Asser International Sports Law Blog

Our International Sports Law Diary
The Asser International Sports Law Centre is part of the T.M.C. Asser Instituut

Not comfortably satisfied? The upcoming Court of Arbitration for Sport case of the thirty-four current and former players of the Essendon football club. By James Kitching

Editor's note: James Kitching is Legal Counsel and Secretary to the AFC judicial bodies at the Asian Football Confederation. James is an Australian and Italian citizen and one of the few Australians working in international sports law. He is admitted as barrister and solicitor in the Supreme Court of South Australia. James graduated from the International Master in the Management, Law, and Humanities of Sport offered by the Centre International d'Etude du Sport in July 2012.


Introduction

On 12 May 2015, the Court of Arbitration for Sport (CAS) announced that the World Anti-Doping Agency (WADA) had filed an appeal against the decision issued by the Australian Football League (AFL) Anti-Doping Tribunal (AADT) that thirty-four current and former players of Essendon Football Club (Essendon) had not committed any anti-doping rule violation (ADRV) identified within the AFL Anti-Doping Code (AADC). The players had each been charged with using Thymosin-Beta 4 (TB4) during the 2012 AFL season.

On 1 June 2015, WADA announced that it had filed an appeal against the decision by the AADT to clear Mr. Stephen Dank (Dank), a sports scientist employed at Essendon during the relevant period, of twenty-one charges of violating the AADC. Dank was, however, found guilty of ten charges and banned for life.

This blog will solely discuss the likelihood of the first AADT decision (the Decision) being overturned by the CAS. It will briefly summarise the facts, discuss the applicable rules and decision of the AADT, review similar cases involving ‘non-analytical positive’ ADRVs relating to the use of a prohibited substance or a prohibited method, and examine whether the Code of Sports-related Arbitration (CAS Code) is able to assist WADA in its appeal.

This blog will not examine the soap opera that was the two years leading-up to the Decision. Readers seeking a comprehensive factual background should view the excellent up-to-date timeline published by the Australian Broadcasting Corporation. More...


EU Law is not enough: Why FIFA's TPO ban survived its first challenge before the Brussels Court


Star Lawyer Jean-Louis Dupont is almost a monopolist as far as high profile EU law and football cases are concerned. This year, besides a mediatised challenge against UEFA’s FFP regulations, he is going after FIFA’s TPO ban on behalf of the Spanish and Portuguese leagues in front of the EU Commission, but also before the Brussels First Instance Court defending the infamous Malta-based football investment firm Doyen Sport. FIFA and UEFA’s archenemy, probably electrified by the 20 years of the Bosman ruling, is emphatically trying to reproduce his world-famous legal prowess. Despite a first spark at a success in the FFP case against UEFA with the Court of first instance of Brussels sending a preliminary reference to the Court of Justice of the EU (CJEU), this has proven to be a mirage as the CJEU refused, as foretold, to answer the questions of the Brussels Court, while the provisory measures ordered by the judge have been suspended due to UEFA’s appeal. But, there was still hope, the case against FIFA’s TPO ban, also involving UEFA and the Belgium federation, was pending in front of the same Brussels Court of First Instance, which had proven to be very willing to block UEFA’s FFP regulations. Yet, the final ruling is another disappointment for Dupont (and good news for FIFA). The Court refused to give way to Doyen’s demands for provisional measures and a preliminary reference. The likelihood of a timely Bosman bis repetita is fading away. Fortunately, we got hold of the judgment of the Brussels court and it is certainly of interest to all those eagerly awaiting to know whether FIFA’s TPO ban will be deemed compatible or not with EU law. More...


The New FIFA Intermediaries Regulations under EU Law Fire in Germany. By Tine Misic

I'm sure that in 1985, plutonium is available in every corner drugstore, but in 1955, it's a little hard to come by.” (Dr. Emmett L. Brown)[1]


Back to the future?

Availing oneself of EU law in the ambit of sports in 1995 must have felt a bit like digging for plutonium, but following the landmark ruling of the European Court of Justice (ECJ) in the Bosman case[2], 20 years later, with all the buzz surrounding several cases where EU law is being used as an efficient ammunition for shelling various sports governing or organising bodies, one may wonder if in 2015 EU law is to be “found in every drug store” and the recent cases (see inter alia Heinz Müller v 1. FSV Mainz 05, Daniel Striani ao v UEFA, Doyen Sports ao v URBSFA, FIFA, UEFA) [3] cannot but invitingly evoke the spirit of 1995.

