Recon, Gonngman and Others v. Dou Boux (CFOR Only)

by **Dou Boux** » Sun Feb 26, 2017 3:55 am

The Supreme Court of The Kingdom of Dou Boux and its Colonies & Protectorates

-Property Division-

Case No: 000/008/101

In the case of

Recon, Gonngman and Others

Joint Plaintiffs

versus

The Kingdom of Dou Boux

Defendant

by **The Recon Empire** » Sun Apr 30, 2017 4:11 am

Dou Bouxian High Commission
OF THE RECON EMPIRE

To: Constitutional Court of The Kingdom of Dou Boux and its Colonies & Protectorates
From: Dou Bouxian High Commission of the Recon Empire

Your Honours,

The Dou Bouxian High Commission of the Recon Empire is seeking this suit to appeal for compensation and proper remuneration for all Reconian citizens residing in Dou Boux who have been affected by the Abolition of Slavery Act, 2017. Upon the request and authorization of High Commissioner Benedict Tenitz, His Majesty's High Commissioner to Dou Boux, the King's Bench has announced the legal team who will take on this case, and they include

Advocate Nathan Hejavec, Juris Doctor, King's Counsel, Companion of the Empire (Second-Class)

Advocate Edward Moudin, Legum Doctor, Crown Prince's Laurel, Companion of the Empire (First-Class)

Advocate Orwell Weston, Juris Doctor, King's Counsel, Consul's Statute of Prestige

Introduction
While we are not seeking justice for the legal authority of the sovereign government of Dou Boux to legislate the Act within its own sovereign borders, we find that the conflicting legal authorities against an Act of Theft should be duly addressed. The Government of Dou Boux ought to act with greater prudence in ensuring the government itself does not commit its own laws.

Theft against Private Citizens
As the High Commission for Reconian citizens, we can only ensure that our citizens do not suffer from an act of theft committed against them, regardless of the perpetrator being the government or private citizens. By passing such law, the government is utilizing its authority and trust given to it, to effectively steal private property from Reconian citizens. Despite the slaves becoming free, the government must still provide remuneration for these slave owners as they have paid real dollars to obtain these slaves while they were still a commodity. By usurping personal property that was legally purchased, the government of Dou Boux undermines the value of money, and the nation's rule of law.

Diplomatic Agreements
When Dou Boux and the Recon Empire formed diplomatic communications several years ago, it was agreed upon the Geneva Diplomatic Convention, effectively protecting all visitors between our two nations. In this instance, the Government of Dou Boux is breaking these protocols that govern the traditions and conventions that protect those who travel. It is to be noted that there exists Dou Bouxian citizens in the Recon Empire as well, and if the government of Dou Boux were to continue in this act of theft, the same form of treatment can be dealt against your own citizens as well. This is a precedent we would not like to set.

Appeal
The High Commission of the Recon Empire appeals to the Constitutional Court to overturn the act's authority due to its inappropriate wording and conflicting authority with theft laws of Dou Boux. The Government of Dou Boux does not have authority to steal from our citizens. It is to be noted that the Supreme Government of the Recon Empire will take further action if these legal mistakes are not properly taken care of.

The High Commission of the Recon Empire would like to point out that this lawsuit has overarching effects on the provisions that protect Dou Bouxian citizens in the Recon Empire, and should be settled with the Ministry of Foreign Affairs of Dou Boux, due to its implicating diplomatic consequences.

The Supreme Government of the Recon Empire has identified all Dou Bouxians and businesses currently residing in the Recon Empire, and will not hesitate to take necessary actions against them should this lawsuit not be settled in proper diplomatic order. However, we hope that through this lawsuit, the matter can be settled without a need to trigger any further aggression for economic sanction.

Yours sincerely,

Mr. Brandon Chen
First Secretary
Dou Boux High Commission of the Recon Empire

by **Dou Boux** » Mon May 01, 2017 6:57 am

___________________________________________________________________________________

Opening Statement by: Advocate Sir Randolph John Palmer, KGCF : Chief Counsel for The Defendant

___________________________________________________________________________________

Your Honours,'

The issue that we are dealing here is mainly one about sovereignty, and the right to exercise jurisdiction over sovereign territory. We are also dealing with the right of a government to exercise its own legislative program

Exercising of Sovereignty

The Government of The Kingdom of Dou Boux is well within its sovereignty to pass a bill that emancipates hundreds of thousands of persons who have resided in this Kingdom for centuries. No other sovereign entity or government has the right to inhibit the government of this realm from executing its legislative program for the time that it in power.

His Imperial Majesty's Loyal Opposition is the only entity that even has the right to make the government believe that they (the opposition) shall interrupt the government's legislative program, if the government is passing unpopular reforms.

