You have repeatedly stated publicly that you do not own any real estate outside the Russian Federation.
On July 4, 2016, the following post was published via the verified Twitter account “AramAshotych” (@AramAshotich): “Ooo, loser Navalny is in on it with Shaltai! Nice! And to whoever finds a penthouse belonging to me anywhere at all—I’ll give it to them!)))” (here and below, the author’s spelling and punctuation are preserved).
Another statement was made through the same account: “honestly , I don’t have any real estate abroad! What do I have to be afraid of, did I steal something or what?”.
It follows from the content of the above statements that A.A. Gabrelyanov publicly addressed an indefinite circle of persons with a promise to award a prize to anyone who performed a specific act—namely, finding his luxury real estate outside the Russian Federation. The promised reward was the discovered luxury property itself. The promise was made without any time limit, and no public revocation of the promise was ever issued.
On May 15, 2018, the Anti-Corruption Foundation published an investigation presenting documentary evidence that A.A. Gabrelyanov, through the Cypriot offshore company Zoranson Holdings Limited, owned a 1/2 share in an apartment located at 74 Boulevard Maurice Barres, 92200, Neuilly-sur-Seine, France. The investigation was accompanied by photo and video materials recorded at the location of the residential property.
On the same day, the person who had promised the reward confirmed that he did in fact own luxury real estate abroad, thereby acknowledging that the Anti-Corruption Foundation had performed the act required to receive the reward, as specified in the public promise. The confirmation was published on Facebook from Aram Gabrelyanov’s personal account: “You little rat, you suck! I earned it, I bought it, and I bought it a long time ago! I didn’t fleece gullible followers, and I didn’t get money from the State Department! And as for proving that you’re a nobody, I’ll keep proving it no matter what!”.
Under Article 1055 of the Civil Code of the Russian Federation, a person who publicly announces the payment of a monetary reward or the granting of another prize (payment of a reward) to anyone who performs the lawful act specified in the announcement within the period stated therein is obligated to pay the promised reward to any person who performs the relevant act, including, in particular, finding a lost item or providing the person who announced the reward with the necessary information. The obligation to pay the reward arises provided that the promise of reward makes it possible to identify the person who made it.
In view of the above circumstances and on the basis of civil law, we hereby demand the immediate transfer to the ownership of the non-profit organization “Anti-Corruption Foundation” of the 1/2 share in the apartment located at 74 Boulevard Maurice Barres, 92200, Neuilly-sur-Seine, France.
May 21, 2018
Founder of the non-profit organization “Anti-Corruption Foundation” A.A. Navalny
Director of the non-profit organization “Anti-Corruption Foundation” R.V. Rubanov
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