One of the aforementioned cases that also stands out pertains to the injunction decision[4] issued on 29 April 2015 by the Regional Court (Landesgericht) in Frankfurt am Main (hereinafter: the Court) in the dispute between the intermediary company Firma Rogon Sportmanagement (hereinafter: the claimant) and the German Football Federation (Deutschen Fußball-Bund, DFB), where the claimant challenged the provisions of the newly adopted DFB Regulations on Intermediaries (hereinafter: DFB Regulations)[5] for being incompatible with Articles 101 and 102 TFEU.[6] The Court, by acknowledging the urgency of the matter stemming from the upcoming transfer window and the potential loss of clients, deemed a couple of shells directed at the DFB Regulations to be well-aimed, and granted an injunction due to breach of Article 101 TFEU. More...




Compatibility of fixed-term contracts in football with Directive 1999/70/EC. Part 2: The Heinz Müller case. By Piotr Drabik

Introduction
The first part of the present blog article provided a general introduction to the compatibility of fixed-term contracts in football with Directive 1999/70/EC[1] (Directive). However, as the Member States of the European Union enjoy a considerable discretion in the implementation of a directive, grasping the impact of the Directive on the world of football would not be possible without considering the national context. The recent ruling of the Arbeitsgericht Mainz (the lowest German labour court; hereinafter the Court) in proceedings brought by a German footballer Heinz Müller provides an important example in this regard. This second part of the blog on the legality of fixed-term contract in football is devoted to presenting and assessing the Court’s decision.


I. Facts and Procedure
Heinz Müller, the main protagonist of this case, was a goalkeeper playing for 1.FSV Mainz 05 a club partaking to the German Bundesliga. More...


Compatibility of Fixed-Term Contracts in Football with Directive 1999/70/EC. Part.1: The General Framework. By Piotr Drabik

Introduction
On 25 March 2015, the Labour Court of Mainz issued its decision in proceedings brought by a German footballer, Heinz Müller, against his (now former) club 1. FSV Mainz 05 (Mainz 05). The Court sided with the player and ruled that Müller should have been employed by Mainz 05 for an indefinite period following his 2009 three year contract with the club which was subsequently extended in 2011 to run until mid-2014. The judgment was based on national law implementing Directive 1999/70 on fixed-term work[1] (Directive) with the latter being introduced pursuant to art. 155(2) TFEU (ex art. 139(2) TEC). On the basis of this article, European social partners’ may request a framework agreement which they conclude to be implemented on the European Union (EU, Union) level by a Council decision on a proposal from the Commission. One of the objectives of the framework agreement,[2] and therefore of the Directive, was to establish a system to prevent abuse arising from the use of successive fixed-term employment contracts or relationships[3] which lies at the heart of the discussed problem.[4] More...

UEFA’s FFP out in the open: The Dynamo Moscow Case

Ever since UEFA started imposing disciplinary measures to football clubs for not complying with Financial Fair Play’s break-even requirement in 2014, it remained a mystery how UEFA’s disciplinary bodies were enforcing the Club Licensing and Financial Fair Play (“FFP”) regulations, what measures it was imposing, and what the justifications were for the imposition of these measures. For over a year, the general public could only take note of the 23 settlement agreements between Europe’s footballing body and the clubs. The evidential obstacle for a proper analysis was that the actual settlements remained confidential, as was stressed in several of our previous Blogs.[1] The information provided by the press releases lacked the necessary information to answer the abovementioned questions.

On 24 April 2015, the UEFA Club Financial Control Body lifted part of the veil by referring FC Dynamo Moscow to the Adjudicatory Body. Finally, the Adjudicatory Body had the opportunity to decide on a “FFP case. The anxiously-awaited Decision was reached by the Adjudicatory Chamber on 19 June and published not long after. Now that the Decision has been made public, a new stage of the debate regarding UEFA’s FFP policy can start.More...