That is the right, and prerogative of His Imperial Majesty's Loyal Opposition and no one else, whatsoever.

Violation of Sovereignty

A case like this, when brought before a Dou Bouxian court of law, no matter the outcome, shall create a precedent, for other cases. If the outcome of this case is decided in favor of the Plaintiff, it shall create a precedent that shall allow foreign powers to file a case in a Dou Bouxian court of law, against a governmental ordinance passed by this realm, simply because they don't agree with that particular ordinance.

Let's say for example, that this government passes an ordinance with regards to her colonies, and Country B isn't in favor of that ordinance they shall have the right (if this particular case is decided in favor of the Plaintiff) to file a lawsuit against this government, which if decided in their favor, would force this government to repeal the law, purely because some other country doesn't agree with this government's legislative policy.

This sequence of events, if they occur in this order would totally undermine the right and ability of this government to pass laws, statutes and ordinances, which would eventually lead to anarchy, and disarray, and if I may be so bold Your Honours, it would lead total break down in the justice system, which would be continually abused. And if governments can do it, then why not private corporations, who let's say, want to drill for oil under a nature reserve?

Rehabilitation of The Former Slaves

The main concern of His Imperial Majesty's Government in this matter is the rehabilitation of the emancipated slaves. Being former property themselves, they never had any income, or property of their own, so now many are destitute.

His Imperial Majesty's Government would like to allocate a large potion of its resources into the providing for these people (housing, healthcare, etc.) so that they can get back onto their feet.

The former slave owners will have capital and resources of their own that they can live on, the former slaves, in most cases, are not so lucky. His Imperial Majesty's Government will not let millions of its citizens go destitute, simply because former slave owners demand compensation.

Act of Theft & Threats of Sanctions

His Imperial Majesty's Government is deeply offended by this being categorized an act of theft by The Recon Empire, and the threat of sanctions by the same. His Imperial Majesty's Government fully intends to address the complaints of the former slave owners, but the Plaintiff must understand that the former slaves are the first priority.

As for the threat of sanctions, His Imperial Majesty's Government is deeply hurt. They believe that that one of this nation's eldest allies should be able to trust them enough to handle the situation as they see fit, and that includes, compensation for the former slave owners.

_______________________________________________________________________________

My thanks.
_______________________________________________________________________________

by **The Recon Empire** » Mon May 01, 2017 8:10 am

Dou Bouxian High Commission
OF THE RECON EMPIRE

To: Constitutional Court of The Kingdom of Dou Boux and its Colonies & Protectorates
From: Dou Bouxian High Commission of the Recon Empire

Your Honours,

It appears the defence is attempting to misdirect this lawsuit into the legal authority of the Dou Bouxian government and its sovereignty. We'd like to point out that it is absolutely not. If one were to review the consistent position that our team puts forth, that is the ultimate respect for sovereignty of a nation and its government in the position to legislate laws that govern its people to the fullest extent.

This is a key point that we have reiterated from the very beginning. We are sure that Your Honours will differentiate this misdirection and the justification for the lawsuit.

In case this still results in any foggy misconceptions of what this lawsuit is about, do allow us to make it clearer. The High Commission of the Recon Empire represents the collective intention of private Reconian citizens residing in Dou Boux, who feel their rights have been stripped in accordance to the law of Dou Boux.

1. "Exercising of Sovereignty" - We are not challenging the authority of the Dou Bouxian Government's ability and authority to legislate laws within its own sovereign borders, and this should not be a factor for consideration. This is a judicial appeal in the Constitutional Court of Dou Boux.

2. "Violation of Sovereignty" - By appealing to the Constitutional Court, we believe it is in every right of any legal entity in Dou Boux to file. If the Dou Bouxian government were to prevent legal entities of Dou Boux in seeking independent judicial appeal from the legislative authority, we have reason to question whether or not this is an overreach of authority. However, it is strictly not in this lawsuit that this appeal is seeking. We do not have any reason to question any potential overreach of government authority, and it is well beyond our means and reason to pursue this. It is up to your nation's own check and balances to maintain this delicate dynamic.

3. "Rehabilitation of Slaves" - It is to be clarified that it is not our responsibility to rehabilitate or provide any form of welfare on behalf of the Dou Bouxian Government. As the Dou Bouxian Government is formed by your electoral process, this authority comes with the responsibility to uphold the implications and burdens that face Dou Boux. It should not be transferred to Reconians residing in Dou Boux.

Today, it stands clear, Reconian citizens residing in Dou Boux, with the trust entrusted by the Reconian government to the Dou Bouxian Government, who have been promised basic human rights, have had slaves, in their pre-Act status as commodities and property, taken away without compensation from the Government.

