Volume VI - Annexes 21-41

INTERNATIONAL COURT OF JUSTICE
APPLICATION OF THE INTERNATIONAL CONVENTION FOR THE SUPPRESSION
OF THE FINANCING OF TERRORISM AND OF THE INTERNATIONAL
CONVENTION ON THE ELIMINATION OF ALL FORMS OF RACIAL
DISCRIMINATION
(Ukraine v. Russian Federation)
REJOINDER
Submitted by the Russian Federation
Volume VI
(Annexes 21 - 41)
10 March 2023

TABLE OF CONTENTS
VOLUME VI
Annexes 21-41
Annex 21 Expert Report of Sergey Miroslavovich Markedonov, 8 March 2023.
Annex 22 Witness Statement of Alexei Gayarovich Zhafyarov,
28 February 2023.
Annex 23 Second Witness Statement of ,
7 March 2023.
Annex 24 Expert Witness Statement of ,
6 March 2023.
Annex 25 Witness Statement of Valentina Vasilyevna Lavrik, 7 March 2023.
Annex 26 Witness Statement of , 2 March 2023.
Annex 27 Witness Statement of , 18 February 2023.
Annex 28 Witness Statement of , 7 March 2023.
Annex 29 Witness Statement of , 7 March 2023.
Annex 30 Witness Statement of ,
22 February 2023.
Annex 31 Witness Statement of , 3 March 2023.
Annex 32 Witness Statement of , 2 March 2023.
Annex 33 Witness Statement of , 7 March 2023.
Annex 34 , Informational Note.
Annex 35 Ministry of Internal Affairs, Information on the number of missing
persons in the Republic of Crimea and the City of Sevastopol between
2014 and 2022, No. 3466/dp, 22 February 2023.
Annex 36 Uspishna Varta, THE RIGHT TO FREEDOM OF SPEECH AND OPINION IN
UKRAINE: THREATS AND OPPORTUNITIES, 2018.
Annex 37 Mediacentre n.a. I. Gasprinsky, Letter, 2 March 2023.
Annex 38 Council of Ministers of the Republic of Crimea, Letter
No. 1/01-46/8775/3/3/214, 14 February 2023.
Annex 39 A. Dyukov, M. Vilkov, FROM MURDERS TO POGROMS: UNPUNISHED
VIOLENCE FROM THE SIDE OF RIGHT-WING ACTIVISTS AGAINST ROMA
IN UKRAINE (Warsaw, 2018).
Annex 40 S. Vnukov, O. Sharov, CRIMEA - TAURIDA. ARCHAEOLOGICAL
RESEARCH IN CRIMEA IN 2017-2018 (Institute of Archeology RAS,
2019, Vol. 1).
Annex 41 S. Kozlov, GRU SPETSNAZ: FIFTY YEARS OF HISTORY, TWENTY YEARS
OF WAR (Russkaya Panorama Publishers, Essays on Contemporary
History Series, 2003).
Annex 21
Expert Report of Sergey Miroslavovich Markedonov, 8 March 2023

Annex 21
INTERNATIONAL COURT OF JUSTICE
APPLICATION OF THE INTERNATIONAL CONVENTION
FOR THE SUPPRESSION OFTHE FINANCING OF TERRORISM
AND OF THE INTERNATIONAL CONVENTION ONTHEELIMINATION
OFALLFORMSOFRACIALDISCRIMINATION
(UKRAINE V. RUSSIAN FEDERATION)
EXPERT REPORT
OF SERGEY MIROSLAVOVICH MARKEDONOV
8 MARCH 2023
Annex 21
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TABLE OF CONTENTS
I. INTRODUCTION ................................................................................................................. 3
A. Qualifications .................................................................................................................... 3
B. Questions Put to the Expert .............................................................................................. 4
II. SUMMARY ......................................................................................................................... 5
III. NONCONTRADICTORY HISTORICAL NARRATIVE AND ITS COSTS .................................... 7
IV. UKRAINIAN PROJECTS: PROBLEMS OF REPRESENTATIVENESS ..................................... 11
V. NATIONAL PROJECTS OF THE TWENTIETH CENTURY .................................................... 16
VI. EXPERT DECLARATION .................................................................................................. 19
Annex 21
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I. INTRODUCTION
A. QUALIFICATIONS
1. My name is Sergey Miroslavovich Markedonov. I am a Russian international political
scholar, specialist in nationalism and nation-building issues, conflicts in the post-Soviet
space and European security, Candidate of Sciences (History), leading scholar of the
Centre for Euro-Atlantic Security, Institute of International Studies, MGIMO, Editor-in-
Chief of International Analysis Journal.
2. I describe my relevant experience below:
(a) 2001-2010 – Head of Department, Deputy Director (January 2009 – May
2010) at the Institute for Political and Military Analysis. Since 2006 –
Associate Professor at the Faculty of World Politics, Lomonosov Moscow
State University, and the Faculty of Modern Russian History, Russian State
University for the Humanities.
(b) May 2010 – October 2013 – Visiting Fellow, Center for Strategic and
International Studies, Russia and Eurasia Program (Washington, DC, USA).
February 2014 – March 2019 – Associate Professor, Faculty of Foreign
Regional Studies and Foreign Policy, Russian State University for the
Humanities.
(c) Visiting researcher at the Institute for Humanitarian Research (IWM) in
Vienna, Austria (June-July 2014), Fudan University in Shanghai, PRC
(April-May 2015), German Society for Foreign Policy (DGAP) in Berlin,
FRG (August-September 2016). Visiting Professor at the Centre for
Eurasian Studies at the University of Mumbai, India (January 2016).
(d) Since 2014, expert at the Russian Council on Foreign Affairs and the
Gorchakov Foundation for the Support of Public Diplomacy. I have
extensive experience in analytical work and field research on security issues
in the South Caucasus, Ukraine, Moldova, and the relationship between
Russia, the US, NATO, and post-Soviet states in the context of Euro-
Atlantic security.
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(e) I regularly participate in prestigious international academic and scholarly
conferences, including those under the auspices of the UN, the OSCE, the
Council of Europe, the Russian Council on Foreign Affairs, the Gorchakov
Foundation, Georgetown University, Harvard University, Princeton
University, Columbia University, Lomonosov Moscow State University,
MGIMO, the Higher School of Economics.
(f) I am the author of more than 50 scientific publications, as well as numerous
expert and analytical reports and commentaries in the media.
B. QUESTIONS PUT TO THE EXPERT
3. I have been asked to prepare an expert report for submission to the International Court of
Justice in the case before ICJ, "Application of the International Convention for the
Suppression of the Financing of Terrorism and of the International Convention on the
Elimination of All Forms of Racial Discrimination" (Ukraine v. Russian Federation). My
task is to assess, whether Second Expert Report of Professor Paul Robert Magocsi
adequate and scientifically sound describes the way of Ukraine and Ukrainians to their
independent national-state existence.
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II. SUMMARY
4. As a result of the analysis of the available materials provided by Ukraine in support of its
allegations as well as of publicly available sources I have come to the following
conclusions.
5. General conclusions:
(a) The Second Expert Report of Professor P.R. Magocsi aims to form an idea
of the struggle of Ukraine and Ukrainians for their independent nationalstate
existence as a deterministic and noncontradictory process without
alternatives. However, the external consistency of the author's constructions
comes at the expense of significant simplifications and sometimes
distortions, which in the end give a wrong picture.
(b) The Ukrainian lands were under different sovereignties, and the people who
lived there participated in different state projects and were bearers of
different loyalties and identities. For a considerable part of historical time,
the Russian and Ukrainian peoples were in unity, which led to their mutual
cultural enrichment and development. Up until the nineteenth century,
debates about identity options and different interpretations of the
proximity/differences between the Great Russians and the Little Russians
were debates that took place within a narrow elite educated stratum. In the
second half of the 19th century, we observe the first, extremely limited in
their numbers Ukrainian nationalist associations - the Kirill and Mefodiy
Society of the 1840s and the Kiev Hromada of the 1860s. However, neither
they, nor the associations that followed, both in the Russian Empire and in
Austria-Hungary, built their plans according to a single design. Some of
them promoted the idea of the particular Ukrainian statehood but some
supported federalist, democratic or socialist values, not looking for the
breakup with the Russian people. Anti-Russian sentiments manifested
themselves, largely fuelled from outside, during the two World Wars and
the civil wars, but were not deterministic until the beginning of the twentyfirst
century.
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(c) In the current context, it is crucial not to use the historical past as a tool to
deepen the confrontation. Unfortunately, attempts to simplify and distort the
narratives of Ukraine, to reduce them to the Galician-Diasporan myth (with
the important caveat that ‘Russophile sentiment’ was not something
marginal in the eastern regions of Austria-Hungary until the early 20th
century, which is what P. R. Magocsi does, have not only academic, but also
political consequences. It has formed the basis of educational policy which
largely consisted of the closing of Russian schools and narrowing of the
sphere of the Russian language use. Attempts to homogenise the Ukrainian
identity on the basis of this narrative resulted in the loss of Crimea and the
south-eastern regions of the country.
6. I describe my findings in more detail below.
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III. NONCONTRADICTORY HISTORICAL NARRATIVE AND ITS COSTS
7. In the introductory part of his report, P.R. Magocsi clearly formulates his super-objective
as a study of the historical experience of Ukrainian nation-state-building. From his point
of view, the Declaration of Independence adopted by the Verkhovna Rada (Parliament)
of Ukraine on August 24, 1991, did not open anything fundamentally new in the history
of that country. According to Magocsi, “in fact, during the twentieth century alone,
independence was proclaimed for all or part of Ukrainian territory no less than five times
before 1991. Nor was the idea of statehood in Ukraine limited to the twentieth century.
Three centuries earlier Ukrainians created a state which existed in some form from the
mid-seventeenth to late eighteenth centuries”.
8. Thus, the author offers a coherent and noncontradictory historical narrative, according to
which the struggle for an independent state has been consistently waged by the bearers of
a separate Ukrainian identity for at least three and a half centuries. A kind of continuity
line is constructed from the Zaporozhian Army led by Bohdan Khmelnytsky and the
Hetmanate (among its leaders Magocsi gives special prominence to Ivan Mazepa) to the
post-Soviet Ukrainian state project.
9. However, the other side of that noncontradictory historiographical construct tends to
oversimplify the historical past of Ukraine. The author ignores a number of fundamental
features of Ukrainian history.
10. First, the very concepts of Ukraine, Ukrainian, as well as the geographical scope of their
application have evolved over the centuries.1 They also coexisted with other selfidentifications
– Maloross (Little Russian), Russian, Rusyn and Cossack. Until the middle
of the 16th century, in the Kingdom of Poland and the Grand Duchy of Lithuania, the
local population of the former Rus (present-day Ukraine) was referred to as ‘Rusyns’.
Then new forms appeared Latin Ruthenia/Ruthenians and Roxolania/Roxolanus, as well
as Hellenized ‘Russia’ (Rosia) and ’Russian people‘. From the fourteenth century the
term ’Malorossia’ (Little Russia) appears, first to denote the Polish part of the Kiev
metropolis, and after 1648 the territory of the Cossack Hetmanate. In the Moscow State,
the inhabitants of the Orthodox lands of the Polish-Lithuanian Commonwealth were
1 F. Gaida, BORDERS AND BOUNDARIES: NOTIONS OF “UKRAINE” AND “UKRAINIANS” IN THEIR HISTORICAL
DEVELOPMENT. (Moscow: Modest Kohlerov. 2019).
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called ’Lithuanians‘ or ’Cherkasses‘, and only later ’Little Russians‘ or ’Cossacks‘. The
term ’Ukrainians‘, ’Ukrainian people‘ was originally used not as an ethnonym, but as a
characteristic of near-the-border (‘u krainy’) population.
11. Politicians and intellectuals of different eras and different countries put different
meanings into the concept of ‘Ukrainian’ (local, ethnic, national, civil). While for a Soviet
citizen the regions of Donbas were parts of the Ukrainian SSR, for a resident of the
Russian Empire or the Polish-Lithuanian Commonwealth of the first half of the 18th
century they were perceived as ‘Wild Fields’, disputed and undeveloped areas with no
clear connection to a particular state.2
12. Secondly, all attempts to create a special statehood in the period from the XVII to the XX
centuries in the territory of post-Soviet Ukraine were realized in different geographical
configurations. The same Zaporizhian Host or Hetmanate did not have in its composition
not only Crimea and Donbas, the regions about which Professor Magocsi writes as
unconditionally Ukrainian, but also the territories on the right bank of the Dnieper. By
the way, the famous project of Ivan Mazepa's closest associate Philip (Pylyp) Orlyk
(1710), which in post-Soviet Ukrainian historiography is defined as the ‘first
Constitution’ of Ukraine, was called ‘The Treaties and Resolutions of the Rights and
Freedoms of the Zaporozhian Army’.3
13. However, even in the twentieth century we can speak rather of Ukrainian projects than of
a single Ukrainian project. A striking example is the (co)existence of the Ukrainian and
West Ukrainian republics, which, despite their proclaimed unification into a ‘single
sovereign’ state, in practice never managed to fully integrate.4
14. Thirdly, P.R. Magocsi underestimates the obvious collision between the current nationalterritorial
ambitions of Kiev (which he consistently defends) and the historical process of
2 Danilevsky I.N., Tairova-Yakovleva T.G., Shubin A.V., Mironenko V.I. HISTORY OF UKRAINE. SPb. Aletheia,
2015. - 290 p. Kotenko A.L., Martyniuk O.V., Miller A.I. ‘MALOROSS’: EVOLUTION OF THE NOTION BEFORE THE
FIRST WORLD WAR // Independent Literary Review. - М., 2011. - № 108. - P. 9-27.
3 Treaties and regulations of rights and liberties of army between hetman Philip Orlik, newly elected after Mazepa's
death and between general's foreman and Zaporizhian army in 16 articles, in Bendery, signed and sealed by Orlik.
1710. April. 5 //Russian State Archive of Ancient Acts (RSAAC). V. 124. Opt. 2. D. 12. p. 2-12. The state is
defined in the document as ‘Little Russia, our Fatherland’ (Article 2), ‘Ukraine’ (Article 14), and the inhabitants
are referred to as ‘the people of Little Russia’, ‘the sons of Little Russia’.
4 Borysenok E.Y. NON-SOVIET UKRAINIANISATION: POLISH, CZECHOSLOVAKIAN AND ROMANIAN AUTHORITIES
AND THE ‘UKRAINIAN QUESTION’ IN THE INTERWAR PERIOD. Moscow: Algorithm. 2018. 141 p.
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‘gathering’ of Ukrainian lands. On the one hand, he agrees that the current ‘territorial
integrity’ of Ukraine (within the 1991 borders) has been shaped by other political forces
rather than fighters for a national Ukrainian idea. He emphasizes that after the victory of
the USSR in World War II ‘for the first time in history, the vast majority of ethnic
Ukrainian-inhabited lands (as defined by Ukrainian scholars) were within the borders of
a single Ukrainian, albeit Soviet, state. Moreover, these were the lands (especially historic
Galicia) where the Ukrainian national movement had its earliest beginnings and where
ethnic national identity was still at its strongest and most widespread’.
15. Indeed, it was the Soviets who incorporated Galicia, Volhynia, Transcarpathia, Northern
Bukovina and Southern Bessarabia into the Ukrainian SSR. But the process did not end
in 1945; in 1954 it was followed by Crimea. It is also worth adding to this picture that in
the pre-revolutionary period it was not the Ukrainian movement but the Russian imperial
authorities who had formed the territorial predicates of the future independent Ukraine,
including the Northern Black Sea coast (1760-1770s), the territory of the former Crimean
Khanate (1783), the southern lands between the Dnieper and Bug rivers (1791) and the
lands of Right-bank Ukraine as a result of the partitions of the Commonwealth of Poland
and Lithuania.
16. Thus, both the Ukrainian SSR and present-day Ukraine have a multi-ethnic population
with different ideas about identity, statehood and different ideals for the past and the
future.
17. Fourth, P.R. Magocsi's historiographical constructs almost completely ignore the loyalist
sentiments among the ancestors of modern Ukrainians. Meanwhile, existing within the
framework of various state projects (Rzeczpospolita, the Moscow state and the Russian
Empire, the Austrian Empire/Austro-Hungary, the interwar Poland, Czechoslovakia,
Romania, the Soviet Union-UkrSSR), they were involved in the socio-political and socioeconomic
processes in these countries, promoted their interests and ensured their security.
There is no reason to consider Ukrainians (Little Russians, Ruthenians) as immanent
separatists, aiming only at the implementation of their national project. The Polish-
Lithuanian Commonwealth was supported by the ‘Russian families’ of the Ostrozhskis
and Vishnevetskis, while the Russian imperial military and diplomatic elite was
reinforced by such figures as Alexander Bezborodko, Ivan Paskevich and Viktor
Kochubey. In the USSR of Leonid Brezhnev's time, the so-called ‘Dnepropetrovsk clan’
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was the basis of power, and even the Secretary General defined himself in the 1926 census
as ‘Ukrainian’.5
18. Fifth, Magocsi's work is based on the conclusions of almost exclusively English-speaking
historiography (American-Canadian researchers of Ukrainian origin). The arguments
(with which the author could have disagreed) of Soviet Marxist historians, representatives
of the ‘Russians abroad’, pre-revolutionary Russian researchers and contemporary
specialists from Russia and Ukraine have been left without any attention.6
5 LITTLE RUSSIANS VS UKRAINIANS: THE UKRAINIAN QUESTION IN THE SCIENCE, STATE AND CULTURAL POLICY
OF THE RUSSIAN EMPIRE AND THE USSR. Essays. Collective monograph. - Moscow: Institute of Slavic Studies,
Russian Academy of Sciences. 2018. - 528 p.
6 Miller A.I. ‘UKRAINIAN QUESTION’ IN THE POLICY OF THE AUTHORITIES AND RUSSIAN PUBLIC OPINION (SECOND
HALF OF THE XIX CENTURY). SPb. 2000. 260 p. Bicilli P. M. PROBLEM OF RUSSIAN-UKRAINIAN RELATIONS IN THE
LIGHT OF HISTORY // Selected works in philology M.: Heritage, 1996. P.107-134. Danilevsky, I.N. et al. Op. cit.
Myakotin V. ESSAYS ON THE SOCIAL HISTORY OF UKRAINE IN THE XVII-XVIII CENTURIES. Volumes 1-3. Prague,
1924.
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IV. UKRAINIAN PROJECTS: PROBLEMS OF REPRESENTATIVENESS
19. One of the ideologues of contemporary Ukrainian nationalism and well-known historian
Mikhail/Mykhailo Hrushevsky presented his programmatic socio-political pamphlet in
the form of the question ‘Who are the Ukrainians and what do they want?’7 In answering
it, perhaps the key issue is the question of representativeness. Who can we consider to be
the spokesman for the will of Ukraine and its people? Magocsi mentions Bohdan
Khmelnitsky as one of the founding fathers of Ukrainian statehood, and makes the
Cossacks look almost identical to the Ukrainians. However, the ‘free Cossacks’ opposed
not only nobles and magnates of the Polish-Lithuanian Commonwealth, but also
Registered Cossacks (the same Little Russians, like the famous hetman, who received
funding for their service from the Polish-Lithuanian state). That project was not supported
by the elite Little Russian groups either, which were defined in the sources as ‘Ruthenian
by origin, Polish by nationality’. And it is no coincidence that the period of 1650-1680s
in the history of Ukraine was called ‘Ruina’ (the Ruin).8 At the same time such a notion
as ‘multi-Hetmanship’ came into use. It was an order when some hetmans were oriented
to Moscow, some to Warsaw, some to Bakhchisarai and Istanbul while some even to
Sweden that did not share the common border with the Little Russian lands but actively
intervened the Eastern European politics. It is by no means an idle question which of them
can be considered the bearers of the ‘true’ idea of Ukrainian statehood. Not to mention
the considerable social distance between the Cossack nobility (who dreamed of rights and
privileges similar to those of the Polish-Lithuanian nobility) and the peasants of Little
Russia. Thus, we can not speak of any single image of a ‘free Ukraine’; on the contrary,
we can speak of a competition among a variety of projects (the pro-Polish choice of Ivan
Vygovsky, pro-Ottoman of Pyotr/Petro Doroshenko, and pro-Russian of Ivan
Briukhovetsky, who was the first Moscow boyar - a Cossack of Zaporozhye). It should
be noted that all the aforementioned hetmans and some other Cossack leaders changed
their ‘geopolitical vector’ more than once.9
7 Hrushevsky M.S. WHO UKRAINIANS ARE AND WHAT THEY WANT. Kiev. ‘Znannya Ukrainy’, 1991. - 240 p.
8 Kostomarov N. I. ‘RUINA’, ‘MAZEPA’, ‘MAZEPA FOLLOWERS.’ HISTORICAL MONOGRAPHS AND STUDIES. (Series
‘The Actual History of Russia’). M.: Charlie, 1995. - 802 p.
9 Yakovleva (Tairova) T. G. HETMANS IN THE SECOND HALF OF THE 50S OF THE XVII CENTURY, THE REASONS AND
THE BEGINNING OF THE RUIN. Kiev. Osnivy. 1998. - 447 p.
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20. P.R. Magocsi, describing the Little Russian Hetmanate as ‘a largely self-governing entity
in central Ukraine for well over a century until it was abolished in the 1780s by the
Russian imperial authorities under Catherine II’, gives special prominence to the figure
of Ivan Mazepa. However, the number of his supporters, who arrived with him in the
vicinity of Poltava to the Swedish King Karl XII’s positions, is estimated by the sources
as 3-4 thousand people, while about 16 thousand ‘loyal Cossacks’, headed by hetman
Ivan Skoropadsky, gathered under the banners of Peter I. Why then should not
Skoropadsky (as well as other figures of Hetmanate, such as Daniel Apostol), but Mazepa
in this case be considered the spokesman of the Ukrainian people?10
21. In his report, Magocsi draws a comparison between the policies of St Petersburg and
Vienna on the ‘Ukrainian track’ in favour of the latter. According to him (referring to his
own work!), ‘the rulers of Habsburg Austria tolerated and even encouraged the national
movement among Ukrainians (officially called Ruthenians at the time) based in the
”western” city of Lviv, while the tsarist Russian authorities aggressively attempted to
suppress the Ukrainian national movement among Ukrainians (officially called Little
Russians) based in the ”eastern” city of Kyiv.’ However, one should not forget the
existence of a powerful ‘Moscowphile’ (‘Russophile’) social movement in Austria-
Hungary. The situation was interesting and at times paradoxical, when the Little Russians,
subjects of the Russian Empire, were striving for cooperation with the Austrians, while
the Ruthenians, subjects of Emperor Franz Joseph, were dreaming of unity with Russia.
Consequently, there was no Galician monopoly on the Ukrainian project, nor was there
any anti-Russian predetermination.
22. The pro-Russian Ruthenian movement in Austria-Hungary, on the other hand, was
gradually suppressed by Vienna from the moment the anti-Russian alliance with Germany
was concluded. With the beginning of the First World War it created two concentration
camps for these people in Tallerhof and Terezin, where 30,000 people were held. They
were, incidentally, the first such camps in Europe. By the way, in 1914-1918 the
Ukrainians found themselves on both sides of the ‘barricades’ and were forced to fight
10 Pavlenko N.I. PETER THE GREAT. Moscow, Mysl. 1990. - 670 p.
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against each other. Three and a half million Ukrainians (Little Russians) were in the
Russian army, 250 thousand served in the Austrian army.11
23. The desire to ensure the noncontradictory character of the expert narrative also leads the
author away from considering the competition of various national projects in Ukraine
throughout its history. P.R. Magocsi is trying to brush aside the article by Russian
President V.V. Putin ‘On the historical unity of Russians and Ukrainians’.12 According
to him, it is ‘denying the historical right of the Ukrainian people to a state of their own,
and even denying that the Ukrainian people are ethnically distinct from their Russian
neighbours.’ However, such an approach is not scientific and the conclusion of the author
is incorrect. The question of the historical unity of Russians and Ukrainians was the
subject of study as early as in the 70s of the XVII century, soon after the left bank of the
Dnieper became part of the Kingdom of Moscow after the revolt of Bohdan Khmelnitsky
and the war with the Commonwealth of Poland and Lithuania. It was reflected in the
Synopsis ‘about a single Slavic-Russian people, part of which were both Little Russians
and Great Russians’, compiled in Pechersk Lavra in Kiev.13 At that time, the terms ‘Little
Russia’ and ‘Great Russia’, as well as the terms ‘Little Poland’ and ‘Great Poland’,
denoted a ‘small’ - in the sense of ‘original’ - and a ‘great’ - in the sense of ‘extended’ -
part.
24. The idea of an all-Russian nation resonated with a significant number of Little Russians.
The struggle for identity in the region was between Russian-oriented Little Russians and
Ukrainians, who shared the idea of a separate Ukrainian nation. For instance, the Union
of the Russian People, even in Volhynia, had far more than 100,000 members at the
beginning of the 20th century before World War I. Large Russian organizations that
united upper classes flourished in Kiev and Odessa. The monument to Pyotr Stolypin in
Kiev, unveiled in 1913 in front of the opera house where he was assassinated in 1911,
bears the words of the Prime Minister engraved on it: ‘I firmly believe that the light of
11 Miller A.I. NATIONAL IDENTITY IN UKRAINE: HISTORY AND POLITICS // Russia in Global Affairs. 2022. V. 20. -
№ 4.- P. 46-65.
12 Article by Vladimir Putin ‘On the historical unity of Russians and Ukrainians’, 12 July 2021, available at:
http://kremlin ru/events/president/news/66181.
13 Miller A.I. NATIONAL IDENTITY IN UKRAINE: HISTORY AND POLITICS // Russia in Global Affairs. 2022. V. 20. -
№ 4.- P. 46-65.
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the Russian national idea kindled in the West of Russia will not go out and will soon
illuminate the whole of Russia’.14
25. Moreover, a number of prominent historical figures of science and culture born in Ukraine
held views about the unity of Russians and Ukrainians (Little Russians). Nikolai Gogol,
in particular, pointed out: ‘Russian and Little Russian are twin souls, complementing each
other, related and equally strong. It is impossible to give preference to one over the
other’.15
26. Ukrainian historian and public figure Mikhail Dragomanov (by the way, a harsh critic of
national policy of the Russian Empire) wrote: ‘...The real Ukrainian policy in Russia must
exclude any thought of state separatism and, therefore, have as its goal only political
reform of the entire state on the basis of regional and communal autonomy’.16 Reviewing
Dragomanov's work, the Galician-born prominent writer Ivan Franko developed these
theses: ‘No intelligent man with even a shred of political common sense, much less
Dragomanov, could even in the most exuberant imagination paint himself the possibility
of separating or fencing off the Ukrainian land from Russia. Whoever knows at least a
little bit about the ethnographic borders between the Ukrainian, Great Russian and other
adjacent peoples can only wonder at the naivety of a publicist who presents such a fantasy
as a postulate of an intelligent politician’.17
27. The world-renowned philosopher Grigory/Hryhorii Skovoroda was a proponent of the
Little Russian identity and a single Russian nation of three branches. Several research
institutes in Ukraine still bear his name and his image is on the 500 hryvnia banknote.
28. The artificial separation of Russians and Ukrainians was not supported by such wellknown
figures of science and culture, natives of Ukraine as Academician Petro
14 Ibid.
15 Quoted from: Danilevsky G.P. ACQUAINTANCE WITH GOGOL (FROM LITERARY MEMOIRS) //Historical Bulletin.
1886. № 12. P. 479.
16 Cited from: Teslya A.A. NATIONAL-POLITICAL VIEWS OF M. P. DRAGOMANOV IN 1888-1895 // Sociological
Review. - 2016. - V. 15. - № 1. P. 106.
17 Funko I. MIKHAILO DRAGOMANOV. MISSING TIME. UKRAINIANS UNDER THE MOSCOW KINGDOM (1654 - 1876)
// Collected works in 50vv. Vol. 47. Kiev: Naukova Dumka, 1986. P. 403 - 404.
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Tolochko,18 President of the Ukrainian SSR Academy (and later National Academy of
Sciences) in 1962-2020, hero of Ukraine Boris Paton.
29. Thus, over several centuries, Ukrainians (Little Russians, Cossacks) have had a wide
spectrum of views as to their identity. Some defended the version of Ukrainian
independence; a significant part of the population rejected it, supporting the idea of a
triune Russian nation under the aegis of an Orthodox monarch. Some saw Ukraine as an
Orthodox entity, while others fought for a ‘Church Union’ (going back to the transfer the
ecclesiastical jurisdiction in the Ruthenian lands of the Polish–Lithuanian
Commonwealth from the Ecumenical Patriarchate of Constantinople to the jurisdiction
of the Holy See of 1596).
30. Ukrainians were subjects of different states and were prepared to defend them, not just
their own particular ethno-national interests. In this respect, one of the main flaws of P.R.
Magocsi's report is the neglect of Ukrainian multi-component nature, identity/loyaltybased
multi-culturalism.
18 Tolochko P.P. WHERE THE RUSSIAN LAND CAME FROM. Kiev. Publishing House D. Burago. 2016. 291 p.
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V. NATIONAL PROJECTS OF THE TWENTIETH CENTURY
31. The author pays particular attention in his report to the twentieth century, a time when
empires were being replaced by nation-states. He focuses on the Ukrainian People's
Republic. However, between 1917 and 1920, a dozen or so different republics emerged
on the territory of the future Ukrainian SSR. In addition to several Ukrainian People's
Republics, the establishment of the Donetsk-Krivoy Rog Republic, the Odessa Soviet
Republic, the Socialist Soviet Republic of Taurida, the Crimean Regional Government,
the West Ukrainian People's Republic, the Galician Socialist Soviet Republic and the
Crimean Soviet Socialist Republic was announced.
32. And it would be quite wrong to present the processes of ‘Sovietisation’ as something
directed solely by Moscow. At the time there was a civil war within Russia itself between
the Bolsheviks and the ‘white’ counter-revolutionary forces, and there was no single
centre for decision-making. Of particular note was the Ukrainian State, a project of former
Tsarist Adjutant-General Pavel Skoropadsky, who had proclaimed himself Hetman.
While supporting the idea of Ukrainian independence, his government did not rule out a
federation with Russia on the basis of the fight against the Bolshevik threat. Nestor
Makhno's anarchist movement, centred in what is now Zaporozhye and
Dnepropetrovsk/Dnieper Oblasts, also played a significant role in determining the
outcome of the civil war on the ruins of the Russian Empire.
33. All this shows that different parts of Ukraine had different visions of the country's future
development due to historical factors. However, all of them envisaged isolation within
the boundaries of those territories that encompassed the new entities. Thus, we can say
that the territory of Ukraine in 1917-1920 was a mosaic of different formations, which
were often the result of the ambitions of individual politicians, a situational reaction to
changes in Moscow, Petrograd or Kiev, rather than a deliberate implementation of some
clear national-state programme.19
34. Magocsi's report does not actually consider the events of the Second World War and their
impact on the projects of Ukrainian statehood. The author's analysis is limited to the
territorial increments of the Ukrainian SSR (due to victory of the Soviet Union in the
19 Zhiltsov S.S. HISTORY OF THE FORMATION OF THE UKRAINIAN STATE (BEFORE THE COLLAPSE OF THE USSR) //
Problems of the post-Soviet space. - 2018. VOL. 5. - No. 3.- PP. 309-328.
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Great Patriotic War) and the attempts to declare independence in the late 1930s and early
1940s. Meanwhile, in today's Ukraine the activities of the Organization of Ukrainian
Nationalists, the Ukrainian Insurgent Army, which are part of the phenomenon of
collaboration with Nazi - Hitler Germany, are glorified at the state level, which leads to
an internal division of Ukraine.20 To no small extent, the popularisation and imposition
of the Galician myth throughout Ukraine after 1991 has contributed to the internal
divisions in that country, first predominantly in electoral terms and then, during the
Orange Revolution and Second Maidan, region-wise. Meanwhile, according to Soviet
historians' calculations, over 16% of the Red Army personnel were of Ukrainian origin
(about 7 million people). Dozens of partisan detachments operated behind the Germans'
lines. As many as 2,021 Ukrainians were awarded the title of Hero of the Soviet Union.21
35. The sections of the report dealing with the post-Soviet period look more like a
presentation of Ukrainian ‘civic nationalism’. Indeed, the post-1991 situation in the
country is paradoxical. By and large, the historical events of the early 1990s were not the
logical conclusion of a protracted and heroic national liberation struggle but rather an
agreement reached between the Ukrainian communist nomenklatura and Ukrainian
nationalists. Against the background of the beginning of the USSR’s collapse, the
communist apparatchiks in Kiev realised that the only way to remain in power was to get
rid of the power of Moscow, retaining full political and economic control on the basis of
a new legitimization, i.e. fight for independence.
36. This allowed the well-known Ukrainian journalist Aleksandr Krivenko to characterise the
new national elite of post-Soviet Ukraine as ‘a product (fusion) of communists and
nationalists.’22 The conglomerate nature of the post-Soviet Ukrainian elite has kept the
country's political system running for years. It was a consequence of maintaining a
complex balance of interests between different political, financial and economic groups,
with none of them gaining complete dominance. It is a rhetorical question, whether it had
anything to do with the declared principles of ‘unity in diversity’. Rather, it was the
20 Bakanov A. I. ‘NO KATSAP, NO KIKE, NO LYAKH’. THE NATIONAL QUESTION IN THE IDEOLOGY OF THE
ORGANIZATION OF UKRAINIAN NATIONALISTS. Moscow: Algorithm. 2014. 535 p.
21 The list is verified by books: ‘HEROES OF THE SOVIET UNION: SHORT BIOGRAPHICAL DICTIONARY / I. N.
Shkadov. - Moscow: Voenizdat, 1987.
22 Quoted from Bondarenko K. Yevhen ‘KUSHNAREV AND THE END OF UKRAINIAN CLASSICAL POLITICS’.
//http://www.vecherniy kharkov.ua/printnews/48355
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preservation of the multiple forms and ways of life inherited from the Ukrainian SSR and
pre-revolutionary times. And the attempts of Ukrainian politicians to homogenise the
identity space by prioritising the ‘escape from Russia’ contributed to the internal crises
that erupted during the Orange Revolution, the Second Maidan and the Russian Spring.
37. P.R. Magocsi speaks about the ‘unification’ of the ‘Ukrainian civic nation’ during the
events of 2014-2022. ‘The newest war with Russia (February 2022) has shown how
strong and widely shared the Ukrainian identity, whether ethnic or civic, has become,’ he
concludes. Magocsi is not alone in this; representatives of the Western expert community
consider the Russian factor to have ‘consolidated’ Ukrainian society.23 This assessment
does not take into account that, first of all, the Ukrainian national project has significantly
changed since February 2014. After the collapse of the Soviet Union, it represented a
compromise between a modification of the Ukrainian SSR and the nationalism nurtured
among intellectuals in the western part of the country and in the diaspora with an outside
influence. After the 'second Maidan', the national project began to develop as a 'sanation',
i.e. a serious 'clean-up' of those forces that proved unprepared for the new post-Maidan
status quo.24 Secondly, while Western authors consider Crimea and Donbas the territories
of Ukraine, the homogenisation of the ‘civic Ukrainian nation’ has been achieved through
the withdrawal of residents of the peninsula and significant parts of the Donetsk, Lugansk,
Zaporozhye and Kherson Oblasts. Western authors may not agree with their motivation,
but it is clear that these people do not want to participate in the ‘renewed’ Ukrainian
project after the two Maidans. Thirdly, according to the UN, as of the end of February,
2023 the number of refugees from Ukraine was more than 8 million, with 2.8 million
people moving to Russia, more than in any of the European Union countries.25
23 Motyl A. IS LOSING CRIMEA A LOSS? WHAT RUSSIA CAN EXPECT IN UKRAINE'S RUST BELT //Foreign
Affairs.2014, March 10 // https://www foreignaffairs.com/articles/russian-federation/2014-03-10/losing-crimealoss
Francis Fukuyama on Ukraine, liberalism and identity politics // https://www.spectator.co.uk/article/francisfukuyama-
on-liberalism-ukraine-and-identity-politics/
24 Gushchin A.V., Markedonov S.M., Tsibulina A.N. THE UKRAINIAN CHALLENGE FOR RUSSIA. Moscow,
Spetskniga, 2015. 48 p.
25 Ukraine refugee situation // https://data.unhcr.org/en/situations/ukraine.
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VI. EXPERT DECLARATION
38. I confirm that all the matters in respect of which I have stated my opinion are within my
area of expertise and competence.
39. I understand that it is my duty to assist the ICJ in deciding the issues in respect of which
this Report has been prepared. I have complied with, and will continue to comply with,
that duty.
40. I confirm that the conclusions I have reached in this Report are unbiased, objective and
impartial; they have not been influenced by the pressures of the proceedings or by any of
the parties to the proceedings.
Expert
Sergey Miroslavovich Markedonov
Moscow, 8 March 2023

Annex 22
Witness Statement of Alexei Gayarovich Zhafyarov, 28 February 2023
(translation)

Annex 22
INTERNATIONAL COURT OF JUSTICE
APPLICATION OF THE INTERNATIONAL CONVENTION
FOR THE SUPPRESSION OF THE FINANCING OF TERRORISM AND
INTERNATIONAL CONVENTION ON THE ELIMINATION OF
ALL FORMS OF RACIAL DISCRIMINATION
(UKRAINE V. RUSSIAN FEDERATION)
WITNESS STATEMENT
OF ALEXEY GAYAROVICH ZHAFYAROV
28 FEBRUARY 2023
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1. I, Alexei Gayarovich Zhafyarov, submit this witness statement in relation to the issues of
countering extremism in the Russian Federation that were raised in Ukraine’s Reply to
the Counter-Memorial of the Russian Federation in the proceedings before the
International Court of Justice.
2. Since 2006, I have been deputy head of the department for supervising the
implementation of the law on federal security, inter-ethnic relations and combating
extremism and terrorism of the Prosecutor General’s Office of the Russian Federation.
Before 2006, I held various positions in the bodies of the Ministry of Justice of the
Russian Federation and the Judicial Department of the Supreme Court of the Russian
Federation. For most of my career I have dealt with issues directly related to countering
extremist organisations.
A. LAWS ON EXTREMISM
3. In the Russian Federation, Federal Law No. 114-FZ “On Countering Extremist Activity”
dated 25 July 2002 (hereinafter the “Law No. 114-FZ”) has been in force since 2002. I
was not among the drafters of the original text of the aforementioned law, but I am very
well familiar with the practice of its application since 2002 and actively participated in
the formation of this law enforcement practice by the Prosecutor General’s Office of the
Russian Federation.
4. Law No. 114-FZ is a framework law: its provisions are further developed through the
application of other legislative acts, including the Code of Administrative Offences of the
Russian Federation (hereinafter the “CAO”) and the Criminal Code of the Russian
Federation (hereinafter the “Criminal Code”). Most of the measures taken by the state
authorities to implement this law are prophylactic and preventive. They are primarily
aimed at eliminating the causes and conditions leading to manifestation of extremism. I
consider the preventive measures of extremism legislation in more detail below.
5. Direct prosecution of those involved in extremism is not regulated by Law No. 114-FZ
but by criminal legislation, whose provisions have been substantially relaxed by the
legislator since 2002. For example, criminal prosecution for incitement to extremism is
currently only permissible where softer preventive measures fail to produce the desired
effect, for instance, when violence, threats of violence or the offender is a repeater.
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6. Since the beginning of the application of the Law No. 114-FZ, it was primarily members
of neo-Nazi and radical nationalist movements, including radical Russian nationalists,
and members of radical pseudo-religious organisations who were held criminally liable
for extremism. Criminal proceedings were generally brought under article 282 of the
Russian Criminal Code (Incitement of Hatred or Enmity). In the early years of the
application of the Law No. 114-FZ, a number of Russian nationalist organisations were
declared extremist, such as the Religious group Krasnodar Orthodox Slavic Community
“VEK RA” (Vedic Culture of Russian Aryans) of the Scythian Vesi Russeniya”, Ryazan
city non-governmental patriotic organisation “Russian National Unity”, International
Public Association “National Socialist Society”, Primorye Region Human Rights Non-
Governmental Organisation “Union of Slavs”, “Interregional Social Movement “Slavic
Union”, Interregional Public Association “Spiritual and Patrimonial Power of Rus” and
others.
7. Thanks to the effective work of law enforcement agencies, the number of crimes covered
by this article has decreased substantially. As I pointed out above, in 2018 article 282 of
the Criminal Code were partially decriminalized: actions aimed at inciting hatred or
enmity, as well as at disparagement of a person or group of persons on the grounds of
gender, race, nationality, language, origin, attitude towards religion or membership of any
social group, committed in public, are now by default an administrative offence under
Article 20.3.1 of the CAO. Criminal prosecution for such an act under Article 282 of the
Criminal Code remains possible only in the presence of aggravating circumstances:
(a) if the offender has already been held administratively liable for incitement to
extremism but then reoffends within a year thereafter;
(b) if the acts involved the use or threat of violence; or
(c) if the acts were committed through abuse of official position or by an organized
group.
B. THE YEAR 2013 CHANGES
8. In December 2013, Article 280.1 was added to the Criminal Code, which prohibited calls
for violation of the territorial integrity of the Russian Federation. I was involved in the
drafting of this article and I know the purpose of this provision: it was combating acts
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aimed at infringing on the territorial integrity of the Russian Federation. This article could
in no way be related to Crimea in 2013.
9. The law introducing Article 280.1 into the Russian Criminal Code was adopted in an
expedited manner because of a sudden and serious threat to the security of the Russian
state. In 2013, separatist groups that advocate the violation of the territorial integrity of
the Russian Federation began to appear en masse on various internet sites, mainly on
social networks.
10. The most prominent were the so-called social movements:
(a) “Free Idel-Ural”, whose members had a mission that consisted in unlawful seizure
of the territories of the Republics of Tatarstan, Udmurtia, Bashkortostan, Mari-El,
Chuvashia and Mordovia from the Russian Federation;
(b) “Crimson Wedge – Independent Kuban”, whose members had a mission that
consisted in unlawful seizure of the territories of Krasnodar Krai, Rostov Oblast,
Adygea, Stavropol Krai and Karachay-Cherkessia from the Russian Federation and
who were hiding their intentions behind discussions regarding the creation of a
certain “Kuban People’s Republic”;
(c) “March for the Federalisation of Siberia” whose participants sought to illegally
alienate a number of Siberian regions from the Russian Federation, disguising their
illegal activities by organising supposedly peaceful rallies and marches in Siberian
cities; and
(d) “Stop Feeding Moscow” movement, whose participants sought to illegally alienate
a number of regions of the Urals and Siberia from the Russian Federation, under
the guise of pseudo-socialist slogans.
11. These movements were coordinated via relevant Internet portals and communities in
social networks by a small group of activists who had previously left the territory of the
Russian Federation and may have been recruited by special services of foreign states
interested in destabilising the situation in the Russian Federation.
12. The emergence of these groups, whose activities posed a serious threat to the public order
and security, as well as the territorial integrity of the Russian Federation, required urgent
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amendments to the laws on extremism. Given the absence of an article in the Criminal
Code that would directly prohibit calls for violation of the territorial integrity of the
Russian Federation, the General Prosecutor’s Office of the Russian Federation did not
have the necessary authority to prohibit the dissemination of information about these
groups on the Internet, including ordering the owners of web resources and social
networks to remove the relevant information, or ordering telecommunications operators
to restrict access to the relevant web pages. This was a real threat to the territorial integrity
of the Russian Federation and required the adoption of measures, including preventive
ones. In other words, Article 280.1 of the Criminal Code was necessary to counter
extremist activities and block access to the relevant web sites and groups in social
networks, which pose a significant threat to the public order and the security of the
Russian Federation.
13. In practical terms, the criminalisation of calls for violation of the territorial integrity has
yielded positive results to the Russian Federation. In the early years of the rule
application, the General Prosecutor’s Office of the Russian Federation successfully
managed to remove several thousand links to web resources per year. Currently, the
number of links that are removed every year is much lower.
14. The law enforcement practice of the Prosecutor General’s Office of the Russian
Federation in the area of blocking Internet resources is organised in full accordance with
the requirements of the Constitutional Court of the Russian Federation, in particular that
any measures of state coercion must:
(a) on the one hand, differentiate legal responsibility according to the gravity of the act,
the amount and nature of the damage caused, the degree of culpability of the
offender and the nature and degree of public danger of the offences;
(b) on the other hand, have a reasonable deterrent effect necessary to ensure compliance
with the precepts protected by administrative tort law.
15. For example, if calls to violate the territorial integrity of the Russian Federation were
contained only on one page of an Internet resource, the Prosecutor General’s Office of
the Russian Federation demanded that access to that particular page, and not to the entire
Internet resource, be blocked.
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16. Thanks to the preventive and proactive measures taken, extremist movements whose
activities were aimed at violating the territorial integrity of the Russian Federation have
been prevented from gaining popularity in the Russian segment of the Internet: the
blocking has prevented search for like-minded individuals for these movements, cut off
communications and stopped the spread of the movements in the Russian media space
and prevented the transformation of such groups into organisations with an established
hierarchy.
17. The adoption of this amendment, as well as the systematic combating of extremist
activities, has significantly reduced the number of people involved in extremist activities.
This is clearly demonstrated by official statistics. According to statistics from the
Prosecutor General’s Office of the Russian Federation, by 2015, the law enforcement
agencies managed to stop the “explosive” growth (25% per year) in the number of those
who committed extremism crimes in the Russian Federation:
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* Number of persons who committed extremism crimes
Moreover, official statistics show that even after the reunification of Crimea with the
Russian Federation, there has not been a significant increase in extremist crimes.
18. With regard to the criminal prosecution, the number of prosecutions initiated and brought
to trial under Article 280.1 of the Criminal Code was rather low. From 2013 to 2022, only
121 crimes under Article 280.1 of the Criminal Code were registered, while in 2021 and
2022 there were none.
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C. PREVENTIVE MEASURES
19. In terms of the correlation between prevention measures and criminal prosecution
measures, Russia’s model of countering extremist activity differs from the American one.
This model to which the Russian Federation adheres focuses on both prevention and
suppression of the spread of radical ideas. This helps prevent the transition from nonviolent
forms of extremism to violent ones and reduces the need for criminal measures.
20. For example, the Russian law on extremism grants the bodies of the General Prosecutor’s
Office of the Russian Federation the power to issue the following to non-governmental
and religious organisations:
(a) warnings not to engage in extremist activities, if there is information about unlawful
acts being prepared; and
(b) a written warning on the discovery of facts demonstrating that the organisation’s
activities show signs of extremism.
21. These preventive measures are much less severe than the instantaneous ban of the
organisation concerned and do not involve criminal prosecution of its members and
leaders. Subsequent measures are only taken if the organisation fails to comply with the
warning or commits other acts showing signs of extremism within one year from the date
of receipt of the warning. Accordingly, such measures are aimed at preventing the
commission of extremist offences.
22. Furthermore, issuing a warning or commits balances the interests of the society as a whole
and those of the specific organisation, as bona fide organisations are granted the
opportunity to bring their activities into line with the laws on extremism and to appeal the
warning or commits in court in order to ensure an independent and transparent check of
the reasonableness of them. Thus, the lawfulness and validity of warnings and commits
issued by officials of the Procurator-General’s Office of the Russian Federation and the
procurator’s offices of the entities of the Russian Federation may be reviewed by courts
of several instances: in the trial court, in the court of appeal, in the court of cassation and
in the Supreme Court of the Russian Federation under the supervisory procedure.
23. Given that an appeal can be lodged, the General Prosecutor’s Office of the Russian
Federation carefully reviews all the evidence before issuing a warning or commits in each
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particular case and ensures strict compliance with the procedural rules in their issuing.
The addressees of warnings and commits on the impermissibility of extremist activity
have the possibility of appealing against them in court.
D. PROHIBITION OF AZOV REGIMENT
24. As a recent example of the fight against extremism in the Russian Federation, I can cite
the prohibition of the Ukrainian paramilitary nationalist association Azov, also known as
“Azov Battalion” or “Azov Regiment”.
25. Azov association was established in May 2014 by members of various radical groups who
held radical far-right and neo-Nazi views. The ideology of this association was based on
Nazi ideology prohibited by judgments of the International Military Tribunal in
Nuremberg. In particular, members of Azov used Nazi paraphernalia and symbols,
including swastika tattoos, chevrons similar to the German Wolfsangel, and the books
Mein Kampf:
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26. In addition, members of the Azov association have publicly expressed racist slogans, held
anti-Russian marches, including with torches similar to Nazi marches in the Third Reich
and modern neo-Nazi events, and committed other actions aimed at inciting hatred against
the Russian and Russian-speaking population of Donbas.
27. For example, on 22 October 2015 and on 20 October 2015, Azov fighters held processions
and ceremonies that looked similar to the “roll call of the dead” or “last roll call”
ceremonies held by members of the Nazi Party on the Memorial Day of the Fallen Heroes
of the Nazi Party in Germany (on the day the “beer putsch” began – 08 November 1923).
The number of participants in these marches was over a thousand and five thousand
fighters respectively. In particular, during the first procession, the fighters of Azov lined
up on the football field and then moved with torches, flags and symbols of Azov, finishing
the procession in front of the regiment’s base, where a memorial sign to the dead Azov
soldiers in the form of a mound with three swords stuck in it was erected. Then in front
of it were lined up 33 Azov fighters, symbolising the 33 dead, with shields on which the
call sign of the dead was written in runic script, and after his name was called, the fighter
raised his shield and said “In formation!”.
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28. During its marches, rallies and concerts, Azov unashamedly replicated the vocabulary,
symbols and rituals of the Third Reich, broadcasting videos of German stormtroopers
diving, firing tanks decorated with runes and German crosses, videos of SS marches
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including fighters from their eastern units, alternating with images of wolves and
werewolves. Participants in such actions often displayed Nazi salutes with their right
hands raised. There are obvious similarities between this symbolism and rituals of the
Azov regiment and those of the contemporary neo-Nazi movements:
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29. Finally, Azov members have staged fights and pogroms against fans with a black skin,
Communist party supporters and the pro-Russian population of Ukraine. It is not
uncommon for them to post video recordings of their actions. For example, Azov activists
are known to have been involved in the 20 October 2015 beating of two fans with a black
skin who entered the stands of the Dynamo stadium in Kyiv during a match between FC
Dynamo (Kiev) and Chelsea. On 17 March 2016, members of the Azov Civil Corps
attacked a picket of the Progressive Socialist Party of Ukraine in central Kiev, whose
participants were mostly elderly people.
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30. Instead of suppressing the activities of Azov association, the Ukrainian law-enforcement
authorities and security agencies supported it and turned it into a paramilitary unit by
incorporating the Azov Regiment into the Ukrainian National Guard and providing it with
military equipment and heavy weaponry for use against the population of Donbas. Highranking
Ukrainian law enforcement officials spoke flatteringly of Azov: in particular, the
head of the Department for Combating Drug Crimes of the National Police of Ukraine,
Ilya Kiva, called it “a fighting regiment for the purity of the Ukrainian nation”.
31. During combat activity since 2014 by the armed forces of the Kiev regime against
residents of south-eastern Ukraine, fighters of the Azov Regiment committed mass crimes
against the Russian-speaking population, persecuting them on the basis of their language.
The commission of such crimes by the Azov Regiment continues, unfortunately, to this
day. Thus, the General Prosecutor’s Office of the Russian Federation has documented
numerous instances where civilians were held hostage and used as human shields.
32. In addition, Azov leaders attempted to commit terrorist acts in Crimea and organised
attacks at governmental and religious institutions of the Republic of Crimea.
33. In 2016, one of Azov’s leaders, Andriy Biletsky, formed the political party National
Corps for the direct participation of the Azov association in Ukraine’s popularly elected
bodies. Leaders of the National Corps party organise and carry out recruitment of
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individual Azov regiment battalions across Ukraine (e.g. Azov-Prykarpattya and Azov-
Poltava), as well as public rallies of nationalists taking the “oath”.
34. In addition, Azov has attempted to recruit Russian citizens in the Russian Federation to
join its ranks for combat operations in the Donbass. For this purpose, Azov activists
organized an extremist group “Mizanthropik Division” in the Internet messenger
“Telegram”, which sanctified actions in support of the Azov regiment and organized the
posting of flyers and banners in the Russian Federation. In August 2022, the Supreme
Court of the Russian Federation examined an application of the General Prosecutor’s
Office of the Russian Federation and the facts referred to above and on their basis declared
the organisation a terrorist organisation and prohibited its activity on the territory of the
Russian Federation.1
E. NO RACIAL DISCRIMINATION IN THE FIGHT AGAINST EXTREMISM
35. As part of my work at the General Prosecutor’s Office of the Russian Federation, I have
been involved in international cooperation on countering extremism. Specifically, I was
a member of the Russian Federation delegations at meetings of the Organisation for
Security and Cooperation in Europe. At no such platform for international cooperation
has the issue ever been raised that the Russian model for countering extremism is
allegedly discriminatory in general or with regard to any ethnic or national group or
otherwise violates the prohibition of racial discrimination imposed by the Convention on
the Elimination of All Forms of Racial Discrimination. I am not aware of any instances
1 Supreme Court of the Russian Federation, Decision, No. AKPI22-411S, 2 August 2022.
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in which the Russian practice of combatting extremism has been criticized internationally
as discriminatory, including in relation to Ukrainians or Crimean Tatars living on the
territory of the peninsula of Crimea.
36. One of the key objectives of Russian legislation on extremism is the prevention of social,
racial, national or religious discord. Any possible restrictions on rights, including the right
to freedom of movement or freedom of expression under Law No. 114-FZ are aimed at
ensuring national security of the Russian Federation and preventing manifestations of,
inter alia, racial or other discrimination. Accordingly, it would be highly incorrect to view
the anti-extremist restrictions in Law No. 114-FZ as violating the prohibition of racial
discrimination.
37. The Constitutional Court of the Russian Federation has repeatedly pointed out that Law
No. 114-FZ complies with the Constitution of the Russian Federation and the standards
for the protection of human and civil rights and freedoms as its application takes into
account the rights and freedoms guaranteed by international legal acts:
(a) The need to legally restrict freedom of expression, assembly and association for the
purpose of countering extremism is also highlighted in the Parliamentary Assembly
of the Council of Europe Resolution 1344 (2003) on “Threats to Democracy by
Extremist Parties and Movements in Europe”, stressing that, regardless of its nature,
extremism is a form of political activity which denies, explicitly or implicitly, the
principles of parliamentary democracy and is based on ideologies and practices of
intolerance, exclusion, xenophobia, anti-Semitism and ultra-nationalism (para 3),
and the tendency of some extremist movements to find justification for their actions
in religion carries a double danger: on the one hand, it fosters intolerance, religious
fanaticism and fundamentalism and, on the other hand, leads to the isolation of
entire religious communities because of individuals who abuse the universal values
of religion (Ruling of the Constitutional Court of the Russian Federation dated 2
July 2013 No. 1053-O).
(b) If a citizen, while exercising his constitutional rights and freedoms (including
freedom of thought and speech, freedom of creativity, the right to hold and
disseminate beliefs and to act in accordance with them), violates the rights and
freedoms of others and such violation (whether directed against specific individuals
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or against public order in general) is socially dangerous and unlawful, the offender
may be held liable under public law (including criminal law), which aims to protect
public interests (Ruling of the Constitutional Court of the Russian Federation dated
27 October 2015 No. 2450-O).
(c) Court-ordered confiscation of information materials deemed extremist by a
prosecutor is not linked to liability, is not a sanction (punishment) for the offence,
but is essentially a special measure of state counteraction to extremism aimed at
preventing extremist activity, including by identifying and subsequently
eliminating the causes and conditions that contribute to it (Ruling of the
Constitutional Court of the Russian Federation dated 02 July 2013 No. 1053-O).
(d) Extremist activities, being addressed to the mass consciousness or the attention of
certain segments of society, segmented by religious, ethnic and other
characteristics, and aimed at forming an environment of acceptability of terrorist
ideology and even desirability of its implementation in public practice, also create
a need for adequate and effective measures of preventive nature (Ruling of the
Constitutional Court of the Russian Federation dated 21 September 2017 No. 1797-
O).
38. Although the Committee on the Elimination of Racial Discrimination (hereinafter the
“Committee”) expressed general concern that the provisions of the Law No. 114-FZ were,
in their view, broad and can potentially be used randomly, this comment was hypothetical
and the Committee did not state that the law was applied in such way, nor did the
Committee mention that the law in question has ever been applied against any ethnic
groups or national minorities.
39. In my view, the Committee expressed only general concern, as it was not aware the direct
implementation of Law No. 114-FZ in practice, with a focus primarily at prevention while
the sanctions for breaches of the law are primarily administrative in nature (e.g. a fine)
without the imposition of criminal liability. Furthermore, the Committee had probably
not been informed that the wording of the Law No. 114-FZ it analysed is subsequently
made more specific in other laws, including the CAO and the Criminal Code and in law
enforcement practice, which precludes broad and the more so arbitrary interpretation of
the law.
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40. Thus, between 2016 and 2018, the Plenum of the Supreme Court of the Russian
Federation provided a number of clarifications on the practice of application of the
legislation on extremism, which further specified its wording and its correlation with
human and civil rights and freedoms:
(a) Considering criminal cases on extremism-related crimes, courts shall take into
account the rights and freedoms guaranteed by the Constitution of the Russian
Federation and international legal acts, such as freedom of conscience and religion,
freedom of thought, speech and mass information, the right to freely seek, receive,
transmit, produce and disseminate information by any lawful means, the right to
assemble peacefully, without weapons, to hold meetings, rallies and
demonstrations, marches and pickets (para. 1 of the Resolution of the Plenum of the
Supreme Court of the Russian Federation dated 28 June 2011 No. 11 as amended
by the Resolution dated 20 September 2018 No. 32).
(b) The said rights and freedoms may only be restricted in exceptional cases expressly
set out in federal law to the extent necessary in a democratic society in order to
protect the foundations of the constitutional order, morality, health, rights and
lawful interests of other persons, to ensure the country’s defence and security,
public order and territorial integrity (para. 1 of the Resolution of the Plenum of the
Supreme Court of the Russian Federation dated 28 June 2011 No. 11, as amended
by the Resolution dated 20 September 2018 No. 32).
(c) Courts must proceed from the nature and degree of public danger of the act and take
into account that an act, although formally containing elements of a criminal
offence, does not constitute a crime, but does not pose a public danger due to its
insignificance, for example, taking into account the size and composition of the
audience, the number of views and the influence of extremist information on the
behaviour of the persons comprising that audience (para. 8.1 of the Resolution of
the Plenum of the Supreme Court of the Russian Federation dated 28 June 2011 No.
11, as amended by the Resolution dated 20 September 2018 No. 32).
(d) Courts must ensure that sentences imposed on persons found guilty of extremist
offences are individualised, for example, by ascertaining and taking into account
the conditions of the minor’s life and upbringing, the level of mental development,
Annex 22
Page 21 out of 22
other personal characteristics, and the influence of older persons on the minor (para.
24 of the Resolution of the Plenum of the Supreme Court of the Russian Federation
dated 28 June 2011 No. 11).
41. The Russian laws on extremism are applied uniformly on the territory of all constituent
entities of the Russian Federation. They began to take shape long before the reunification
of Crimea with Russia in 2014 and continue to be developed now, having a delayed
positive effect in guaranteeing a stable rule of law and development of justice. That said,
after the reunification of Crimea with the Russian Federation, the organisations who were
operating in the territory of Crimea were even provided with more favourable conditions
compared to organisations operating in other Russian regions, to ensure their smooth
transition to the legal framework of the Russian Federation.
42. One significant extremist threat in Crimea came from Hizb ut-Tahrir and Tablighi Jamaat
organisations, which are banned in a number of states but have not been banned in
Ukraine. For example, Hizb ut-Tahrir is banned in Bangladesh, Germany, Indonesia and
a number of Arab states. The ideological basis of these organisations is radical pseudoreligious
ideas falsely presented as branches in Islam. These organisations are, in turn,
breeding grounds for recruiters of terrorist organisations, including ISIS which is a
terrorist organisation banned in the Russian Federation. As the majority of Crimean
Tatars in Crimea are Muslims, measures to combat such organisations may legitimately
affect the Crimean Tatars who, along with other persons, profess Islam and are members
of such organisations.
43. However, given that these organizations were not banned when Crimea was part of
Ukraine, after the accession of the peninsula to the Russian Federation, members of these
organizations living in Crimea were not prosecuted for participation in the activities of
an extremist organization for a long time. They were given a year to voluntarily renounce
participation in the banned organizations. There was also a moratorium on the seizure of
extremist materials by law enforcement agencies in Crimea, so that their owners could
voluntarily surrender the banned literature and avoid prosecution.
44. As for the Mejlis, which is banned in the Russian Federation, they, as stated in the
Appellate Ruling of the Supreme Court of the Russian Federation dated 29 September
2016, were declared an extremist organisation in view of the fact that they organised and
Annex 22
Page 22 out of 22
performed acts of violence to block the operation of the border control post on 03 May
2014 and were carrying out the blockade of Crimea, which resulted in power supply and
communication equipment disconnection on the peninsula. Despite this, the Russian law
enforcement authorities have not yet initiated any criminal proceedings on the grounds of
membership of the said organisation.
F. CONCLUSION
45. Thus, it can be concluded that Russian laws on extremism do not discriminate against any
ethnic or national group and do not allow for excessive or arbitrary criminal prosecution;
they provide primarily preventive and proactive measures and are driven exclusively by
the fight of the State against radical manifestations of extremism, such as terrorist
activities of the Azov organisation.
46. I hereby certify that to the best of my knowledge and belief the information set out in this
witness statement is correct.
Witness
Alexey Gayarovich Zhafyarov
Moscow, 28 February 2023
Annex 23
Second Witness Statement of , 7 March 2023
(translation)

Annex 23
INTERNATIONAL COURT OF JUSTICE
APPLICATION OF THE INTERNATIONAL CONVENTION
FOR THE SUPPRESSION OF THE FINANCING OF TERRORISM AND
INTERNATIONAL CONVENTION ON THE ELIMINATION OF
ALL FORMS OF RACIAL DISCRIMINATION
(UKRAINE V. RUSSIAN FEDERATION)
SECOND WITNESS STATEMENT
OF
7 MARCH 2023
Annex 23
Page 2 out of 9
Annex 23
Page 3 out of 9
A. INTRODUCTION
1. I, , have previously given witness statement in the
proceedings initiated by Ukraine before the International Court of Justice (hereinafter,
“First Witness Statement”). I covered in them, among others, the following topics:
(a) The process of listing the Khan’s Palace as a UNESCO World Heritage Site;
(b) The state of the Khan's Palace, which required urgent restoration work;
(c) Progress of repair and restoration works at the Khan’s Palace.
2. I have familiarized myself with the content of the Ukraine Reply to the Counter-Memorial
of the Russian Federation (hereinafter, “Reply”). I believe that Ukraine has not presented
any arguments or evidence that would refute my witness statement. Moreover, Ukraine
has simply ignored a significant number of the facts I mentioned, and with regard to the
rest it makes unsubstantiated or contradictory allegations.
3. I have prepared a new witness statement (hereinafter, “Second Witness Statement”) in
order to give detailed comments on Ukraine's arguments.
B. INTERACTION WITH UNESCO
4. Ukraine claims that UNESCO representatives are allegedly unable to enter the territory
of the Khan’s Palace ensemble.1
5. I have read excerpts from the UNESCO document2 to which Ukraine refers as supporting
the above argument, and must note that the information about the inability to enter Crimea
relates to the activities of another organization, namely the UN Human Rights Monitoring
Mission in Ukraine,3 but not UNESCO.
6. Therefore, my explanation that the Bakhchisaray Historic, Cultural and Archeological
Museum and Reserve (hereinafter, “Museum-Reserve”) does not restrict UNESCO
1 Reply, ¶648.
2 Implementation of decisions and resolutions adopted by the Executive Board and the General Conference at
previous sessions thereof, Doc. No. 207 EX/5.I.C (13 September 2019). Ukraine refers to this document in ¶648
of the Reply.
3 See Ibid., ¶21.
Annex 23
Page 4 out of 9
representatives’ access to the Khan’s Palace4 has not been refuted. On the contrary, as I
pointed out in my First Witness Statement, not only do we not prevent UNESCO
representatives from visiting the Khan’s Palace, but we would be happy to see them and
continue our cooperation5.
C. STATUS OF RESTORATION WORKS AT THE KHAN’S PALACE FACILITIES BEFORE 2014
7. Ukraine’s claims that there were active restoration works going on in the Khan’s Palace
before 2014 are quite unsubstantiated. Ukraine has not commented in any way on the
documents I quoted indicating the unsatisfactory condition of the Khan’s Mosque in
1989, 2003, 2010, and 2013.6 I managed to find only a reference to the letter of the
national (Ukrainian) coordinator of the International Centre for the Study of the
Preservation and Restoration of Cultural Property (hereinafter, “National Coordinator
Letter”).7 According to Ukraine, he allegedly studied the materials of scientific research
of the Khan’s Palace for 1960, 1962, 1965, 1987, 1988, 1994 “and subsequent years”,
prepared by the UkrNIIproyektrestavratsia Institute, as well as a large number of
photographs and description of works in progress 8 (here I must note that I do not
understand how it conforms with the statement of Ukraine that it is denied the opportunity
to obtain detailed information about the progress of such works).9
8. From the contents of the letter, which draws general conclusions regarding the “high level
of decisions taken” on the conservation, restoration and rehabilitation of historic building
elements, it is not possible to ascertain what specific work was carried out, in what year,
or on what grounds. Even the aforementioned scientific research materials are not
attached to either the letter or the Reply, so I cannot comment on them substantively.
However, I find it difficult to imagine what kind of high level we are talking about here.
For example, the author points out that he got acquainted with the research performed by
4 First Witness Statement, ¶14.
5 Crimean Newswire, Crimean Ministry of Culture Invites UNESCO Experts to Personally Assess Cultural
Development on Peninsula (18 September 2017), available at: https://crimeanews.
com/culture/2017/09/18/324396 html (Exhibit A).
6 See First Witness Statement, ¶¶21-26.
7 Letter of the National Coordinator of the ICCROM in Ukraine No.12 (27 April 2018). Annex 1030 to the
Memorial.
8 Ibid.
9 Reply, ¶648
Annex 23
Page 5 out of 9
UkrNIIproyektrestavratsia in 1988. However, documents prepared by the same
organisation in the following, 1989, year, clearly indicate the poor condition in which the
mosque found itself then: they observed roof beam deflection, rotten lining, systematic
wetting of wooden structures of the east façade, etc.10
9. Claims of “active work” by UkrNIIproyektrestavratsia on the Khan’s Palace are in turn
supported only by a link to an internet resource that repeats the arguments of Ukraine
(with the content of which I strongly disagree), but provides no real evidence
whatsoever.11
10. Accordingly, the claims of a “high level of decision-making” regarding the restoration
and preservation of the Khan’s Mosque in the pre-2014 period appear unsubstantiated to
me.
D. PROGRESS OF REPAIR AND RESTORATION WORKS AT THE KHAN’S PALACE FACILITIES
11. Ukraine has made a number of statements regarding the progress of restoration works at
the Khan’s Palace facilities that I would also like to comment on, as I do not consider
them to be corresponding to reality.
12. First, Ukraine claims that only a small part of the beams of the Khan’s Mosque needed to
be replaced.12 I cannot assess this claim due to the fact that, as far as I can see, Ukraine
has been unable to back it up in any way. This is particularly surprising in light of the fact
that, judging by the Letter of the National Coordinator, the documents on the study of the
Khan’s Mosque have not been lost and the National Coordinator himself, as confirmed
by publicly available data,13 was UkrNIIproyektrestavratsia’s director from 1983 to 2010.
13. Second, as I pointed out in the First Witness Statement, the decision to replace the beams
was prompted by their infestation with rot, fungi and insects (which could spread to the
rest of the wooden structures of the Khan’s Mosque) as well as their substantial wear and
10 First Witness Statement, ¶21.
11 Reply, ¶654.
12 Reply, ¶654.
13 Wikipedia, Antoniuk, Anatoly Evdokimovich, available at:
https://ru.wikipedia.org/wiki/Антонюк,_Анатолий_Евдокимович (Exhibit B)
Annex 23
Page 6 out of 9
deterioration in strength.14 That is why it was decided to dismantle the beams, remove the
damaged elements from them and, if possible, use that material in the restoration of other
objects. At present, the beams are stored on the territory of the Salachik historical and
archaeological complex under round-the-clock guard.
14. Third, I am also surprised that Ukraine has ignored the considerations I made in the First
Witness Statement about the primary need to ensure the safety of people. The mosque is
a functioning facility and regularly visited by believers, as well as by Museum-Reserve
employees and tourists. It would be inadmissible to endanger their lives and health.
15. Fourth, as far as I can judge, Ukraine has completely ignored my claim that the original
“Tatarka” roof tiles covering the Khan’s Mosque were completely replaced as early as in
1967. Also, despite the fact that I pointed out in the First Witness Statement that all the
tiles removed from the roof had been transferred to the funds of the Museum-Reserve,
Ukraine claims that they were destroyed.15 This is obviously untrue. They were used in
the reconstruction of other facilities of the Khan’s Palace ensemble: The Sary-Guzel
Bathhouse, The Stable Pavilion, and The Library Pavilion.
16. Fifth, Ukraine claims that the interior of the Khan’s Mosque was damaged due to the lack
of protection from the weather.16 In fact, however, the interior of the Mosque was
protected by a temporary shelter during the works. The only incident of weather-related
wetting was when rain fell inside the mosque through an installation opening made in the
temporary shelter above the central part of the mosque. I described that incident in the
First Witness Statement.17 However, only the floor got soaked, while the inside of the
mosque walls was not affected and waterproof insulation was restored in less than three
days.
17. Sixth, it is worth pointing out separately that Ukraine does not provide any support for
the claim that restoration works are not usually carried out in winter time. As I already
noted in the first witness statement, the works were carried out in accordance with the
agreed schedule. I am not aware of the extent to which it constitutes standard practice in
14 First Witness Statement, ¶¶32-34.
15 Reply, ¶649.
16 Ibid.
17 First Witness Statement, ¶43.
Annex 23
Page 7 out of 9
general; however, I have read news reports that, for example, restoration works of the
Notre Dame Cathedral were due to start in winter time.18
18. Seventh, Ukraine claims that due to the use of improper cleaning technology using high
pressure washing equipment cracks formed on the wall.19 This claim is unsubstantiated.
As far as I know, during the works at the Khan’s Palace only gentle low-pressure water
cleaning methods were used, only fragmentarily at that and only on the Soviet-era plaster
layer whose microcracks had been identified earlier due to partial deformation of the
foundations and walls.
E. OTHER OBSERVATIONS
19. To conclude my Second Witness Statement, I would like to share a few observations.
20. First, I noticed that in the Reply, Ukraine alleges the “destruction” of the Khan’s Palace,
although almost all of its claims refer to the works carried out on the Khan’s Mosque.
However, as I pointed out in my first witness statement, the ensemble of the Khan’s
Palace includes 17 facilities, many of which have been undergoing repair and restoration
works up to this time, including the Stable Pavilion, the Library Pavilion, the Falcon
Tower, the Main Building, the Harem Pavilion, the Khan’s Kitchen, the Gardens and the
Park Structures. The works on the Khan’s Mosque have not been completed either. Some
facilities are awaiting commissioning, works on some more have been completed.
Moreover, as far as I am aware, prior to 2014 in the USSR and Ukraine only isolated
repairs were made to some of facilities at Khan’s Palace, while a full-scale complex
restoration work was only commenced for the first time after reunification of Crimea with
the Russian Federation. Clearly, works of such scale cannot but face some problems, but
by now mechanisms of internal and public control have been implemented that allow to
quickly react to, and resolve issues as they arise.
21. As to internal control over restoration of Khan’s Palace facilities, staff of the Museum-
Reserve daily visually inspect the works sites. At the end of each week of works we
compile a report on completed works where all requests and objections are recorded as
18 See, e.g., RIA Novosti, Paris Completes Reinforcement Work on Fire Damaged Notre-Dame (18 September
2019, updated 19 September 2019), available at: https://ria ru/20210918/sobor-1750674763.html (Exhibit C)
19 Reply, ¶649.