Policing the (in)dependence of National Federations through the prism of the FIFA Statutes. By Tine Misic

…and everything under the sun is in tune,

but the sun is eclipsed by the moon…[1] 


The issue

Ruffling a few feathers, on 30 May 2015 the FIFA Executive Committee rather unsurprisingly, considering the previous warnings,[2] adopted a decision to suspend with immediate effect the Indonesian Football Federation (PSSI) until such time as PSSI is able to comply with its obligations under Articles 13 and 17 of the FIFA Statutes.[3] Stripping PSSI of its membership rights, the decision results in a prohibition of all Indonesian teams (national or club) from having any international sporting contact. In other words, the decision precludes all Indonesian teams from participating in any competition organised by either FIFA or the Asian Football Confederation (AFC). In addition, the suspension of rights also precludes all PSSI members and officials from benefits of any FIFA or AFC development programme, course or training during the term of suspension. This decision coincides with a very recent award by the Court of Arbitration for Sport (CAS) in this ambit, which shall be discussed further below.[4]More...


The Brussels Court judgment on Financial Fair Play: a futile attempt to pull off a Bosman. By Ben Van Rompuy

On 29 May 2015, the Brussels Court of First Instance delivered its highly anticipated judgment on the challenge brought by football players’ agent Daniel Striani (and others) against UEFA’s Club Licensing and Financial Fair Play Regulations (FFP). In media reports,[1] the judgment was generally portrayed as a significant initial victory for the opponents of FFP. The Brussels Court not only made a reference for a preliminary ruling to the European Court of Justice (CJEU) but also imposed an interim order blocking UEFA from implementing the second phase of the FFP that involves reducing the permitted deficit for clubs.

A careful reading of the judgment, however, challenges the widespread expectation that the CJEU will now pronounce itself on the compatibility of the FFP with EU law. More...

A Bridge Too Far? Bridge Transfers at the Court of Arbitration for Sport. By Antoine Duval and Luis Torres.

FIFA’s freshly adopted TPO ban entered into force on 1 May (see our Blog symposium). Though it is difficult to anticipate to what extent FIFA will be able to enforce the ban, it is likely that many of the third-party investors will try to have recourse to alternative solutions to pursue their commercial involvement in the football transfer market. One potential way to circumvent the FIFA ban is to use the proxy of what has been coined “bridge transfers”. A bridge transfer occurs when a club is used as an intermediary bridge in the transfer of a player from one club to another. The fictitious passage through this club is used to circumscribe, for example, the payment of training compensation or to whitewash a third-party ownership by transforming it into a classical employment relationship. This is a legal construction that has gained currency especially in South American football, but not only. On 5 May 2015, in the Racing Club v. FIFA case, the Court of Arbitration for Sport (CAS) rendered its first award involving directly a bridge transfer. As this practice could become prevalent in the coming years we think that this case deserves a close look. More...

20 Years After Bosman - The New Frontiers of EU Law and Sport - Special Issue of the Maastricht Journal of European and Comparative Law

Editor's note: This is a short introduction written for the special Issue of the Maastricht Journal of European and Comparative Law celebrating the 20 years of the Bosman ruling and dedicated to the new frontiers of EU law and Sport (the articles are available here). For those willing to gain a deeper insight into the content of the Issue we organize (in collaboration with Maastricht University and the Maastricht Journal) a launching event with many of the authors in Brussels tomorrow (More info here).More...

Asser International Sports Law Blog | International and European Sports Law – Monthly Report – October 2016. By Kester Mekenkamp.

Asser International Sports Law Blog

Our International Sports Law Diary
The Asser International Sports Law Centre is part of the T.M.C. Asser Instituut

International and European Sports Law – Monthly Report – October 2016. By Kester Mekenkamp.

Editor’s note: This report compiles all relevant news, events and materials on International and European Sports Law based on the daily coverage provided on our twitter feed @Sportslaw_asser. You are invited to complete this survey via the comments section below, feel free to add links to important cases, documents and articles we might have overlooked.  


The Headlines
We are looking for an International Sports Law Intern (with a particular interest in the CAS)! More information can be found here.