If the Dou Bouxian Government wishes to say that the government has every right in taking away property of private citizens; does that set a precedent against the theft laws that govern Dou Boux? And if so, is the government setting a role model for all thieves of Dou Boux? Does that mean that any entity has the legal right to take property away from another private citizen, whether or not he or she is Reconian?

Furthermore, in accordance to monarchies worldwide, only the Monarch himself is above law. His Majesty's Government is, and only is, authorized to legislate, executive and interpret the laws that govern the great Dou Bouxian state, and therefore, these acts of theft, which we suppose, are part of the laws of Dou Boux, should bind the Dou Bouxian Government in its acts and hold it responsible to standards of any other Dou Bouxian entity, private or public. This is the right of the judicial court, to uphold the Constitution and the laws. If a government were to infringe its own laws, only the Constitutional Court has the power to seek the proper justice.

However, the High Commission is, within our legal rights, to state that we are open to settle this by out-of-court settlement, as long as at the end of the day, Reconians residing in Dou Boux receive their fair share of compensation and remuneration.

Yours sincerely,

Mr. Brandon Chen
First Secretary
Dou Boux High Commission of the Recon Empire

by **Dou Boux** » Mon May 01, 2017 1:45 pm

___________________________________________________________________________________

Reply by: Advocate James Arthur Hudson, MOF : Counsel for The Defendant

___________________________________________________________________________________

Your Honours,

Setting of a Precedent

His Imperial Majesty's Government is incredibly offended at statements made by the Plaintiff that this act is setting a precedent to the thieves of Dou Boux. The thieves of Dou Boux don't deal in cases where human life, and human liberty is at stake.

His Imperial Majesty's Government isn't stealing property from any person residing within Dou Boux. They are merely emancipating millions of persons who have lived under a state of bondage for all their lives, as have their ancestors, sometimes for hundreds of years.
Holding persons in bondage is not, and I repeat to Your Honours, not in line with the ancient statutes, and ordinances of Dou Boux, and while, prior to this act, it was not illegal to keep slaves, and other related chattels, it was against universal human rights.

Nothing was done about this travesty until now. All men have the right to life, liberty, and the pursuit of happiness. Slaves don't enjoy any of these rights. They don't have the right. Let's use this country prior to the passing of this act as an example. The slaves didn't have the right to life. Their lives could be snuffed out at any time by their masters, and there was no law in the country that could punish their masters, because there is another law that says that you cannot hold a man criminally to account for dealing with his goods and chattels as he sees fit.

A slave has no right to liberty. He lives to serve his master. He cannot be free. His sole existence, his sole purpose for living is to serve his master. He cannot pursue his own happiness. How can he, when his marriage is not recognized under law, he can be split from his wife and children at any time, and his children will suffer the same sorrowful existence.

This is not something we can allow in our first-world country. It is the right of this government to abolish this outrageous practice, and settle the manner as they see fit, without the interference of third-parties, however honourable their intentions may be.

Plea

The Defendant recognizes the right of the Plaintiff to petition This Honourable Court, but is just worried about the precedent it shall set for future cases, where the Plaintiff is not as honourable as this one.

His Imperial Majesty's Government wishes that all persons living in His Imperial Majesty's empire know that they have the right to petition in His Imperial Majesty's court whenever they see fit.

Out-of-Court Settlement

Surely if His Imperial Majesty's Government compensates the parties represented by the Joint-Plaintiffs, then they will have to surely compensate the millions, and millions of other slave owners in Dou Boux, who also lost slaves?

His Imperial Majesty's Government is already paying for the well-fare and upkeep of the former slaves for the time being, and to place an additional financial burden on them, would be out of taste, to say the very least.

However, in the spirit of diplomacy, we, would consider in the presence of Your Honours, to negotiate with the Joint-Plaintiffs, if they can come up with, reasonable compensations packages for slave owners who owned a particular variety of slave (i.e. adult male between the ages of thirty-five and fifty, and adult female from the same age to the same age), per slave.

We would also like the opinion of the Joint-Plaintiffs, that if His Imperial Majesty's Government compensates the parties they are representing, would His Imperial Majesty's Government be obligated to compensate former slave owners in all parts of Dou Boux, and its empire, for the loss of their slaves. Because as far as we are aware, this case is only about the Joint-Plaintiffs fighting for compensation for the parties they represent, or would they like all former slave owners to receive compensation, regardless of nationality, because as far as we are aware, this case is not about compensation across the board, it is merely compensation for those parties being represented by Our Honourable Colleagues the representatives of the Joint-Plaintiffs.

