COHRE Individual Complaint Bulgaria 2009

EQUAL OPPORTUNITIES INITIATIVE # 3 313 str., 1373 SOFIA, BULGARIA Tel: + 359 2 8 22 11 44 Fax: + 359 2 8 22 11 44 E-mail: equal_opportunities@abv.bg

83 R UE DE M ONTBRILLANT 1202 G ENEVA , S WITZERLAND Tel: + 41.22.7341 028 Fax: + 41.227338 336 E-mail: litigation@cohre.org

INDIVIDUAL COMPLAINT TO THE HUMAN RIGHTS COMMITTEE UNDER THE OPTIONAL PROTOCOL TO THE INTERNATIONAL COVENANT ON CIVIL AND POLITICAL RIGHTS and REQUEST FOR URGENT INTERIM MEASURES 21 September 2009

Table of Contents: I. Information Concerning the Complaint ..................................................................2 II. Statement of the Facts.............................................................................................4 III. Urgent Request for Interim Measures..................................................................6 IV. Admissibility .......................................................................................................6 V. Law .........................................................................................................................7 A. The forced evictions and threatened forced evictions amount to a violation of Articles 17 of the International Covenant on Civil and Political Rights read in conjunction with Article 2. ..........................................................................................7 B. The forced evictions and threatened forced evictions amount to a violation of Articles 26 of the International Covenant on Civil and Political Rights read in conjunction with Article 2. ..........................................................................................9 C. Concluding Comments on the Law. ..................................................................12 VI. Conclusions ......................................................................................................12 ANNEX A:...................................................................................................................14 ANNEX B:...................................................................................................................16 ANNEX C:...................................................................................................................18

I.

Information Concerning the Complaint

THE AUTHORS (VICTIMS): List of the plaintiffs forcibly evicted from Gorno Ezerovo, Bourgas who authorized COHRE and EOA to represent them before international justice authorities (see Annex A).

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Stoyko Iliev Draganov, No 39 Minzuhar str., Gorno Ezerovo, Bourgas Marin Andonov Todorov, No 45 Kavatzi str., Gorno Ezerovo, Bourgas Atanas Atanasov Slavov, No 52 Kavatzi str., Gorno Ezerovo, Bourgas Radka Stoyanova Georgieva, No 52 Kavatzi str., Gorno Ezerovo, Bourgas Ognyan Andonov Todorov, No 45 Kavatzi str., Gorno Ezerovo, Bourgas Maya Galabinova Hristova, No 52 Perla str., Gorno Ezerovo, Bourgas Galabina Simeonova Georgieva, No 55 Perla str., Gorno Ezerovo, Bourgas Ivan Simeonov Rusev, No 54 Perla str., Gorno Ezerovo, Bourgas Fidanka Andonova Todorova, No 61 Perla str., Gorno Ezerovo, Bourgas Naska Atanasova Shtereva, No 59 Kavatzi str., Gorno Ezerovo, Bourgas Yana Boyanova Kozareva, No 59 Kavatzi str., Gorno Ezerovo, Bourgas Galabina Yordanova Todorova, No 59 Kavatzi str., Gorno Ezerovo, Bourgas Lily Ivanova Raicheva, No 30 Minzuhar str., Gorno Ezerovo, Bourgas Lilyana Yordanova Moskova, No 59 Kavatzi str., Gorno Ezerovo, Bourgas Danail Marinov Moskov, No 59 Kavatzi str., Gorno Ezerovo, Bourgas Simo Assenov Kostov, No 52 Kavatzi str., Gorno Ezerovo, Bourgas Yanka Kirilova Patronova, No 54 Kavatzi str., Gorno Ezerovo, Bourgas and similarly situated persons forcibly evicted from Gorno Ezerovo, Bougas

List of the plaintiffs threatened with forced eviction from Gorno Ezerovo, Bourgas who authorized COHRE and EOA to represent them before international justice authorities (see Annex B).