The (terrible) State of the World Anti-Doping System

The fight against doping is still on top of the agenda after the Russian doping scandal. The national anti-doping organizations (NADOs) have reiterated their call for an in depth reform of the World Anti-Doping Agency at a special summit in Bonn, Germany. These reforms are deemed urgent and necessary to “restore confidence of clean athletes and those who value the integrity of sport” and secure “the public’s desire for a fair and level playing field”. The NADOs propose, amongst others things, to separate the investigatory, testing and results management functions from sports organizations, and to remove sports administrators from crucial anti-doping executive functions. They insist that “no decision maker within an anti-doping organization should hold a board, officer, or other policy-making position within a sport or event organizer”. WADA welcomed the reform proposals and pledged to discuss them at the upcoming meeting of the foundation board. The necessity of such a reform, or at least of improving the effectiveness of the anti-doping system, has been highlighted (again!) by the release of WADA’s Report of the Independent Observers concerning the 2016 Rio Olympic Games. The reports point out that “the logistical arrangements made by Rio 2016 to support the sample collection process at official venues during the Games suffered from a number of serious failings”. These “foreseeable and entirely avoidable” logistical issues resulted in a strained sample collection process. On the way forward to reform WADA you can read some ASSER proposals in a recent policy brief by our Senior Researcher Antoine Duval. 


The Sharapova CAS award

Everything related to Maria Sharapova is necessarily making a lot of noise. Unsurprisingly, the CAS award on her positive doping test to Meldonium has attracted a lot of media attention. The decision in the dispute between Maria Sharapova and the International Tennis Federation (ITF) reduced the period of her suspension by nine months. The Russian tennis star had, during the Australian Open in January 2016, tested positive for the presence of Meldonium. A substance which had, for the first time, been put on WADA’s prohibited list in 2016. Subsequently, Sharapova announced she had been taking Mildronate tablets that had been prescribed by her doctor for many years. As her medical team “had failed to notice” that Meldonium was included on the list of prohibited substances, Sharapova claimed to be unaware that she committed a violation of an anti-doping rule. The CAS Panel shortened the period of ineligibility from the initial period of two years (imposed by the ITF’s judicial body) to fifteen months. It emphasized that the case turned on “the degree of fault that can be imputed to the player for her failure to make sure that the substance contained in a product that she had been taking over a long period remained in compliance with the anti-doping rules”. Given that her ban started on 26 January 2016, Sharapova will already be back in action late spring 2017. This ASSER International Sports Law blog by Marjolaine Viret, triggered by the Sharapova case, tackles the specific questions of the athletes (ir)responsibilities when taking medication. To what extent should they consult experts before taking a medication and to what extent can we assume that they are sufficiently qualified to assess the doping consequences of a specific product. .


The Bundesgerichtshof’s ruling in the SV Wilhelmshaven case

The ruling by Germany’s Highest Civil Court in the SV Wilhelmshaven case challenging FIFA’s training compensation system has been released. The BGH sided with the club but declined to pronounce itself on the compatibility of the FIFA regulations with EU law and on the validity of the original CAS award. The Asser International Sports Law Centre together with the Dutch Federation of Professional Football Clubs (FBO) organized a high-level conference on the case. You can read the conference report here.


New developments regarding State aid in sport

Real Madrid claim to have returned the State aid of €20.3 million it illegally received from the municipality of Madrid through various land transactions. However, the Spanish giants have also underlined that it is seeking annulment of the Commission’s decision at the Court of Justice of the EU, meaning that the saga continues despite the repayment.

The “Real Madrid appeal” has not yet been registered officially with the CJEU, contrary to the appeals launched by Athletic Club de Bilbao and Valencia CF respectively. Bilbao’s appeal concerns the Commission’s conclusion that Spain’s corporate tax system was selectively favourable for the clubs Athletic Club Bilbao, Osasuna, FC Barcelona and Real Madrid CF in comparison to the other clubs in Spain. At this moment it is still unknown whether the other clubs will join the appeal. More information on this State aid decision can be found in the blog written by Oskar van Maren.

In addition to its action for annulment, Valencia CF also launched proceedings for interim measures which aim to suspend the repayment of the aid until the General Court decides in the main proceedings. In parallel, the Spanish public authority responsible for ordering the return of the State aid from Valencia CF, i.e. the government of the autonomous region of Valencia, has asked the Commission to prolong the deadline for the return of the aid. These two requests need to be read in light of Valencia CF’s current financial situation. Its obligation to repay more than €23 million could well mean the bankruptcy of the Champions League finalist of 2000 and 2001.

Our in-house State aid and sport expert, Oskar van Maren, will dissect all the decisions of this year in a special lecture (State aid in Football: The year of the European Commission) on 24 November. 


