The plaintiff specifically itemizes its accrued losses as follows: I. The value of the teak plantation is One Billion US Dollars ($1,000,000,000.00 USD) II. The Tama-Tonkololli Forest Reserve is One Billion, Five Hundred and Thirty Two Million, Six Hundred and Seventy Five Thousand US Dollars ($1,532,675,000 USD ) III. The total loss of Revenue is One Billion, Three Hundred and Eighty Million, Seven Hundred Thousand US Dollars ($1,380,700,000.00 USD) RELIEFS SOUGHT BY THE APPLICANT The Applicant seeks the following reliefs from the Honourable Court: (A) A DECLARATION that the deliberate breach of the Concession Agreement voluntarily made on the 25th Day of July 2007 by the Defendant without any justifiable cause is illegal, unlawful, null and void and of no effect whatsoever. (B) A DECLARATION that the willful and persistent refusal by the Defendant to perform its contractual obligation in accordance with the express terms and conditions stipulated in the Concession Agreement made on the 25th Day of July 2007 is illegal, null and void as same is a violation of the provisions of ARTICLE 15 of the African Charter on Human and Peoples Rights, ARTICLE 23 of the Universal Declaration of Human Rights. (C) AN ORDER of this Honourable Court by way of a mandatory injunction compelling the Defendant, its agents, servants, privies and by 6