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Ivan Simeonov Rusev, No 40a Perla str., Gorno Ezerovo, Bourgas Temenujka Simova Marinova, No 42 Perla str., Gorno Ezerovo, Bourgas Ivanka Milanova Kozareva, No 44 Perla str., Gorno Ezerovo, Bourgas Anka Strahilova Strahilova, No 53 Perla str., Gorno Ezerovo, Bourgas Maia Galubinova Hristova, No 22 Kavatzi str., Gorno Ezerovo, Bourgas Sofka Metodieva Nikolova, No 53 Perla str., Gorno Ezerovo, Bourgas Mirka Deianova Patronova, No 49 Perla str., Gorno Ezerovo, Bourgas Nadejda Ianakieva Stoianova, No 53 Perla str., Gorno Ezerovo, Bourgas Roza Andonova Snejanova, No 59 Perla str., Gorno Ezerovo, Bourgas Mladen Hristov Georgiev, No 55 Perla str., Gorno Ezerovo, Bourgas Slavcho Ivanov Vasilev, No 23 Minzuhar str., Gorno Ezerovo, Bourgas Radka Ivanova Kostova, No 52 Kavatzi str., Gorno Ezerovo, Bourgas Liliana Simova Kostova, No 52 Kavatzi str., Gorno Ezerovo, Bourgas Sultanka Mitkova Kozarova, No 33a Minzuhar str., Gorno Ezerovo, Bourgas Maria Jurieva Cterionova, No 33 Minzuhar str., Gorno Ezerovo, Bourgas Kuta Stoianova Petrova, No 33b Minzuhar str., Gorno Ezerovo, Bourgas and similarly situated persons under threat of eviction from Gomo Ezerovo, Bourgas

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List of the plaintiffs threatened with forced eviction from Meden Rudnik, Bourgas who authorized COHRE and EOA to represent them before international justice authorities (see Annex C).

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Emilia Andreeva Bakurdjieva, No 13, Alen Mak str., Meden Rudni, Bourgas Kalina hristova Simeonova, No 13, Alen Mak str., Meden Rudni, Bourgas Mariana Ilieva Djambazova, No 13, Alen Mak str., Meden Rudni, Bourgas Zymbyla Siikova Andreeva, No 13, Alen Mak str., Meden Rudni, Bourgas and similarly situated persons under threat of eviction from Meden Rudnik, Bourgas

REPRESENTATION: Name: Centre on Housing Rights and Evictions (COHRE) Counsel: Bret Thiele, Senior Expert for Litigation and Legal Advocacy, COHRE Address: 83 Rue de Montbrillant, 1202 Geneva, Switzerland Second Address: 8 N. 2nd Avenue East #208, Duluth, MN 55802, U.S.A. (for all correspondence to COHRE related to this complaint) Email: Litigation@cohre.org and Name: Equal Opportunities Association (EOA) Counsel: Daniela Mihailova, Legal Program Coordinator Address: No 3 “313� str., 1373 Sofia, Bulgaria (for all correspondence to EOA related to this complaint) Email: equal_opportunities@abv.bg Authorisation: The representatives are acting by virtue of a power of attorney signed by the Authors (Victims) on or about 12 September 2009 at Bourgas, Bulgaria, attached at Annex A, Annex B and Annex C. STATE PARTY: Bulgaria (ratified the ICCPR on 21 September 1970; ratified the Optional Protocol 26 March 1992).

VIOLATIONS: Articles 2, 17, 26

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II.

Statement of the Facts

1.

The Regional Agency for the Control of Unlawful Building has issued eviction

orders against the communities of Gorno Ezerovo and Meden Rudnik in the Municipality of Bourgas, Bulgaria. The eviction orders cite Art. 225, para 1 of the Territory Law which allows for demolition of housing built without the proper permits.

Both communities are made up of impoverished Roma citizens of Bulgaria. The orders require the residents to demolish their own homes or have them demolished by the Agency. If the latter occurs, the residents are required to reimburse the Agency for its costs. These eviction orders are to remedy a property rights claim by private individuals over the land on which these long-standing communities reside.

2.

The Gorno Ezerovo community has been in existence for over 50 years. During

this time, the community was recognized by public authorities including being provided with individual mail service as well as publically regulated services such as water, sanitation and electricity.

3.

Some 52 Romani households of Gomo Ezerovo received eviction orders in 2007.

On 8 September 2009, Bourgas municipal authorities forcibly evicted 27 Romani households and demolished their houses. The demolitions were implemented with the assistance of the local police, the people were forced out of their homes, some of them were hit and/or beaten. They were forced to leave much of their personal belongings including furniture which was still in their homes when they were demolished. The families were rendered homeless, including children and the elderly. The others face imminent forced eviction as early as later in September 2009.

4.

The Meden Rudnik community has also been in existence for over 50 years.