We respectfully request that Our Honourable Colleagues the representatives of the Joint-Plaintiffs, help as with regards to the answer to a very burdening question on our minds? And this is addressed to them- Honourable Colleagues, is this case for compensation across the board, or is it just merely a case of claiming compensation for the parties you represent?

_______________________________________________________________________________

-I thank Your Honours-
_______________________________________________________________________________

by **The Recon Empire** » Tue May 02, 2017 5:36 am

Dou Bouxian High Commission
OF THE RECON EMPIRE

To: Constitutional Court of The Kingdom of Dou Boux and its Colonies & Protectorates
From: Dou Bouxian High Commission of the Recon Empire

Your Honours,

Being offended does not excuse one from the crimes which may have been committed. It is no denying that the Dou Bouxian Government has chosen to emancipate slaves from their original status, this act itself perpetrates the crime of theft. It is not a situation of "either or", but a decision and a consequence that happens within the same action.

As mentioned before, the plaintiff is not seeking to dispute the right to life and liberty of all people, as stated within your Constitution. Despite the Defence consistently pointing out this fact, it should not have any bearings or reason to alter the case in any way.

What needs to be addressed is the fact that private Reconian citizens have paid real money for these slaves, and then have the Dou Bouxian government take them away without compensation. The very fact that private Reconian citizens have had the opportunity to buy, legalizes the fact that it is well within the rights of all to purchase slaves. What cannot be denied is the fact that Reconian citizens have lost wealth and resources due to the lack of compensation provided by the Dou Bouxian government when setting this law. This is where the appeal comes in.

The Plaintiff has no authority to determine whether or not the Defendant needs to settle the compensation for the millions of other slave owners which this act has affected, but it ought to give fair compensation to foreign citizens who have placed their trust in Dou Boux and its government. As mentioned again, it is also not our duty as private citizens to ensure whether or not the government compensating is "out of taste" or as a "burden", either due to the government's own potential incompetence or other reasons. If the government elected into office cannot deal with their own finances, maybe it would've been wiser for Dou Bouxian legislators to relook the bill's budgeting before signing it into law. However, what cannot be disputed is that these Reconian citizens are due for compensation, and this cannot be made clearer.

Now comes the negotiation for the settlement. Out of court settlements are proposed by the Defendant, and the Plaintiffs will await a proposal for this settlement. We have offered the Defendant an option which we may interested, and it is not one that we necessary need to have proposed. We will say, that it is expected for settlements to be equal or more to the amount paid by the slaveowners, adjusted for inflation. The Plaintiff is not obliged to agree to the settlement, as it is likely for the Court to award it directly for us.

The reason for this is because should the Defendant not wish to offer this private settlement, it will risk the Constitutional Court ruling a groundbreaking precedent, awarding the Plaintiff for compensation. This, we believe, will be more disastrous for the Dou Bouxian Government as it will open up a floodgate of appeals from other Dou Bouxian and slaveowners of other nationalities to claim their fair share of compensation based on this court case. Thus, it is important for the Defendant to consider how they wish to settle this issue, whether through a one-time out of court settlement or risk millions more seeking future appeals.

We believe the Court to uphold the justice that binds every entity of Dou Boux, the King exempt, to the same standard.

Yours sincerely,

Mr. Brandon Chen
First Secretary
Dou Boux High Commission of the Recon Empire

by **Dou Boux** » Sun May 07, 2017 6:36 am

___________________________________________________________________________________

Reply by: Advocate Dame Brigitte Dos Santos, DcOE (Dou Boux), Counsel for The Defendant

___________________________________________________________________________________

Your Honours,

Court Settlement

After many discussions with our client, we have decided against an out of court settlement, but we have come up with a basic (in court) settlement for the parties represented by the Joint-Plaintiff, which we hope that this honourable court shall accept, and award to the parties represented by the Joint-Plaintiffs.

The settlement is as follows:

Each Reconian/Gonngmanian citizen who has lost their slave/s because of this act, shall receive a cash amount, which shall be 75% of the value of the slave/s at the time of their emancipation; and the former slave owners shall receive a tax deduction for the year of 2018, to the value of the remaining 25% of the value of their slave/s at the time of the emancipation, that is still owed to them (the owners).
Furtherly, the owners shall receive a further payment of 5% of the value of each of their slaves in December 2018, as a personal gesture from The Dou Bouxian Government our clients.

We hope that the Joint-Plaintiffs shall accept this offer of compensation, and we further hope that this honourable court shall grant it to them.

