Η ΠΑΕ Ξάνθη έστειλε εξώδικο στην ΕΠΟ εκφράζοντας με αυτόν τον τρόπο την αντίρρησή της για τη διεξαγωγή των αγώνων μπαράζ με τον Απόλλωνα Σμύρνης.
Αναλυτικά η ανακοίνωση:
«Ελληνίδες, Έλληνες,
«Παρόλο που αυτό το οποίο κάνουμε αυτήν τη στιγμή, είναι αντιδεοντολογικό και δεν είθισται να γίνεται.»
ΔΕΝ ΕΧΟΥΜΕ ΚΑΝΕΝΑΝ ΑΛΛΟ ΤΡΟΠΟ από το να σας γνωστοποιήσουμε ένα εξώδικο το οποίο απευθύνεται προς την Ελληνική Ποδοσφαιρική Ομοσπονδία, με μία λέξη ΕΠΟ.
Σας ευχαριστούμε εκ των προτέρων για το χρόνο που θα αφιερώσετε για να το διαβάσετε.
ΕΝΩΠΙΟΝ ΚΑΘΕ ΑΡΜΟΔΙΟΥ ΔΙΚΑΣΤΗΡΙΟΥ ΚΑΙ ΑΡΧΗΣ
ΕΞΩΔΙΚΗ ΔΙΑΜΑΡΤΥΡΙΑ-ΠΡΟΣΚΛΗΣΗ-ΔΗΛΩΣΗ
ΜΕΤ’ ΕΠΙΦΥΛΑΞΕΩΣ ΔΙΚΑΙΩΜΑΤΩΝ
Της Ποδοσφαιρικής Ανώνυμης Εταιρείας με την επωνυμία ΑΟ ΞΑΝΘΗ ΠΑΕ, που εδρεύει στα Πηγάδια Ξάνθης, νομίμως εκπροσωπούμενης.
Κ Α Τ Α
Του Σωματείου με την επωνυμία «ΕΛΛΗΝΙΚΗ ΠΟΔΟΣΦΑΙΡΙΚΗ ΟΜΟΣΠΟΝΔΙΑ» που εδρεύει στην Αθήνα ( Πάρκο Γουδί) νομίμως εκπρο-σωπουμένου.
……………………………….
Με απόφαση της Εκτελεστικής Επιτροπής σας της 3ης Αυγούστου 2020, ορίσατε να διεξαχθούν οι αγώνες κατάταξης (μπαράζ),μεταξύ της ομάδας μας, 13ης στον βαθμολογικό πίνακα της Σούπερ Λιγκ 1 της περιόδου 2019-2020 και της αντίστοιχης της «ΠΑΕ ΓΣ ΑΠΟΛΛΩΝ ΣΜΥΡΝΗΣ», 2ης στο βαθμολογικό πίνακα της Σούπερ Λιγκ 2, στις 22 και 29 Αυγούστου 2020. Σας είναι γνωστά τα πολύ πρόσφατα γεγονότα που προηγήθηκαν, της απόφασης σας αυτής.
Σας υπενθυμίζουμε ειδικότερα : α) τις από 05.06.2020 και 19.06.2020 αποφάσεις της Εκτελεστικής Επιτροπής σας, με την οποία ορίσατε ως απώτατη και καταληκτική ημερομηνία διεξαγωγής των ως άνω αγώνων την 02.08.2020, β) την απόφαση της 22.06.2020 της Σούπερ Λιγκ 2 με την οποία αποφασίστηκε, εξαιτίας των παραπάνω αποφάσεων της Εκτελεστικής Επιτροπής σας, η διακοπή του πρωταθλήματος και η επικύρωση του βαθμολογικού πίνακα, όπως είχε διαμορφωθεί την στιγμή της διακοπής, γ) την απόφαση της Επιτροπής Εκτάκτων Θεμάτων της ΕΠΟ της 31.07.2020, με την οποία αποφασίστηκε η παράταση της καταληκτικής και απώτατης ημερομηνίας, διεξαγωγής των αγώνων μπαράζ, μέχρι την 31.08.2020, και τέλος δ) την υπ’ αριθ. 91/2020 απόφαση του Διαιτητικού Δικαστηρίου Ποδοσφαίρου της ΕΠΟ, με την οποία απορρίφθηκαν οι προσφυγές της ομάδας μας και της «ΠΑΕ ΓΣ ΑΠΟΛΛΩΝ ΣΜΥΡΝΗΣ» κατά της από 3-8-2020 αποφάσεώς της ΕΕ/ΕΠΟ.
