Applications to the European Court of Justice against "Terrorist" Listing by the Council of the European Union, 2002
Appeal of 26 September 2002 against the Sanctieregeling terrorisme 2002 III.
(Translation)

SCHOOLPLEIN Schoolplein 5A
ADVOCATEN 3581 PX Utrecht
tel. (030) 231 36 46
fax (030) 234 29 95
email: [email protected]

To the Minister of Foreign Affairs
Mr. J.G. de Hoop Scheffer
P.O. Box 20061
Bezuidenhoutseweg 67
2500 EB ‘s-Gravenhage
registered

Our ref: Sison/BuZa your ref: DJZ.BR/749-02& 781-02 Utrecht, 26 september 2002


Dear mr de Hoop Scheffer,

Mr. M.M.C. SISON, of Filipino nationality, born on 8 February 1938, living in Utrecht on the Rooseveltlaan 778, has turned to me with the request to assist him with regards to the Sanctieregeling terrorisme 2002 III dated 13 August 2002 and the Amendment Sanctieregeling terrorisme 2002 III of 23 August 2002. The person concerned has given me power of attorney to represent him and appeal against the “regeling” that is hereby submitted.

Because of the Sanctieregeling the person concerned is with immediate effect deprived of all means of livelihood; this violates the fundamental right to life. Furthermore the person concerned is now publicly reputed as a terrorist whose life and that of his family are now in danger because of the demonizing character of such stigmatization also considered in the light of the events of 11 September 2001 in New York, USA.

In a letter to you, the Prime Minister J.P. Balkenende and to your colleague of the ministry of Finance, J.F. Hoogervorst, of 16 September 2002, the person concerned has pointed out to you the consequences for his person caused by the issued Sanctieregeling terrorisme 2002 III without there being any evidence that he is or was involved with terrorist activities. The person concerned is not and has never been a terrorist; neither has he ever had any ties with international terrorism and should therefore not have been included in the Sanctieregeling. I submit to you the said letter and request you to consider this as repeated and included [as part of this appeal]. In this framework, I would like to point out to you that the person concerned plays an important role in the agreement on respect for human rights and international law with regards to maintaining the human rights as agreed between the Government of the Republic of the Philippines and the National Democratic Front of the Philippines on 16 May 1998 in The Hague. A copy of the said agreement is being submitted.

I hereby request you and if necessary summon you, with immediate effect, or in any case within 48 hours after the sending of this writing, to remove the name of the person concerned from the appendix as mentioned in article 2 of the Sanctieregeling terrorisme 2002 III.

If you would not comply with this summons, than I shall present the matter to the “provisions”judge at the court in the Hague.

Respectfully,


Hans Langenberg