Just Published! The Yearbook of International Sports Arbitration

Senior Researcher and head of ASSER International Sports Law Centre, Antoine Duval, has just published with CAS expert (and lawyer) Antonio Rigozzi a new Yearbook of International Sports Arbitration (the 2015 edition is available here). This is the first ever academic publication aiming to offer comprehensive coverage, on a yearly basis, of the most recent and salient developments regarding international sports arbitration, through a combination of general articles and case notes.


Case law

CAS

CAS 2016/A/4643 Maria Sharapova v. International Tennis Federation

CAS 2016/O/4684 The Russian Olympic Committee (“ROC”), [Russian Athletes] v. The International Association of Athletics Federations (IAAF)


EU

EU Commission State Aid SA.44439 (2016/N) – Sporting Arena Cork – Ireland


IOC

IOC Disciplinary Commission decision regarding Anna Chicherova

IOC Disciplinary Commission decision regarding Tatyana Lysenko


Wilhelmshaven ruling

Bundesgerichtshof Urteil vom 20. September 2016 - II ZR 25/15 - OLG Bremen LG Bremen


Other

Doyen’s Appeal to FIFA’s TPO ban before Paris court 


Official documents and Press releases

CAS list of hearing November and December

CAS The Court of Arbitration for Sport Reduces the ban of Maria Sharapova to fifteen months

CAS Essendon Case: The appeal filed by 34 players is not entertained by the Swiss Federal Tribunal

CAS The Court of Arbitration for Sport issues decisions in the case of five Russian racewalkers

CAS IAAF appeal upheld – Rita Jeptoo suspended for four years by the Court of Arbitration for Sport

CIES Football Observatory Monthly Report n°18 - October 2016, “Recruitment strategies throughout Europe”

Commentary by the Spanish anti-doping agency AEPSAD on the whereabouts High Court decision (in Spanish)

European Parliament Committee on Culture and Education on an integrated approach to Sport Policy: good governance, accessibility and integrity (2016/2143(INI))

FIFA Several football associations sanctioned after discriminatory and unsporting conduct of fans

FIFA President Infantino provides update on steps taken to improve governance and compliance as well as football development efforts

Spanish FA sanctioned for international transfers of minors

IAAF Ethics Board Statement on preliminary investigations into ‘brown envelope’ rumours surrounding bid for 2017 World Championships

IOC Declaration of the 5th Olympic Summit Protecting clean athletes is an absolute priority for the entire Olympic Movement

NADA-Statement zum 5. Olympic Summit

UK Parliament Culture, Media and Sport Committee, The Governance of Football inquiry

WADA Statement regarding Maria Sharapova CAS decision

WADA statement regarding Olympic Summit

WADA Compliance Review Committee Update

WADA Statement by Richard H. McLaren, Independent Person, Concerning Release of his Investigation Report, Part II

WADA Report of the Independent Observers, Games of the XXXI Olympiad, Rio de Janeiro 2016

WADA statement regarding renewed NADO anti-doping reform proposals 


In the news

Doping

AP, New WADA director general Olivier Niggli anticipates more state-sponsored doping

Nick Butler, Exclusive: IOC Medical Commission chair calls for more Government funding for WADA

Nick Butler, WADA report is microcosm of everything wrong with Rio 2016 and IOC

Causa Sport, „Fall Scharapowa“: Unachtsamkeit schützt vor (Doping-)Strafe

George Georgakopoulos, Greece lags in doping tests and would need assistance

David Millar, How to Get Away With Doping

Michael Pavitt, New testing authority within WADA proposed at Olympic Summit

Sport Leaks and Doping Leaks

Luis Torres Montero, Claves de la reducción de la sanción a Sharapova: análisis del reciente laudo del TAS

Jonathan Sachse and Daniel Drepper, Wie VfB Stuttgart und SC Freiburg Doping organisierten

Thorhild Widvey, WADA Must Be Reinforced and Publicly Supported 


Football

Vivek Chaudhary, FIFA's Gianni Infantino may face Ethics Committee investigation

Willem Feenstra, FIFA charged with complicity in human rights violations Qatar

Keir Radnedge, Infantino talks a good game about Fifa reform, but can he deliver?

Mike Ticher, Human error is part of football and video refereeing will solve nothing  


Ice Skating

Ernst Bouwes, De internationale sportweek van S&S: EU geeft schaatsers gelijk in 'Ice-derby'-zaak

Causa Sport, Kartellverfahren gegen den internationalen Eislaufverband ISU: Das „Ein-Platz-Prinzip“ vor dem Aus? 