Θεωρούμε επιβεβλημένο στο σημείο αυτό να διευκρινίσουμε απολύτως ξεκάθαρα, τι ακριβώς συνέβη στη συνεδρίαση της Εκτελεστικής Επιτροπής σας, της 03.08.2020, διότι στο κρίσιμα αυτά περιστατικά εδράζεται η παρούσα μας.
Κατά την προαναφερθείσα αυτή συνεδρίαση, ετέθη προς ψήφιση, πριν τη λήψη της απόφασης για ορισμό των αγώνων μπαράζ, η πρόταση του μέλους της Εκτελεστικής Επιτροπής σας, κ. Παναγιώτη Διακοφώτη, με δύο άξονες.
Το πρώτο θέμα που τέθηκε, όπως αποτυπώνεται στα πρακτικά της συνεδρίασης της ΕΕ της 03.08.2020, αφορούσε την παράταση της προθεσμίας διεξαγωγής των μπαράζ η οποία είχε αποφασισθεί την 31.07.2020 από την Επιτροπή Εκτάκτων Θεμάτων της ΕΠΟ και με την οποία παρατάθηκε η ημερομηνία διεξαγωγής των μπαράζ μέχρι 31.08.2020. Με την πρότασή του, το προαναφερθέν μέλος της ΕΕ, εισηγήθηκε ότι δεν είναι δυνατή η παράταση της ημερομηνίας διεξαγωγής των μπαράζ, διότι μία τέτοια παράταση είναι παράνομη, αφού η ΕΕ είχε ορίσει την 02.08.2020 ως καταληκτική ημερομηνία.
Το δεύτερο θέμα που τέθηκε από το ίδιο μέλος ως λογικό επακόλουθο της πρώτης ως άνω πρότασής του, και προς αντιμετώπιση του προφανούς αδιεξόδου το οποίο είχε δημιουργηθεί από την μη τέλεση των αγώνων εντός των προθεσμιών που είχαν αποφασιστεί από την ΕΕ/ΕΠΟ, χωρίς δική μας υπαιτιότητα, αλλά και από την αδυναμία παράτασης των προθεσμιών αυτών με νόμιμο τρόπο, ήταν η εισήγησή του για την αύξηση των ομάδων της Σούπερ Λιγκ 1, από 14 σε 15.
Συνεπώς η πρόταση αυτή του κ. Π. Διακοφώτη, είχε διττό περιεχόμενο. Πρώτον να μη παραταθεί η ημερομηνία διεξαγωγής των μπαράζ και δεύτερο να αυξηθούν οι ομάδες της ΣΛ 1.
Οι ως άνω δύο προτάσεις του κ. Διακοφώτη, έλαβαν υπέρ ψήφους 9 και κατά 8 ψήφους, επί συνόλου 17 μελών της ΕΕ.
Όλως παραδόξως, η ερμηνεία που δόθηκε, από την Νομική Υπηρεσία της ΕΠΟ, ήταν ότι για να είναι έγκυρη η απόφαση αυτή της ΕΕ, θα έπρεπε να έχει συγκεντρώσει τα 3/4 του συνόλου των ψήφων, σύμφωνα με το άρθρο 8 του Ν.2482/2020.
Σύμφωνα όμως με την ως άνω διάταξη, η αυξημένη πλειοψηφία απαιτείται όταν η διοργανώτρια η Ομοσπονδία προβαίνει στη τροποποίηση διατάξεων κανονισμών η προκηρύξεων. Και ναι μεν για το δεύτερο σκέλος της πρότασης του κ. Διακοφώτη, θα μπορούσε κανείς να ισχυρισθεί, ακόμη και αν εμείς διαφωνούμε ρητώς με τον ισχυρισμό αυτό, ότι η απόφαση τροποποιεί την προκήρυξη και απαιτούνται τα 3/4 των ψήφων.
Για το πρώτο σκέλος της πρότασης του κ. Διακοφώτη όμως, υπήρξε κάποια διάταξη που τροποποιήθηκε είτε κανονισμού, είτε προκήρυξης; Βεβαίως και όχι, και η μοναδική τροποποίηση που έγινε με την λήψη της ως άνω απόφασης, ήταν μόνο η ακύρωση της απόφασης της Επιτροπής Εκτάκτων Θεμάτων της ΕΠΟ για παράταση της προθεσμίας διεξαγωγής των αγώνων μπαράζ και ουδέν άλλο.