Annex 23
Page 9 out of 9
Witness
[Signature]
Bakhchisaray, 7 March 2023
Annex 23
Annex 23
LIST OF EXHIBITS
Number: Name of exhibit:
Exhibit A Crimean Newswire, Crimean Ministry of Culture Invites UNESCO Experts
to Personally Assess Cultural Development on Peninsula (18 September
2017).
Exhibit B Wikipedia, Antoniuk, Anatoly Evdokimovich.
Exhibit C RIA Novosti, Paris Completes Reinforcement Work on Fire Damaged
Notre-Dame (18 September 2019, updated 19 September 2019).
Exhibit D SBI RC Bakhchisaray Historical, Cultural and Archeological Museum-
Reserve, Letter to the Head of the Republic of Crimea S. Aksyonov.
Exhibit E Tavrida Muftiyat, Khan's Palace Restoration to Be Monitored by Public
Figures (22 March 2022).
Exhibit F National University of Kiev-Mohyla Academy, Dr Kateryna Busol.
Exhibit G Kateryna Busol, Crimea's Occupation Exemplifies the Threat of Attacks on
Cultural Heritage, Chatham House (4 February 2020).

Exhibit A
Crimean Newswire, Crimean Ministry of Culture Invites UNESCO Experts to Personally Assess
Cultural Development on Peninsula (18 September 2017)
(translation)

Annex 23 Exhibit A
Translation
Crimean Newswire, Crimean Ministry of Culture Invites UNESCO Experts to Personally
Assess Cultural Development on Peninsula (18 September 2018), available at:
https://crimea-news.com/culture/2017/09/18/324396.html.
Crimean Newswire
Crimean Ministry of Culture Invites UNESCO Experts to Personally Assess
Cultural Development on Peninsula
18 September 2017 at 05:38 PM
Culture
Simferopol, 18 September. Kryminform. Arina
Novoselskaya, Minister of Culture of Crimea, invited
UNESCO representatives to personally visit the peninsula for
an objective assessment of the state of its cultural and
historical heritage sites. She did so in response to an Ukrainian
report describing the condition of the Crimean cultural sites
presented to UNESCO.
“We are open. If there is such an initiative (for UNESCO representatives to visit Crimea), we
will be happy to open the doors of our museums and nature reserves, to show how much they
have improved, how they have become better off, what salaries museum staff get, and what
additions have been made to museum collections. We will be happy to do so to help them make
an objective decision,” Mrs Novoselskaya said.
Earlier, Ukraine presented a report describing the condition of the cultural heritage sites in
Crimea for the first half of 2017 at a session of the UNESCO Executive Board. The report says
it was prepared on the basis of materials obtained “from human rights defenders and other
reliable sources” who were not disclosed. However, it is obvious that the authors of the report
have no idea about the current state of cultural and historical heritage sites in Crimea.
In particular, the Ukrainian side complains about some “illegal” geological work near the
Swallow’s Nest, about the renovation of the Bakhchysarai Palace, archaeological excavations
at the construction sites of the Tavrida highway and the access roads to the Crimean Bridge.
“I think our colleagues need to come and see just how much our sites have improved. The rock
base of the Swallow’s Nest had to be reinforced because it could have collapsed being
threatened by water and storm winds. The Bakhchysarai Palace, one of the major UNESCO
sites in the Republic of Crimea, is also being renovated and becoming more and more beautiful
as we speak. Preventive maintenance work on the famous Divan Hall is near completion,” Mrs
Novoselskaya said.
A major complaint of the Ukrainian side was that the repair and renovation work takes place
without their consent. “I worked in the cultural governance system under the Ukrainian rule, so
I can tell you what Ukraine did,” said Mrs Novoselskaya. “No funding at all was provided for
the Vorontsov, Livadia, Massandra palaces, the Swallow’s Nest, and Chekhov’s Dacha.
Annex 23 Exhibit A
Administrations of the Palaces barely made ends meet to pay their staff a meagre salary. What
kind of renovation, or collection enlargement, or facility improvement could we talk about
then? They were simply stricken off from the budget of the Republic! This is a good example
of how Crimean cultural heritage sites were treated during the Ukrainian time”.
According to the Minister, the citizens of Ukraine have not been banned from accessing cultural
heritage sites in Crimea and they do visit them while spending their vacations there.
Exhibit B
Wikipedia, Antoniuk, Anatoly Evdokimovich
(translation)

Annex 23 Exhibit B
▪ in Moscow – the Cultural Centre of Ukraine;
▪ in Sevastopol – St. Vladimir’s Cathedral, etc.
From 1983 to 2010, Mr. Antonyuk was the Director of UkrNIIproektrestavratsiya Design
Institute under the State Committee on Construction of Ukraine.
In 1992, Mr. Antonyuk was an adviser to the Director General of the International Centre for
the Study of the Preservation and Restoration of Cultural Property at UNESCO (Rome).
Since 2013, Mr. Antonyuk has been working at the National Kyiv-Pechersk Historical and
Cultural Reserve.
Since 2016, Mr. Antonyuk has been the National Coordinator of the ICCROM of Ukraine
(International Centre for Study of the Preservation and Restoration of Cultural Property)
He has 55 printed works and four copyright certificates for inventions.
Selected publications:
▪ Enclosing Structures in Rural Civil Buildings. The Construction & Architecture
magazine, 1976, #6;
▪ Engineering Analysis as the Basis of Reconstruction. The Construction & Architecture
magazine, 1987, #10;
▪ Site Tests of Micropile Foundations in Weak Soils at Architectural Monument
Restoration Projects. The Budivelnyk magazine, 1988, #21;
▪ Collapsible Soil Resistance for Micropile Design. The Bases and Foundations
interdepartmental collection of works, 1990, #23.
Awards:
▪ Order of Merit (Ukraine), I degree
▪ Order of Merit (Ukraine), II degree
▪ Order of Merit (Ukraine), III degree
▪ State Prize of Ukraine in Architecture (1999)
▪ Honoured Construction Worker of Ukraine.
Links:
■ Anatoly Evdokimovich Antonyuk http://esu.com.ua/search_articles.php?id=43022
ARCHIVE COPY:
https://web.archive.org/web/20161018212125/http://esu.com.ua/search_articles.php7id
=43022 dated 18 October 2016 on Wayback Machine (in Ukrainian)
Source:
https://ru.wikipedia.org/w/index.php?title=Aнтoнюк,_Aнaтoлий_Eвдoкимoвич&oldid=1207
49243
Exhibit C
RIA Novosti, Paris Completes Reinforcement Work on Fire Damaged Notre-Dame
(18 September 2019, updated 19 September 2019)
(translation)

Annex 23 Exhibit C
Translation
RIA Novosti, Paris Completes Reinforcement Work on Fire Damaged Notre-Dame (18
September 2021), available at: https://ria.ru/20210918/sobor-1750674763.html.
RIA Novosti
18 September 2021 at 02:18 PM
Paris Completes Reinforcement Work on Fire Damaged Notre-Dame
In Paris, reinforcement work has been completed on the fire damaged Notre-Dame Cathedral.
© RIA Novosti / Alexey Filippov
PARIS, 18 September, RIA Novosti. Work to secure and reinforce the Notre-Dame Cathedral,
heavily damaged by fire more than two years ago, has been completed, and reconstruction is
scheduled to commence this winter, according to a press release by the public institution in
charge of the restoration of Notre-Dame.
“The work to secure and reinforce the Notre-Dame de Paris Cathedral that began on the 16th of
April 2019, has been successfully completed in accordance with the established schedule,” the
press release says as quoted by BFM TV.
In particular, scaffolding has been removed, wooden framework has been installed, and leadcontaminated
areas have been cleaned up.
The press release stresses that restoration works are scheduled to begin this winter.
The largest fire in the history of the Notre-Dame Cathedral broke out on the 15th of April 2019.
The spire of the cathedral collapsed, and the supporting structure was engulfed in flames. The
fire destroyed the unique wooden roof framework made of 800-year old oak beams, each from
Annex 23 Exhibit C
a single tree trunk. According to firefighters, the overall structure of Notre-Dame and the main
relics kept at the cathedral have survived. French President Emmanuel Macron has announced
an ambitious goal to restore Notre Dame in five years, although many experts say that the
reconstruction will take 10 to 15 years.
Exhibit D
SBI RC Bakhchisaray Historical, Cultural and Archeological Museum-Reserve, Letter to the
Head of the Republic of Crimea S. Aksyonov
(translation)

Annex 23 Exhibit D
Translation
SBI RC Bakhchisaray Historical, Cultural and Archeological Museum-Reserve, Letter to
the Head of the Republic of Crimea S. Aksyonov.
REPUBLIC OF CRIMEA
MINISTRY OF CULTURE
STATE BUDGETARY
INSTITUTION OF
THE REPUBLIC OF CRIMEA
"BAKHCHISARAY HISTORICAL,
CULTURAL AND ARCHAEOLOGICAL
MUSEUM-RESERVE"
_____________________________________________________________________________
298405, Bakhchisaray, tel. / fax <...>
Rechnaya St., 133 e-mail: <...>
web: http://handvorec.ru
ref. No._____________
of _____________2022
To the Head
of the Republic of Crimea
S. Aksyonov
Dear Sergey Valeryevich!
For purposes of providing information, I am forwarding data on the progress of work on the
preservation of the cultural heritage of federal importance ensemble “Khan's Palace” as of 07
October 2022.
Annex: 22 pages.
1. a note, on 3 sheets;
2. the photographs, on 19 sheets.
Sincerely,
the Director General V. Martynuk
Annex 23 Exhibit D
A note
on the progress of work on the preservation of the cultural heritage objects of federal significance of the ensemble “Khan's Palace” as of 07
October 2022
No. Name of
object
Work performed
Number of
people
carrying
out the
work
Name, position
and telephone
number of the
person in charge
Name, position
and telephone
number of the
person in charge
on the
contractor's side
Wishes,
comments or
complaints about
the production of
the work
1 The Retinue
(Svetsky)
corps
no work was recorded during the reporting
period
Chief Architect of
SBI RC
"BHCAMR"
<...>
tel. <...>
Manager of the
project "RC
Gefest" LLC
<…>
tel. <...>
2 Khan’s
kitchen
work is in progress:
- installation of curb plate and floor girders.
3 Stable
building
work is in progress:
- the roof overhang on the west facade;
- the cladding of the skylight windows on the
west slope of the roof in Axes 2-3 and 4-5;
- floor sanding in room No. 103;
- restoration of tiling;
- restoration of the pinnacle in Axes 4-5;
- floor sanding in room No. 201;
4 Falcon Tower work is in progress:
- installation of battens;
- restoration of the decorative wooden ceiling
elements on the middle and upper levels;
- plastering the internal surfaces of the stone
walls.
Annex 23 Exhibit D
5 Library corps work is in progress:
- installation of battens and tiling on the roof;
- restoration of the pinnacle of the Cultural
Heritage "Palace Cemetery"
- the continuation of archaeological
investigations on the eastern side of the "Mufti's
House";
- cleaning of the joints of the masonry fence in
the south-west corner of the main courtyard;
- cleaning of the seams of the masonry fence on
the eastern and southern sides of the Persian
Garden.
10 Khan’s
Mosque
work is in progress:
- plastering of the destructed areas of the eastern
wall;
- replacement of the floor beams on the east and
west wall in room No.1 (in accordance with
Technical Inventory Bureau);
- Replacement of the floor beams on the east
wall in room No.2 (in accordance with Technical
Inventory Bureau);
- Marking and resurfacing of masonry floor in
room No.1 (in accordance with Technical
Inventory Bureau);
- Dismantling of the roof of the western and
eastern minarets.
11 Quay with
three bridges
no work was recorded during the reporting
period
Annex 23 Exhibit D
12 "Sary-Guzel"
baths
no work was recorded during the reporting
period
Head of section
"NST" LLC
<…>
tel. <…>
13 Tombstone
rotunda
Head of section
«STK" AM
STROY" LLC
<…>
tel. <…>
Annex 23 Exhibit D
The “Khan's Palace” ensemble. Stable building. The roof overhang on the west facade. Photo dated
6 October 2022.
The “Khan’s Palace” Ensemble. Stable Building. Skylight window cladding on the west gable of
the roof in axes 4-5. Photo dated 6 October 2022.
Annex 23 Exhibit D
.
The “Khan's Palace” ensemble. Stable Building. Skylight window cladding on the west gable of the
roof in axes 2-3. Photo dated 6 October 2022.
The “Khan's Palace” ensemble. Stable Building. Sanding the floor in room No. 103. Photo dated 6
October 2022.
Annex 23 Exhibit D
The “Khan's Palace” ensemble. Stable Building. Restoration of the tiles. Photo dated 6 October
2022.
The “Khan's Palace” ensemble. Stable Building. Restoration of the pinnacle in axes 4-5. Photo
dated 6 October 2022.

Exhibit E
Tavrida Muftiyat, Khan's Palace Restoration to Be Monitored by Public Figures
(22 March 2022)
(translation)

Annex 23 Exhibit E
Translation
Tavrida Muftiyat, Khan's Palace Restoration to Be Monitored by Public Figures (22
March 2022), available at: https://qmdi.ru/za-restavracziej-hanskogo-dvorcza-budutsledit-
obshhestvenniki/.
Khan's Palace Restoration to Be Monitored by Public Figures
Published on the 22nd of March 2022
At the instigation of Hadji Emirali Ablayev, the Mufti of Crimea, a Public Advisory Panel has
been set up to provide public oversight, monitoring and advice on repair and restoration of the
federal-level cultural heritage site called the 16th-19th Century Khan’s Palace Ensemble in
Bakhchysarai. The first founding meeting was led by Sergey Aksyonov, Head of the Republic
of Crimea. “The Khan’s Palace is not only a pearl of Crimea, it is a unique and one-of-a-kind
monument to traditions and culture of the Crimean Tatar people. It is planned that the
restoration work will bring the palace back to its historical appearance, to what it looked like
when it was built,” Mr. Aksyonov said.
The Public Advisory Panel consists of Dmitry Rudnitsky, Chairman of the Union of Restorers,
an archaeologist, Head of the Department of History at the Fevzi Yakubov Crimean
Engineering & Pedagogical University, Emil Seidaliev, a historian, Andrey Malgin, a regional
ethnographer, construction engineers Eldar Yayachik and Enver Emirdjiev, architects and
restorers Valery Borisov and Shukri Khalilov.
“The efforts of this Panel will be aimed at helping the restoration workers and at keeping the
public informed to avoid any potential speculations around the restoration of the Khan’s
Palace,” said Crimean Mufti Hadji Emirali Ablayev.
Sergey Aksyonov noted that the Public Advisory Panel will also provide monitoring at other
future cultural heritage work sites.
“Given that we have more than 4,000 various cultural monuments in the Republic of Crimea, I
suggest that we should identify the most significant cultural heritage sites that are unique and
symbolise Crimean historical milestones. These should include the main palace ensembles and
monuments associated with the culture of all the ethnicities who have inhabited the peninsula.
A specification of requirements will be issued by the Panel every time repair and restoration
work is to be carried out at such sites. This will help avoid unnecessary expenses and ensure
that the sites preserve their original appearance,” Mr. Aksyonov said.
The meeting was also attended by Mikhail Nazarov, Deputy Chairman of the Council of
Ministers of the Republic of Crimea, Karlen Petrosyan, Minister of Construction and
Architecture of the Republic of Crimea, Tatiana Manezhina, Minister of Culture of the Republic
of Crimea, and Ayder Tippa, Chairman of the State Committee for Interethnic Relations of the
Republic of Crimea.
Annex 23 Exhibit E
Press Service of the Spiritual Direction of the Muslims of Crimea, based on the information
provided by the Information and Press Office of the Head of the Republic of Crimea.
Exhibit F
National University of Kiev-Mohyla Academy, Dr Kateryna Busol

Exhibit G
Kateryna Busol, Crimea's Occupation Exemplifies the Threat of Attacks on Cultural Heritage,
Chatham House (4 February 2020)

Annex 23 Exhibit G
— ‘The destructive reconstruction of the 16th-century Bakhchysarai Palace is being conducted by a team
with no experience of cultural sites, in a manner that erodes its authenticity and historical value.’ Photo:
Getty Images.
Violations against cultural property – such as archaeological treasures, artworks,
museums or historical sites – can be no less detrimental to the survival of a nation
than the physical persecution of its people. These assaults on heritage ensure the
hegemony of some nations and distort the imprint of other nations in world history,
sometimes to the point of eradication.
As contemporary armed conflicts in Syria, Ukraine and Yemen demonstrate, cultural
property violations are not only a matter of the colonial past; they continue to be
perpetrated, often in new, intricate ways.
Understandably, from a moral perspective, it is more often the suffering of persons,
rather than any kind of ‘cultural’ destruction, that receives the most attention from
humanitarian aid providers, the media or the courts. Indeed, the extent of the
damage caused by an assault on cultural property is not always immediately evident,
but the result can be a threat to the survival of a people. This is strikingly exemplified
by what is currently happening in Crimea.
Ukraine’s Crimean peninsula has been occupied by Russia since February 2014,
meaning that, under international law, the two states have been involved in an
international armed conflict for the last six years.
While much attention has been paid to the alleged war crimes perpetrated by the
occupying power, reports by international organizations and the International
Criminal Court (ICC) have been less vocal on the issue of cultural property in Crimea.
Where they do it, they tend to confine their findings to the issue of
misappropriation.
raise
Annex 23 Exhibit G
However, as part of its larger of the annexation and Russification of the
peninsula and its history, Russia has gone far beyond misappropriation.
Crimean artefacts have been transferred to Russia – without security justification or
Ukrainian authorization as required by the international law of occupation – to be
showcased at exhibitions celebrating Russia’s own cultural heritage. In 2016, the
Tretyakov Gallery in Moscow staged its record-breaking ,
which included 38 artworks from the Aivazovsky Museum in the Crimean town of
Feodosia.
Other ‘cultural’ violations in the region include
, whose findings are often to Russia
or end up on the black market.
There is also the example of Russia’s plan to establish a in
Ukraine’s , the Ancient City of Tauric Chersonese. This
is an indication of Russia’s of asserting itself as a
in the Slavic world, with Crimea as one of the centres.
The harmful effects of Russia’s destructive cultural property policy can be seen in the
situation of the Crimean Tatars, Ukraine’s indigenous Muslim people. Already
depleted by a Stalin-ordered in 1944 and previously repressed by the
Russian Empire, the Crimean Tatars are now facing the destruction of much of the
remainder of their heritage.
For example, Muslim burial grounds have been demolished to build the Tavrida
Highway, which leads to the newly built Kerch Bridge connecting the peninsula to
Russia.
The of the 16th-century Bakhchysarai Palace – the only
remaining complete architectural ensemble of the indigenous people, included in the
UNESCO World Heritage – is another example of how the very identity
of the Crimean Tatars is being threatened. This reconstruction is being conducted by a
team with no experience of cultural sites, in a manner that its authenticity
and historical value – which is precisely as Russia intends.
policy
Aivazovsky exhibition
numerous unsanctioned
archaeological excavations unlawfully exported
museum of Christianity
UNESCO World Heritage site
policy bastion of Orthodox
Christianity and culture
deportation
destructive reconstruction
Tentative List
erodes
Annex 23 Exhibit G
There is a solid body of international and domestic law covering Russia’s treatment of
Crimea’s cultural property.
Under the 1954 Hague Convention for the Protection of Cultural Property in the Event
of Armed Conflict – ratified by both Ukraine and Russia – the occupying power must
facilitate the safeguarding efforts of the national authorities in occupied territories.
States parties must prevent any vandalism or misappropriation of cultural property,
and, according to the first protocol of the convention, the occupying power is required
to prevent any export of artefacts from the occupied territory.
The 1907 Hague Regulations and the 1949 Fourth Geneva Convention confirm that
the authentic domestic legislation continues to apply in occupied territories. This
leaves Russia with no excuse for non-compliance with Ukraine’s cultural property
laws and imposing its own rules unless absolutely necessary.
Besides, both Ukrainian and Russian criminal codes penalise pillage in occupied
territory, as well as unsanctioned archaeological excavations. As an occupying power,
Russia must not just abstain from such wrongdoings in Crimea, but also duly
investigate and prosecute the alleged misconduct.
The clarity of the international legal situation demonstrates that no exhibitions in
continental Russia and no archaeological excavations which are not sanctioned by
Ukraine can be justified. Likewise, any renovation or use of cultural sites, especially
those on permanent or tentative UNESCO lists, must only be conducted pursuant to
consultancy with and approval of the Ukrainian authorities.
But the resonance of the Crimean case goes beyond law and touches on issues of the
very survival of a people. The Soviet deportation of the Crimean Tatars in 1944 did
not only result in the deaths of individuals. Their footprints in Crimea have been
gradually erased by baseless treason charges, the long exile of the indigenous
community from their native lands and ongoing persecution.
First the Soviet Union and now Russia have targeted the Crimean Tatars’ cultural
heritage to undermine their significance in the general historical narrative, making
attempts to preserve or celebrate this culture seem futile. Russia is thus imposing its

Annex 24
Expert Witness Statement of , 6 March 2023
(translation)

Annex 24
INTERNATIONAL COURT OF JUSTICE
APPLICATION OF THE INTERNATIONAL CONVENTION
FOR THE SUPPRESSION OF THE FINANCING OF TERRORISM AND
INTERNATIONAL CONVENTION ON THE ELIMINATION OF
ALL FORMS OF RACIAL DISCRIMINATION
(UKRAINE V. RUSSIAN FEDERATION)
EXPERT WITNESS STATEMENT
OF
6 MARCH 2023
Annex 24
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Annex 24
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conservation architect of the second category with the Ministry of Culture of the Russian
Federation.
8. I have been ,
and
. For 36 years I have been
.
9. I have been living in Crimea for nearly 44 years, during which period, as part of my
professional activities both before and after the reunification of Crimea with the Russian
Federation,
.
10. In this witness statement I address the history of the restoration of the Bakhchisaray
Palace complex and provide my opinion as an architecture expert on Ukraine’s claims
regarding the Bakhchisaray Palace restoration process set out in the Memorial and the
Reply to Russia’s Counter-Memorial in the proceedings under the Convention on the
Elimination of All Forms of Racial Discrimination (hereinafter, “Reply”).
A. BAKHCHISARAY PALACE BEFORE 2014
11. First of all, it should be noted that the use of the name “Bakhchisaray Palace Complex”
is not accidental, as the name “Khan’s Palace” is not accurate. The fact is that the use of
the name “Khan’s Palace” with regard to the complex is not quite correct: the main,
freestanding building (“Khan Saray”, which means “Khan’s Palace” in Turkic), which
housed the residence of the khans, was completely lost in the XVIII century. The whole
complex was originally named after this property. At present, there is a building on the
territory of the complex which is conventionally called the “Main Palace”, but historically
it never fulfilled the functions of a palace. This building was originally used as a summer
residence intended mainly for receiving ambassadors. Thus, the name “Khan’s Palace” is
essentially a symbol representing the totality of its buildings.
12. Throughout its existence, the Bakhchisaray Palace has been constantly exposed to various
factors which, in one way or another, have affected the degree of preservation and
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authenticity of the complex’s objects. For instance, back in the XVIII century the Khan’s
Mosque was, in fact, rebuilt after a fire. The initial volume and look of the mosque
underwent significant changes. When the mosque was rebuilt after the fire in 1740
windows were installed, the dome was replaced by a pitched roof with a slope of more
than 12 degrees and covered with concave tile instead of the original zinc tile (this fact is
also confirmed by the experts referred to by Ukraine).2 At that time the roof slope angle
was determined without taking into account the concave tile installation technique, which
subsequently caused problems with exploitation of the roof, and, consequently, the
mosque itself.
13. During the Soviet period, the Bakhchisaray Palace became the centre of tourist attraction,
which had its advantages and disadvantages. On the one hand, until 1991 the state
allocated 4% of the income from tourism for the maintenance and restoration of historical
and cultural monuments, including the Bakhchisaray Palace buildings, which allowed
maintaining them in proper condition. On the other hand, the buildings of the
Bakhchisaray Palace complex were turned into a museum and were open to tourists. In
spite of the restorers’ efforts, the bearing structures of the buildings of the Khan’s Palace
complex in Bakhchisaray were gradually deteriorating, also because of the change in their
functional use. The large flow of visitors created considerable dynamic loads and
vibrations that were not in line with its original purpose as the Khans’ summer residence.
The increased vibrations caused the multi-ton roof structure and concave tiles to move,
resulting in the displacement, disintegration and collapse of the roof fragments. The said
dynamic loads, combined with the peculiarities of the frame structure, difficult
hydrogeological conditions at the footing of the buildings and a change in the ground
water level of the Churuk-Su River, on the left bank of which the complex is located,
negatively affected the deterioration of the technical condition of the buildings.
14. After the collapse of the USSR, the Crimea became part of Ukraine, a separate state. After
the Autonomous Republic of Crimea was formed the Bakhchisaray Khan’s Palace
complex received status of a site of regional significance, resulting in corresponding
financing throughout the Ukrainian period. As a result, restoration work was financed
mostly from own funds of the administration of the Bakhchisaray Palace complex. Under
2 Ibid., p. 2.
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such conditions it was extremely difficult to meet the needs of cultural heritage objects
for full-scale, systematic research and for a set of restoration works.
15. At the end of the 20th century, at the request of Bakhchisaray Historical and Cultural
Reserve, experts of the Institute “Ukrzhilremproektrekonstruktsiya”, jointly with experts
of the Building Structures Department of the National Academy of Environmental and
Resort Construction, examined the structures of the main building of the Khan’s Palace.
The results showed that the load carrying structures of the wooden frame were affected
by rot. As a result of continuous overmoistening, changes in the ground water level and
leaks in the roof, the upper and lower mounting assemblies of the framework’s vertical
supports, frame of the roof, and inter-floor constructions and garret floors had rotten and
lost bearing capacity. In the meantime, the roof tiles continued to deteriorate due to
dynamic loads. The situation was aggravated by an erroneous technological solution
implement in the Ukrainian period consisting of securing the roof tiles with cement
mortar, which replaced the elastic mortar of sand, lime, and clay. The roof acquired the
characteristics of hard surface, two longitudinal cracks formed in it, and the roof began
to easily let precipitation in, which constantly moistened the wooden structures of the
supporting framework over a long period of time.
16. In the last decade of the 20th century, application was made to enter the Khan’s Palace
complex on the UNESCO World Heritage List. As far as I know, the application was
denied because of the site’s lack of authenticity. I became acquainted with the
correspondence on this issue at the records repository of the Bakhchisaray Historical and
Cultural Reserve in 2017, when I was making preparations for a public discussion of
scientific and design solutions pertaining to the restoration of the Bakhchisaray Palace.
B. BAKHCHISARAY PALACE AFTER 2014
17. In the period after 2014, all buildings of the Khan’s Palace complex in Bakhchisaray were
assigned the status of Sites of Federal Significance and, accordingly, they received the
highest level of funding from the State Budget of the Russian Federation.
18. In 2016, at instructions of the Chairman of the Scientific and Methodological Council of
the Committee for the Protection of Cultural Heritage of the Republic of Crimea, I took
part in a preliminary inspection of the Main Building. The purpose of the preliminary
inspection was to determine the condition of the building and the scope and types of

Annex 24
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24. Kiramet LLC’s creative works have been regularly awarded 1st, 2nd and 3rd class
diplomas at the annual international competitions Arkhnaslediye and No-Priz organised
by the Union of Architects of Russia. The scientific and design documentation developed
by the company at all project stages comply with the methodology of restoration works
and the current regulatory framework, and have been developed in full and are complete.
Moreover, all necessary approval statements of construction and historical and cultural
appraisals have been obtained, and the respective projects have been repeatedly reviewed
at public discussion meetings with the involvement of the media and representatives of
national and cultural societies.
25. For example, before carrying out the first phase of the restoration of the Khan's Mosque,
in the framework of relevant assignment3and permit4 to conduct restoration works 6
volumes of project documentation were prepared, including 20 sections in total.5 This
design documentation underwent a state historical, cultural and construction appraisal.6
26. I believe that in the dispute about the causes of the unsatisfactory and, to some extent,
pre-emergency and emergency condition of the Bakhchisaray Palace complex and its loss
of authenticity, it is necessary to rely on the totality of all research results, taking into
account previous restoration, repair, maintenance, technical, technological and external
works, and also taking into account changing engineering and geological conditions and
the seismic situation at the complex location.
27. It should be borne in mind that throughout its centuries-long existence, the objects of the
Khan’s Palace complex in Bakhchisaray have changed both externally and in terms of the
degree of preservation, with due regard for the impact of various factors, such as
3 State Budgetary Institution Bakhchisaray Historical, Cultural and Archaeological Museum-Reserve, Assignment
for the performance of works to preserve a cultural heritage object (historical and cultural monument) of the
peoples of the Russian Federation No. 15/2016, 28 March 2016 (Exhibit A).
4 State Committee for the Protection of the Cultural Heritage of the Republic of Crimea, Permit for the performance
of works to preserve cultural heritage sites included in the Unified State Register of Cultural Heritage Sites
(historical and cultural monuments) of the peoples of the Russian Federation No. 01-03/1415, 10 March 2017
(Exhibit B).
5 Scientific and Design Documentation, Volume IV, Section 4, Mycological investigations. Mechanical Testing,
2017, Counter-Memorial (CERD), Annex 696, pp. 3-4.
6 Report on the State Historical and Cultural Appraisal of the design documentation for the preservation of the
federally significant cultural heritage site “Khan’s Palace (XVI-XIX centuries): Khan’s Mosque (1740-1743), 29
June 2017, Counter-Memorial (CERD), Annex 696.
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(a) physical “ageing” of the main load-bearing structures and finishing materials of the
complex;
(b) loss of the original space planning solutions and building and finishing materials
and technologies;
(c) normal wear and tear of structures, building materials, roofing, coverings, design
and ornamented surfaces and members of structure and decorations;
(d) changes in dynamic loads due to changes in the functional use of the complex’s
buildings;
(e) operational and technological mistakes during the period of the use of buildings and
structures and of the drainage system to remove water from the adjacent areas;
mistakes during the performance of restoration and repair works;
(f) changes in the hydrogeological and seismic situation that have significantly
affected the stability and integrity of the load-bearing structures and their
capabilities; and
(g) the impact of natural disasters (floods, earthquakes, mud streams, etc.).
28. This far from complete list of causes and factors, as well as historically determined
processes, have led to the inevitable, practically and scientifically justified replacement
of building and finishing materials of basic, load-bearing and enclosure structures and
their finishing, and to the modernisation of technological solutions.
29. Regarding the replacement of the wooden beams on the roof of the Khan’s Mosque during
the restoration works, it must be explained that this was a forced measure of necessity.
As a first step, it is necessary to determine which of the mosque’s inter-floor constructions
Ukraine considers authentic: the wooden centres, slab beams or the anti-seismic belt of
the original dome mosque, which burned out completely during the 1736 fire, or the beam
ceilings installed during the repairs following the fire and reconstruction of the mosque.
30. The wooden beams on the roof of the mosque were replaced at least four times in different
periods of the mosque’s existence, as described in detail by the expert referred to by
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Ukraine itself.7 The roof structures were successively replaced in 1740 under Selamet II
Giray; in the 1770-ies, in preparation for the visit of Empress Catherine II; in the 1920-
30-ies, in preparation for the arrival of Emperor Alexander II; and in the 1990-ies, in
connection with the rebuilding of the minarets.
31. In the meantime, at all stages of the mosque’s existence, the problem of preservation and
integrity of the tile roofing has been observed. The grooved tiles of the roof, which are
laid on the elastic mortar of sand, lime, and clay, cannot hold out on the roof structures
and so they go down according to the laws of physics. In their turn, the displacement and
collapse of the tiles allow atmospheric precipitation to penetrate into structures of the
roof, attic flooring, anti-seismic belt, and intermediate floor. Under the long-term
influence of continuous moisturization, all of the above-listed structures are infected by
fungus and decay processes develop. As a result of all the processes described above, the
support sections of the mosque beams have lost their load-bearing capacity.
32. Poor condition of the beams on the roof of the Khan’s Mosque is evident from the diagram
of defects I have in my possession, as was prepared upon visual inspection of the
mosque’s roof (Figure 1).
7 See “Restoration” of the Great Khan Mosque (Biyuk Khan-Djami) in Bakhchisaray: on the tile roofing. Expert
opinion, № 33/02, 14 March 2018, Memorial, Annex 1031.
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Figure 1
Annex 24
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33. Meanwhile, the beams themselves have become shorter in length than the span they are
supposed to bridge. Under safety and structural stability requirements it is prohibited to
incorporate a prosthesis into support elements of beams in buildings that are in use. In
accordance with the requirements of Construction Standards and Regulations SP
14.13330.2018 “SNiP II-7-81*, Construction in Seismic Areas”, in seismic environments
the floor structure must be homogeneous. In view of these requirements and based on the
calculation results, larch beams were selected to replace all wooden structures. The reason
for replacing oak with larch is the decay resistance of larch and the fact that currently the
oak trees no longer grow to a height that would allow beams to be manufactured to the
required length.
34. The remarks about the loss of authentic specifically Crimean Tatar roofing, flooring and
anti-seismic technologies are difficult to regard as fair. The use of post and beam
framework is observed as early as in 1st century A.D. throughout archaeological sites in
Crimea and its design and techniques do not differ from those used in buildings in the
northern Black Sea Region dating much earlier.
35. As for the removed masonry stones, they were removed from those sections of the
masonry that had lost their load-bearing capacity as a result of soaking and thawing. The
reason for the soaking is the same: disturbance and loss of the tile roofing long before the
restoration process began.
36. As for the Ukraine’s statements about alleged cracks, as far as I understand those
allegations were made with regard to the Khan’s Mosque. I need to mention that such
information is false as using cleaning equipment employing high pressure water may not
deform the structures. Cracks in the plaster layer only indicate that the latter lost its
stability earlier as a result of use. Furthermore, as far as I am aware for the purpose of
cleaning the walls during restoration of Bakhchisaray Palace specific “safe” methods of
cleaning were employed with pre-calculated water pressure.
37. Regarding the anti-seismic belt, I can provide the following clarifications. The installation
of a concrete anti-seismic belt in the Khan’s Mosque was also due to objective
circumstances. The fact is that the Bakhchisaray Palace is located in a seismically active
zone that has changed since the time of its construction on the unstable soils of the
Churuck-Su River bank. Russia's construction standards, in particular, SP 14.13330.2018
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“SNiP II-7-81*, Construction in Seismic Areas”, require that an anti-seismic belt be
installed on cultural heritage objects and in public buildings in seismically active zones.
38. The design solution for the anti-seismic belt installation was developed in such a way as
to “build” the belt in a wall niche and create a decorative layer which would hide the antiseismic
belt inside the palace wall so that it would not be visible to the outside observer
and would not conflict with the overall appearance and cultural value of the building. In
the meantime, creating a wooden anti-seismic belt is not envisaged by the building
regulations of the Russian Federation, since such belt should not have an open contour,
which arises at corner nodes when it is made of timber beams.
39. Ukraine also claims that the replacement of the “original” tiles with the Spanish ones
causes significant damage to the cultural value of the Khan’s Mosque, but fails to take
into account that the tiles at the mosque were re-laid at least 8 times from 1740 to the
1950-60-ies. This fact is also confirmed by the expert Ukraine refers to in its statements.8
When the tiles were re-laid, their standard size, shape and manufacturing technology
changed. Thus, it is incorrect to call the tiles currently dismantled from the mosque
roofing “authentic”. The removed tiles are remnants of reused tiles left over after the
demolition of dilapidated houses in Bakhchisaray and the Bakhchisaray region. By now
this tile replenishment resource has been exhausted.
40. That said, it is not possible to manufacture authentic tiles again, as the manufacture of
replicas using a traditional technology is a process of modern imitation involving the use
of a lost production line, raw materials from deposits whose locations have not been
identified, and the craftsmen who are our contemporaries. In view of these factors, it
appears to be impossible to consider this method of production as authentic. It is a modern
imitation of historical technology and forms. Considering this, tiles were chosen for the
roofing that are identical in shape, colour, composition and size to the authentic ones and
that correspond to the decorative and volumetric and spatial parameters which are
characteristic of the image of the Khan’s Palace. After a thorough analysis of proposals
from manufacturers and suppliers, we opted for tiles that met the abovementioned criteria.
8 See ibid.
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41. Regarding the method of laying tiles, I would like to clarify that nowadays the installation
of tiles is done with self-tapping screws in accordance with the technology. Also, it should
be noted that a change in the roof pitch back in the 18th century (which I mentioned earlier)
made it impossible to use lime-sand-clay mixture for fixing, while cement-lime mixture
makes the roof excessively heavy.
42. I would also like to clarify the issue regarding the shed over the Main Building of the
Bakhchisaray Palace. The roof of the Main Building at the time of the study and design
had ceased to protect the building from precipitation. To protect the Main Building from
further deterioration a solution was designed to build a temporary protective shed. The
architecture of this shed and its aesthetic and spatial features are utilitarian and do not
claim to rival the grandeur of the architecture of the Khan's Palace complex.
43. Another statement that is obviously false is reference to a crack in the tomb of Ferah
Sultan hani that allegedly resulted from improper restoration. Even superficial overview
of earlier photos of the tomb show that it had already been significantly damaged prior to
commencement of restoration. (Figure 2).
Figure 29
9 See O. Gayvoronskiy, A CEMETERY OF CRIMEAN KHANS IN BAKHCHISARAY PALACE. SCHEME AND CATALOGUE
OF MONUMENTS (DOLYA, 2006) (Exhibit C).
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44. Furthermore, I personally observed that tombs in the immediate vicinity of the works
were thoroughly protected from external forces by wooden scaffolding (Figure 3).
Figure 3
45. Regarding the issue of preserving the authenticity of building materials and technologies,
I feel it necessary to advise that the term “authentic”, translated from the Greek, means
“real, genuine, conforming to an original”. It is a very broad and variable concept,
allowing for different interpretations. The only thing clearly excluded from the definition
of “authentic” is a requirement of exclusive originality. Based on the definition, it is
legitimate to consider as authentic all the materials, technologies, and volumetric and
spatial solutions used during all historical periods of the existence of a cultural heritage
object. In the study of objects such transformations are called “construction periods”.
They may mimic the construction techniques and materials of previous periods, but are
always traceable in the object. Therefore, the design solutions involving the use of some
or other modern building materials and technologies in the buildings of the palace
complex in Bakhchisaray have been dictated by the reasonableness of their use for
ensuring physical preservation of the buildings, taking into account the need to meet the
Annex 24
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exhibition requirements and the volumetric and spatial, ideological, image and other
parameters of the object being restored.
46. It is known that the progress of restoration work at the Bakhchisaray Palace is monitored
by representatives of the Crimean Tatar public, who from time to time approach the
conservation professionals with questions regarding the restoration process. The
conservation professionals respond to any comments they receive and, if they are
constructive and justified, take steps to eliminate shortcomings.
47. As of now, the following works have been carried out since 2014:
(a) The status of the Khan’s Palace complex in Bakhchisaray has been raised to that of
a Cultural Site of Federal Significance, with appropriate funding being allocated
under the Federal Targeted Programme for its operation and development and the
performance of top-priority anti-damage works and restoration, conservation and
repair works;
(b) A Comprehensive Engineering Examination of the complex’s buildings has been
conducted to assess the physical condition of the entire territory, including land
improvement facilities, such as: gardens, courtyards, fountains, drainage system,
etc;
(c) A strategy has been developed to implement measures to address the progressing
deterioration of the complex’s buildings;
(d) Projects have been developed and works have been performed to restore and
conserve the following objects: the Mosque, the Turbes (Northern, Southern, and
Dilyara-Bikech Turbes, the Sary-Guzel bathhouse, Rotunda); top-priority antidamage
works have been carried out in the Main Palace building; a digital model
of the impact of loads on the structural system of the palace has been developed;
(e) The restoration of seven objects of the Bakhchisaray Palace complex has been
completed;
(f) Research is carried out, including that involving the use of modern methods and
technology for the purposes of review and obtaining the seal of approval in
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connection with expert examinations at all levels corresponding to a federally
significant site.
48. During exploitation prior to the commencement of the Main Palace and Great Khan’s
Mosque restoration, there occurred non-recoverable loss of the load-bearing capacity of
the elements of their structure and the grooved tiles of the roof. When developing projects
for the restoration of the buildings, a full set of research and design documentation was
envisaged and prepared, covering all stages, from the research and documentation stage
to the full completion of the works, when the designer’s and engineer’s supervision was
carried out, taking into account the requirements and basic principles of the Restoration
Work Methodology.
49. All research and design works are carried out with due consideration for the need to
preserve to the greatest possible extent the volumetric and spatial, compositional, and
silhouette parameters of the complex, the national and cultural traditions, and the
exhibitional and other features that display characteristics of the image corresponding to
the symbol of Khan’s Palace, in honour of which the complex is historically named.
50. The disputes concerning the degree of preservation and authenticity of an object,
conservation methods and techniques, technological subtleties and peculiarities of
applying construction and finishing materials and coatings are of academic or scientific
and methodological nature. The resolution of such disputes, subject to observance of
copyright and author's solutions, lies within the competence of collegial bodies, as such
issues are to be considered at meetings of scientific and methodological councils, which
usually include experienced technologists, engineers, architects, historians, and art
historians.
51. In my view, Ukraine’s accusations against the Russian Federation regarding the progress
of the restoration of the Bakhchisaray Palace complex and of deliberate destruction of the
cultural heritage of the Crimean Tatars are unsubstantiated. In this case, the dispute has a
scientific and methodological basis and has nothing to do with the issues of the alleged
discrimination against Crimean Tatars. On the contrary, had the Russian Federation not
started the process of comprehensive restoration of the Bakhchisaray Palace buildings, it
could have led to the collapse of the unique cultural heritage sites. In any event, stopping
Annex 24
Page 18 out of 18
the process of the Bakhchisaray Palace restoration at this point could have irreversible
consequences.
52. I cannot but note that Ukraine uses already outdated data from before 2014.
53. I hereby certify that to the best of my expert knowledge and belief the information set out
in this witness statement is true.
Expert Witness
[Signature]
Bakhchisaray, 6 March 2023
Annex 24
LIST OF EXHIBITS
Number: Name of exhibit:
Exhibit A State Budgetary Institution Bakhchisaray Historical, Cultural and
Archaeological Museum-Reserve, Assignment for the performance of
works to preserve a cultural heritage object (historical and cultural
monument) of the peoples of the Russian Federation No. 15/2016, 28
March 2016.
Exhibit B State Committee for the Protection of the Cultural Heritage of the Republic
of Crimea, Permit for the performance of works to preserve cultural
heritage sites included in the Unified State Register of Cultural Heritage
Sites (historical and cultural monuments) of the peoples of the Russian
Federation No. 01-03/1415, 10 March 2017.
Exhibit C O. Gayvoronskiy, A CEMETERY OF CRIMEAN KHANS IN BAKHCHISARAY
PALACE. SCHEME AND CATALOGUE OF MONUMENTS (DOLYA, 2006).

Exhibit A
State Budgetary Institution Bakhchisaray Historical, Cultural and Archaeological Museum-
Reserve, Assignment for the performance of works to preserve a cultural heritage object
(historical and cultural monument) of the peoples of the Russian Federation No. 15/2016,
28 March 2016
(translation)

Annex 24 Exhibit A
Translation
State Budgetary Institution Bakhchisaray Historical, Cultural and Archaeological Museum-
Reserve, Assignment for the performance of works to preserve a cultural heritage object
(historical and cultural monument) of the peoples of the Russian Federation No. 15/2016, 28
March 2016.
AGREED:
General Director
State budgetary institution
Bakhchisarai Historical, Cultural and
Archaeological Museum-Reserve
Martyshok V.L
17 March 2016
(Round Seal)
APPROVED:
First Deputy Chairman
State Committee for the Protection of Cultural
Heritage of the Republic of Crimea
A.P.Belyantsev
28 March 2016
(Round Seal)
ASSIGNMENT
for the performance of works to preserve a cultural heritage object
(historical and cultural monument) of the peoples of the Russian Federation
No. 15/2016
1. Name of cultural heritage object:
Khan’s Palace (16th - 19th centuries)
Object of the FTP - Bakhchisarai Palace and Park Complex (Khan’s Palace), XVI - XIX cc.
2. Address (location) of the cultural heritage site: Republic of Crimea, City of Bakhchisarai, 133
3. Information on the owner (user) of the cultural heritage object:
Owner (user): State Budgetary Institution of the Republic of Crimea "Bakhchisarai Historical, Cultural
and Archaeological Museum-Reserve
Address: Republic of Crimea (Republic, Oblast, Region), City of Bakhchisarai, 133
Bank account: _________________________________________________________
KPP: 910401001
Personal account: (redacted)
BIC: (redacted)
Correspondent account: _________________________________________________
Authorised representative: Vadim Leonidovich Martynyuk
(Round Seal)
Telephone for contacts: _______________________________________________
(including city code)
Annex 24 Exhibit A
Email address: ______________________________________________
4. Details of current protection obligations, protection and lease agreements or protection agreements:
Type: Protection agreement
No.: n/a
Date: 27 January 2011
Nature of contemporary usage: Sightseeing
5. Description of the boundary of the cultural heritage site and its protection zones (brief description
with reference to the approval document):
Decision #284 dated 22.05.1979 of the Crimean Regional Executive Committee established the protection
area of the Khan's Palace and Eski-Durbe and delimited the same by a boundary along Lenina street, Zoya
Kosmodemyanskaya street, the Churuk-Su river, Proletarskaya street, Skalistaya street, continued further
at a distance of 50m from the monument's southern and western fences and Shkolnaya street.
6. Brief information on the cultural heritage site and its technical condition, including minor architectural
forms, monumental paintings and interior decoration, engineering structures and equipment
The Khan's Palace complex is a unique historical and architectural complex of monuments from the
16th-19th centuries, where elements of Oriental and European styles were intricately combined.
The complex of the khan's palace, which currently occupies an area of 4 hectares, is visible only from
the palace itself, which is enclosed by a high stone fence, due to the closed nature of the oriental
architectural traditions. With the exception of the minarets of the khan's mosque, no other structures are
visible from the city.
The exact start date of the construction of the palace is unknown, and it was completed during the reign
of Adil Sahib Giray-khan. The Sultan's palace in Istanbul (Top Kapi) served as a model for the construction.
The Turkish architecture was transformed in a peculiar way by the participation of numerous captive
craftsmen of different nationalities in its construction. Local traditions were also used: projecting roof
canopies, arcades, terraces, carved lattices. The artistic value is represented by wood and stone carvings,
paintings on walls, plafonds and door leaves.
The palace ensemble was built over two and a half centuries. It consists of various structures of different
purposes and architectural style flanking a rectangular courtyard, which was used in khan's times for
parades and gatherings of Crimean nobles.
The palace was built as three separate but interconnected complexes: the residential part, the harem and
the front part.
In the XVII century, the residential complex was brought closer to the front part of the palace: to the
north of the latter a two-storey residential building was built, opposite which the harem building was
located. The second storey was built on top of the once single-storey front part of the palace.
In the 18th century the front part of the palace is connected to the living quarters and a new harem
building is built. Buildings appear in the northern part of the complex, and the Dürbe Dilary Bikeç is built.
Annex 24 Exhibit A
The earliest structures of the complex are the Sary-Guzel baths, located in the eastern part. The large
mosque and the cemetery are dated back to the 16th century.
After the fire of 1736, when Russian troops captured Bakhchisarai, a new period in the history of the
palace begins: the surviving buildings were restored, new ones were built - these works lasted for 30 years.
It was at that time that the present-day ensemble was created, the decoration of which came to be dominated
by the so-called Ottoman baroque. In that period, the servants' pavilion, count's pavilion and watchtowers,
Golden cabinet and Falcon Tower were built.
With the annexation of Crimea to Russia (1783) the history of the palace's renovations begins, which
tended to be timed with the arrival of Russian emperors.
The Khan’s Palace, which forms a part of the Bakhchisarai State Historical and Cultural Reserve, still
attracts numerous tourists with its uniqueness and original architectural solutions.
The Khan's Mosque. It is located in the main square of the Khan's palace, to the left of the main entrance.
According to the inscription above the portal, the mosque was built in 1740. That, in all probability, relates
only to the reconstructed of the facility, because the Polish king Stefan Bathory’s envoy to Khan
Muhammad Giray, who had visited the palace of Bakhchisarai in 1578, reported that here "a stone mosque
and khans' tombs were built on some Christian ruins." Inscriptions on the facade show that in 1763, Khan
Krim-Giray did a renovation. At the same time, the walls were painted by the court painter, architect and
calligrapher Omer.
The basilica mosque is a rectangular stone building stretching from north to south, covered with a tiled
roof with four sloping surfaces. Galleries with lancet arches and a single hip-tiled roof adjoin the main
building from the east and west. There are two entrances - in the west and north. The narrow stone stairway
adjoining the main façade leads to the khan's lodge. In the piers between the barred windows are green
majolica cartouches with decorative patterns and excerpts from the Koran made in Arabic script.
On the north and south sides, the mosque is flanked by two minarets with multifaceted stone sherfe
balconies with a rosette pattern on each face. The pointed end of the minarets is topped by an alem (the
Muslim symbol of the 'three worlds').
The internal space of the mosque is a three-nave hall with arches and columns, surrounded on both sides
by choir lofts. The choir lofts on the western side form a separate room, the khan's lodge, which is faced
with faience tiles and covered with paintings. There is a stuccoed niche in the south side with a wooden
preaching pulpit - minbar - on the right side of the niche.
The Great Khan Mosque is a monument of Ottoman art, which in the 18th century was strongly influenced
by European Baroque and Rococo. Biyuk-Khan-Jami is one of the last monumental constructions created
in the Crimean Khanate.
7. Сultural heritage object protection scope:
As of the time of writing this assignment, the scope of protection is not determined. In developing a full
restoration design for the monument, a draft protection scope for the cultural heritage object "Khan’s Palace
(16th - 19th centuries)" must be developed and approved in the prescribed manner in accordance with the
Annex 24 Exhibit A
requirements of Article 47.3 of Federal Law No. 73-FZ of 25.06.2002 "On Cultural Heritage Objects
(Historical and Cultural Monuments) of the Peoples of the Russian Federation”.
8. Basis for carrying out preservation work on a cultural heritage site:
State contract
Registration number 16
Date of approval 29.12.2015
The main content of the
preservation works of a cultural
heritage site:
Develop a complete restoration design of the cultural heritage object with
determination of the protection scope (1st stage - preliminary studies, design
of priority anti-disaster works)
Time of work commencement: Stage 1 - January 2016
Completion date: 31.03.2016
Intended use of the object of cultural heritage: Sightseeing
9. Information about the Customer:
Customer: State Committee for the Protection of Cultural Heritage of the Republic of Crimea
Address: Republic of Crimea, Simferopol, Gogol Street, 14
Bank account: _____________________________________________________
KPP: 910201001
Personal account: __________________________________________________
BIC: (redacted)
Correspondent account: ____________________________________________
Authorised representative: Alexei Pavlovich Belyantsev
Contact phone number: ____________________________________________
10. Information on the design organisation: (natural person):
Organisation:
Limited Liability Company «Corporation ATTA Group"
Address: Russian Federation, Moscow, Koptevskaya Street, 73a, building 5
Bank account: (redacted)
Corr. Account: ________________________________________________
Details of the Licence to carry out activities for the preservation of cultural heritage sites:
Annex 24 Exhibit A
Registration number MCRF 01019
Date of issue 12.08.2013
Authorised representative: Vedenkina Yulia Aleksandrovna
Contact telephone number: (redacted)
11. Information on design organizations by type of works: n/a
12. Information on the production organization/natural person:
Organisation:
Limited Liability Company «Corporation ATTA Group"
Address: Russian Federation, Moscow, Koptevskaya Street, 73a, building 5
Bank account: (redacted)
Corr. Account: ________________________________________________
Details of the Licence to carry out activities for the preservation of cultural heritage sites:
Registration number MCRF 01019
Date of issue 12.08.2013
Authorised representative: Vedenkina Yulia Aleksandrovna
Contact telephone number: (redacted)
13. Information on production organizations by type of works: n/a
14. Information about the previously made research and design documentation and possibility of using
thereof: Research and design documentation for the restoration of the monument of architecture
"Bakhchisarai palace and park complex (Khan’s Palace') Khan Mosque. Preliminary works.”
15. Composition and content of research and design documentation on the preservation of cultural
heritage objects (general, by stage, local works):
Section 1: Preliminary work: Required priority emergency works phase of the Khan Mosque -
explanatory note, working documentation, local cost estimates
Section 2: Integrated scientific research: required
1. pre-production stage - preparatory work
2. production stage – as needed
Section 3: Restoration and adaptation design (indicating whether options need to be developed,
including on a competitive basis):
1. schematic design (architectural solutions) – required
2. design – required
Section 4: Detailed Research and Design Documents: Required
Annex 24 Exhibit A
1. pre-production stage – Working architectural and construction drawings. Estimated
cost documentation in paper and electronic form.
2. production stage - Refinement and adjustment of design solutions (as needed)
Section 5: Scientific-restoration report: draw up a report on the results of the repair-restoration
work.
To be submitted to the State Committee for the Protection of Cultural Heritage of the Republic of Crimea
within 90 working days from the date of completion of these works. A report shall include:
- recording and assessing the conformity of the work carried out with the approved design solutions;
- justified deviations from the design as a result of newly identified data, with appropriate adjustments to
the design and estimate documentation prior to completion of the works;
- A description of the work carried out, indicating the technologies, materials, structures and equipment
used; a scientific assessment of the work carried out and recommendations for further maintenance and
operation;
- photographic material describing the monument before, during and after the work (with a fixed
date).
16. Type and composition of demonstration materials: Not required
17. The procedure and conditions for the approval of the scientific and design documentation, indicating
authorities and organisations:
The design documentation is submitted for approval to the State Committee for Cultural Heritage
Protection of the Republic of Crimea in 4 copies along with the acts of the State Historical and Cultural
Expert Examination of the scientific and design documentation for the preservation of the cultural
heritage object in paper and electronic forms. If the works on the preservation of the cultural heritage
object affect the structural and other characteristics of the reliability and safety of the object, these works
are performed with a positive conclusion of the State expert examination of the design documentation
provided in accordance with the Urban Development Code of the Russian Federation, and subject to State
construction supervision over such works and State supervision in the field of protection of cultural
heritage objects.
18. Requirements for scientific guidance, design and technical supervision, with indication of duration:
Highly qualified specialists and scientists to be consulted. Authors’ supervision, scientific supervision and
technical supervision required.
19. Need to carry out experimental works on technology and methods of work with indication of types
of work: as needed.
20. Initial and permit documentation to be submitted by the Client:
State contract, assignment for works on preservation of the cultural heritage object, documents certifying
the right to use the cultural heritage object; protection agreement; act of determining the impact of the
proposed works on structural and other characteristics of reliability and safety of the cultural heritage
object (architectural and cultural monument) of the peoples of the Russian Federation.
Annex 24 Exhibit A
21. Need to collect and prepare initial and permit documentation to provide technical assistance to the
Customer with a list of documents: as needed.
22. Additional requirements and conditions:
Develop measures to ensure accessibility for people with disabilities when carrying out a full restoration
project.
The Urban Planning Code of the Russian Federation of 01.01.2001 provides for the development of the
above measures and technical solutions as part of a separate section of the design documentation
"Measures to provide access for persons with disabilities" (Article 48 (12) (10) of the Code)
The assignment prepared by:
Director General
ATTA Group Corporation Ltd Natalya Valerievna Kryakvina

Exhibit B
State Committee for the Protection of the Cultural Heritage of the Republic of Crimea, Permit
for the performance of works to preserve cultural heritage sites included in the Unified State
Register of Cultural Heritage Sites (historical and cultural monuments) of the peoples of the
Russian Federation No. 01-03/1415, 10 March 2017
(translation)

Annex 24 Exhibit B
Translation
State Committee for the Protection of the Cultural Heritage of the Republic of Crimea,
Permit for the performance of works to preserve cultural heritage sites included in the
Unified State Register of Cultural Heritage Sites (historical and cultural monuments) of the
peoples of the Russian Federation No. 01-03/1415, 10 March 2017.
STATE COMMITTEE FOR THE PROTECTION OF THE CULTURAL HERITAGE
OF THE REPUBLIC OF CRIMEA
__________________________________________________________________________
14 Gogolya str., Simferopol, Republic of Crimea, Russian Federation, 295011
Tel./fax:24-76-62 e-mail: mail@gkokn rk.gov ru
OGR 1149102018493; INN / KPN 9102012851/910201001
10.03.17 No. 01-03/1415
PERMIT
for the performance of works to preserve cultural heritage sites included in the Unified
State Register of Cultural Heritage Sites (historical and cultural monuments) of the peoples of
the Russian Federation
In accordance with Article 45(2) of Federal Law No. 73-FZ of 25 June 2002 “On Objects
of Cultural Heritage (historical and cultural monuments) of the Peoples of the Russian
Federation”, this permit is issued to:
Limited Liability Company “Corporation ATTA Group”,
INN 7743797029
OGRN/OGRNIP 1107746869092
Address: 125239, Russian Federation, Moscow, Koptevskaya Street, 73a, building 5
Licence for the performance of activities to preserve objects of cultural heritage:
Issued 12.08.2013 No. MKRF 01019
Types of works: scientific research (test-pitting, trial-trenching)
When inspecting foundations, works should be performed pursuant to GOST R 55627-
2013.
Object of cultural heritage: The Khan’s Palace (XVI-XIX centuries), Khan Mosque
Address (acc. to BTI): Republic of Crimea, Bakhchisarai, Rechnaya Street, 133, des. Ш.
Grounds for the Permit: Contract (Additional Agreement #8 dated 23.12.2016 to State
Contract #16 dated 29.12.2015)
According to: Plan showing locations of field exploration work in the form of trial trenches
and test pits at the object of cultural heritage “Khan’s Palace (XVI-XIX centuries), Khan
Mosque” at address: Republic of Crimea, Bakhchisarai, Rechnaya Street, 133, des. Ш.
Documentation developed by:
Limited Liability Company “Corporation ATTA Group”,
INN 7743797029
OGRN/OGRNIP 1107746869092
Address: 125239, Russian Federation, Moscow, Koptevskaya Street, 73a, building 5
Licence for the performance of activities to preserve objects of cultural heritage:
Issued 12.08.2013 No. MKRF 01019.
Annex 24 Exhibit B
This Permit is issued for the period until 30 April 2017.
Chairman of the State Committee (signature) S.A. Efimov
(Round Seal)
Exhibit C
O. Gayvoronskiy, A CEMETERY OF CRIMEAN KHANS IN BAKHCHISARAY PALACE.
SCHEME AND CATALOGUE OF MONUMENTS (DOLYA, 2006)
(excerpt, translation)

Annex 24 Exhibit C
Excerpt
Translation
O. Gayvoronskiy, A CEMETERY OF CRIMEAN KHANS IN BAKHCHISARAY PALACE. SCHEME AND
CATALOGUE OF MONUMENTS (DOLYA 2006).
Annex 24 Exhibit C
Oleksa Gayvoronskiy
A CEMETERY OF CRIMEAN KHANS
IN BAKHCHISARAY PALACE
Oleksa Gayvoronskiy
BAGÇASARAY'DAKI KIRIM HANLARINA AIT MEZARLIK
Simferopol
DOLYA
2006
Annex 24 Exhibit C

Annex 25
Witness Statement of Valentina Vasilyevna Lavrik, 7 March 2023
(translation)