Similar to Gorno Ezerovo, during this time, the community was recognized by public authorities including being provided with individual mail service as well as publically regulated services such as water, sanitation and electricity.

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5.

In Meden Rudnik, approximately 32 houses out of some 300 are under imminent

threat of forced eviction, after originally receiving eviction orders in 2007. About half of these homes have existed for some 20 years while the other half are newer.

6.

None of those forcibly evicted or threatened with forced eviction have been

offered alternative housing and no meaningful consultation has taken place with the communities. The Bourgas mayor has publicly stated that the municipality will provide alternative housing for the families who are legally registered in Bourgas. In fact all of the people who were left homeless are registered Bourgas inhabitants, however no one was resettled.

7.

The causes for the communities of Gorno Ezerovo and Meden Rudnik being in

informal settlements (e.g., “unlawful buildings”) are due in large part to the persistent pattern of racial discrimination against Roma.

This discrimination includes lack of

education and employment opportunities necessary to afford housing at market rates.

Indeed, the Committee on Economic, Social and Cultural Rights has stated that “success has not been achieved” in government efforts to combat unemployment as well as “deplor[ing] the situation where those [Roma] who are employed receive salaries which do not allow them to secure for themselves and their families an adequate standard of living.”1 8.

Additionally, another cause of urban informal settlements is that rural Roma have

been forced to seek economic opportunity, however meagre, in urban areas since essentially being displaced off rural land. Indeed, the Committee on the Elimination of Racial Discrimination found as early as 1997 that “rural Roma are discouraged from claiming land to which they are entitled under the law disbanding agricultural collectives.”2

Committee on Economic, Social and Cultural Rights, Concluding Observations: Bulgaria, UN Doc. E/C.12/1/Add.37 (8 December 1999) at paras. 13 and 14.

2 Committee on the Elimination of Racial Discrimination, Concluding Observations: Bulgaria, UN Doc. CERD/C/304/Add.29 (23 April 1997).

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III. Urgent Request for Interim Measures 9.

Some of the authors from the Gorno Ezerovo community and the Meden

Rudnik community face imminent forced eviction and destruction of their homes. These threatened forced evictions may be implemented before the end of September 2009.

10.

Forced eviction and destruction of homes will result in irreparable harm to the

relevant authors of this Complaint as well as similarly situated persons in the Gorno Ezerovo and Meden Rudnik communities. Such irreparable harm includes, inter alia, the loss of housing and other personal belongings, the dangers associated with lack of shelter due to resulting homelessness, and the loss of social networks.

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Those already forcibly evicted have been rendered homeless and are in urgent

needs of alternative housing.

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Consequently, COHRE and EOA urgently request interim measures including an

immediate halt to any further evictions and the provision of alterative housing to those already evicted.

IV.

Admissibility

13.

Bulgaria has denied the long-standing communities of Meden Rudnik and Gorno

Ezerovo, situated in Bourgas, Bulgaria, any security of tenure, including the minimum “degree of security of tenure which guarantees legal protection against forced eviction, harassment and other threats” required by its international and domestic human rights obligations.3 There are no mechanisms at the domestic level to challenge eviction in such cases where there exists a denial of even the minimum degree of security of tenure.

Notwithstanding this situation, several households have attempted to bring cases before

Committee on Economic, Social and Cultural Rights, General Comment No. 4, UN Doc. The right to adequate housing (Sixth session, 1991), U.N. Doc. E/1992/23, annex III at 114 (1991), reprinted in Compilation of General Comments and General Recommendations Adopted by Human Rights Treaty Bodies, U.N. Doc. HRI/GEN/1/Rev.6 at 18 (2003) at para. 8(a), (stating in relevant part that “Tenure takes a variety of forms, including rental (public and private) accommodation, cooperative housing, lease, owner-occupation, emergency housing and informal settlements, including occupation of land or property.

Notwithstanding the type of tenure, all persons should possess a degree of security of tenure which guarantees legal protection against forced eviction, harassment and other threats. States parties should consequently take immediate measures aimed at conferring legal security of tenure upon those persons and households currently lacking such protection, in genuine consultation with affected persons and groups.”)

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the Bourgas Administrative Court, but the eviction orders have been upheld due to the lack of the degree of security of tenure required by international human rights norms.

14.

