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I.

Alimar has not violated International Law and is not internationally responsible
for the death of the Iggams in the Halu Cave, due to non-disclosure of revelant
informations.

The Federal State of Alimar has complied with all the obligations under the International
Law. There was no breach on the obligation on the part of Alimar to disclose relevant
information to determine the probable cause of the death of Iggams in the Halu Cave. The
Alimar Bureau of Investigation already released its findings in the death of the Iggams in the
Naxor Cave Complex.
Alimar cooperated with the respective agencies or investigation teams to further gather
evidences for the real cause of the death of the Iggams in the Halu Cave. Furthermore, he even
issued an order directing the opening of the Naxor Cave Complex for all fact-finding
investigation teams and even invited the United Nations Commission on Human Rights to visit
the cave complex and conduct its probe
Alimar shall not be help internationally responsible for the death of Iggams in the Halu
Cave, provided that the Alimar Bureau of Investigation already released its findings that the
death of the Iggams in the Naxor Cave Complex was due to the high concentration of sulfur
dioxide in the Halu cave. Such findings were supported by evidence (photos) showing of dead
animals inside the Halu cave that were likewise caused by the high concentration of sulfur
dioxide.

II. Alimar has not violated International Law in its treatment towards Iggams on
the series of alleged killings.

Being a signatory in the Convention Relating to the Status of Refugees and the Protocol
Relating to the Status of Refugees, they treated Iggams in accordance with their obligation that is
to promote and protect the welfare of their people. Iggams not considered being refugees as they
are considered an organized terrorist group in Alimar, are not subject to the Convention Relating
to the Status of Refugees.
A. The Convention Relating to the Statues of Refugees and the Protocol to the Status of
Refugees does not apply.
The 1951 Convention has defined refugees as a person who is outside his or her
country of nationality or habitual residence; has a well-founded fear of being
persecuted because of his or her race, religion, nationality, membership of a
particular social group or political opinion; and is unable or unwilling to avail him
or herself of the protection of that country, or to return there, for fear of persecution.
Based on the definition given by the Convention, the Iggams are not within the
meaning contemplated.

Conclusion/Prayer fro Relief

For the foregoing reasons, the Applicant (The Federal States of Alimar) respectfully requests this
Honorable Court to find, ajudge and declare that Alimar is not internationally responsible for the
death of the Iggams in the Halu Cave.

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