______________________________________________________________________________

I thank you.
______________________________________________________________________________

by **The Recon Empire** » Sun May 07, 2017 7:20 am

Dou Bouxian High Commission
OF THE RECON EMPIRE

To: Constitutional Court of The Kingdom of Dou Boux and its Colonies & Protectorates
From: Dou Bouxian High Commission of the Recon Empire

Your Honours,

We are glad to see appropriate action taken by the Defence in pursuit of fairness and justice.

The Joint-Plaintiffs will accept the deal proposed by the Defence, only with the additional clauses be included, provide comprehensive and detailed contractual agreements.

An independent Recon-Dou Boux Commission, filled with 3 members from each nation, to evaluate the value of the slaves.
The national Dou Bouxian central bank interest rates to be applied to the total compensation package beginning from the hour which the said bill was signed into law.
The national Dou Bouxian inflation rates to be applied to the total compensation package beginning from the hour which the said bill was signed into law.
All compensation to be made within the coming 30 days, ending on 7 June 2017, 11:59pm Federal Recon Time.
Any additional delays (referring to the 25% tax deduction delayed until 2018) in payment, from 7 June 2017 onwards, to be treated with the national Dou Bouxian corporate loan interest rates.
All payment to be made in Dou Bouxian dollars.
For the Defendant to be incurred any additional payments for the process of distributing compensation (transport and miscellaneous costs of the individual claimants'), claimable up to R$800.

Upon agreement by the Defence, the Joint-Plaintiffs will accept the settlement, and withdraw the lawsuit.

Yours sincerely,

Mr. Brandon Chen
First Secretary
Dou Boux High Commission of the Recon Empire

by **Dou Boux** » Sun May 07, 2017 8:26 am

___________________________________________________________________________________

Reply by: Advocate Dame Brigitte Dos Santos, DcOE (Dou Boux), Counsel for The Defendant

___________________________________________________________________________________

Your Honours,

Our clients do hereby agree to clause 3, but would like to make some other changes to the other clauses:

1) The former slave owners shall have to submit compensation claims, which must include the following:

A formal claim.
Official legal (court, etc.) records as to the value of their slaves at the time of their emancipation, or last valuation (it is this valuation, that shall be used for the basis of each individual compensation package). There shall be Dou Bouxian commission made up of ten persons that shall be charged with paying the various compensation packages. They shall be appointed by His Imperial Majesty and shall be assisted by various government departments, as required.

2) The interests rates of The Dou Bouxian Central Bank shall only be added to the 75% cash payment, if it isn't paid by the 7th of July at 23h59. The Joint-Plaintiffs need to realise the sheer number of compensation packages that need to be put together.
3) Accepted
4) With regards to the tax deduction, this shall be a tax deduction automatically taken off the taxes of Reconian citizens who owned slaves. This tax deduction shall be to cover the remaining 25% of the value of the slaves. No interest shall be charged on it as it is an automatic deduction, and not a payment in the conventional sense.
5) All payments shall be made in Dou Bouxian Pounds.
6) The Joint-Plaintiffs are representing the Reconian and Gonngmanian citizens living in Dou Boux, who did not attend the trial in their own right as Plaintiffs (they might have as spectators), the Dou Bouxian Government is no obligated in any way to renumerate their transport, etc., costs.

We hope that the Joint-Plaintiffs and this honourable court shall find these amendments acceptable.

______________________________________________________________________________
I thank you.
______________________________________________________________________________

by **The Recon Empire** » Sun May 07, 2017 9:17 am

Dou Bouxian High Commission
OF THE RECON EMPIRE

To: Constitutional Court of The Kingdom of Dou Boux and its Colonies & Protectorates
From: Dou Bouxian High Commission of the Recon Empire

Your Honours,

1. "The national Dou Bouxian central bank interest rates to be applied to the total compensation package beginning from the hour which the said bill was signed into law."

This clause will not be open for changes, due to the fact that during the time of emancipation, several business owners have suffered tremendously due to suspended credit. These slaves are meant to work in their businesses, but due to the act, has resulted in their wealth decreasing. The Defendant must compensate this amount to the full extent, from when the Defendant had emancipated the slaves, thus starting from the hour of the bill signed.

As for percentage, it must be recognized that if it were 75% paid and 25% owed, it still retains 25% owned. The Joint Plaintiffs will not hesitate to open another lawsuit to chase for the additional 25%. It is to be mentioned again, "sheer number" should not be a reason for paying any lesser, and the Defendant should either borrow or declare bankruptcy to pay back what is originally due. The Joint Plaintiffs will be open to discussing extending the deadline by another 30 days, but what needs to be paid must be paid.

"For the Defendant to be incurred any additional payments for the process of distributing compensation (transport and miscellaneous costs of the individual claimants'), claimable up to R$800."