Notwithstanding, EOA has assisted the communities to challenge the eviction

orders by bringing a case before the Administrative Court. The arguments were based solely on international law, as Bulgarian law does not provide for any remedy. The Administrative Court upheld the eviction and demolition orders.

Cases were also

brought before the Supreme Administrative Court, which also upheld the eviction and demolition orders.

15.

The individuals, families and communities at issue have not received any

protection from governmental institutions, including judicial authorities.

On the

contrary, the police actively participated in the demolition of the houses and used disproportionate force against the Roma inhabitants.

16.

The threat of this forced eviction was brought to the attention of the Human

Rights Council under its Complaint Procedure on 28 May 2008 (Communication G/SO 215/1 BGR 50 & 51). The Working Group on Communications kept the complaint under consideration until April 2009, when it ceased consideration. Evictions had been halted while this earlier communication was under consideration by the Working Group on Communications, indicating that interim measures by the Human Rights Committee should result in a beneficial impact.

V.

Law

A.

The forced evictions and threatened forced evictions amount to

a violation of Articles 17 of the International Covenant on Civil and Political Rights read in conjunction with Article 2.

17.

The Human Rights Committee has previously stated that the practice of forced

evictions “arbitrarily interferes with the Covenant rights of the victims of such evictions, especially their rights under article 17 of the Covenant.�4 The Committee went on to 4

Human Rights Committee, Concluding Observations: Kenya, para. 21, UN Doc. CCPR/CO/83/KEN

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state that the State party should “ensure that evictions from settlements do not occur unless those affected have been consulted and appropriate resettlement arrangements have been made.�5 18.

The forced evictions and threatened forced evictions of the Gomo Ezerovo and

Meden Rudnik communities are also unlawful in that they contravene, inter alia, the right to adequate housing, including the prohibition on forced eviction, enshrined in Article 11 of the International Covenant on Economic, Social and Cultural Rights (ICESCR) as informed by General Comments Nos. 4 and 7 of the Committee on Economic, Social and Cultural Rights.

19.

As examined in greater detail below, the ICESCR is binding within the domestic

legal regime of the Republic of Bulgaria pursuant to Article 5(4) of the Constitution of the Republic of Bulgaria. As such, forced evictions, as contrary to the ICESCR, amount to unlawful interference with the home.

20.

The forced evictions are also arbitrary in that they are undertaken in a racially

discriminatory manner. The forced evictions and threatened forced evictions of the communities of Gorno Ezerovo and Meden Rudnik are due in large part because of the residents Romani ethnicity and the informal housing conditions under which persons of Romani ethnicity have to live on account of their ethnicity. As such, the evictions have both an unlawful discriminatory intent as well as an unlawful discriminatory effect.

21.

Additionally, on 23 February 2005 the Council of Europe adopted

Recommendation (2005) 4 on improving the housing conditions of Roma and Travellers in Europe. As a Member State of the Council of Europe, and pursuant to Article 5(4) of its Constitution, the Republic of Bulgaria is obligated to abide by this Recommendation.

22.

Recommendation (2005) 4, inter alia, requires that national housing policies

address the specific problems of Romani housing as a matter of emergency and in a nondiscriminatory way.67

(29 April 2005).

5 Id. 6 Council of Europe, Committee of Ministers, Recommendation Rec(2005) 4 on improving the housing conditions of Roma and Travellers in Europe (23 February 2005).

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23.

The Recommendation also states that “Member states should promote and

protect the right to adequate housing for all, as well as ensure equal access to adequate housing for Roma through appropriate, proactive policies, particularly in the area of affordable housing and service delivery.”8 24.

With respect to “protection and improvement of existing housing”, the Republic

of Bulgaria “should ensure that Roma are protected against unlawful eviction, harassment and other threats regardless of where they are residing” and “should establish a legal framework that conforms with international human rights standards, to ensure effective protection against unlawful forced and collective evictions and to control strictly the circumstances in which legal evictions may be carried out.”9 25.

Council of Europe General Recommendation (2005) 4 should be used as

persuasive authority in interpreting Article 17 of the ICCPR. Based on the foregoing, the forced evictions and threatened forced eviction at issue in this Complaint should be deemed unlawful as well as arbitrary and consequently in violation of Article 17.

B.

The forced evictions and threatened forced evictions amount to

a violation of Articles 26 of the International Covenant on Civil and Political Rights read in conjunction with Article 2.

26.