Annex 25
INTERNATIONAL COURT OF JUSTICE
APPLICATION OF THE INTERNATIONAL CONVENTION
FOR THE SUPPRESSION OF THE FINANCING OF TERRORISM AND
INTERNATIONAL CONVENTION ON THE ELIMINATION OF
ALL FORMS OF RACIAL DISCRIMINATION
(UKRAINE V. RUSSIAN FEDERATION)
WITNESS STATEMENT OF
VALENTINA VASILYEVNA LAVRIK
7 MARCH 2023
Annex 25
Page 2 out of 8
Annex 25
Page 3 out of 8
1. I, Valentina Vasilyevna Lavrik, declare the following.
2. Since December 2019, I have been heading the Ministry of Education, Science and Youth
of the Republic of Crimea (hereinafter, “Ministry of Education”). I received my education
as a teacher of the Ukrainian language, worked for a long time as a teacher and director
in schools where instruction was in the Ukrainian language.
3. In this witness statement, I provide explanations on issues relating to the activities of the
Ministry of Education and also comment on a number of allegations set out in Ukraine's
Memorial and its Reply to the Russian Federation's Counter-Memorial on the dispute
under the Convention on the Elimination of All Forms of Racial Discrimination.
4. This witness statement is based on my experience at the Ministry of Education and the
material referenced below.
A. TEACHING UKRAINIAN AND CRIMEAN TATAR LANGUAGES IN CRIMEA
5. I fundamentally disagree with Ukraine’s assertion that since Crimea’s reunification with
the Russian Federation, Russian authorities have consistently restricted opportunities for
education in the Ukrainian and Crimean Tatar languages in Crimea.
6. As for the Crimean Tatar language, there are 7 300 students studying in the Crimean Tatar
language in Crimea in the 2022/2023 school year, with a total of 33 351 students studying
the Crimean Tatar language. These figures are significantly higher than the 5 551
students, according to Ukraine, taught in the Crimean Tatar language in the 2013/2014
school year, before Crimea’s reunification with Russia. 1 Those statistics show that
Ukraine's allegations are unfounded.
7. As for the Ukrainian language, the number of students receiving their academic
instruction in that language has indeed decreased. However, Ukraine’s argument that the
Russian authorities are to blame for this reduction disregards a number of objective
reasons for a drastic reduction in demand for the study of Ukrainian language.
8. First, learning Ukrainian was not popular in Crimea even before 2014. Even ethnic
Ukrainians living in Crimea overwhelmingly considered Russian to be their native
1 Memorial, ¶536.
Annex 25
Page 4 out of 8
language. Before 2014, only 7% of students were taught in Ukrainian, and this figure has
been decreasing year by year. 2
9. Second, after Crimea’s reunification with the Russian Federation, Crimean students have
much more opportunities to enter Russian universities, which are more prestigious than
Ukrainian ones.3
10. Third, given the unpopularity of the Ukrainian language in Crimea, instruction in it was
necessary primarily for students intending to build a career in fields in which knowledge
of the Ukrainian language was essential. Such spheres were primarily civil service,
military service and philology. After the reunification of Crimea with the Russian
Federation, knowledge of the Ukrainian language is no longer a prerequisite for civil and
military service. As for philology, Crimean universities, in particular Crimean Federal
University n.a. Vernadsky (KFU) and Crimean Engineering and Pedagogical University
n.a. Fevzi Yakubov (KIPU) still have educational programmes for specialists in the
Ukrainian language.
11. Fourth, after the reunification of Crimea with the Russian Federation, the Ukrainian
authorities have demonstrated that students from Crimea have no place in Ukraine. I am
referring, in particular, to Letter No. 1/9-535 of the Ministry of Education and Science of
Ukraine dated 14 October 2014.4 The letter stipulates that, for the purposes of entering
Ukrainian higher education institutions, any documents of education issued by the
Russian authorities in Crimea are void. In order to be considered to have graduated from
school and be able to enter a Ukrainian university, Crimean schoolchildren (the vast
majority of whom are minors), according to the Ukraine authorities’ instructions, must
leave their homeland and move from Crimea to Ukraine to complete their education in a
2 Counter-Memorial (CERD), ¶¶294-295.
3 Thus, in 2023, the Times Higher Education world ranking included 77 Russian universities and only 10 Ukrainian
ones. Among 1,799 universities, the most prestigious Russian university (Lomonosov Moscow State University)
ranks 163, while the most successful Ukrainian university (Sumy State University) is not even in the first 400
universities. See Interfax, Times Higher Education World University Rankings 2023 (14 October 2022), available
at: https://academia.interfax ru/ru/analytics/research/9301/ (Exhibit A); Osvita.UA, 10 Ukrainian universities
included in The Times World University Rankings (14 October 2022), available at:
https://ru.osvita.ua/vnz/rating/87567/ (Exhibit B).
4 Ministry of Education and Science of Ukraine, Letter No. 1/9-535 “On the organisation of education in general
educational institutions for persons residing in the temporarily occupied territory in the Autonomous Republic of
Crimea, Sevastopol and anti-terrorist operation locations in Donetsk and Lugansk regions”, 14 October 2014,
available at: https://don kyivcity.gov.ua/files/2014/10/17/sodo1.pdf (Exhibit C).
Annex 25
Page 5 out of 8
Ukrainian school. Needless to say, when the Ukrainian authorities “said goodbye” to all
Crimean schoolchildren in that way, mass study of the Ukrainian language was out of the
question: students did not associate their lives with enrolment in Ukrainian universities
anymore, and, consequently, with the Ukrainian language. At the same time, the Russian
Federation offered quotas for students from Crimea to study at universities.5 In a situation
where Ukraine is telling Crimean schoolchildren at the state level that it does not need
them, while Russian institutions are ready to accept students from Crimea en masse,
schoolchildren's interest in studying Russian and the lack of demand for Ukrainian seem
to me absolutely natural.
12. Between 2014 and 2019, I was the director of the Simferopol Academic Gymnasium,
which also taught in Ukrainian, besides other languages. I witnessed with my own eyes
the decline in demand for instruction in Ukrainian; the management was forced to respond
to the decline in demand by reducing the number of classes instructed in Ukrainian.
Schools cannot force students to choose Ukrainian as the language of instruction;
however, educational institutions are willing to teach in Ukrainian if demand grows.
13. Moreover, the Ministry of Education is currently working with the Federal Institute of
Native Languages of the Peoples of the Russian Federation to develop new Ukrainian
language textbooks for 5-9 grades.
14. Besides, the Ministry is working on the construction of a new building in Feodosiya for
School No. 20 with the instruction in Ukrainian. As far as I know, the city administration
has already allocated a land plot of more than 2.5 hectares for the new building; work is
under way to ensure financing of 500 million roubles for the construction works.
B. SVITANOK SCHOOL
15. The closure of the Svitanok group, contrary to Ukraine's unfounded allegations, does not
indicate the “elimination” of Ukrainian culture by the Russian authorities in Crimea and
does not show restrictions on the activities of children's groups promoting Ukrainian
culture.
5 On that topic, see, e.g. RBC, Crimean Quote (22 July 2014), available at:
https://www.rbc ru/newspaper/2014/07/22/56be2aba9a7947299f72ccb2 (Exhibit D).
Annex 25
Page 6 out of 8
16. First of all, the closure of the group was due to the fact that its head Alla Petrova had
voluntarily quit her job at the House of Children's and Youth Creativity (hereinafter,
“House of Children's Creativity”). Before leaving the job, Alla Petrova had never
complained to the Ministry of Education about the work of the administration of the
House of Children's Creativity.
17. Second, I have found that Ukraine refers only to an article by the British newspaper The
Guardian in support of its claims about the situation with the Svitanok group. The article
contains obvious distortions of the facts, for example, it states that the House of
Children’s Creativity is under the auspices of the Ministry of Culture of the Republic of
Crimea, although in fact it is under the auspices of the Ministry of Education. Thus, I
have good reason to believe that the authors of the article either did not understand the
real situation or deliberately tried to mislead the readers.
18. Third, Ukraine has ignored the information of the House of Children’s Creativity that
children from Svitanok were invited to take part in other hobby groups (including theatre)
existing at the House of Children’s Creativity, including in the Ukrainian language.6
19. Fourth, the House of Children's Creativity reported that it had studios whose repertoire
included Ukrainian art.7 The situation is not unique: children’s and youth groups all over
Crimea regularly perform Ukrainian art at various festivals and competitions. Here are
just a few examples:
(a) In 2016, the Ministry of Education organised the annual “Crimean Terem House”
music festival dedicated to the cultures of the peoples of Russia, including
Ukrainian culture.
i) In 2018, the winner of the festival was the “Ulybka” (“Smile”) Ensemble of the
Alushta Children's Creativity Centre, who performed the Ukrainian Hutsul
Dance.8
6 Annex 644 to the Counter-Memorial (CERD), p. 2.
7 Annex 644 to the Counter-Memorial (CERD), p. 3.
8 Crimean Newswire, III “Crimean Terem House” Open Festival-Contest of Children's Folklore Groups held in
Crimea (3 December 2018), available at: https://crimea-news.com/society/2018/12/03/465715.html (Exhibit E).
Annex 25
Page 7 out of 8
ii) In 2019, the winner of the festival was the “Pearl of Crimea” Ensemble of the
Kerch Educational Complex/Boarding School-Lyceum of Arts, which performed
the Ukrainian Veselka dance. 9
(b) At the Hopes of Europe International Competition in 2020, the “Vesnyanka” folk
dance group (of the above-mentioned House of Children's Creativity) won a
second-degree diploma with the Ukrainian “Transcarpathian Dance”.10
(c) At the 2018 Sevastopol Dance Festival, several groups performed Ukrainian
dances: the “Sudarushka” Ensemble of the Sevastopol Palace of Culture performed
the Ukrainian Khorovod, 11 the “Sevastopol” Ensemble performed the Hutsul
Dance, and the “Crimean Pearl” Ensemble from Saki performed the “Spring Spell”
dance composition based on Ukrainian folk motifs.12
(d) At the 2017 “Choreographic Recognition of Crimea” festival, the “Mozaica”
Ensemble of the Children’s Choreographic School in Simferopol was remembered
for its performance of the Ukrainian Pleskach dance.13
20. Thus, Ukraine's claims that the Crimean or Russian authorities are hindering the
dissemination of Ukrainian culture, including Ukrainian children's art, are pure
speculation and in contradiction to real situation.
21. I hereby confirm that, to the best of my knowledge and beliefs, the information set out in
this witness statement is true.
9 State Budgetary General Education Institution of the Republic of Crimea “Kerch Educational Complex/Boarding
School-Lyceum of Arts”, Pearl of Crimea Dance Ensemble - Winner of the Republican Competition “Crimean
Terem House” (6 December 2019), available at: http://liceyiskusstv.
ru/news/ansambl_tanca_zhemchuzhina_kryma_pobeditel_respublikanskogo_konkursa_krymskij_terem/
2019-12-06-1123 (Exhibit F). Ukrainian dances are Pearl of Crimea’s hallmark – See Pearl of Crimea performance
of the Ukrainian dance “Pleskach”: YouTube, Valera Mouzyka, Ukrainian dance "Pleskach" (17 June 2018),
available at: https://www.youtube.com/watch?v=s58n97jdJ-k&ab_channel=ValeraMouzyka (Exhibit G).
10 YouTube, Russia’s Young Talents, Transcarpathian dance. The folk-dance ensemble “Vesnyanka” from
Simferopol performs at the competition in Sochi (20 January 2020), available at:
https://www.youtube.com/watch?v=XVlSJf-SafQ (Exhibit H).
11 YouTube, Krym Realii, Ukrainian Khorovod performed at Sevastopol dance festival (24 March 2018), available
at: https://www.youtube.com/watch?v=xIMw-tYXcfU (Exhibit I).
12 Krym.Realii, Ukrainian and European dances performed in Sevastopol (+video) (24 March 2018), available at:
https://ru.krymr.com/a/news/29121649 html (Exhibit J).
13 YouTube, MTO UFK, Crimean “Mozaica” Ensemble (Simferopol) performs Ukrainian dance “Pleskach” (28
May 2017), available at: https://www.youtube.com/watch?v=reg0-suYQi8 (Exhibit K).
Annex 25
Page 8 out of 8
Witness
[Signature]
Valentina Vasilievna Lavrik
Simferopol, 7 March 2023
Annex 25
LIST OF EXHIBITS
Number: Name of exhibit:
Exhibit A Interfax, Times Higher Education World University Rankings 2023 (14
October 2022).
Exhibit B Osvita.UA, 10 Ukrainian universities included in The Times World
University Rankings (14 October 2022).
Exhibit C Ministry of Education and Science of Ukraine, Letter No. 1/9-535 “On the
organisation of education in general educational institutions for persons
residing in the temporarily occupied territory in the Autonomous Republic
of Crimea, Sevastopol and anti-terrorist operation locations in Donetsk and
Lugansk regions”, 14 October 2014.
Exhibit D RBC, Crimean Quote (22 July 2014).
Exhibit E Crimean Newswire, III “Crimean Terem House” Open Festival-Contest of
Children's Folklore Groups held in Crimea (3 December 2018).
Exhibit F State Budgetary General Education Institution of the Republic of Crimea
“Kerch Educational Complex/Boarding School-Lyceum of Arts”, Pearl of
Crimea Dance Ensemble - Winner of the Republican Competition
“Crimean Terem House” (6 December 2019).
Exhibit G YouTube, Valera Mouzyka, Ukrainian dance “Pleskach” (17 June 2018).
Exhibit H YouTube, Russia’s Young Talents, Transcarpathian dance. The folk-dance
ensemble “Vesnyanka” from Simferopol performs at the competition in
Sochi (20 January 2020).
Exhibit I YouTube, Krym Realii, Ukrainian Khorovod performed at Sevastopol
dance festival (24 March 2018).
Exhibit J Krym.Realii, Ukrainian and European dances performed in Sevastopol
(+video) (24 March 2018).
Annex 25
Exhibit K YouTube, MTO UFK, Crimean “Mozaica” Ensemble (Simferopol)
performs Ukrainian dance “Pleskach” (28 May 2017).
Exhibit A
Interfax, Times Higher Education World University Rankings 2023 (14 October 2022)
(translation)

Annex 25 Exhibit A
Translation
Interfax, Times Higher Education World University Rankings 2023 (14 October 2022),
available at: https://academia.interfax.ru/ru/analytics/research/9301/.
InterFax
Education
Times Higher Education World University Rankings 2023
14 October 2022 at 06:18 PM
Moscow, 14 October, Interfax – The British publication Times Higher Education (THE) has
presented Times Higher Education World University Rankings 2023. This time, the rankings
include 1,799 universities from 104 countries and regions of the world. Russia is represented
by 77 universities, with the Lomonosov Moscow State University ranking at the 163rd place –
the highest position among them.
THE World University Rankings are prepared annually based on 13 performance indicators
grouped into the following five areas:
1) Teaching (30%), including reputation survey (15%), staff-to-student ratio (4.5%),
doctorate-to-bachelor’s ratio (2.25%), doctorates-awarded-to-academic-staff ratio (6%), and
institutional income (income-to-staff ratio) (2.25%).
2) Research (30%), including reputation survey (18%), research income (research-income-tostaff
ratio) (6%), and research productivity (academic-publications-to-staff ratio) (6%).
3) Citations (30%) consisting of one indicator: impact factor of academic citations (countrynormalised
average number of citations of one academic publication).
4) International outlook (7.5%), including proportion of international students (2.5%),
proportion of international staff (2.5%), and international collaboration, which is the
proportion of a university’s publications that have at least one international co-author of a
university’s publications total publications for a five-year period (2.5%).
5) Industry income (knowledge transfer) (2.5%) consisting of one indicator measuring a
university’s income from industry-ordered research per university’s staff member.
THE World University Rankings’ coverage is continually expanded. This year, it includes
1,799 universities – an increasingly higher number compared to 1,662 in 2021 and 1,527 in
2020.
The Oxford University has been ranking the highest for the seventh year in a row. The leading
group of the top 10 institutions includes seven U.S. and three UK universities.
Times Higher Education 2023 Top 10 World Universities
Rank Name Overall Teaching Research Citations Industry
Income
International
Outlook
Annex 25 Exhibit A
1 University of Oxford 96.4 92.3 99.7 99 74.9 96.2
2 Harvard University 95.2 94.8 99 99.3 49.5 80.5
3 University of Cambridge 94.8 90.9 99.5 97 54.2 95.8
3 Stanford University 94.8 94.2 96.7 99.8 65 79.8
5 Massachusetts Institute of Technology 94.2 90.7 93.6 99.8 90.9 89.3
6 California Institute of Technology 94.1 90.9 97 97.3 89.8 83.6
7 Princeton University 92.4 87.6 95.9 99.1 66 80.3
8 University of California, Berkeley 92.1 86.4 95.8 99 76.8 78.4
9 Yale University 91.4 92.6 92.7 97 55 70.9
10 Imperial College Landon 90.4 82.8 90.8 98.3 59.8 97.5
The list of Russian universities is topped by the Lomonosov Moscow State University (163),
with MIPT ranking in the 201-250 group, Peter the Great St. Petersburg Polytechnic
University, in the 301-350 group, and HSE University and MEPhI, in the 401-500 group.
17 Russian universities were assessed for the first time. Among them, the Financial University
under the Government of the Russian Federation ranked the highest in the 601-800 group.
Russian universities performed showed the highest results in terms of industry income:
MEPhI got 100 scores, and the Lomonosov Moscow State University and MIPT, 99.1 each.
Citations remain the weakest point for Russian universities: it is this indicator they showed
the poorest results for.
Russian Universities in THE World University Rankings 2023
Rank 2023 Name Overall Teaching Research Citations Industry
Income
International
Outlook
163 Lomonosov Moscow State University 56.9 81 72.9 9.3 99.1 72.4
201-250 Moscow Institute of Physics and Technology (MIPT) 51.2-54.3 55.7 46.8 51.4 99.1 62.2
301-350 Peter the Great St. Petersburg Polytechnic University 47.0-48,7 31.1 23.7 83 75.5 57.4
401-500 HSE University 42.1-44.9 32.5 45.3 54.6 61.6 43.9
401-500 National Research Nuclear University MEPhI 42.1-44.9 45.3 41.7 29.1 100 70
501-600 Bauman Moscow State Technical University 39.3-42.0 56.6 32 23.8 81 49.5
501-600 Saint-Petersburg Mining University 39.3-42.0 22.6 14.5 83.3 82.3 35.3
601-800 Financial University under the Government of the
Russian Federation 34.0-39.2 18.8 14.6 71.1 39.7 23.7
601-800 National University of Science and Technology
(MISiS) 34.0-39.2 30.7 22.2 38.3 85.9 64.6
601-800 Plekhanov Russian University of Economics 34.0-39.2 21.9 12.2 66.7 40.1 42.1
601-800 RUDN University 34.0-39.2 38 21.5 37.9 43.4 63.5
Annex 25 Exhibit A
601-800 Tomsk State University 34.0-39.2 41.5 374 18 88.7 73.5
801 1000 ITMO University 29.8-33.9 28.8 32.6 28.2 71.7 65.5
801-1000 Kazan Federal University 29.8-33.9 38.8 19.7 23.9 50.7 61.8
801-1000 Novosibirsk State University 29.8-33.9 39.2 34 16.6 39.2 46.5
801-1000 Saint Petersburg State University 29.8-33.9 46.3 39.7 11.9 39.7 45.7
801-1000 Sechenov University 29.8-33.9 27.3 15.7 38.8 42.7 56.7
801 1000 South Ural State University 29.8-33.9 17 13.3 64.9 41.6 41.6
1001-1200 Don State Technical University 24.4-29.7 17 8.8 61.5 38.2 27.1
1001-1200 Tomsk Polytechnic University 24.4-29.7 31.5 20.2 19.3 684 63.8
1001-1200 Ufa State Petroleum Technological University 24.4-29.7 18.5 8.7 61.9 36.9 24.9
1201-1500 Altai State University 184-24.3 18.8 15 11.8 43.2 55.9
1201-1500 Far Eastern Federal University 18.4-24.3 27.7 18.4 16.1 43.6 53.9
1201-1500 Immanuel Kant Baltic Federal University 18.4-24.3 30.7 15 12.6 48.3 53.3
1201-1500 Irkutsk National Research Technical University 18.4-24.3 17.7 9.6 34.5 43 26.2
1201-1500 Kazan National Research Technical University 18.4-24.3 17.8 12.3 31.4 51.1 27.6
1201-1500 Kazan National Research Technological University 184-24.3 18 9.2 38.6 52.1 32.2
1201-1500 Kazan State Medical University 18.4-24.3 39.4 9.2 1.2 36.9 42.4
1201-1500 Lobachevsky State University of Nizhni Novgorod 184-24.3 264 12,5 9.9 46.4 34.4
1201-1500 Moscow Aviation Institute 18.4-24.3 25.4 12.7 23 70.9 27.5
1201-1500 Moscow State University of Civil Engineering 184-24.3 18.1 11.3 32.8 53.6 23
1201-1500 National Research University of Electronic
Technology (MIET) 184-24.3 39.7 13.5 34 78 22.9
1201-1500 National Research Saratov State University 18.4-24.3 21.3 13.5 14.3 43.7 33.9
1201-1500 Pirogov Russian National Research Medical
University 18.4-24.3 42.1 11.2 3.1 40.8 20.8
1201-1500 Samara National Research University (Samara
University) 18.4-24.3 213 15.4 17.6 42.8 36.5
1201-1500 Siberian Federal University 184-24.3 24.8 19.6 17 684 54.9
1201-1500 Southern Federal University 184-24.3 222 134 13 48.2 37.3
1201-1500 St. Petersburg Electrotechnical University (LETI) 184-24.3 142 154 14 54.8 38.1
1201-1500 Ural Federal University 18.4-24.3 23.8 23.2 15 62.9 55.2
1201 1500 Volgograd State Technical University 18.4-24.3 15.9 9.6 39.2 38.8 23
1201-1500 Voronezh State Technical University 184-24.3 19.7 8.7 404 38.6 20.5
1501+ Bashkir State University 104-18.3 16.3 9.3 4.2 40.2 17.9
Annex 25 Exhibit A
1501+ Belgorod State National Research University 104-18.3 192 114 7.8 50.6 38.3
1501+ Gubkin Russian State University of Oil and Gas 104-18.3 18 10.6 11.6 53.1 24.5
1501+ Industrial University of Tyumen 104-18.3 17 9.5 20.1 38 20.2
1501+ Irkutsk State University 104-18.3 17.1 10 10.3 38.9 23.9
1501+ Ivanovo State University of Chemistry and
Technology 104-18.3 16.6 10 0.8 36.9 22.1
1501+ Kemerovo State University 104-18.3 16.8 9.6 2.6 394 20.3
1501+ Mendeleev University of Chemical Technology 104-18.3 17.5 13.6 6.5 47.7 20.5
1501+ MIREA- Russian Technological University 104-18.3 15.2 11.1 2.9 58.3 19.7
1501+ Moscow Polytechnic University 104-18.3 17.1 94 8.9 36.9 27.8
1501+ Moscow Power Engineering Institute 104-18.3 19.4 16.7 9.6 75.4 34.8
1501+ Nizhny Novgorod State Technical University 104-18.3 17.6 9.2 6.4 48.9 20
1501+ North-Caucasus Federal University 10.4-18.3 22.7 9 16.5 38.4 29.7
1501+ North-Eastern Federal University 104-18.3 21.5 9.7 6 37.7 23.5
1501+ Northern (Arctic) Federal University named after
M.V. Lomonosov 10.4-18.3 17.7 11 4 39.3 27.5
1501+ North-Western State Medical University named after
I.I. Mechnikov 104-18.3 22.1 8.3 1.3 36.9 25.1
1501+ Nosov Magnitogorsk State Technical University 104-18.3 15.9 10.3 5.5 38.7 17.7
1501+ Novosibirsk State Technical University 10.4-18.3 20.1 13 5.5 40.5 36.9
1501+ Ogarev Mordovia State University 104-18.3 15.5 9.2 3.2 39.7 28.9
1501+ Omsk State Technical University 10.4-18.3 16.4 8.7 6.5 38.9 32.2
1501+ Pavlov First Saint Petersburg State Medical University 104-18.3 23.1 9.2 10.6 39.7 31.4
1501+ Penza State University 104-18.3 14.1 84 9 37.3 27.5
1501+ Perm National Research Polytechnic University 10.4-18.3 19.3 10.8 3.9 67.5 24.9
1501+ Perm State University 104-18.3 18.9 11.3 2.2 42.3 20.9
1501+ Platov South-Russian State Polytechnic University
(NPI) 104-18.3 15.1 9.4 3.8 41.6 21.9
1501+ Privolzhsky Research Medical University 104-18.3 18.8 84 1.4 36.9 33.7
1501+ Russian Presidential Academy of National Economy
and Public Administration 104-18.3 20.8 16.3 6.5 41 21
1501+ Samara State Technical University 104-18.3 15.6 114 7.1 47.9 18.4
1501+ Siberian State Medical University 104-18.3 17.3 8.3 0.9 37 38.8
1501+ Southwest State University 104-18.3 17.7 10.1 7 41.1 26.9
1501+ Tomsk State University of Control Systems and
Radioelectronics 104-18.3 175 11.2 18.1 55.6 33.2
Annex 25 Exhibit A
1501+ University of Tyumen 104-18.3 16.6 12.7 9 41.1 34.5
1501+ Ufa State Aviation Technical University 104-18.3 15.8 9.5 8.7 42.7 18
1501+ V.I. Vernadsky Crimean Federal University
(Vernadsky CFU)** 104-18.3 17.1 8.6 6.5 37.1 24.1
1501+ Voronezh State University 104-18.3 18.8 10.2 3.3 37.9 34.7
1501+ Yuri Gagarin State Technical University of Saratov
(SSTU) 104-18.3 12.5 8.9 7.2 37.5 16.7
Reporter Almazov National Medical Research Centre n/a n/a n/a n/a n/a n/a
Reporter Bashkir State Medical University n/a n/a n/a n/a n/a n/a
Reporter Derzhavin Tambov State University n/a n/a n/a n/a n/a n/a
Reporter
Donetsk National University of Economics and Trade
named after Mykhailo Tuhan-Baranovsky
(DonNUET)**
n/a n/a n/a n/a n/a n/a
Reporter Dostoevsky Omsk State University n/a n/a n/a n/a n/a n/a
Reporter Innopolis University n/a n/a n/a n/a n/a n/a
Reporter Ivanovo State University n/a n/a n/a n/a n/a n/a
Reporter Kabardino-Balkarian State University n/a n/a n/a n/a n/a n/a
Reporter Kazan State Power Engineering University n/a n/a n/a n/a n/a n/a
Reporter Moscow Pedagogical State University n/a n/a n/a n/a n/a n/a
Reporter Moscow State University of Food Production n/a n/a n/a n/a n/a n/a
Reporter Moscow State Linguistic University n/a n/a n/a n/a n/a n/a
Reporter Novosibirsk State University of Economics and
Management n/a n/a n/a n/a n/a n/a
Reporter Omsk State Agrarian University n/a n/a n/a n/a n/a n/a
Reporter Orel State Agrarian University named after N.V.
Parahin n/a n/a n/a n/a n/a n/a
Reporter Orel State University named after 15. Turgenev n/a n/a n/a n/a n/a n/a
Reporter Rostov State University of Economics n/а n/а n/а n/а п/а n/а
Reporter Russian State Agrarian University - Moscow
Timiryazev Agricultural Academy n/а n/а n/а n/а п/а n/а
Reporter Russian State University for the Humanities n/а n/а n/а n/а n/а n/а
Reporter Russian State Social University n/а n/а n/а n/а n/а n/а
Reporter Ryazan State Medical University n/а n/а n/а n/а n/а n/а
Reporter Saint Petersburg State Pediatric Medical University n/а n/а n/а n/а n/а n/а
Reporter Samara State University of Economics n/а n/а n/а n/а n/а n/а
Reporter Samara State Medical University n/а n/а n/а n/а n/а n/а
Annex 25 Exhibit A
Reporter State University of Land Use Planning n/а n/а n/а n/а n/а n/а
Reporter Tomsk State Pedagogical University n/а n/а n/а n/а n/а n/а
Reporter Ural State Medical University n/а n/а n/а n/а n/а n/а
Reporter Volgograd State University n/а n/а n/а n/а n/а n/а
* “Reporter” means a university that has submitted data for including in the rankings but fails to meet any of the inclusion criteria. 526
universities were considered to be “Reporters” in THE 2023 World University Rankings 2023.
** The V.I. Vernadsky Crimean Federal University and the Donetsk National University of Economics and Trade named after Mykhailo
Tuhan-Baranovsky are considered to be Ukrainian institutions by Times Higher Education.
Exhibit B
Osvita.UA, 10 Ukrainian universities included in The Times World University Rankings
(14 October 2022)
(translation)

Annex 25 Exhibit B
Translation
Osvita.UA, 10 Ukrainian universities included in The Times World University Rankings
(14 October 2022), available at: https://ru.osvita.ua/vnz/rating/87567/.
10 Ukrainian universities included in The Times World University
Rankings
Osvita.ua
14 October 2022
Times Higher Education
World University Rankings
2023 Includes 10 Ukrainian
Universities
Times Higher Education World University Rankings 2023 includes 10 Ukrainian universities.
This year, the list includes a total of 1,799 universities from 104 countries and regions.
The compilers of the list note it is based on 13 carefully calibrated performance indicators
grouped into the following four categories: teaching, research, knowledge transfer, and
international outlook.
The Sumy State University ranked the highest among all Ukrainian universities – it was
included in the 401-500 group.
The Lvov Polytechnic National University ranked the second, in the 601-800 group.
The Kharkov National University of Radio Electronics ranked the third, in the 1,001-1,200
group.
The other Ukrainian universities ranked in the following order:
• Ivan Franko National University of Lvov;
• National Technical University Kharkov Polytechnic Institute:
• National Technical University of Ukraine – Igor Sikorsky Kiev Polytechnic Institute;
• Oles Gonchar Dnepr National University;
• Taras Shevchenko National University of Kiev;
Annex 25 Exhibit B
• V.N. Karazin Kharkov National University; and
• Yury Fedkovych Chernivtsi National University.
The Oxford University has been topping THE World University Rankings for the last seventh
years. The Harvard University remained number two, and the University of Cambridge
climbed from the fifth place last year to the third one this year.
The United States is the most represented country in THE World University Rankings 2023,
which includes a total of 177 U.S. universities, 58 of them ranking among the top 200.
Mainland China ranked fourth in terms of the number of universities among the top 200 (11
this year compared to 10 last year) and was ahead of Australia (along with the Netherlands),
which came down to the fifth place.
Exhibit C
Ministry of Education and Science of Ukraine, Letter No. 1/9-535 “On the organisation of
education in general educational institutions for persons residing in the temporarily occupied
territory in the Autonomous Republic of Crimea, Sevastopol and anti-terrorist operation
locations in Donetsk and Lugansk regions”, 14 October 2014
(translation)

Annex 25 Exhibit C
Translation
Ministry of Education and Science of Ukraine, Letter No. 1/9-535 “On the organisation
of education in general educational institutions for persons residing in the temporarily
occupied territory in the Autonomous Republic of Crimea, Sevastopol and anti-terrorist
operation locations in Donetsk and Lugansk regions”, 14 October 2014, available at:
https://don.kyivcity.gov.ua/files/2014/10/17/sodo1.pdf.
MINISTRY OF EDUCATION AND SCIENCE OF UKRAINE
10 Peremohi Avenue, Kiev, 01135, tel. (044) 481-32-21, fax (044) 481-47-96
E-mail: [email protected], EDRPOU code 38621185
Our No. ____________ dated ____________
Your No. ___________ dated ____________
Educational and science departments/offices
of regional and Kiev municipal public
administrations
On the organisation of education in general educational
institutions for persons residing in the temporarily occupied
territory in the Autonomous Republic of Crimea,
Sevastopol and anti-terrorist operation locations in Donetsk
and Lugansk regions
Taking into account the extraordinary events taking place in the temporarily occupied
territory in the Autonomous Republic of Crimea, the city of Sevastopol and in the places of
the anti-terror operation in the Donetsk and Lugansk Regions, the Ministry of Education and
Science of Ukraine hereby provides its explanations on the further teaching of students and
the issuance of official documents of education to graduates.
We stress that any statements made or actions taken by terrorist organisations to imitate the
“educational processes” are legally null and void and will not be recognised. Similarly, no
“documents of education” issued by the occupation entities of the Russian Federation
and the self-proclaimed “authorities” on the Crimean Peninsula or by the terrorists in
the part of the territory of the Donetsk and Lugansk Regions under their temporary
control currently have or will have in the future any legal force. Neither the Ministry of
Education and Science nor any other governmental authorities in Ukraine or elsewhere
will “recognise”, “nostrificate” or “exchange” any such “documents”.
The parents of those students, especially 11th graders, residing in the temporarily occupied
territory in the Autonomous Republic of Crimea, the city of Sevastopol and in the places of
the anti-terror operation in the Donetsk and Lugansk Regions should be recommended to take
steps to enable their children to undergo the required procedures, obtain official documents of
Annex 25 Exhibit C
education and have a chance to enter vocational or higher educational institutions of Ukraine
in the spring of 2015.
More specifically, under the current laws of Ukraine, those students residing in the
aforementioned areas and wishing to obtain an official document of education may continue
their studies in Ukraine in all forms available (such as daytime, evening, distant, external,
individual or group). The procedure for admission to general educational institutions is
prescribed by regulatory documents.
Given the situation that poses a threat to the life and health of children, we instruct all local
educational authorities and heads of general educational institutions to help resolve the issues
of admission to those institutions and the passage of the official final certification in 2015, to
create the necessary conditions in advance and also to treat children in difficult life
circumstances with understanding.
We draw your attention to the fact that the Regulation on Externship in General Educational
Institutions as approved by Ministry of Education and Science of Ukraine Order No. 431
dated 19 May 2008 and registered by the Ministry of Justice of Ukraine on 3 June 2008 under
No. 498/15189 stipulates that the possibility to pass an annual assessment for the
corresponding class and a certification of their educational level corresponding to the primary,
basic or complete general secondary education is granted, in particular, to those persons who
are unable to attend classes in a general education institution for any valid reasons (Clause
1.3).
In order to pass the annual assessment and certification, in addition to an application
addressed to the head of an educational institution, each extern shall also submit a document
of his or her education. When passing an external annual assessment for a subject or a course
of study in another educational institution, each extern shall submit a certificate signed by the
head, and sealed by the seal, of the educational institution where his/her external training took
place. In any extern has no document of education, the educational institution offering
external training shall independently determine the educational level of such external. For this
purpose, a commission shall be established by order of the head of said educational institution
to consist of the head of such commission (the head or deputy head of said educational
institution), and teachers of those subjects which the extern’s educational level is to be
determined for. The head of the commission shall draw up a schedule of events to assess the
extern’s knowledge in the relevant subjects. The members of the commission shall prepare a
list of exercises, tasks and questions for each subject. The results of the assessment and the
extern’s educational level as determined based on those results shall be formalised by a
protocol to be signed by all members of the commission (Clause 2.2).
The acceptance of applications from externs shall begin from October and, as a rule, end no
later than on the 1st of March of the current academic year (Clause 2.4).
Given the situation, the foregoing entitles the heads of the educational institutions in question
to decide, if necessary and as an exception, to admit an extern before the end of the academic
year.
The heads of the local educational authorities and educational institutions admitting externs
shall be responsible for ordering and issuing documents of general secondary education to
those persons residing in the temporarily occupied territory in the Autonomous Republic of
Crimea, the city of Sevastopol and in the places of the anti-terror operation in the Donetsk and
Annex 25 Exhibit C
Lugansk Regions. In turn, Inforesurs State Enterprise will provide the most favoured
treatment for carrying out this work.
We instruct you to bring this information to all heads of subordinate educational management
bodies and educational institutions.
[Signed]
Pavel Polyansky,
Deputy Minister
A.V. Davidovich 481 47 66
[Stamp:
Ministry of Education and Science of Ukraine
No. 1/9-535 dated 14 October 2014
Barcode]
[Stamp:
Department of Education, Science, Youth and Sports
No. 063/11090 dated 15 October 2014
Barcode]

Exhibit D
RBC, Crimean Quote (22 July 2014)
(translation)

Annex 25 Exhibit D
Translation
RBC, Crimean Quote (22 July 2014), available at:
https://www.rbc.ru/newspaper/2014/07/22/56be2aba9a7947299f72ccb2.
RBC Gazette
Crimean Quote
RBC Gazette No. 131 (1906) (2207) //1935 Society, 22 July 2014 at 01:25 AM
Crimean Quote
By Farida Rustamova, with assistance of Tatiana Klyonova
Applicants from the new territories will occupy state-funded places in Russian universities out
of usual competition.
Photo: ITAR-TASS
Admission to universities is unusual this year as graduates from Crimean schools join the
applicants. 18,000 thousand additional state-funded places have been allocated to them, which
equals the total number of graduates. They will be admitted out of general competition and
not according to the results of their Unified State Exams. The universities themselves will
Annex 25 Exhibit D
choose the methods for admitting young people from the new territories, and the situation will
remain the same at least in 2015.
In late April, a little more than one month after Crimea and Sevastopol joined Russia, the
State Duma adopted amendments to the Law on Education, which integrates the educational
systems of the new constituent entities to the all-Russian system. Under that Law, Crimean
and Sevastopol school graduates will have the option in 2014-2015 to pass the Unified State
Exams or the final exams in another form to be determined by the Ministry of Education and
Science. This year, a vast majority of Crimean schoolchildren will enter universities without
regard to the results of their Unified State Exams: only 300 out of about 18,000 graduates
expressed a desire to pass the Unified State Exams, Rossiyskaya Gazeta quoted a statement by
Minister Education and Science Dmitry Livanov. In total, according to the Ministry of
Education and Science, 18,000 additional state-funded places have been allocated in
universities subordinate to the Ministry to graduates from Crimea and Sevastopol this year.
Deputy Minister of Education and Science Alexander Klimov explains that Crimeans will
undergo entrance tests to be specified by each university independently depending on its
specialisation. The Ministry of Education and Science believes there should be at least two
entrance tests. Similar rules will be applied in 2015. According to another official in charge of
education, such preferential rules may remain in force in 2016.
Special privileges will be granted to the winners of the fourth stage of the all-Ukrainian
student Olympiads, those Ukrainian national team members who participated in international
Olympiads in general education subjects, and applicants for bachelor’s and specialist’s
educational programmes. Under law, they are equated with the winners of the final stage of
the All-Russian Schoolchildren Olympiad, and those Russian national team members who
participated in international Olympiads in general education subjects.
Those Crimean and Sevastopol residents who have not completed their studies and have been
expelled from Ukrainian universities after the annexation of Crimea will be admitted to the
relevant training courses and educational programmes at the expense of Russia’s budget.
The Ministry of Education and Science plans to extensively reform the Crimean education
system. In particular, it intends to establish a federal university in Simferopol and unite
several universities in Sevastopol into a single one.
Another 1,830 places in 12 universities in four federal districts, including Moscow, will be
allocated to refugee graduates from South-East Ukraine, the Ministry of Education and
Science said in response to a request from RBC. These include the Peoples’ Friendship
University of Russia, the North Caucasus Federal University, the Southern Federal
University, etc.
Unlike Crimean graduates, refugees will be allocated places in universities from a total quota
of 15,000 places intended for foreign and stateless students in 2014. Ukrainians will be
admitted to universities as compatriots. Mr. Klimov says refugees will be provided with
places in student dormitories and humanitarian aid.
Irina Abankina, Director of the HSE Institute for Educational Development, pointed out that
the average cost of one state-funded place in a Russian university is about RUB 63,600 per
year. “Talking about priority specialties, the cost is RUB 113,000 to RUB 118,000 per year”,
Annex 25 Exhibit D
she said, adding that those industries requiring complex equipment are more expensive.
According to her, the admission of 1,500 students will only compensate for “the 0.2%
demographic decline”.
The Ministry of Education and Science has not yet been replied to RBC’s inquiries regarding
the cost of training Crimean and Ukrainian graduates.
Artyom Khromov, Russian Commissioner for Student Rights, is confident the preferential
admission conditions for graduates of Crimean schools are absolutely logical. In the same
way, foreign applicants are accepted on the basis of their interviews and additional tests.
According to him, students will have to be duly trained to pass the Unified State Exams, so it
is quite natural for Crimean applicants to choose the quota-based admission.
The preferential conditions do not violate equality among Russian graduates, Ms. Abankina
believes. “In Ukraine, there is a state exam, and we have been accepting students for statefunded
places under international treaties with the CIS countries based on quotas for years”,
she explained. According to her, many countries, including Russia, provide grants and
scholarships for foreigners.
“This is not the best but an inevitable solution. It is impossible to make a whole generation of
children hostages of Russian foreign policy and deprive them of the opportunity to enter a
university. It is reasonable that the new students will not take away places from the old ones”,
Mikhail Gelfand, a professor at the Moscow State University, comments. Nevertheless, in his
opinion, in order to restore justice, no further concessions should be made in the future for
those who have entered on preferential terms, and then weak students will deservedly “fall
off” after the first session. However, Mr. Gelfand notes, an interview, which is likely to be
chosen as an alternative to examination, is potentially a more corrupt procedure than the
Unified State Exams or regular exams as it has no assessment criteria.

Exhibit E
Crimean Newswire, III “Crimean Terem House” Open Festival-Contest of Children's Folklore
Groups held in Crimea (3 December 2018)
(translation)

Annex 25 Exhibit E
Translation
Crimean Newswire, III “Crimean Terem House” Open Festival-Contest of Children's
Folklore Groups held in Crimea (3 December 2018), available at: https://crimeanews.
com/society/2018/12/03/465715.html.
III “Crimean Terem House” Open Festival-Contest of Children's Folklore
Groups held in Crimea
The Crimean Terem Third Open Festival Contest of Children’s Folklore Groups took place
from 30 November 2018 to 2 December 2018 in Simferopol, the press service of the Ministry
of Education, Science and Youth of the Republic of Crimea reports.
According to the press service, over 450 performers, including children’s and youth vocal,
choreographic and instrumental folklore groups and soloists from nine Crimean and Russian
regions, namely the Krasnogvardeyskoye, Simferopol and Dzhankoy Districts and the cities
and towns of Feodosia, Alushta, Dzhankoy, Yevpatoria, Simferopol and Penza, took part in
the festival.
“The jury was headed by Igor Mikhailevsky, the artistic director of the vocal and
choreographic ensemble “Tauria” of the Crimean State Philharmonic and an Honoured Artist
of Ukraine and the Republic of Crimea. The contest programmes included works of various
genres, including music and song, dance, game and oral folklore, instrumental music, and
fragments of popular fests and rites”, the press service said.
Upon completion of the competitive auditions, the following ensembles became Degree I
laureates: the folk dance ensemble “Smile” (junior group) of the Centre for Children’s
Creativity in Alushta (headed by N.F. Lindegrin), who performed “Hutsul Dance” and
“Belarusian Dance”; the folk song ensemble “Sudarushka” of the Simferopol School of Arts
(headed by I.N. Andreichenko and led by A.V. Morgunov), which performed “Dubravushka”,
the wedding majestic song of the Don Cossacks, “Mountain Roosters Sing on the Mountain”,
Annex 25 Exhibit E
and the Kupala song from the Voronezh Region; the folklore ensemble “Svetlitsa” (junior
group) of the Simferopol School of Arts (headed by E.S. Mirgorodskaya and led by D.A.
Benko), who performed “Baiki-Pobaiki” based on maternal folklore; the exemplary folk
dance group “Dance College” of the Rodnikovo Rural House of Culture in the Simferopol
District (headed by L.I. Nakonechnaya), who performed “Paths” and “Greek Dance”; the
folklore ensemble “Svetlitsa” of the Simferopol School of Arts (headed by I.L.
Mikhailevskaya and led by D.A. Benko and E.V. Uvarov), who performed the Russian
Lakeland spiritual song “How the Red Sun Climbed” and the Studyonki suffering song
“Golosochek Zakatimay” from the Lipetsk Region; and the folk dance ensemble “Smile”
(junior group) of the Centre for Children’s Creativity in Alushta (headed by N.F. Lindegrin),
who performed “Dymkovo Toy” and “Vasya-Vasilyok”.
Exhibit F
State Budgetary General Education Institution of the Republic of Crimea “Kerch Educational
Complex/Boarding School-Lyceum of Arts”, Pearl of Crimea Dance Ensemble - Winner of the
Republican Competition “Crimean Terem House” (6 December 2019)
(translation)

Annex 25 Exhibit F
Translation
State Budgetary General Education Institution of the Republic of Crimea “Kerch
Educational Complex/Boarding School-Lyceum of Arts”, “Pearl of Crimea” Dance
Ensemble - Winner of the Republican Competition “Crimean Terem House” (6 December
2019), available at: http://liceyiskusstv.
ru/news/ansambl_tanca_zhemchuzhina_kryma_pobeditel_respublikanskogo_ko
nkursa_krymskij_terem/2019-12-06-1123.
State Budgetary General Education Institution of the Republic of Crimea "Kerch Educational
Complex/Boarding School-Lyceum of Arts"
Pearl of Crimea Dance Ensemble - Winner of the Republican Competition
"Crimean Terem House"
On the 5th of December at 02:00 PM, the State Academic Music and Drama Theatre in
Simferopol held a gala concert and a prize-awarding ceremony of the Crimean Terem Open
Festival Contest of Children’s Folklore Groups.
The Festival has been founded by the Ministry of Education,
Science and Youth of the Republic of Crimea. It is intended
to promote the aesthetic, moral and spiritual education of the
younger generation via the best examples of folk arts,
preserve and continue folk performing traditions, develop
national cultures, and identify and support original creative
teams and soloists. This year, 93 applications were accepted
for the Festival, and more than 700 young folk tradition followers aged from 6 to 18 years
from different parts of the Crimea presented their performance to the jury.
The exemplary folk dance ensemble “Pearl of
Crimea” of the Lyceum of Arts represented by its
mid-age group took part in the contest for the first
time. It was nominated in the category
“Choreographic Art”.
Dance is the most ancient form of art: it is
interesting, multifaceted, bright, and
emotionally charging. Long time ago, folk
dance became the ancestor of all future
dances such as classical, historical, pop, and modern. Fashion and the passage of time
could not make folk dance disappear from the life and history of various nationalities.
Until our days, every society has been sacredly preserving the memory of its previous
generations and cherishing everything what reflected their lives. Therefore, dance is a
priceless treasure preserving the life and traditions of various peoples. Taking in mind
those specific features of folk dance, teachers of the choreographic department of the Lyceum
of Arts prepared our ensemble consisting of T.V. Mamykina, A.I. Tikhonenko and E.N.
Antonova and led by Vera A. Ivanova, an Eminent Culture Worker of the Republic of
Crimea and an Excellent Educator of Ukraine, for the contest.
The ensemble successfully performed two dance routines at the contest – the cheerful Russian
Annex 25 Exhibit F
dance “Pritopy” and the incendiary Ukrainian dance “Vesyolka”.
It also performed a Ukrainian dance among the contest’s best performers at the gala concert.
Congratulations to the students and teachers on winning the contest!
Exhibit G
YouTube, Valera Mouzyka, Ukrainian dance “Pleskach” (17 June 2018)
(translation)

Annex 25 Exhibit G
YouTube, Valera Mouzyka, Ukrainian dance "Pleskach" (17 June 2018), available at:
https://www.youtube.com/watch?v=s58n97jdJ-k&ab_channel=ValeraMouzyka.

Exhibit H
YouTube, Russia’s Young Talents, Transcarpathian dance. The folk-dance ensemble
“Vesnyanka” from Simferopol performs at the competition in Sochi (20 January 2020)
(translation)

Annex 25 Exhibit H
YouTube, Russia’s Young Talents, Transcarpathian dance. The folk-dance ensemble
“Vesnyanka” from Simferopol performs at the competition in Sochi (20 January 2020),
available at: https://www.youtube.com/watch?v=XVlSJf-SafQ.

Exhibit I
YouTube, Krym Realii, Ukrainian Khorovod performed at Sevastopol dance festival
(24 March 2018)
(translation)

Annex 25 Exhibit I
YouTube, Krym Realii, Ukrainian Khorovod performed at Sevastopol dance festival (24
March 2018), available at: https://www.youtube.com/watch?v=xIMw-tYXcfU.

Exhibit J
Krym.Realii, Ukrainian and European dances performed in Sevastopol (+video)
(24 March 2018)
(translation)

Annex 25 Exhibit J
Translation
Krym.Realii, Ukrainian and European dances performed in Sevastopol (+video) (24
March 2018), available at: https://ru.krymr.com/a/news/29121649.html.
Ukrainian and European dances performed in Sevastopol (+video)
Krym.Realii
On the 24th of March, the 23rd citywide dance festival began in Sevastopol, featuring various
choreographic ensembles from the annexed Crimea, a Krym.Realii correspondent reports.
The event was held in the Sevastopolsky Palace of Culture in the suburban village of
Sakharnaya Golova. It was organised by the Palace’s administration in conjunction with the
administration of Sevastopol’s Russian Balaklava municipality.
On the first day of the festival, Russian, Ukrainian and Moldovan folk dances as well as
European classical, Chinese and Kazakh dances were performed.
The folk dance ensembles “Sudarushka” and “Sevastopol” and the Sak-based ensemble
“Crimean Pearls” performed the “Ukrainian Round Dance” in a modern arrangement, the
“Hutsul Dance” and the dance composition “Screaming for Spring” based on Ukrainian folk
motifs, respectively.
At the end of the first day of the festival, the organisers presented certificates to those
ensembles which performed folk and classical dances.
On Sunday, the 25th of March, pop dances will also be performed in the Sevastopol Palace of
Culture.

Exhibit K
YouTube, MTO UFK, Crimean “Mozaica” Ensemble (Simferopol) performs Ukrainian dance
“Pleskach” (28 May 2017)
(translation)

Annex 25 Exhibit K
YouTube, MTO UFK, Crimean “Mozaica” Ensemble (Simferopol) performs Ukrainian dance
“Pleskach” (28 May 2017), available at: https://www.youtube.com/watch?v=reg0-suYQi8.

Annex 26
Witness Statement of , 2 March 2023
(translation)

Annex 26
INTERNATIONAL COURT OF JUSTICE
APPLICATION OF THE INTERNATIONAL CONVENTION
FOR THE SUPPRESSION OF THE FINANCING OF TERRORISM AND
INTERNATIONAL CONVENTION ON THE ELIMINATION OF
ALL FORMS OF RACIAL DISCRIMINATION
(UKRAINE V. RUSSIAN FEDERATION)
WITNESS STATEMENT OF
2 MARCH 2023
Annex 26
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Annex 26
Page 4 out of 5
6. Ukraine, referring to Clement’s witness statement, claims that children who study
Ukrainian or are taught in Ukrainian are bullied and physically abused by their
classmates, and that teachers do not prevent this in any way. There are absolutely no such
incidents at School No. 20; furthermore, I, as someone familiar with the study of the
Ukrainian language in Crimea, am unaware that such incidents ever existed in other
schools in Crimea, including School No. 13 in Yevpatoria, which is listed in Clement’s
witness statement.
7. Moreover, Ukraine points out that teachers at a school in Crimea allegedly hand out prefilled
questionnaires to parents with Russian as the language of education, thereby
encouraging parents to choose. This information does not seem reliable to me, as in
School No. 20, for example, the choice of the language of instruction and the language of
study is absolutely free and does not depend on the teachers’ preferences. I have not seen
any cases of compulsion to study in Russian in other schools I know in Crimea.
8. I would also like to report that a number of changes for the better have been taking place
at School 20 thanks to the additional public funding. The long-awaited process of
renovation of the school building is a big event. In 2022, the administration of Feodosiya
allocated a plot of land on which to build a new building for School No.20, which will
accommodate over 300 students. It is planned to be a prefabricated building with a sports
ground and a playground. At present, the issue of appropriation of 500 million roubles
for its construction is being resolved and, as far as I know, the administration supports us
in our need for a new building.
9. Compared to previous school years, the number of students has increased this year. There
are now 207 children in School No. 20.
10. At the same time, the school continues to hold regular extracurricular activities related to
the Ukrainian language. In March 2022, for example, in honour of the birthday of the
great Ukrainian poet Taras Shevchenko, our school held an event called “Shevchenko’s
Days”; we annually participate in the “Language is the Spirit of Nation”.
11. High quality of Ukrainian language instruction in the school is also confirmed by the fact
that many of our students plan to take their final exams in Ukrainian.
Annex 26
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12. We would also like to point out that we welcome the use of the Ukrainian language and
respect the traditions of the Ukrainian people. Official events at School No. 20 are
bilingual - both in Ukrainian and Russian. We also honour holiday customs: this year we
are going to celebrate St Nicholas Day on 19 December and build a traditional nativity
scene.
13. As far as the teaching process, I would like to point out that the process in Ukrainian is
based on textbooks published during the Ukrainian period. All the textbooks have been
certified by the interdepartmental commission set up in 2014 and are available in our
school library. I have personally seen these textbooks.
14. I hereby confirm that, to the best of my knowledge and beliefs, the information set out in
this witness statement is true.
Witness
[Signature]
Feodosiya, 2 March 2023

Annex 27
Witness Statement of , 18 February 2023
(translation)

Annex 27
INTERNATIONAL COURT OF JUSTICE
APPLICATION OF THE INTERNATIONAL CONVENTION
FOR THE SUPPRESSION OF THE FINANCING OF TERRORISM AND
INTERNATIONAL CONVENTION ON THE ELIMINATION OF
ALL FORMS OF RACIAL DISCRIMINATION
(UKRAINE V. RUSSIAN FEDERATION)
WITNESS STATEMENT OF
18 FEBRUARY 2023
Annex 27
Page 2 out of 14
Annex 27
Page 3 out of 14
1. I, , hereby declare as follows:
2. I am
Previously, I also worked as
3. In the present witness statement I will respond to a number of allegations made by
Ukraine in the Memorial and Reply to the Counter-Memorial of the Russian Federation
in the proceedings before the International Court of Justice initiated by Ukraine. In
particular, I will highlight the following issues:
(a) Activities of the Crimean Tatar media in Crimea;
(b) The role of the Mejlis of the Crimean Tatar People and claims that it represents the
interests of Crimean Tatars;
(c) Blockade of Crimea organised by former Mejlis leaders Refat Chubarov, Mustafa
Dzhemilev, Lenur Islyamov;
(d) Access of the Crimean Tatar population to public service in the Russian Federation;
(e) The ability of Crimean Tatars to hold mass events.
4. By virtue of the fact that I have lived in Crimea all my life and am also a Crimean Tatar
woman, I have a comprehensive understanding of the above-mentioned issues. This
witness statement is based on
.
A. CRIMEAN TATAR MEDIA IN CRIMEA
5. As for the work of the Crimean Tatar media in Crimea, it should be noted that they are
widely and fully represented. At the moment, in the territory of the Republic of Crimea
the Crimean Tatar public television and radio company “Millet” is operating. Its holding
company also controls the radio station “Vatan Sedasy”.1 The most popular republican
channel “Krym-24” broadcasts the special project “Key Point: The Crimean Tatar Issue”
1 As far as I understand, the Russian Federation has provided detailed information on Millet and the programmes
and broadcasts it produces in Annex 498 to the Counter-Memorial.
Annex 27
Page 4 out of 14
every Friday in prime time.2 That platform was created to discuss the burning political,
social, economic and cultural issues of Crimean Tatars in Crimea. The Mediacentre n.a.
I. Gasprinsky is also actively working. It is a structural subdivision of the State Committee
on Inter-Ethnic Relations of the Republic of Crimea. The following Crimean Tatar
publications are issued under aegis of the Center: Yany Dyunya,3 Meraba,4 Yildiz,5 Ana
Tili Odzhalaryna,6 and Arzy.7 Also, the newspaper “Golos Kryma” is published in
Crimea.8 It originated in the early 1990s. Since then, its permanent editor is a Crimean
Tatar – Eldar Seitbekirov. The newspaper is not part of any state holdings and is published
on a self-sustaining basis.
6. In 2015, the newspaper was licenced under the new Russian requirements,9 although it
did not outline its open position with regard to the referendum and the Russian authorities
in Crimea. In this context, it is worth stressing that the broadcasting or publishing licence
was granted to all who really wanted it, regardless of language and thematic content.
7. The ATR TV channel, on the contrary, took an extremely aggressive, unconstructive
stance from the very beginning of the events of 2014. The channel covered the events in
a very biased way, openly intimidating Crimean Tatars with their stories and hysterical
presentation of the facts.10 This has undoubtedly affected, among other things, the state
of health of many elderly Crimean Tatars.
2 See for example, Krym 24, #KEYPOINT #CRIMEANTATARISSUE (10 February 2023), available at:
https://crimea24tv ru/content/glavnoe-krimskotatarskiyvopros-11/ (Exhibit A).
3 Mediacentre n.a. I. Gasprinsky, Archive of the “Yany Dyunya” newspaper, available at:
https://mediacentr.org ru/arhiv-gazety-yany-dyunya/ (Exhibit B).
4 Mediacentre n.a. I. Gasprinsky, Archive of the “Meraba” newspaper, available at:
https://mediacentr.org ru/gazeta-meraba/arhiv-gazety-meraba/ (Exhibit C).
5 Mediacentre n.a. I. Gasprinsky, “Yildiz” Magazine, available at: https://mediacentr.org ru/zhurnal-jyldyz/
(Exhibit D). Archive of the “Yildiz” magazine, available at: https://disk.yandex ru/d/cTMRLZBXNsPkow?w=1
(Exhibit E).
6 For example, a manual for teachers of the Crimean Tatar language and literature has been produced, see
Mediacentre n.a. I. Gasprinsky, For teachers of the native language: a scientific-methodological guide for teachers
of the Crimean Tatar language and literature. No. 1 (15) (16 July 2018), available at:
https://mediacentr.org ru/2018/07/16/ana-tili-odzhalaryna-kyrymtatar-tili-ve-edebiyaty-odzhalary-ichyun-ilmijusulij-
medzhmua-1-15/ (Exhibit F).
7 Mediacentre n.a. I. Gasprinsky, Arzy, available at: https://mediacentr.org ru/arzy/ (Exhibit G).
8 Golos Kryma, Homepage (17 February 2023), available at: http://goloskrimanew.ru/ (Exhibit H).
9 Roskomnadzor, Certificate No. FS 77-60738, 11 February 2015, available at: https://rkn.gov ru/masscommunications/
reestr/media/?id=538108&page= (Exhibit I).
10 RIA Novosti, Aksyonov: Incitement to Hatred in Crimea is unacceptable at this difficult time (19 March 2015),
available at: https://ria.ru/20150319/1053392148 html (Exhibit J).
Annex 27
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8. I do not rule out that the former management of the ATR TV channel, in particular Lenur
Islyamov, simply wanted to use the fact of the termination of broadcasting to put pressure
on the public and international structures, as well as to obtain funding from the Ukrainian
authorities, as we have subsequently observed.
9. It should be noted that, over time, some of ATR’s management and staff (in particular,
Elzara Islyamova, deputy general director of ATR, and Liliya Budzhurova, editor and
presenter of ATR) have opened a Karadeniz Production studio, and an internet site11
which are still operating, and there is no talk of blocking them. These organisations also
regularly hold various kinds of events without any obstacles, such as organising a largescale
annual Crimean Tatar book fair12 and holding meetings for their resources with
Crimean Tatar opinion leaders, historians, artists13 etc.
10. Another example is the work of Canli production studio in Crimea.14 Its head, Nadzhie
Femy, is also one of those who did not support the events of 2014. She went to Kiev
several times and held all sorts of talks there. But in the end she chose Crimea. At the end
of 2022, she received a distribution certificate for the screening of her film “Obsessed”,
based on historical events.15
11. Thus, there are numerous media outlets covering the Crimean Tatar agenda in Crimea.
These include both those that were freely re-registered after 2014 and those that have
appeared relatively recently. All of them operate independently, choose their own
thematic episodes for coverage, and the state authorities do not hinder their activities.
11 Crimeantatars.club, Homepage (17 February 2023), available at: https://www.crimeantatars.club/ (Exhibit K).
12 Crimeantatars.club, IV Crimean Tatar Book Fair is the Brightest Event of Autumn 2022 (13 September 2022),
available at: https://www.crimeantatars.club/culture/literature/iv-krymskotatarskaya-knizhnaya-yarmarka-samoeyarkoe-
sobytie-oseni-2022 (Exhibit L).
13 See for example, Crimeantatars.club, Full video of meeting with journalist and writer Zera Bekirova (20
November 2020), available at: https://www.crimeantatars.club/life/society/polnaya-videoversiya-vstrechi-szhurnalistom-
i-pisatelem-zeroj-bekirovoj (Exhibit M). Crimeantatars.club, Meeting with coppersmith master
Rustem Dervish (full video) (28 May 2022), available at: https://www.crimeantatars.club/life/people/vstrecha-srustemom-
dervishem-polnaya-versiya (Exhibit N). Crimeantatars.club, Meeting with Crimean Tatar national
movement veteran Arsen Alchikov (video) (30 August 2020), available at:
https://www.crimeantatars.club/life/society/vstrecha-s-veteranom-natsionalnogo-dvizheniya-arsenomalchikovym-
videoversiya (Exhibit O).
14 Canli.online, CANLI – a new generation of Crimean Tatar media, available at: https://canli.online/about/
(Exhibit P).
15 Ministry of Culture of the Russian Federation, “The Possesed” Film Distribution Certificate No. 111030522, 8
November 2022, available at: https://culture.gov.ru/services/reestr-prokatnykh-udostovereniy/5750863/# (Exhibit
Q).
Annex 27
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B. MEJLIS
12. Regarding the activities of the Mejlis, it should be noted that Mustafa Dzhemilev literally
usurped power in this structure from the outset. Were there any alternatives? Yes, of
course there were. A bright and promising leader of the NMCT (an alternative branch of
the national movement) was Yury Osmanov. But he was brutally assassinated in 1993.16
The masterminds are unknown to this day. After that, there was a wave of political
murders among Crimean Tatars, including a brutal massacre of Norik Shirin in 2006.17
The vibrant and charismatic leader of the increasingly popular Birlik/Unity movement,
did not take instructions from the Mejlis and was an advocate of constructive cooperation
of all the peoples of Crimea. What is important, the killings were carried out with
deliberate brutality to intimidate other activists. The entire policy of the Mejlis was aimed
at forming a protest mob out of the Crimean Tatars. Their slogans and provocations had
only one objective – to keep the people in tension, permanent anger and fear.
13. Separately, I will address the “democratic nature” and alleged legitimacy of the structure.
The Mejlis was illegitimate, in the political life of Ukraine, too. Throughout the entire
period from 1991 to 2014, there was not a single Ukrainian document that in any way
regulated its activities in Ukraine!
14. As for so-called “peoples” legitimacy. The Crimean Tatar People's Assembly (Qurultay)
was formed on an electoral basis. The elected Qurultay formed the Mejlis. Initially the
Qurultay was elected according to the formula: 30-35 voters – 1 elector, 30 electors – 1
delegate (thus, 1 delegate in the Qurultay represented about 1000 Crimean Tatars), and
then according to a two-stage system – 50 voters elected an elector and 20 electors – 1
delegate.18 National politicians constantly asked for a review of the electoral system,
because this outdated model was not transparent and did not provide objective
representation; the system allowed monstrous falsifications in the election of electors,
16 Taurica.net, The Forgotten Leader of the Crimean Tatar People – Dead Opponent of Dzhemilev in the Early
1990s (9 December 2016), available at: https://taurica net/238739-Zabytyiy-lider-krymsko-tatarskogo-narodapogibshiiy-
protivnik-Dzhemileva-v-nachale-90-h html (Exhibit R).
17 Gazeta.ua, Norik Shirin Killed in Garage (21 December 2006), available at: https://gazeta.ua/ru/articles/ukrainenewspaper/_
norika-sirina-ubili-v-garazhe/144219 (Exhibit S).
18 Milli Firka, Nothing Is Worse Than Someone Else’s Rightness, Nothing Is Better Than One's Mistakes (12
October 2010), available at: http://milli-firka.org/нет-ничего-хуже-чужой-правоты-нет-ниче/ (Exhibit T).
Annex 27
Page 7 out of 14
which the interested persons constantly used.19 The apogee was 2006, when a group of
Qurultay delegates insisted on reform, but the leaders of the Mejlis completely rejected
the introduction of a direct voting system.20 It demonstrated once again the domination
of the principles of self-interest rather than objectivity of Mustafa Dzhemilev and Refat
Chubarov.
15. Case with voting system and many other decisions of Dzhemilev and Chubarov prompted
the departure of a group of prominent Crimean Tatar politicians from the Qurultay-Mejlis
system. At the 5th session of the 5th convocation of the Qurultay on 12 January 2013, a
reform was carried out and a new “Regulation on Elections” adopted.21 The bizarre
document was criticized, both during and after the election, by almost everyone –
opposition members, electoral actors, and the Committee of Voters of Ukraine.
Everything was done to prevent the growth of the number of delegates from public forces.
16. Thus, the attempt to create and develop Crimean Tatar political parties was defeated. It is
clear why. Mustafa Dzhemilev was always very afraid of competition, so he had always
tried to get rid of his opponents by all means. In general, the electoral system was very
complicated and completely incomprehensible to ordinary people.
17. First, the elections to the Qurultay were stretched out over several months! No one clearly
understood where and how to vote. Secondly, there was no transparent system of control
over voting and counting. Thirdly, a mixed voting system for election of delegates was in
place.
18. Under the new system, part of the delegates to the Qurultay were elected under the
majoritarian system and part under the proportional system. Without widespread outreach
(which was lacking), the older generation did not understand according to which system
one or another candidate should be elected. From the outside, the last elections to the
Qurultay were the least reminiscent of a genuine expression of the people’s will. The
victory depended not on the real support of the people, but on the agility and recognition
19 Ibid.
20 Ibid.
21 Qurultay of the Crimean Tatar People, Regulation “On the Election of Delegates of the Qurultay of the Crimean
Tatar People”, 12 January 2013, available at:
http://web.archive.org/web/20140323224623/http://qtmm.org/положение-о-выборах-делегатов-курултая-
крымскотатарского-народа (Exhibit U).
Annex 27
Page 8 out of 14
of undercurrents and procedural tricks by the participants in the process. The irregularities
on the days of voting itself were colossal.22 Voters were driven to the polling stations,
ballot papers were issued in packs, dots were placed on the ballot papers opposite the
correct candidates, voters were allowed to vote without a passport, the same polling
stations were listed in different districts, and in some polling stations they did not even
think to set up voting booths.
19. The observers had the least luck. In the Kirov district or Alushta, for example, they were
simply pushed out of the station. If before 2006, elections to the Qurultay were considered
successful with a minimum of 50% of voters participating, between 2006 and 2013 it was
only a third. And under the new Regulations of 12 January 2013, it did not matter how
many people came to vote – it was the relative majority that decided the matter.
20. The efforts of the Crimean Branch of the Committee of Voters of Ukraine (CB CVU)
require special attention.23 In the beginning of the race they strongly criticised the
organisation and course of the election, but with each successive stage their tone became
softer. What was the reason for this? Was it because the organisers had managed to
improve in such a short space of time, or was it simply because they were able to strike a
bargain?
21. The summing up of the CB CVU’s findings on the Qurultay elections in 2013 is
interesting. On the whole, the following characteristic was given: “The Crimean Tatar
Qurultay election in most polling districts were without any significant violations but had
some organisational drawbacks that led to infringement on the voters’ rights to express
their will in certain localities.”24 But in the end the head of the CB CVU Andrey Krisko
noted as follows: “Considering the level of political tolerance demonstrated by the
subjects of the electoral process in this election, if the tangle of organisational problems
22 Crimea24.info, Exceptional Violations Noted during Crimean Tatar Qurultay Elections (14 May 2013),
available at: https://crimea24.info/2013/05/14/na-vyborakh-v-kurultajj-krymskikh-tatar-zafiksirovali-unikalnyenarusheniya-
pravil-vyborov/ (Exhibit V). Milli Firka, Wide-Scale Violations During Qurultay Election (19 June
2013), available at: http://milli-firka.org/выборы-делегатов-курултая-прошли-с-ма/ (Exhibit W).
23 Public organisation monitoring elections in Ukraine.
24 Milli Firka, Their Qurultay Election Passed (30 July 2013), available at: http://milli-firka.org/прошли-выборы-
их-курултая/ (Exhibit X).
Annex 27
Page 9 out of 14
is removed and the regulatory framework is improved, all performance indicators of the
next Qurultay election can be significantly closer to the standards of electoral law.”25
22. It is therefore inappropriate to say that the Qurultay formed in this way and thus the Mejlis
had total or any meaningful support among Crimean Tatars. The so-called leader Mustafa
Dzhemilev himself and his system were harshly criticised and questioned long before the
events of 2014.26 Nor was he perceived as a moral leader. As his corrupt schemes, empty
promises and separation of himself from the people were already evident. But he managed
to find individual associates: politicians, businessmen, journalists and his security forces
loyal to him personally. Using various resources, they provided him with media exposure
and perceived support.
23. After 2014, Mustafa Dzhemilev and Refat Chubarov have been actively calling for mass
resistance actions by Crimean Tatars. But there is no need or any meaningful reason for
Crimeans to hold such actions.
24. Representatives of the Mejlis used various methods and means to suppress criticism. For
example, as , I personally was repeatedly
subjected to pressure and threats from Refat Chubarov and his entourage. After 2014, I
have regularly been receiving messages of an insulting and humiliating nature. In
addition, I receive messages on behalf of anonymous users saying “Pack your bags, we
will be there soon.”
25. There are no specific results of the activities of the Mejlis. Before 2014, the Crimean
Tatar language in Crimea was not recognised as a state language by Ukraine, there were
huge difficulties with the native language in the school system, there was no proper
representation of Crimean Tatars in the government, etc. The Mejlis did nothing to change
this situation. They did not achieve any more or less meaningful social or political results
through their activities.
25 Ibid.
26 ZN.UA, Authoritarian democracy (26 December 1997), available at:
https://zn.ua/politcs_archive/avtoritarnaya_demokratiya.html (Exhibit Y); E. Muedinov, Report Chairman of the
Review Committee of Qurultay (Avdet newspaper, No. 23(186) 31 December 1997), see Milli Firka, Who and
How Ripped Off the People in the Mejlis (25 March 2011), available at: http://milli-firka.org/кто-и-как-в-
меджлисе-обворовывал-народ/ (Exhibit Z).
Annex 27
Page 10 out of 14
26. Regarding corruption. Since the early 1990s, large amounts of humanitarian aid have
come from the foreign Crimean Tatar diaspora (mainly from Turkey). Both financial and
material. But that aid ended up in the pockets of Dzhemilev and his associates.27
27. On Krym-24 TV, Special Project “Key Point: The Crimean Tatar Issue” (broadcast on 3
February 2023), the head of the Federation of Crimean Tatar Cultural Societies of Turkey,
Unvar Sel, said that Crimean Tatars started returning to their homeland in Crimea from
exile in 1989. Two years later, the Soviet Union collapsed and the Crimean Peninsula
became part of the already independent Ukraine. Since that time, the assistance of Turkey
to our compatriots in Crimea increased dramatically. A significant part of this assistance
was provided by the Turkish state. Crimean Tatars in Turkey also collected aid through
Crimean associations and delivered it to Crimea. Mustafa Dzhemilev took responsibility
for a significant portion of these receipts. However, many events ostensibly for the benefit
of the Crimean Tatar people were not successful. The biggest problem for Crimean Tatars
was housing. Aid was sent to Crimea from Turkey for this purpose. As a result, there are
no houses and no funds. Over the years, much of the humanitarian aid collected from
Turkey and sent to Mustafa Dzhemilev was distributed around himself. Those who sent
the aid witnessed that much of it was sold at markets and handed over to wholesalers.
28. Mustafa Dzhemilev and his company profited from Crimean Tatars for years. While
Crimean Tatar society was in poverty, they got rich, including through fraud with funds
coming from Turkey. Mustafa Dzhemilev has transformed from an uneducated man to a
man who now owns luxury cars, villas and flats in Kiev, Istanbul, Cyprus and London,
companies that do business with Europe, Canada and the USA. He has registered most of
them in the name of other people – his wife, his friends, his drivers. Today, he has set up
“coordination offices” outside associations in Turkey. Through them, he seeks ways to
turn the war into a booty, supplying arms and aid to the Ukrainian army. It is time to put
an end to these structures enriching themselves at the expense of the suffering and despair
of Crimean Tatars. The Turkish state must also take responsibility in this regard and set
up a team to investigate the fate of the aid and money sent. Nothing should be a secret
27 Millie Firka, How Dzhemilev Ripped Off Three Orphans (12 October 2013), available at: http://millifirka.
org/как-джемилев-трех-сирот-обокрал/ (Exhibit AA).
Annex 27
Page 11 out of 14
anymore. Those who have plundered the values of Turkish and Crimean Tatar society for
years must be held accountable to the public.28
29. I will give just one example of mismanagement and waste of humanitarian money. In the
late 1990s, on the initiative of a prominent figure of the Crimean Tatar diaspora in Turkey
and a prominent doctor, Ahmet Ihsan Qirimly, the idea of creating a children’s hospital
in Crimea arose. He found and transferred money for this purpose to the Crimea
Foundation (which was under the personal control of Mustafa Dzhemilev). He, in turn,
found a building in Simferopol district and bought it. However, it soon became clear that
the building was neither functionally or infrastructurally suitable for a children’s
hospital.29 Some work was done, but even after them the building could not be used as a
medical facility. Moreover, the author of the idea, a Turkish philanthropist, sent very
expensive equipment, including Crimea's first CT scanner and other medical equipment,
as charitable aid.
C. THE BLOCKADE OF CRIMEA
30. In the autumn of 2015, a blockade of Crimea was initiated by representatives of the Mejlis
leaders, so Mustafa Dzhemilev, Refat Chubarov, Lenur Islyamov.30 First, it was
economic, then power lines were blown up.31 The terrorist attacks on power lines resulted
in the peninsula being de-energised. Representatives of the Mejlis, in particular Lenur
Islyamov, through their resources and their people in Crimea, tried to organise
informational support for this act.32 They tried to present the situation as if the Crimean
Tatars were rejoicing at the blackout, and with the lights would come Ukraine. However,
28 VKontakte, Crimea24.tv, Mustafa Dzhemilev sold most of the humanitarian aid handed over from Turkey to
Crimean Tatars (3 February 2023), available at: https://vk.com/crimea24tv?z=video-
116028735_456268795%2F368833c9596954b4ed%2Fpl_post_-116028735_170054 (Exhibit AB).
29 Politnavigator.net, Erdogan is suggested to initiate an investigation into the theft of Turkish money by the Mejlis
leadership (7 February 2023), available at: https://www.politnavigator.net/ehrdoganu-predlagayut-iniciirovatrassledovanie-
vorovstva-tureckikh-deneg-medzhlisovskojj-verkhushkojj html (Exhibit AC).
30 RIA Novosti (Crimea), How Crimea Was Tempered: Five Blockades in the Peninsula's Modern History (28
February 2019), available at: https://crimea ria ru/20190228/1116152860.html (Exhibit AD).
31 Ibid. See also RBC, Crimea's Shutdown: The Threat of an Energy Blockade to the Republic (22 November
2015), available at: https://www rbc.ru/society/22/11/2015/5651b8cf9a79474f3a9e0f59 (Exhibit AE).
32 Odessa Crisis Media Center, Lenur Islyamov: We Will Return Crimea Within 2016 (25 December 2015),
available at: https://web.archive.org/web/20160207145939/http://www.odcrisis.org/lenur-islyamov2/ (Exhibit
AF). Youtube, ATR TV, The Civil Blockade of Crimea: How it All Started 3 Years Ago and What the Outcome
Was (21 September 2018), available at: https://www.youtube.com/watch?v=_2J5XG_qgjs (Exhibit AG).
Annex 27
Page 12 out of 14
most of Crimean Tatars live in the countryside.33 Most families have many children.
Elderly people and young children live in the same house. How could people be happy in
such conditions? Not all villages had gas back then. Naturally, houses with electric
heating were left to freeze to death in the already cold season. Moreover, the blockade
has affected all areas of life, for example, people had extreme difficulty in organising
funeral events. The organisation of the energy and water blockade had a direct negative
impact on the quality of life of Crimean Tatars, led to an increase in morbidity and the
exacerbation of chronic diseases.
D. ACCESS OF THE CRIMEAN TATAR POPULATION TO PUBLIC SERVICE IN THE RUSSIAN
FEDERATION
31. Crimean Tatars enter the service of state bodies of the Russian Federation. If they
“considered Crimea to be part of Ukraine”, they would certainly not have made such
career decisions. Crimean Tatars are represented as deputies in some ministries and in
most district administrations. There are two Crimean Tatar deputies in the State Council
of the Republic of Crimea, so Edip Gafarov and Chinghiz Yakubov.34 One of them is
Edip Gafarov – Deputy Chairman of the State Council of Crimea.35 Crimean Tatars are
also represented in the municipal deputy bodies. In all sectors of the economy Crimean
Tatars are involved and successfully carry out their activities.
32. Emiraly Ablayev – Mufti of Muslims of Crimea – has held this position consistently since
1999. On 27 October 2018, by an open vote of the delegates of the VI Qurultay of
Muslims of Crimea, he was re-elected Mufti of the Republic of Crimea and Sevastopol.
To call him a renegade or a “derelict” is something only someone very distant from
Crimean realities can do. Also in 2018, the Council (Shura) of the Crimean Tatars under
the Head of the Republic of Crimea was established by decree of the Head of the Republic
of Crimea. Candidates for the Council were chosen during the meeting of the VI Qurultay
of Crimean Muslims. Emiraly Ablayev is the deputy chairman of this structure. The
33 Federal State Statistics Service, RESULTS OF THE POPULATION CENSUS IN THE CRIMEAN FEDERAL DISTRICT
(Russian Institute of Statistics, 2015), available at: https://rosstat.gov ru/storage/mediabank/KRUM_2015.pdf
(Exhibit AH), p. 109.
34 State Council of the Republic of Crimea, Edip Gafarov, available at: http://crimea.gov.ru/deputy/285 (Exhibit
AI). State Council of the Republic of Crimea, Chinghiz Yakubov, available at: http://crimea.gov ru/deputy/394
(Exhibit AJ).
35 State Council of the Republic of Crimea, Edip Gafarov, available at: http://crimea.gov.ru/deputy/285 (Exhibit
AI).
Annex 27
Page 13 out of 14
Council is a representative body broadcasting the interests and key problems of Crimean
Tatars in Crimea. The members of the Council actively debunk lies from abroad about
Crimean Tatars in Crimea. The organisation has its own reception room. They receive
citizens on a weekly basis and also accept applications remotely. They deal, among other
things, with issues related to the everyday living conditions and obtaining the necessary
documents.
E. THE ABILITY OF CRIMEAN TATARS TO HOLD MASS EVENTS
33. How credible is the thesis that Russia is blocking events/assemblies of Crimean Tatars?
The thesis is untrue. Russia does not block the holding of events/assemblies of Crimean
Tatars, if they are declared in compliance with the procedure. For sure, the mass event of
the Day of Remembrance of the Victims of Deportation on 18 May in the territory of
Crimea was moved from Lenin Square in Simferopol, but an alternative venue was
proposed in a historically significant place for Crimean Tatars. The event has been used
for decades as a political platform for the Mejlis leaders,36 rather than as an opportunity
to commemorate the victims of the deportation. Now Crimean Tatars are not restricted in
their right, for example, to go to Lenin Square in Simferopol on the evening of 17-18 May
and light a memorial candle. Or visit the Syuren Memorial Complex (erected by Russia),
where mourning events are held every year.37 Or simply come to the mosque and pray for
the victims of that tragedy.
34. I hereby confirm that, to the best of my knowledge and beliefs, the information set out in
this witness statement is true.
Witness
36 Milli Firka, Mejlis wants Mogilev's resignation (7 May 2013), available at: http://milli-firka.org/меджлисмены-
хотят-отставки-могилева// (Exhibit AK).
37 RIA Novosti, The 75th Anniversary of the Deportation of Peoples from Crimea: Remembrance Events at the
Syuren Memorial (18 May 2019), available at: https://crimea.ria.ru/20190518/1116661184.html (Exhibit AL).
Crimean Tatar Museum of Cultural and Historical Heritage, Events in Memory of Victims of Deportation of
Peoples from Crimea Held at Syuren Station (18 May 2022), available at: https://krtmuseum ru/18-maya-denpamyati-
zhertv-deportatsii-narodov-kryma/ (Exhibit AM).
Annex 27
Page 14 out of 14
[Signature]
Simferopol, 18 February 2023
Annex 27
LIST OF EXHIBITS
Number: Name of exhibit:
Exhibit A Krym 24, #KEYPOINT #CRIMEANTATARISSUE (10 February 2023).
Exhibit B Mediacentre n.a. I. Gasprinsky, Archive of the “Yany Dyunya” newspaper.
Exhibit C Mediacentre n.a. I. Gasprinsky, Archive of the “Meraba” newspaper.
Exhibit D Mediacentre n.a. I. Gasprinsky, “Yildiz” Magazine.
Exhibit E Archive of “Yildiz” magazine.
Exhibit F Mediacentre n.a. I. Gasprinsky, For teachers of the native language: a
scientific-methodological guide for teachers of the Crimean Tatar
language and literature. No. 1 (15) (16 July 2018).
Exhibit G Mediacentre n.a. I. Gasprinsky, Arzy.
Exhibit H Golos Kryma, Homepage (17 February 2023).
Exhibit I Roskomnadzor, Certificate No. FS 77-60738, 11 February 2015.
Exhibit J RIA Novosti, Aksyonov: Incitement to Hatred in Crimea is unacceptable
at this difficult time (19 March 2015).
Exhibit K Crimeantatars.club, Homepage (17 February 2023).
Exhibit L Crimeantatars.club, IV Crimean Tatar Book Fair is the Brightest Event of
Autumn 2022 (13 September 2022).
Exhibit M Crimeantatars.club, Full video of meeting with journalist and writer Zera
Bekirova (20 November 2020).
Exhibit N Crimeantatars.club, Meeting with coppersmith master Rustem Dervish (full
video) (28 May 2022).
Exhibit O Crimeantatars.club, Meeting with Crimean Tatar national movement
veteran Arsen Alchikov (video) (30 August 2020).
Annex 27
Exhibit P Canli.online, CANLI – a new generation of Crimean Tatar media.
Exhibit Q Ministry of Culture of the Russian Federation, “The Possesed” Film
Distribution Certificate No. 111030522, 8 November 2022.
Exhibit R Taurica.net, The Forgotten Leader of the Crimean Tatar People – Dead
Opponent of Dzhemilev in the Early 1990s (9 December 2016).
Exhibit S Gazeta.ua, Norik Shirin Killed in Garage (21 December 2006).
Exhibit T Milli Firka, Nothing Is Worse Than Someone Else's Rightness, Nothing Is
Better Than One's Mistakes (12 October 2010).
Exhibit U Qurultay of the Crimean Tatar People, Regulation “On the Election of
Delegates of the Qurultay of the Crimean Tatar People”, 12 January 2013.
Exhibit V Crimea24.info, Exceptional Violations Noted during Crimean Tatar
Qurultay Elections (14 May 2013).
Exhibit W Milli Firka, Wide-Scale Violations During Qurultay Election
(19 June 2013).
Exhibit X Milli Firka, Their Qurultay Election Passed (30 July 2013).
Exhibit Y ZN.UA, Authoritarian democracy (26 December 1997).
Exhibit Z Milli Firka, Who and How Ripped Off the People in the Mejlis
(25 March 2011).
Exhibit AA Millie Firka, How Dzhemilev Ripped Off Three Orphans
(12 October 2013).
Exhibit AB VKontakte,Crimea24.tv, Mustafa Dzhemilev sold most of the humanitarian
aid handed over from Turkey to Crimean Tatars (3 February 2023).
Exhibit AC Politnavigator.net, Erdogan is suggested to initiate an investigation into the
theft of Turkish money by the Mejlis leadership (7 February 2023).
Exhibit AD RIA Novosti (Crimea), How Crimea Was Tempered: Five Blockades in the
Peninsula's Modern History (28 February 2019).
Annex 27
Exhibit AE RBC, Crimea's Shutdown: The Threat of an Energy Blockade to the
Republic (22 November 2015).
Exhibit AF Odessa Crisis Media Center, Lenur Islyamov: We Will Return Crimea
Within 2016 (25 December 2015).
Exhibit AG YouTube, ATR TV, The Civil Blockade of Crimea: How it All Started 3
Years Ago and What the Outcome Was (21 September 2018).
Exhibit AH Federal State Statistics Service, RESULTS OF THE POPULATION CENSUS IN
THE CRIMEAN FEDERAL DISTRICT (Russian Institute of Statistics, 2015).
Exhibit AI State Council of the Republic of Crimea, Edip Gafarov.
Exhibit AJ State Council of the Republic of Crimea, Chinghiz Yakubov.
Exhibit AK Milli Firka, Mejlis wants Mogilev's resignation (7 May 2013).
Exhibit AL RIA Novosti, The 75th Anniversary of the Deportation of Peoples from
Crimea: Remembrance Events at the Syuren Memorial (18 May 2019).
Exhibit AM Crimean Tatar Museum of Cultural and Historical Heritage, Events in
Memory of Victims of Deportation of Peoples from Crimea Held at Syuren
Station (18 May 2022).

