To: Mr V. V,. Yakovenko .
Head, Main Investigations Directorate
Investigation Committee of the Russian Federation
Moscow city Department
119002, Bldg. 1, Block 2, House 16, Arbat St., Moscow
From: Navalny Alexey Anatolyevich,
Lawyer, the “Mezhregion” Moscow Bar Association,
Residence address
STATEMENT
of committed crime
According to the letter from the Deputy Mayor of Moscow, Moscow city Government, Mr A. N. Gorbenko on May 04, 2012, the following public events concurred with a group of citizens consisting of I. V. Bakirov, S. K. Davidis, E. A. Lukyanova, N. L. Mityushkina and S. S, Udaltsov on May 06, 2012: starting at 4:00 pm – a demonstration from Kaluzhskaya Sq. along B. Yakimanka St. and B. Polyanka St. to Bolotnaya Sq., and a rally till 07:39 pm in Bolotnaya Sq., with the purposes of “lodging a protest against abuse and fraud during the parliamentary and presidential elections; requiring clean elections; observing human rights, the legislation of the RF and its international obligations”.
According to the information placed on May 05, 2012 on the official site of the Ministry of the Interior, Moscow Sate Dept (
http://petrovka38.ru/news/38875/), from 4:00 pm to 19:00 pm a march numbering up to 5 thousand persons was agreed with the citizen group, from Kaluzhskaya Sq. along Bolshaya Yakimanka St. and Bolshaya Polyanka St., across the Maly Kamenny Bridge to Bolotnaua Sq., whererin the rally was to be held; the passway to the rally would be arranged from the Bolshoy and Maly Kamenny Bridges, where 15 walk-through metal detectors were to be installed. In addition, a sheme of these events was published on the said site, with the locations of metal detectors, the line of the march, sections of traffic shut-off and the location of the rally, mapped.
On May 06, 2012, when people were marching to the rally’s area, the Moscow Government and the Main Directorate of the Interior Ministry officials displayed gross violations of the previously agreed scheme and procedure of the event. Thus, the gardens of the Bolotnaya Sq. - in contravention of the scheme (the black hexagon marked as the “Rally”), published on the official site of the Moscow city Main Directorate of the Interior Ministry – was completely sealed off by the police. The passway from the Bolshoy Kamenny Bridge to the the rally’s destination was not organized, but shut. No walk-through metal detectors were installed in the denoted area. The passway from the Maly Kamenny Bridge was almost completely cordoned off with only a narrow passage left leading to Bolotnaya Embankment.
The mentioned contraventions of the procedure, scheme and route of the public actions, which had been pre-agreed and published in the media, made it impossible for the people to proceed to the venue and, consequently, resulted in the crowding of the public event attendees at the narrow passage to Bolotnaya Embankment, causing a throng and disorientation of the participants of the event; made it impossible to hold the rally with the use of public-address amplifiers; led to police violence and damage of varying severity to the health of citizens.
Thus, the public event participants were purposefully and wilfully deluded. Any attempt of the participants of the event to follow the route, which had been pre-agreed and published on the official site of the Moscow city Main Directorate of the Interior Ministry, inevitably lead to “breaches” of police cordons. Despite all their resources, the Moscow city Government and the Main Directorate of the Interior Ministry officials took no action to inform the public event organizers and participants of the changes to the march route and location. Likewise, in contravention of the pre-agreed and published scheme of the rally participants’ disposition, the police officials cordoned off Bolotnaya Embankment near Luzhkov Bridge, straight across from the Vodootvodny Canal, forcing the citizens to move towards the stage through a narrow passage not more than 3 metres wide, thus provoking a jam and the impossibility for the march participants to proceed to Bolotnaya Embankment. Besides, the police officers directly obstructed execution of the action by way of de-energizing the erected stage, thus eliminating the possibility of using a PA amplifier.
Therefore, there are essential elements of crime, such as is envisaged by Articles 149, 285, 286 and 293 of the Criminal Code of the Russian Federation, which can be traced in the actions of the Moscow city Government and the Main Directorate of the Interior Ministry officials in charge of security and observance of conditions and procedure of the aforementioned public events .
In view of the above and in accordance with Articles 144, 145 of the Criminal Procedure Code,
I APPLY WITH A REQUEST
To investigate the matter stated, to initiate a criminal proceeding on the results of the investigation and to institute a criminal case against the guilty persons.
I wish that the member of the Moscow regional Bar, branch # 5, lawyer Kobzev, Vadim Dmitrievich, represent my interests in the course of verification of evidence.
Attachments:
- 1. Copy of the letter from the Deputy Mayor of Moscow, Moscow city Government, Mr A. N. Gorbenko, d/d May 04, 2012, on two pages.
- 2. Copy of the announcement published on the official site of the Ministry of the Interior, Moscow Sate Dept, on May 06, 2012: “Security Procedures During Public Events on May 6th”, with a scheme, on 3 pages.
- 3. Laywer Kobzev’s Certificate, on 1 page.
I am warned about the criminal responsibility for knowingly giving false information.
______________A. A. Navalny
______________May 17, 2012
(Attachments)Originally posted by
navalny on
May 17th, 15:29