Article 5(4) of the Constitution of the Republic of Bulgaria states that: Any international instruments which have been ratified by the constitutionally established procedure, promulgated, and come into force with respect to the Republic of Bulgaria, shall be considered part of the domestic legislation of the country. They shall supersede any domestic legislation stipulating otherwise.10

Id. at para. 2.

Id. at para. 4.

9 Id. at paras. 23 and 26.

10 Constitution of the Republic of Bulgaria, Art. 5(4), adopted 1991.

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27.

As such, the rights enshrined in the ICCPR are directly binding within the

domestic legal framework of the Republic of Bulgaria.11 Article 26 requires that the rights guaranteed by Article 17 of the ICCPR be guaranteed without discrimination on account of Romani descent as well as guaranteeing the equal protection of Article 17 of the ICCPR. 28.

Additionally, the Republic of Bulgaria has ratified the International Covenant on

Economic, Social and Cultural Rights (ICESCR) on 21 September 1970. Consequently, the rights enshrined in the ICESCR are directly binding within the domestic legal framework of the Republic of Bulgaria, including the right to adequate housing, including the prohibition on forced eviction, enshrined in Article 11 of the ICESCR. 29.

Article 11 of the ICESCR, read in conjunction with Article 2, obliges the

Republic of Bulgaria to respect, protect and fulfil the right to adequate housing without discrimination. The causes for the communities of Gomo Ezerovo and Meden Rudnik being in informal settlements (e.g., “unlawful buildings” as described by the Regional Agency for the Control of Unlawful Building) are due in large part to the persistent pattern of racial discrimination against Roma and the unwillingness of the Republic of Bulgaria to fulfil the right to adequate housing without such discrimination.

This

discrimination includes lack of education and employment opportunities necessary to afford housing at market rates. As mentioned above, the Committee on Economic, Social and Cultural Rights has stated that “success has not been achieved” in government efforts to combat unemployment as well as “deplor[ing] the situation where those [Roma] who are employed receive salaries which do not allow them to secure for themselves and their families an adequate standard of living.”12 Additionally, Bulgaria has denied the long-standing communities of Meden Rudnik and Gorno Ezerovo any security of tenure, including the minimum “degree of security of tenure which guarantees legal protection against forced eviction, harassment and other threats” required by its international and domestic human rights obligations.13 For instance, the European Committee of Social Rights held that the European Social Charter, upon ratficiation, “has been incorporated in the Bulgarian demostic legal orer with a status higher than statutory law” pursuant to Article 5(4) of the Constitution. See European Roma Rights Centre v. Bulgaria, Complaint No. 31/2005 (18 October 2006) (finding violations of Art. 16 and Art. E on account of forced evictions and other violations of the right to adequate housing of Roma generally).

12 Committee on Economic, Social and Cultural Rights, Concluding Observations: Bulgaria, UN Doc. E/C.12/1/Add.37 (8 December 1999) at paras. 13 and 14.

13 Committee on Economic, Social and Cultural Rights, General Comment No. 4, UN Doc. The right to 11

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30.

Furthermore, another cause of urban informal settlements is that rural Roma

have been forced to seek economic opportunity, however meagre, in urban areas since essentially being displaced off rural land. Indeed, the Committee on the Elimination of Racial Discrimination found as early as 1997 that “rural Roma are discouraged from claiming land to which they are entitled under the law disbanding agricultural collectives.”14 31.

Furthermore, the right to adequate housing enshrined in Article 11 of the

ICESCR, similar to the rights protected by Article 17 of the ICCPR, prohibits forced eviction.

Under the ICESCR, evictions can only be justified in highly exceptional

circumstances and after all feasible alternatives to eviction have been explored in meaningful consultation with the persons affected.15 Even then, various due process protections as outlined in General Comment No. 7 of the Committee on Economic, Social and Cultural Rights must be adhered to.16 Finally, and, even if the above criteria have been satisfactorily met, evictions can not be carried out in a discriminatory manner nor can they result in rendering individuals homeless or vulnerable to the violation of other human rights.17

adequate housing (Sixth session, 1991), U.N. Doc. E/1992/23, annex III at 114 (1991), reprinted in Compilation of General Comments and General Recommendations Adopted by Human Rights Treaty Bodies, U.N. Doc. HRI/GEN/1/Rev.6 at 18 (2003) at para. 8(a), (stating in relevant part that “Tenure takes a variety of forms, including rental (public and private) accommodation, cooperative housing, lease, owner-occupation, emergency housing and informal settlements, including occupation of land or property.