Exhibit A
Krym 24, #KEYPOINT #CRIMEANTATARISSUE (10 February 2023)
(translation)

Annex 27 Exhibit A
Translation
Krym 24, #KEYPOINT #CRIMEANTATARISSUE (10 February 2023), available at:
https://crimea24tv.ru/content/glavnoe-krimskotatarskiyvopros-11/.
#KEYPOINT
#CRIMEANTATARISSUE
Friday, 10 February. Krym 24. The difficult stage of the Crimean Tatars’ social and domestic
adaptation has been completed in general. But there are still a lot of questions. Who are we?
Crimean Tatars? Crimeans? Kyrymlys? How politically mature are we? Is our path now a
survival or development one? What’s about our demographics? Emigration amidst a strong
natural growth?
We discuss these and other topics in our TV show called “The Key Point. Special Project. The
Crimean Tatar Issue”.

Exhibit B
Mediacentre n.a. I. Gasprinsky, Archive of the “Yany Dyunya” newspaper
(translation)

Annex 27 Exhibit B
Translation
Mediacentre n.a. I. Gasprinsky, Archive of the “Yany Dyunya” newspaper, available at:
https://mediacentr.org.ru/arhiv-gazety-yany-dyunya/.
Archive of the “Yany Dyunya” newspaper
Archive of the “Yany Dyunya” newspaper in PDF for 2018
Yany Dyunya No.1 (1435) 2018
Yany Dyunya No.2 (1436) 2018
Yany Dyunya No.3 (1437) 2018
Yany Dyunya No.4 (1438) 2018
Yany Dyunya No.5 (1439) 2018
Yany Dyunya No.6 (1440) 2018
Yany Dyunya No.7 (1441) 2018
Yany Dyunya No.8 (1442) 2018
Yany Dyunya No.9 (1443) 2018
Yany Dyunya No.10 (1444) 2018
Yany Dyunya No.11 (1445) 2018
Yany Dyunya No.12 (1446) 2018
Yany Dyunya No.13 (1447) 2018
Yany Dyunya No.14 (1448) 2018
Yany Dyunya No.15 (1449) 2018
Yany Dyunya No.16 (1450) 2018
Yany Dyunya No.17 (1451) 2018
Yany Dyunya No.18 (1452) 2018
Yany Dyunya No.19 (1453) 2018
Yany Dyunya No.20 (1454) 2018
Yany Dyunya No.21 (1455) 2018
Yany Dyunya No.22 (1456) 2018
Yany Dyunya No.23 (1457) 2018
Yany Dyunya No.24 (1458) 2018
Yany Dyunya No.25 (1459) 2018
Yany Dyunya No.26 (1460) 2018
Yany Dyunya No.27 (1461) 2018
Yany Dyunya No.28 (1462) 2018
Yany Dyunya No.29 (1463) 2018
Yany Dyunya No.30 (1464) 2018
Yany Dyunya No.31 (1465) 2018
Annex 27 Exhibit B
Yany Dyunya No.32 (1466) 2018
Yany Dyunya No.33 (1467) 2018
Yany Dyunya No.34 (1468) 2018
Yany Dyunya No.35 (1469) 2018
Yany Dyunya No.36 (1470) 2018
Yany Dyunya No.37 (1471) 2018
Yany Dyunya No.38 (1472) 2018
Yany Dyunya No.39 (1473) 2018
Yany Dyunya No.40 (1474) 2018
Yany Dyunya No.41 (1475) 2018
Yany Dyunya No.42 (1476) 2018
Yany Dyunya No.43 (1477) 2018
Yany Dyunya No.44 (1478) 2018
Yany Dyunya No.45 (1479) 2018
Yany Dyunya No.46 (1480) 2018
Yany Dyunya No.47 (1481) 2018
Yany Dyunya No.48 (1482) 2018
Yany Dyunya No.49 (1483) 2018
Yany Dyunya No.50 (1484) 2018
Yany Dyunya No.51201852 (1485-1486) 2018
Archive of the “Yany Dyunya” newspaper in PDF for 2019
Yany Dyunya No.1 (1487) 2019
Yany Dyunya No.2 (1488) 2019
Yany Dyunya No.3 (1489) 2019
Yany Dyunya No.4 (1490) 2019
Yany Dyunya No.5 (1491) 2019
Yany Dyunya No.6 (1492) 2019
Yany Dyunya No.7 (1493) 2019
Yany Dyunya No.8 (1494) 2019
Yany Dyunya No.9 (1495) 2019
Yany Dyunya No.10 (1496) 2019
Yany Dyunya No.11 (1497) 2019
Yany Dyunya No.12 (1498) 2019
Yany Dyunya No.13 (1499) 2019
Yany Dyunya No.14 (1500) 2019
Yany Dyunya No.15 (1501) 2019
Yany Dyunya No.16 (1502) 2019
Annex 27 Exhibit B
Yany Dyunya No.17 (1503) 2019
Yany Dyunya No.18 (1504) 2019
Yany Dyunya No.19 (1505) 2019
Yany Dyunya No.20 (1506) 2019
Yany Dyunya No.21 (1507) 2019
Yany Dyunya No.22 (1508) 2019
Yany Dyunya No.23 (1509) 2019
Yany Dyunya No.24 (1510) 2019
Yany Dyunya No.25 (1511) 2019
Yany Dyunya No.26 (1512) 2019
Yany Dyunya No.27 (1513) 2019
Yany Dyunya No.28 (1514) 2019
Yany Dyunya No.29 (1515) 2019
Yany Dyunya No.30 (1516) 2019
Yany Dyunya No.31 (1517) 2019
Yany Dyunya No.32 (1518) 2019
Yany Dyunya No.33 (1519) 2019
Yany Dyunya No.34 (1520) 2019
Yany Dyunya No.35 (1521) 2019
Yany Dyunya No.36 (1522) 2019
Yany Dyunya No.37 (1523) 2019
Yany Dyunya No.38 (1524) 2019
Yany Dyunya No.39 (1525) 2019
Yany Dyunya No.40 (1526) 2019
Yany Dyunya No.41 (1527) 2019
Yany Dyunya No.42 (1528) 2019
Yany Dyunya No.43 (1529) 2019
Yany Dyunya No.44 (1530) 2019
Yany Dyunya No.45 (1531) 2019
Yany Dyunya No.46 (1532) 2019
Yany Dyunya No.47 (1533) 2019
Yany Dyunya No.48 (1534) 2019
Yany Dyunya No.49 (1535) 2019
Yany Dyunya No.50 (1536) 2019
Yany Dyunya No.51201952 (1537-1538) 2019
Archive of the “Yany Dyunya” newspaper in PDF for 2020
Yany Dyunya No.1 (1539) 2020
Annex 27 Exhibit B
Yany Dyunya No.2 (1540) 2020
Yany Dyunya No.3 (1541) 2020
Yany Dyunya No.4 (1542) 2020
Yany Dyunya No.5 (1543) 2020
Yany Dyunya No.6 (1544) 2020
Yany Dyunya No.7 (1545) 2020
Yany Dyunya No.8 (1546) 2020
Yany Dyunya No.9 (1547) 2020
Yany Dyunya No.10 (1548) 2020
Yany Dyunya No.11 (1549) 2020
Yany Dyunya No.12 (1550) 2020
Yany Dyunya No.13 (1551) 2020
Yany Dyunya No.14 (1552) 2020
Yany Dyunya No.15 (1553) 2020
Yany Dyunya No.16 (1554) 2020
Yany Dyunya No.17 (1555) 2020
Yany Dyunya No.18 (1556) 2020
Yany Dyunya No.19 (1557) 2020
Yany Dyunya No.20 (1558) 2020
Yany Dyunya No.21 (1559) 2020
Yany Dyunya No.22 (1560) 2020
Yany Dyunya No.23 (1561) 2020
Yany Dyunya No.24 (1562) 2020
Yany Dyunya No.25 (1563) 2020
Yany Dyunya No.26 (1564) 2020
Yany Dyunya No.27 (1565) 2020
Yany Dyunya No.28 (1566) 2020
Yany Dyunya No.29 (1567) 2020
Yany Dyunya No.30 (1568) 2020
Yany Dyunya No.31 (1569) 2020
Yany Dyunya No.32 (1570) 2020
Yany Dyunya No.33 (1571) 2020
Yany Dyunya No.34 (1572) 2020
Yany Dyunya No.35 (1573) 2020
Yany Dyunya No.36 (1574) 2020
Yany Dyunya No.37 (1575) 2020
Yany Dyunya No.38 (1576) 2020
Yany Dyunya No.39 (1577) 2020
Yany Dyunya No.40 (1578) 2020
Annex 27 Exhibit B
Yany Dyunya No.41 (1579) 2020
Yany Dyunya No.42 (1580) 2020
Yany Dyunya No.43 (1581) 2020
Yany Dyunya No.44 (1582) 2020
Yany Dyunya No.45 (1583) 2020
Yany Dyunya No.46 (1584) 2020
Yany Dyunya No.47 (1585) 2020
Yany Dyunya No.48 (1586) 2020
Yany Dyunya No.49 (1587) 2020
Yany Dyunya No.50 (1588) 2020
Yany Dyunya No.51-52 (1589-1590) 2020
Archive of the “Yany Dyunya” newspaper in PDF for 2021
Yany Dyunya No.1 (1591) 2021
Yany Dyunya No.2 (1592) 2021
Yany Dyunya No.3 (1593) 2021
Yany Dyunya No.4 (1594) 2021
Yany Dyunya No.5 (1595) 2021
Yany Dyunya No.6 (1596) 2021
Yany Dyunya No.7 (1597) 2021
Yany Dyunya No.8 (1598) 2021
Yany Dyunya No.9 (1599) 2021
Yany Dyunya No.10 (1600) 2021
Yany Dyunya No.11 (1601) 2021
Yany Dyunya No.12 (1602) 2021
Yany Dyunya No.13 (1603) 2021
Yany Dyunya No.14 (1604) 2021
Yany Dyunya No.15 (1605) 2021
Yany Dyunya No.16 (1606) 2021
Yany Dyunya No.17 (1607) 2021
Yany Dyunya No.18 (1608) 2021
Yany Dyunya No.19 (1609) 2021
Yany Dyunya No.20 (1610) 2021
Yany Dyunya No.21 (1611) 2021
Yany Dyunya No.22 (1612) 2021
Yany Dyunya No.23 (1613) 2021
Yany Dyunya No.24 (1614) 2021
Yany Dyunya No.25 (1615) 2021
Annex 27 Exhibit B
Yany Dyunya No.26 (1616) 2021
Yany Dyunya No.27 (1617) 2021
Yany Dyunya No.28 (1618) 2021
Yany Dyunya No.29 (1619) 2021
Yany Dyunya No.30 (1620) 2021
Yany Dyunya No.31 (1621) 2021
Yany Dyunya No.32 (1622) 2021
Yany Dyunya No.33 (1623) 2021
Yany Dyunya No.34 (1624) 2021
Yany Dyunya No.35 (1625) 2021
Yany Dyunya No.36 (1626) 2021
Yany Dyunya No.37 (1627) 2021
Yany Dyunya No.38 (1628) 2021
Yany Dyunya No.39 (1629) 2021
Yany Dyunya No.40 (1630) 2021
Yany Dyunya No.41 (1631) 2021
Yany Dyunya No.42 (1632) 2021
Yany Dyunya No.43 (1633) 2021
Yany Dyunya No.44 (1634) 2021
Yany Dyunya No.45 (1635) 2021
Yany Dyunya No.46 (1636) 2021
Yany Dyunya No.47 (1637) 2021
Yany Dyunya No.48 (1638) 2021
Yany Dyunya No.49 (1639) 2021
Yany Dyunya No.50 (1640) 2021
Yany Dyunya No.51-52 (1641-1642) 2021
Archive of the “Yany Dyunya” newspaper in PDF for 2022
Yany Dyunya No.1 (1643) 2022
Yany Dyunya No.2 (1644) 2022
Yany Dyunya No.3 (1645) 2022
Yany Dyunya No.4 (1646) 2022
Yany Dyunya No.5 (1647) 2022
Yany Dyunya No.6 (1648) 2022
Yany Dyunya No.7 (1649) 2022
Yany Dyunya No.8 (1650) 2022
Yany Dyunya No.9 (1651) 2022
Yany Dyunya No.10 (1652) 2022
Annex 27 Exhibit B
Yany Dyunya No.11 (1653) 2022
Yany Dyunya No.12 (1654) 2022
Yany Dyunya No.13 (1655) 2022
Yany Dyunya No.14 (1656) 2022
Yany Dyunya No.15 (1657) 2022
Yany Dyunya No.16 (1658) 2022
Yany Dyunya No.17 (1659) 2022
Yany Dyunya No.18 (1660) 2022
Yany Dyunya No.19 (1661) 2022
Yany Dyunya No.20 (1662) 2022
Yany Dyunya No.21 (1663) 2022
Yany Dyunya No.22 (1664) 2022
Yany Dyunya No.23 (1665) 2022
Yany Dyunya No.24 (1666) 2022
Yany Dyunya No.25 (1667) 2022
Yany Dyunya No.26 (1668) 2022
Yany Dyunya No.27 (1669) 2022
Yany Dyunya No.28 (1670) 2022
Yany Dyunya No.29 (1671) 2022
Yany Dyunya No.30 (1672) 2022
Yany Dyunya No.31 (1673) 2022
Yany Dyunya No.32 (1674) 2022
Yany Dyunya No.33 (1675) 2022
Yany Dyunya No.34 (1676) 2022
Yany Dyunya No.35 (1657) 2022
Yany Dyunya No.36 (1658) 2022
Yany Dyunya No.37 (1659) 2022
Yany Dyunya No.38 (1660) 2022

Exhibit C
Mediacentre n.a. I. Gasprinsky, Archive of the “Meraba” newspaper
(translation)

Annex 27 Exhibit C
Translation
Mediacentre n.a. I. Gasprinsky, Archive of the “Meraba” newspaper, available at:
https://mediacentr.org.ru/gazeta-meraba/arhiv-gazety-meraba/.
Archive of the “Meraba” newspaper
Archive of the “Meraba” newspaper in PDF for 2017
Meraba No.1 (58)
Meraba No.42 (99)
Archive of the “Meraba” newspaper in PDF for 2018
Meraba No.1 (108)
Meraba No.2 (109)
Meraba No.3 (110)
Meraba No.4 (111)
Meraba No.5 (112)
Meraba No.6 (113)
Meraba No.7 (114)
Meraba No.8 (115)
Meraba No.9 (116)
Meraba No.10 (117)
Meraba No.11 (118)
Meraba No.12 (119)
Meraba No.13 (120)
Meraba No.14 (121)
Meraba No.15 (122)
Meraba No.16 (123)
Meraba No.17 (124)
Meraba No.18 (125)
Meraba No.19 (126)
Meraba No.20 (127)
Meraba No.21 (128)
Meraba No.22 (129)
Meraba No.23 (130)
Meraba No.24 (131)
Meraba No.25 (132)
Meraba No.26 (133)
Annex 27 Exhibit C
Meraba No.27 (134)
Meraba No.28 (135)
Meraba No.29 (136)
Meraba No.30 (137)
Meraba No.31 (138)
Meraba No.32 (139)
Meraba No.33 (140)
Meraba No.34 (141)
Meraba No.35 (142)
Meraba No.36 (143)
Meraba No.37 (144)
Meraba No.38 (145)
Meraba No.39 (146)
Meraba No.40 (147)
Meraba No.41 (148)
Meraba No.42 (149)
Meraba No.43 (150)
Meraba No.44 (151)
Meraba No.45 (152)
Meraba No.46 (153)
Meraba No.47 (154)
Meraba No.48 (155)
Meraba No.49 (156)
Meraba No.50 (157)
Meraba No.51,52 (158)
Archive of the “Meraba” newspaper in PDF for 2019
Meraba, No.1 2019
Meraba, No.2 2019
Meraba, No.3 2019
Meraba, No.4 2019
Meraba, No.5 2019
Meraba, No.6 2019
Meraba, No.7 2019
Meraba, No.8 2019
Meraba, No.9 2019
Meraba, No.10 2019
Meraba, No.11 2019
Annex 27 Exhibit C
Meraba, No.12 2019
Meraba, No.13 2019
Meraba, No.14 2019
Meraba, No.15 2019
Meraba, No.16 2019
Meraba, No.17 2017
Meraba, No. 18 2019
Meraba, No.19 2019
Meraba, No.20 2019
Meraba, No.21 2019
Meraba, No.22 2019
Meraba, No.23 2019
Meraba, No.24 2019
Meraba, No.25 2019
Meraba, No.26 2019
Meraba, No.27 2019
Meraba, No.28 2019
Meraba, No.29 2019
Meraba, No.30 2019
Meraba, No.31 2019
Meraba, No.32 2019
Meraba, No.33 2019
Meraba, No.34 2019
Meraba, No.35 2019
Meraba, No.36 2019
Meraba, No.37 2019
Meraba, No.38 2019
Meraba, No.39 2019
Meraba, No.40 2019
Meraba, No.41 2019
Meraba, No.42 2019
Meraba, No.43 2019
Meraba, No.44 2019
Meraba, No.45 2019
Meraba, No.46 2019
Meraba, No.47 2019
Meraba, No.48 2019
Meraba, No.49 2019
Meraba, No.50 2019
Annex 27 Exhibit C
Meraba, No.51-52 2019
Archive of the “Meraba” newspaper in PDF for 2020
Meraba No.1 (211) 2020
Meraba No.2 (212) 2020
Meraba No.3 (213) 2020
Meraba No.4 (214) 2020
Meraba No.5 (215) 2020
Meraba No.6 (216) 2020
Meraba No.7 (217) 2020
Meraba No.8 (218) 2020
Meraba No.9 (219) 2020
Meraba No.10 (220) 2020
Meraba No.11 (221) 2020
Meraba No.12 (222) 2020
Meraba No.13 (223) 2020
Meraba No.14 (224) 2020
Meraba No.15 (225) 2020
Meraba No.16 (226) 2020
Meraba No.17 (227) 2020
Meraba No.18 (228) 2020
Meraba No.19 (229) 2020
Meraba No.20 (230) 2020
Meraba No.21 (231) 2020
Meraba No.22 (232) 2020
Meraba No.23 (233) 2020
Meraba No.24 (234) 2020
Meraba No.25 (235) 2020
Meraba No.26 (236) 2020
Meraba No.27 (237) 2020
Meraba No.28 (238) 2020
Meraba No.29 (239) 2020
Meraba No.30 (240) 2020
Meraba No.31 (241) 2020
Meraba No.32 (242) 2020
Meraba No.33 (243) 2020
Meraba No.34 (244) 2020
Meraba No.35 (245) 2020
Annex 27 Exhibit C
Meraba No.36 (246) 2020
Meraba No.37 (247) 2020
Meraba No.38 (248) 2020
Meraba No.39 (249) 2020
Meraba No.40 (250) 2020
Meraba No.41 (251) 2020
Meraba No.42 (252) 2020
Meraba No.43 (253) 2020
Meraba No.44 (254) 2020
Meraba No.45 (255) 2020
Meraba No.46 (256) 2020
Meraba No.47 (257) 2020
Meraba No.48 (258) 2020
Meraba No.49 (259) 2020
Meraba No.50 (260) 2020
Meraba No.51-52 (261-262) 2020
Archive of the “Meraba” newspaper in PDF for 2021
Meraba No.1 (263) 2021
Meraba No.2 (264) 2021
Meraba No.3 (265) 2021
Meraba No.4 (266) 2021
Meraba No.5 (267) 2021
Meraba No.6 (268) 2021
Meraba No.7 (269) 2021
Meraba No.8 (270) 2021
Meraba No.9 (271) 2021
Meraba No.10 (272) 2021
Meraba No.11 (273) 2021
Meraba No.12 (274) 2021
Meraba No.13 (275) 2021
Meraba No.14 (276) 2021
Meraba No.15 (277) 2021
Meraba No.16 (278) 2021
Meraba No.17 (279) 2021
Meraba No.18 (280) 2021
Meraba No.19 (281) 2021
Meraba No.20 (282) 2021
Annex 27 Exhibit C
Meraba No.21 (283) 2021
Meraba No.22 (284) 2021
Meraba No.23 (285) 2021
Meraba No.24 (286) 2021
Meraba No.25 (287) 2021
Meraba No.26 (288) 2021
Meraba No.27 (289) 2021
Meraba No.28 (290) 2021
Meraba No.29 (291) 2021
Meraba No.30 (292) 2021
Meraba No.31 (293) 2021
Meraba No.32 (294) 2021
Meraba No.33 (295) 2021
Meraba No.34 (296) 2021
Meraba No.35 (297) 2021
Meraba No.36 (298) 2021
Meraba No.37 (299) 2021
Meraba No.38 (300) 2021
Meraba No.39 (301) 2021
Meraba No.40 (302) 2021
Meraba No.41 (303) 2021
Meraba No.42 (304) 2021
Meraba No.43 (305) 2021
Meraba No.44 (306) 2021
Meraba No.45 (307) 2021
Meraba No.46 (308) 2021
Meraba No.47 (309) 2021
Meraba No.48 (310) 2021
Meraba No.49 (311) 2021
Meraba No.50 (312) 2021
Meraba No.51-52 (313-314) 2021
Archive of the “Meraba” newspaper in PDF for 2022
Meraba No.1 (315) 2022
Meraba No.2 (316) 2022
Meraba No.3 (317) 2022
Meraba No.4 (318) 2022
Meraba No.5 (319) 2022
Annex 27 Exhibit C
Meraba No.6 (320) 2022
Meraba No.7 (321) 2022
Meraba No.8 (322) 2022
Meraba No.9 (323) 2022
Meraba No.10 (324) 2022
Meraba No.11 (325) 2022
Meraba No.12 (326) 2022
Meraba No.13 (327) 2022
Meraba No.14 (328) 2022
Meraba No.15 (329) 2022
Meraba No.16 (330) 2022
Meraba No.17 (331) 2022
Meraba No.18 (332) 2022
Meraba No.19 (333) 2022
Meraba No.20 (334) 2022
Meraba No.21 (335) 2022
Meraba No.22 (336) 2022
Meraba No.23 (337) 2022
Meraba No.24 (338) 2022
No.25 (339) MERABA pdfA.pdf
No.26_(340)_MERABA_pdfA.pdf
No.27_(341)_MERABA_pdfA.pdf
No.28_(342)_MERABA_pdfA.pdf
No.29 (343) MERABA pdfA.pdf
No.30 (344) MERABA pdfA.pdf
No.31_(345)_MERABA_pdfA.pdf
No.32_(346)_MERABA_pdfA.pdf
No.33 (347) MERABA pdfA.pdf
No.34 (348) MERABA pdfA.pdf
No.35_(349)_MERABA_pdfA.pdf
No.36_(350)_MERABA_pdfA.pdf
No.37_(351)_MERABA_pdfA.pdf
No.38 (352) MERABA pdfA.pdf
No.39 (353) MERABA pdfA.pdf
No.40_(354)_MERABA_pdfA.pdf
No.41_(355)_MERABA_pdfA.pdf
No.42_(356)_MERABA_pdfA.pdf
No.43_(357)_MERABA_pdfA.pdf
No.44 (358) MERABA pdfA.pdf
Annex 27 Exhibit C
No.45_(359)_MERABA_pdfA.pdf
No.46_(360)_MERABA_pdfA.pdf
No.47_(361)_MERABA_pdfA.pdf
No.48 (362) MERABA pdfA.pdf
No.49 (363) MERABA pdfA.pdf
No.50_(364)_MERABA_pdfA.pdf
No.51-52_(365-366)_MERABA_pdfA.pdf
Exhibit D
Mediacentre n.a. I. Gasprinsky, “Yildiz” Magazine
(translation)

Annex 27 Exhibit D
Translation
Mediacentre n.a. I. Gasprinsky, “Yildiz” Magazine, available at:
https://mediacentr.org.ru/zhurnal-jyldyz/.
Yildiz Magazine - Mediacentre n.a. I. Gasprinsky
Editor-in-Chief: Dlyaver Ibraimovich Osmanov
Legal address: 23a Trubachenko str., Simferopol
Actual address: 23a Trubachenko str., Simferopol
Tel. 598-711; Mobile: +7 (978) 024-46-24
Email address: [email protected]
“Yildiz” Magazine is the world's only socio-political, literary and artistic magazine in the Crimean Tatar
language. “Yildiz” started to be published during the deportation years in Tashkent. A group of Crimean
Tatar writers came up with the initiative to create a literary magazine in the Crimean Tatar language.
After months of pounding the doorsteps of various authorities, permission was granted.
The first issue of “Yildiz” Literary Almanac was published in November, 1976 (it was published as a
biannual almanac till the end of 1979, and as a bimonthly magazine (once in 2 months) from 1980).
The publication played an important role in the preservation and development of the Crimean Tatar
literary language during the deportation. It has published news of Crimean Tatar culture, works of fiction
- stories, novels, plays, verse and poems by Crimean Tatar writers and authors of the pre-war to
contemporary period (Yusuf Bolat, Eshref Shemyi-zade, Ziyadin Javtobeli, Raim Tyncherov, Abduraim
Altanly, Gafar Bulganakly, Mambet Ablyalimov, Shakir Selim, Emil Amitov, Ervin Umerov, Bilal
Mambet, Eskender Fazil, Isa Abduraman, Sheryan Ali and many others), publicism, materials on Crimean
Tatar literature and history, literature criticism, music, and more.
Annex 27 Exhibit D
In December 1991, the editorial staff of “Yildiz” returned home to Crimea. In January 1992, the first
issue of “Yildiz” was published in Akmesjıt (Simferopol). With the return to the homeland, the content of
the magazine changed dramatically and was enriched with new materials on the history and literature of
the Crimean Tatar people.
Over the more than 40 years of the Magazine’s existence, many writers and journalists have worked in
various positions at the editorial office: Shamil Alyadin, Uriye Edemova, Riza Fazil, Cherkez-Ali, Safter
Nagaev, Ibraim Pashi, Shevket Ramazanov, Aider Osmanov, Ablyaziz Veliyev, Zakir Kurtnezir, Lenyar
Dermendzhi, Yusuf Aliyev, Sabriye Seutova, Dilyara Seitjelilova, Najie Ametova, Adkhat Sinogul and
others.
Poet Cherkez-Ali was editor-in-chief from 1976 to 1979, writer Shamil Alyadin from 1980 to 1985,
writer Ajder Osman from 1985 to 1998, poet Shakir Selim from 1998 to 2008, and poet Dilyaver Osman
since 2009 till present.
“Yildiz” Magazine is a jewel of Crimean Tatar culture, which we should all preserve and do everything
necessary for its development.
Exhibit E
Archive of “Yildiz” magazine
(translation)

Exhibit F
Mediacentre n.a. I. Gasprinsky, For teachers of the native language: a scientific-methodological
guide for teachers of the Crimean Tatar language and literature. No. 1 (15) (16 July 2018)
(translation)

Annex 27 Exhibit F
Translation
Mediacentre n.a. I. Gasprinsky, For teachers of the native language: a scientific-methodological
guide for teachers of the Crimean Tatar language and literature. No. 1 (15) (16 July 2018),
available at: https://mediacentr.org.ru/2018/07/16/ana-tili-odzhalaryna-kyrymtatar-tili-veedebiyaty-
odzhalary-ichyun-ilmij-usulij-medzhmua-1-15/.
EDITIONS
For teachers of the native language: a scientificmethodological
guide for teachers of the Crimean Tatar
language and literature. No. 1 (15)
For the Teachers of Native Language: Scientific and Methodological Journal for Teachers of the
Crimean Tatar Language and Literature. No. 1 (15). - Simferopol: Mediacentre n.a. I. Gasprinsky,
2018. - 56 с.

Exhibit G
Mediacentre n.a. I. Gasprinsky, Arzy
(translation)

Annex 27 Exhibit G
Translation
Mediacentre n.a. I. Gasprinsky, Arzy, available at: https://mediacentr.org.ru/arzy/.
ARZY
The Crimean Tatar magazine "Arzy" is a colorful, richly illustrated publication, which publishes
materials aimed at the preservation and development of the native language, culture, traditions,
customs and rituals of the Crimean Tatars. On its pages you can read interesting historical materials
telling about the activities of prominent Crimean Tatar women, literary works, get acquainted with
the bright contemporaries, who contributed to the development of Crimea, with the masters of arts
and crafts, whose activities are aimed at developing national traditions in folk and crafts, handed
down from generation to generation. The magazine is focused on moral, ethical and cultural values
that never lose their relevance at any time.
Subscription index 78301
Cost of subscription for six months: 180, 36 roubles
Khalilova Lentara Kemalovna
E-mail: [email protected]
tel: +7978 802 46 55

Exhibit H
Golos Kryma, Homepage (17 February 2023)
(translation)

Exhibit I
Roskomnadzor, Certificate No. FS 77-60738, 11 February 2015
(translation)

Annex 27 Exhibit I
Translation
Roskomnadzor, Certificate No. FS 77-60738, 11 February 2015, available at:
https://rkn.gov.ru/mass-communications/reestr/media/?id=538108&page=.
MINISTRY OF DIGITAL DEVELOPMENT, COMMUNICATIONS AND MASS MEDIA OF
THE RUSSIAN FEDERATION
FEDERAL SERVICE FOR SUPERVISION OF COMMUNICATIONS, INFORMATION
TECHNOLOGY AND MASS MEDIA (ROSKOMNADZOR)
Golos Kryma new
Certificate number PI No. FS 77-60738
Registration date 11 February 2015
Certificate status Valid
Media outlet name Golos Kryma new
Form of distribution printed media/newspaper
Area of distribution Republic of Crimea
Sevastopol
Founder(s) E.T. Seitbekirova
Address of the editorial office 11 Chichibabina Street, Pionerskoye, Simferopol District,
Republic of Crimea, 297577
Languages Russian, Crimean Tatar, Ukrainian
This article is available at: https://rkn.gov.ru/mass-communications/reestr/media/?id=538108

Exhibit J
RIA Novosti, Aksyonov: Incitement to Hatred in Crimea is unacceptable at this difficult time
(19 March 2015)
(translation)

Annex 27 Exhibit J
Translation
RIA Novosti, Aksyonov: Incitement to Hatred in Crimea is unacceptable at this difficult time
(19 March 2015), available at: https://ria.ru/20150319/1053392148.html.
Everyone who incites conflicts, whether in media or elsewhere, will not be able to work in the
Republic, Crimean leader Sergey Aksyonov said. In particular, he drew attention to the activities
of the Crimean Tatar TV channel ATR.
Moscow, 19 March, RIA Novosti. Inciting hatred between different peoples in Crimea during
these difficult times is unacceptable, so all those who do so in one way or another, in particular,
mass media, will not be able to work in the Republic, Sergey Aksyonov, Head of the Republic of
Crimea, told reporters on Thursday on the sidelines of a round table discussion held in Moscow
on the occasion of the ninth anniversary of the reunification of Crimea and Russia.
According to him, it is unacceptable when people “are pitted against each other on a national
basis in an attempt to drive a wedge between us, Russians and Crimean Tatars, who have lived
here for centuries”.
“That will never happen, one way or another. Therefore, all those who will incite conflicts, be it
mass media or anyone else, will not be able to work in the Republic”, Mr. Aksyonov said.
In particular, the Crimean leader drew attention to the activities of the Crimean Tatar TV channel
ATR.
“We have made it clear to the TV channel’s management that it is unacceptable to escalate the
situation and cause a sense of tension among the population by giving some people hope that
Crimea will return to Ukraine while inciting other people to act and speaking of how they will
then deal with those who have received Russian passports – those TV channels should not be
allowed to work in the Republic during the current paramilitary period”, Mr. Aksyonov said.

Exhibit K
Crimeantatars.club, Homepage (17 February 2023)
(translation)

Exhibit L
Crimeantatars.club, IV Crimean Tatar Book Fair is the Brightest Event of Autumn 2022
(13 September 2022)
(translation)

Annex 27 Exhibit L
Translation
Crimeantatars.club, IV Crimean Tatar Book Fair is the Brightest Event of Autumn 2022 (13
September 2022), available at: https://www.crimeantatars.club/culture/literature/ivkrymskotatarskaya-
knizhnaya-yarmarka-samoe-yarkoe-sobytie-oseni-2022.
The IV Crimean Tatar Book Fair, one of the most anticipated events of this autumn, took place
in Crimea last weekend. This year, the Fair presented 20 new books written by Crimean Tatar
authors, including children’s, educational, research and fiction literature as well as interesting
media projects. A creative meeting dedicated to the memory of Shakir Selim, a Crimean Tatar
classical writer, became a special attraction of the Fair. More than 5,000 people visited the Fair
in one day this year, each of them taking away books and vivid impressions from the festive
event. See our story to discover how it was going on.

Exhibit M
Crimeantatars.club, Full video of meeting with journalist and writer Zera Bekirova
(20 November 2020)
(translation)

Annex 27 Exhibit M
Translation
Crimeantatars.club, Full video of meeting with journalist and writer Zera Bekirova (20
November 2020), available at: https://www.crimeantatars.club/life/society/polnayavideoversiya-
vstrechi-s-zhurnalistom-i-pisatelem-zeroj-bekirovoj.
By the Editorial Board
Watch the full video of a meeting with Zera Bekirova, a chronicler of the history of the Crimean
Tatar national movement, an eminent writer, and a journalist. During the meeting, Ms. Bekirova
shared her research, spoke about creativity and answered questions asked by young people.

Exhibit N
Crimeantatars.club, Meeting with coppersmith master Rustem Dervish (full video)
(28 May 2022)
(translation)

Annex 27 Exhibit N
Translation
Crimeantatars.club, Meeting with coppersmith master Rustem Dervish (full video) (28 May
2022), available at: https://www.crimeantatars.club/life/people/vstrecha-s-rustemomdervishem-
polnaya-versiya.
By the Editorial Board
A meeting with Rustem Dervish, the creator of the famous Dervish Evi Ethnographic House
Museum in Bakhchysarai, a master coppersmith, a collector, and a researcher, took place on the
28th of May in the Sarabuz Ethnic Complex. By the way, he celebrates his 59th birthday today.
Watch the full version of the meeting by clicking the link below.

Exhibit O
Crimeantatars.club, Meeting with Crimean Tatar national movement veteran Arsen Alchikov
(video) (30 August 2020)
(translation)

Annex 27 Exhibit O
Translation
Crimeantatars.club, Meeting with Crimean Tatar national movement veteran Arsen Alchikov
(video) (30 August 2020), available at: https://www.crimeantatars.club/life/society/vstrechas-
veteranom-natsionalnogo-dvizheniya-arsenom-alchikovym-videoversiya.
By the Editorial Board
We continue sharing videos of various meetings of veterans of the Crimean Tatar national
movement with young people as arranged for by Qaradeniz Production Studio. One such meeting
took place with Arsen Alchikov. Crimean Tatars call such people “those who have opened the
way to the Motherland”.

Exhibit P
Canli.online, CANLI – a new generation of Crimean Tatar media
(translation)

Annex 27 Exhibit P
Translation
Canli.online, CANLI – a new generation of Crimean Tatar media, available at:
https://canli.online/about/.
CANLI is a new-generation
Crimean Tatar media outlet.
We are all a team of friends and professionals
who listen to good music, read native
literature, are interested in history
and ponder the future.
100
videos
40000
social media followers
800000
views of our product
3
years of live streaming
Annex 27 Exhibit P
Our ultimate task is to preserve
Crimean Tatar cultural heritage and
develop it in modern formats.
In four years, we have created a Crimean Tatar
radio station in a 24/7 format from scratch,
launched the Ders media lecture series,
recorded the best Crimean Tatar audio books,
and launched a video blog about our contemporaries.
Working to create and
promote Crimean Tatar
cinematography
More about cinematography here
Exhibit Q
Ministry of Culture of the Russian Federation, “The Possesed” Film Distribution Certificate No.
111030522, 8 November 2022
(translation)

Annex 27 Exhibit Q
Translation
Ministry of Culture of the Russian Federation, “The Possesed” Film Distribution
Certificate No. 111030522, 8 November 2022, available at: https://culture.gov.ru/
services/reestr-prokatnykh-udostovereniy/5750863/#.
“The Possessed”
Drama
Year 2022
Country of production Russia
Director E. Ablayev
Scriptwriter E. Ablayev
Producer IE Ablayeva Nadzhiye Femiyevna
Composers U. Bekirov, A. Osmanov, and B. Abdullayev
Art director S. Gavrilenkov
Production studio IE Ablayeva Nadzhiye Femiyevna (trademark: CANLI
Production)
Colour Coloured
Publicity rights Screening in cinema halls, distribution on tangible media,
and screening by other technical means
Age category 16+
Duration, minutes 27
Distribution certificate number 111030522
Distribution certificate issue date 8 November 2022

Exhibit R
Taurica.net, The Forgotten Leader of the Crimean Tatar People – Dead Opponent of Dzhemilev
in the Early 1990s (9 December 2016)
(translation)

Annex 27 Exhibit R
Translation
Taurica.net, The Forgotten Leader of the Crimean Tatar People – Dead Opponent of
Dzhemilev in the Early 1990s (9 December 2016), available a:
https://taurica.net/238739-Zabytyiy-lider-krymsko-tatarskogo-naroda-pogibshiiy-protiv
nik-Dzhemileva-v-nachale-90-h.html.
The Forgotten Leader of the Crimean Tatar People – Dead Opponent of
Dzhemilev in the Early 1990s
By Informer
Today, the phrase “the leader of the Crimean Tatar people” brings to mind only Mustafa
Dzhemilev, whose personality has been effectively made into a cult by human rights activists
and the ideology of post-Maidan Ukraine. A man with harsh nationalist views, an ardent
opponent of the Armenian genocide recognition, a destroyer of his compatriot opponents,
calling for an ethnic conflict in Crimea and devoting his last decades to the struggle for power in
the Verkhovnaya Rada, this, in fact, is all him, the self-proclaimed “leader” of an entire nation,
says Novoross.info.
Dzhemilev, his supporters and sponsors did everything they could to make sure that his killed
and ostracised Crimean Tatar movement opponents were eventually forgotten.
Sooner or later, justice will prevail anyway, and the “the leader of the Crimean Tatar people”
will be firmly associated with Yuri Bekirovich Osmanov, a prominent representative of the
Soviet intelligentsia, a scientist, writer and publicist who devoted his life to a peaceful return
and the restoration of the honest name of the Crimean Tatar people.
Annex 27 Exhibit R
The dissident’s life path was chosen under the strong influence of his father, Bekir
Osmanovich, who was rejected from the army during WWII because of his cardiac defect, but
with the arrival of German troops joined the partisans and did reconnaissance for the
Sevastopol, Akmechet detachments and the Central Headquarters of the Crimean partisan
movement. It was he who instilled in Yuri a love for the history and culture of the Crimean
Tatar people.
In 1958, Yuri graduated from school with a gold medal and went up to the Moscow State
University but was not accepted because of his nationality. With the assistance of the Crimean
Tatar national hero, pilot Sultan Amet-Khan, he managed to enter the Bauman Moscow Higher
Technical School, from which he graduated in 1965 with a degree in mechanical engineering.
He worked at the Joint Institute for Nuclear Research in Dubna and the Institute for High
Energy Physics (Serpukhov).
While at the institute, Yuri Osmanov became an active participant of the Crimean Tatar
movement and began to study the legacy of the Crimean Tatar educator Ismail Gasprinsky,
devoting his whole life to studying his works. As a student, he began to write poetry and later
also did literary translations of poems by Crimean Tatar poets, published in outlaw
underground press known as “Samizdat”.
As a dissident, he was arrested many times. In 1973 and 1974, Yuri and his father organised and
conducted a self-census of the Crimean Tatar people, from which he derived the total number of
Crimean Tatars deported from Crimea. He drew up seven formal notes concerning damage
caused to Crimean Tatars by deportation and drafted a statement of claim on behalf of the
Crimean Tatar people which he sent to the UN and the USSR supreme authorities. Yuri was
also an active public figure whose initiative helped prevent the impending massacre of the
Crimean Tatars during the riots in Fergana in 1989.
Yet, the Crimean Tatar national movement was never cohesive. The movement was represented
by various “initiative groups”, who created the so-called Central Initiative Group in the spring
of 1987. The key role in the creation of the Group was played by Mustafa Dzhemilev. This
group later became the core of the Crimean Tatar National Movement Organisation, aka
OKND, which in 1989 took shape as a political party. Some groups, for example, the so-called
Fergana Valley Group of Yuri Osmanov, did not join the Central Initiative Group, laying the
groundwork for the national movement of Crimean Tatars, aka NDKT. This was when the
confrontation between Osmanov and Dzhemilev broke out.
The more conservative NDKT and the OKND were separated by fundamental disagreements.
The NDKT strove after the restoration of the Crimean ASSR under Lenin's decree of 1921 and
counted on the assistance of the USSR’s party and state leadership, while the OKND strongly
opposed the Soviet system and counted on the creation of national statehood.
Dzhemilev immediately adopted nationalistic ideology and moved into extremism, getting
ready for seizure of land in Crimea and confronting the authorities and law enforcement.
Having enlisted the support of local authorities, the OKND summoned a “national congress”
(Qurultay) of the Crimean Tatars in 1991. The Congress decisions caused a serious aggravation
in Crimean interethnic tensions as it announced the creation of the Crimean Tatar national state
in Crimea, being the ultimate goal, declared all subsurface resources and waters the property of
only Crimean Tatar people and considered all other residents of Crimea, in fact, as illegal
outsiders and second-class citizens.
Annex 27 Exhibit R
Qurultay established a special body to govern the movement, the Crimean Tatar People’s
Mejlis, effectively a shadow nationalist government of Crimea, acting accordingly.
In contrast, the NDKT tried to find a way to avoid any new tragedies and bloody conflicts when
returning the Crimean Tatars to their historical homeland. Yuri Osmanov accused radical
opponents of striving for momentary political success, which could make Crimean Tatars
uninvited guests on their own land. He was convinced that his opponents from the OKND were
driven by the lust for power and profit rather than by concern for the future of their people.
Soon, though, Yuriy Bekirovich and the NDKT were sidelined for opposing the misuse of
financial resources allocated from the USSR budget by the Crimean authorities. So, the
organised resettlement of the Crimean Tatars was in fact disrupted, a spontaneous return,
unauthorized seizure of land and conflict between the Crimean Tatars and the authorities began.
After his dismissal, Yuri Osmanov devoted himself to the prevention and averting of any
potential ethnic and social conflict situations related to the mass return of Crimean Tatars to
Crimea. It soon turned out that while Osmanov and his organisation were making every
possible effort to rule out ethnic conflict in Crimea, the Mejlis leader was telling the media
about "the inevitability of armed clashes between the Crimean Tatars and the Russian
population in Crimea," referring to the readiness of the Crimean Tatars to take up arms and
essentially calling on the Turkish authorities to intervene. Osmanov went to the editorial offices
of those newspapers that had published an interview with Dzhemilev and protested against such
publications...
Shortly thereafter, on the 6th of November 1993, Yury Osmanov was severely beaten on his
way home from work and died of his injuries the next day. The death of such a bright leader,
capable of developing political theory and turning it into practice, led to the actual decline of the
NDKT. So Dzhemilev became the sole "leader" of the Crimean Tatar people.
As never before, Yuri’s words about the Mejlis ring true today, “The Mejlis was called upon to
inflame the non-Tatar population in Crimea with hysterical, openly provocative and absolutely
useless "physical" actions and scandals. All these actions are mere ventures played out solely
for the empire’s own interests or grand national and political intrigue schemes. Mejlis is about
trade and profiting from the people who are in such a dramatic state.”
Yet justice will one day prevail, and "the leader of the Crimean Tatar people" will be firmly
associated with Yuri Osmanov.

Exhibit S
Gazeta.ua, Norik Shirin Killed in Garage (21 December 2006)
(translation)

Annex 27 Exhibit S
Translation
Gazeta.ua, Norik Shirin Killed in Garage (21 December 2006), available at:
https://gazeta.ua/ru/articles/ukraine-newspaper/_norika-sirina-ubili-v-garazhe/144219
By Vladimir Grebenkin
On Wednesday, Norik Shirin, 22, the leader of Birlik (which means “Unity” in Tatar), a Crimean
youth public organisation, was found killed in Simferopol. He was discovered lying in a garage
near his car. There were seven knife wounds on his body.
“I’ve known him for a long time, we’ve been friends since we were five years old”, says Zhenya,
20, a friend of Norik. “He was always cheerful and in a good mood. He did not say anything bad
to anyone, even if he was angry. With a smile on his face, he explained to a person what he or
she was wrong about. He was fair and balanced”.
According to her, Shirin was fond of history. He wrote poetry and read some of them to his
friends and acquaintances.
“It was his idea to establish Birlik. He wanted to unite the Crimean youth regardless of their
nationalities. We do not belong to any political parties or forces”, Zhenya says.
Norik Shirin studied at the Faculty of Economics of the Vladimir Vernadsky Taurida National
University. He was a member of the Youth Policy Council under the speaker of the Crimean
Verkhovnaya Rada. He founded and published his own newspaper named Golos Molodyozhi
(Voice of Youth). A few days ago, he received a permission from the Ukrainian National TV and
Radio Broadcasting Council in Kiev to launch a youth radio station in Crimea.
Norik is survived by his parents and two younger brothers, Ibrahim, 19, and Arslan, 14.
He was buried on Thursday in Simferopol.

Exhibit T
Milli Firka, Nothing Is Worse Than Someone Else's Rightness, Nothing Is Better Than One's
Mistakes (12 October 2010)
(translation)

Annex 27 Exhibit T
Translation
Milli Firka, Nothing Is Worse Than Someone Else's Rightness, Nothing Is Better Than One's
Mistakes (12 October 2010), available at: http://milli-firka.org/нет-ничего-хуже-чужой-
правоты-нет-ниче/.
By Elvira Seitova
Golos Kryma No. № 41 (876), 9 October 2010
Why do you think prominent, well-known veterans of the Crimean Tatar national movement and
socio-political figures have been breaking away from the Qurultay-Mejlis system, whether
individually or in whole groups, for a certain period of time? After all, you will agree that
making such a decision is not that simple. Withdrawing from the sole national self-government
structure means losing a sense of belonging to what was supposed to be in the public domain. A
solid, resilient and professional alternative is emerging today. And there are almost as many big
oppositionist names as there are those who consider the Mejlis to be the only authorised
representative body of the Crimean Tatars. The reason lies in the usurpation of power, the
existence of only one decision-making centre, and the dominance of vested interests. Born in the
womb of the Crimean Tatar people, the original system was essentially unbiased and democratic,
but was then stubbornly reshaped into a court retinue, an obedient silent mass of people, and a
caste of the “chosen ones”. However, as recent events have shown, it is well possible to lose the
“bridle” even under those conditions. For a long time, those daring to express their views in the
national parliament were advised to go out, take the air, regain consciousness, and then only go
back. And those who did not understand what was expected of them at all and those who
methodically refused to build themselves in the “right” framework have been called “public
enemies” and accursed. There was a strong conviction that the “sacred insights”, i.e. decisions
really necessary for the people, could only be born in the minds of the leaders and in no one
else’s. So it turned out that while the ideas voiced by the Qurultay delegates a few years ago
were then perceived by the tops as nonsense, the famous exclamation “Eureka!” was heard from
the leaders after a while!
In his recent interview with Golos Kryma, Refat Chubarov said, “There is no longer any doubt
that the elections of the Qurultay delegates, which will take place in 2012, will also be held by a
secret ballot based on a universal, equal and direct suffrage. I am convinced this will be a
qualitative breakthrough in the activities of the national self-government bodies of the Crimean
Tatar people” (see Golos Kryma No. 39 dated the 24th of September). It should be noted that
until now the first deputy chair of the Mejlis had been a staunch supporter of the two-tier system
with 50 people electing an elector and 20 electors electing one delegate of the Qurultay. It is
interesting to know what contributed to such a change in his views.
Perhaps, at the initial stage, when the structure of the national self-government was just being
formed, a stepped election system was a reasonable choice. As the migration process was
Annex 27 Exhibit T
underway, most people did not live at their registered places of residence, which means there
was a kind of the Brownian motion of people on the peninsula. But this approach to electing the
Qurultay delegates became increasingly subject to harsh criticism over time. Apparently, the
frightening facts of falsification of the election results could not help but catch the eye.
According to the regulation on the election of the Qurultay delegates, electors were elected at
meetings of residents, but it turned out that the desire to attend such meetings was simply
eradicated knocked out among the Crimean Tatars; then they chose another way by deciding to
collect approvals in favour of an elector. 50 signatures collected meant the status of an elector.
The trick was to obtain a form to be used by applicants when visiting their compatriots. After all,
such paper descended from the Central Headquarters to the regions and from there to the local
mejlises. And it was there that the coveted document fell into the hands of the “right guys”. If the
chair of a local mejlis does not like you, you will never get that document even if you try as you
might. The validity of all signatures was also questionable – although we will not assert they
were all fabricated, but what is now called nepotism did take place.
By and large, at first glance, electoral conferences were held in an unbiased manner. The process
was especially improved when representatives of political and public organisations were
involved in it. Moreover, observers were introduced. We emphasise that falsifications took place
at the first level, namely during the election of electors, when people were frankly deprived of
their ability to directly participate in the election process. The situation clearly contributed to the
establishment of a clan system.
Talks about abolishing the two-tier system and introducing a direct suffrage have become
particularly acute since the mid-2000s. Realising the malignant nature of such an approach to
electing delegates, Azatlyk, a well-known group of Mejlis members consisting of Nadir Bekirov,
Aider Mustafayev, Sinaver Kadyrov, Eskender Bariyev, and Eldar Seitbekirov, tried to lobby for
the introduction of a direct ballot. After all, this step could stimulate the Crimean Tatars by
giving them an opportunity to make their own choice. That would make it possible for them to
feel themselves responsible and directly involved in the national congress. A scheme of the
election process and a mechanism for financing the campaign were also developed. At the 2006
Qurultay Session, Ayder Mustafayev and Sinaver Kadyrov, standing at their microphones in the
delegates’ meeting room, aggressively defended their position. Their main opponents – Mustafa
Dzhemilev and Refat Chubarov – sat in the presidium and completely rejected reasonable
proposals made by the speakers. They insisted on the irrationality of the idea and referred to the
lack of funds to implement the reform. Of course, they were supported by a majority of those
present. So the idea of introducing a direct secret ballot was blocked. “When electing electors at
meetings of compatriots or electoral conferences, where Qurultay delegates are already elected,
if the required quorum is absent, then you can postpone the meeting or conference for one or two
weeks during which you can take steps to secure the quorum. In direct elections, elections should
be held everywhere on the same day, and if the elections are postponed for a week or two due to
a weak turnout, they will become several times more expensive”, commented on this issue the
chair of the Mejlis in his report. Should we assume that the Mejlis does not encounter any such
issues today?
Years later, the initiators of the reform commented on Mr. Chubarov’s current position as
follows:
Sinaver Kadyrov: “Mr. Chubarov’s statement that the upcoming elections of the Qurultay
delegates will most likely be held by a direct secret ballot only shows that the awareness of the
need to reform the system of national self-government of the Crimean Tatars has already reached
the highest echelon of our representative body. However, if we limit our reforms to changing the
procedure for electing the Qurultay delegates and decide that we have made a huge
Annex 27 Exhibit T
breakthrough, then we well be mistaken. No doubt, the procedure for electing the Qurultay
delegates does need be changed, but it is equally important to reform the Qurultay itself as an
institution”.
Ayder Mustafayev: “At one time, at the last Qurultay session which I participated in, Refat
Chubarov did everything possible and impossible to cause a well-developed design for electing
the Qurultay delegates, enabling every Crimean Tatar to participate through a direct secret ballot,
to fail. Then we calculated the costs, trying to take into account everything to the smallest detail.
I want to dwell on one point that fully characterises the tops of the Mejlis. Then they said,
‘Dostlar, can you imagine who will become members of the Qurultay as a result of direct
elections?’ They were afraid that people who did not like them for one reason or another would
become members of the Qurultay. The Qurultay-Mejlis structure, which is completely
illegitimate at the moment, is trying to impose some new rules, which, again, they will control.
Can we allow one and the same person to be the chair of the election commission, a member of
the Mejlis, and the chair of a regional mejlis?”
However, life dictates its own rules. The elections of the recent years have shown a considerable
decrease in the electoral activity of Crimean Tatars. Fewer and fewer people believe they can
have any influence on the outcome of elections. Here, apparently, it turns out that Mr. Dzhemilev
and Mr. Chubarov now adopt the same arguments they had completely rejected previously. So,
as Sinaver-aga has already noted, the Qurultay decided to change the election system, but only at
the level of local mejlises. But this initiative has been half-hearted until today. And most
importantly, the elections did not take place in the Crimean capital and the Simferopol District.
It is no longer possible to ignore the fact that a new generation of politicians and officials has
grown up among our people, who, through their activities, are connected with and depend on
various political forces. In turn, various Crimean Tatar organisations conclude friendship and cooperation
alliances with the players they like. In this situation, loudly asserting that there is only
one authorised representative body of Crimean Tatars would be shaking the air in vain.
No wonder it is right now – during those critical days – that they recall the reforms again and
will definitely talk about them especially loudly after the 31st of October, when the situation will
become even more depressing for the Mejlis. One thing is quite obvious; if the actions taken are
half-hearted and accompanied by scandals and the results are manipulated and re-voted, then
there will be more harm than good from those actions.
In our opinion, there is only one way to revive the Crimean Tatar representative body and make
it truly popular. This includes a number of steps to be taken. First, we should begin negotiations
with all political groups of compatriots. Second, we should create an organising committee to
include all and any interested persons without using any methods to downplay their roles and
overestimate the importance of the Mejlis members or the Qurultay delegates. Third, we should
form the Central Election Commission on a parity basis, provided that those people involved in
its activities should not run for the national parliament. Only a system based on those principles
should develop a provision on direct secret elections of the Qurultay delegates. Only in this case
will the national congress be able to work effectively and gain the authority of an actual majority
of the Crimean Tatars by showing the results of its activities. Otherwise, the centrifugal trends
will increase further.
We understand that much of the foregoing does not correspond to the political nature of the
Mejlis functionaries. Taking such a step would mean voluntarily recognise the fact that they are
not the only authorised flagships of the nation – with all the ensuing consequences. But you can’t
argue against the fact. Follow the logic. Originally, the Mejlis’ authority was indisputable. Then
Annex 27 Exhibit T
some individuals and, later, groups began to break away from it. Now, a full-blooded opposition
to the Mejlis is acting and developing. Every ambitious Crimean Tatar politician standing outside
the Qurultay-Mejlis system is looking for and, importantly, finding partners and associates. So,
sooner rather than later, the power concentrated in the hands of today’s oppositionists will
become really colossal. But, unfortunately, it will remain dispersed. In the end, we should ask
ourselves this question; will the stubborn ignorance of compatriots having alternative views
continue to prevail among the tops of Mejlis despite the fact they can foresee it now?
Exhibit U
Qurultay of the Crimean Tatar People, Regulation “On the Election of Delegates of the Qurultay
of the Crimean Tatar People”, 12 January 2013
(excerpt, translation)

Annex 27 Exhibit U
Excerpt
Translation
Qurultay of the Crimean Tatar People, Regulation “On the Election of Delegates of the
Qurultay of the Crimean Tatar People”, 12 January 2013, available at:
http://web.archive.org/web/20140323224623/http://qtmm.org/положение-о-выборах-
делегатов-курултая-крымскотатарского-народа.
REGULATION ON THE ELECTION OF DELEGATES OF THE QURULTAY OF THE
CRIMEAN TATAR PEOPLE
I. GENERAL PROVISIONS
Article 1. General Principles of Electing Delegates of the Qurultay of the Crimean Tatar People
1.1. Delegates of Qurultay of the Crimean Tatar people (hereinafter - delegates) shall be elected by
the citizens of Ukraine - Crimean Tatars and their family members, who have reached 18 years of age
on the day of voting, on the basis of common, equal and direct suffrage by secret ballot.
1.2 A Crimean Tatar citizen/citizen of Ukraine and his/her family member regardless of political,
religious and other beliefs, social origin, property status, who is 21 years old on the day of election,
speaks Crimean Tatar and has the right to vote can be elected as a delegate of Qurultay of the Crimean
Tatar people.
1.3 The right to nominate candidates for delegates belongs to the citizens of Ukraine - Crimean Tatars
and members of their families who have the right to vote. This right is exercised by them through the
Crimean Tatar public and political organisations and their blocs, or by self-nomination according to
the procedure set forth in this Regulations.
1.4 The number of members of Qurultay of the Crimean Tatar people shall be 250 delegates.
1.5 The election of the delegates shall be based on a mixed (majoritarian-proportional) basis:
- 200 delegates are elected under the first-past-the-post voting system in the multi-member electoral
districts (hereinafter - the multi-member majoritarian electoral district) and the single-member
electoral district, which includes the city of Kiev and the settlements of the Kiev region;
- 50 delegates are elected under the proportional representation system in a single multi-member
electoral district (hereinafter - a single multi-member electoral district) by the electoral lists of
Crimean Tatar public and political organisations and their blocs.
1.6. One and the same person has the right to simultaneously run for delegates in a multi-member
majoritarian electoral district or a single-member electoral district, which includes the city of Kiev
and settlements of Kievskaya oblast, and a single multi-member electoral district.
1.7 The term of office of the Qurultay delegates is 5 years.

