Notes:

The Respondent or an expert

To prove discrimination and arbitrariness in the Respondents application of the national law when
determining;

Principle Controversy - the Equal Administration of Justice and Punishment

under law

Issues

Equal Opportunity in Prison Housing – open and transitional type

Equal Opportunity in access to Employment

Equal Opportunity in access to Education

Equal Opportunity in access to Benefits for Good Behavior

Religious “Intolerance

Constitution Law

International Law

Responses to Defense

Defenses in such case are always the same that defended apartheid in South Africa and racism in
the United States, “separate but equal”. see (It is of significant to any of analysis when reviewing
the conduct of the defendant Bulgaria to recall that the United Nations Human Rights Committee
has stressed on more than one occasion that the obligation of states is to treat persons deprived of
their liberty with dignity and humanity is a fundamental and universally applicable rule, not
dependent on the material resources available to the state party [see: Ibid., paragraph 4; see also
Mukong v. Cameroon (No. 458/1991) (August 10, 1994), U.N. Doc. CCPR/C/51/D/458/1991
(stating that minimum requirements regarding floor space, sanitary facilities, provision of food,
etc., must be observed, "even if economic or budgetary considerations may make compliance
with these obligations difficult")], mutatis mutandis, difficulties or costs encountered by the
defendant Bulgaria to meet its international duty to conduct a prisoner to a foreign state for a
judicial hearing. Financial difficulties are not sufficient cause to refuse a person deprived of their
liberty his or her right to attend or otherwise access a foreign court to prosecute or defend civil
claims.)

. Such equally available under the same objective circumstances to ALL person deprived of
liberty under the Criminal Code and as provided for under the Law for the Execution of
Punishments. And that is REGARDLESS of their nationality, citizenship, race, sex, property
status or place of residence.

As a result, to determine the extent of the unlawful discrimination and the Applicant’s complaints
that item 4 of ORDER LC 4-277 (1) serves no lawful purpose or reasonable objective, and; (2) is
being abused by officials of the Respondent and leads to corruption, requires that the Applicants
request the Court secure from the Respondent certain data and documents only in its possession.

created an atmosphere of hostility, alienation and distrust