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The act--in its particulars including the proposed "exit date" and the PM's duty to submit an extension request to president of the EU Council--passed by parliament is not disputed: You and I agree.
Ironically, pleadings of Applicants claim that the PM's prorogation is unlawful for various reasons. One of these, inexplicably, is that Order of Council for prorogation prevents the PM from submitting a timely extension request to president of the EU Council and prevents parliament sufficient time to "debate" any and all decision(s) by the EU Council on or before 31 October 2019.
Ostensibly the prorogation period ends 14 Oct 2019, the EU Council meets for decisions, 17-18 Oct. EUWA-2-2019 stipulates the form of the request to be submitted by PM and schedule for debate commencing PM receipt of EU Council decision: 2 days later. Regardless of the date of submission, UK parliament response to it ("debate") is limited to the period between 18-31 Oct. Regardless of the prorogation period, UK parliament response to it ("debate") is limited to the period between 18-31 Oct.
UK parliamentary "constitutional" procedures in this matter are predicated on--depend on-- EU Council acceptance of parliament's specified extension period. Did you notice? EUWA-2-2019 does express any formula response to EU Council rejection of the request. Did you notice? EUWA-2-2019 SCHEDULE form letter does not express any report of parliamentary progress or "a way forward" to approval or ratification of the withdrawal agreement prepared by T. May and EU Council and 3x rejected. Did you notice?
To be charitable, it is difficult to make sense from a string of non sequiturs purported by a PM to represent simultaneously either "no deal" or a deal or an agreement with either the EU Council or parliament.
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