Exhibit V
Crimea24.info, Exceptional Violations Noted during Crimean Tatar Qurultay Elections
(14 May 2013)
(translation)

Annex 27 Exhibit V
Translation
Crimea24.info, Exceptional Violations Noted during Crimean Tatar Qurultay Elections (14
May 2013), available at: https://crimea24.info/2013/05/14/na-vyborakh-v-kurultajjkrymskikh-
tatar-zafiksirovali-unikalnye-narusheniya-pravil-vyborov/.
By watcher
The number of violations noted by observers from the Crimean Branch of the Committee of
Voters of Ukraine (CB CVU) during the Crimean Tatar Qurultay elections in the Kirovsky
District and the town of Sudak was high, but the nature of the violations has changed.
This is a statement made by Andrey Krisko, the head of a non-governmental organisation.
According to him, problems with organising the voting process and drawbacks in the Election
Regulations have come to the fore at this stage. In addition, CB CVU noted an increase in the
number of cases of campaigning on election day, use of various “dirty” election tricks, and
violation of the secrecy of vote.
“In one of the villages of the Kirovsky District, a candidate to the Qurultay was present at the
polling station asking the voters if they knew who to vote for, and after they dropped their ballots
he would try to unfold the ballots in the ballot box with a ruler to find out who the people had
voted for,” said Mr. Krisko.
He added that one of the polling stations failed to open at all due to organisational problems,
depriving many residents of the community of the opportunity to exercise their right to vote.
Moreover, the Election Regulations did not describe the procedure of voting at home, so the
electoral commissions acted at their own discretion at each polling station; in some places they
went out to all and sundry, in other places, only to those who had filed applications, while in
some other cases they did not go out at all to those who were unable to come to the polling
stations for health reasons.
Among the positive trends, the members of the Committee of Voters noted a significant
reduction of violations related to voters receiving ballots without presenting their passports. Such
violations, however, were isolated and only observed at a few polling stations. The NGO
believes this is a result of the awareness campaign conducted by the Qurultay Central Electoral
Commission among the members of district electoral commissions after the CB CVU traced
wide-spread violations of the ballot issuance procedure at the previous voting stage.
Last week, the Crimean Branch of the Committee of Voters of Ukraine reported that the
Qurultay elections in the Razdolnensky, Pervomaisky, Alushta, Feodosia and Saki Regions saw
multiple violations that could have affected the election results.
As Crimea24 has already reported, the Crimean Tatar Qurultay election campaign will end on
the 15th of June. At the next stage of the elections, the voting will take place on the 25th of May
in the City of Kiev and the Kiev Region.

Exhibit W
Milli Firka, Wide-Scale Violations During Qurultay Election (19 June 2013)
(translation)

Annex 27 Exhibit W
Translation
Milli Firka, Wide-Scale Violations During Qurultay Election (19 June 2013), available at:
http://milli-firka.org/выборы-делегатов-курултая-прошли-с-ма/.
Wide-scale violations have been observed during the final stage of the 6th convocation Crimean
Tatar Qurultay election in Crimea.
The violations have been noted by the Central Election Commission for the Qurultay election
and by the observers of the Committee of Voters of Ukraine.
In a comment on the Qurultay election, Andrey Krisko, the head of the Crimean branch of the
Committee of Voters of Ukraine, said that “from the very beginning, at the first stages,
everything was very suspicious, especially the widespread issuance of ballots against
photocopies rather than original passports”. According to Mr. Krisko, the number of such cases
decreased significantly later on, but the observers from the Committee of Voters of Ukraine still
documented some violations.
Mr. Krisko also added that violations such as failure to open or late opening of polling stations,
campaigning on the voting day, failure to observe ballot issuance procedure have been recorded.
For example, a polling station in Yalta started its work more than an hour late, while another one
changed its address. In the village of Saffron, Simferopol District, the polling station was closed
at noon.
In the Simferopol District, some voters did not vote at their polling stations. “In the Simferopol
District, one of the main violations was that some people who were registered as voters with a
certain polling station went to another polling station because the first one was too far away from
them. This is a clear violation because they had to choose from majority election candidates but
ended up voting for completely different people,” explains the head of the Crimean branch of the
CVoU.
The Crimean branch of the Committee of Voters of Ukraine will prepare recommended practices
for the Qurultay Central Election Commission to improve the election procedure.
Let us remind you that the Crimean stage of the 6th convocation Crimean Tatar Qurultay election
has ended in Yalta. The final stage of the Qurultay elections will be held in Uzbekistan.

Exhibit X
Milli Firka, Their Qurultay Election Passed (30 July 2013)
(translation)

Annex 27 Exhibit X
Translation
Milli Firka, Their Qurultay Election Passed (30 July 2013), available at: http://millifirka.
org/прошли-выборы-их-курултая/.
By Ulker Amzaev
In the early turbulent 1990s, Crimean Tatars literally rushed into the Ukraine’s political life with
their demands, viewpoints, and self-organisation… At that time, all the public and political
figures had the appearance of some sort of trainees, except for the Communists, of course, who
looked like political hippos compared to other actors.
Against that background, the creation of the Qurultay-Mejlis system seemed to be a major
breakthrough and pinnacle of the national self-organisation of the Crimean Tatar people. It
looked like a real achievement, not only on a regional scale but for the entire Ukraine.
But the fledging period ended quite quickly, as it should have. Changes manifested themselves
through deeper nation-building processes, more professional authorities, and attempts
(sometimes successful) to democratise the social and political life. However, the Qurultay-Mejlis
system has not been able to evolve into an established and healthy organism on track for a
successful future. Despite the potential that existed.
The reason why we are talking about this is clear to many people. But the leaders and heralds of
the Mejlis are persistent in positioning their brainchild as the only viable structure that should
represent the Crimean Tatars and handle the distribution of all the benefits they are entitled to.
These arguments are based on the allegedly popular election of the national parliament,
Qurultay, which in turn appoints the right people to the necessary positions and decides
everything for all.
On one occasion, when Akhtem Chiygoz, an avid spokesperson for the Mejlis, relented at a TV
show, he said that discussions were permitted until a decision was made by the Qurultay, but
there should be no dissent after the voting …
Well, if that is how the question is put, then Qurultay elections must be set up perfectly. That’s a
given, because it is the Qurultay that puts everything and everyone right and determines the
course for the entire people!
Annex 27 Exhibit X
But is this really the case?
What Has the Mountain Brought Forth?
The issue of the Qurultay election system has always excited the politically active public. Let us
remind you that initially the Qurultay was elected through a two-stage system: 30 to 35 voters
chose one elector, then 30 electors chose one delegate (who represented approximately 1,000
Crimean Tatars), then it was changed to 50 voters choosing one elector, and 20 electors choosing
one delegate. Frankly speaking, the algorithm is questionable. But it was difficult to come up
with something more manageable during the fledging period.
As everyone knows, it does not take long for a growing organism to overgrow its childhood
clothes. Soon, voices demanding that the Qurultay election system be revised became
widespread, louder, and more convincing, as the outdated model did not ensure unbiased
representation. The process reached its climax in 2006 when a group of Qurultay delegates
insisted on reform, but Mejlis leaders did not even bother to listen to their “delusional ideas”.
This fact once again demonstrated the dominance of the principles of self-interest, opportunism
and subjectivity on the part of the head of the Mejlis and his first deputy in the Qurultay-Mejlis
system. Along with many other things, it served as the motive for a group of well-known
Crimean Tatar politicians to leave the Qurultay-Mejlis system.
In 2012, a miracle of miracles, Mustafa Dzhemilev and Refat Chubarov suddenly saw the light
and realised that the world had moved far ahead while they were stuck in the eternal yesterday.
So they began assessing potential options for reforming the native structure. They even let their
close friends think about that too, but not to delve into it too deeply or for too long.
And then it happened! At the 5th sitting of the 5th convocation Qurultay on the 12th of January
2013, a new VI Qurultay Election Regulation was triumphantly voted in. Both before and after
its adoption, the seemingly bizarre document was criticised by almost everyone including the
opposition, subjects of the electoral process, and the Committee of Voters of Ukraine. A detail
description of this treatise would be long and tedious, a lot has already been said and written
about it.
At the same time, journalists from the pro- and near-Mejlis pool, including a chorus of voices
from Kiev, launched a campaign in support of the unprecedented and unheard-of “renewal” of
the Qurultay. What novelties were introduced then?
The requirement to have a 50-person NGO representation in the Qurultay existed since the
1990s. However, the number of delegates from NGOs was increased neither in 2006 nor in 2013.
Therefore, an attempt to promote the creation and development of political parties in the
Crimean Tatar environment failed. The reasons behind this are quite obvious. Mr. Dzhemilev has
always feared competition as the devil fears holy water, so he always tries to get rid of his
opponents by all means available.
The novelty brought by the new Regulations was the so-called direct election process. It should
be emphasised here that no one except the leadership of the Mejlis has ever questioned the very
idea of direct elections. Moreover, Mr. Dzhemilev and Mr. Chubarov publicly rejected the idea
at a Qurultay session in 2006. In 2012, with their revolutionary enthusiasm and the dedication of
young pioneers, they began to assure everyone that direct elections were very much needed!
How come no one else had thought about it before?!
Annex 27 Exhibit X
An important precondition: as far as the implementation of the will of the voter (who is not
savvy in the intricacies of political systems) is concerned, the legal framework must be made, in
crude terms, “for dummies”. The whole algorithm should be simple, transparent and
understandable for everyone, including the young and the elderly. But what happened during the
last Qurultay election was something unspeakable!
The mixed proportional / majority system – okay, the whole process stretched to last several
months – okay, but how should elderly people (a dominant group of voters) distinguish between
single-member and multi-member candidates, or find out in the number of those multi-member
candidates in their constituency?
Moreover, the Regulations provide that any ballots with more marks than the required number
are invalid, while those with less marks than required are fine. This is just a hunting ground for
election fraudsters. On top of that, hardly any clarification was offered to the voters.
Let the Chips Fall Where They May…
The most recent Qurultay election least of all resembles the true expression of the will of the
people. After all, the victory depended not so much on real popular support as on the process
participants’ pep and ability to see the undercurrents. Experienced figures know how the desired
result can be secured for their candidate or political force. By the way, the process started at the
Central Electoral Commission where the drawbacks of electoral lists were used with colossal
benefits for the Chubarov-led dominant bloc Milli Hak.
Then, the local mejlises put their foot in by slipping a note about the “most fit” local candidate
with voter invitation cards (I also got one of those). This was sort of a hint for the narrowminded
who are unable to decide for themselves.
What happened on the election day is too fabulous for words. Out-of-constituency voters were
brought in, ballots were given out in bundles, the “right” candidates’ names were pre-marked on
the ballots, people were allowed to vote without presenting their passports (“Hey, what’s wrong
about it, we all know each other here”), different polling districts had the same polling station,
there was a mess-up with ballot counting forms, some polling stations did not even bother to put
up voting booths…
Election observers were howled down. For instance, in the Kirovsky District and in Alushta, they
were simply pushed out of the room. Nothing was impossible to collect the votes. There were
cases of voting at home without a shadow of confidentiality, or in a store – while you’re buying
some bread, buddy, why don’t you sign here for our guys as well.
Needless to say, some electoral commissions were put together with violations, illegal
campaigning was taking place, ballot counts were suspicious. All this happened more than once
and was thoroughly described by the media. Furthermore, while 50%+ turnout was needed for
the election to be valid before 2006, only a 1/3 turnout was required from 2006 to 2013.
According to the 12 January 2013 Regulations, the turnout does not matter at all, everything is
decided by a relative majority.
A Qurultay Made of What Was Available…
Annex 27 Exhibit X
To have a more or less valid (at least at a first glance) reformed Qurultay election was of
paramount importance for the current leaders of the Mejlis. Avoidance or total failure of the
elections would mean a fierce political death trap for everyone in charge. So they did their best
for the occasion, using all advantages of incumbency and relying on audacity. And even with all
their efforts, the turnout was only 50.49%.
Curiously, the turnout was quite low in places where the election process was strictly monitored,
while in some remote villages unreachable to observers people were eager to vote, all as one, if
you believe what the CEC says. It just so happened somehow that the turnout in remote places
with no observer or media presence was well above 90%, while under the eye of observers or
fellow competitors, the turnout was zero, or the polling station failed to open, or it closed by
noon, or election results were invalid…
Am I the only one who thinks that this is weird?
The efforts of the Crimean branch of the Committee of Voters of Ukraine (CB CVU) require
special attention. At the beginning of the electoral race, they strongly criticised the organisation
and running of the election. But time after time, with each subsequent stage of the election, their
tone became milder and more tolerant. What is the reason behind this? Could it be that the
organisers managed to improve the election process during the race, or did the parties agree on a
price?
The CB CVU summary of the Qurultay election results is quite interesting. In general, it comes
down to the following:
“The Crimean Tatar Qurultay election in most polling districts were without any significant
violations but had some organisational drawbacks that led to infringement on the voters’ rights to
express their will in certain localities”.
However, Andrey Krisko, the head of the Committee, finally noted that:
“Considering the level of political tolerance demonstrated by the subjects of the electoral process
in this election, if the tangle of organisational problems is removed and the regulatory framework
is improved, all performance indicators of the next Qurultay election can be significantly closer
to the standards of electoral law”.
It sounds like the slogan of the Soviet-era sports competitions: “Winning is not that important as
participating!” That is, what he said was: yes, you have organised some sort of a process there,
some things worked out, some did not, but next time please do the opposite and only then you
may get closer to the standards of electoral law.
In layman’s terms, it sounds like this: “Maybe next time the election will be true and valid...”.
And this is 20 years after the first Qurultay election! During the 5th election campaign!
Recalling the last sitting of the previous Qurultay, there was so much talk about all sorts of noble
men taking part in the upcoming election as international observers. But the closer the election,
the quieter were these statements.
In the end of the day, the only observer of the show was the organisation headed by Andrey
Krisko. One can say that they were literally dragged to the polls, because otherwise there would
have been no observers at all, thus making the election results unrecognised.
The Crimean branch of the Committee of Voters of Ukraine found itself in pincers, as they came
to the election not out of their passionate desire, but at the call of their fellows from the Mejlis.
Annex 27 Exhibit X
Therefore, they could not tell the truth, that is, admit that this was not a real election. But they
did not really want to risk losing whatever respect they may have on the eve of the presidential
race, either. So they had to compose the ornate conclusion reports to somehow keep the balance.
All this, of course, did not prevent the CEC head, Zair Smedlyaev, who is literally taking money
from Mr. Dzhemilev as an MP assistant, from solemnly calling it a successful election. He noted,
however, that there had been problems, but no one from the Mejlis HQ was honestly going to
admit that they meant failure of the election.
Instead of a Forecast
As we can see, the Qurultay election was extremely non-transparent. It’s a shame to even talk
about observing the traditions of the National Movement.
In fact, there is no such thing as the Qurultay anymore!
This is an assembly of 250 figures whom you and I are told to cherish and love, the ones who by
hook or by crook got together as a group of impostors calling themselves by the holy name of
representatives of the Crimean Tatar people.
Considering that it is mostly composed of crime-sponsored businessmen and old-time civil
servants, there is no doubt that this assembly will be very, very obedient, regardless of the
colours of the party in power in Ukraine, be they blue, or red, or even carrot-orange. No matter
how pathetic they are, somewhere deep inside they realise there is no one behind them. Each of
them knows the value of his credentials.
As for the snide comments such as “the winner takes it all”, it’s always easy to criticise, why
wouldn’t you try and get elected to the Qurultay, and other incoherent nonsense…
I will say that it is better and nobler to go one’s own way and do everything one can to
strengthen the position of the Crimean Tatar people in their homeland, and simply work hard to
this end, than to participate in dubious pseudo-political shows that have little to do with the
system of national self-government and the development of the Crimean Tatar people.
Why “pseudo-political”? Because no matter how puffed-up the leaders of the Mejlis and the
newly-minted delegates of the VI Qurultay are, these so-called “bodies” of national selfgovernment
have never had, and will never have, any real influence on the Crimean, Ukrainian,
or national policy, because neither the Mejlis nor the Qurultay are in any way incorporated into
the legal system of Ukraine, and due to this regretful fact for our people, they have no legal
levers of influence, neither on the government, nor on the people, nor on anything at all.
What this entire 22-years epic of “Crimean Tatar national self-government bodies” under the
leadership of Mr. Dzhemilev and Mr. Chubarov boils down to can be clearly and truly described
as hand-waving.
It’s exactly what the “revamped” new Qurultay will busy itself with: hand-waving and
distracting Crimean Tatars from real participation in the processes of nation-building of Ukraine
and the Crimean autonomy (to the delight of the enemies of our people!). Also, it is needless to
say, stuffing their own pockets with state budget money and humanitarian aid earmarked for the
resettlement of the Crimean Tatar people.
Annex 27 Exhibit X
As for internal problems of the new Qurultay, the most interesting question for its next sitting is
who is going to be the new chairman of the Mejlis. The obscenely long story of Mr. Dzhemilev’s
re-elections will most likely come to an end, and this time there will be a change of faces.
Who will the new leader be? Judging by the general mood, it may quite predictably be Refat
Chubarov. If that is how the scenario is going to unfold, Mr. Dzhemilev's plans most likely
position his first deputy as a transitional figure. After all, Refat Abdurakhmanovich is a
humanitarian by nature and by life. He has few really influential connections, no access to big
money, he is bad at negotiating, bad at building relationships.
That said, he is quite a recognisable character and, as we must admit, a skilful speaker who has
some authority among the people.
But it seems to me that this is not enough.
Isn’t that why Mr. Dzhemilev is always accompanied by the freshly baked Aslan Omer Kyrymly
(born Aslan Umerov), a tough businessman of international stature and an extremely hard man
with obvious habits of a tough authoritarian leader. It is quite possible that he is Mr. Dzhemilev’s
real joker.
The Qurultay of the new convocation is literally full of business people, there is a place both for
local princes and for hot shots. This suggests that the bidding will be very competitive. If Enver
Abduraimov managed to put Refat Chubarov in a stalemate situation in his time, it’s anyone’s
guess what the newly minted Qurultay delegates are capable of.
In summary, we can say as a lame excuse for a national self-government system that the
leadership of the Mejlis, their relatives and some quite nimble persons who can get almost
anywhere have arranged for themselves is a colourful, noisy, rackety farce.
Under such circumstances, the 250 delegates can dictate their will to each other as much as they
like, but they will certainly be unable to do so to the entire Crimean Tatar people!
Exhibit Y
ZN.UA, Authoritarian democracy (26 December 1997)
(translation)

Annex 27 Exhibit Y
Translation
ZN.UA, Authoritarian democracy (26 December 1997), available at:
https://zn.ua/politcs_archive/avtoritarnaya_demokratiya.html.
AUTHORITARIAN DEMOCRACY
Nikolai Semena
The split in the Crimean Tatar national movement at the Qurultay has
not been overcome, but has only worsened, its veterans believe…
Last week in Simferopol an extraordinary session of the third Qurultay of the Crimean
Tatars considered the crisis in the Mejlis. Addressing the Qurultay sixteen of its
delegates raised the issue that "a group of unscrupulous businessmen is trying to turn
the Mejlis into a "political cover" for their illegal operations related to the
embezzlement of budgetary funds allocated for the Program for the Return and
Settlement of the Crimean Tatar People". Even after the Qurultay, Lenur Arifov stated
that "reaction and authoritarianism have settled in the Mejlis" and that the Mejlis and
the Qurultay "have turned into bodies serving the interests of one person and persons
close to him." "Now what young Mustafa once fought against, he is implementing in
the body he heads," L. Arifov concluded.
People sympathetic to the Crimean Tatars took the news of the split with pain. After
all, the Crimean Tatar national movement has been fighting for the ideals of democracy
for the last several decades of its history. So what happened? Aisha Seitmuratova, a
veteran of the movement, described the incident as "Stalinism," telling a correspondent
of "Zerkalo Nedeli" and other journalists the following: "Mustafa is our national hero.
He stood up to the pressure of the authorities and KGB, this terrible machine. Not
everyone stood up to it. But Mustafa - alas! - is not a leader, with all my respect to him.
Not every hero can be a leader and not every leader can be a hero...". According to her,
in her New York office (Ayshe Hanum is an American citizen) there's a letter written
in 1989 by Izzet Hairov, a member of the movement who was expelled from the Mejlis
during this Qurultay: "Mustafa is no longer the one for whom we fought. I do not
understand what happened to him. Mustafa will lead the people to a precipice, from
which we all the people will not get out...". Naturally, not everything in this story is as
straightforward as it seems at first glance. All the more so because we are talking about
quite influential people in Crimea. According to the poll, conducted by the Crimean
independent center of political researchers and journalists, Mustafa Dzhemilev was the
tenth most influential person in the past year, Lilya Budzhurova - the 18th and Lenur
Arifov - the 22nd. However, Refat Chubarov shared 3-4th place, and Nadir Bekirov -
19th-20th. To understand the problem, let's listen to both sides of the argument…
Crisis, split
or revolt?
Sixteen delegates, ideologically led by the Deputy Prime Minister of the autonomy, one
of the leaders of the national faction in the Crimean parliament Lenur Arifov and
journalist Lilya Budzhurova, stated that "the Mejlis chairman with all his authority and
direct actions created the conditions in which these embezzlements were possible. The
economic and financial instruments of embezzlement of budgetary funds were Imdat
Bank and the "Crimea" Public Fund... the president of which is the chairman of the
Annex 27 Exhibit Y
Mejlis...". Sixteen delegates of the Qurultay stated that "the Fund "Crimea", having
received 800 thousand grivnas from the state budget to help individual developers - our
compatriots, has been keeping this money in its "pockets" for more than two years,
condemning many hundreds of people to live in dugouts or unfinished houses. And this
is just one example..."
In the report, which Lenur Arifov was not allowed to read to the end, he stated that
having discovered the embezzlement, members of the Mejlis demanded that the account
of the Capital development administration of State Committee on Interethnic Relations
of the Republic of Crimea, where the money was transferred by Kiev, be transferred to
another bank. But contrary to their expectations, Mustafa Dzhemilev not only did not
agree to this, but refused to sign and hindered the implementation of the decisions made
by the majority of the Mejlis. And the shortage of funds in the Imdat Bank account at
the beginning of the outgoing year was already about 2 million grivnas and continued
to grow. Lenur Arifov drew a clear scheme according to which the bank, the State
Committee on Interethnic Relations of the Republic of Crimea and commercial
structures acted - the budget funds from the accounts of the Capital development
administration were transferred to the accounts of the "Crimea" Fund, the "Torshe"
Private Entrepreneurship, the "RED" Private Enterprise, the "Sinan" Private Enterprise
and the "Oasis" Cooperative, which, according to Arifov, are "the property of private
firms, behind which stand several specific individuals, Crimean Tatars by nationality".
Arifov states that the image of Imdat-Bank as a national Crimean Tatar financial
institution is a myth, because it has never been under the control of the Mejlis, it has
always been managed by only one person - Mustafa Dzhemilev.
The opposition called such a state of the Mejlis a crisis, outside observers called it a
split, while Mustafa Dzhemilev himself and his colleagues tried to present the
opposition's actions at the Qurultay as a revolt in the Mejlis itself. Let's listen to the
arguments of the second side for full objectivity. In his report, Mustafa Dzhemilev
categorically denied the "information" about his personal accounts and involvement in
the ownership of commercial structures. He claimed that the money received by the
firms were not embezzled, but used as loans and had to be returned. According to
Mustafa Dzhemilev, one cannot "classify all debtors as thieves and embezzlers," even
if "it is unlikely that these firms will be able to repay debts in the near future. He also
recalled that it was the "Crimea" Fund that invested a lot of money donated by the Tatar
diaspora in the Imdat Bank. He rejected accusations of authoritarianism, saying that "if
even in such situations the chairman of the Mejlis cannot make volitional decisions,
then why does the Mejlis need a chairman at all?" He accused journalist Lilya
Budzhurova of "using standard methods of exposure," in which on television they
compared the "good" houses of some Crimean Tatars with the unfinished houses of
others.
In short, the Qurultay created a situation where, as it were, "two rights" collided. It
would have been correct, however, under one condition - if the opposition was given a
decent and normal voice. But Arifov was booed and the microphone was taken away
from Budzhurova. Democracy cannot be limited; it either exists or it doesn't exist. It's
good and easy to be a democrat when you have nothing. It turned out that if a manager
gets to manage at least one bank and a fairly significant amount of money in it, it is
almost impossible to dispose of them so that everyone was happy.
Naturally, for Mustafa Dzhemilev to let the question "about the crisis" go on its own,
meant, perhaps, to be removed from politics today, when, in his opinion, this should
not be allowed at all - he is included tenth in the election list of Rukh, which almost
guarantees the former dissident and the leader of long-suffering people election to
Annex 27 Exhibit Y
Verkhovnaya Rada of Ukraine. Of course, Mustafa Bey could not take the risk, but he
was afraid to trust the people (more precisely, the Qurultay delegates) and to hold, as it
should be, closed voting about prolongation of his powers. As a result, voting was
conducted in a usual and primitive way from the point of view of democracy - each
delegate had to stand up and say - "for", "against" or "abstained", under the gaze of
tough "guards".
As a result, the events have not gone at all according to the scheme expected by the
opposition. The Qurultay took tough measures, but not to the "commercial and banking
structures" that the rebellious delegates accused of machinations, but to themselves -
all sixteen were expelled from the Mejlis, three - Lenur Arifov, Lilya Budzhurova and
Nariman Abdureshitov - were recalled from the deputy fraction in the Supreme Soviet
of Crimea, the decision "About the Crimean Tatar mass media" was made, which
replaced the entire editorial board of the "rebellious" newspaper "Avdet"; the national
editorial board on the Crimean television is ordered to have "a public council from the
representatives of the Mejlis, as well as the Crimean Tatar culture, science and
education"; a "concept of development of the Crimean Tatar journalism for the
implementation of a common information policy" will be developed (?). Its former
chairman Enver Muedinov was recalled from the revision commission. The Qurultay
confirmed the authority of Mustafa Dzhemilev, the chairman of the Mejlis, and gave
him additional rights - to withdraw without discussion one third of the nominated
candidates (although he asked for only one tenth of them) when electing the members
of the Mejlis, to veto its decisions and others. If we take into account that the veto can
be overridden by only two-thirds of votes, and the chairman has the right to withdraw
one third of votes even without discussion, Mustafa Dzhemilev can be congratulated -
practically he has received the right of absolute veto, which actually gives him the rights
of khan. If Kirsan Ilyumzhinov can be, as they write, a "democratic khan," why can't
Mustafa Dzhemilev be one?
The delegates also confirmed the decision of the Mejlis on the participation of the
Crimean Tatars in the elections to the Verkhovnaya Rada of Ukraine in the bloc with
Rukh and adopted several other documents - an appeal to the OSCE, the UN High
Commissioner for Human Rights, President of Ukraine and the Verkhovnaya Rada of
Ukraine "On the continuation of discrimination of the Crimean Tatar people and the
need for urgent measures to protect their rights" and the appeal to the leadership of the
country "On consideration of the interests of the Crimean Tatar people in the
privatization process in Ukraine", which, however, in connection with the issue of the
Mejlis crisis are kind of in the shadow.
What is the result?
Mustafa Dzhemilev, in terms of overcoming the crisis, considers the Qurultay to have
"achieved its goals." The opposition, hoping that the Qurultay would calmly listen to
them and delve into the problem, left the congress.
And yet the losses from the Qurultay were probably greater than the gains. First of all,
the movement practically lost its image as a democratic movement, and accusations of
authoritarianism poured in against the head of the Mejlis. Secondly, the movement has
now completely lost its unity, which even before was questioned by the presence of the
Crimean Tatar National Movement and the disagreement with the official line of the
Mejlis of some representatives of the movement in Moscow, Krasnodar, and other
regions. Such "fragmentation" in the near future will take away a lot of power for
internal discord, which could have been spent with greater benefit.
Annex 27 Exhibit Y
Thirdly, Mustafa Dzhemilev must clearly realize that a significant part of the veterans
of the movement are against him, and in time their archives, scattered today all over the
world, will be opened, where you'll probably find even more sudden letters than quoted
by Aisha Seytmuratova. As a politician, he apparently understands that it is time that
will paint his final image for history, and he doesn't care what that portrait will be. This
Qurultay added a lot of unflattering material for him...
Exhibit Z
Milli Firka, Who and How Ripped Off the People in the Mejlis (25 March 2011)
(translation)

Annex 27 Exhibit Z
Translation
Milli Firka, Who and How Ripped Off the People in the Mejlis (25 March 2011), available at:
http://milli-firka.org/кто-и-как-в-меджлисе-обворовывал-народ/.
Who and how ripped off the people in the Mejlis
Today everyone is aware of the rapid decline in the authority of the Mejlis among compatriots and, first
and foremost, of its leaders, M. Dzhemilev and R. Chubarov. The first attempt to "cleanse the Mejlis from
within" was made in 1997 by a "group of 16" members of the Mejlis at the time who were outraged by
financial machinations around budgetary funds perpetrated by the Mejlis leaders through the notorious and
no longer existing "people's" "Imdat-Bank".
The protest by fighters for truth and democracy in the Mejlis was crushed, and the troublemakers were
severely obstructed, finding themselves "out of the business" of the Qurultay-Mejlis. "MF-Inform" decided
to return to those events, after which the processes of internal degradation of the Mejlis could no longer be
hidden from the public.
We bring to your attention materials of newspaper "Avdet" No.23 (186) dated 31 December 1997 which
are opening just a little part of what and how Mustafa Dzhemilev and his today's closest surrounding started
to fall "from pedestal". I give the floor to Enver Muedinov.
Report of Enver Muedinov,
Chairman of the Review Committee of Qurultay
Dear Qurultay delegates!
Annex 27 Exhibit Z
In its activities, the Review
Committee was guided by the Regulations on the Review Committee, approved by the Qurultay.
During the reporting period after the first session of the III Qurultay the Review Committee held
12 meetings where there was always a quorum for taking decisions. During this period the Review
Committee has considered about 20 applications.
The essence of many applications boiled down to almost one thing: to assist in solving the housing
problem. Besides, there were applications from inhabitants of Ukrainka village about doubts in the
results of elections of the chairman of Mejlis of Ukrainka village and applications from delegates
of Kirov regional conference about violations during the conference.
All the applications were checked, the results of checks were discussed at the meetings of the
Review Committee and decisions were made.
Audits of the financial and economic activities of the "Crimea" Fund for 1996, accounting
department of the Mejlis for 1996, and 10 months of 1997 were conducted. I will elaborate on the
results of the audits below.
The Review Committee attended all the meetings of the Mejlis during the reporting period.
The Review Committee of the Qurultay several times made statements and initiated meetings of
the Mejlis and consideration of such issues as:
Annex 27 Exhibit Z
- on the activities of commercial bank "Imdat-Bank" and the transfer from this bank of the Capital
development administration of Republican Committee of the Autonomous Republic of Crimea
account;
- on the activities of the deputy faction "Qurultay" in the Supreme Soviet of Crimea.
At the request of the Mejlis Chairman, the Qurultay Review Committee checked the reasons for
the disruption of the Mejlis meeting in Foti Sala village.
The Review Committee, carrying out its work in a rather difficult environment, carried out the
functions entrusted to it by the Qurultay.
The crisis in the Mejlis of the Crimean Tatar people could not but affect the Qurultay's Review
Committee.
Until recently, there was no particular disagreement in the Review Committee. I, as the Chairman
of the Review Committee, trying to comply with the principles of democracy, obeyed the decisions
taken, although I didn't always agree with the decision. But when some members of the Review
Committee tried to act as censors to forbid me to speak about negative phenomena discussed in
the sessions of Mejlis, I refused to obey. This ended with the Review Committee meeting deciding
to remove me from my position by expressing distrust of me, which only the Qurultay can do.
Thus, some members of the Review Committee in their eagerness to silence everyone who is
unwanted are even exceeding their authority and violating the regulation on the Review Committee
of the Qurultay. I have informed you about this in detail in my statements to the media.
Only the Qurultay may assess the activities of the Review Committee and hence my work as the
Chairman of the Review Committee elected at the Qurultay, so I am submitting to your judgment
a report on the work done by the Review Committee of the Qurultay.
I bring to your attention the report compiled without embellishing the facts, but also without
glossing over the painful problems, the attempt to solve which led to the crisis in Mejlis.
So far, the desire not to wash dirty linen in public has worked for us while discussing these or
those questions. But in order to understand the reasons of the created crisis it is necessary to wash
this dirty linen as long as without telling the truth we won't achieve unity and solidarity of the
national movement, without this it will be difficult to gain trust of the people, which has been
noticeably shaken lately.
Some members of the Mejlis and the Review Committee are trying to blame for the crisis situation
on those members of the Mejlis who sought to bring order to the Mejlis and in the distribution of
funds allocated under the Program for Return and Settlement of the Crimean Tatar People. All the
"guilt" of these members of the Mejlis is that they made public the negative phenomena that were
happening with the funds allocated under the program. And the Chairman of Mejlis M. Dzhemilev
and his supporters are against publicising these facts.
Disclosure of which facts are the Chairman of Mejlis and his supporters afraid of?
At the Mejlis meetings from August 1996 to March 1997 the questions about the efficiency of the
use of budgetary funds allocated under the Program for the return and settlement of the Crimean
Tatar people and the principles of the relationship between the Mejlis and "Imdat-bank" were
considered 6 times.
Annex 27 Exhibit Z
During this time, we witnessed how Mejlis commission was established to make recommendations
on the activities of "Imdat-Bank", how extraordinary meetings of the Mejlis were initiated at the
request of 13 members of the Mejlis and at the decision of the Review Committee in order to
cancel the decisions made. We also faced such a fact as the refusal of the Mejlis chairman to sign
and execute adopted decisions without taking into account the opinion of the majority of Mejlis
members.
Even then, the first signs of the impending crisis appeared, but the Chairman of Mejlis M.
Dzhemilev did nothing to eliminate the crisis phenomena, but on the contrary, did everything
possible to deepen it.
The opinion of the majority of Mejlis members was categorical: to transfer the budget account of
the capital development administration from "Imdat-bank" to one of those authorised by the
national bank of Ukraine to service budget funds, thereby expressing distrust in the activities of
"Imdat-bank" and its management.
The Mejlis Chairman, realising that he could not change the mind of the majority of the Mejlis
members, went to an extreme step: it was stated that the Mejlis Chairman would resign if the
budget account of the capital development administration was withdrawn from the "Imdat-bank".
With this step, M. Dzhemilev went to the political blackmail of the Mejlis. He made it clear to
everyone that he would reject any decision to withdraw the capital development administration
account from the "Imdat-Bank".
What does the Chairman of the Mejlis and his supporters actually stand for, and what do most
members of the Mejlis oppose so strongly?
Why does the Chairman of Mejlis M. Dzhemilev persistently continue to defend his pet project -
"Imdat-bank" without taking into account the opinion of the majority of Mejlis members?
And everything turns out to be in the control, or rather, in the uncontrolled spending of budgetary
funds allocated under the Program for the return and settlement of the Crimean Tatar people, in
order to keep "Imdat-bank" afloat.
At one time, when "Imdat-Bank" was organised, it was entrusted with the functions of control over
the efficient spending of funds allocated under the Program through the Public Fund "Crimea",
which is one of the founders of the bank.
Much in the activities of "Imdat-bank" is hidden behind the term "commercial secret". No one can
learn anything about the activities of the bank without the consent of all the founders of the bank.
In October 1995, by order of the Chairman of the Mejlis, a commission of the Mejlis conducted
the first and so far the only partial inspection of "Imdat-Bank".
In parallel with this inspection by the commission, an audit of the "Imdat-Bank" activity was
carried out by the specialists of an independent financial expertise from Kharkov, at the invitation
of the Chairman of the Mejlis. The main purpose of the audit was to make a clear picture of the
bank's activities.
Much about the activity of "Imdat-bank" became known due to the results of these inspections.
Inspection reports were presented to the Chairman of Mejlis M. Dzhemilev. But the results of the
inspections were so unexpected and overwhelming even for M. Dzhemilev that he decided to hide
the acts of inspection under the carpet and, rolling up his sleeves, takes decisive measures to save
the bank.
Annex 27 Exhibit Z
So what did the inspections on the activity of "Imdat-Bank" reveal, and what results of the
inspections did the Chairman of the Mejlis decide to hide?
Here are a few excerpts from the act of inspections:
The bank's insolvency was caused by the fact that the bank's management... in violation of the
requirements of the National Bank of Ukraine, regulating lending activities, in January-September
1994, issued loans totaling 72.303 billion krb. (karbovanets), which have not been repaid even at
the time of the inspection. The issuance of unprofitable loans was made without analysing their
recoverability and security.
The most serious mistake of the bank officials mentioned above is that credit resources were
provided to a number of companies that already had outstanding loans and fees for using credit
resources in this bank.
As a result of the inactive credit policy of the Council and the Board of the Bank, "Imdat-Bank"
incurred losses amounting to 178.703 billion krb. (non-repayment of issued and guaranteed loans,
lost income, as well as losses from interbank credit operations).
Despite the created situation, when the bank incurred losses, the Council of the Bank set the salary
for the employees of the bank - 15% of the income received by the bank.
Incompetence of the management of "Imdat-bank" led to the fact that the bank was on the verge
of bankruptcy. Changing the chairmen of the Board of "Imdat-bank", one after another, they tried
to save the situation. Only in 1994, 5 chairmen of the bank's Board changed.
In an interview with a correspondent of the "All-Ukrainian News", R. Kenje, a former chairman
of the bank's Board, stated that he had not worked at the bank when it was suffering losses. This
is an impertinent lie. What can you expect from a man who does his best to justify these actions?
R. Kenje was forced to write a notice of resignation from the post of Chairman of the Bank during
the inspection of "Imdat-bank" by the Commission of the Mejlis, i.e. in October 1995.
The 53rd meeting of the Mejlis adopted a decision in relation to R. Kenje as well, but no one
executes this decision because of the disagreement of the Chairman of the Mejlis with it.
The tape recording of the 53rd meeting of the Mejlis and the minutes of the meeting of 24 August
1996, where the decisions on the account of the capital development administration in the "Imdat-
Bank", on the bank officials were taken away and are kept personally by M. Dzhemilev.
The leadership of the Mejlis, the Imdat-Bank and the State Committee on National Security were
busy with one problem - how to find funds to replenish the hole that had formed due to nonrepayment
of loans. They found both ways and means.
These were the budgetary funds of the Capital development administration of Republican
Committee of the Autonomous Republic of Crimea under the Program for the Return and
Settlement of the Crimean Tatar People. They used persuasion and, if necessary, threats of physical
violence in order to use the budget funds to the benefit of the bank founders and the managers of
some companies. Through these companies and small businesses the budget funds intended for the
arrangement of the Crimean Tatar people, flowed into the pockets of managers of various ranks,
and the people began to be openly deceived, hiding behind the assurances that official Kiev is
gradually phasing out funding for the Program of Return and Settlement of the Crimean Tatar
People.
Annex 27 Exhibit Z
Capital development administration of Republican Committee of the Autonomous Republic of
Crimea, its budget account in the "Imdat-bank" was the very cash cow, from the funds of which
the bank still existed.
How else can be explained such a fact that the allocation of 80 billion krb. by the Capital
development administration of the "Crimea" Fund in August 1995, which, according to the order
of the State Committee of National Security, were intended for the payment of financial aid to
individual developers for the completion of houses, were used by the President of the "Crimea"
Fund M. Dzhemilev for strengthening the financial position of the "Imdat-bank", for the repayment
of debts on loans previously taken by a number of small enterprises and companies.
In order to give the appearance of legitimacy of use of 80 billion krb. received from the Capital
development administration, the contracts were concluded between the "Crimea" Fund and the
"Geos" and "Arsen-bey" enterprises for the supply of building materials, and the money was
transferred to these enterprises in the amount of 63,0 billion krb. and 10 billion krb. respectively,
leaving 7,0 billion krb. on the current account of the "Crimea" Fund. But in those two years not a
single karbovanets worth of building materials has been delivered.
Where was the money spent? With this money "Geos" and "Arsen-bey" enterprises bought their
promissory notes in the "Imdat-bank".
Moreover, at the expense of the above mentioned 63.0 billion krb. "Geos" enterprise repaid the
debts of the following enterprises:
1. "Zodiac" enterprise 9.9 billion krb.
2. "Turk-Krym" LLC 10.0 billion krb.
3. "RED" enterprise 12.7 billion krb.
4. "Sparta" LLC 4.62 billion krb.
5. "Ecotech" LLC 4.0 billion krb.
6. "Cruz" enterprise 4.7 billion krb.
7. "Avesta" enterprise 4.6 billion krb.
8. "Krymzemstroi" enterprise 4.6 billion krb.
And the "Arsen-bey" enterprise, at the expense of the public fund "Crimea" received 10 billion
krb, has repaid debts of the enterprise "Marat-94" in the amount of 2,0 billion krb.
The way in which after some time the appearance of payment of a part of debts between "Geos"
enterprise and Fund "Crimea" was created refers to the category of puzzles and when solving them
one starts to wonder: who took credits after all and why one enterprises pay debts of other
enterprises and what source was chosen for repayment of debts?
From March 12, 1996 to July 15, 1996 "RED" enterprise transferred to the Fund "Crimea" 25 219
565 000 krb., drawing up payment orders as a repayment of accounts payable. But in the
accounting documents in the Fund "Crimea" there is no confirmation of the document on the
presence of such debt, but there is a letter from the "RED" enterprise that the transferred amount
of 25 219 565 000 Krb is the payment of the debt of "Geos" enterprise.
S. Tokhtarov was the Director of the "RED" enterprise and the Chairman of the Board of "Imdatbank"
at that time, and he probably chose budgetary funds as the source for paying the debt.
Annex 27 Exhibit Z
The events that happened after that belong to those that are called incredible. The leadership of the
"Crimea" Fund decided to use part of the funds coming from compatriots living abroad to replenish
the Fund's current account in the "Imdat-Bank". For this purpose, $31,497 was allocated and
handed over to S. Tokhtarov for currency exchange and crediting to the current account of the
"Crimea" Fund.
For the execution of this operation S. Tochtarov chose the "Geos" enterprise. The "Geos"
enterprise transfers 58107 grivnas to the "Crimea" Fund by issuing a payment order, as a return of
accounts payable. Is this not absurd? The funds of the "Crimea" Fund are used to pay off debts to
the "Crimea" Fund.
How can one think of choosing a partner to credit funds to a company that has been indebted to
the "Crimea" Fund for more than one year? According to the accounting documents, "Geos"
enterprise reduced its debt ashes to the "Crimea" Fund at the expense of the funds received by
SME "RED" and for the currency received. According to accounting documents, "Geos" enterprise
reduced its debt to the "Crimea" Fund through funds received by "RED" enterprise and for the
currency received.
All the funds received from "RED" enterprise and "Geos" enterprise the management of the Fund
"Crimea" decided to direct for payment of material aid to individual developers for the completion
of houses. In 1996, 347.776 grivnas 50 kopecks was allocated for payment of financial assistance
to the developers, and to date the indebtedness of the "Crimea" Fund to the developers in the
amount of 4,522,234 grivnas 50 kopecks remains.
But what happened with 80 billion krb. is not the only thing that happened with the budget funds.
In the same way, 45 billion brb. was used to repay the debts of some enterprises through the "Poisk"
enterprise and the "RED" enterprise. A total of 8.9 billion krb. was misappropriated through the
"Toria" enterprise on August 7, 1996. And there are dozens and dozens of such facts.
From the outside it seemed that official Kiev did not notice, to put it mildly, "these tricks" of the
"Imdat-bank" management. But, to its credit, the Ukrainian government has taken steps to
streamline the budget. In accordance with Cabinet of Ministers Resolution No 401 of 03.04.96,
enterprises and organisations financed from the state budget were obliged to transfer accounts to
authorised banks determined by this resolution before 15.05.96. However, this decree, as well as
the decisions of the Mejlis taken in accordance with this decree, have not been implemented to
date.
The most vigorous opposition to the withdrawal of the Capital development administration account
from "Imdat-Bank", following the decision taken at the Mejlis meeting, came from M. Dzhemilev
and R. Kenje, a deputy of the Supreme Soviet of Crimea and former chairman of the bank's
Council.
At a time when one part of the Mejlis members were trying to bring order to the use of budgetary
funds, another part was actively working to keep the budgetary account of the Capital development
administration in the "Imdat-Bank".
Without discussing it at meetings of the Mejlis, they held secret negotiations with the Chairman
of the Council of Ministers of the Autonomous Republic of Crimea, A. Demidenko, and the
Permanent Representative of the President of Ukraine in the Autonomous Republic of Crimea, V.
Kiselev. As a result of these negotiations, a letter was initiated to the Prime Minister of Ukraine
P.I. Lazarenko. I will read an excerpt from this letter:
Annex 27 Exhibit Z
"The incompetence of the former management, which manifested itself in misconduct, seriously
complicated and worsened the financial situation of the bank, the new composition of the Council
and the Board of the bank are taking measures to resolve the crisis situation. In these conditions,
the control and audit department and the state treasury department of Simferopol charged the
amount of 2,772,218 grivnas 85 kopecks on the balance of budgetary funds with penalties, while
the authorised capital of the bank is 1,200,074 grivnas.
Taking into account the role of "Imdat-bank" which activity is under constant control of the
Supervisory Board and the "Qurultay" faction of the Supreme Soviet of Crimea, I ask to consider
it appropriate to withdraw the collection orders and give it the status of an authorized bank for
servicing the funds sent from the State Budget of Ukraine, to finance the return and settlement of
the Crimean Tatar people."
How they controlled, and how they wanted to control the use of budgetary funds, we have shown
above.
How can we hope that the leadership of "Imdat-bank" will finally begin to show a sense of
compassion for their people if they continue to steal from the Capital development administration,
but now in a different way.
Imdat-bank's management takes inter-bank loans and lends them to the Capital development
administration at a higher interest rate. During the first five months of 1996, the Capital
development administration paid "Imdat-bank" interest of 205,278 grivnas and 27 kopecks, while
"Imdat-bank" transferred 54,610 grivnas 66 kopecks for interbank credits to "Krym-credit" bank.
The difference in the amount of 150,667 grivnas 61 kopecks is the profit of "Imdat-bank" received
at the expense of the Capital development administration.
The "Crimea" Fund, being the founder of the bank, has more than 362 thousand grivnas in the
"Imdat-bank" statutory fund, but has not received a single penny of dividends for these years.
So who do the resources of the fund work for and who gets dividends from it?
The answer to this question can only be given by the management of the "Crimea" Fund and
"Imdat-bank".
The funds invested in the "Imdat-Bank" statutory fund by the management of the "Crimea" Fund
are the funds collected on the donations of compatriots abroad, for the improvement of the entire
nation, and not for the profits of a number of high-ranking leaders.
The funds for the operation of the "Crimea" Fund are allocated by the President of the Fund M.
Dzhemilev. Only M. Dzhemilev knows the true sources and quantity of the incoming funds. The
Crimean Republic cannot say anything about it. Therefore, the verification covers that part of the
documents which were provided to us.
Having failed to eliminate the contradictions that led to the confrontation in the Mejlis when
addressing the issue of the effectiveness of the use of budgetary funds, the Mejlis Chairman
continued to rely on the support of the majority of the Mejlis members when addressing other
issues. This was particularly evident in the discussion of candidates for nomination to the new
Crimean government
A majority of Mejlis members did not support the candidates for the Crimean government
proposed by the Mejlis chairman. But M. Dzhemilev, without a decision of Mejlis, considered that
Ennanov's candidacy for the post of Minister of Social Protection was the best one, and
Annex 27 Exhibit Z
disregarding the opinion of the majority of Mejlis members, who rejected this candidacy,
supported Ennanov and achieved his approval in this post.
The Mejlis chairman understood that decisions in Mejlis meetings are made by a majority vote of
the Mejlis members, but he also understood that he could not persuade the majority of the Mejlis
members to support his ideas.
And so, in this difficult situation, the Chairman of the Mejlis decided to go on leave, until the
Qurultay session.
He was well aware that the Mejlis Rules do not foresee a situation where the Mejlis chairman goes
on long-term leave on his own initiative before the Qurultay session.
The Mejlis meeting offered M. Dzhemilev to go on leave for 2-3 months, but he refused and
insisted on taking leave until the Qurultay session.
And then the Mejlis meeting was forced to assign the duties of Mejlis chairman to the First Mejlis
Deputy Chairman R. Chubarov until an extraordinary session of the Qurultay.
Having gone on leave, M. Dzhemilev became more active and began to meet more often with his
compatriots in different regions of Crimea, which he did not do so often before.
Two weeks later, at a meeting of the Mejlis, R. Chubarov made a statement that he was physically
unable to combine his duties as deputy chairman of the Supreme Soviet of Crimea and acting
deputy chairman of the Mejlis, and asked to be relieved of his duties as chairman of the Mejlis.
But the real reason of R. Chubarov's unwillingness to act as Mejlis Chairman is that though Mejlis
Chairman M. Dzhemilev went on holiday, he continued active work and all questions were agreed
with him without taking into consideration Acting Mejlis Chairman, and that he is not willing to
work in such circumstances.
The members of the Mejlis faced a dilemma: how to break the deadlock, how to untangle the tangle
of painful problems in a situation when the Mejlis leadership withdrew from solving them,
aggravating the crisis in the Mejlis.
All members of the Mejlis understood that any decision taken by the Mejlis would go against the
rules of procedure of the Mejlis.
At such a critical moment when the issue was put forward: should the Mejlis be the representative
body of the people, the majority of Mejlis members accepted Mr Chubarov's statement that he
would step down as Mejlis chairman and hand his duties over to Reshat Ablaev on a temporary
basis until an extraordinary session of the Qurultay.
Concluding my report, I would like to hope that the delegates of the Qurultay will have the courage
to assess in a balanced and objective manner the activity of the Mejlis and its President and
moreover, to assess the causes of the crisis. I hope that Qurultay will find the ways of getting out
of the crisis and create opportunities for strengthening the positions of the system of representative
bodies of Qurultay and Mejlis of the Crimean Tatar people.
It will depend on you, the Qurultay delegates, what composition of the Mejlis you will choose.
But we must not allow the authority of the Mejlis to be used for mercenary purposes, by people
with impure intentions - whoever these people are, whatever merits they have before the people.
Annex 27 Exhibit Z
You have a difficult decision to make, on which the unity of the people will depend.
I think Qurultay decisions will be realistic and their realisation will contribute to the restoration of
rights of our people, their return and settlement on their native land.
Enver MUEDINOV
Newspaper "Avdet" No.23 (186) dated 31 December 1997
MF-inform
Exhibit AA
Millie Firka, How Dzhemilev Ripped Off Three Orphans (12 October 2013)
(translation)

Annex 27 Exhibit AA
Translation
Millie Firka, How Dzhemilev Ripped Off Three Orphans (12 October 2013), available at:
http://milli-firka.org/как-джемилев-трех-сирот-обокрал/.
How Dzhemilev Ripped Off Three Orphans
Information about Mustafa Dzhemilev's financial fraud has been appearing in the media since the
1990s. However, all these years, Dzhemilev's supporters were quick to dismiss all the "insinuations",
demanding documentary confirmation of the accusations.
This has always been more difficult as the process of moving money or material assets in
circumvention of existing laws and regulations bypassing existing laws and regulations from one
owner to another usually takes place without witnesses and without signing any papers.
But even the with the documented facts of Mustafa Dzhemilev's financial scams he has time and
again gotten away with it. The Mejlis leader is protected by his popularity "behind the scenes" and
parliamentary immunity.
For example, in 1997 the chairman of Audit commission of the II Qurultay Enver Muedinov prepared
a report in which he highlighted the results of the audit of financial activities of the "Crimea" Fund,
the accounting department of Mejlis and the commercial "Imdat-Bank" supervised by M. Dzhemilev,
through the accounts of which the budgetary funds allocated by Ukraine for the accommodation of
the Crimean Tatars passed.
E. Muedinov's report uncovered the facts of colossal financial abuses, indicated the machination
schemes and named the counterparties to whom the budgetary funds were transferred in
circumvention of the law.
However, M. Dzhemilev's specially organised team of "loudmouths and whistleblowers" did not
allow the speaker to make a report at the Qurultay.
But the report of the head of Qurultay Auditing commission was published in the newspaper "Avdet"
№23(186) of 31.12.1997 and after all became known to public, supervisory and law enforcement
agencies - but there was no reaction from Finance Ministry, Treasury or Economic Crimes Unit.
Annex 27 Exhibit AA
On the other hand, there was an immediate reaction from Dzhemilev: the Chairman of the Revision
Commission Enver Muedinov was immediately removed from the Qurultay.
After such a frank carte blanche of the authorities to embezzle people's funds, the number of those
wishing to catch M.Dzhemilev by the hand has sharply decreased...
And this is only with regard to budgetary funds. As to the humanitarian aid, which fall into the hands
of Mustafa Dzhemilev, the head of Mejlis never reported to anyone, neither to the people, nor to
Qurultay.
According to various foreign data, the total amount of material assistance of the international
community to the Crimean Tatar people for two decades is from one to one and a half billion US
dollars!
Thus, for example, the former ambassador of Turkey in Ukraine Ahmed Byulent Merich in one of
his speeches confirmed that Turkey alone transferred for the needs of the Crimean Tatar people more
than 20 million dollars.
The way M. Dzhemilev distributes the money that fall into his hands is evidenced by the recent
financial scandal related to the charitable assistance to Crimean Tatars by a well-known businessman
from Turkey, chairman of the Federation of Crimean Societies and Society of Culture and Mutual
Aid of the Crimean Tatars of the city of Kocaeli Ibraim Araci.
The essence of the scandal is as follows.
Twice, in November and December 2011, Ibraim Araci transferred 50,000 US dollars each to the
account of the "Crimea" Fund, whose founder is Mustafa Dzhemilev. This was his contribution for
organising the II World Congress of Crimean Tatars in Turkey, in Eskisehir.
Annex 27 Exhibit AA
However, the Mejlis flatly refused to hold the congress in Turkey.
Later, on 4 May 2013, a meeting of representatives of the Crimean Tatar diaspora abroad was
organised in Crimea to discuss where and when to hold the Second World Congress of the Crimean
Tatars.
It was decided to hold it only in Crimea.
Ibraim Araci was also present at this meeting. He did not agree with the decision and left the meeting
without waiting for the end of the event.
And suddenly, in violation of all the agreements, in the autumn of 2013 the head of the Mejlis' Foreign
Relations Department Ali Khamzin spread information that the II Congress would be held not in
Crimea and not even in Turkey, but in Romania (?!), which caused a sharp negative reaction from the
Crimean Tatar diaspora in Turkey, which invested a lot of effort and money into the preparation of
the II Congress.
One of the manifestations of this reaction was the quite reasonable question of the fate of the $100,000
transferred to the accounts of the Dzhemilev’s "Crimea" Fund.
Mustafa Dzhemilev habitually decided to remain silent...
Here are the texts of two letters addressed to Mustafa Dzhemilev by Ibraim Araci regarding the fate
of the 100,000 dollars he sent to the head of the Mejlis.
Letter 1:
Sent: Monday, September 23, 2013
Dear Mustafa Dzhemilev.
As you know, on May 4, 2013 we took part in a meeting at the restaurant "Ayshe" in Simferopol at
your invitation.
Annex 27 Exhibit AA
After that meeting, you wanted the Ankara General Centre and especially dear Mukremin Şhahin, the
chairmen of the societies belonging to our federation (e.g. dear Ergin Batur) to confirm that the
money I sent you, you allegedly returned to me.
However, the people mentioned could not have been informed in any way concerning this subject.
I personally have never spread the word about the money given to charity. I have never demanded or
wanted the return of cash and non-cash funds invested in Crimea. I sent that money to support my
compatriots, to help the people. I would like to remind you that I did not demand the return of funds.
But if you did send the funds, I DID NOT RECEIVE them and they WERE NOT RETURNED.
Please provide details of where you said you returned the funds you received in the amount of 100,000
(one hundred thousand) dollars. Details of the $100,000 income are given in the annex below.
Out of the funds which you are very well aware of, I ask you to allocate to the Rector of KIPU
(Crimean State Engineering and Pedagogical University), Fevzi Yakubov the sum of $20,000 (twenty
thousand) dollars on my behalf. If you do not need the remaining amount, please let me know and we
will distribute this money to the people.
All the best.
V. Ibraim Araji
Chairman of the Federation of Crimean Societies and Society of Culture and Mutual Assistance of
the Crimean Tatars of Kocaeli.
Letter 2:
V. İbrahim ARACI
Sent: 30 September 2013
Dear Mr. Mustafa Dzhemilev.
I want to inform you that I have not received a response to the email dated 23 September 2013.
As you know, there are three orphans of our tribesmen living in Saki. I ask you to allocate $20,000
from this amount for their purchase of a house.
I would like to ask you to provide information about the amount of these funds allocated for charity
on the holiday of Oraza Bayram from the Kocaeli Society of Crimean Tatars.
All the best.
According to a Turkish source, Ibraim Araci has not yet received a response from Mustafa Dzhemilev.
Also, neither the three orphans from the city of Saki nor the rector of the KIPU, Fevzi Yakubov, have
received financial assistance.
* * *
Annex 27 Exhibit AA
The above case is just one small episode of Mustafa Dzhemilev's more than 20 years of "haymaking"
in the fat field of foreign charitable aid to the Crimean Tatar people.
What conclusions can be drawn from the described situation?
Firstly, it's time for the Crimean Tatar public, and first of all the Qurultay delegates, to demand from
the Mejlis head and heads of the organisations accountable to him - "Crimea" Fund, "Crimea
Development Fund", "League of Crimean Tatar women", "Maarifchi" Association and others,
participating in receiving and distributing humanitarian and charitable aid - a full and public report
about the amount of humanitarian aid received in recent years, as well as about its distribution and
final recipients.
Second, the Crimean Tatar community needs to establish an effective system for receiving and
distributing charitable aid, with mandatory monthly public reports by the recipients and distributors
of humanitarian and charitable aid on the amount of aid received and its distribution to those in need,
as well as on the principles and criteria for selecting candidates and projects to receive such aid.
Thirdly, the Crimean Tatar public should publicly call on the international community, charitable
foundations and the Crimean Tatar diaspora to ensure transparency and openness in sending
humanitarian and charitable aid to the Crimean Tatar people and its distribution in Crimea. And to
ensure that these principles are strictly adhered to.
Without this, embezzlement and abuse will continue in the future, no matter who is at the helm of the
Mejlis, inevitably leading the people to further impoverishment and degradation...
Milli Firka Press Service

Exhibit AB
VKontakte, Crimea24.tv, Mustafa Dzhemilev sold most of the humanitarian aid handed over
from Turkey to Crimean Tatars (3 February 2023)
(translation)

Annex 27 Exhibit AB
Transcript
Translation
VKontakte, Crimea24.tv, Mustafa Dzhemilev sold most of the humanitarian aid handed over
from Turkey to Crimean Tatars (3 February 2023), available at: https://vk.com/
crimea24tv?z=video-116028735_456268795%2F368833c9596954b4ed%
2Fpl_post_-116028735_170054.
[00:02]
[Speaks Russian]: Yes, in the late nineties and noughties, humanitarian and financial aid for the
Crimean Tatars came mainly from Turkey. All flows were controlled personally by Mustafa
Dzhemilev, but the people themselves did not feel this support in any way. The head of the
Federation of Crimean Tatar Cultural Societies of Turkey, Univer Sel explains the details.
[00:20]
[Speaks Turkish] [Translated into Russian]: Crimean Tatars began returning home to Crimea
from exile in 1989. Two years later, the Soviet Union collapsed and the Crimean Peninsula
became part of the now independent Ukraine. Since then, Turkey's assistance to our compatriots
in Crimea has increased dramatically. Much of this aid was provided by the Turkish state.
Crimean Tatars in Turkey also collected aid through Crimean associations and delivered it
to Crimea. Mustafa Dzhemilev took responsibility for a significant portion of these inflows.
However, a number of actions that were allegedly taken for the benefit of the Crimean Tatar
people were not successful. During the presidency of Suleiman Demirel in Turkey financial and
humanitarian aid was sent to Crimea to build a hospital. In the end, the hospital was never
built. The most major issue for Crimean Tatars was dwelling. For this purpose the aid was
sent from Turkey to Crimea. As a result, there are no houses and no funds. Over the years,
much of the humanitarian aid collected from Turkey and sent to Mustafa Dzhemilev has
been distributed around himself. Senders witnessed that the better half of this aid was sold
in markets and with wholesalers. Presently separated from Ukaraine the Zaporozhye and the
Kherson regions were historical lands of the Crimean Khanate and the Crimean Tatar
population lived there. In 2014, these people relocated to Crimea. And their remaining houses,
fields, hotels, factories and restaurants were looted by representatives of a Crimean Tatar
battalion set up on behalf of NATO. Mustafa Dzhemilev and his company have been profiting
from Crimean Tatars for years. While the Crimean Tatar community was living in misery,
they got rich, including through fraudulent arrangements with Turkey. Mustafa Dzhemilev
being an uneducated man evolved into a man owning luxury cars, villas and flats in Kiev,
Istanbul, Cyprus and London as well as companies doing business with Europe, Canada and the
United States. He made over most of them with other people: his wife, his friends, his drivers.
Today he has set up coordination offices outside the Turkish association. He is looking for ways
to turn the war into a spoilsport by supplying arms and aid to the Ukrainian
Annex 27 Exhibit AB
army through them. It is time to put an end to these structures enriching themselves at the expense
of the suffering and despair of Crimean Tatars. In this regard the Turkish state should also take
responsibility and set up a team to investigate the fate of the aid and money sent. Nothing else
should be a secret. Those who have plundered the values of Turkish and Crimean Tatar society for
years must be publicly brought to responsibility.
[...]
Exhibit AC
Politnavigator.net, Erdogan is suggested to initiate an investigation into the theft of Turkish
money by the Mejlis leadership (7 February 2023)
(translation)

