EUROPEAN COURT of HUMAN RIGHTS Council of Europe Ctrasbourg

   Form A. Plaintiff Ė v. file B. The Honorable Convening Country Ė Russia

        II p.14 Statement of the facts:

       The USSR in the past, and now Russia, have been practicing wide scope war medicine experiments on humans while developing and updating new varieties of weapons, such as psychophysical, genetic, including the ethnic.

      Citizensí apartments have been transformed into torture chambers, different things are tested on the people, as well as gases, neuroleptics, narcotics, psychotropic substances, bacteriological preparations, including those banned by the International Convention. All 27 persons from different cities of Russia who are pleading before the European Court for protection have similar ailments, such as diabetes, varicose veins, cataracts; the women have the prolapse of the uterus; burns, hematomes, angyomae, diverse swellings; cardiovascular complaints; all are confirmed by medical certificates and evidence torture and abuse to which the people are subject and as a result to which they and their family members have lost lives and health (v. Annex: files on 30 persons).

      The peopleís plaints to diverse Government instances get no results, only token responses. Until the Amendment to Art.6 of the Federal Law Concerning Weapons was passed, when people complained of radiation exposure, they were put, in absentia, under psychiatric control or interned in psychiatric institutions. Being thus branded, the person was henceforth unable to plead with any instance.

      The Moscow Housing Ecology Committee, members of the St. Petersburg ďSociety of Persons Subject to Bioenergetic terrorĒ, and individual citizens have repeatedly pleaded before the Procurator Generalís Office, demanding that criminal proceedings be initiated in connection with exposure of people to radiation. The Procurator General Office relegated the plaints to City Procuratorís Offices, these Ė to District Procuratorsí, and these made nothing but token responses. Then a number of members of the Moscow Housing Ecology Committee filed suits in district courts against the Procuratorsí inaction, and some suits were won. (v. files of Vorontsova S.B., Domojizova T.K., Tretyakova T.V.), some were lost, but neither the court decisions in our favor moved the procuratorsí offices or the law enforcement agencies to initiate criminal proceedings against radiation inflicted on the people.

      After the Amendment to Art.6 of the Federal Law ďConcerning WeaponsĒ, the Moscow Housing Ecology Committee addressed letters to the Government of Russia and the Presidentís administration, requesting that it be made clear, which of the executive powers would execute the mentioned Amendments. The answer was: the law enforcement agencies did the best to estrange themselves from this weapons issue, pleading that these weapons are banned for distribution and on the RF Defense Ministry and Federal Security Serviceís hands.

      Understanding what ministries we have to deal with, and that no one intends to act in accordance with the court decisions (waiting for Kremlinís directives that never came), on December 15, 2002, 14 members of the Moscow Housing Ecology Committee filed criminal suit at the Superior Court against RF Defense Minister Ivanov S.B., FSS Director Patrushev N.L., Public Health Minister Shevchenko Yu.L., and RF Procurator General Ustinov V.V., bearing in mind that Art.19 of the Russian Constitution states:

      ďp.1: All are equal before law and court; p.2: The State guarantees equal rights and liberties, human and civil, regardless of sex, race, nationality, patrimony or officeĒ (v. Annex).

      By our law, criminal proceedings may be initiated by procuratorsí offices or law enforcement agencies, which, by inaction, virtually undermine this law. The Superior Court, in accordance with Art.448 p.2 of RF Criminal Proceedings Code, ďInitiation of criminal proceedings against the Procurator General by a college of three Superior Court JudgesĒ, is empowered to initiate criminal proceedings against the Procurator General, and we were hoping the Court would subpoena the RF Procurator General to initiate criminal proceedings in connection with exposure of humans to radiation. But our country is distinguished by total absence of government, and when it comes to redistribution of possessions, little does it matter how money is obtained - by genocide, narcotics or petroleum. These matters are of no concern to our government, or the President.

      On December 24, 2002, in the RF Supreme Courtís closed session, in the absence of the plaintiffs and the accused and their representatives, Judge Zaitsev V.Yu. passed a decision to deny initiation of criminal proceedings against Defense Minister Ivanov S.B., FSS Director Patrushev N.P., Public Health minister Shevchenko Yu.L., and RF Procurator General Ustinov V.V., referring to Russiaís Civil code (v. Annex). It is unclear, why did Judge Zaitsev V.Yu. consider our suit under a Civil Code aspect, the worldwide practice being, in cases of crimes committed against the people, the criminals to be judged in accordance with the Criminal Code.