Επομένως η απόφαση αυτή να μην παραταθεί η ημερομηνία διεξαγωγής των μπαράζ, είναι κατά πάντα ισχυρή και η ερμηνεία που δόθηκε, ότι απαιτούνται τα 3/4 των ψήφων είναι μη νόμιμη, απαράδεκτη και σκόπιμη.
Επειδή η απόφαση, σε συνέχεια αυτής, για διεξαγωγή των αγώνων μπαράζ δεν θα μπορούσε να ληφθεί, αφού με την απόφαση της μη παράτασης, δεν είναι νόμιμος ο ορισμός των αγώνων μπαράζ.
Επειδή εν γνώσει σας, ερμηνεύσατε εσφαλμένα τη διάταξη του άρθρου 8 του Ν.4684/2020, με αποτέλεσμα να έχουμε κληθεί να αγωνιστούμε στους αγώνες μπαράζ, παράνομα.
Επειδή προσέτι εν γνώσει σας, μας οδηγείτε παράνομα να αγωνιστούμε, αν και γνωρίζετε καλώς ότι δεν έχουμε τη δυνατότητα να συγκροτήσουμε αξιόμαχη ομάδα, η οποία θα αγωνισθεί σε τέτοιας σπουδαιότητας αγώνες, με το διακύβευμα να είναι τόσο αγωνιστικό όσο και οικονομικό, αφού με τις αποφάσεις σας της 05.06.2020 και της 19.06.2020, μας γνωστοποιήσατε ότι την 02.08.2020 θα έχουν ολοκληρωθεί οι αγώνες μπαράζ και κατά το τρόπο αυτό, δεν προβήκαμε στη παράταση των συμβολαίων των ποδοσφαιριστών μας που έληγαν την 30.06.2020, όπως θα είχαμε τη δυνατότητα να πράξουμε, εάν γνωρίζαμε ότι θα μας οδηγήσετε να αγωνιστούμε παρανόμως, ενώ η απόφαση της ΕΕ, που ελήφθη με ψήφους 9-8, είναι να μην δοθεί καμία παράταση στην ημερομηνία διεξαγωγής των αγώνων μπαράζ.
Επειδή η απόφαση σας αυτή είναι κατά πάντα παράνομη, απαράδεκτη και αδικαιολόγητη, μας δημιουργεί πέραν όλων των άλλων τεράστια οικονομική απώλεια σε περίπτωση που υποχρεωθούμε παράνομα να αγωνισθούμε.
Επειδή η απόφαση σας με ψήφους 9-8 έχει την εκ του Καταστατικού και του Αστικού Κώδικα, απαιτούμενη απόλυτη πλειοψηφία, με αποτέλεσμα να δεσμεύει την Ομοσπονδία, αλλά και τους τρίτους που έλκουν δικαιώματα από αυτήν.
ΔΙΑΜΑΡΤΥΡΟΜΕΘΑ
Εντόνως για την ερμηνεία που αποφασίσατε, για υπαγωγή στη διάταξη του άρθρου 8 του Ν. 4684/2020.
ΣΑΣ ΚΑΛΟΥΜΕ
όπως με απόφαση της Εκτελεστικής Επιτροπής σας, αποκαταστήσετε και επαναφέρετε τη νομιμότητα, ακυρώνοντας με νεότερη απόφαση σας, τη διεξαγωγή των αγώνων μπαράζ που ορίσατε για την 22 και 29 Αυγούστου 2020, απόφαση η οποία είναι αντίθετη με τις διατάξεις του Καταστατικού σας. Εις αντίθετη περίπτωση,
ΣΑΣ ΔΗΛΩΝΟΥΜΕ
ότι θα προχωρήσουμε σε όλες τις δικαστικές ενέργειες, τόσο αστικές όσο και ποινικές, για την αποκατάσταση κάθε θετικής και αποθετικής ζημίας που θα υποστεί η Εταιρεία μας, εξαιτίας της παράνομης και υπαίτιας συμπεριφοράς σας καθώς και για τον ποινικό κολασμό και τη διερεύνηση της πιθανότητας ενδεχόμενου δόλου, κάθε ενέργειας στην οποία θα προβείτε, χωρίς να λαμβάνετε υπόψη σας την ως άνω απόφαση της Εκτελεστικής Επιτροπής.
Αρμόδιος δικαστικός επιμελητής να επιδώσει νόμιμα την παρούσα, προς τον νόμιμο εκπρόσωπο του Σωματείου, στο οποίο απευθύνεται η παρούσα, αντιγράφοντας την ολόκληρη, στην έκθεση επίδοσης.
Ξάνθη, 17.08.2020
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