Annex 27 Exhibit AC
Translation
Politnavigator.net, Erdogan is suggested to initiate an investigation into the theft of Turkish
money by the Mejlis leadership (7 February 2023), available at:
https://www.politnavigator.net/ehrdoganu-predlagayut-iniciirovat-rassledovanievorovstva-
tureckikh-deneg-medzhlisovskojj-verkhushkojj.html.
By Lyubov Smirnova
Turkey should make a narrow search into the loss of funds allocated for construction of a
hospital for Crimean Tatars and multi-storey buildings. The money vanished without a trace in
business structures linked with Mustafa Dzhemilev, ex-Chairman of the Mejlis of the Crimean
Tatar people banned in the Russian Federation for extremism.
This is what Unver Sel, the head of the Federation of Crimean Tatar Cultural Communities of
Turkey, told during a live show at Crimea24, as reported by a PolitNavigator correspondent.
“Crimean Tatars began returning to their homeland in Crimea in 1989. The Soviet Union
collapsed two years later, and the Crimean peninsula became part of the already independent
Ukraine; since that time, Turkey’s aid to our compatriots in Crimea increased dramatically,” Mr.
Sel said.
He clarified that “a significant part of the aid was provided by the Turkish State through the
Crimea Foundation controlled by Mustafa Dzhemilev”.
“However, many actions allegedly taken for the benefit of the Crimean Tatar people have been
unsuccessful. During the presidency of Suleyman Demirel, Turkey sent humanitarian aid to
Crimea to build a hospital, but it was never built.
Annex 27 Exhibit AC
Housing was a major problem for Crimean Tatars. To cope with it, Turkey sent aid to Crimea,
but no houses were built, and the money vanished.
Over the years, most of the humanitarian aid that had been collected was distributed among
Mustafa Dzhemilev’s cronies, and those who sent aid saw most of it offered in markets and sold
by wholesalers”.
The Zaporozhye and Kherson Regions that have now separated from Ukraine were historically
the land of the Crimean Khanate inhabited by the Crimean Tatar diaspora, Mr. Sel recalled.
In 2014, these residents moved to Crimea, while the houses, fields, hotels, factories and
restaurants that they left behind have been looted by members of the Crimean Tatar battalion set
up on behalf of the Armed Forces of Ukraine.
“Mustafa Dzhemilev and his gang have been profiting from the Crimean Tatars for years while
the Crimean Tatar community lived in misery, they got rich on fraudulent transactions with
Turkey. Mustafa Dzhemilev, for his part, has turned from a man who had no education into an
owner of luxury cars, villas and apartments in Kiev, Istanbul, Cyprus and London, as well as
companies doing business in Europe, Canada and the USA. He registered most of them in other
people’s names such as his wife’s, friends’, and drivers’,” noted Mr. Sel. “Now, he has set up
coordination offices in Turkey, looking for ways to turn war into profit through them by
supplying arms and aid to the Ukrainian Army.
It is time to put an end to those structures making money at the expense of Crimean Tatars’
suffering and despair. In this vein, the Turkish State should also put together a team to
investigate what has become of the aid that has been provided and the money that has been sent.
Nothing should be kept secret anymore. Those who have been plundering the riches of the
Turkish and Crimean Tatar peoples for years should be held accountable to the public.”
Exhibit AD
RIA Novosti (Crimea), How Crimea Was Tempered: Five Blockades in the Peninsula's Modern
History (28 February 2019)
(translation)

Annex 27 Exhibit AD
Translation
RIA Novosti (Crimea), How Crimea Was Tempered: Five Blockades in the Peninsula's
Modern History (28 February 2019), available at:
https://crimea.ria.ru/20190228/1116152860.html.
How Crimea Was Tempered: Five Blockades in the
Peninsula's Modern History
07:24 28.02.2019
© RIA Novosti. Andrei Stenin
Evgeniya Martynenko, RIA Novosti Crimea correspondent
Day by day Crimea is approaching a landmark date - the first five-year anniversary of the
Russian peninsula's recent history. In these February-March days, Crimea, like the rest of the
country, is remembering the events of 2014, when Crimeans decided to reunite with Russia.
Over these years, the peninsula has gone through a difficult path of establishing the region
as a full-fledged constituent entity of the Russian Federation, facing Ukrainian provocations
time and again. In particular,
With Russia's help, the peninsula went through five blockades imposed by Ukraine:
economic, water, transport, energy and informational. On the eve of the anniversary of
reunification with Russia, RIA Novosti Crimea recalls what it was like.
It all started with the water
Since Crimea became part of Russia and a new government was established in Ukraine, Kiev
has repeatedly threatened to blockade its border with the peninsula. Kiev has had all the
Annex 27 Exhibit AD
"trump cards" for this, as the peninsula, which is connected by land only with Ukraine,
received resources and most goods from there.
The "provocative debut" was not long in coming - immediately after the peninsula became
part of Russia, a water blockade was imposed.
Until 2014, Ukraine provided up to 85% of Crimea's fresh water needs through the North
Crimean canal from the Dnepr River, this water was used to irrigate farmland. Approximately
one third of the Kherson region was fed with water through the same canal. After the events
of the "Crimean spring", the Ukrainian part of the waterway was taken under enhanced
protection and the Administration of the North Crimean canal in Tavriysk (Khersonskaya
Oblast - ed.) was instructed to close the flood-gates on the barrier near the border with
Crimea. The inflow of water to the peninsula has practically stopped.
In May 2014, information emerged that a dam was being constructed on the territory of
Kherson Oblast approximately 15 km from the border with Crimea. After the completion of
this facility, "excess water" was discharged into the Black Sea gulf through one of the drains,
drying up the channel of the North Crimean canal. A cofferdam was then built there with
sluices and water metering structure in case of water supply to Crimea after conclusion of
the relevant agreement. However, there were no official negotiations on this issue - Crimea
took all sorts of measures on its own to provide itself with water and no longer depend on
Ukraine in this matter.
© RIA Novosti . Konstantin Chalabov
"The problem of sustainable water supply to the peninsula has always been there, the issue
of drinking water quality was relevant many years ago. And the closure of the North Crimean
canal directed us to solve the issue of sustainable water supply to Crimea, now we are
successfully dealing with these issues," Sergey Tsekov, a member of the Federation Council
Committee on International Affairs, said in a commentary to RIA Novosti Crimea.
Annex 27 Exhibit AD
In the absence of water from the Dnepr River, the peninsula's agriculture suffered significant
losses: the area of irrigated land decreased several times, the agricultural sector switched to
drip irrigation and cultivation of drought-resistant crops, and the cultivation of some crops
had to be abandoned altogether.
A number of projects have been implemented to supply water to consumers in Crimea. For
example, in 2014, hydraulic engineering structures were built to fill the North Crimean canal
with water from the Belogorsk and Taigan reservoirs along the Biyuk-Karasu River. Thanks to
this engineering solution, residents of eastern Crimea, where the water supply situation was
the most difficult, began to receive water.
In addition, construction of three water intakes in Nizhnegorsk and Dzhankoy districts -
Novogrigoryevsky, Nezhynsky and Prostornensky - started in October 2014. The project, with
a total cost of 1.2 billion roubles, envisaged drilling of 12 artesian wells from 110 to 180
metres deep at each of the water intakes. The water wells were constructed within two years,
and this allowed to supply drinking water to about 200 thousand residents of the Eastern
Crimea.
© Photo: Information Policy Department of the Ministry of Information of the Republic of Crimea
As part of the implementation of priority measures for water supply 30 wells were drilled,
repaired and equipped in 30 localities of the Republic. In a number of Crimean villages, where
water was supplied by the hour for 15-20 years, a round-the-clock water supply has been
established.
The ordeal of water scarcity did not break Crimea; on the contrary, the region was able to
promptly begin to meet the challenges faced by the newly-formed Russian region.
"The water blockade of Crimea did not lead to the disastrous results our enemies hoped for.
The water needs of the peninsula's population and guests for domestic and drinking needs
have been fully met," stressed Sergey Aksenov, head of the Republic, during his annual report
Annex 27 Exhibit AD
on the Council of Ministers' activities in 2018. - In five years, more than 173 million cubic
metres of water have been supplied to the region's reservoirs".
The food supply was cut off
© RIA Novosti . Denis Petrov
The water blockade has not led to the desired effect for Ukraine and it has made its next
move. This time, Kiev appears to have "checkmated" the peninsula's food security.
On September 8, 2015, deputies of the Verkhovnaya Rada and leaders of the Russian-banned
organisation "Mejlis of the Crimean Tatar people"* Mustafa Dzhemilev and Refat Chubarov
said.
it was necessary to stop trade turnover with the peninsula. Dzhemilev announced
preparations for a so-called "peaceful transport blockade" on the border between Kherson
Region and Crimea. All Ukrainian patriots were urged to join the action. A week later, Russianbanned
extremist organisation Right Sector* announced its intention to join the upcoming
blockade. Later, the Kherson police said that they were preparing to ensure law and order at
the blockade and to provide the protesters with everything they needed.
While some officials from the rostrum in Kiev publicly "pitied" Crimeans and called for help
to overcome the difficulties of the so-called "occupation", others tried in every way to isolate
the peninsula from the outside world. Considering that Ukrainian goods were still actively
supplied to Crimea at that time, the radicals took a drastic decision - to cut off the supply of
products to the peninsula. The Russian side responded immediately, saying that the
Annex 27 Exhibit AD
peninsula was not afraid of these threats and that only the Ukrainians themselves would be
made worse off by the organisers.
"You didn't have to be a very smart state official to go along with it. In fact, they did not
impose food blockade on us but on their producers. Everyone who grew their own
vegetables, fruits and produced their own goods - they were simply deprived of the market.
For us, however, this was an incentive to quickly replace and increase the productivity of our
Crimean market," Senator Sergey Tsekov recalled.
However, Kiev has not heard the call for common sense . At noon on 20 September 2015,
concrete checkpoints and a tent camp were set up at the Chongar checkpoint. Thus began
the trade blockade of the peninsula. The following trucks into Crimea were blocked by radical
Crimean Tatar representatives, who were joined by civic activists and members of volunteer
battalions. All this with the tacit consent of the Ukrainian police.
Later, roads to the Chaplynka and Kalanchak checkpoints were blocked. The blockade only
applied to trucks carrying goods to and from Crimea, which led to repeated clashes between
truckers and activists. Personal vehicles were initially allowed through the border
unimpeded, but later Right Sector members* began to inspect cars as well, checking the
documents of people crossing the border and checking them in the database of the
scandalous website "Mirotvorets".
In the first hours after the blockade began, trucks began to pile up at the checkpoints, and
queues numbered in the hundreds. The transporters tried for some time to talk sense into
the radicals, but they remained adamant that Ukraine would not feed and support the
"traitors of the motherland". For his part, Petr Poroshenko said that the rally was held to
"restore state sovereignty as soon as possible over Crimea". And the head of the Mejlis*,
Refat Chubarov, stressed that the main goal of this blockade was to demonstrate "to the
whole world that Russia must pay for the upkeep of Crimea until it withdraws from there"
© RIA Novosti . Maks Vetrov
Annex 27 Exhibit AD
However, Kiev's calculations did not come true. Firstly, the republic's counters were already
full of Russian goods, and there was plenty to choose from. Secondly, during the first days of
the trade blockade more than 30 retail chains of the peninsula and the government of Crimea
signed a memorandum on limitation of the prices. In addition, The Russian Federation did its
best to provide the "cut off" peninsula with everything necessary through the Kerch ferry
crossing. Despite the calls of the official authorities to boycott the region, a number of
Ukrainian manufacturers tried their best to maintain trade relations with the peninsula and
transported products via detour routes - by ships across the sea and through the Russian
territory.
Experts believe the economic blockade was actually an attempt to control trade with Crimea
where wages, pensions and effective demand increased sharply during the year. However,
the attempt failed - the peninsula did not experience any deficit, continued to actively
integrate into Russia, while Ukraine was left with ruins, as it was Ukrainian producers who
suffered enormous losses from the blockade. After the first setback, Kiev played the second
"card" - at the end of September, the Verkhovnaya Rada registered a draft law on the
complete blockade of Crimea and Donbass. The document regulated the complete closure of
railway, freight and bus traffic to these territories. This marked the beginning of the next
blockade of the peninsula - the transport blockade.
No planes are flying and no trains are travelling
© AP Photo/Sergei Grits
In fact, Crimea saw the beginnings of a transport blockade back in late 2014, when Ukraine
unilaterally halted train traffic across the border with the Russian peninsula. Passenger and
freight trains travelling to Crimea ended their route in Kherson Region before reaching the
border. The Ukrainian railway transport administration, "Ukrzaliznytsya", explained that it
was impossible to ensure passenger safety.
Annex 27 Exhibit AD
Direct sea and air links between Crimea and abroad were interrupted. Crimeans with Russian
passports began to fly abroad from mainland Russian airports. The carriers and owners of
bus stations also received letters demanding that they stop selling tickets and carrying
passengers on bus routes connecting the Ukrainian mainland with the territory of Crimea.
The official bus service to the peninsula has also been terminated.
However, even here, the complete isolation that the Ukrainian side still hoped for did not
happen. It was possible to reach Crimea from the neighbouring country, albeit with transfers:
by driving through the territory of Ukraine to the border settlements, then by car to the
checkpoint, then on foot through the border strip to the checkpoint on the Russian side and
from there by any means of transportation through the towns of the peninsula. Later, a more
convenient way of crossing the border was found - those who wished to do so could get to
Crimea by private transport or use the services of enterprising carriers who drove people in
their cars or minibuses. This service quickly became popular among residents of both
countries as they had family and friends on both sides of the border. Taxi drivers are still
making good money from the Crimea transport blockade to this day - they quickly 'took over'
the service of transporting passengers across the border. So this blockade, too, was
essentially ineffective in Kiev's attempt to cut off all ties with the peninsula.
Six months of blackout
© REUTERS/ Stringer
The peninsula's third and most severe blockade in a year began in November 2015. At that
time, Crimea faced a phenomenon unprecedented in modern history: a group of extremists
supported by the Ukrainian authorities blew up electricity transmission towers in the Kherson
region and left the entire peninsula without electricity.
Annex 27 Exhibit AD
As the energy system of Crimea was in deficit in Ukrainian times and the main volume of
consumed electricity was covered by overflows from other regions of Ukraine through four
high-voltage power lines "Melitopol - Dzhankoy", "Kakhovka - Dzhankoy", "Kakhovka -
Ostrovskoe", "Kakhovka - Titan", the peninsula was energy dependent on the neighbouring
state. Crimea's own generation was no more than 20-25%, which radical political circles in
Ukraine did not fail to take advantage of.
On the night of October 6, 2015, unknown persons damaged a high-voltage pole of one of
the transmission lines that supplied electricity to Crimea. At first, the "Right Sector"* denied
involvement in the incident and called it "a provocation aimed at discrediting the action to
blockade the peninsula". However, the organisation later stood by the supporters of the
Crimean Tatar Mejlis*, which is now banned in Russia, who prevented "Dneprenergo"
specialists from repairing the power line tower.
In November, radical supporters from various regions of the neighbouring state began to
flock to Kherson Region on the border with Crimea. The "Right Sector"* said that it had
"received operational information about possible provocations due to the difficult internal
situation" in Ukraine. On the night of 20 November, a group of Ukrainian radicals blew up the
supports of the Melitopol-Dzhankoy high-voltage power transmission line in Kherson Region
near the border with the peninsula. The Kakhovka-Titan and Melitopol-Dzhankoy lines
supplying Crimea are out of order. To clarify the circumstances, the Russian Energy Ministry
set up an operational headquarters to supply power to Crimea.
A day later, "Ukrenergo" said that during an inspection of the power lines, experts also found
damage on the two remaining lines: a crack in the reinforced concrete pole of the Kakhovka-
Ostrovska line and damage to the metal structure on the "Kakhovka - Dzhankoy" line. The
pylons were surrounded by activists of the so-called Crimean blockade who oppose electricity
supplies to Crimea. They blocked the access of repair teams to the damaged power lines,
which led to clashes with Ukrainian security forces who arrived on the scene.
And the next night, the peninsula was completely plunged into darkness - on November 22,
all Crimean settlements went out of power. This time, all four power lines on the border with
the peninsula were blown up, leaving nearly 2 million people without power supply. Lenur
Islyamov, a former Moscow businessman who is now the leader of an armed Ukrainian
militant extremist battalion and one of the most ardent supporters of the return of Crimea
to Ukrainian control, was one of the organisers and sponsors of the attack. The Crimean and
Sevastopol authorities introduced a state of emergency. All social facilities on the peninsula
immediately switched to reserve power sources, and hundreds of additional diesel generator
sets and fuel were transferred to Crimea from all regions of Russia.
The Ukrainian authorities were in no hurry to restore power supply and the peninsula's own
generation facilities could not cover the region's needs, so they had to accelerate the
commissioning of the power bridge, which had been under construction since April 2015 to
connect Crimea to the Unified Energy System of Russia.
The first line was launched in early December, providing Crimeans with 200 MW of Russian
electricity. The second was commissioned two weeks later, on December 15, and the third in
April 2016. On 11 May 2016, the energy bridge started operating at full capacity - in a video
conference, President Vladimir Putin launched the last, fourth string of the energy bridge
from Krasnodar Region.
Annex 27 Exhibit AD
On 18 May, the state of emergency in Crimea was lifted. After Crimea, the state of emergency
was also lifted in the hero city of Sevastopol.
The blackout in Crimea, which was organised by Ukrainian extremists and radicals, lasted
almost six months. The Crimean prosecutor's office opened a criminal case against its
organisers, and the damage caused by their actions was estimated at about 2.5 billion
roubles. These six months were a serious test for Crimeans, but the peninsula's residents
withstood all the difficulties of the energy shortage with honour.
International recognition in the sanctions regime
© RIA Novosti . Vasiliy Batanov
After the reunification of the peninsula with the Russian Federation, the European and US
authorities did everything possible to isolate it from the rest of the world. Thus, a large-scale
information and political blockade was imposed on the newly-formed entities of Russia -
Crimea and Sevastopol.
International media reported with enviable consistency on the "horrors" of the "occupied
Crimea". A number of countries announced an international boycott of the Russian
peninsula, securing their decision with sanctions and all kinds of restrictions.
However, despite the large-scale information blockade, some European politicians decided
to personally check the situation in Crimea and visited the Russian entity. Some of them
officially, some with a private visit, and some as part of large delegations.
In the past two years alone, about 100 official foreign delegations have visited the Republic,
including from Germany, France, Norway, Bulgaria, the USA and other countries. And all the
foreigners have been pleased with the visit, admitting that there is peace and order in the
Annex 27 Exhibit AD
region. After the visits, they admitted that the picture painted in many Western media of
what is happening in Crimea is far from reality, and each visit by foreign guests makes a
significant contribution to breaking the information blockade of the peninsula.
The number of politicians openly supporting the reunification of the peninsula with the
Russian Federation in Europe and other countries is increasing year by year. More and more
often, statements about the recognition of the Russian status of Crimea are heard not from
members of the public, but from current officials who hold serious official positions in their
states and members of national and European parliaments. This demonstrates that European
countries are gradually realising the need to recognise the peninsula as part of Russia and to
lift economic sanctions that are harmful to everyone.
© RIA Novosti . Aleksandr Polegenko
"In five years, it has become obvious to all sane people that attempts to isolate Crimea have
completely failed. Much credit is due to the people's diplomacy. Last year, the leadership of
the Council of Ministers paid official visits to Syria, China, Armenia, South Ossetia, Abkhazia,
Laos and the Donetsk People's Republic. Crimea hosted 25 international events last year
alone, - "Sergey Aksyonov said in his annual report to the State Council. - In just five years,
representatives of at least half of the world's countries have visited Russia's Crimea, and if
private visits are taken into account, of course, even more".
"The biggest blockade Crimea faced was when it was part of Ukraine. Everything was being
destroyed then - the economy, infrastructure, agriculture. And all this was happening against
the backdrop of creeping Ukrainianisation," Senator from the Republic Sergey Tsekov told
RIA Novosti Crimea. - All of this combined has allowed us to successfully overcome the
blockades that Ukraine put on us after reunification with the Russian Federation. So much
so that we did not perceive Ukraine as our motherland, we considered it more as a
stepmother, that when it arranged all these blockades for us, we coped with them very
Annex 27 Exhibit AD
successfully. And they allowed us to quickly solve all the problems that Crimea needed to
solve in principle".
*Organisations banned in Russia

Exhibit AE
RBC, Crimea's Shutdown: The Threat of an Energy Blockade to the Republic
(22 November 2015)
(translation)

Annex 27 Exhibit AE
Translation
RBC, Crimea's Shutdown: The Threat of an Energy Blockade to the Republic (22 November
2015), available at: https://www.rbc.ru/society/22/11/2015/5651b8cf9a79474f3a9e0f59.
Crimea's Shutdown: The Threat of an Energy Blockade to the
Republic
(Photo: Alexei Pavlishak/TASS)
The power supply to Crimea from Ukraine has been cut off due to the undermining of power
transmission towers by unknown assailants. It will take up to two days to restore it if Crimean
blockade activists do not obstruct repairs
Outdoor concession stand in one of the walking tunnels in Stroganovka village, Simferopol district
Shutdown in two days
Crimea's maximum demand for electricity is 1,200 MW per day. About 30% of this capacity is
provided by its own generation (thermal, solar, and wind power plants), and from 500 to 900 MW,
depending on the time of the day, is delivered by transmission lines from Ukraine. Energy purchases
there, as well as from Crimean producers, are handled by the Settlement Implementation Centre, a
subsidiary of Russia's "Inter RAO". It was allocated a budget subsidy of 10 billion roubles for 2015,
of which 8.8 billion had been spent as of 1 November.
The scheme suffered its first failure on Friday. On the morning of November 20, the poles of two
power transmission lines (PTL) were blown up by unknown assailants: Melitopol - Dzhankoy
(330KW) and Kakhovskaya - Titan (220KW). The remaining two transmission lines took over the
supply of electricity to the Crimean peninsula at this point: Kakhovskaya-Ostrovskaya (330KW) and
Kakhovskaya-Dzhankoy (330KW). The second failure occurred on Saturday at 23:20 (00:20 Moscow
time on Sunday), when "Ukrenergo", the Ukrainian energy company, received a signal that these two
lines were also down.
Annex 27 Exhibit AE
The Crimean energy system
© RBC, 22 November 2015 The source "Ukrenergo" The map: openstreetmap.org
On Sunday morning, the Ukrainian Energy Ministry reported that electricity supplies to consumers
on the Crimean peninsula had been completely cut off. In addition, according to its estimates, there
is a risk of disconnection of up to 40 percent of consumers in Kherson and Nikolaev regions.
"Household consumers of the Republic of Crimea and the city of Sevastopol (about 1.9 million
people) were left without electricity supply. The capacity of the disconnected consumers is 673 MW,"
the Russian Energy Ministry reported on Sunday.
No one has claimed responsibility for undermining the pylons. In late September, one of the initiators
of the civil blockade of Crimea from the Ukrainian side, people’s deputy of Verkhovnaya Rada Refat
Chubarov, promised to de-energise the peninsula. Since 20 September, Crimean Tatar activists,
supported by the representatives of the "Automaidan" movement, "Right Sector" (an organisation
banned in Russia), and other Ukrainian organisations have been blocking the movement of Ukrainian
commercial vehicles into the peninsula.
One of the leaders of the Crimean Tatars, people’s deputy Refat Chubarov, wrote in his Facebook
account on Saturday that participants in the Civil Blockade of Crimea demanded that the authorities
take effective measures aimed at protecting the rights of Ukrainian citizens "living in the temporarily
occupied territory of Crimea". "As such a measure... appears to be the termination/restriction of
electricity supplies from mainland Ukraine to occupied Crimea," Chubarov wrote. According to
"Interfax-Ukraine" news agency, activists of the Civil Blockade of Crimea movement posted photos
Annex 27 Exhibit AE
of the fallen pylons on social media on Sunday morning, but did not claim any involvement in the
incident, suggesting that it was "the work of saboteurs".
In an interview with "Interfax-Ukraine", one of the leaders of the Crimean Tatar movement, people’s
deputy Mustafa Dzhemilev, said that on Saturday he discussed with Ukrainian President Petr
Poroshenko "the incident between participants in the "blockade of Crimea" and law enforcers". The
latter demanded that energy workers be allowed to access the damaged power lines in order to ground
them, but blockade activists did not allow the repairmen to the pylons.
President Poroshenko and Prime Minister Yatsenyuk have not yet commented on the situation.
Internal Affairs Minister’s adviser and people’s deputy Anton Gerashchenko said that he believed it
was necessary to discuss the energy blockade of Crimea in parliament, but so far there have been no
official statements on the issue.
The Ukrainian side did not give an exact deadline for eliminating the accident and restoring power
supply on Sunday. The management of "Ukrenergo" said that it had started negotiations with the
participants in the Crimean energy blockade "on the possibility of carrying out repair works". Dmitriy
Marunych, co-chairman of the Ukrainian Energy Strategy Foundation, told RBC that two days would
be enough to repair the blown-up power line poles if the activists do not block the repairs. According
to Marunych, the poles of the power lines, which supply electricity to Crimea, will be restored in any
case, as they also supply Ukrainian regions.
According to "Ukrenergo", in order for the situation in Crimea to normalise, it is enough to restore
one of the transmission lines that feeds Crimea with a capacity of 330 kilowatts; then the peninsula
will be able to receive 500-550 megawatts per day through it. For now, the Ukrainian energy sector
has promised to notify the buyer of electricity, a subsidiary of "Inter RAO", about the force majeure.
Crimean Deputy Energy Minister Evgeniy Demin told "RIA Novosti" that fuel reserves for mobile
power plants in Crimea will last for 25 days. In 2014, Russian Emergencies Minister Vladimir
Puchkov reported that his ministry had sent about 1,400 mobile stations to the peninsula. In addition,
nine large mobile gas turbine power plants (GTPPs) with a total capacity of 241 MW have been sent
to Crimea from Sochi. "Currently, all reserve power sources are engaged in Crimea, all social
infrastructure is connected, but it is impossible to increase the number of mobile stations and diesel
generators - the peninsula's entire demand cannot be covered this way," a source in the republic's
Energy Ministry told RBC.
No boilers and no fridge
The peninsula authorities have decided that street lighting will not work during dark hours "for the
sake of economy". Crimean head Sergey Aksyonov also warned the region's residents about possible
disruptions in the work of mobile communications and the Internet. Simferopol authorities said, that
rolling blackouts in the city might last for up to nine hours. The Crimean capital has also turned off
heating, however city head Gennadiy Bakharev said that this was due to the warm weather: the city
recorded a temperature of plus 18 degrees on Sunday.
Crimean Industrial Policy Minister Andrei Skrynnik said Sunday afternoon that "according to
operational monitoring, most retail businesses as well as retail markets continue to operate and have
sufficient stock to meet consumer demand in full, despite restrictions on electricity supplies." Natalya
Kashcheyeva, a spokeswoman for the agency, later noted that many retailers "are finding a way out
by connecting to backup power sources".
The association "Assistance to Trade of Crimea" estimates are more pessimistic: according to its data,
more than half of the chain shops in Crimea - at least 50 outlets - are without electricity. "Of these,
Annex 27 Exhibit AE
only 5% are now operating on backup power supplies," says association chairman Sergei Makeyev.
- But it is too early to talk about any serious losses for retailers: everyone has freezers, so that everyone
can make it through the day. The general mood among the population is calm, there is no panic, no
one is asking to go back to Ukraine. We do not notice an increase in demand for any goods".
Of the 13 shops of the "Yabloko" grocery chain, only two in Simferopol are not operating at the
moment, director of the chain, Tatyana Pikalova, told RBC. "Two shops - one in Kerch and one in
Evpatoria - are running on diesel. In Simferopol we have eight shops, only two are not working
because the others are in areas where there is electricity," she said. - We have stored all the goods in
freezers and will be able to keep them cold for the next eight to nine hours," she said. Authorities
have kept us informed of the current situation. We are promised that within today the situation will
improve and a schedule of rolling blackouts will be drawn up."
"At night we had power outages, now everything is working," Yanina Pavlenko, general director of
Massandra winery, told RBC. - We will adjust our work to the blackout schedule. Ukraine has cut off
our electricity supply before, so we are used to it".
Cable from Russia
The only way to make Crimea independent of Ukrainian energy supplies is to connect the peninsula
to the Russian energy system. It was reported in July that the Energy Ministry had signed a state
contract on the construction of a power bridge to Crimea. The total cost of the project (it includes
four cable lines and the construction of two power plants in Crimea) exceeds 47 billion roubles,
including value added tax. In 2015, 9.5 billion roubles was allocated to the project. The client is the
Russian Energy Agency (part of the Ministry of Energy), and the main contractor is the "Engineering
and Construction Management Centre of the Unified Energy System", a subsidiary of the Federal
Grid Company.
How the energy bridge works
Four cable lines with a length of 13.5 km each will be laid on the bottom of the Sea of Azov. The
cables will be laid at a depth of 8-18 m. The total area of the corridor in the water area of the strait
will be 202.5 ha.
At the same time, the United Power Grids of the South will be prepared to serve the Crimean energy
system. It is a question of building 500KW high-voltage lines Rostovskaya-Andreyevskaya-
Vysheblyevskaya (Taman) and Kubanskaya-Vysheblyevskaya. The 500KW Kubanskaya substation
will also be expanded and the 500KW Vyshebliyevskaya substation will be built.
The construction of the energy bridge is being carried out in two stages. The first phase of the work
should be completed by early 2016, Crimean Deputy Energy Minister Evgeniy Demin told reporters
in October, and it will provide the peninsula with 300-400 MW of energy. "The cable for the power
bridge has almost been laid, but in order to launch it, the infrastructure around it is still needed, so the
urgent commissioning is out of the question now," a source close to the Ministry of Energy familiar
with the details of the project told RBC.
The second stage, as the official said in an interview with kerch.com.ru a month ago, will be
completed in the summer of 2016 (the deadline may be pushed back to 2017. - RBC) and will make
it possible to supply a total of 600-800 MW to Crimea. The additional generation is to be provided
by Rostov Atomic Power Station. Once the two new thermal power plants with a total capacity of
about 900 MW start operating (the first stage is scheduled for 2017), the peninsula will become
energy-independent from Ukraine.
Annex 27 Exhibit AE
With the participation of Polina Khimshiashvili

Exhibit AF
Odessa Crisis Media Center, Lenur Islyamov: We Will Return Crimea Within 2016
(25 December 2015)
(translation)

Annex 27 Exhibit AF
Translation
Odessa Crisis Media Center, Lenur Islyamov: We Will Return Crimea Within 2016
(25 December 2015), available at:
https://web.archive.org/web/20160207145939/http://www.odcrisis.org/lenur-islyamov2/.
Lenur Islyamov: We Will Return Crimea Within 2016
This entry was made in News on 25 December 2015 by Alena Balaba, our author, and tagged
as “Odessa”, “Noman Chelebzhikhan Battalion”, “blockade of Crimea”, “civil blockade of
Crimea”, “Krim”, “Crimea”, “Lenur Islyamov”, “Naval blockade of Crimea”, “Odessa”,
“customs”, “ports”, “Chonhar” and “energy blockade”.
A plan to return the occupied and annexed Crimea is ready; a food blockade is successfully
maintained, the peninsula receives electricity in a metered manner, a volunteer battalion is being
formed in the border zone, and activists plan to impose a naval blockade in the near future.
Read the details in our publication.
The blockade of the occupied and annexed peninsula began as early as on the 20th of September,
when Crimean Tatars, who are persecuted in every possible way by Russian occupiers, blocked
the roads leading to the peninsula, preventing trucks carrying food from passing. Mass media
were full of various information with assessments and criticism of the civil blockade of the
Crimea imposed by activists. Soon Azov and Right Sector members joined Crimean Tatars in
their efforts to maintain the blockade, with the Armed Forces of Ukraine and Ukrainian border
guards also supporting the blockade. On the 21st of November, unknown persons blew up the
four power line pylons supplying electricity to the occupied peninsula in Chaplynka, Kherson
Region, resulting in a long-time blackout. Following their old tradition, Russian propagandists
began to threaten and blackmail the activists, launching various fake news. At the moment, one
power line to the Crimea has been restored, and the peninsula still receives electricity on an
hourly basis. The food blockade is still maintained, and, according to Lenur Islyamov, the
commander of the “Civil Blockade of the Crimea” movement’s headquarters, the invaders
should expect a naval blockade to begin in January. Odessa Crisis Media Center’s reporters
visited the site and took a detailed interview with Lenur Islyamov.
“A lot of various information is circulating, including in Ukrainian media, about the
blockade of the Crimea and who benefits from it. So we want you to tell us what is going on
here, what are your plans, and what you are going to do next”.
“We started the blockade consisting of three stages: the first one is a goods blockade, the second
one is an electricity blockade, and the third one is a naval blockade. There was also an idea of
one small blockade called the “network blockade”, but the Mejlis has not yet given its go-ahead
for it because the whole Crimea will then lose the Internet connectivity. As a matter of fact, we
Annex 27 Exhibit AF
do not insist on it. On the 15th of December, the Cabinet of Ministers passed a resolution
officially prohibiting everything from being imported into the Crimea beginning from 15
January 2016. We gave 30 days for it to become effective. The power line pylons are the next
target. One 220-V line of the four disabled lines is now turned on again. We have to disable it
on the 31st of December. If it is not turned off, then we will move away, removing our
roadblocks everywhere, that is, the electricity should not enter the Crimea beginning from the
1st of January. We left this line for our legislators, members of the Verkhovna Rada, because
we have no hope for the government. As regards the naval blockade, we want to make it very
painful for the Russians. The goods blockade is transforming into civil associations that will be
located in the coastal territory. We are currently forming a new volunteer battalion named after
Noman Çelebicihan. We should wait to receive a military unit number to be assigned to it, but
we already receive volunteer assistance as a battalion. On Friday, we will receive the first batch
of Turkish military uniforms. While the Ukrainian Defence Ministry is still only fidgeting, the
Turkish Defence Ministry has already begun to support us. We will get 250 sets of uniforms
and boots. As soon as we get a military unit number, hopefully, by the 15th of January or so, the
World Congress of Crimean Tatars will be held on Chonhar, and its executive committee will
be here. All Crimean Tatars from all over the world – i.e., from America, Canada, Poland,
Romania, and Turkey, about 43 countries in total, will come here, and all of them will be here,
in our headquarters on Chonhar”.
“Please tell me more about your Battalion”.
“The Battalion will consist of 560 persons. They will deal with the tasks set by the General
Staff. But their main task will be to protect the Crimean border inside the Crimea. We will make
the Crimea closer as soon as possible. The mission of this Battalion is to strike in a way only
we know. We know all trails and springs in the Crimea. Crimean Tatars in the Crimea are
expected to bring the liberation of the peninsula closer. We are told, ‘wait three to four years at
the international level’, but we want this to happen in one year. In three to four years, Russia
will be completely devastated. We want that to happen in one year”.
“How do you plan to impose a naval blockade?”
“Ships with smuggled goods are leaving Odessa. They go to the 12-mile zone and turn off their
GPS navigators. Ships from Sevastopol approach them and take their goods. That is one option.
The other one is that the navigator on the ship is turned off, the ship moves on, goes into the
port of Sevastopol, unload its freight, goes on the same route, turns on its navigator as if it was
broken, and enters Skadovsk. And then it goes to Istanbul. Odessa customs authorities and SSU
know about it. Unfortunately, people are ready to be annexed and raise Russian flags. We need
to return the Ukrainian cities and towns to Ukraine”.
“How are locals responding to the blockade?”
“At first, they were scared. Russian TV channels are broadcast here, there are seven Crimean
radio stations talking about the junta, Tatar-Banderites and so on. The Ukrainian information
field is not protected. When we drive through the Kherson Region, they call us “Banderites”.
But this is half the trouble. People do not understand what will happen to them if Russia comes
here. That Russia they see on TV has long gone”.
“Please tell me, do Ukrainian border guards know about the sea smuggling?”
Annex 27 Exhibit AF
“I do not want to blame anyone, I just know that is happening. But I cannot figure out how all
those services ca be unaware of the smuggling. But this is not an easy question. We have
imposed a civilian blockade of the Crimea, but on what ground border guards should detain
those vessels? Even here. We have set up roadblocks illegally. Someone can speed up and ram
through them. And what do we say? There is Law No. 4032, no one has abolished it. You can
drive to the Crimea and bring, say, ice cream from Lviv. The same case is with the ports of the
Greater Odessa; there is no blockade from Ukraine, the resolution will only begin to work from
the 15th of January. Recently, one lawyer went from Mariupol, carrying six bottles of
champagne to the Crimea. I told him, “You are from Mariupol, you were attacked, shelled, and
you are carrying champagne to the Crimea”. He replied, “Yes, I am, I don’t care that they fired
Mariupol, my wife lives there”. We have a tricolour kimono hanging in here. It was Kharkiv
women who carried a whole pile of those kimonos. They are very stubborn. They just say,
“That’s how we want it”. The local councils do not stand up for the anthem of Ukraine here”.
“Okay, but how can this naval blockade be implemented?”
“If there were more patriots in Odessa, it would be possible to attack ships with small boats
when they allegedly go to Skadovsk while really carrying goods to the Crimea. Information on
their exits is available. The neutral waters are open to any ships. No fleet is entitled to operate
there. The 12-mile zone near the Crimea is also occupied, so this could be done. But we will
use this method when we have already tried all other ones. We have more interesting methods
to prevent ships from moving further”.

Exhibit AG
YouTube, ATR TV, The Civil Blockade of Crimea: How it All Started 3 Years Ago and What the
Outcome Was (21 September 2018)
(translation)

Annex 27 Exhibit AG
Translation
YouTube, ATR TV, The civil blockade of Crimea: how it all started 3 years ago and what the
outcome was (21 September 2018), available at: https://www.youtube.com/watch?v=_2J5XG_qgjs
[00:00]
[Host]: ‘Stop feeding the occupier!’ - This was the slogan with which the trade blockade of Crimea began
three years ago on 20 September 2015. It was initiated by the Mejlis. Crimean Tatar leaders decided to
stop trade with the enemy. They allowed only cars to enter the peninsula from Crimea, completely
blocking truck traffic. How did it all begin? And what were the consequences of this action? My
colleagues will tell you.
[00:28]
[Voice-over]: On 20 September 2015, at noon sharp, civic activists block 3 checkpoints into occupied
Crimea: Chongar, Kalanchak and Cheplinka. Anti-vehicle hedges and tyres are deployed at the
administrative border of mainland Ukraine in occupied Crimea. People with Ukrainian and Crimean Tatar
flags walk continuously along the pedestrian crossing. From now on, it is only possible to get in and out
of the peninsula by car or on foot. Trucks carrying goods to the peninsula queue up for kilometres. With
some drivers, emotions fly high.
[01:00]
[Driver]: Where should I go? Am I going to stick here, live here? I need to go to Genichesk. I live there.
Am I driving on my own?
[01:08]
Annex 27 Exhibit AG
[Refat Chubarov]: I don't want you to feed those bandits who kill our people. That's it! You will not feed
them.
[01:15]
[Voice-over]: Stop feeding the occupier - this is the principled position of the organizers of the blockade
of Crimea. The Mejlis of the Crimean Tatar people has stopped the supply of goods to the occupied
peninsula.
[01:23]
[Refat Chubarov]: It is unacceptable that our goods should be supporting the occupying power,
especially the military garrisons, which they have set up all over Crimea. Let them think how they are
going to bring food from mainland Russia instead of tanks.
[01:40]
[Voice-over]: Over time, the blockers were joined by the Right Sector, Azov Civil Corps activists and
hundreds of patriotically-minded people. Half a thousand activists guarded the administrative border with
Crimea every day.
[01:52]
[Evelina Arifova]: Here, if you remember all the emotions you had back then. It's unreal to describe,
because my heart was bursting out of my chest. There was such a fountain of patriotism, when you
wanted to do everything possible for Crimea. Someone showed their talents, who could cook - cooked,
who could build - built.
[02:12]
[Voice-over]: This poster contains almost the entire history of the blockade of Crimea. It was created by
Evelina Arifova, now a member of the ‘Asker’ civic formation. From the first days of blockade she was
on duty. It contains names, messages, autographs of those who together wrote the newest history of the
annexed peninsula.
[02:30]
[Lenur Islyamov]: That’s from Donbass here, it says: ‘27.09’. Here, that’s his signature. Enver’s, that is,
his name is Enver Kutia. Here, his signature; he is still here with us now. That’s Amina who is not here
anymore, she is dead now. Here, she wrote: ‘25.09.2015. Amina Tatar Bandera.’ She is, unfortunately, no
longer with us. Here we have: Azov, Right Sector. Here, Vorobey Cossack - the biggest patriot of
Ukraine. Here [unintelligible]. Before that, here, Aydar. Those are from Turkey, who came here: Rambo,
Serbes Turklesov, Lagov.
[03:08]
[Voice-over]: Lenur Islyamov, the organiser of the blockade, recalls that in those days the phone was
ringing off the hook with people wanting to help.
Annex 27 Exhibit AG
[03:15]
[Lenur Islyamov]: People called, saying: ‘Hold on!’ People called and said: ‘Come on, where can I
transfer money to?’ You have to give credit to those people who came and worked completely as
volunteers, as cooks. They helped, washed, cleaned and served. It was very hard work! Doctors came.
Doctors who stayed with us. The only thing we didn’t have was childbirth. But there were even weddings.
Really, energy was everywhere. People were all on fire.
[03:41]
[Voice-over]: However, not everyone was so enthusiastic. Ukrainian business at the time, which had close
relations with the already annexed Crimea, was in no way willing to lose billions of dollars in revenue. So
threats to the organizers of the blockade were pouring in every day.
[03:56]
[Lenur Islyamov]: They pushed business cards of some secret service officers in our hands in the vans:
‘Here, please, we are from that man.’ Yanukovych was no longer there, but business was still operating
by those laws. I grew up in that time, I was setting up my business in the time of banditry. That is why,
when people threaten me, I'm not afraid of such people. It is much more difficult with people who quietly
do their business.
[04:18]
[Voice-over]: The leader of the Crimean Tatar people, Mustafa Dzhemilev. Then in 2015 he was at the
forefront of the blockade of Crimea.
[04:26]
[Mustafa Dzhemilev]: In the history of world wars, it had never happened that a partially occupied
country continued to supply the occupier with everything it needed. That happened here because many
people did not give a fig about the territorial integrity of their country, about the dignity of the country.
The main thing for them was to make money.
[04:44]
[Voice-over]: Empty shelves in shops, rising prices on markets - Ukrainian goods stopped coming to
Crimea. Two weeks after the blockade began, high-voltage lines supplying electricity to the peninsula
began to fall down. On 22 November, unknown persons damaged the last tower. The next day, the
occupation authorities declared a state of emergency in Crimea. The lights went out, mobile phone service
was cut off, and people did not go to work. Recalling that time, Mustafa Dzhemilev says that the blockade
was the only right answer to the challenges of reality. Crimea returned to the global political agenda, and
the Cabinet of Ministers officially banned the movement of cargo vehicles across the administrative
border after an appeal by the president. Sanctions against Russia for the annexation of the peninsula,
including trade sanctions, were imposed by almost all EU countries and the US.
[04:26]
Annex 27 Exhibit AG
[Mustafa Dzhemilev]: They talked about the blockade, but at the same time they talked about how it had
happened – the occupation of Crimea. Thousands and tens of thousands of publications all over the world.
This is the subject that was understood in Crimea. And the main point of our strategy, as long as we do
not contemplate military liberation of Crimea, is to make the maintenance of the occupied territory of
Crimea as expensive as possible for Russia. And we have achieved that goal too.
[06:15]
[Voice-over]: On 31 December, activists removed all roadblocks at checkpoints with occupied Crimea. In
another year, the trade blockade of Crimea will be hailed in Ukraine and around the world as the first
most effective step to begin de-occupation. But there are many more steps ahead. The main one is
granting autonomy to Crimean Tatars.
[06:36]
[Lenur Islyamov]: The pace we maintained since the blockade, we must keep it up. The ATR TV channel
that airs news every day. It is like an information bomb that flies out of the mainland and hits right on
target because we are telling the truth about what is happening in Crimea. It is not highly visible and
doesn’t bring in cash, but it is very important politically for those people who are now in this hostage
situation in Crimea.
Exhibit AH
Federal State Statistics Service, RESULTS OF THE POPULATION CENSUS IN THE CRIMEAN FEDERAL
DISTRICT (Russian Institute of Statistics, 2015)
(excerpt, translation)

Annex 27 Exhibit AH
Excerpt
Translation
Federal State Statistics Service, RESULTS OF THE POPULATION CENSUS IN THE CRIMEAN
FEDERAL DISTRICT (Russian Institute of Statistics, 2015), available at:
https://rosstat.gov.ru/storage/mediabank/KRUM_2015.pdf.
FEDERAL STATE STATISTICS SERVICE
RESULTS OF
THE POPULATION
CENSUS
IN THE CRIMEAN
FEDERAL
DISTRICT
__________________
OFFICIAL PUBLICATION
Information-publishing centre "STATISTICS OF RUSSIA»
MOSCOW
2015
Annex 27 Exhibit AH
UDC 60.721.13
BBC 314.02
I93
Editorial board
A. Surinov - Chairman of the Editorial Board
M. Dianov - Deputy Chairman of the Editorial Board
V. Arkhangelskiy, A. Bazarov, V. Blinchuk, V. Voronin, M. Denisenko, V. Yelizarov, L.
Eroshina, A. Zhuravskiy, V. Zorin, A. Zotova, N. Konovka, G. Kulyaeva, O. Manzhula, V.
Nesterov, S. Nikitina, G. Rivina, V. Stepanov, E. Strakhova, E. Frolova, O. Chudinovskikh,
G. Sheverdova, G. Scherbakova
Results of the population census in the Crimean Federal District / Federal Service of State
Statistics. - Moscow: Russian Statistics Information Centre, 2015. - 279 p.
ISBN 978-5-4269-0054-7
This is the official publication of the results of the federal statistical observation
"Population Census in the Crimean Federal District" with 100 percent coverage of the
population.
The publication contains information on the results of the census in the Crimean Federal
District on the size and location of the population, age and sex composition and marriage
status, fertility, number and composition of households, nationality, native language,
language proficiency, citizenship, educational level, sources of livelihood, economic activity
(employment and unemployment), length of residence of the population in the place of
permanent residence, as well as housing conditions of the population. The data for the
Crimean Federal District is presented in comparison with similar data from the All-Russian
Population Census 2010 and supplemented by graphical, tabular and cartographic material.
For each topic there are tables with characteristics of population, households and dwellings
for the Crimean Federal District, the Republic of Crimea and Sevastopol, as well as the
urban districts and municipal areas included in them.
UDC 60.721.13
BBC 314.02
Annex 27 Exhibit AH
ISBN 978-5-4269-0054-7 © Federal State
Statistics Service, 2015
E-mail: [email protected]
http://www.gks.ru
[…]
Urban settlements are home to 86% to 88% of Karaites and Krymchaks, 62% to 64% of
Bulgarians and Armenians, Russians, 52% to 54% of Germans and Greeks. There is an
equal proportion of urban and rural inhabitants among Ukrainians. A high proportion of the
population living in rural areas is found among Crimean Tatars (74%) and Tatars (66%).
[…]

Exhibit AI
State Council of the Republic of Crimea, Edip Gafarov
(translation)

Annex 27 Exhibit AH
Translation
State Council of the Republic of Crimea, Edip Gafarov, available at:
http://crimea.gov.ru/deputy/285.
Edip GAFAROV
Mr. Gafarov was elected in the republican electoral district as a member of
the Crimean regional branch of the All-Russia Political Party “United
Russia”.
He is Deputy Chairman of the State Council of the Republic of Crimea and
member of the faction of “United Russia” in the State Council of the Republic
of Crimea.
Biographical Note
Deputy Chairman of the State Council of the Republic of Crimea, member of the All-Russia
Political Party “United Russia”.
Mr. Gafarov was born on the 9th of May 1952 in the village of Aktash, Narpai District of the
Samarkand Region, Uzbek SSR. He has a higher education and graduated from the Samarkand
State Architecture & Construction Institute in 1982 with a major in Industrial and Civil
Engineering.
In 2004, he graduated from the Kharkov Regional Institute of Public Administration at the
National Academy of Public Administration under the President of Ukraine as a Master of Public
Administration.
From 1970 to 1972, Mr. Gafarov served in the Group of Soviet Forces in the German
Democratic Republic. He started his career in 1974 at the Samarkand Regional Department of
Property Inventory and Registration Authority. During his employment there, he worked his way
up from a technician to deputy head of the regional Property Inventory and Registration
Authority. In 1991-1994, he worked as the director of a construction materials plant. From July
1994 to January 1999, he was a deputy manager, and then a manager of a construction group. In
1999, he became Deputy Chairman of the Republican Committee of the Autonomous Republic
of Crimea on Nationalities and Deported Citizens. From December 1999 to June 2000, he was
Acting Chairman of the Republican Committee of the Autonomous Republic of Crimea on
Nationalities and Deported Citizens. From June 2000 to May 2002, he was Chairman of the
Republican Committee of the Autonomous Republic of Crimea on Nationalities and Deported
Citizens. From May 2002 to May 2005, he was Deputy Chairman of the Council of Ministers of
the Autonomous Republic of Crimea. From July 2008 to April 2014, he was First Deputy
Chairman of the Republican Committee of the Autonomous Republic of Crimea for Water
Management Construction Projects and Irrigated Agriculture. On 4 April 2014, he was appointed
Chairman of the Permanent Commission of the State Council of the Republic of Crimea on
Interethnic Relations and Problems of Deported Citizens. From September 2014 to August 2018,
he was Chairman of the Committee of the State Council of the Republic of Crimea on Interethnic
Relations. From August 2018 to September 2019, he was Deputy Chairman of the State Council
of the Republic of Crimea. Since September 2019, he is Deputy Chairman of the State Council
of the Republic of Crimea.
Annex 27 Exhibit AH
Mr. Gafarov is married with two children.
He has got the following awards:
2001 – “Honoured Construction Worker of the Autonomous Republic of Crimea”;
2004 – Certificate of Honour from the Cabinet of Ministers of Ukraine;
2015 – Fidelity to Duty Order.
Mr. Gafarov was a member of the Verkhovnaya Rada of the Autonomous Republic of Crimea of
the 2002-2006 convocation and a member of the 6th convocation of the State Council of the
Republic of Crimea in 2010-2014 (the Supreme Council of the Autonomous Republic of
Crimea).
From September 2014 to September 2019, he was a member of the 1st convocation of the State
Council of the Republic of Crimea.
From September 2019, he is a member of the 2nd convocation of the State Council of the
Republic of Crimea.
Exhibit AJ
State Council of the Republic of Crimea, Chinghiz Yakubov
(translation)

Annex 27 Exhibit AJ
Translation
State Council of the Republic of Crimea, Chinghiz Yakubov, available at:
http://crimea.gov.ru/deputy/394.
Chinghiz Fevzievich YAKUBOV
Mr. Yakubov was elected in the republican electoral district as a member of
the Crimean regional branch of the All-Russia Political Party “United
Russia”.
He is a Rector of the Crimean Engineering and Pedagogical University, a
state-funded institution of higher education of the Republic of Crimea, and a
member of the faction of “United Russia”.
Mr. Yakubov is a member of the following committees of the State Council of the Republic of
Crimea
• Committee on Culture and Cultural Heritage Protection Issues
office 438, phone 544-125, 27-40-34, e-mail: [email protected], for public
contacts: [email protected] (Committee member)
• Committee on People's Diplomacy and Interethnic Relations
office 517, phone 544-141, e-mail: [email protected], for public contacts: pismagrazhdan@
crimea.gov.ru (Committee member)
• Committee on Education, Science and Youth Policy
office 453, phone 544-155, e-mail: [email protected], for public contacts: pismagrazhdan@
crimea.gov.ru (Committee member)
• Committee for Patriotic Education and Veterans Affairs
office 320, e-mail: [email protected], for public contacts: pismagrazhdan@
crimea.gov.ru (Committee member)
Biographical Note
Mr. Yakubov was born on the 5th of May 1972 in Tashkent, Sabir Rakhimov District, Uzbek
SSR.
He has a higher education and graduated from the Tashkent State Technical University in 1994.
From January 1996 to November 1998, Mr. Yakubov was a lecturer at the Department of
General Technical Disciplines of the Crimean Industrial and Pedagogical Institute. From
November 1998 to November 2001, he completed postgraduate studies at the Kharkov
Polytechnic Institute (a national technical university) as part of off-the-job training. From
November 2001 to September 2005, he was a lecturer at the Department of Mechanical
Engineering Technology of the Crimean Engineering and Pedagogical University (hereinafter,
CE&PU). From September 2005 to September 2006, he was a senior lecturer at the Department
of Mechanical Engineering Technology of CE&PU. From September 2006 to September 2009,
he was an Associate Professor at the Department of Mechanical Engineering Technology of
Annex 27 Exhibit AJ
CE&PU. From September 2009 to November 2009, he was an Associate Professor at the
Department of Integrated Mechanical Engineering Technologies of the Kharkov Polytechnic
Institute. From November 2009 to November 2012, he studied for a doctorate degree at the
Kharkov Polytechnic Institute as part of on-the-job training. From September to December 2012,
he was a part-time Associate Professor at the Department of Mechanical Engineering
Technology of CE&PU. From December 2012 to June 2014, he was a full-time Associate
Professor at the Department of Mechanical Engineering Technology of CE&PU. From June
2014 to November 2016, he was Head of the Department of Mechanical Engineering
Technology of CE&PU. From November 2016 to date, he is the Rector of the Crimean
Engineering and Pedagogical University, a state-funded institution of higher education of the
Republic of Crimea
Mr. Yakubov is married with four children.
He has got the following awards:
2018 – Certificate of Honour from the Ministry of Education, Science and Youth of the Republic
of Crimea; 2018 – Honoured Worker of Science and Technology of the Republic of Crimea;
2022 – Diploma of the Presidium of the State Council of the Republic of Crimea.
From September 2019, Mr. Yakubov is a member of the 2nd convocation State Council of the
Republic of Crimea.
Communication with constituents
Information on handling public appeals
Reception schedule
Feedback from constituency
Information on income, expenses, assets and property liabilities
Exhibit AK
Milli Firka, Mejlis wants Mogilev's resignation (7 May 2013)
(translation)

Annex 27 Exhibit AK
Translation
Milli Firka, Mejlis wants Mogilev's resignation (7 May 2013), available at: http://millifirka.
org/меджлисмены-хотят-отставки-могилева//.
Mejlis wants Mogilev's resignation
07.05.2013
Mejlis wants Mogilev's resignation
A briefing for journalists was held in Simferopol on 4 May 2013 following a closed meeting
between members of the Mejlis and representatives of Crimean Tatar organizations and
associations from Turkey and several other countries.
The briefing, along with Mustafa Dzhemilev, head of the Mejlis, was attended by Chairman of
the Istanbul branch of the Society of Culture and Mutual Assistance of Crimean Tatars in Turkey
Dzhelyal Içten, Mejlis representative in Turkey Zafer Karatay, Head of Crimean Tatar Culture
and Mutual Assistance Society of Eskisehir Mesut Or and representative of Crimean Tatar
Culture and Mutual Assistance Society of Kocaeli (Turkey) Zumran Araci. This was reported by
the website of the Milli Mejlis.
The head of the Mejlis revealed the theses of the draft resolution, which Mejlis intends to
announce at its rally on 18 May, on the Crimean Tatar People's Day of Mourning. One of the
main points of the resolution will be a demand for the resignation of the current Crimean prime
minister, Anatoliy Mogilev, as well as a demand for the Ukrainian authorities to recognise the
Mejlis as a representative body of the people.
"Now Ukraine does not recognise the Qurultay as a body elected by the people and gives full
power to the 'Council of Representatives'," the Mejlis head complained to the authorities.
М. Dzhemilyev also said that the Mejlis has always been and remains the defender of Ukraine's
independence and territorial integrity and its integration into the European and Euro-Atlantic
community.
According to him, the unprecedented pressure, rejection and desire to destroy the Mejlis is the
machinations of certain chauvinist forces of the modern Ukrainian authorities.
"All responsibility for this criminal policy and possible complications lies precisely with these
forces in Ukraine, led by Crimean Prime Minister A. Mogilev," the Mejlis leader pronounced his
verdict on the Ukrainian authorities.

Exhibit AL
RIA Novosti, The 75th Anniversary of the Deportation of Peoples from Crimea: Remembrance
Events at the Syuren Memorial (18 May 2019)
(translation)

Annex 27 Exhibit AL
Translation
RIA Novosti, The 75th Anniversary of the Deportation of Peoples from Crimea:
Remembrance Events at the Syuren Memorial (18 May 2019), available at:
https://crimea.ria.ru/20190518/1116661184.html.
Commemorative events dedicated to the Day of Remembrance of the Victims of the Deportation
of Ethnic Groups from Crimea are being held in the Republic. The main event took place at the
site of the Syuren Memorial Complex which is currently under construction in the Bakhchysarai
District. It was attended by Sergey Aksenov, Head of the Republic of Crimea, Efim Fiks, First
Vice Speaker of the Parliament of the Republic of Crimea, Ruslan Balbek, a member of the State
Duma, Metropolitan Lazarus of Simferopol and Crimea, Mufti Emirali Ablaev of Crimea,
members of the Crimean Parliament, and members of the Council of Ministers of the Republic of
Crimea.

Exhibit AM
Crimean Tatar Museum of Cultural and Historical Heritage, Events in Memory of Victims of
Deportation of Peoples from Crimea Held at Syuren Station (18 May 2022)
(translation)

Annex 27 Exhibit AM
Translation
Crimean Tatar Museum of Cultural and Historical Heritage, Events in Memory of Victims
of Deportation of Peoples from Crimea Held at Syuren Station (18 May 2022), available at:
https://krtmuseum.ru/18-maya-den-pamyati-zhertv-deportatsii-narodov-kryma/.
Founded by the Ministry of Culture of the Republic of Crimea
Events in Memory of Victims of Deportation of Peoples from Crimea Held at Syuren
Station
On the 18th of May, the Crimean Tatar Museum of Cultural and Historical Heritage held a poster
exhibition at the site of the Syuren Memorial Complex in the Bakhchysarai District named
“Forever in People’s Memory” and dedicated to the memorable events of the 18th of May 1944,
to life in exile settlements, to repatriation of the people to Crimea, and to the restitution of the
deported peoples’ rights after Vladimir Putin, President of the Russian Federation, signed the
Decree “On Measures for the Rehabilitation of the Armenian, Bulgarian, Greek, Crimean Tatar
and German Peoples and on State Support of Their Revival and Development” on the 21st of
April 2014, as part of the commemorative events dedicated to the 75th anniversary of the
deportation of peoples from Crimea.
A requiem concert dedicated to the 75th anniversary of the deportation of peoples from Crimea
was also given at the Syuren Memorial Complex.
Words of sympathy for the deported peoples were offered by Sergey Valerievich Aksenov, Head
of the Republic of Crimea, Efim Zisievich Fiks, First Deputy Chairman of the State Council of
Annex 27 Exhibit AM
the Republic of Crimea, Chairman of the Committee for Nation-Building and Self-Governments
at the State Council of the Republic of Crimea, and by Metropolitan Lazarus of Simferopol and
Crimea.
Haji Emirali Ablaev, Mufti of Muslims of Crimea, recited a dua (prayer) in memory of the
victims.
Annex 28
Witness Statement of , 7 March 2023
(translation)

Annex 28
INTERNATIONAL COURT OF JUSTICE
APPLICATION OF THE INTERNATIONAL CONVENTION
FOR THE SUPPRESSION OF THE FINANCING OF TERRORISM AND
INTERNATIONAL CONVENTION ON THE ELIMINATION OF
ALL FORMS OF RACIAL DISCRIMINATION
(UKRAINE V. RUSSIAN FEDERATION)
WITNESS STATEMENT OF
7 MARCH 2023
Annex 28
Page 2 out of 7
Annex 28
Page 3 out of 7
1. I, , declare the following:
2. I
.
3. I have been asked to give a witness statement in the dispute on racial discrimination before
the International Court of Justice. In this witness statement, I describe the development
of the song and dance culture of the Crimean Tatar people in Crimea and, in particular,
the role played by the Haytarma ensemble. I also describe the activities of this group
related to the Ukrainian culture. My witness statement is based on my personal knowledge
and experience accumulated during more than twenty years of my creative work in
Crimea, as well as memories of the people I know.
4. I received my artistic education
.
5. Since then my creative work has been inextricably associated with Crimea
6. The Haytarma ensemble became part of the Crimean Philharmonic in 1992, but its history
began much earlier, in 1939. During the years of deportation, it was revived in Uzbekistan
in 1957 and remained one of the few surviving centers of Crimean Tatar culture.
7. Despite the importance of the Crimean Philharmonic and its member ensembles for the
culture of Crimea, we had to live through some difficult times before 2014. The money
allocated from the state budget of Ukraine was barely enough for salaries, and even those
were cut in half in 2010. As far as I know, the Haytarma ensemble had a particularly hard
time: they experienced difficulties with going on tours at the proper level; there was not
enough money for costumes and makeup, equipment and machinery.
Annex 28
Page 4 out of 7
8. In 2016 , those problems,
fortunately, were already in the past thanks to additional government funding, which did
not exist before 2014. At the moment Ensemble is fully supported by the Ministry of
Culture of the Republic of Crimea and has the opportunity to develop its full potential.
For example, more than 200 million roubles are allocated from budgetary funds in favour
of the Crimean State Philharmonic,1 and in total, more than 1.1 billion roubles were
allocated to the Philharmonic from 2017 to 2022.2 In comparison, in 2013 Ukraine set a
maximum limit of budgetary subsidies limit for philharmonics at just over 16 million
gryvnas, which was about 60 million roubles at the then exchange rate.3
The Haitarma ensemble performs in 2018
9. perform a lot in different Russian cities, we
introduce our culture to other regions: from Rostov-on-Don and Krasnodar Kray to
1 Ministry of Culture of the Republic of Crimea, Budget Expenditure Report 2022, 13 October 2015, available at:
https://mkult.rk.gov.ru/uploads/txteditor/mkult/attachments//d4/1d/8c/d98f00b204e9800998ecf8427e/phpmoz7U
i_25.pdf (Exhibit A).
2 Crimea-news.com, Crimea Government Holds Meeting on Crimean State Philharmonic Society Issues (20
September 2022), available at: https://crimea-news.com/culture/2022/09/20/968984 html (Exhibit B).
3 Verkhovnaya Rada of the Autonomous Republic of Crimea, Decree “On the Budget of the Autonomous Republic
of Crimea for 2013” No. 1075-6/12, 26 December 2012, available at:
https://ips.ligazakon net/document/view/km120459?an=1&ed=2013_12_25 (Exhibit C)
Annex 28
Page 5 out of 7
Khabarovsk and Vladivostok. We were even invited to the Nicaraguan Embassy in
Moscow!
10. We also often tour abroad: we visited Serbia in 2016, Vietnam in 2017 and Armenia in
2021 and 2022. Our most memorable tours were to Turkey in 2018 and 2019, where we
performed at the Crimean Tatar Culture Days; after all, the largest diaspora of Crimean
Tatars lives in Turkey.
11. We now have the opportunity to make professional videos of our performances so that
they can get more people interested in our culture.
A music video of the Haytarma ensemble with the song “Mashalla”. The video is available at:
https://www.youtube.com/watch?v=pA34BIw_9lc
12. It is noteworthy that our repertoire includes not only Crimean Tatar songs and dances –
we also perform Georgian, Armenian, Gypsy, Russian and Ukrainian dances and songs
in different languages; I myself sing in more than 15 languages.
13. Our Ukrainian show acts are also popular: the gopak dance and the Chornobrivtsy song.
Annex 28
Page 6 out of 7
The Haytarma ensemble performs gopak. The video is available at:
https://www.youtube.com/watch?v=ktT9e-gEkEQ
14. But the heart of the ensemble is always the Crimean Tatar culture. We have complete
control over our repertoire.
15. We have put on many new concert programmes in recent years. Many of them are
designed to tell the audience about the history of Crimean Tatars, to show them the
ancient traditions of our song and dance.
16. The concert programme “Vatan Sedasi” (Echoes of the Motherland), for example, is
dedicated specifically to that theme. The theatralized musical programme “Bakhchisaray
– Khansaray” is inspired by the Khan’s Palace: in it we try to recreate the spirit of the
Khan’s dynasty times. The Khansaray chechekleri (Dreams of the Rose Garden)
programme is based on the poetry of the Crimean Tatar Khans of the 14th century. The
“Khatyra” (Memory) programme talks about the difficult pages of our history: it is
dedicated to the victims of the deportation.
17. At the same time, we also have “modernized” performances to interest young people in
our culture. For example, the “Altyn Beshik” (Golden Cradle) programme is based on
ancient Crimean legends, but in addition to classical Crimean Tatar dances, there are also
show acts with elements of modern dance and dancing en pointe.
Annex 28
Page 7 out of 7
18. We also have musical productions based on famous fairy tales to appeal to the youngest
audiences.
19. Thus, the Crimean Tatar culture is actively developing in Crimea, and specifically thanks
state support for our Ensemble.
20. As a Crimean Tatar woman and of the Crimean Tatar Ensemble, I do not feel
any discrimination against me.
21. I hereby confirm that, to the best of my knowledge and beliefs, the information set out in
this witness statement is correct.
Witness
[SIGNATURE]
Simferopol, 7 March 2023
Annex 28
Annex 28
LIST OF EXHIBITS
Number: Name of exhibit:
Exhibit A Ministry of Culture of the Republic of Crimea, Budget Expenditure Report
2022, 13 October 2015.
Exhibit B Crimea-news.com, Crimea Government Holds Meeting on Crimean State
Philharmonic Society Issues (20 September 2022).
Exhibit C Verkhovnaya Rada of the Autonomous Republic of Crimea, Decree “On
the Budget of the Autonomous Republic of Crimea for 2013” No. 1075-
6/12, 26 December 2012.

Exhibit A
Ministry of Culture of the Republic of Crimea, Budget Expenditure Report 2022,
13 October 2015
(translation)

Annex 28 Exhibit A
heating 480 938,02 480 938,02 100,0
property rental charge 224 0,00 0,00
work, property maintenance
services
225
other work, services 226 8 346 421,53 3 346 421,53 40,1
Insurance 227 1 962,12 1 962,12 100,0
Services, work for capital
investment purposes
228
Other expenses (taxes, fines,
penalties, etc.)
290
Increase in value of fixed
assets
310 16 610 396,00 16 610 396,00 100,0
Increase in value of intangible
assets
320
Increase in value of tangible
assets
340 693 904,00 693 904,00 100,0
TOTAL EXPENSES x 206 265 878,90 201 265 878,89 97,6
Deputy Director
General [signature] P. Paramonova
Chief accountant [signature] A. Bocharova
Exhibit B
Crimea-news.com, Crimea Government Holds Meeting on Crimean State Philharmonic Society
Issues (20 September 2022)
(translation)

Annex 28 Exhibit B
Translation
Crimea-news.com, Crimea Government Holds Meeting on Crimean State Philharmonic
Society Issues (20 September 2022), available at: https://crimeanews.
com/culture/2022/09/20/968984.html.
Crimea Government Holds Meeting on Crimean State Philharmonic
Society Issues
A meeting on the activities of the Crimean State Philharmonic Society was held in Simferopol under the
leadership of the Deputy Chairman of the Council of Ministers of the Republic of Crimea Mikhail
Nazarov.
The meeting was attended by Crimean Minister of Culture Tatiana Manezhina, deputy ministers Andrey
Tereshchenko, Lilia Memetova, Natalia Pisareva, chairman of the supervisory board of the Crimean State
Philharmonic Society, general director of the joint-stock company “Fiolent Plant” Alexander Batalin,
general director of the Crimean State Philharmonic Society Tamara Aronova and her deputies, artists,
staff, and heads of philharmonic arts groups.
The event summed up the results of the Crimean Philharmonic Society's activities in the previous periods,
and also discussed possible solutions to problems. In particular, the meeting considered aspects of
fulfilling the state assignment and achieving targets thereof, as well as financing, organisation of the
rehearsal process, tours and concert programmes.
Tatyana Manezhina noted that the Head of the Republic of Crimea and the leadership of the Council of
Ministers of the Republic highly appreciated the success of artists and groups of the Philharmonic
Society, were aware of the current difficulties of the Society and many years of inadequate material
support of the institution. The activities of the Philharmonic Society in the Crimea are important and
visible (over the past five years, the Society received 66 awards of the Council of Ministers and the State
Council of the Republic of Crimea of different value, besides agency-level awards).
Between 2017 and 2022, RUB 1,155 mln was allocated to the Philharmonic Society from the Crimean
budget, including RUB 28.8 mln to strengthen its material and technical base (purchase of stage costumes
and shoeware, musical instruments and equipment, including as part of anti-terrorist measures).
The Ministry has taken all necessary measures to provide the Philharmonic staff with workplaces in other
organizations in connection with the start of the long-awaited renovation of the Philharmonic Society
building on Pushkin Street in Simferopol.
At present, the Ministry has submitted proposals for the draft Republican Targeted Investment
Programme and Capital Repair Plan for repair and restoration works in 2023-2025 (cost RUB 77.7 mln)
on the L.F. Schlee House in Simferopol, which is the base of the L.D. Chernysheva Vocal and
Choreographic Ensemble “Tavria”.
As part of the Republic of Crimea Capital Repair Plan, the Ministry has organised work to develop
scientific and design documentation for the Pushkin Theatre building in Yevpatoria at a cost of RUB 17.8
mln.
As a result of the meeting, instructions were given to Tamara Aronova, General Director of the State
Philharmonic Society, to work out further ways of solving the pressing problems. All questions
concerning the Philharmonic Society activities and employee appeals are under control of the Ministry of
Culture of the Republic of Crimea.