      Members of the Moscow Housing Ecology Committee filed against the Supreme Courtís December 24, 2002 decision (v. Annex) a cassation appeal , which was considered on March 11,2003. The plaintiffs were summoned to this hearing, but neither the accused nor their representatives were present. Our 14 committee members were joined by several more members of our committee, residing in other cities, and by members of the St.Petersburgh ďSociety of Persons Subject to Bioenergetic TerrorĒ. In the course of the Court session, a petition was submitted, but it was rejected by Judge Fedin A.I.

      This court also rejected our appeal (v. Annex). Concerning this decision, the Moscow Housing Ecology Committee jointly with the members of the St.Petersburgh ďSociety of Persons Subject to Bioenergetic TerrorĒ appealed for revision to the President of the RF Supreme Court, Lebedev V.M., and again our case was considered in our absence and, signed by Judgeís Helper Kulikov I.V., a response was sent to us of such a nature, that it is the shame to read it (v. Annex). In Russia, the people is considered as a kind of lowly creatures which it is permissible to kill, torment and use as a source of income; all with impunity. The Judgeís Helper again refers to the RF Civil Code and two of its Articles, and does so because he simply has nothing to say.

        III. p.15 Statement of alleged violation(s) of the Convention and / or protocols and of relevant arguments. .   Our plaint, based on the International Convention, adds up to the fact that Russia, having signed the International Convention, has never fulfilled it, and the European Community countries treat this with latitude. We consider that Russia violates the following Articles of the Convention: 2,3,5,6,8.

        Art.2 .  Ė Right to life. In Russia, the people are not endowed with the right to life; there is the Russian Constitution, which guarantees the right to life, and there are laws, but there are not observed. Russiaís special services can, without benefit of court hearing or investigation, kill a person; they can use the latest technical innovations to transform his apartment into a torture chamber, subject him, without his consent, to all sorts of medicine experiments, and regardless of instances before which he may plead help, he will get none (v. files of persons appealing to the European Court: each has recurred to several instances).

        Art.3 .   Ė Ban of torture. In Russia, persons have been and still are, subject to torture. If in the past there was one variety of torture, now, with the employment of different technical apparatus and chemical preparations, the torture and abuse have become more cruel and sophisticated. A person lives in an apartment transformed into torture chamber, it is impossible for him to live in the apartment. He is deprived of slumber; day and night he is a subject to painful sensations; his psyche is broken into; before his very eyes, his close relatives are killed and he is helpless to assist them; depriving of sleep, he loses working capacity, is reduced to vagrancy with total deprivation of means of normal existence; his wife is raped, her sex organs burned; his child is raped; a personís memory is obliterated, leaving only working habits, in other words, a person is transformed into biological robot, into a slave. By orders of unknown source, a person is deprived of life or made invalid (v. life of Katzerikova G.I., Rozanchuk M.I., and others).

        Art.5 .   Ė right to liberty and personal immunity. If a person, unknowing, is selected for experiments, what liberty is this? He is under round the clock observation with employment of all the scientific achievements and the technical. If the person leaves in another country, our special services persecute him there too. There is no question for personal immunity: a person is at the experimentatorsí mercy. They can test on him any gas, narcotic, biological preparation; he is in sadistsí hands (v. files).

        Art.6 .  Ė right to fair trial. In Russia, people are deprived of fair public trial by an independent and impartial court. The courts are corrupted. The Moscow Housing Ecology Committee has had to life a compliant against the judges to the president of judiciary qualification commission. The compliant referred to the unworthy behavior of Preobrazhensky District Court Judge Ivleva. The responses we got are beyond criticism: it turned out that all is our own fault that we provoked Judge Khokhlov to assault the woman with fists, and if Judge Ivleva has failed in a yerís time to give hearing to the Rybinsí plaint against law enforcement agencies, we must keep our opinion to ourselves. Many members of the Moscow Committee have tried to file suits in first instance courts (urban district); but the suits were simply not accepted. The Supreme Court would not accept our plaint, and we were forced to expedite all our materials by registered mail with notice of delivery. When we tried to learn our documents registration number, we were misinformed that mail deliveries had not been sorted out during two weeks, while a closed session an unfavorable decision concerning our plaint. We could make many such references to our ďindependent and impartial courtĒ.

