To the Head of the Main Investigative Directorate of the Investigative Committee of the Russian Federation for the City of Moscow V.V. Yakovenko 16 Arbat St., Bldg. 2, Structure 1 Moscow 119002 from attorney Alexei Anatolyevich Navalny of the Interregional Moscow Bar Association residing at STATEMENT regarding a committed crime According to the letter of Deputy Mayor of Moscow in the Moscow City Government A.N. Gorbenko dated May 4, 2012, public events scheduled for May 6, 2012 were approved with a group of citizens consisting of I.V. Bakirov, S.K. Davidis, E.A. Lukyanova, N.L. Mityushkina, and S.S. Udaltsov: a march from Kaluzhskaya Square along Bolshaya Yakimanka and Bolshaya Polyanka Streets to Bolotnaya Square from 4:00 p.m., and a rally at Bolotnaya Square until 7:30 p.m., for the purpose of “expressing protest against abuses and falsifications during the elections to the State Duma of the Russian Federation and the President of the Russian Federation, demanding fair elections, respect for human rights, compliance with Russian law, and its international obligations.” According to information posted on May 5, 2012 on the official website of the Moscow Main Directorate of the Ministry of Internal Affairs (http://petrovka38.ru/news/38875/), from 4:00 p.m. to 7:30 p.m. a march by a group of citizens, with an announced attendance of up to 5,000 people, was approved from Kaluzhskaya Square along Bolshaya Yakimanka and Bolshaya Polyanka Streets, across Maly Kamenny Bridge, to Bolotnaya Square, where a rally was to take place; access to the rally was to be organized from Bolshoy Kamenny Bridge and Maly Kamenny Bridge, where 15 metal detector frames were also to be installed. At the same time, the above website published a diagram of these events showing the locations of the metal detector frames, the march route, traffic closure sections, and the rally site. On May 6, 2012, as people were moving toward the rally site, it became apparent that officials of the Moscow City Government and the Moscow Main Directorate of the Ministry of Internal Affairs had grossly failed to comply with the previously approved plan and procedure for the events. In particular, the square at Bolotnaya Square, contrary to the diagram published on the official website of the Moscow Main Directorate of the Ministry of Internal Affairs (marked with a black hexagon labeled “rally”), was completely cordoned off by police officers. Access to the rally site from Bolshoy Kamenny Bridge was not organized and was blocked. The metal detector frames were absent from the location indicated on the diagram. Access from Maly Kamenny Bridge was almost completely blocked, leaving only a narrow passage to Bolotnaya Embankment. These violations of the previously approved procedure, diagram, and route for the public events, as published in the media, made it impossible for people to reach the rally site and consequently caused a mass buildup of march participants at the narrow passage to Bolotnaya Embankment, crowd crushes, disorientation among participants in the public event, the impossibility of holding the rally using sound amplification equipment, the use of violence by police officers, and bodily harm of varying severity to citizens. Thus, there was a deliberate and intentional effort to mislead the participants in the mass public event. Any attempt by march participants to proceed along the route previously approved and published on the official website of the Moscow Main Directorate of the Ministry of Internal Affairs inevitably led to a “breach” of the police cordon. Despite having every opportunity to do so, officials of the Moscow City Government and the Moscow Main Directorate of the Ministry of Internal Affairs took no steps whatsoever to inform the organizers and participants of the mass public event about changes to the march route and the placement of rally participants. Also, in violation of the previously approved and published layout for rally participants, police officers set up a cordon on Bolotnaya Embankment near Luzhkov Bridge, perpendicular to the Vodootvodny Canal, leaving a narrow corridor no more than 3 meters (about 10 feet) wide for citizens to pass toward the stage, thereby provoking a crowd crush and making it impossible for march participants to reach Bolotnaya Embankment. In addition, police officers directly obstructed the lawful and approved rally by cutting power to the installed stage and thereby eliminating the possibility of using sound amplification equipment. That is, the actions of officials of the Moscow City Government and the Moscow Main Directorate of the Ministry of Internal Affairs, whose duties included ensuring the safety of the above public events as well as compliance with the conditions and procedure for holding them, show signs of criminal offenses under Articles 149, 285, 286, and 293 of the Criminal Code of the Russian Federation. Based on the above, P**LEASE: ** Instruct subordinate staff to conduct an inquiry into the above circumstances in accordance with Articles 144 and 145 of the Criminal Procedure Code of the Russian Federation, and based on the results, initiate a criminal case and bring the guilty parties to criminal liability. I request that during the course of the inquiry my interests be represented by attorney Vadim Dmitrievich Kobzev of Branch No. 5 of the Moscow Regional Bar Association. Attachments: Copy of the letter of Deputy Mayor of Moscow in the Moscow City Government A.N. Gorbenko dated May 4, 2012, on 2 pages; Copy of the notice posted on the official website of the Moscow Main Directorate of the Ministry of Internal Affairs for Moscow on May 6, 2012, “Maintaining Public Order During Mass Events on May 6,” with diagram, on 3 pages; Attorney Kobzev’s warrant, on 1 page. ________________________/A.A. Navalny/ I have been informed of criminal liability under Article 306 of the Criminal Code of the Russian Federation for knowingly making a false report of a crime ________________________/A.A. Navalny/ May 17, 2012 Attachments