Exhibit C
Verkhovnaya Rada of the Autonomous Republic of Crimea, Decree “On the Budget of the
Autonomous Republic of Crimea for 2013” No. 1075-6/12, 26 December 2012
(excerpt, translation)

Annex 28 Exhibit C
Excerpt
Translation
Verkhovnaya Rada of the Autonomous Republic of Crimea, Decree “On the Budget of the
Autonomous Republic of Crimea for 2013” No. 1075-6/12, 26 December 2012, available at:
https://ips.ligazakon.net/document/view/km120459?an=1&ed=2013_12_25.
VERKHOVNAYA RADA OF THE AUTONOMOUS REPUBLIC OF CRIMEA
DECREE
On the budget of the Autonomous Republic of Crimea for 2013
As amended and supplemented by the Decrees of the Verkhovnaya Rada of the
Autonomous Republic of Crimea
of 20 February 2013 No. 1138-6/13,
of 27 March 2013 No. 1183-6/13,
of 17 April 2013 No. 1230-6/13,
of 22 May 2013 No. 1266-6/13,
of 21 June 2013 No. 1310-6/13,
of 7 August 2013 No. 1346-6/13,
of 18 September 2013 No. 1390-6/13,
of 18 October 2013 No. 1441-6/13,
of 27 November 2013 N No. 1482-6/13,
of 25 June 2013 No. 1535-6/13
The Verkhovnaya Rada of the Autonomous Republic of Crimea decides:
[…]
"3.2 Establish for 2013 the procedure for determining the budgetary allocation limit for
theatre, entertainment and concert organisations in the following amounts:
Types of organisations
Subsidy from the budget
of the Autonomous
Republic of Crimea
(thous. grivnas)
Planned own revenues
from self-supporting
activities (thous. grivnas)
Amounts subsidised in
case of failure to fulfil the
plan for income from
self-supporting activities
(thous. grivnas)
Theatres 35876,7 7617,4 25113,7
Philharmonic and
concert organisations
16383,2 2095,0 11468,2

Annex 29
Witness Statement of , 7 March 2023
(translation)

Annex 29
INTERNATIONAL COURT OF JUSTICE
APPLICATION OF THE INTERNATIONAL CONVENTION
FOR THE SUPPRESSION OF THE FINANCING OF TERRORISM AND
INTERNATIONAL CONVENTION ON THE ELIMINATION OF
ALL FORMS OF RACIAL DISCRIMINATION
(UKRAINE V. RUSSIAN FEDERATION)
WITNESS STATEMENT
OF
7 MARCH 2023
Annex 29
Page 2 of 10
Annex 29
Page 3 of 10
1. I,
(hereinafter,
“Museum”) and
declare the following:
2. I am providing this witness statement on issues raised in the resolution of dispute initiated
by Ukraine before the International Court of Justice. In my statement, I will describe the
activities of our museum, its importance for the preservation of the culture of the Crimean
Tatar people, and the current condition of the Museum.
3. My witness statement is based on my personal knowledge, which I possess by virtue of
my position .
4. The Museum is a complex structure. It consists of several departments: in addition to the
funds department, research and display work department and cultural-educational and
exhibition work department located in Simferopol, the structure of the Museum also
includes
.
5. Below are photos of the memorial complex, which commemorates the victims of the main
tragedy in the history of the Crimean Tatar people – the Deportation in 1944. This place
is especially significant because it was from the railway station “Siren” that the trains
with the deportees departed. Now mourning events are held here every year. The complex
was built after 2016 thanks to the Russian authorities, who fully financed its creation,
investing hundreds of millions of roubles,1 and are now allocating 9 million roubles for
its maintenance.
1 Regnum.ru, The date of completion of the construction of the memorial to the victims of deportation was
announced in Crimea (20 April 2021), available at: https://regnum ru/news/3248235 html (Exhibit A); Argumenty
Nedely, The cost of building a memorial in Crimea to the victims of the deportation has risen again by 300m
roubles (30 November 2020), available at: https://argumenti ru/society/2020/11/699760 (Exhibit B); RIA Novosti,
Aksyonov talks about what Crimea is doing for returnees (18 May 2019), available at:
https://ria.ru/20190518/1553600929 html (Exhibit C).
Annex 29
Page 4 of 10
Annex 29
Page 5 of 10
6. The main purpose of the Museum, established in 1992, was to collect the material
fragments of Crimean Tatar culture that survived despite the deportation. At present, we
have about 15,000 items of crucial historical and artistic importance for the Crimean Tatar
people in our collection, but we do not intend to remain complacent from now on, and
will further increase and grow it. We move forward with our activities thanks to the full
support of the state and, first and foremost, the Ministry of Culture of the Republic of
Crimea.
7. The most active visitors of the Museum are tourists and travelers from other regions. This
gives hope that Crimean Tatar culture will become better known outside Crimea, but we
also try to motivate the Crimean population to visit us more often. We organise master
classes in folk crafts, seminars and conferences. For example, on 26 January 2023, with
the support of the Ministry of Culture of the Republic of Crimea, the Museum hosted the
presentation of the first-ever etymological dictionary of the Crimean Tatar language,
prepared by Enver Kurtumerov, a lecturer of the Crimean State University n.a.
Vernadsky. On 4 November 2022, the Museum joined the “Night of Arts-2022” all-
Russian event and arranged a number of events for its visitors: a concert of the traditional
Crimean Tatar music, a master class on Crimean Tatar tailoring, a literary evening and a
concert at the Amet-Khan Sultan Museum in Alupka. The Museum of History and
Annex 29
Page 6 of 10
Archaeology in Stary Krym hosted historical expositions dedicated to the ancient
Crimean city of Solkhat, master classes on Crimean Tatar tailoring and beadwork, as well
as clay molding of ceramics with folk Crimean Tatar ornaments. Below I am posting
photos from these events.
Presentation of dictionary prepared by Enver Kurtumerov
Annex 29
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Annex 29
Page 8 of 10
Events at ‘Night of Arts-2022’
Annex 29
Page 9 of 10
Exposition dedicated to the ancient Crimean city of Solkhat at the Museum of History
and Archaeology
8. We also actively establish links with other museums. Specifically, in 2018 the Council of
Ministers of the Republic of Crimea signed an interregional agreement with the
government of St. Petersburg. On the basis of that agreement, we were able to work with
the Russian Museum of Ethnography. In the same year, we managed to jointly organise
an exhibition in our Museum dedicated to Crimean Tatar embroidery of the beginning of
the last century and photos documenting the life of Crimean Tatars during that period.
The items for this exhibition were taken from the collections of the Russian Museum of
Ethnography.
9. We also hope that the popularity of our Museum will grow as a result of joining the
Pushkin Card Programme. This project allows young people aged 14 to 22 to visit
museums, exhibitions and theatres at federal expense. We are sure it will help us to pass
on our historical and cultural heritage to a new generation.
10. Thus, in my opinion, based on personal experience, Crimean Tatar culture, history and
language are developing in Crimea thanks to state support and the activities of the Council
of Crimean Tatars and other Crimean Tatar communities. Since 2014, much has been
done for Crimean Tatar culture and history, and a large number of projects have been
planned to promote Crimean Tatar culture.
Annex 29
Page 10 of 10
11. My Crimean Tatar colleagues and I, as
and a Crimean Tatar woman, do not feel any political,
cultural, linguistic pressure or discrimination in Crimea.
12. I hereby confirm that, to the best of my knowledge and beliefs, the information set out in
this witness statement is true.
Witness
[SIGNATURE]
Simferopol, 7 March 2023
Annex 29
LIST OF EXHIBITS
Number: Name of exhibit:
Exhibit A Regnum.ru, The date of completion of the construction of the memorial to
the victims of deportation was announced in Crimea (20 April 2021).
Exhibit B Argumenty Nedely, The cost of building a memorial in Crimea to the
victims of the deportation has risen again by 300m roubles (30 November
2020).
Exhibit C RIA Novosti, Aksyonov talks about what Crimea is doing for returnees (18
May 2019).

Exhibit A
Regnum.ru, The date of completion of the construction of the memorial to the victims of
deportation was announced in Crimea (20 April 2021)
(translation)

Annex 29 Exhibit A
Translation
Regnum.ru, The date of completion of the construction of the memorial to the victims of
deportation was announced in Crimea (20 April 2021), available at:
https://regnum.ru/news/3248235.html.
The date of completion of the construction of the memorial
to the victims of deportation was announced in Crimea
SIMFEROPOL, 20 April 2021, 17:44 - REGNUM The construction of the
Memorial to the victims of deportation near the Siren Station in the Bakhchisaray District of the
Republic of Crimea is 85 percent complete. This was reported by the regional government's press
service on 20 April.
“To date, the work is progressing vigorously. We plan to have the main work completed by
May 18, and then only the interior work will continue. The construction of the facility is
budgeted at 286.5 million rubles, and work has already been carried out for 126 million.
The arrangement of the museum complex is underway, monuments have been erected,
works are being carried out in the mosque and the church, and some greenery has been
planted. As for the money, 65% of the funds have been used, and 85% of the construction
work is complete. It is planned that the object will be put into operation by December 1 of
this year”, - Chairman of the State Committee on Interethnic Relations of the Republic of
Crimea Ayder Tippa said.
Mourning events are planned for 18 May on Crimean Tatar Deportation Remembrance Day at
the memorial complex.
As REGNUM news agency reported, a memorial capsule was laid at the site of the memorial in
2015. The first phase of the memorial was handed over by 18 May 2016. The entire complex was
scheduled to be completed by 18 May 2019, but it was then postponed until May 2020, but even
then the memorial was not ready. In February 2020, it was revealed that the contractor,
StroyComTech Ltd, had blown the construction deadline, the contract with it was terminated and
a new contractor was chosen

Exhibit B
Argumenty Nedely, The cost of building a memorial in Crimea to the victims of the deportation
has risen again by 300m roubles (30 November 2020)
(translation)

Annex 29 Exhibit B
Translation
Argumenty Nedely, The cost of building a memorial in Crimea to the victims of the deportation
has risen again by 300m roubles (30 November 2020), available at:
https://argumenti.ru/society/2020/11/699760.
The cost of building a memorial in Crimea to the victims of the
deportation has risen again by 300m roubles
30 November 2020, 14:38 Source: Argumenty Nedely Krym
The cost of construction of the facility, which started in 2016, was 340 million rbl. Almost
300 was planned for 2021.
The construction of the memorial complex commemorating the victims of the 1944 deportation
from Crimea began in 2016. The project was estimated at 340 million roubles. The project was
postponed year after year. In 2020, it became known that the contractor demanded that the design
and estimate documentation be revised upwards.
On 30 November 2020, at a meeting of the Crimean government, the minister of finance
announced that the draft budget for 2021 “includes the construction and repair of a number of
socially important facilities, namely ... the continuation of construction of a memorial complex to
victims of deportation in the village of Siren – 294.4 million”.

Exhibit C
RIA Novosti, Aksyonov talks about what Crimea is doing for returnees (18 May 2019)
(translation)

Annex 29 Exhibit C
Translation
RIA Novosti, Aksyonov talks about what Crimea is doing for returnees (18 May 2019),
available at: https://ria.ru/20190518/1553600929.html.
Aksyonov talks about what Crimea is doing for returnees
© RIA Novosti / Alexey Malgavko
Head of the Republic of Crimea Sergey Aksyonov and Crimean Muslim Mufti Haji Emirali Ablaev at a
commemorative event marking the Crimean deportation victims' Memorial Day. 18 May 2019
BAKHISARAY (Crimea), 18 May - RIA Novosti. Head of Crimea Sergey Aksyonov told
journalists what measures are being taken in Crimea to settle the families of those deported in the
1940s and to achieve inter-confessional peace on the peninsula.
The memory of the victims of the deportation of Crimean peoples was honoured on Saturday 18
May near Bakhchisaray, at the Syren (formerly Syuren) Railway Station, from where Crimean
Tatars, residents of south-western Crimea, were deported in 1944. Today, the memorial complex
“Path of Revival of the Peoples of Crimea” is being built at this location. The event was attended
by the Head of the Republic Sergey Aksenov, Crimean clergy - Crimean Muslim Mufti Emirali
Ablaev and Metropolitan of Simferopol and Crimea Lazar, deputies, public figures and Crimean
residents.
“More than 10 billion rubles have been allocated to support people who were deported, new flats
are being allocated. Today we were at KIPU (National Engineering and Pedagogical University),
what a huge centre of multi-ethnic culture is being built here. Under Ukraine they only promised
to build it. A remarkable school in the Fontany neighbourhood (Simferopol) is one of the best
equipped in Crimea (with education in the Crimean Tatar language – ed.). Much more is being
done,” Aksyonov told reporters.
Annex 29 Exhibit C
© RIA Novosti / Alexey Malgavko
Девушка на памятном мероприятии, приуроченном ко Дню памяти жертв депортации народов Крыма
The Head of Crimea recalled the construction of a memorial complex at the Syren station, the main
works on which have already been completed. The amount of funding for the work is 400 million
rubles, the authorities said earlier. Aksyonov also highlighted the construction of Crimea's central
mosque in Simferopol.
“It will be an adornment of the city of Simferopol, just like the Alexander Nevsky Cathedral in the
city centre. The construction is being carried out with the support of the President. And also…
previously it was only promised (to build it), but nevertheless the matter has only moved forward
in Russian Crimea," Aksyonov said.
Annex 29 Exhibit C
© RIA Novosti / Alexey Malgavko
Participants in commemorations marking the Day of Remembrance for the Victims of the Deportation of the Peoples
of Crimea at the “Path of Revival of the Peoples of Crimea” memorial complex. 18 May 2019
During the Great Patriotic War, representatives of 20 nationalities, including Greeks, Armenians,
Germans and Bulgarians, were forcibly deported from Crimea on suspicion or charges of treason.
The Crimean Tatars suffered the most; more than 183 thousand people were deported from the
peninsula at that time. Their deportation began on May 18, 1944.
After the referendum in March 2014, Crimea became part of the Russian Federation, and in April,
Russian President Vladimir Putin signed a decree on measures to rehabilitate the Crimean Tatar
and other peoples of Crimea.
Annex 29 Exhibit C
© RIA Novosti / Alexey Malgavko
Remembrance Day for the victims of the deportation of the peoples of Crimea at the memorial complex “Path of
Revival of the Peoples of Crimea” at the Syren Railway Station in the Bakhchisaray District. 18 May 2019
Annex 30
Witness Statement of , 22 February 2023
(translation)

Annex 30
INTERNATIONAL COURT OF JUSTICE
APPLICATION OF THE INTERNATIONAL CONVENTION
FOR THE SUPPRESSION OF THE FINANCING OF TERRORISM AND
INTERNATIONAL CONVENTION ON THE ELIMINATION OF
ALL FORMS OF RACIAL DISCRIMINATION
(UKRAINE V. RUSSIAN FEDERATION)
WITNESS STATEMENT
OF
22 FEBRUARY 2023
Annex 30
Page 2 out of 6
Annex 30
Page 3 out of 6
1. I, , declare the following.
2. I graduated from the
3. I provide this witness statement in relation to the allegations made in Ukraine's Reply to
the Counter-Memorial of the Russian Federation on the dispute initiated by Ukraine
before the International Court of Justice (hereinafter, “Reply”). My witness statement
raises a number of issues relating to the territory of the probable location of the Palace of
Kalga-Sultan in Simferopol. Ukraine claims that construction is allegedly taking place on
the site of the Crimean Tatar cultural heritage monument, namely an Orthodox Christian
church and a building have been constructed.1 In reality, Ukraine’s statements are full of
false information and inaccuracies, which I am going to discuss below.
A. HISTORICAL CONTEXT
4. According to written sources and cartographic material, the Palace of Kalga-Sultan was
supposedly located in the area Ukraine indicates. According to the available historical
information, most of the buildings located on this territory were completely demolished
during the construction of the S.H. Weisbord brewery in the middle of the 19th century.
From that time until 1983, the territory was occupied by a large brewery.
5. In 1984, the buildings of the brewery were demolished and no profound archaeological
research was carried out. To the best of my knowledge, only the basements of the brewery
1 Reply, ¶659.
Annex 30
Page 4 out of 6
were examined in 1984, where single small fragments of medieval glazed pottery were
found.
6. In the period when Crimea was part of Ukraine, there were no profound archaeological
studies of these land plots. That said, I can say with certainty that the public knew that
the Palace of Kalga-Sultan was situated somewhere on the territory of the former brewery,
and it tried to attract attention of the Ukrainian authorities in every way possible to the
need to conduct research and, if necessary, protect the cultural heritage of Crimean Tatars,
which at that time did not attract much attention in Ukraine.
7. The studies of the site were carried out only after Crimea’s reunification with the Russian
Federation. In 2017, under the auspices of the Institute of Archaeology, an archaeological
survey of the area of land on which the Palace of Kalga-Sultan was presumably located,
was carried out. As a result of this study, the Palace of Kalga-Sultan was included in the
Register of Cultural Heritage Monuments.2 In this regard, Ukraine's argument that “[i]n
2017, an archaeological study of Akmejit and the Kalga-Sultan's palace was conducted
so the Russian occupation authorities could begin the construction of a Russian Orthodox
Church on the territory of a former brewery”3 has no foundation in facts.
B. CONDUCTING EXAMINATION
8. The Palace of Kalga-Sultan could supposedly be located on several plots of land. I have
seen documents confirming that all these plots were transferred to private ownership by
the Ukrainian authorities before 2014.
9. The owners of two of these plots approached Institute of Archaeology in 2019 with a
request for an archaeological examination of the plots. One of the owners, Mr Shayarliyev
O.S. was in conflict with the state authorities at the time he approached Institute of
Archaeology, because based on the location of his plot within the boundary of a cultural
heritage site they were prohibiting the development of the territory in question.
2 See RAS Crimean Institute of Archaeology, Information on the newly discovered cultural heritage site for
submission to the State Committee for the Protection of Cultural Heritage of the Republic of Crimea, 19 February
2018 (Exhibit A), p. 15; State Committee of Cultural Heritage Protection of the Republic of Crimea, Order No.
41, 27 March 2018 (Exhibit B).
3 Reply, ¶659.
Annex 30
Page 5 out of 6
10. According to the current Russian legislation (Federal Law No. 73), if there is a cultural
heritage site on the territory of the plot which deserve to be museographed the possibility
of building on it is severely limited or prohibited. The purpose of the expert examination
owners of the plots wanted me to carry out was a comprehensive study of the plots to
determine whether the cultural layer is spread throughout their entire territory and, if so,
how this spread occurs.
11. The experts of the Institute of Archaeology conducted a thorough archaeological
examination of the plots in accordance with the Contracts. As a result of this examination,
it was found that more than half of the plots territory not examined in 2017 was occupied
by buildings and cisterns of the brewery, during the construction of which the cultural
layer had been completely destroyed. In the remaining territory of the plots, the cultural
layer was only recorded in the form of individual interlayers, which were fully examined
during the 2017 examination of the territory. According to single pottery fragments and
a few coins, its accumulation began in the first half of the 19th century. However, even
in the places of discovery, the cultural layer was also heavily damaged by economic
activities in the 20th century.4
12. All surviving fragments of the cultural layer were fully examined in the course of the
2019 works on both the one and the other plots.5 Technical reports were sent to the clients
of the works and then submitted to the State Committee of Cultural Heritage Protection
of the Republic of Crimea (now the Department of Cultural Heritage Protection of the
Ministry of Culture of the Republic of Crimea). The scientific report on the works was
sent to the Department of Field Research of the Institute of Archaeology of the Russian
Academy of Sciences. All archaeological finds obtained in the course of works were
handed over to the Museum of History of Simferopol, where they are now.
13. Since the cultural layer on the two plots had been examined and no construction remains
which deserve to be museographed had been recorded, both plots were excluded from the
4 RAS Crimean Institute of Archeology, Research and planning documentation for the boundary modification
project in relation to the territory of newly discovered cultural heritage site “Urban Area of Ak-Mosque, XVII -
XVIII centuries (possible site of the Palace of Kalga-Sultan)” (Exhibit C), pp. 2-3.
5 RAS Crimean Institute of Archeology, Report of V.V. Masyakin on archaeological explorations in the territory
of the newly discovered cultural heritage site "Urban Area of Ak-Mosque, XVII - XVIII centuries (possible site
of the Palace of Kalga-Sultan)" at 21 Vorovskogo Street, city of Simferopol, the Republic of Crimea in 2019
(Exhibit D).
Annex 30
Page 6 out of 6
boundaries of the cultural heritage object according to the current legislation of the
Russian Federation (Federal Law No. 73). The excluded territory constituted
approximately 1/6th of the total territory of the cultural heritage object. A similar
procedure of changing the territory of cultural heritage objects after their archaeological
examination is in place in Ukraine.
14. On the territory of the allotted plots, which are the personal property of their owners,
these owners erected buildings, in particular, an Orthodox chapel. As far as I know, the
Simferopol Eparchy objected to the construction of the latter.
15. As far as I know, the rest territory of the cultural heritage object has been preserved and
is not being developed. Moreover, its expansion is being considered at the moment.
16. I hereby confirm that, to the best of my knowledge and beliefs, the information set out in
this witness statement is true.
Witness
[SIGNATURE]
Simferopol, 22 February 2023
Annex 30
LIST OF EXHIBITS
Number: Name of exhibit:
Exhibit A RAS Crimean Institute of Archaeology, Information on the newly
discovered cultural heritage site for submission to the State Committee for
the Protection of Cultural Heritage of the Republic of Crimea, 19 February
2018.
Exhibit B State Committee of Cultural Heritage Protection of the Republic of Crimea,
Order No. 41, 27 March 2018.
Exhibit C RAS Crimean Institute of Archeology, Research and planning
documentation for the boundary modification project in relation to the
territory of newly discovered cultural heritage site “Urban Area of Ak-
Mosque, XVII - XVIII centuries (possible site of the Palace of Kalga-
Sultan)”.
Exhibit D RAS Crimean Institute of Archeology, Report of V.V. Masyakin on
archaeological explorations in the territory of the newly discovered cultural
heritage site "Urban Area of Ak-Mosque, XVII - XVIII centuries (possible
site of the Palace of Kalga-Sultan)" at 21 Vorovskogo Street, city of
Simferopol, the Republic of Crimea in 2019.

Exhibit A
RAS Crimean Institute of Archaeology, Information on the newly discovered cultural heritage
site for submission to the State Committee for the Protection of Cultural Heritage of the Republic
of Crimea, 19 February 2018
(translation)

Annex 30 Exhibit A
Translation
RAS Crimean Institute of Archaeology, Information on the newly discovered cultural
heritage site for submission to the State Committee for the Protection of Cultural Heritage
of the Republic of Crimea, 19 February 2018.
Information on the newly discovered cultural heritage site
for submission to
the State Committee for the Protection of Cultural Heritage of the Republic of
Crimea
1. Site name:
Urban Area of Ak-Mosque, XVII - XVIII centuries (possible site of the Palace of
Kalga-Sultan).
2. Dating of the site:
XVII-XVIII centuries.
3. Site location (region, district, rural area, or settlement; location features):
19-23 Vorovskogo Street, city of Simferopol, the Republic of Crimea.
4. Brief description of the monument (boundaries, nature of the cultural layer,
major finds, losses that have changed the original appearance of the site):
The examined territory is wasteland in the mouth of Petrovskaya Balka
("Petrovskaya Ravine") located at 19-23 Vorovskogo Street. The wasteland is
bounded to the north by Vorovskogo Street and to the east and south by Petrovskaya
Balka Street and to the west by the cliffs of Petrovskiye Cliffs (Figures 1 to 5). The
wasteland is a relatively flat site with numerous traces of anthropogenic influence,
which is explained by the existence of Simferopol Brewery on this territory until the
80s of the XX century, when, following the construction of a new beer and soft drinks
plant, it was closed down and dismantled. Within the boundaries of the site there are
numerous potholes and cross-ditches, which formed as a result of extraction of ferrous
and non-ferrous metals by local residents, and a considerable amount of construction
Annex 30 Exhibit A
2
and household waste. The terrain descends gently from south to north. In the western
part of the site, there is a water source (spring) in the wall, which may be identified
as the source for the fountain that existed in the territory of the Palace of Kalga-Sultan
palace and subsequently in the territory of the brewery. It is possible that the same
spring is referred to as "Petrovsky Fountain" in late written and graphic accounts.
In order to identify the absence or presence of a cultural layer; to define more
precisely from a stratigraphical perspective; and to identify possible construction
debris, 9 archaeological pits (Nos.1-9) were dug and studied (Fig.5). Archaeological
remains were found in pits Nos. 1-5, 7-9 and include fragments of ceramic vessels,
smoking pipes, construction ceramics, metalware, numismatic finds, etc.
The thickness of the cultural layer is 1.4 to 3.0 metres, according to the results
of the archaeological reconnaissance.
Pit 1. (Coordinates: N44.94807°, E034.11689°)
Located in the north-western part of the site, 17 m south of the parking area of the
Training Centre of the Main Department of the Russian Ministry of Emergency
Situations of the Republic of Crimea. It is oriented along the north-west - south-east
line. The dimensions of the pit are 2x2 m. Under the vegetable layer there is a XX
century layer of about 0.7 m thick under which stones can be seen in the north-eastern
part. Beneath the stones is dark brown loam containing XVIII-XIX century remains
(fragments of pottery vessels and a coin of the Russian Empire) (Figure 11). A trench
oriented along the north-south axis with a XX century metal water (?) pipe was dug
in the soil. Along the north-eastern side, below the vegetable layer, mortar-built
foundations of a XX century building were found. In the south-eastern part of the pit,
there is a large concrete remnant which could not be removed due to lack of technical
means. Under the layer with finds from the XVIII and XIX centuries, there is a greybrown
sandy loam with an admixture of clay and possibly silt,; this layer is sterile and
Annex 30 Exhibit A
contains no finds. Underneath is also a sterile pebble layer - apparently a continental
surface, as neither it nor the previous layer contain finds (Figures 6 to 10).
Pit 2. (Coordinates: N44.94773°, E 034.11691°)
Located in the western part of the site, 16 m to the north-east of the electrical
substation. The original dimensions of the pit were 2x2m, subsequently, in order to
clarify the stratigraphic situation and detect hydraulic structures the pit was extended
westwards by 1m and its dimensions are now 2x3m. It is oriented along the cardinal
directions. Under the 0.1-0.15 m thick vegetable layer, there is a layer of dark brown
loam containing XX century remains, construction waste, and asphalt. It also contains
two pipes from the corresponding period (metal water pipe and ceramic sewage
pipe?). On the northern side of the pit, beneath the turf layer, a stone and shell
construction was found, which was is embedded in the layer of the XX century. Under
dark brown loam is light brown friable loam with small stones and rare inclusions of
tiles and other XIX century materials. The thickness of this layer is 0.25 to 0.3 m.
Under this layer and partly in it, there is a 0.1-0.15 m thick tile rubble. Beneath it,
there is another layer of light brown loam with lime. The thickness of this layer is 0.2
to 0.25 m (Figures 13-16a). It also contains fragments of "Tartar"-type tiles, fragments
of green-glazed pottery, imported Turkish faience and ceramic smoking pipes,
fragments of ceramic pipes of various diameters, etc. Coins from the era of the
Crimean Khanate (mid- XVIII century, see the table "Inventory of Coins") also come
from this layer. At the base of this layer there is a ceramic water-pipe with partially
preserved construction of small and medium-sized stones on lime mortar around it.
Beneath the lime mortar, dark brown dense loam containing no archaeological
remains is observed. The thickness of this layer is approximately 0.5 m. Underneath
it, sterile continental clay can be traced, which was dug down to the depth of the test
bayonet. Archaeological remains, including five segments of ceramic water pipe,
were extracted from the layer, for further processing and transfer to the museum
(Figures 17-18).
Annex 30 Exhibit A
4
Pit 3. (Coordinates: N44.94785°, E034.11663)
Located 9 m north of the water source, in the north-western part of the site. Its
dimensions are 3x3m. Under the vegetable layer, a 0.2 to 0.25 m thick, XX century
layer of brown loam with large amounts of building and domestic debris (0.4 to 2 m
thick) was revealed, and in the north-east corner, a XX century structure of shell
limestone on cement mortar, which stands on a concrete foundation, is observed at a
depth of 2 m. In the south-western part of the pit, under the vegetable layer, there is a
slurry of clay mortar (?). Under it and under the XX century layer, at a depth of 0.8 to
0.9 m, in the central part of the square, masonry of ragged limestone with hewn outer
edge, on clay mortar, is found. In the northern side of the pothole, a layer with remains
of dismantled wall in the form of a clay column can be seen. The height of the
remaining part of the wall from the foundation to the top course of the brickwork is
0.8 to 1 m, the depth of the foundation is 0.6 to -0.8 m. Along the wall, on both sides,
there is a layer of light grey loam with an admixture of lime particles and XVIII-XIX
century material (fragments of pottery and faience, "Tartar"-type tiles, coins of the
Russian Empire) (Fig. 24 to 29). At the foundation level, there is a layer of soot, 0.05
to 0.1 m thick, under which is light grey, loose moist sandy loam containing material
from the XVIII and XIX centuries. Beneath it, there is a sterile, dense horizon of clay
and calcareous (rocky?) outcrops. Given that water had come out at this level at the
bottom of the pit, the study was discontinued (Figures 19 to 23).
Pit 4. (Coordinates: N44.94790°, E034.11742°)
Located 34m west of the edge of the pavement on Vorovskogo Street, and 60m south
of the car park of the Training Centre of the Main Department of the Russian Ministry
of Emergency Situations in the Republic of Crimea. It is oriented along the cardinal
points. Its dimensions are 2x2m. Under the 0.1-0.15 m turf a thick cultural layer of
XX century is observed, which includes dark-brown loam containing construction
waste and asphalt. A layer of grey loam with inclusions of charcoal, limestone grit
and fragments of XIX century ceramics (tiles, fragments of vessels) was found under
Annex 30 Exhibit A
the asphalt layer (Fig. 33). The thickness of the layer is 0.3 m. In the north-eastern
corner there is a series of large stones (one of which had been worked, probably
serving as a retaining base for a pillar). Under this layer, a light grey sandy loam with
an admixture of clay is traced, as in Pit 1. It is similarly sterile, with a slightly lower
thickness of 0.7m, and below this layer there is brownish-green sterile clay,
continental surface. Control excavation of the continental clay was undertaken, no
finds were found. In the south and west sides a layer of charcoal containing XIX
century material could not be observed. In the southern side, at a depth of 0.8 m, an
asbestos pipe embedded in grey sandy clay is observed. The depth at which the pipe
lies in the trench is 1.2m. (Figures 30-32)
Pit 5. (Coordinates: N44.94722°, E034.11771°)
It was dug on the land plot at 21a Vorovskogo St., 1 m from the western wall of the
site. The choice of the location for the pit was based on the proximity of the site to the
area of the Scythian Naples Nature Reserve, the maps provided by Dubois de Monpere
and Blaramberg, and German aerial photographs from 1941, in which the land plot
had no buildings of the brewery on it. Although the land plot is not part of the area
under the contract, it is of potentially high importance for the study. The original
dimensions of the pit were 2x2m but subsequently it was extended eastwards and now
its dimensions are 2x3m. The top layer is re-deposited soil, probably from
construction work on the site (construction of a wall?) or other general labour activity.
The thickness of the layer is 0.3 to 0.5 m. Under it, there is a thin layer of buried turf
up to 0.05 m. Further, grey loam with construction and domestic waste and asphalt I
observed. Under the asphalt, there is light grey loam with XVIII-XIX century remains
(fragments of pottery vessels, smoking pipes, glass vessels, fragments of "Tartar"-
type tiles). This layer is 0.4 m thick. Under this layer there is light grey sandy loam
with small stones, 0.15-0.25 m thick. Under the light grey sandy loam, dark grey loam
with rare inclusions of small limestone stones and fragments of "Tartar"-type tiles is
observed in the upper part of the layer and at the bottom. The tile fragments at the
base of the layer form the boundary with the next layer under which masonry
Annex 30 Exhibit A
6
(foundation?) and slab paving to the north of the masonry can be observed in the
western part of the pit. The layer above is light grey loam with limestone and tile
fragments and fragments of XVII-XVIII century pottery vessels (Figs. 40-44). This
layer can be roughly described as layer with remains of a dismantled wall. In the
eastern part, the wall was disassembled just below the slab paving. The structure is
masonry on clay mortar made of large equal hewn stones. The masonry is 0.8m wide
and it was disassembled to the floor slabs. The wall is in the east-west direction,
slightly deviating to the north. The paving (floor?) is a series of limestone slabs (5
pieces found), 0.4 m wide and 0.6-1.2 m long, the thickness of the slabs and the depth
at which they had been laid were not clear at this stage of the study. In view of a threat
to the integrity of the discovered structure and the reasonableness of opening this level
of the cultural layer over a wide area, works at this location were discontinued
(Figures 35-39).
Pit 6. (Coordinates: N44.94759°, E034.11722°)
Located at the place where there were traces of a trench excavated 33 m to the east of
the electrical substation. Its dimensions are 3m x 3m and it is oriented along the
cardinal points, with a slight deviation to the east. In its upper part, there is a 0.3-0.6
m thick re-deposited layer with buried turf. In the northern part, under the turf, there
is a 0.7 m layer of building rubble, under which a reinforced concrete structure is
preserved, which is part of the foundations of the XXth (?) century brewery walls
with limestone rubble. In the southern part, remains of concrete and walls made of
shell rock and lime blocks on lime mortar with traces of plaster on the outside and
lime plaster (whitewash?) on the inside are localized. The end wall of the structure is
made of untreated limestone on lime mortar. The outer corner of the masonry is made
of sawn limestone blocks, and the inner corner is made of limestone bricks. The end
wall was sloped by limestone masonry, probably, to make an arch. There is no lintel
between the end wall and the vault. Due to the remains of construction rubble and
heavy debris, it was not possible to continue further studies here without the
Annex 30 Exhibit A
appropriate equipment. The work was discontinued. The site can be additionally
explored in the course of full-scale works. No materials of archaeological value were
found, while some of the structures may be related to a late XVIII-XIX brewery built
on the site of previous palace complex structures (Figure 45).
Pit 7. (Coordinates: N44.94773°, E034.11794)
Located 42 metres north-west of the intersection of Vorovskogo Street and
Neapolskaya Street. It is oriented along the cardinal directions. The dimensions of the
plot are 1x2m. Under the vegetable layer (0.1 m thick), there is 0.2 m thick light gray
loam containing contemporary rubbish. Under it, a 0.03 to 0.05 m thick layer of
asphalt can be traced. Under the asphalt, there is light grey loam with interlayers of
limestone grit and medium to fine limestone. Also, in the central part of the pit, under
the asphalt, there was found a XX century metal pipe going in the east-west direction.
The layer filling the trench is mixed and modern rubbish is found along with XVIIIXIX
century material. (Fig. 46-48a). In the light grey loam, with a total thickness of
1-1.2 m, there are fragments of Tartar-type tiles, fragments of ceramic vessels and
smoking pipes (dated XVII-XIX cc.), etc. (Fig. 50-51) Under the light grey loam is
dark brown sterile loam (0.3-0.4 m thick), lying on a dense sterile layer with pebbles
(probably continental surface as in Pit 1). Due to the absence of archaeological
material in this layer, work in this area was discontinued.
Pit 8. (Coordinates: N44.94741°, E034.11813°)
Located 16m north of the car service station on Neapolskaya Street. The dimensions
are 2x2m. The top layer is re-deposited soil with turf that formed as a result of clearing
of the parking area for the car service station. The layer thickness is 0.2 to 0.3 m.
Underneath there is a layer of grey soil containing large amount of construction and
domestic waste and asphalt. The layer thickness is 0.3 to 0.4m. Under the asphalt there
is stone rubble resulting from the demolition of the wall which is traced under the
stone rubble at the depth of 1.3 to 1.4 m. The wall is 0.8 m wide masonry made of
Annex 30 Exhibit A
8
untreated stones on clay mortar, with stones hewn on the outer side. The wall runs in
an east-west direction. To the north and south of the masonry, dark brown loam is
traced, containing almost no finds. In general, however, XIX century material
(fragments of pottery vessels, glass, fragments of Tartar-type tiles) was found in the
stone rubble above the wall (Fig. 55). Due to the fact that the masonry runs exactly in
the centre of the pit and further research was associated with a threat of disturbing the
integrity of the discovered structure, the work at this site was discontinued
(Figs. 49, 52-54).
Pit 9. (Coordinates: N44.94786°, E034.11764°)
Located 15m south of Pit 4. Dimensions are 2 x 3 m. The stratigraphic situation is the
same as in Pit 4. Under the turf layer with a thickness of 0.1 to 0.15 m, there is a XX
century cultural layer consisting of dark brown loam containing construction debris
and asphalt. Under the asphalt layer there is a layer of grey loam with inclusions of
charcoal, limestone grit and fragments of XIX century ceramics (tiles, fragments of
vessels) (Fig. 61 and 62). Under this layer there is light grey sandy loam with clay
admixture, as in pit 1. It is also sterile, its thickness is slightly lower, 0.7 m, under this
layer there is brown-green sterile clay, continental surface. Control excavation of the
continental clay was undertaken and no finds were discovered (Figures 56-60).
5. Conclusion
In November 2017, 9 pits with a total area of 50 square metres were dug in the study
area. The main objective was to determine the presence/absence of cultural heritage
objects in the study area. As a result of the field work, it was established that a
cultural layer containing archaeological artefacts of the XVII-XIX centuries and
architectural and hydraulic structures of the relevant period had been discovered in
the study area. The depth of the cultural layer varies in different parts of the territory
and can vary from 0.5 to 1 m. In view of this, and also taking into account the
references to this place as the location of the Palace of Kalga-Sultan in the XVIAnnex
30 Exhibit A
XVIII centuries in written sources, we consider it necessary to include the site on
the List of Newly Discovered Cultural Heritage (Archaeological) Sites. In the future,
a full-scale archaeological study will need to be carried out, including the
museumisation of any identified construction remains and the creation of an
appropriate museum complex or inclusion of this site in Historical and
Archaeological Museum-Reserve "Scythian Naples".
Annex 30 Exhibit A
Coordinates of characteristic points along the bndary in the World Geodetic
System (WGS-84) and SK-63 Coordinate System:
# of measured point on
the boundary of the
archaeological heritage
site territory and the p
Coordinates of characteristic
points in the World Geodetic
System (WGS-84)
Coordinates of characteristic points in SK-
63 Coordinate System
Northern
latitude
Eastern
longitude Northern latitude
Eastern
longitude
Point 1 44.94822° 034.11666° 4971009.32 5190939.643
Point 2 44.94816° 034.11654° 4971002.814 5190930.059
Point 3 44.94812° 034.11644° 4970998.503 5190922.091
Point 4 44.94719° 034.11691° 4970894.518 5190957.419
Point 5 44.94717° 034.11705° 4970892.107 5190968.43
Point 6 44.94719° 034.11763° 4970893.548 5191014.241
Point 7 44.94724° 034.11800° 4970898.607 5191043.536
Point 8 44.94779° 034.11844° 4970959.137 5191079.302
Point 9 44.94844° 034.11689° 4971033.459 5190958.211
Pit 1 44.94807° 034.11689° 4970992.34 5190957.509
Pit 2 44.94773° 034.11691° 4970954.529 5190958.443
Pit 3 44.94785° 034.11663° 4970968.242 5190936.573
Pit 4 44.94790° 034.11742° 4970972.734 5190999.014
Pit 5 44.94722° 034.11771° 4970961.5 5191005.927
Pit 6 44.94759° 034.11722° 4970938.553 5190982.642
Pit 7 44.94773° 034.11794° 4970953.142 5191039.729
Pit 8 44.94741° 034.11813° 4970917.324 5191054.117
Pit 9 44.94786° 034.11764° 4970961.5 5191005.927
The area of the newly discovered cultural heritage (archaeological) site is approximately
13,690 square metres (1.369 ha)
Holder of the Archaeological Excavation Permit,
Performer of the Works, Research Fellow, Candidate of
Historical Sciences
E. I. Seydaliev
Acting Director of the Federal State Budgetary
Research Institution "Crimean Institute Of
Archaeology of the RAS, Doctor of Historical
Sciences
В. V. Maiko

Annex 30 Exhibit A
A description of the archaeological material:
The archaeological material discovered during the 2017 archaeological
reconnaissance consisted of numerous fragments of vessels from the XVII-XVIII
centuries, as well as from modern times (see the respective section):
Pit 1. Layer 1. - 15 fragments of walls of red-clay Tatar-type tiles, tentatively dated
to the XVII-XX centuries, 1 fragment of wall of beige clay vessel, tentatively dated
to the XIX c., 1 fragment of cupolas of light red clay vessel, 6 fragments of walls of
orange clay vessels and cupolas with oval handle, 1 fragment of cupolas and 3
fragments of walls of red clay vessels, 1 fragment of wall outside and inside covered
with green glaze, tentatively dated to the XVII-XVIII centuries. A copper coin dated
to the XIX century was also found.
Pit 2. Tile rubble. - 634 edge fragments and 325 wall fragments of red-clay Tartartype
tiles, tentatively dated to the XVII - XX centuries.
Pit 2. Layer under tile rubble. - 5 sections and 6 fragments of red-clay pipes,
tentatively dated XVI-XVII centuries, 12 fragments of walls of red-clay "tartar" tiles,
tentatively dated XVII-XX centuries, 1 fragment of red-clay plinth edge, 12 walls of
red-clay pots, 7 walls of light-clay vessels covered with green glaze, 9 fragments of
corolla and 5 fragments of cup walls with cobalt-painted "Iznikware" type
decorations, tentatively dated XVII- XVIII centuries. 2 fragments of a glass bracelet
with yellow accents, 1 pipe and 2 fragments of a Turkish type sleeve with a stamped
ornament, 1 circular copper piece from a belt set (?), provisionally dated to the XVIIXVIII
centuries. 4 white metal coins from the XVIII century.
Pit 3 - 22 fragments of walls of red-clay "tartar" type tiles, 1 fragment of wall and 1
fragment of edge of red-clay tiles outside and inside covered by green glaze,
tentatively dated XVII-XX centuries, 2 fragments of spout of red-clay cuman, 1
archaeological complete profile of a light beige clay bowl, green-glazed on the
outside and inside, 1 fragment of the corolla with the wall and the upper stick of the
handle of a rose-clay jug, green-glazed on the outside and inside, 1 fragment of the
bottom of a flat grey-clay pot, covered with light brown glaze on the inside and green
on the outside, 1 fragment of the handle of a red-clay jug, covered with light green
glaze with streaks of brown glaze, fragment of the bottom of a red-clay amphora,
Secondary use as a grater, 1 iron horseshoe, tentatively dated to the end of the XVIIIXIX
centuries, 1 pipe and 1 fragment of a Turkish type sleeve with stamped
ornament, tentatively dated to the XVII-XVIII centuries, 1 copper coin from the
reign of Catherine II.
Pit 4 - 1 fragment of an architectural stone detail, 1 fragment of the bottom of a flat
red-clay pot, 1 fragment of a wall with an upper moulding
􀏭􀏯
Annex 30 Exhibit A
3
handles and 1 fragment of the corolla of beige clay vessels, externally and internally
coated with green glaze, tentatively dated to the late XVIII-XIX centuries.
Pit 5 - 6 fragments of walls of red-clay "Tartar"-type tiles, tentatively dated to the
XVII-XX centuries, 1 fragment of the bottom of a flat red-clay pithos, 1 fragment of
the bottom of a conical beige-clay amphora, 1 fragment of the bottom of a flat redclay
amphora, 2 fragment from the wall of a yellow-clay amphora, 2 spouts of drain
and 1 handle of a red-clay cuman, 7 fragments from the walls of red-clay pots coated
with green glaze inside and outside, 1 fragment from the bottom of a flat beige-clay
vessel, 1 fragment of the corolla of a red-clay bowl, inside and outside on the edge
covered with brown glaze, inside ornament in the form of two parallel lines with
green glaze, 1 fragment of the bottom on the ring tray of a white-clay dish, inside
and outside covered with mother-of-pearl glaze, on the inside a floral ornament in
blue, green and black, 2 fragments of a Turkish type sleeve with a stamped ornament,
tentatively dated XVII-XVIII cc, 5 kopecks 1857
Pit 7 - 12 fragments of edges and 38 walls of red-clay "Tartar" type tiles, tentatively
dated XVII - XX centuries, 1 fragment of pithos corolla, 1 fragment of corolla and
handle of red-clay amphora, 6 fragments of walls and 1 fragment of handle of beigeclay
amphora, 1 fragment of corolla of dark-clay pot, 4 fragment of walls, 1 fragment
of rim and 1 fragment of handle of red-clay jugs, 10 fragments of walls of red-clay
jugs outside covered with green glaze, 4 fragments of walls of beige-clay jugs
outside covered with light-brown glaze, tentatively dated XVII-XVIII centuries.
Pit 8 - 11 fragments of walls of red-clay "Tartar" type tiles, tentatively dated to the
XVII - XX centuries, 1 fragment of wall with lower handle of red-clay amphora, 1
fragment of wall and 1 fragment of handle of red-clay jug, 1 fragment from the wall
of a beige clay bowl, internally glazed with light brown glaze, with underglaze
painting in dark green glaze, tentatively dated to the XVII - XVIII centuries.
Pit 9 - 16 fragments of edges and 31 fragments of walls of red-clay "Tartar"-type
tiles, tentatively dated XVII-XX cc., 1 fragment of wall with red-clay pipe edge, 1
fragment of flat red-clay amphora bottom, 1 fragment of red-clay jug rim outside
and inside covered with green glaze, under which there is a white engobe, 1 fragment
of the edge of a red-clay plate covered with a light brown glaze on the inside and a
green glaze on the outside, 1 fragment of a Turkish-type sleeve with a stamped
ornament, tentatively dated to the XVII - XVIII centuries.
Total: 188 items.
Annex 30 Exhibit A
COIN AND SEAL INVENTORY 1
# #
c/o
Photo of the find Description Weight
(gr.)
Metal Diameter
(mm)
Note
1 18
Obverse: The side is
heavily corroded
Reverse: Side heavily
corroded; Crimean
Khanate, Bakhchisaray
mint, 18th century.
0,86 Billon 15-16 The coin
needs
professional
restoration
2 19
Obverse: The
inscription: "[Khan
Arslan Giray son
of Devlet]
Reverse: Inscription:
"[Coined in
Ba]khchi[saray], 1161"
(1161 = 1748-1749
A.D.)
Crimean Khanate,
Arslan Giray (1748-
1756 A.D.),
Bakhchisaray mint,
Beshlyk
0.68 Billon 15-16
3 20
Obverse: Inscription:
"[Kha]n Selim [Giray
son of Kaplan]".
Reverse: Inscription:
"[Coined in
Bakhchisaray, 1156]".
(1156 = 1743-
1744 AD).
Crimean Khanate,
Selim Giray II
(1743-1748 AD),
Bakhchisaray mint,
1182 Beshlyk
0,58 Billon 15-16
1 Coin attribution by A.V. Yakushechkin
Annex 30 Exhibit A
4 21
Obverse: The
inscription: "[Khan
Ar]slan [Giray son
of Devlet]
Reverse: Inscription:
"[Coined in
Ba]khchi[saray], 1161"
(1161 = 1748-1749
A.D.)
Crimean Khanate,
Arslan Giray (1748-
1756 A.D.),
Bakhchisaray mint,
Beshlyk
0,58 Billon 14-17
􀏭􀏱
5. An opinion on the scientific and historical significance of the site:
The urban area of Ak-Mosque, XVII - XVIII centuries (possible site of
the Palace of Kalga-Sultan) is an interesting late medieval and modern object
with preserved cultural layer and structures. Its study will add to the
understanding of the history and topography of the Ak-Mosque, the nature of
the material culture of the city's population, and the military, political and socioeconomic
history of the Crimean Khanate.
The newly discovered cultural (archaeological) heritage site, the Urban
Area of Ak-Mosque, XVII - XVIII centuries (possible site of the p Palace of
Kalga-Sultan), is to be included on the List of newly discovered cultural
(archaeological) heritage sites.
6. Information about the owner of the land:
1. Plot 1. Cadastral number: 90:22:010223:31
Land category: Settlement lands (residential areas). Sports. (Fig. 3. 1).
Land plot is located at: Republic of Crimea, Simferopol, Vorovskogo Street,
in the area of house No. 21 (position as per GP-1).
Annex 30 Exhibit A
2. Plot 2. Cadastral number: 90:22:010223:590
Land category: Settlement lands (residential areas) for individual
housing construction. Land plot is located at: Republic of Crimea, Simferopol,
Vorovskogo Street, near the house number 21 (position as per GP-1) (Fig. 3. 1).
3. Plot 3. Cadastral number: 90:22:010223:118
Land category: Land of settlements (residential areas) for individual
housing construction Land plot located at the address:
Republic of Crimea, city of Simferopol, 21a Vorovskogo Street (Figure 3. 1).
4. Plot 4. Cadastral number: 90:22:010223:906
Land category: Land of settlements (residential areas) for individual
housing construction Land plot is located at:
Republic of Crimea, Simferopol, 21 Vorovskogo Street, Simferopol (pos. as per
GP-2). (Fig. 3. 1).
7. Information on the land plot user:
1. Plot 1. Cadastral number: 90:22:010223:31
Land category: Settlement lands (residential areas). Sports. Land plot
located at the address: Republic of Crimea, Simferopol, Vorovskogo Street,
near house number 21 (pos. as per GP-1).
2. Plot 2. Cadastral number: 90:22:010223:590
Land category: Settlement lands (residential areas) for individual
housing construction. Land plot is located at: Republic of Crimea, Simferopol,
Vorovskogo Street, near house number 21 (pos. as per GP-1).
3. Plot 3. Cadastral number: 90:22:010223:118
Land category: Land of settlements (residential areas) for individual
housing construction. Land plot is located at:
Republic of Crimea, Simferopol, 21a Vorovskogo Street.
4. Plot 4. Cadastral number: 90:22:010223:906
Annex 30 Exhibit A
Land category: Land of settlements (residential areas) for individual
housing construction. Land plot is located at:
Republic of Crimea, Simferopol, 21 Vorovskogo Street (pos. as per GP-
2).
8. The character of today's use:
At present, the area of the newly discovered site is partially unused, with
one of the plots (21a Vorovskogo St.) fenced off.
9. Legal regime for the usage of the land plot within the
boundaries of which the newly discovered cultural heritage site is located
(protection zone, nature reserve, etc.): not established.
10. Historical information (history of discovery; who and when
carried out archaeological reconnaissance and excavations; place of
storage):
It should be noted that prior to this field studies, the area at the indicated
address had not been explored archaeologically. The nearest excavations in the
study area were at the site of the ancient settlement of Scythian Naples and at
the Petrovskie Vysoty massif.
As a result of archival and bibliographic research the following
information regarding the study area was gathered.
The historical sources containing information about the Palace of Kalga-
Sultan are quite numerous. Among them, of particular interest are descriptions
of those writers who were in Crimea themselves. The Palace of Kalga-Sultan
was described by such writers as Evliya Chelebi, Charles de Peyssonnel, Abri
de la Motere, Christophe Manstein and others. Much was written about the
palace by later authors.
Annex 30 Exhibit A
One of the earliest mentions of the palace, dating from the first half of the
17th century, belongs to a Dominican monk, Jean de Luc, who visited the
Crimea in 1625 (or 1633). He notes: "The Khan has five palaces, the Sultan [i.e.
Kalga-Sultan - translator's note] has two. The palaces of the Sultan (i.e. Kalga-
Sultan) are in the Ak-Mosque".
The information of the famous Turkish traveller of the 17th century Evliya
Celebi, who devoted a separate chapter to the Palace of Kalga-Sultan in his
"Book of Travels", is rather valuable. According to him, the palace complex had
"200 two-storey buildings made of stone, with kyuryunyusha (chambers for the
Divan meetings - ed.), with bright and luxurious rooms. The palace, though, was
not as splendidly appointed and decorated as the khan's palace in Bakhchisaray.
In the wide square of this palace there is a mosque with one minaret". The
mosque was named after its builder, the Crimean Khan Mengli Giray, it was not
big, covered with tiles, with one stone minaret of the old design.
Noteworthy is the mention of the palace made by a Russian official in
1787: "The Great Palace of Kalga-Sultan is not itself big in size and is occupied
by our soldiers, who have already managed to destroy some of the fountains
decorating his palace, and cut down trees. Behind the fence of the palace there
was a fountain which flowed out of a solid stone wall, and further away there
were squalid tiny houses of Tartars. Behind the Palace of Kalga-Sultan, not far
from Salgir, there is a cemetery with a white fence in the midst of it and canopy
with a green sign above the fence, under which a mullah is sitting all day long
whispering prayers in honour and glory of some saint buried here".
Sometime later, in the first half of the 19th century, the location of the
former Palace of Palace of Kalga-Sultan was indicated on the plans by
Blaramberg and Dubois de Monpere.
Subsequent researchers wrote the following about the palace: "Near the
rock itself, above the Petrovsky fountain, and near the road, the brewery of
Annex 30 Exhibit A
Weisbord stands. <...> on this spot, where the brewery now is, was formerly the
Palace of Kalga-Sultan ". There is also a handwritten plan of the site showing
"Sultan Saray" with "Weisbord brewery" located there.
Thus, the former Weisbord brewery, later the Simferopol Brewery, which
was located at 21 Vorovskogo Street, was one of the landmarks indicating the
palace location. According to the recollections of the brewery workers, they
were stunned by huge cellars, which had remained actually untouched by the
destruction of the factory premises during the liquidation of the brewery..
In the course of the present archaeological study, 9 pits were dug. As a
result of the field work, it was found that the study area has a cultural layer
containing archaeological artefacts from the XVII-XIX centuries and
architectural and hydraulic structures of the relevant period.
11. Bibliography, archival sources:
1. Bocharov S.G. Ak-Mechet: Historical Topography of the City of the
Crimean Khanate // Medieval Turkic-Tatar States. 2015. №7. P. 5-10.
2. Zaytsev Y.P. Scythian Naples (II century BC - III century AD) /
Monograph. - Simferopol: Universum, 2003. – 212 pages
3. Manstein's Notes on Russia. 1728-1744 // Translated from the original
manuscript by Manstein. - SPb., 1875. – 378 pages
4. Ivanić M. Crimean Tatar embassies to the Vienna court in 1598-1682 (from
the history of Crimean Tatar diplomacy in the XVI-XVII centuries).
Turcica et Ottomanica: Collection in honour of M. S. Meyer's 70th
birthday. - М, 2006. - p. 226- 237.
5. Historic and Architectural Master Plan of Simferopol -
Available at: http://sim.gov.ua/userfiles/file/istarkplan.pdf
Annex 30 Exhibit A
6. Kondaraki V. H. A universal description of the Crimea. Parts. 1-17. -
Nikolaev - SPb., 1873-1875.
7. Crimea. Guidebook / Edited by L.S. Vagin, E.V. Wolf, P.A.
Dvoichenko and V.V. Sokolov. Sokolov. - Simferopol, 1923.
8. Lashkov F. Historical Sketch of Crimean Tatar Land Tenure. - Simferopol,
1997. – 203 pages
9. Moskvich G. Illustrated practical guide to the Crimea.
Tenth edition. - Odessa, 1901.
10. Description of the Perekop and Nogai Tatars, Circassians, Mingrelians and
Georgians by Jean de Luc, a monk of the Dominican Order (1625) //
ZOIID. - Vol. 11 - Odessa, 1879. – pages 473-493.
11. Pallas P. S. Observations made during his travels in the southern provinces
of the Russian state in 1793-1794 / Per. - М.: Nauka, 1999, 246 pages
12. Ch. de Peyssonel Note on Small Tartary / Translated from French by V.
Lotoshinsky, introduction and notes by V. Gribovsky. - Dnepropetrovsk:
Gerda, 2009. – 80 pages
13. The third study tour of Simferopol Men's Gymnasium. Report compiled by
order of the Pedagogical Council by F. Lashkov. - Simferopol, 1890.
14. Evliya Çelebi, Book of Travels. Crimea and the Adjacent Regions. Extracts
from the works of the Turkish traveller of the XVII century / Translation
and commentary by Е. V. Bakhrevsky. - Simferopol: DOLYA, 2008. - 172
pages
15. J. de Blaramberg. De la position de Trois fortresses Tauro-Scythes, don’t
parle Strabon, avec cartes, plans, copies d'inscroptions et dessins d'apres
des mabres antiques.- Odessa, 1831. Published in the book: Y. P. Zaitsev
Annex 30 Exhibit A
Scythian Naples (II century B.C. - III century A.D.) / Monograph. -
Simferopol: Universum, 2003, 212 pages
16. De La Motraye. Voyage du Sr. A. De La Motraye en Europe,
Asie et Afrique. Tome Second. - La Haye, 1727.
17. Dubois de Montpereux F. Voyage autour du Caucase, chez les Tcherkesses
et les Abkhases, en Georgie, en Armenie, en Crimee: A 6 v.- Paris, 1843,-
V, 6.
12. Recommendations on the mode of usage of the land plot within
the boundaries of which the archaeological site "Urban Area of Ak-
Mosque, XVII - XVIII centuries (possible site of the Palace of Kalga-
Sultan)" is located:
A possibility is to be provided for conducting archaeological field work in
accordance with the procedure established by Federal Law No. 73-FZ "On
Cultural Heritage (Historical and Cultural Monuments) Sites of the Peoples of
the Russian Federation" dated 25.06.2002 and earth, construction, and
reclamation works and general labour activities, provided that the newly
discovered archaeological heritage site is preserved and that citizens have
access to such archaeological heritage site.
1. The following should be prohibited:
1.1 Performance of earthworks or construction or reclamation works,
general labour activities or other works without the approval of the
state body for the protection of cultural heritage.
1.2 Disturbance of turf and earth excavation in previously unexcavated
and undisturbed areas, except for activities related to archaeological
study and activities aimed at the conservation and scientific study of
archaeological heritage sites.
1.3 Conducting archaeological studies on an archaeological heritage
site territory without a (archaeological excavation) permit issued by
the Ministry of Culture of the Russian Federation to the researcher.
1.4 The use of metal detectors, GPRs and other instrumental search
tools aimed at identifying and collecting archaeological material.
Annex 30 Exhibit A
1.5 Discarding of waste (creation of dumps) on archaeological heritage
sites.
2. The following should be allowed:
2.1 Activities related to archaeological studies and scientific study of
archaeological heritage sites shall be carried out under the laws
currently in force.
2.2 Conservation and museumisation of archaeological heritage sites
and other activities that are necessary to ensure the conservation of
archaeological heritage sites in their historical and landscape setting,
as approved by the state authority for the protection of cultural
heritage.
2.3 Use, in accordance with Article 45.2 of Federal Law No. 73-FZ"On
Cultural Heritage Sites (Historical and Cultural Monuments) of the
Peoples of the Russian Federation" dated 25.06.2002, of special
technical means for search and/or excavation machines to locate
archaeological heritage sites and/or archaeological items only during
archaeological fieldwork carried out on the basis of a (archaeological
excavation) permit.
Date: 19.02.2018
Holder of the Archaeological Excavation
Permit, Performer of the Works, Research
Fellow, Candidate of Historical Sciences
E. I. Seydaliyev
Acting Director of the Federal State Budgetary
Research Institution “RAS Crimean Institute of
Archaeology”, Doctor of Historical Sciences
В. V. Mayko
Exhibit B
State Committee of Cultural Heritage Protection of the Republic of Crimea, Order No. 41,
27 March 2018
(translation)

Annex 30 Exhibit B
Translation
State Committee of Cultural Heritage Protection of the Republic of Crimea, Order No. 41,
27 March 2018.
State Committee for the Protection of Cultural Heritage of the Republic of Crimea
27 March 2018 #41
On entry of the identified object of archeological heritage
into the Register of identified objects of cultural heritage
of the Republic of Crimea and on the establishment of
boundaries and modes of using the territory thereof
In accordance with Articles 3.1, 16.1 and 45.1 of Federal Law No.73 dated 25.06.2022 “On
objects of cultural heritage (monuments of history and culture) of the peoples of the Russian
Federation, Order No.2328 dated 01.09.2015 “On the establishment of register of information
about archeological heritage objects not suitable for publication”, based on the excerpt from
Minutes No. 04-18 dated 23 March 2018 of the meeting of the Scientific and Methodological
Council on Cultural Heritage under the auspices of the State Committee for the Protection of
Cultural Heritage of the Republic of Crimea and documentation on the identified object of
cultural (archeological) heritage “Section of the urban buildup area of Ak-Mosque, XVII-XVIII
centuries (probable location of the Kalga Sultan Palace” received from FGBUN “RAS Institute
of Archeology of Crimea” (D.Sci. V.V. Maiko) and individual person, holder of Open List No.
2355 of 30.10.2017, C.Sci. E.I. Seidaliev,
I HEREBY ORDER AS FOLLOWS:
1. Enter the identified object of cultural (archeological) heritage “Section of the urban
buildup area of Ak-Mosque, XVII-XVIII centuries (probable location of the Kalga Sultan
Palace” located in Simferopol, Republic of Crimea, into the Register of identified cultural
heritage objects of the Republic of Crimea.
2. Establish the boundaries of the territory of the identified object of cultural (archeological)
heritage and the mode of usage of the land plot within whose boundaries the identified
object of cultural (archeological) heritage is located, according to the Annex to this Order
(not for publication).
3. Assign control over the implementation of this Order to Deputy Chairman of the State
Committee for the Protection of Cultural Heritage of the Republic of Crimea V.G.
Zarubin.
Chairman (signature) S.A. Efimov

Exhibit C
RAS Crimean Institute of Archeology, Research and planning documentation for the boundary
modification project in relation to the territory of newly discovered cultural heritage site “Urban
Area of Ak-Mosque, XVII - XVIII centuries (possible site of the Palace of Kalga-Sultan)”
(translation)