Other

Brittany Bronson, Politicians Place a Bet on a Stadium, and Vegas Pays for It

Juliet Macur, Long Before Kaepernick, There Was Navratilova

Rebecca Ruiz, Russia Sports Minister Promoted to Deputy Prime Minister 


Academic materials

Antoine Duval, Tackling Doping Seriously - Reforming the World Anti-Doping System after the Russian Scandal

Despina Mavromati, Application of the 2015 WADA Code through the Example of a recent CAS Award (Sharapova v. ITF)

Despina Mavromati, The Role of the Swiss Federal Tribunal and Its Impact on the Court of Arbitration for Sport (CAS)

Mordehai Mironi, The promise of mediation in sport-related disputes

Michal Radvan and Jan Neckář, Taxation of Professional Team Sport Athletes in the Czech Republic


Books

Antoine Duval and Antonio Rigozzi, Yearbook of International Sports Arbitration 2015 


Blogs

Richard Bush, Best practice for Sports Governing Bodies when dealing with individual complainants: Part 1 - Internal procedure and Part 2 - Guidelines for legal teams

Sean Cottrell and Mark Hovell, Life as a CAS arbitrator at the Rio Olympic Games

Sean Cottrell, Protecting the integrity of the Rugby World Cup - Ben Rutherford, Senior Legal Counsel and Integrity Unit Manager at World Rugby

Sean Cottrell, Nick De Marco, Nick Tsatsas and Richard Berry, How does the transfer market influence the integrity of football?

Nick De Marco, “Football for Sale” - What is the problem, and what are the solutions?

Antoine Duval and Kester Mekenkamp, De- or Re-regulating the middlemen? The DFB’s regulation of intermediaries under EU law scrutiny at the OLG Frankfurt

Jon Elphick, How athletes will be affected by the UK’s changes to “non-dom” tax rules

Alex Haffner and Krish Mistry, The law on banning athletes from competing in rival sports leagues

Philip Hutchinson, Who shoulders the blame? An analysis of vicarious liability in the sports industry

Interpol Integrity in Sport Bi-Weekly Bulletin - 3-16 October 2016 and 17-31 October 2016

Christian Keidel and Alexander Engelhard, How the Bundesliga’s new “no single buyer” rule has increased the broadcasting revenue for German football

Saurabh Mishra, Important lessons for athletes on doping sabotage: A review of WADA v. Narsingh Yadav

Laura McCallum, An overview of key case law relating to negligent liability for sports injuries (Part 1) and (Part 2)

Alice McDonald, Footballers facing tax fines: who is responsible for inaccurate tax returns?

Marine Montejo, Case note: TAS 2016/A/4474 Michel Platini c. Fédération Internationale de Football Association

Michael Rueda, What is next for NCAA student-athletes? From O'Bannon onto Jenkins

Ralph Russo, Although NCAA loses its appeal, future still hazy

Luke Sayer, Possible ways the Therapeutic Use Exemptions system can be improved to prevent abuse

Zane Shihab and Nick Bitel, What effects have FIFA’s Intermediaries Regulations had on player representation and commission levels?

The Swiss Ramble, Arsenal - New Sensation

The Swiss Ramble, Borussia Dortmund - The Sound Of The Crowd

The Swiss Ramble, Manchester City - My Aim Is True

The Swiss Ramble, Stoke City - But I'm Different Now

Oskar van Maren, Case note: State aid Decision on the preferential corporate tax treatment of Real Madrid, Athletic Bilbao, Osasuna and FC Barcelona

Ben Van Rompuy, What can EU competition law do for speed skaters?

Marjolaine Viret , Taking the Blue Pill or the Red Pill: Should Athletes Really Check their Medications against the Prohibited List Personally? 


Upcoming events

18 November - Football Law Conference and Sportspersons’ Dinner, St John’s Buildings Barristers’ Chambers and the Centre for Sports Law Research at Edge Hill University, Stretford, UK

24 November – Sports Law Lecture “State aid in Football: The year of the European Commission”, T.M.C. Asser Instituut, The Hague, the Netherlands

8 December - Actualiteitencursus Internationaal Sportrecht, De Kempenaer Advocaten, Arnhem, the Netherlands


 


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