TEAM ASSIGNMENTS Statement of Facts Hannie - Basis is Compromis for all the statement of facts - Refer to Jessup Memorial

l For Applicant and Respondent 641A and 641R Files and follow the format for Statement of Facts .

Applicant Issue # a Juvy Issue # b Juvy Issue # c Golda Issue # d Golda Las Aplayas seeks the Court to adjudge and declare that: (a) The court may exercise jurisdiction over its claims; ; (refer to Respondent Memorial Issue #1 in 641A file) (b) Los Pueblos has violated its obligations under international law and shall indemnify Las Aplayas by causing or allowing the deposit on its territory of toxic herbicides that have caused damage to human health, property and the environment as well as by greatly contibuting to greenhouse gas emissions that caused adverse climate change impacts felt specially in Las Aplayas; (1. Support this issue. Bind the use of toxic herbicides directly with climate change; 2. Support the health and environmental issue with medical and scientific findings by reputable agencies and organizations)

(c) Los Pueblos shall: i. Respect the sovereignty and territorial integrity of Las Aplayas; and (highlight the territorial violations of Los Pueblos. Bind the responsibility of use of third part contractors as solidary with Los Pueblos government) ii. Forthwith, take all steps necessary to prevent, on any part of its territory, the use of any toxic herbicides in such a way that they could be deposited onto the territory of Las Aplayas; and (Find internationally accepted protocols, cases and measures that are effective in preventing the dispersion of herbicides that Los Pueblos is not currently doing)

iii. Prohibit the use, by means of aerial dispersion, of such herbicides in Las Aplayas, or on or near any part of its border. (cite alternative methods of dispersion that are less indiscriminate and more precise) (d) It is entitled to make claims in relation to the treatment of the detained Las Aplayas migrants or environmentally displaced persons now in Los Pueblos, and Los Pueblos has failed to accord them status consistent with international law; (Refer to Issue # 3 in 641A file, Almost all issues are addressed there)

Respondent Issue # a Hazel Issue # b Hazel Issue # c Kate Issue # d Kate Los Pueblos requests the Court to adjudge and declare that: (c) The court lacks jurisdiction over the claims of Las Aplayas, as it is no longer a state; (refer to Memorial Issue #1 in 641R file) (d) Los Pueblos aerial spraying is a legitimate exercise of sovereignty over its territory; (Support this issue by jurisprudence or International Case Law)

(e) Los Pueblos acts of spraying herbicides with the use of glyphosate does not cause environmental damage as it is presently not listed as an organic pollutant (Annex I, Protocol to the 1979 Convention of LongIRange Transboundary Air Pollution on Persistent Organic Pollutants) that could cause potential damage to the environment; If at all, aerial spraying falls under the doctrine of the state of necessity; (Research: Medical Effects, jurisprudence, and similar cases that support this issue) (f) Los Pueblos has not violated international law in its treatment of the migrants from (former) Las Aplayas as the migrants are being treated in

accordance with its obligations under international law and, in any event, Las Aplayas is foreclosed from making claims with respect to those individuals because of its failure to take available affirmative steps to protect them. (refer to Respondent Jessup Memorial Issue #3 in 641R file. Cite failure of Las Aplayas in preventing mass exodus of immigrants)