Notwithstanding the type of tenure, all persons should possess a degree of security of tenure which guarantees legal protection against forced eviction, harassment and other threats. States parties should consequently take immediate measures aimed at conferring legal security of tenure upon those persons and households currently lacking such protection, in genuine consultation with affected persons and groups.”)

14 Committee on the Elimination of Racial Discrimination, Concluding Observations: Bulgaria, UN Doc. CERD/C/304/Add.29 (23 April 1997).

15 See Committee on Economic, Social and Cultural Rights, General Comments. Nos. 4 and 7.

16 Committee on Economic, Social and Cultural Rights, General Comment 7, Forced evictions, and the right to adequate housing (Sixteenth session, 1997), U.N. Doc. E/1998/22, annex IV at 113 (1997), reprinted in Compilation of General Comments and General Recommendations Adopted by Human Rights Treaty Bodies, U.N. Doc. HRI/GEN/1/Rev.6 at 45 (2003) (para. 16 states that “The Committee considers that the procedural protections which should be applied in relation to forced evictions include: (a) an opportunity for genuine consultation with those affected; (b) adequate and reasonable notice for all affected persons prior to the scheduled date of eviction; (c) information on the proposed evictions and where applicable, on the alternative purpose for which the land or housing is to be used, to be made available in reasonable time to all those affected; (d) especially where groups of people are involved, government officials or their representatives to be present during an eviction; (e) all persons carrying out the eviction to be properly identified; (f) evictions not to take place in particularly bad weather or at night unless the affected persons consent otherwise; (g) provision of legal remedies; and (h) provision, where possible, of legal aid to persons who are in need of it to seek redress from the courts.”).

17 Committee on Economic, Social and Cultural Rights, General Comment No. 7.

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32.

Consequently, the Republic of Bulgaria is in violation of Article 26 of the ICCPR

for not prohibiting discrimination on account of Romani descent and not providing for the equal protection of Article 17 of the ICCPR or for the equal protection of the rights enshrined in the ICESCR, including the right to adequate housing and the prohibition on forced eviction.

C.

Concluding Comments on the Law.

33.

While the property rights claim is noted by COHRE and EOA, the remedy for

enforcing property rights should not and indeed can not lawfully be implemented by carrying out a gross violation of human rights, particularly when the rationale for such evictions is the unwillingness of the Republic of Bulgaria to fulfil the right to adequate housing without discrimination.

34.

Indeed, as mentioned above, under international human rights law binding upon

Bulgaria, evictions can only be justified in highly exceptional circumstances and after all feasible alternatives to eviction have been explored in meaningful consultation with the persons affected.18 In this case, not only has this process not been followed, but there exist feasible alternatives to remedying a property rights claim that do not entail committing a gross violation of human rights. For instance, Bulgaria could provide compensation to the ostensible owner of the land in question and then meet its obligation to respect, protect and fulfil the right to adequate housing by regularising the communities of Meden Rudnik and Gorno Ezerovo including by providing the communities with a degree of security of tenure which guarantees legal protection against forced eviction, harassment and other threats.19

VI. Conclusions 35.

The Republic of Bulgaria is in violation of Articles 17 and 26 of the ICCPR read

alone and in conjunction with Article 2, including the non-discrimination clause of Article 2(2).

See Committee on Economic, Social and Cultural Rights, General Comments. Nos. 4 and 7.

This is essentially the process used by the Republic of South Africa in the case of Modder East Squatters and Another v Modderklip Boerdery (Pty) Ltd (SCA 187/03).

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36.

Remedies should including housing and land restitution as well as compensation

for those forcibly evicted.

37.

Remedies should also include the regularization of Gomo Ezerovo and Meden

Rudnik including the provision of a degree of security of tenure which guarantees legal protection against forced eviction, harassment and other threats.

38.

All remedies should be implemented with the meaningful participation of the

affected members of the Goma Ezerovo and Meden Rudnik communities.

39.

COHRE and EOA reserve the right to amend this Complaint.

Respectively submitted,

Bret G. Thiele Senior Expert for Litigation and Legal Advocacy Centre on Housing Rights and Evictions (COHRE) Daniela Mihailova Legal Program Coordinator Equal Opportunities Association (EOA)

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ANNEX A:

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ANNEX B:

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ANNEX C:

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