This refers to the individual owners' process of going to retrieve compensation from the Defendant. Unless the Defendant can produce an alternative method to collect money that does not impose additional costs on the Joint-Plaintiffs, this clause must stand to protect the full compensation amount.

The Plaintiff will make the changes as follows below, specifically to clause 3 and 6, while summarizing all terms that have been included thus far.
==================================

1. Each Reconian/Gonngmanian citizen who has lost their slave/s because of this act, shall receive a cash amount, which shall be 75% of the value of the slave/s at the time of their emancipation; and the former slave owners shall receive a tax deduction for the year of 2018, to the value of the remaining 25% of the value of their slave/s at the time of the emancipation, that is still owed to them (the owners).

2. Furtherly, the owners shall receive a further payment of 5% of the value of each of their slaves in December 2018, as a personal gesture from The Dou Bouxian Government our clients.

3. The formation of an independent commission to evaluate the final value of slaves made up of members
who are of neither Reconian, Dou Bouxian nor Gonngman citizenry,
who do not hold any public office in any nation,
with credentials to evaluate the true value of slaves at their point of emancipation.
4. The national Dou Bouxian central bank interest rates to be applied to the total compensation package beginning from the hour which the said bill was signed into law.

5. The national Dou Bouxian inflation rates to be applied to the total compensation package beginning from the hour which the said bill was signed into law.

6. All compensation to be made within the coming 60 days, ending on 7 July 2017, 11:59pm Federal Recon Time.

7. Any additional delays (referring to the 25% tax deduction delayed until 2018) in payment, from 7 July 2017 onwards, to be treated with the national Dou Bouxian corporate loan interest rates.

8. All payment to be made in Dou Bouxian pounds.

9. For the Defendant to be incurred any additional payments for the process of distributing compensation (transport and miscellaneous costs of the individual claimants'), claimable up to R$800.

10. All Recon or Gonngman former slave owners shall have to submit compensation claims, which consists of the following:
A formal claim
Official legal (court, etc.) records as to the value of their slaves at the time of their emancipation, or last valuation. There shall be Dou Bouxian commission made up of ten persons that shall be charged with payment (Note: not evaluation) of the various compensation packages. They shall be appointed by His Imperial Majesty the King of Dou Boux and shall be assisted by various government departments, as required.

11. The Agreement shall be signed by a representative from the Joint Plaintiffs and the Defendants each, while witnessed by a Dou Bouxian notary public or any persons with such authority.
================================================

Upon agreement by the Defence, the Joint-Plaintiffs will accept the settlement, and withdraw the lawsuit.

Yours sincerely,

Mr. Brandon Chen
First Secretary
Dou Boux High Commission of the Recon Empire

by **Dou Boux** » Sun May 07, 2017 10:18 am

___________________________________________________________________________________

Reply by: Advocate Dame Brigitte Dos Santos, DcOE (Dou Boux), Counsel for The Defendant

___________________________________________________________________________________

Your Honours,

The Defendant is paying 75% of the value of the slaves as a cash amount, while leaving the other 25% as a tax-deduction, not because of financial constraints, but because we feel that it might be more favorable to the parties represented by The Joint-Plaintiff.

We feel that we have to give an example of this, to illustrate our point:

Let's say Mr. Bert Bloggs, a Reconian citizen, owns a slave (Casper), and that slave is worth one hundred thousand Dou Bouxian Pounds. What we are proposing is that Mr. Bloggs receive from the Dou Bouxian Government at some time within the next two months, a cash payment of DB£75 000,00; and then next year, he shall get an automatic tax-deduction of DB£25 000,00. In December 2018, Mr. Bloggs shall receive the amount of DB£5000 ,00 (the 5% gift from The Dou Bouxian Government). Coupled with the first payment of DB£75 000, 00 shall be a further amount of DB£5 800 (the interest on the amount, from the date that the bill was signed into law + the costs of the slave owner up to DB£800 ,00), so in total, Mr. Bert Bloggs shall receive a compensation value of DB£110 800, 00 for a slave worth DB£100 000,00.

The above example is in essence what shall happen in each compensation case. But, Mr. Bert Bloggs shall receive the amount, on condition that a) he can prove ownership of the slave; and b) he can prove the slave's value.

With the above in mind:

1) Accepted & Explained above.
2) Accepted.
3) Accepted, but the commission shall be made up as follows:

4 Dou Bouxian Commissioners,
3 Reconian Commissioners,
3 Gonngmanian Commissioners

The (independent) Commissioners must be appointed by the Government of each state, and they may never have owned slaves.
4) Denied. There has been an extra 10.8% in further compensation added on, which is more than generous.
5) See 4.
6) All initial cash payments shall be made within the next two months. Ending on 7 July 2017, 11:59PM, Federal Recon Time.
7) Denied. There shall be no additional delays with the 25% because it is a tax-deduction.
8. Accepted.
9) Accepted.
10) Accepted.

