of compensation for breach of contract in the case at hand. 41. 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 enabled 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 Claimant’s general obligation to mitigate his damages. 42. The Chamber recalled that, on 4 January 2013, the Claimant signed an employment contract with club E from country D, valid from 5 January 2013 until 30 June 2014, in accordance with which he was to receive a monthly salary of EUR 8,000, a sign-on fee of EUR 10,000 and accommodation costs “up to EUR 500”. This employment contract enabled the Claimant to earn an income of EUR 163,000 between said dates. 43. Consequently, on account of all of the above-mentioned considerations and the specificities of the case at hand as well as the Claimant’s general obligation to mitigate his damage, the Chamber decided to partially accept the Claimant’s claim and that the Respondent must pay the amount of EUR 127,000, as compensation for breach of contract in the case at hand. 44. Taking into account the Claimant’s request and considering that its claim was lodged on 15 January 2013, the Chamber concluded that the Respondent must pay interest of 5% p.a. on the amount of EUR 127,000 as from 15 January 2013 until the date of effective payment. 45. With regard to the Claimant’s claim for legal and procedural costs, the Chamber recalled the contents of art. 18 par. 4 of the Procedural Rules as well as its long-standing and well-established jurisprudence, which clearly stipulates that no procedural compensation is awarded in proceedings in front of the Dispute Resolution Chamber. Therefore, the members of the Chamber had no other alternative than to reject this part of the claim. 46. The Dispute Resolution Chamber concluded its deliberations in the present matter by establishing that any further request filed by the Claimant is rejected. III. Decision of the Dispute Resolution Chamber 2. The claim of the Claimant, Player A, is admissible. 3. The claim of the Claimant is partially accepted. 4. The Respondent, Club C, is ordered to pay to the Claimant, within 30 days as from the date of notification of this decision, outstanding remuneration in the amount of EUR 40,000, plus 5% interest p.a. until the date of effective payment as follows: a. 5% p.a. as of 26 August 2012 on the amount of EUR 10,000; b. 5% p.a. as of 26 September 2012 on the amount of EUR 10,000; c. 5% p.a. as of 26 October 2012 on the amount of EUR 10,000; d. 5% p.a. as of 26 November 2012 on the amount of EUR 10,000. 5. The Respondent is ordered to pay to the Claimant the reimbursement of accommodation expenses in the amount of 4,693.99, within 30 days as from the date of notification of this decision. 6. The Respondent is ordered to pay to the Claimant compensation for breach of contract in the amount of EUR 127,000, plus 5% interest p.a. as from 15 January 2013 until the date of effective payment, within 30 days as from the date of notification of this decision. 7. In the event that the amounts due to the Claimant in accordance with the above-mentioned numbers 3., 4. and 5. are not paid by the Respondent within the stated time limit, interest at the rate of 5% p.a. will fall due on the amount referred to in number 4. above 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. 8. Any further claims lodged by the Claimant are rejected. 9. The Claimant is directed to inform the 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 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: info@tas-cas.org www.tas-cas.org For the Dispute Resolution Chamber: Jérôme Valcke Secretary General Encl.: CAS directives