        Art.8 .  Ė All are endowed with the right to respect of private and family life. This Article is totally violated with respect to the plaintiffs. They are broken into and undergo maraudery. Valuable property is taken, so is money; the entire apartment and personal belongings are drenched with chemicals; furniture, TV-sets, recorders, sanitary installations and telephones are spoiled. All telephone conversations are monitored, the mail is controlled (v. affidavits signed by witness and certified by notary public in plaintiffsí files).

        IV p.16 statement relative to article 35 p.1 of the Convention .   On December 15,2002, 14 members of Moscow Housing Ecology Committee filed suit at the RF Supreme Court, demanding criminal proceedings against Defense Minister Ivanov S.B., FSS Director Patrushev N.P., Public Health Minister Shevchenko Yu.L., RF Procurator General Ustinov V.V. for unsanctioned war medicine experiments on humans; indemnity to families for the loss of family members; indemnity for ruined health, material loss and indemnity moral damage.(v. Annex.2.a) The Supreme Court hearing took place in closed session and in absence of plaintiffs and accused. On December 24, 2002, the Supreme Court passed a decision to reject the suit for criminal proceedings and indemnity of material loss and indemnity moral damage (v. Annex 2.b).

      On January 18, 2003, we received notice from Supreme Court that our suit is rejected, but we may file a cassation plea. Together with six other members of the Moscow Housing Ecology Committee, residing in other cities, and seven more members of the St. Petersburg ďSociety of Persons Subject to Bioenergetic terrorĒ, on January 25, 2003, we filed our plea for cassation(v Annex 2.c). The hearing was scheduled by Supreme Court for March 11,2003.

      On March 11, 2003, our cassation plea was considered in open hearing, but only the plaintiffs were present. The accused did not appear, nor did their representatives. We offer to the Court a petition that 13 more persons be included in the list of plaintiffs.(v Annex 2.d) Presiding Judge Fedin A.I. declines the petition, thus breaking Art.271 of RF Criminal Proceedings Code. Also defines as us the following: definition of the judge of the Supreme Court of the Russian Federation from December, 24, 2002 to leave without changes, the individual complaint of applicants - without satisfaction ( v.Annex2.e)

      We consider that a court hearing as such did not take place. We have included all the Courtís violations in our plea for revision (v. Annex 2. f) addressed to RF Supreme Court President, Lebedev V.M.

      Our plea for revision has also been considered in the plaintiffsí absence, and a response we received from the Supreme Court in April 14,2003 is, in our opinion, a ďmasterpieceĒ of our judiciary system (v. Annex 2.g).

        18. .   In our State, there are no more instances which we might plead for protection. We are in permanent contact with the RF State Dumaís Security Committee, and entire Duma knows of this terror. The President is also well informed, for we have pleaded with him personally through internet. On hundreds of occasions we have recurred to the Procurator Generalís Office, gone through district and city courts, all Supreme Court instances; now we are forced to seek protection of the European Court.

        19. .   Pleading before the European Court, we seek, above all, protection at international level for ourselves, our kin and our friends, against this terror , initiated in times of totalitarian regime and still practiced nowadays. Besides.

      We plead for: 1. Russiaís subpoena to comply with the International Convention provisions undersigned by her; 2. Ban of experiments on humans and development of new types of psychophysical weapons; 3. Recognition of the plaintiffs as victims; 4. Russiaís subpoena to reveal the names of the criminal authors of this terror and initiate criminal proceedings against them; 5. International Court prosecution of these criminals for genocide of Russiaís peoples; 6. Pay for indemnity to the families of their bereavement, damage to health, material loss and moral damage in the amount of 1000000 (One million) dollars USD to each plaintiff and bereaved family.

        20. .   We have not recurred to other competent international instances. The Moscow Housing Ecology Committee and members of the St. Petersburg ďSociety of Persons Subject to Bioenergetic terrorĒ humbly plead before His Excellency, the President of the European Court and the honorable Judges to give us gratis legal assistance, for our plaintiffs lack the means to pay legal counsel. We shall present for your examination an account of our financial means. Our representative, Petukhova Alla Yakovlevna, whom we have entrusted our interests in the European Court at the stage of primary plea, lacks education in the field of Law. We understand that difficulties may arise during consideration of our plea. We are grateful in advance.



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