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Mr. /Madame President, Your Excellencies, may it please this Honorable Court.

My name is
Mary Ann Bernadette Cafe, the agent of the Applicant in this case.

I will prove before this Court our four submissions:


1. Reverentia’s encouragement of the East Agnostican referendum violated
Agnostica’s territorial integrity, the principle of non intervention, and the
United Nations Charter generally

2. The purported secession and subsequent annexation of East Agnostica are


illegal and without effect, and therefore East Agnostica remains part of the
territory of the Federal Republic of Agnostica

3. The Marthite Convention ceased to be in effect as of 2 April 2012 and, in


any event, Agnostica did not breach the Convention

4. Reverentia’s removal of the software at the Marthite extraction facilities


violated international law

First Argument

First, Reverentia violates the territorial integrity of Agnostica under..(legal basis)

The act of proposing a resolution by the Reverentia Parliament is void and illegal,
this will constitute a threat to the peace and stability of our nation. Under Article 2 (4) of the
United Nations Charter which provides that, “all members shall refrain in their international
relations from the threat or use of force against the territorial integrity or political independence
of any state, or in any other manner inconsistent with the Purposes of the United Nations”.

(not sure if isasama ito)..

Under Article 3of the U.N Charter of Rights and Duties which provides that “every
State has the Duty to refrain from Intervention in the internal or external affairs of any other
State. The foregoing principle prohibits not only armed force but also any other for interference
or attempted threat against the personality of the State or against its political and, economic or
cultural elements. Furthermore, no State may use or encourage the use of coercive measures of
an economic or political character in order to force the sovereign will of another state and obtain
from its advantages of any kind.

On the 18 paragraph of the record, the Vice-President of Reverentia in his article in The
Reverentian Times, uses threat and force to reaffirm the Convention between Agnostica and
Reverentia. This is untenable and impermissible under the Article 2 (4) of the United Nations.

Morever, the act of Reverentian Parliament Referendum is unlawful under Article 2


(4) of the United Nations Charter. The possible annexation of East Agnostica by Reverentia
would entail the risks of peace and stability of the state. The mineral resources are found in
Agnostica, it is where the core ingredient of the Reverentia’s traditional medicine and the
source of raw materials needed for the exportation into Reverentia. The Agnorevs only took
advantage of the economic opportunities in Agnostica. It is our moral obligation to protect
and save the Marthite industry from individuals who are only after to the high profit made by
such instance.

Second Argument

This will lead me to my second argument that that proposed resolution for the
dissolution of the nation was defeated. Meaning the succession proposed by Reverentia did not
reached the required vote of three quarters to dissolve the union and create two independent
states.

(Look for a case).....

The requirement of annexation or secession needs the consent of the State....

Third Argument

The State of Reverentia failed to comply with the provision provided for under Article
4 (a) which provides that ‘except as permitted under article 4(d), Reverentia undertakes that
RMT will distribute Marthite only to traditional medicine practitioners in Reverentia and East
Agnostica. The international market sale of Reverentia breached the Convention.
The RMT’s act of international sale is invalid and impermissible. The Covenant does
not permit the sale of Marthite outside Reverentia and Agnostica. Hence, Agnostica has a valid
ground to terminate the validity of the Mathite Convention.
The primary function of Mathite is for the traditional medicine of Reverentia, it is
unknown outside the Thanatosian Plains until the publication of the journal from Institut
Luxembourgeois des Sciences Appliquess (ILSA) changed the situation. We, Agnosticans
entered into a Convention out respect for the traditional medicine of Reverentia and its users.
There is a substantial change in the nature and character of the subject matter of the Convention
as a result we need to terminate the Convention.
Assuming arguendo that there is no substantial change in the Marthite Convetion. In the
law of supply and demand, defines the effect the availability of a particular product and the
demand for that product has on price. On the 13 paragraph of the record, there is a sudden
increase of price in the market sale of Marthite and shortages among its traditional users made
by RMT. This would still constitute a breach of obligation under the Marthite Convention.

Fourth Argument

The removal of the personnel in East Agnostica constitutes a violation provided for
Article 8 of the Montevideo Convention on the Rights and Duties of the States which provides
that ‘no state has the right to intervene in the internal and external affairs of the other’.

On the 16 paragraph of the record, the Prime Minister Mortiz declares that the
Marthite Convention terminated and it was no longer subject to the Convention. The lease
between Baxter Enterprises is valid in compliance with the international law. The act of
Reverentia’s withdrawal of the personnel in the East Agnostica was intentional hence,
constitute a sabotage which violates the Article 8 of the Montevideo Convention on the
Rights and Duties of the States. In the plight of this, it has crippled the Marthite operations.
Under Article 2 of the Marthite Convention, the facilities which includes the mining-
support facilities with the territory of East Agnostica, engineers and equipment are owned by
the Government of Agnostica. (Legal basis for this)…

The applicant respectfully submits, Your Excellencies, to help to us settle this dispute.
The Federal Republic of Agnostica has the moral obligations under international law to ensure
and provide a life-saving product and to alleviate the suffering of the children around the world.

Hence, to settle this dispute, we plead this Court to uphold the equity and justice
brought about by the State of Reverentia.

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