___________________________________________________________________________________
I thank you.
___________________________________________________________________________________

by **The Recon Empire** » Mon May 08, 2017 5:54 am

Dou Bouxian High Commission
OF THE RECON EMPIRE

To: Constitutional Court of The Kingdom of Dou Boux and its Colonies & Protectorates
From: Dou Bouxian High Commission of the Recon Empire

Your Honours,

Upon reviewing the 5% additional compensation to make up for the miscellaneous losses of our clients, the Joint Plaintiff will accept the following agreements without additional counter-proposition. The agreement, temporarily named the "Los Bouxiana Agreement", shall be ratified on the Reconian representative by the Reconian High Commissioner to Dou Boux, HE Benedict Tenitz; and witnessed by Vice Minister of Foreign Affairs, Mr Ralph P. Glinka, who will be flying into Dou Boux tomorrow.

A location for this agreement to be signed suggested by the Defence may serve better to remember this momentous agreement. The location can also serve as the name of the Agreement.

==================================
1. Each Reconian/Gonngmanian citizen who has lost their slave/s because of this act, shall receive a cash amount, which shall be 75% of the value of the slave/s at the time of their emancipation; and the former slave owners shall receive a tax deduction for the year of 2018, to the value of the remaining 25% of the value of their slave/s at the time of the emancipation, that is still owed to them (the owners).

2. Furtherly, the owners shall receive a further payment of 5% of the value of each of their slaves in December 2018, a rounded figure to cover any miscellaneous losses of the Joint-Plaintiffs.

3. The formation of an independent commission to evaluate the final value of slaves made up of 4 Dou Bouxian Commissioners, 3 Reconian Commissioners, 3 Gonngmanian Commissioners; all of whom shall not hold any public office in any nation, and they shall not have owned slaves.

4. All compensation to be made within the coming 60 days, ending on 7 July 2017, 11:59pm Federal Recon Time.

5. All payment to be made in Dou Bouxian pounds.

6. For the Defendant to be incurred any additional payments for the process of distributing compensation (transport and miscellaneous costs of the individual claimants'), claimable up to R$800.

7. All Recon or Gonngman former slave owners shall have to submit compensation claims, which consists of the following:
A formal claim
Official legal (court, etc.) records as to the value of their slaves at the time of their emancipation, or last valuation. There shall be Dou Bouxian commission made up of ten persons that shall be charged with payment (Note: not evaluation) of the various compensation packages. They shall be appointed by His Imperial Majesty the King of Dou Boux and shall be assisted by various government departments, as required.

8. The Agreement shall be signed by a representative from the Joint Plaintiffs and the Defendants each, while witnessed by a Dou Bouxian notary public or any persons with such authority.

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Upon agreement by the Defence, the Joint-Plaintiffs will accept the settlement, and withdraw the lawsuit.

As for members on the independent commission, the High Commission officially nominates HE Mr Charles Fletcher, Deputy High Commissioner to Dou Boux; Ms Linda Fullerton, Political Counselor; as well as Prof. Nathan Hejavec, a counsel for the Joint-Plaintiffs; to serve on behalf of the Recon Empire.

The Dou Bouxian High Commission of the Recon Empire also submitted the nominations of our counsels, Prof. Nathan Hejavec, Dr. Edward Moudin, and Prof. Orwell Weston to be considered for recipients of the Star of Foreign Service, for outstanding services to foreign service.

Yours sincerely,

Mr. Brandon Chen
First Secretary
Dou Boux High Commission of the Recon Empire

by **Dou Boux** » Sat May 13, 2017 1:24 pm

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Verdict By: The Right Honourable The Lord William Collingsworth-Dawes, The Chief Justice of The Kingdom of Dou Boux and its Colonies & Protectorates

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Order in the court Ladies and Gentlemen,

I, on behalf of my honourable colleges and myself, would like to thank both the Advocates representing The Joint-Plaintiffs and the Advocates representing The Defense for the professional way in which you all have handled this case, may I be so bold as to say that you are a true credit to the nations and people you represent.

This is an incredibly complex case, one of the most complex that I think I have ever been either the Judge or Co-Judge of, and I think that my honourable colleges will concur with me. On one side, there are the laws of liberty, which entitle all persons to their freedom, and the freedom to live their own lives and pursue their own destinies; but on the other hand, enshrined in older statutes are the rights of man to his property, and one of those rights is that the government may not reprocess and/or confiscate the property of a free citizen, with adequate compensation, as stated and set out in The Statute of Chattels passed by His Imperial Majesty’s Parliament in the year 1551.

While we adamantly believe in the right of all residents of this realm to be free, we also adamantly wish to uphold the rights of the residents of this realm to their property, and their right to compensation if their property is confiscated. In this case, the persons represented by the Joint-Plaintiffs were forbidden to own their property because of The Slavery Abolition Act, 2017 which can be likened to confiscation.

Now, we think of the aforementioned statutes as two sides of an equation, and like all good equations, they have to equate. One side of the equation has been satisfied, the slaves are free, and are being taken care of by the government; now the other side of the equation must be satisfied, the persons represented by The Joint-Plaintiffs must be compensated.

In view of the above, we do hereby name the agreement agreed to by both parties, The Santa Handro Accord (named after Palazzo Santa Handro), but we do wish to make amendments with regards to dates, in recognition of this late verdict. The terms ordered by this court are as follows, in accordance with the preliminary agreement agreed by all parties:

1. Each Reconian/Gonngmanian citizen who has lost their slave/s because of The Slavery Abolition Act,, shall receive a cash amount, which shall be 75% of the value of the slave/s at the time of their emancipation; and the former slave owners shall receive a tax deduction for the year of 2018, to the value of the remaining 25% of the value of their slave/s at the time of the emancipation, that is still owed to them (the owners).

2. Furtherly, the owners shall receive a further payment of 5% of the value of each of their slaves in December 2018, a rounded figure to cover any miscellaneous losses of the Joint-Plaintiffs.

3. The formation of an independent commission to evaluate the final value of slaves made up of 4 Dou Bouxian Commissioners, 3 Reconian Commissioners, 3 Gonngmanian Commissioners; all of whom shall not hold any public office in any nation, and they shall not have owned slaves.

4. All compensation to be made within the coming 60 days, ending on 13 July 2017, 11:59pm Federal Recon Time.

5. All payment to be made in Dou Bouxian Pounds.

6. For the Defendant to be incurred any additional payments for the process of distributing compensation (transport and miscellaneous costs of the individual claimants'), claimable up to R$800.

7. All Recon or Gonngman former slave owners shall have to submit compensation claims, which consists of the following:
• A formal claim
• Official legal (court, etc.) records as to the value of their slaves at the time of their emancipation, or last valuation. There shall be Dou Bouxian commission made up of ten persons that shall be charged with payment (Note: not evaluation) of the various compensation packages. They shall be appointed by His Imperial Majesty the King of Dou Boux and shall be assisted by various government departments, as required.

8. The Agreement shall be signed by a representative from the Joint Plaintiffs and the Defendants each, while witnessed by a Dou Bouxian notary public or any persons with such authority.

We must make clear that the commission that is established by this agreement shall only have the power to make judgements and valuations, in Reconian and Gonngmanian compensation cases, no Dou Bouxian cases may be decided by the said commission, and there must be a unanimous decision/valuation by the commission, with regards to a compensation package. If there is not, they mayn’t proceed until they do.

Thank you all once again for the professional way in which you have handled this case.

Judgement is awarded in the favour of the Joint-Plaintiffs, you may now withdraw.

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by **The Recon Empire** » Sat May 13, 2017 7:52 pm

Dou Bouxian High Commission
OF THE RECON EMPIRE

To: All
From: Dou Bouxian High Commission of the Recon Empire

Official Release

Vice Minister of Foreign Affairs, Mr Ralph Glinka is in Dou Boux for the next few days to finalize the Santa Handro Accord, a groundbreaking legal settlement in slave emancipation remunerations. The High Commission has been in a lawsuit with the Dou Bouxian Government for the past months, but is glad to emerge victorious in the class action lawsuit, representing all Reconian slave owners in Dou Boux.

In honour of the Vice Minister's visit, the High Commission will be holding a special High Commission Formal Dinner, welcoming all Reconian citizens in Dou Boux and select Dou Bouxian officials at the High Commission. As per our protocol, all attending guests will be receiving a bottle of Laudebon-Cresden Duncan 2006, a Plaque of Commemoration, a Friends of the Service Medal, and a personalized gift of tropical fruits from New Chatham, the new colony of Recon. You can view more about our diplomatic systems at our diplomatic handbook!

We look forward to seeing you at the dinner!

Yours sincerely,

Ms. Kelly Rudd
Spokesperson
Dou Boux High Commission of the Recon Empire

Recon, Gonngman and Others v. Dou Boux (CFOR Only)

Recon, Gonngman and Others v. Dou Boux (CFOR Only)

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