Annex 30 Exhibit C
Translation
RAS Crimean Institute of Archeology, Research and planning documentation for the boundary
modification project in relation to the territory of newly discovered cultural heritage site “Urban
Area of Ak-Mosque, XVII - XVIII centuries (possible site of the Palace of Kalga-Sultan)”.
FEDERAL STATE BUDGETARY RESEARCH INSTITUTION "CRIMEAN
INSTITUTE OF ARCHAEOLOGY OF THE RUSSIAN ACADEMY OF
SCIENCES"
Main State Registration Number 1159102130660 TIN 9102201070
RESEARCH AND PLANNING DOCUMENTATION
FOR THE BOUNDARY MODIFICATION PROJECT IN RELATION TO THE
TERRITORY OF
newly discovered cultural heritage site “Urban Area of Ak-Mosque, XVII - XVIII
centuries (possible site of the Palace of Kalga-Sultan)”.
Developed pursuant to
Resolution of the Ministry of
Culture of the Russian
Federation
No. 1745 dated 04 June 2015
1. Information on the site name:
"Urban Area of Ak-Mosque, XVII - XVIII centuries (possible site of the Palace of Kalga-
Sultan)".
2. Dating of the site:
XVII-XVIII centuries.
3. Location of the site (region, area, rural district, locality, peculiarities of the location):
19-23 Vorovskogo Street, city of Simferopol, the Republic of Crimea.
4. Brief description of the site (boundaries, composition of the cultural layer, major
finds, losses that have changed the original appearance of the site):
The territory of the cultural heritage site is wasteland in the mouth of Petrovskaya Balka
("Petrovskaya Ravine") located at 19-23 Vorovskogo Street. The wasteland is bounded to the
north by Vorovskogo Street and to the east and south by Petrovskaya Balka Street and to the
west by the cliffs of Petrovskiye Cliffs. The wasteland is a relatively flat site with numerous
traces of anthropogenic influence, which is explained by the existence of Simferopol Brewery
on this territory until the 80s of the XX century, when, following the construction of a new
beer and soft drinks plant, it was closed down and dismantled. Within the boundaries of the
Annex 30 Exhibit C
examined territory there are numerous potholes and cross-ditches, which formed as a result of
extraction of ferrous and non-ferrous metals by local residents, and a considerable amount of
construction and household waste. The terrain descends gently from south to north. In the
western part of the site, there is a water source (spring) in the wall, which may be identified as
the source for the fountain that existed in the territory of the Palace of Kalga-Sultan and
subsequently in the territory of the brewery. It is possible that the same spring is referred to as
"Petrovsky Fountain" in late written and graphic accounts.
Boundary coordinates of the cultural heritage site
Item
Coordinates (WGS-1984)
North latitude East longitude
Point 44.94822o 034.11666o
Point 2 44.94816o 034.11654o
Point 3 44.94812o 034.11644o
Point 4 44.94719o 034.11691o
Point 5 44.94717o 034.11705o
Point 6 44.94719o 034.11763o
Point 7 44.94724o 034.11800o
Point 8 44.94779o 034.11844o
Point 9 44.94844o 034.11689o
In June 2019, the Federal State Budgetary Research Institution "Crimean Institute of
Archaeology of RAS" conducted field archaeological studies to define more precisely the
boundaries of the newly discovered cultural heritage site "Urban Area of Ak-Mosque, XVII -
XVIII centuries (possible site of the Palace of Kalga-Sultan)" located at 19-23 Vorovskogo
Street, Simferopol.
Three pits were dug in the south-eastern part of the land plot located at 21a
Vorovskogo Street, Simferopol, with cadastral number 90:22:010223:118. The north-western
part of the land plot was occupied by tanks of the Simferopol Beer and Soft Drinks Plant.
Pit No. 1. (N44.947379o, E34.117632o). Was excavated one metre from the northeastern
boundary of the site and is oriented along the NE-SW line. Dimensions: 2x2 m, depth:
2.52 to 2.90 m. A (0.2 to 0.28 m) layer of dark grey loam containing limestone inclusions and
modern-day debris, tile fragments, sporadic fragments of glazed vessels, and isolated animal
bones, was found under the turf (of up 0.12 m). This layer is cut through by a 0.6m wide and
0.4m deep trench going down from the modern-day surface, which is oriented along the NESW
line and in which four iron water pipes were laying. Thin (0.02 m) interlayers of
limestone grit and light grey loam with large amounts of sand and modern-day debris (0.05
m) were discovered below. This level was overlapping layers of grey (0.42 to 0.6 m) and light
brown (0.05 to 0.4 m) loam containing isolated limestones, tile fragments, sporadic fragments
of pottery vessels, fragments of clay smoking pipes (2 items) and animal bones. Below, there
was a layer of limestone grit with sand clay (0.12 to 0.39 m) and, below that layer, light brown
Annex 30 Exhibit C
loam (0.38 to 0.59 m) with numerous fragments of roof tiles, fragmented ceramic smoking
pipes of the first quarter of the 19th century (3 pcs.), and small fragments of glass bottles. The
latter one was underlain by a layer of dark loam (0.12 to 0.44 m). In the stratigraphic
succession of N - E and N - W sides, contours of (0.38 to 0.45 m deep) holes dug from the
surface were detected, on which modern-day debris were found.
Pit No. 2. (N44.947258o E34.117715o). Was excavated 1m from the eastern boundary
of the site and is orientated along the NE-SW line. Dimensions: 2x2 m, depth: 2.68 to 2.9 m.
The top layer consists of dark soil with large amounts of modern-day construction and
household waste (0.12 to 0.20 m thick), which overlapped the buried turf (0.08 m) and a (0.24
to 0.28 m) layer of dark soil with modern-day debris overlying asphalt (0.12 m). Below the
asphalt, there were detected layers of light brown (0.12 to 0.14 m) and dark brown (0.16 m)
loam. Below them, there were layers of sandy loam with small inclusions of limestone (0.10
to 0.18 m), light yellow (0.7 to 0.12 m) and dark loam with limestone grit (0.12 to 0.22 m),
dark loam with small tile fragments (0.6 to 0.78 m), dark soil with limestone grit (0.08 to 0.10
m), grey loam (0.30 to 0.32 m) with limestone grit, fragments of 19th century glass bottles, a
fragment of a ceramic smoking pipe, a layer of limestone grit (0.04 to 0.06 m), dark soil (0.20
to 0.36 m). A 0.28 m wide trench was dug in the latter, in which a 0.12 m diameter ceramic
water pipe had been laid (which was oriented along the NW-SE line). The joints of the pipe
sections were coated with lime mortar. There were small limestones around the pipe and (0.08
m) fine limestone filler below the pipe in the trench.
Pit No. 3 (N44.947241o, E34.117571o). Was excavated 4.7 m from the eastern
boundary of the site and is oriented along the NE-SW line. Dimensions: 2x2 m, depth: 3.91
m to 4.05 m. Under (0.14 to 0.2 m thick) asphalt, layers of dark grey loam (0.12 to 0.2 m),
light sandy clay with crushed stone and limestone grit (0.37 to 0.38 m), and brown loam (0.88
to 0.98 m) were lying sequentially. Those layers contained modern-day rubbish and small
fragments of tiles. Below, a (1.18 to 1.42 m) layer of brown clay loam with tile fragments and
fragments of pottery vessel walls covered with dark green glaze (2 items) was lying. Under
that layer, there was dark brown homogeneous soil (0.88 to 0.91). A fragment of ceramic
pipe, 0.12 m in diameter, was recorded in the northern face at a depth of 2.51 m. In the
southern side wall, a 0.58 m wide and 1.94 m deep trench oriented along the NW-SE line was
discovered, which had been dug from the surface overlain by asphalt. Isolated large
limestones were found in the trench. Modern-day rubbish was found in the trench fill and
between masonry stones. A 1.3m deep and 1.2 m wide hole with a massive concrete base of
a structure was discovered in the north-eastern side wall.
Proceeding from the pitting conducted in 2019, it can be argued that no remains of
structures dating earlier than the first half of the XX century were found on the land plot
located at 21a Vorovskogo Street, Simferopol, with cadastral number 90:22:010223:118. The
only remains of the cultural layer of the end of XVIII - first half of XIX century are some
fragments strongly mixed with rubbish of the first half of the XX century. These fragments
of the cultural layer in Pit 5 of 2017 and Pits 1 through 3 of 2019 were examined in their
entirety.
Based on archival data and the 2019 pitting, the area of the land plot located at 21a
Vorovskogo Street, Simferopol, with cadastral number 90:22:010223:118, can be excluded
Annex 30 Exhibit C
from the territory of the newly discovered cultural heritage object "Urban Area of Ak-
Mosque, XVII - XVIII centuries (possible site of the Palace of Kalga-Sultan)".
The turning point coordinates of the land plot located at
21a Vorovskogo Street, Simferopol, cadastral number 90:22:010223:118
*Urban development plan of the land plot
Annex 30 Exhibit C
Proposed coordinates of the cultural heritage site boundaries
Item
Coordinates (WGS-1984)
Northern latitudes East longitude
Point 1 44.94822o 034.11666o
Point 2 44.94816o 034.11654o
Point 3 44.94812o 034.11644o
Point 4 44.94719o 034.11691o
Point 5 44.94717o 034.11705o
Point 13 44.56502o 034.07279o
Point 14 44.56507o 034.07175o
Point 10 44.56512o 034.07225o
Point 11 44.56505o 034.07374o
Point 12 44.56504o 034.07402o
Point 6 44.94719 o 034.11763o
Point 7 44.94724o 034.11800o
Point 8 44.94779o 034.11844o
Point 9 44.94844o 034.11689o
Modified area of the newly discovered cultural heritage (archaeological) site is 12, 681
square metres.
Proposed description of the cultural heritage site boundaries
Beginning of section End of section Distance (m)
Point 1 Point 2 14
Point 2 Point 3 19
Point Z Point 4 101
Point 4 Point 5 19
Point 5 Point 13 16.19
Point 13 Point 14 27.12
Point 14 Point 10 19.83
Point 10 Point 11 43.13
Point 11 Point 12 3.07
Point 12 Point 6 17.87
Point 6 Point 7 29
Point 7 Point 8 70
Point 8 Point 9 144
Point 9 Point 1 22
The proposed total perimeter of the newly discovered cultural heritage (archaeological) site
territory boundary is 324 m.
Annex 30 Exhibit C
Boundaries of the cultural heritage site "Urban Area of Ak-Mosque, XVII - XVIII
centuries (possible site of the Palace of Kalga-Sultan)" and boundaries of the land plot
territory to be excluded from the territory of the cultural heritage site
Director of FSBIS "RAS Crimean Institute of Archaeology" V. V. Mayko
Annex 30 Exhibit C

Exhibit D
RAS Crimean Institute of Archeology, Report of V.V. Masyakin on archaeological explorations
in the territory of the newly discovered cultural heritage site “Urban Area of Ak-Mosque, XVII -
XVIII centuries (possible site of the Palace of Kalga-Sultan)” at 21 Vorovskogo Street, city of
Simferopol, the Republic of Crimea in 2019
(excerpt, translation)

Annex 30 Exhibit D
Extract
Translation
RAS Crimean Institute of Archeology, Report of V.V. Masyakin on archaeological
explorations in the territory of the newly discovered cultural heritage site "Urban Area of
Ak-Mosque, XVII - XVIII centuries (possible site of the Palace of Kalga-Sultan)" at 21
Vorovskogo Street, city of Simferopol, the Republic of Crimea in 2019.
FEDERAL STATE BUDGETARY RESEARCH INSTITUTION
"CRIMEAN INSTITUTE OF ARCHAEOLOGY OF THE RUSSIAN ACADEMY OF
SCIENCES"
Approved by
Institute Director _________
V. V. Mayko
V. V. Masyakin
REPORT
on archaeological explorations in the territory of the newly discovered
cultural heritage site "Urban Area of Ak-Mosque, XVII - XVIII centuries
(possible site of the Palace of Kalga-Sultan)" at 21 Vorovskogo Street, city of
Simferopol, the Republic of Crimea in 2019
(Archaeological Excavation Permit No. 0600-2019)
Annex 30 Exhibit D
Simferopol, 2019
ABSTRACT
V. V. Masyakin. Report on archaeological reconnaissance on the territory of
the newly discovered cultural heritage site "Urban Area of Ak-Mosque, XVII -
XVIII centuries (possible site of the Palace of Kalga-Sultan)" at 21 Vorovskogo
Street, city of Simferopol, the Republic of Crimea, in 2019.
The report contains the results of archaeological reconnaissance (pitting) on
the territory of the newly discovered cultural heritage site "Urban Area of Ak-
Mosque, XVII - XVIII centuries (possible site of the Palace of Kalga-Sultan)" at 21
Vorovskogo Street, city of Simferopol, the Republic of Crimea, which were
conducted in June and October 2019. A total of 7 pits with a total area of 20 sq. m.
were explored. The purpose of the reconnaissance was to define more precisely the
boundaries of the newly discovered cultural heritage site "Urban Area of Ak-
Mosque, XVII - XVIII centuries (possible site of the Palace of Kalga-Sultan) located
at 19-23 Vorovskogo Street, Simferopol.
Annex 30 Exhibit D
3
TABLE OF CONTENTS
ABSTRACT.............................................................................................................................2
TABLE OF CONTENTS ......................................................................................................3
INTRODUCTION...................................................................................................................4
Brief historical and geographical information..............................................................5
Description of the area under study......... ...... ...............................................................6
ARCHAEOLOGICAL STUDIES (PITS 1 THROUGH 7) ..................................................8
Archaeological research (pitting) on the land plot located at 21a Vorovskogo Street,
Simferopol, with cadastral number
90:22:010223:118.......................................................................................................................8
Archaeological reconnaissance (pitting) on the land plot at Vorovskogo Street, near house
number 21, Simferopol, with cadastral number
90:22:010223:590.......................................................................................................................8
CONCLUSION.......................................................................................................................13
List of references.....................................................................................................................13
Annex 1. Storage of finds certificate and items acceptance report...........................................14
Field inventory of finds..............................................................................................................14
Collection inventory of finds...................................................................................................16
Illustrations.................................................................................................................................17
Archaeological excavation permit.............................................................................................58
Annex 30 Exhibit D
4
INTRODUCTION.
In June 2019, under Contract No. 58 dated 25 June 2018 entered into between
O. S. Shayarliyev, citizen of Russia, and FSBRI "Crimean Institute of Archaeology
of the RAS", pursuant to Archaeological Excavation Permit No. 0600-2019 issued
on 31 May 2019 in the name of a junior researcher of the Institute, V. V. Masyakin,
field archaeological studies were carried out to define more precisely the boundaries
of the newly discovered cultural heritage site "Urban Area of Ak-Mosque, XVII -
XVIII centuries (possible site of the palace of Palace of Kalga-Sultan) located at 19-
23 Vorovskogo Street, Simferopol.
In October 2019, under Contract No. 137 dated 02 September 2019 entered
into between S. V. Suvorova, citizen of Russia, and FSBRI "Crimean Institute of
Archaeology of the RAS", archaeological studies were carried out in the territory of
the land plot located at 21 Vorovskogo Street, Simferopol, cadastral number
90:22:010223:590, with an area of 1,000 square meters.
The employees of the FSBRI "Crimean Institute of Archaeology of the RAS"
V. V. Masyakin, A. S. Devaev, A.A. Lysenko, A.E. Masyakin, A.S. Devaev, V.A.
Lysenko, A.E. Solomonenko, and V. A. Tikhomirov took part in the works. The
elevations are given in the Baltic Height System.
Annex 30 Exhibit D
5
BRIEF HISTORICAL AND GEOGRAPHICAL
INFORMATION
As a result of archival and bibliographic research the following information
regarding the territory under study was gathered.
The historical sources containing information about the palace of Palace of
Kalga-Sultan are quite numerous. Among them, of particular interest are descriptions
of those writers who were in Crimea themselves. The palace of Palace of Kalga-
Sultan was described by such writers as Evliya Chelebi, Charles de Peyssonnel, Abri
de la Motere, Christophe Manstein and others. Much was written about the palace
by later authors.
One of the earliest mentions of the palace, dating from the first half of the 17th
century, belongs to a Dominican monk, Jean de Luc, who visited the Crimea in 1625
(or 1633). He notes: "The Khan has five palaces, the Sultan (i.e. Kalga-Sultan
(translator's note)) has two. The palaces of the Sultan (i.e. Kalga Sultan) are in the
Ak-Mosque".
The information of the famous Turkish traveller of the 17th century Evliya
Celebi, who devoted a separate chapter to the Palace of Kalga-Sultan in his "Book
of Travels", is rather valuable. According to him, the palace complex had "200 twostorey
buildings made of stone, with kyuryunyusha (chambers for the Divan
meetings - ed.), with bright and luxurious rooms. The palace, though, was not as
splendidly appointed and decorated as the khan's palace in Bakhchisaray. In the wide
square of this palace there is a mosque with one minaret". The mosque was named
after its builder, the Crimean Khan Mengli Giray, it was not big, covered with tiles,
with one stone minaret of the old design.
Noteworthy is the mention of the palace made by a Russian official in 1787:
"The Great Palace of Kalga-Sultan is not itself big in size and is occupied by our
soldiers, who have already managed to destroy some of the fountains decorating his
palace, and cut down trees. Behind the fence of the palace there was a fountain which
flowed out of a solid stone wall, and further away there were squalid tiny houses of
Tartars. Behind the Palace of Kalga-Sultan, not far from Salgir, there is a cemetery
with a white fence in the midst of it and canopy with a green sign above the fence,
under which a mullah is sitting all day long whispering prayers in honour and glory
of some saint buried here".
Sometime later, in the first half of the 19th century, the location of the former
Palace of Kalga-Sultan was indicated on the plans by Blaramberg and Dubois de
Monpere.
Annex 30 Exhibit D
6
Subsequent researchers wrote the following about the palace: "Near the rock
itself, above the Petrovsky fountain, and near the road, the brewery of Weisbord
stands. <...> on this spot, where the brewery now is, was formerly the Palace of
Kalga-Sultan". There is also a handwritten plan of the site showing "Sultan Saray"
with "Weisbord brewery" located there.
Thus, the former Weisbord brewery, later the Simferopol Brewery, which was
located at 21 Vorovskogo Street, was one of the landmarks indicating the palace
location. According to the recollections of the brewery workers, they were stunned
by huge cellars, which had remained actually untouched by the destruction of the
factory premises during the liquidation of the brewery.
Of particular note are the cartographic data obtained by the Museum of the
History of Simferopol from the military archives and provided to the Crimean
Institute of Archaeology of the Russian Academy of Sciences for examination.
The territory of the studied land plots located at 21-21a Vorovskogo Street,
Simferopol, is within the boundaries of the territory of the newly discovered cultural
heritage site "Urban Area of Ak-Mosque, XVII - XVIII centuries (possible site of
the Palace of Kalga-Sultan)". The boundaries of this cultural heritage site located at
19-23 Vorovskogo Street, Simferopol, were determined on the basis of
archaeological reconnaissance involving pitting carried out in November 2017 by a
joint archaeological expedition of FSBRI "Crimean Institute of Archaeology of the
RAS" and State-Funded Educational Institution "Crimean Engineering and
Pedagogical University" led by E. I. Seydaliev.
A DESCRIPTION OF THE AREA UNDER STUDY
The territory of the cultural heritage site is wasteland in the mouth of
Petrovskaya Balka ("Petrovskaya Ravine") located at 19-23 Vorovskogo Street. The
wasteland is bounded to the north by Vorovskogo Street and to the east and south by
Petrovskaya Balka Street and to the west by the cliffs of Petrovskiye Cliffs. The
wasteland is a relatively flat site with numerous traces of anthropogenic influence,
which is explained by the existence of Simferopol Brewery on this territory until the
80s of the XX century, when, following the construction of a new beer and soft
drinks plant, it was closed down and dismantled. Within the boundaries of the
examined territory there are numerous potholes and cross-ditches, which formed as
a result of extraction of ferrous and non-ferrous metals by local residents, and a
considerable amount of construction and household waste. The terrain descends
gently from south to north. In the western part of the site, there is a water source
(spring) in the wall, which may be identified as the source for the fountain that
existed in the territory of the Palace of Kalga-Sultan and subsequently in the territory
Annex 30 Exhibit D
7
of the brewery. It is possible that the same spring is referred to as "Petrovsky
Fountain" in late written and graphic accounts.
The boundaries of the cultural heritage site located at 19-23 Vorovskogo
Street, Simferopol, were determined on the basis of archaeological reconnaissance
involving pitting carried out in November 2017 by a joint archaeological expedition
of FSBRI "Crimean Institute of Archaeology of the RAS" and State-Funded
Educational Institution "Crimean Engineering and Pedagogical University" led by
E. I. Seydaliev.
Pursuant to Order of the State Committee for the Protection of Cultural
Heritage of the Republic of Crimea No. 41 dated 27 March 2018, the cultural
heritage site "Urban Area of Ak-Mosque, XVII - XVIII centuries (possible site of
the Palace of Kalga-Sultan)" was included in the list of newly discovered cultural
heritage sites of the Republic of Crimea.
In September 2018, the FSBRI "Crimean Institute of Archaeology of the RAS"
received archival materials consisting of a land plot development plan in relation to
the land plot allocated to Simferopol Beer and Soft Drinks Plant "Krymbrodtrest",
which was prepared on 30 June 1952 by Bystritsky, surveying engineer of
Simferopol OKH. According to the plan, there were tanks "M" and "L" and an
unsheltered warehouse of the brewery on the territory of the land plot with cadastral
number 90:22:010223:118 at 21a Vorovskogo Street. Those structures, as per the
plan, were occupying a large part of the land plot with cadastral number
90:22:010223:118. In the immediate vicinity of the land plot, there were tanks "K",
"I", "P", a shed and site No. 1 of the brewery (Fig. 3).
The land improvement works carried out by the owner of the land plot with
cadastral number 90:22:010223:118 in the second half of September 2018 confirmed
that remains of the brewery's ruined cistern "L", divided by partitions into several
sections, were present in the north-western part of the land plot. In the course of the
works, a completely preserved tank "M" abutting tank "L" was found.
On 26 and 27 February 2019, the owner of the land plot performed further
land improvement works on their land plot at 21a Vorovskogo Street, cadastral
number 90:22:010223:118, for the purpose of soil movement. The examination of
the land plot made on 28 February 2019 revealed that the two ruined brewery tanks
previously discovered in the western part of the land plot had been extracted from
the ground using an excavator and a crane (Fig.4). Furthermore, another similar tank
was found in the central part of the land plot, which had also been extracted from the
ground. In the northern and southern parts of the land plot, ground had been levelled
to a depth of 3.10 m, the base of all three found brewery tanks, using earthmoving
equipment. The displaced soil is grey loam with construction and household debris,
Annex 30 Exhibit D
8
asphalt and small stones. No archaeological finds were discovered on visual
inspection of the entire displaced soil.
ARCHAEOLOGICAL STUDIES (PITTING) ON THE LAND PLOT
LOCATED AT 21 VOROVSKOGO STREET, SIMFEROPOL, CADASTRAL
NUMBER 90:22:010223:118.
In June 2019, under Contract No. 58 dated 25 June 2018 between O. S.
Shayarliyev, citizen of the Russian Federation, and FSBRI "Crimean Institute of
Archaeology of the RAS", pursuant to Archaeological Excavation Permit No. 0600-
2019 issued on 31 May 2019 in the name of a junior researcher of the Institute, V.
V. Masyakin, field archaeological studies were carried out to define more precisely
the boundaries of the newly discovered cultural heritage site "Urban Area of Ak-
Mosque, XVII - XVIII centuries (possible site of the Palace of Kalga-Sultan) located
at 19-23 Vorovskogo Street, Simferopol.
Three 2 x 2 m pits were dug in the south-eastern part of the land plot located
at 21a Vorovskogo Street, Simferopol, with cadastral number 90:22:010223:118.
The north-western part of the land plot was occupied by tanks of the Simferopol Beer
and Soft Drinks Plant, which made the digging of pits there impossible (Fig. 1; 2;
and 5).
Pit No. 1. (N44.947379o, E34.117632o). Was excavated one metre from the
north-eastern boundary of the site and is oriented along the NE-SW axis.
Dimensions: 2x2 m, depth: 2.52 to 2.90 m. A (0.2 to 0.28 m) layer of dark grey loam
containing limestone inclusions and modern-day debris, tile fragments, sporadic
fragments of glazed vessels, and isolated animal bones, was found under the turf (of
up 0.12 m). This layer is cut through by a 0.6m wide and 0.4m deep trench going
down from the modern-day surface, which is oriented along the NE-SW axis and in
which four iron water pipes were laying. Thin (0.02 m) interlayers of limestone grit
and light grey loam with large amounts of sand and modern-day debris (0.05 m) were
discovered below. This level was overlapping layers of grey (0.42 to 0.6 m) and light
brown (0.05 to 0.4 m) loam containing isolated limestones, tile fragments, sporadic
fragments of pottery vessels, fragments of clay smoking pipes (2 items) and animal
bones. Below, there was a layer of limestone grit with sand clay (0.12 to 0.39 m)
and, below that layer, light brown loam (0.38 to 0.59 m) with numerous fragments
of roof tiles, fragmented ceramic smoking pipes of the first quarter of the 19th
century (3 pcs.), and small fragments of glass bottles. The latter one was underlain
by a layer of dark loam (0.12 to 0.44 m). In the stratigraphic succession of N - E and
Annex 30 Exhibit D
9
N - W sides, contours of (0.38 to 0.45 m deep) holes dug from the surface were
detected, on which modern-day debris were found.
Pit No. 2. (N44.947258o E34.117715o). Was excavated 1m from the eastern
boundary of the site and is orientated along the NE-SW axis. Dimensions: 2x2 m,
depth: 2.68 to 2.9 m. The top layer consists of dark soil with large amounts of
modern-day construction and household waste (0.12 to 0.20 m thick), which
overlapped the buried turf (0.08 m) and a (0.24 to 0.28 m) layer of dark soil with
modern-day debris overlying asphalt (0.12 m). Below the asphalt, there were
detected layers of light brown (0.12 to 0.14 m) and dark brown (0.16 m) loam. Below
them, there were layers of sandy loam with small inclusions of limestone (0.10 to
0.18 m), light yellow (0.7 to 0.12 m) and dark loam with limestone grit (0.12 to 0.22
m), dark loam with small tile fragments (0.6 to 0.78 m), dark soil with limestone grit
(0.08 to 0.10 m), grey loam (0.30 to 0.32 m) with limestone grit, fragments of 19th
century glass bottles, a fragment of a ceramic smoking pipe, a layer of limestone grit
(0.04 to 0.06 m), dark soil (0.20 to 0.36 m). A 0.28 m wide trench was dug in the
latter, in which a 0.12 m diameter ceramic water pipe had been laid (which was
oriented along the NW-SE axis). The joints of the pipe sections were coated with
lime mortar. There were small limestones around the pipe and (0.08 m) fine
limestone filler below the pipe in the trench.
Pit No. 3. (N44.947241o, E34.117571o). Was excavated 4.7 m from the eastern
boundary of the site and is oriented along the NE-SW axis. Dimensions: 2x2 m,
depth: 3.91 m to 4.05 m. Under (0.14 to 0.2 m thick) asphalt, layers of dark grey
loam (0.12 to 0.2 m), light sandy clay with crushed stone and limestone grit (0.37 to
0.38 m), and brown loam (0.88 to 0.98 m) were lying sequentially. Those layers
contained modern-day rubbish and small fragments of tiles. Below, a (1.18 to 1.42
m) layer of brown clay loam with tile fragments and fragments of pottery vessel
walls covered with dark green glaze (2 items) was lying. Under that layer, there was
dark brown homogeneous soil (0.88 to 0.91). A fragment of ceramic pipe, 0.12 m in
diameter, was recorded in the northern face at a depth of 2.51 m. In the southern side
wall, a 0.58 m wide and 1.94 m deep trench oriented along the NW-SE axis was
discovered, which had been dug from the surface overlain by asphalt. Isolated large
limestones were found in the trench. Modern-day rubbish was found in the trench
fill and between masonry stones. A 1.3m deep and 1.2 m wide hole with a massive
concrete base of a structure was discovered in the north-eastern side wall.
FINDINGS
Annex 30 Exhibit D
10
Thus, the stratigraphic picture is the same in all of the pits. In addition to a
layer of twentieth-century construction debris, an interlayer containing isolated finds
from the first half of the 19th century was discovered. Below, there is a thick layer
of dark brown homogenous soil to a depth of 4.5 m in pit 3 containing isolated finds
from the first half of the XIX century.
Based on the archaeological studies conducted in 2019, it can be argued that
no remains of structures dating earlier than the first half of the XX century were
found on the land plot located at 21a Vorovskogo Street, Simferopol, cadastral
number 90:22:010223:118. The only remains of the cultural layer of the end of the
XVIII - first half of the XIX century are some fragments strongly mixed with rubbish
of the first half of the XX century. These fragments of the cultural layer in Pit 5 of
2017 and Pits 1 through 3 of 2019 were examined in their entirety. Pit 1 contained
fragments of tiles and pottery from the first and second half of the XIX century and
three smoking pipes from the first half of the XIX century. Pit 2 contained fragments
of pottery, including faience pottery from the first and second half of the XIX century
and a fragment of a smoking pipe from the first half of the XIX century. Pit 3
contained fragments of tiles, pottery and glass from the second half of the XIX
century – early XX century.
Thus, based on the geological situation in pits 1 through 3 of 2019 and in view
of the lack of archaeological remains or cultural layer of the XVII-XVIII centuries,
it can be argued that there are no structures or cultural layer associated with the newly
discovered cultural heritage site "Urban Area of Ak-Mosque, XVII - XVIII centuries
(possible site of the Palace of Kalga-Sultan)" on the land plot located at 21a
Vorovskogo Street, Simferopol, cadastral number 90:22:010223:118. On the basis
of the archival data found, in the first instance, the land plot development plan in
relation to the land plot allocated to Simferopol Beer and Soft Drinks Plant
"Krymbrodtrest" in 1952, it was established that brewery tanks were located on the
territory of the land plot.
ARCHAEOLOGICAL RECONNAISSANCE ON THE LAND PLOT WITH
CADASTRAL NUMBER 90:22:010223:590 AT VOROVSKOGO STREET,
NEAR HOUSE 21
In October 2019, four pits were dug on the territory of the land plot with
cadastral number 90:22:010223:590 located at Vorovskogo Street, near house
number 21. The numbering of the pits continues that of the previous ones.
Pit No. 4. (N44°56.869', E034°07.023') (Figure 32-34). Located 10 m from
the northern boundary and 13 m from the western boundary of the site and oriented
Annex 30 Exhibit D
11
along the N-S axis. Dimensions: 2x1m, depth: 2.2 to 2.3m. A (up to 0.3 m) layer of
modern-day construction debris lies under the turf (up to 0.12 m deep), and below
it there is part of the foundation of a building made of limestone blocks and shell
rock, with remnants of concrete and plaster and vertically directed metal utility pipes.
The interior space of the building is the brewery's basement filled with a massive
pile of construction debris.
Pit No. 5. (N44°56.861', E034°07.0263') (Figure 35-37). Located 0.5 m from
the northern boundary and 14 m from the western boundary of the site and oriented
along the N-S axis. Dimensions: 2x1m, depth: 1.2 to 1.4m. Under the turf (up to
0.3m deep), a pile of construction debris was found, consisting of blocks of
limestone, shell rock, bricks, and concrete, which filled one of the brewery's
underground premises.
Pit No. 6. (N44°56.866', E034°07.016') (Figures 38-46). Located 0.5 m from
the northern boundary and 1.5 m from the western boundary of the site and oriented
along the N-S axis. Dimensions: 2x1m, depth: 1.7 to 1.76m. A layer of modern-day
construction debris (0.6 to 0.12 m), consisting mainly of shell fragments, was found
under the turf (up to 0.2 m thick) and below it there is grey ash layer (0.56 to 0.8 m)
with lenses of burnt debris, limestone inclusions, small fragments of tiles and glass
bottle fragments. Water supply and sewerage metal pipes are laid in this layer. Below
that layer there are layers of dark brown loam (0.11 to 0.2 m) with coals and tile
fragments. Further below, there is a layer of light brown loam (0,36 to 0,7 m), in
which fragments of tiles and pottery, a shot glass, a poorly preserved small coin or
pendant of white metal (disintegrated during cleaning), and a fragment of a glass
bracelet were found. A 0.3 m wide trench was dug in that layer, in which a 0.12 m
diameter ceramic water pipe had been laid (which was oriented along the NE-SW
axis). The joints of the pipe sections were coated with lime mortar. One of the section
of the water supply pipe was discovered nearby.
Pit No. 7. (N44°56.858', E034°07.017') (Figure 47-50). Located 18 m from
the northern boundary and 5 m from the western boundary of the site and oriented
along the N-S axis. Dimensions: 2x1m, depth: 2 to 2.20m. Interlayers of lime and
burnt modern-day debris (0.9 to 0.14 m), pebbles (0.2 to 0.22 m), and burnt clay
(0.2 to 0.14 m) were under the turf (up to 0.12 m thick). Below them, there was a
grey ash layer (0.6 to 0.68 m) with thin interlayers of brown loam and inclusions of
limestone containing small fragments of tiles. Further below, there were layers of
light brown loam with ashy lenses (0.6 to 0.75 m) and dark brown loam (0.14 to 0.25
m) containing tile fragments. In the northern and southern parts of the pits, at a depth
of 0.5 m, 1.1 m thick masonry from limestone was discovered, probably forming a
corner of a building orientated along the NW-SE axis. Fragments of shell rock and
Annex 30 Exhibit D
12
tiles with lime mortar are found among the masonry stones and below. Further
below, at a depth of 2.08 m, a 0.28 m wide and 0.12 m high slab (part of the
masonry?) oriented along the NE-SW axis was identified. Near the slab, remains of
a causeway made of thin tiles, with traces of burning on the surface, were found. A
large part of the causeway had been destroyed by a late intrusion into the layer.
FINDINGS
In October 2019, the FSBRI "Crimean Institute of Archaeology of the RAS"
conducted field archaeological studies to define more precisely the boundaries of the
newly discovered cultural heritage site "Urban Area of Ak-Mosque, XVII - XVIII
centuries (possible site of the Palace of Kalga-Sultan) located at 19-23 Vorovskogo
Street, Simferopol.
The archaeological studies were carried out pursuant to Archaeological
Excavation Permit No. 0600-2019 issued on 31 May 2019 in the name of a junior
researcher of the Institute, V. V. Masyakin.
Four pits were dug on the territory of the land plot located at Vorovskogo
Street, near house number 21, Simferopol, cadastral number 90:22:010223:590.
The stratigraphic picture is the same in pits 1, 2, and 4. In addition to a layer
of XX century construction debris, there is a layer containing fragments of Tartar
tiles from the first half of the XX century, isolated fragments of ceramics from the
second half of the XIX century and isolated fragments of glass vessels from the
second half of the XIX and first half of the XX century. Fragments of building walls
made of limestone blocks and shell rock, with remnants of concrete and plaster are
located below. Metal utility pipes were found throughout the depth of the pits. The
interior space of the buildings is the brewery's underground premises containing
massive piles of construction debris.
In Pit 3, below a layer of XX century construction rubble and a layer of dark
brown loam with charcoal and tile fragments, there was found a section of a cultural
layer heavily damaged by excavations of the second half of the XX century,
containing fragments of tiles and pottery, as well as other finds, and a section of a
ceramic water pipe, which can be dated to the late XVIII - first half of the XIX
century. This part of the cultural layer was studied in its entirety throughout Pit 3.
Based on the pitting conducted in 2019, it can be argued that no remains of
structures dating earlier than the first half of the XX century were discovered on the
land plot located at Vorovskogo Street, near house number 21, Simferopol, cadastral
Annex 30 Exhibit D
13
number 90:22:010223:590. The only remains of the cultural layer from the end of
the XVIII - first half of the XIX century are isolated fragments strongly mixed with
rubbish of the second half of the XX century, which were found in pit 3 in the northwest
corner of the land plot allotted.
Given that a fragment of damaged cultural layer of the end of XVIII - first half
of XIX century was found on the territory of the land plot with cadastral number
90:22:010223:590, archaeological monitoring would be required in case
construction work are carried out.
CONCLUSION
In 2019, the FSBRI "Crimean Institute of Archaeology of the RAS" conducted
field archaeological studies to define more precisely the boundaries of the newly
discovered cultural heritage site "Urban Area of Ak-Mosque, XVII - XVIII centuries
(possible site of the Palace of Kalga-Sultan) located at 19-23 Vorovskogo Street,
Simferopol. Seven pits with a total area of 20 sq. m were studied on two land plots
with the cadastral numbers 90:22:010223:118 and 90:22:010223:590. A large part
of the territory is occupied by a layer of ruined structures of the brewery from the
XX century. A fragment of a damaged cultural layer of the end of the XVIII - first
half of the XIX century was discovered on the territory of the land plot with the
cadastral number 90:22:010223:590. No remains of structures dating earlier than the
first half of the XIX century were identified.
LIST OF REFERENCES
Abdulvapov N. The Territory of the Palace of the Crimean Kalga-Sultan and
the Mosque of Mengli Giray // Collection of Historical, Architectural and Cultural
Monuments of the Crimean Tatars. Vol. 3. Simferopol, 2018.
Seydaliev E. I. Reconnaissance on the supposed site of the Palace of Kalga-
Sultan in Simferopol // IAK. Vol. VIII, 2018.

Annex 31
Witness Statement of , 3 March 2023
(translation)

Annex 31
INTERNATIONAL COURT OF JUSTICE
APPLICATION OF THE INTERNATIONAL CONVENTION
FOR THE SUPPRESSION OF THE FINANCING OF TERRORISM AND
INTERNATIONAL CONVENTION ON THE ELIMINATION OF
ALL FORMS OF RACIAL DISCRIMINATION
(UKRAINE V. RUSSIAN FEDERATION)
WITNESS STATEMENT OF
3 MARCH 2023
Annex 31
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Annex 31
Page 3 out of 9
1. My name is
(hereinafter, “KFU”).
2.
3. I have taught the Ukrainian language at different levels of education: school, teacher
training college and university. In 2007, I completed m
4. I was asked to talk about the teaching process at the Department of Ukrainian Philology
at KFU and extracurricular activities related to the Ukrainian language.
5. The Department of Ukrainian Philology is part of the Institute of Philology. The
Department provides Education for Bachelors by programme 45.03.01 Philology (the
Ukrainian Language and Literature) and for Masters by programme 45.04.01 Philology
(the Ukrainian philology in cross-cultural interaction). The curricula include such
disciplines as Modern Ukrainian Language, History of Ukrainian Literature, History of
Ukrainian Language, Methods of Teaching Ukrainian Language, Oral Folk Art,
Crimean Motifs in Ukrainian Literature, etc.
6. Our institute is provided with everything necessary for teaching students the Ukrainian
language, including classrooms and textbooks.
7. About 15 students annually enroll in Ukrainian Philology programmes for Bachelor’s
programmes (according to the State order) and 5-10 students for Master’s programmes.
The competition for admission is 1.1-1.2 students per place. At the same time, if the
university management sees an increased demand for our Department programmes, it
tries not to refuse to enroll more students for studies on a budgetary basis1 and often
finds a way to accommodate applicants, especially those with good grades and personal
achievements.
1 Studying on a budgetary basis means that the student does not have to pay tuition fees, as they are paid from
the state budget.
Annex 31
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8. After graduation, most of our students stay to work in Crimea, some become teachers of
native language and Russian language and literature in schools.
9. As for research activities, the Department is alternately recruiting postgraduate students
in the fields of Slavic Language and Literature of Foreign Countries (Ukrainian
Literature). Scientific personnel at the Department are engaged in a variety of problems
related to the Ukrainian language and literature: problems of phraseology, literary
comparativism (the study of Ukrainian-Russian literary relations), the study of the pages
of life and works of Ukrainian writers, the coverage of the Crimean motifs in Ukrainian
literature. The Department is currently developing a research theme “Ukrainian
Philology in a Multicultural Communicative Space”.
10. I would like to emphasise that most of teachers have degrees.
11. The Department is an active organiser of various scientific events. In particular,
together with the Department of Ukrainian Philology at the Faculty of Philology of
KIPU named after Fevzi Yakubov and the Shevchenko Library, we organise a scientific
and practical conference “Taras Shevchenko i Syogodennya” (Taras Shevchenko and
the Present). On 10 March 2022, it was held for the twelfth time.2 I am posting photos
from the event below.
2 Library – branch No. 7 n.a. T. Shevchenko, Events dedicated to T. Shevchenko (2022), available at:
https://libsevchenko.nethouse ru/page/1081880 (Exhibit A).
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Annex 31
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12. I want to mention also literary readings “Aleksandr Gubar and Petr Kyrychek -
Chroniclers of Crimean Ukrainian Literature”, 3 scientific and practical conference
“Genre and Style Specificity of Ukrainian Poetry of the ХХth - Early ХХIst Century",4
other conferences dedicated to the Ukrainian writers (Lesya Ukrainka, for instance).5 I
am also posting photos from these events below.
Conference “Aleksandr Gubar and Petr Kyrychek - Chroniclers of Crimean Ukrainian
Literature”
3 Tavrida Academy, In memory of the chroniclers of Ukrainian literature in Crimea (31 October 2019), available
at: https://ta.cfuv ru/ru/news/6170 (Exhibit B).
4 Tavrida Academy, Conference “Genre and Stylistic Specificity of Ukrainian Poetry of the XXth - Early XXIst
Centuries” (6 April 2018), available at: https://ta.cfuv.ru/ru/news/4727 (Exhibit C).
5 Tavrida Academy, Scholars discuss the work of Lesya Ukrainka and other modern writers and artists (8
October 2019), available at: https://ta.cfuv ru/ru/news/6065 (Exhibit D).; Tavrida Academy, XVII Scientific and
Practical Conference Dedicated to the Works of Lesya Ukrainka (1 November 2018), available at:
https://ta.cfuv.ru/ru/news/5344 (Exhibit E).
Annex 31
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Conference “Genre and Stylistic Specificity of Ukrainian Poetry of the XX - Beginning
of the ХХI Century”
Annex 31
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Conferences on the work of Lesya Ukrainka
13. Having become a structural part of the Institute of Philology, the Department of
Ukrainian Philology is a permanent and active participant in international events
organised by the Institute, such as the VII International Interdisciplinary Scientific
Conference “Convergent Technologies XXI: Variability, Combinatorics,
Communication” (25-26 November 2022).
14. Within the Days of Academic and Scientific Mobility of Students, held in 2020, the
staff of our Department, including myself, held a student forum “Literary Criticism and
Linguacultural Aspects of Work on the Text (on the Example of Ukrainian Literature
and Language). Literary and Cultural Aspects”.
15. Students with an active interest in the Ukrainian language can express themselves in
various extra-curricular activities where they can demonstrate their language skills.
16. For example, I would like to mention the translation competition “Varietasdelectat”, in
which students competed in the quality of translation of poetry in Russian, Ukrainian,
Belarusian, Bulgarian, Crimean Tatar, Polish and Czech. and were awarded prizes.
Annex 31
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17. students are regular participants and winners of the Crimean recitation competition
“On the Main Thing in your Native Language" (held in the village of Simeiz).
18. The high quality of teaching Ukrainian at our Department is confirmed by the success
of our students at major student events. At the III All-Russian Student Forum of the
state languages of the Republic of Crimea with international participation, students of
our Department won eight prizes. They also performed excellently at the Republican
Scientific-Practical Conference “Scientific Research in the Modern Realities of
Crimea”.
19. students do not limit themselves to philology, but also attend cultural events, such
as an annual workshop on traditional Ukrainian Easter egg painting (pysanka) and a
workshop on making Slavic motanka dolls, which are organized by our Department.
20. I am not aware of any attempts on the part of the State to limit or prohibit the education
and study of the Ukrainian language or its use in the educational process in higher
education.
Witness
[Signature]
Simferopol, 3 March 2023
Annex 31
Annex 31
LIST OF EXHIBITS
Number: Name of exhibit:
Exhibit A Library – branch No. 7 n.a. T. Shevchenko, Events dedicated to T.
Shevchenko (2022).
Exhibit B Tavrida Academy, In memory of the chroniclers of Ukrainian literature in
Crimea (31 October 2019).
Exhibit C Tavrida Academy, Conference “Genre and Stylistic Specificity of
Ukrainian Poetry of the XXth - Early XXIst Centuries” (6 April 2018).
Exhibit D Tavrida Academy, Scholars discuss the work of Lesya Ukrainka and other
modern writers and artists (8 October 2019).
Exhibit E Tavrida Academy, XVII Scientific and Practical Conference Dedicated to
the Works of Lesya Ukrainka (1 November 2018).

Exhibit A
Library – branch No. 7 n.a. T. Shevchenko, Events dedicated to T. Shevchenko (2022)
(excerpt, translation)

Annex 31 Exhibit A
Excerpt
Translation
Library – branch No. 7 n.a. T. Shevchenko, Events dedicated to T. Shevchenko (2022),
available at: https://libsevchenko.nethouse.ru/page/1081880.
Events dedicated to T. Shevchenko
2022
The XII scientific and practical conference “Taras Shevchenko and Today” was opened at the Fevzi
Yakubov Crimean Engineering and Pedagogical University (KIPU) on 10 March 2022 in the framework
of the Forum of Native Languages. The organizers of the conference were the Department of Ukrainian
Philology of the Faculty of Philology of the KIPU, the Department of Ukrainian Philology of the Institute
of Philology of the Vernadsky Crimean Federal University (KFU) and Branch No. 7 named after
Shevchenko of the Centralised Library System of the City of Simferopol.
The plenary session of the conference was opened by Doctor of Sciences (Philology), assistant professor,
head of the Department of Ukrainian Philology of the Fevzi Yakubov KIPU Nina Fedorovna Grozyan.
Welcoming remarks were made by: Alime Ismailovna Apselyamova, Candidate of Sciences (Politics),
associate professor, dean of the Faculty of Philology of the Fevzi Yakubov KIPU, and Nikolai Ivanovich
Pelipas, Candidate of Sciences (Philology), associate professor, head of the Department of Ukrainian
Philology, Institute of Philology, Vernadsky KFU (online).
Presentations were made by scholars of the KIPU and KFU.
The head of Library Branch No. 7 named after T. Shevchenko Natalia Vasilyevna Karzhavina gave a
presentation and the report “To Live is to Serve the People” (online).
Annex 31 Exhibit A
Annex 31 Exhibit A
Annex 31 Exhibit A
Annex 31 Exhibit A

Exhibit B
Tavrida Academy, In memory of the chroniclers of Ukrainian literature in Crimea
(31 October 2019)
(translation)

Annex 31 Exhibit B
Translation
Tavrida Academy, In memory of the chroniclers of Ukrainian literature in Сrimea (31 October
2019), available at: https://ta.cfuv.ru/ru/news/6170.
In memory of the chroniclers of Ukrainian literature in Crimea
In October of this year, students and teachers from the Department of Ukrainian Philology at
Crimean Federal University held annual literary readings “Aleksandr Gubar and Petr Kyrychek -
Chroniclers of Ukrainian Literature in Crimea”.
Opening the readings, Head of the Chair of Ukrainian Philology Professor Viktor Gumenyuk
noted that it was Aleksandr Gubar and Petr Kyrychek, who for many years worked in the leading
university of Crimea, were those who skillfully combined the work of a scholar and a teacher and
raised several generations of Ukrainian philologists. The participants of the readings emphasised the
significant contribution of scholars to the study of Ukrainian literature and interethnic cultural
relations.
Students prepared reports based on Aleksandr Gubar and Petr Kyrychok’s research materials.
Ksenia Kuryata, Andrey Georgiev, and Anton Krutikov were recognised as the best speakers.
The organisers of the readings are sure that such events will familiarise students with the pages
of the university's history and expand the scope of their scientific research.

Exhibit C
Tavrida Academy, Conference “Genre and Stylistic Specificity of Ukrainian Poetry of the XXth -
Early XXIst Centuries” (6 April 2018)
(translation)

Annex 31 Exhibit C
Translation
Tavrida Academy, Conference “Genre and Stylistic Specificity of Ukrainian Poetry of the XXth -
Early XXIst Centuries” (6 April 2018), available at: https://ta.cfuv.ru/ru/news/4727.
Conference “Genre and Stylistic Specificity of Ukrainian Poetry of the
XXth - Early XXIst Centuries”
On April 4, Department of Ukrainian Philology of the Faculty of Slavic Philology and
Journalism held a scientific and practical conference "Genre and Stylistic Specificity of Ukrainian
Poetry of the XXth - Early XXI Centuries".
The conference discussed trends, currents and styles in Ukrainian poetry of XX - early XXI
centuries, thematic and genre-stylistic horizons of poetic discourse of the given period, stylistic and
linguistic and cultural aspects of the study of new poetic texts. A number of papers included
comparative analysis of Ukrainian and Russian poetry.
A separate area of the conference was research into the methodological and theoretical aspects
of studying poetic creativity. In addition to professors and students, teachers from Crimean schools,
including former graduates of the Ukrainian Philology Department, were active in this area.
The conference included a round table entitled "The Poetic World of Mikhail Ternavsky: Text
and Contexts" dedicated to the Crimean poet and translator, author of original vers libre and Esperanto
poetry. The first-year students, who have recently begun their philological studies but are already
making bold steps in philological science, were especially active in the round table.

Exhibit D
Tavrida Academy, Scholars discuss the work of Lesya Ukrainka and other modern writers and
artists (8 October 2019)
(translation)

Annex 31 Exhibit D
Translation
Tavrida Academy, Scholars discuss the work of Lesya Ukrainka and other modern writers and
artists (8 October 2019), available at: https://ta.cfuv.ru/ru/news/6065.
Scholars discuss the work of Lesya Ukrainka and other modern writers
and artists
Crimea hosted the XVIII scientific-practical conference "The works of Lesya Ukrainka and
other modern writers and artists in the context of tendencies of dramatisation and theatricalisation of
the artistic process". It brought together prominent scientists, pedagogues, and teachers from Crimean
schools, as well as students.
The conference included sections dedicated to the writer's work, aspects of literature studies,
linguistic and cultural aspects of the dramatisation and theatricalisation of the art process, and
methodological aspects of studying and teaching literature, including questions of interaction between
narrative and theatrical works. The conference also included a creative meeting with teachers of the
Academy of Humanities and Education of the CFU n.a. Vernadsky and Ukrainian poets Viktor
Vinogradov and Denys Mokrentsov. At the Crimean Engineering and Pedagogical University, a
round table discussion entitled "The Anthropological Paradigm of Literary and Language Space and
Its Role in Teaching Methodology of Philological Disciplines" was held.
The conference was organised by the Department of Ukrainian Philology at the Tavrida
Academy of CFU together with the Department of Russian and Ukrainian Philology and Teaching
Annex 31 Exhibit D
Methodology at the CFU Academy of Humanities and Education and the Department of Ukrainian
Philology at the Crimean Engineering and Pedagogical University.
Exhibit E
Tavrida Academy, XVII Scientific and Practical Conference Dedicated to the Works of Lesya
Ukrainka (1 November 2018)
(translation)

Annex 31 Exhibit E
Translation
Tavrida Academy, XVII Scientific and Practical Conference Dedicated to the Works of Lesya
Ukrainka (1 November 2018), available at: https://ta.cfuv.ru/ru/news/5344.
Scientific and Practical Conference Dedicated to the Works of Lesya
Ukrainka
The Department of Ukrainian Philology of the Faculty of Slavic Philology and Journalism
hosted the XVII Academic and Practical Conference "The Work of Lesya Ukrainka and Other Writers
and Artists of the Modern Era in the Context of Dramatisation and Theatricalisation of the Art
Process".
The conference was held during three days (October 24-26) at three traditional venues. In
addition to the Department of Ukrainian Philology at the Taurida Academy, the conference
participants were hosted by the Crimean Engineering and Pedagogical University and the Academy
of Humanities and Education in Yalta.
The event was attended by teachers and students from various departments of Vernadsky
Crimean Federal University and other Crimean universities, and teachers from Crimean schools.
The conference dedicated to Lesya Ukrainka has been organised by the department of Ukrainian
philology since 2002. Today the event broadened the scope of the research, so in addition to literary,
linguistic and cultural studies devoted to Lesya Ukrainka, the reports were presented on various
topics. For example, the section meetings were focused on the literature of the native land, Crimean
Annex 31 Exhibit E
motifs in works of fiction, the Slavic pantheon, modern issues of literary genology (the Christmas
story, fanfiction, fantasy), the works of contemporary authors (Luko Dashvar, Maria Matios,
Sviatoslav Vakarchuk), etc.
As part of the event, teachers and students of Ukrainian Philology department visited Yalta to
visit the monument and museum of Lesya Ukrainka and to continue the conference. The creative
meeting with the Yalta poets Viktor Vinogradov and Denis Mokrentsov was memorable. They recited
poems, told about the beginning of their creative way and revealed some secrets of their work. After
the performance the listeners, especially those interested in poetry, had an opportunity to talk to the
authors additionally.
The conference was productive and will be continued next year.
Violetta Kalina
Annex 32
Witness Statement of , 2 March 2023
(translation)

Annex 32
INTERNATIONAL COURT OF JUSTICE
APPLICATION OF THE INTERNATIONAL CONVENTION
FOR THE SUPPRESSION OF THE FINANCING OF TERRORISM AND
THE INTERNATIONAL CONVENTION ON THE ELIMINATION OF
ALL FORMS OF RACIAL DISCRIMINATION
(UKRAINE V. RUSSIAN FEDERATION)
WITNESS STATEMENT
OF
2 MARCH 2023
Annex 32
Page 2 out of 6

Annex 32
Page 4 out of 6
7. In addition to our ensemble, the village club has a number of multinational creative
groups. The Fenix choreographic group includes Russians, Crimean Tatars and
Ukrainians. The children’s choreographic group “Kinderdance” even includes
Bulgarians. There are Russians, Crimean Tatars, Ukrainians and Greeks in the
Vdokhnovenye folk theatre. All groups friendly cooperate with each other regardless of
the nationality of members.
8. For our cultural activities many members of the ensemble are awarded and given honorary
titles. In addition to me, the title of Honored Cultural Worker of Crimea was awarded to
the accompanist of the Raduga folk ensemble . Head of the
Vdokhnovenye folk theatre is also Honored Cultural
Worker of Crimea. And, for example, one of the members of our collective,
, at the moment will be included in the booklet of honorary
participants of amateur art with a length of service of more than 20 years, because she has
been engaged in folk art and promoted the Ukrainian culture for 40 years.
9. Our team performs traditional folk songs, many of them are Ukrainian. Moreover, we
perform them in traditional Ukrainian costumes: folk costumes of Kharkov region and
stylized modern Ukrainian costumes.
10. We choose our own repertoire and include Ukrainian folk songs, as most of our members
are ethnic Ukrainians, who have been taught to love very melodious and euphonious
Ukrainian songs since their childhood. At the same time, we have never felt harassed or
censored in relation to performing songs in Ukrainian. Our audiences are happy to hear
Ukrainian folk songs and always expect them with enthusiasm.
11. We take part in concerts and competitions of different levels: rural, district, regional and
all-Russian. At the same time, we also tour throughout Russia and perform songs in
Ukrainian. For example, we have recently performed a medley of Ukrainian songs to
confirm our title of a folk group. This year we also took part in the All-Russian Festival-
Marathon “Songs of Russia” in Simferopol, where we performed songs in Ukrainian.2 In
2015, we took part in a folk-art festival at the Lesya Ukrainka Palace of Culture in
2 Crimean Newswire, “Songs of Russia” festival-marathon starts in Crimean capital (25 June 2022), available at:
https://crimea-news.com/culture/2022/06/25/937897 html (Exhibit B).
Annex 32
Page 5 out of 6
Novograd-Volynsky.3
12. We have won many vocal competitions. For example, in 2019 we won the Republican
Festival-Contest FFrom Heart to Heart” dedicated to Elderly People's Day.4 This year we
won first places at the “Altyn Maidan” festival in the Chernomorsky District and at the
festival dedicated to Elderly People's Day in Schebetovka.
13. The group rehearses in a building dating back to 1975, which was first used as a
kindergarten, later constantly converted into a café and sports facilities.
14. Unfortunately, soon after the creative team started working in the building, it became
clear that it was in need of repair, which had not been done for decades. It was not very
comfortable to work in the club because of the quality of windows. Nevertheless, our love
of Ukrainian folk art and culture allowed us to overcome all hardships.
15. After Crimea’s reunification with the Russian Federation in 2014, the situation changed.
Money was allocated from the state budget through the Simferopol district
Administration to repair the building. As a result, we had windows replaced, new doors
installed, new wiring, heaters and air conditioning and lighting installed. All this allowed
the staff of the village club to work in comfortable conditions.
16. In addition, I also observe how funds are allocated in the Simferopol district for the
renovation of clubs and Houses of culture.
17. I regularly receive my salary without any delays, as well as the benefits for honorary titles
and excellence.
Witness
3 City of Zvyagel, Creativity Festival in Novograd-Volynsky (18 November 2015), available at:
https://www.04141.com.ua/news/1033378/prazdnik-tvorcestva-v-novograd-volynskom (Exhibit C).
4 Feodosiya Guide, “From Heart to Heart” Republican Festival-Contest held on Day of the Older Persons -
Feodosiya news (8 October 2019), available at: https://feodosiya-gid.ru/news/kultura/sostoyalsyarespublikanskiy-
festival-konkurs-ot-serdca-k-serdcu-posvyaschennyy-dnyu-pozhilogo-cheloveka.htm (Exhibit
D).
Annex 32
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[Signature]
Lekarstvennoye Village, Simferopol District, 2 March 2023
Annex 32
LIST OF EXHIBITS
Number: Name of exhibit:
Exhibit A Centre for Folk Art of the Republic of Crimea, Folk Vocal Ensemble
“Raduga” of the Lekarstvensky Village Club of the Second Municipal
Budgetary Institution of Culture “Centralised Club System of Simferopol
District”.
Exhibit B Crimean Newswire, “Songs of Russia” festival-marathon starts in
Crimean capital (25 June 2022).
Exhibit C City of Zvyagel, Creativity Festival in Novograd-Volynsky (18 November
2015).
Exhibit D Feodosiya Guide, “From Heart to Heart” Republican Festival-Contest
held on Day of the Older Persons - Feodosiya news (8 October 2019).

Exhibit A
Centre for Folk Art of the Republic of Crimea, Folk Vocal Ensemble “Raduga” of the
Lekarstvensky Village Club of the Second Municipal Budgetary Institution of Culture
“Centralised Club System of Simferopol District”
(translation)

Annex 32 Exhibit A
Translation
Centre for Folk Art of the Republic of Crimea, Folk Vocal Ensemble “Raduga” of the
Lekarstvensky Village Club of the Second Municipal Budgetary Institution of Culture “Centralised
Club System of Simferopol District” (Head - Rudakova Tatyana Ivanovna), available at:
https://cnt-rk.ru/narodnuy-vocalnyi-ansambl-raduga/.
Folk Vocal Ensemble “Raduga” of the Lekarstvensky Village Club of the
Second Municipal Budgetary Institution of Culture “Centralised Club
System of Simferopol District" (Head - Rudakova Tatyana Ivanovna)
In 1983 the vocal ensemble "Raduga" was created by an accordionist Rudakov Yuri Mikhailovichin
in the club of the phytosovkhoz "Raduga" LLC of Lekarstvennoe village. Since 1985 the ensemble
has been headed by choirmaster Rudakova Tatiana Ivanovna.
The main purpose of the group is to protect and promote Russian and Ukrainian folk art and formation
of aesthetic taste both among the participants and the audience.
Rehearsal process in the group is organised according to the traditional system of work in vocalchoral
genre and includes different forms: work on breathing, articulation exercises, singing, work
on the piece (familiarisation, technical, artistic mastering of the peace), technical, dress rehearsals -
all this is geared to the final result - concert performances, the most important element in the activity
of the ensemble and, last but not least, the final stage - analysis of the performance, review of video
material, and discussion of the negative and positive aspects. Studying and performing the songs
solves many of the following tasks: expanding the voice range, developing vocal and choral skills,
developing harmonic hearing, fostering a good musical taste, etc.
The repertoire of the group is diverse, includes both traditional and modern styles and directions of
vocal arts. Every year a lot of new and interesting songs appear in the repertoire from various regions
of Russia. Their genre includes flowing and lyrical, fun and playful songs. The repertoire also
includes wedding ceremonies, Christmas carols and other folk performances.
In 1995 the ensemble "Raduga" was awarded the title "Folk amateur ensemble", which has been
renewed for many times. In 2016, the ensemble was awarded the title "People's" in accordance with
the Regulation of Ministry of Culture of the Russian Federation. In 2019, the ensemble has deservedly
reclaimed this title.
The ensemble Raduga leads an active concert life, performing at the district festivals: Maslenitsa,
Ivan Kupala, Autumn fairs, Days of Simferopol district, Days of village workers, at the Plenums of
the employees of the Simferopol district organisation of trade unions of education and science, in the
military unit in charge, in the Republican Hospital of War Veterans, the Line Department of Railway
Police.
The companion ensemble "Raduzhanochka" performs annually in the children's boarding school in
the village of Gvardeyskoe on Day of the Disabled. The children's group is a permanent participant
in all events held in Lekarstvenniy village club - 2, gaining skills in vocal and choral singing,
improving their general musical culture, developing creativity, giving birth to a child's vivid
imagination and creativity.
Annex 32 Exhibit A
In 2009 Crimean television presented a film about the work of the ensemble "Raduga", in 2010 the
ensemble took part in the TV show "Good Morning", in 2019 - in the programme "Crimean Stories".
Ensemble took part in International and Republican festivals - Festival of Cossack culture
"Krymskiye Tulumbasy", "Sodruzhestvo" in Taganrog, Rostovskiy region, "Venok druzhby" in
Bobruisk, Republic of Belarus, festival of Ukrainian folklore in Lutsk, Ukraine, festival of artistic
creativity «With Russia in the Heart" in Moscow and Smolensk.
Since 2000 the leaders of the ensemble "Raduga" Rudakova Tatyana Ivanovna and Rudakov Yuriy
Mikhailovich have been awarded the title "Honoured Worker of Culture of the Republic of Crimea".
Exhibit B
Crimean Newswire, “Songs of Russia” festival-marathon starts in Crimean capital
(25 June 2022)
(translation)

Annex 32 Exhibit B
Translation
Crimean Newswire, “Songs of Russia” festival-marathon starts in Crimean capital
(25 June 2022), available at: https://crimea-news.com/culture/2022/06/25/937897.html.
“Songs of Russia” festival-marathon starts in Crimean capital
25 June 2022, 21:27 | Culture
The "Songs of Russia" All-Russian Festival-
Marathon was launched in Simferopol under the
art direction of its author, People's Artist of the
Russian Federation Nadezhda Babkina. The
project aims to promote, develop and support the
traditions of Russian culture, the rich intangible
heritage of the peoples of Russia.
For Crimeans and guests of the peninsula a concert
was held. The concert included folk art of People's
Artist of Russia Nadezhda Babkina and the Moscow State Ensemble "The Russian Song", the
Governor's Dance Theatre "Siberian Kaleidoscope", singer Evgeny Gora, the ensemble "Slavyane",
the ballet "Live Planet", folk-rock band "After 11", the accordionist duo "The Bondarenko Brothers",
singer Ivan Zamotayev.
In the framework of the festival creative meetings and master classes will be held. The concerts of
the festival will be held in Feodosia (June 26), the townlet of Krasnogvardeisky (June 27), Evpatoria
(June 28), Kerch (June 29), Yalta (June 30), the townlet of Razdolnoe (July 1), Pervomaysky District
(July 2), Belogorsk (July 3) and Bakhchisaray (July 4). Start of the concert at 19:00. Entrance is free
to all the events.
Press service of the Ministry of Culture of the Republic of Crimea

Exhibit C
City of Zvyagel, Creativity Festival in Novograd-Volynsky (18 November 2015))
(translation)

Annex 32 Exhibit C
Translation
City of Zvyagel, Creativity Festival in Novograd-Volynsky (18 November 2015), available at:
https://www.04141.com.ua/news/1033378/prazdnik-tvorcestva-v-novograd-volynskom.
Creativity Festival in Novograd-Volynsky
10:39, 18 November 2015
Once again, the Lesya Ukrainka Town Palace of Culture is welcoming lovers of Ukrainian folk
songs.
On November 15, the great hall gathered admirers of the folk men's ensemble "Khmel", which
celebrated its 15th anniversary since its establishment, the head of which is the Honoured Worker of
Culture of Ukraine Nikolay Kurkach.
More than 600 spectators had the opportunity to enjoy the performance of rousing songs of the
ensemble and the creativity of People's Artist of Ukraine Yuri Gradovsky and amateur teams of the
Palace of Culture. In the warm and friendly atmosphere, in which the whole event took place on the
stage, the team received congratulations from the Directorate of Culture of the Regional State
Administration, represented by the Head of Yu. G. Gradovsky, the Head of the Department of
Culture of the City Council L.V. Zayats and the director of the City Palace of Culture I. D.
Antipchuk.
On such an important day for "Khmel", they were congratulated by colleagues with whom the
ensemble has been working for many years. Leaders of creative collectives not only welcomed
jubilees with beautiful and warm words but also presented their creative performance. Folk trio
"Vera" (Head - honoured worker of culture of Ukraine Matviychuk), representatives of folk theatre
(Head - V. Olshevskiy), folk song and dance ensemble "Polesye" (the head of the choir group -
Honored Worker of Culture of Ukraine M. Artemiuk and the head of the dance group (A.Dirko),
participants of folk choir of veterans of labor, represented by the head of the group L. Steblina and
leading singer L. Ozyuk, children's choreographic ensemble "Raduga" (director K. Rudakova) and a
municipal dixieland band (director O. Gurban) were able to touch the soul of every viewer by their
creativity.
Each appearance of the ensemble "Khmel", that was announced by the director and host of the
event Irina Panasiuk, was accompanied by loud applause of the audience and the ensemble did not
leave the stage for two hours.The concert was also visited by the conscripts of 30th separate
mechanized brigade, who were not indifferent to the creativity of the ensemble. It is pleasant that
the folk men's ensemble "Khmel" also has its patrons, namely, private entrepreneurs V. F.
Androshchuk, M. M. Martinyuk and A. A. Lavrenyuk, to whom the team is sincerely grateful.
"The highest award for the artist is the presence and applause of the audience". We wish the
ensemble to gather their fans in future, giving them their unique art.

Exhibit D
Feodosiya Guide, “From Heart to Heart” Republican Festival-Contest held on Day of the Older
Persons - Feodosiya news (8 October 2019)
(translation)

Annex 32 Exhibit D
Translation
Feodosiya Guide, “From Heart to Heart” Republican Festival-Contest held on Day of the
Older Persons - Feodosiya news (8 October 2019), available at: https://feodosiyagid.
ru/news/kultura/sostoyalsya-respublikanskiy-festival-konkurs-ot-serdca-k-serdcuposvyaschennyy-
dnyu-pozhilogo-cheloveka.htm.
“From Heart to Heart” Republican Festival-
Contest held on Day of the Older Persons -
Feodosiya news
More than 400 people took part in the event: solo performers, duets, trios, ensembles,
choirs, and amateur folk groups.
The Shchebetovka House of Culture (HC), Feodosia Urban District, hosted the Republican
festival-contest "From Heart to Heart" dedicated to the Day of the Older Persons. The
founders and organisers of the contest were the Ministry of Culture of the Republic of
Crimea and the Folk Art Centre of the Republic of Crimea.
More than 400 people took part in the event: solo performers, duets, trios, ensembles,
choirs, and amateur folk groups from all regions of the peninsula aged 55 and older.
The head of the Shchebetovka village administration Igor Ivanov and the chairperson of the
jury, professor of the musical art department of the Crimean University of Culture, Arts and
Tourism, People's Artist of Ukraine Elena Basargina delivered welcome speeches. The
military orchestra of the Russian National Guard conducted by Daniil Rafailov presented
musical compositions.
A jury consisting of leading specialists in the sphere of culture of the peninsula was formed
for the contest programme: chair Elena Basargina; head of the department of recreational
activities of the Folk Art Center of the Republic of Crimea Evgeniy Litvinenko; specialist in
concert and tour activities of the Crimean State Philharmonic Society Natalia Prokopenko;
methodology expert of the Simferopol district Centralised Club System Larissa
Sapozhnikova; and director of the Shchebetovka HC Yuriy Zheleko.
Performances of the groups and solo performers resulted in the following winners:
First prize winners:
Enver Barakaev (Slavyanskoye Rural HC, head Ilimdar Petislyamov); Rainbow Folk Vocal
Ensemble (Lekarstvennoye Rural HC, head Tatyana Rudakova); Native Tunes Folk Choir
(Kolchugino Rural HC, Simferopol district, head Natalia Panchenko).
Second prize winners:
Annex 33
Nina Suvorova (soloist of Feodosia Urban HC headed by Margarita Zorina and Alexander
Berzhakov); Smerichka Ukrainian Folk Song Ensemble (Sudak Urban HC, head Sofia
Mysiv); Zori Folk Choir (Chernomorsky District HC, head Elvis Abibullayev).
Third prize winners:
Maria Tsurkan (soloist, Native Tunes Ensemble, Zavetnoye Village), Singing Hearts
Ensemble (Nasypnoye Centre of Culture and Recreation, head Valery Dolgikh); Choir of the
amateur association "Veteran" (Bakhchisarai District HC, soloist Galina Krasova, head
Lyudmila Sarycheva, accompanist Nikolay Ryabov).
The Grand Prix was awarded to the Red Carnation Folk Choir of war and labour veterans
(Feodosia Urban HC headed by Margarita Zorina and Aleksandr Berzhakov).
The Audience Award went to the Singing Hearts Ensemble of the Simferopol Variety Arts
Centre (led by Alexander Dudorov).
Press Service of the Ministry of Culture of the Republic of Crimea
Annex 33
Witness Statement of , 7 March 2023
(translation)

Annex 33
INTERNATIONAL COURT OF JUSTICE
APPLICATION OF THE INTERNATIONAL CONVENTION
FOR THE SUPPRESSION OF THE FINANCING OF TERRORISM AND
INTERNATIONAL CONVENTION ON THE ELIMINATION OF
ALL FORMS OF RACIAL DISCRIMINATION
(UKRAINE V. RUSSIAN FEDERATION)
WITNESS STATEMENT
OF
7 MARCH 2023
Annex 33
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Annex 33
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1. I, , a Crimean Tatar, declare the following.
2. I am an
.
3. Between 2017 and 2020, I was
which includes
the Millet TV channel and the Vatan Sedasy radio station.
4. I present this witness statement on issues related to the dispute initiated by Ukraine before
the International Court of Justice. The statement raises a number of issues related to the
activities of the Crimean Tatar media in Crimea, the functioning of Crimean Tatar
representative institutions, the perception by Crimean Tatars of the Mejlis of the Crimean
Tatar People, and the quality of higher education in Crimea.
5. Due to my active participation in public, academic and political life on the peninsula, as
well as the fact that I have lived in Crimea all my conscious life, I am fully aware of the
condition of Crimean Tatars before and after the reunification of Crimea with Russia in
2014. This witness statement is based on my personal knowledge of the circumstances
surrounding these issues, as well as on the documents referenced below.
A. MEJLIS
6. I strongly disagree with the assertion that the Mejlis of the Crimean Tatar People can be
considered the mouthpiece of all Crimean Tatars.
7. First, the Mejlis has never represented all Crimean Tatars. According to some estimates,
in 2014 support for the Mejlis among Crimean Tatars was round 18%.1 Despite this, the
Mejlis has always sought the role of the sole representative of our people. The Mejlis
always got in confrontation with other public associations that also supported the Crimean
Tatars if it saw they were getting attention.
1 Ukraine ru, Dzhemilev and the West Try to Prevent Crimea from Joining Russia (28 November 2014), available
at: https://ukraina.ru/20141128/1011319376.html (Exhibit A).
Annex 33
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8. Specifically, when Ukrainian President Viktor Yanukovych appointed representatives of
Crimean Tatar organizations opposed to the Mejlis to the Council of Representatives of
the Crimean Tatar People Under the President of Ukraine in 2010, the Mejlis boycotted
the Council's work.2
9. Second, support from Crimean Tatars to Mejlis vanished after the inhumane blockade of
Crimea by the Mejlis activists. The blockade included:
(a) The closure of the North Crimean Canal which accounted for more than 85% of
fresh water supply to the peninsula (water blockade);
(b) Blowing up of the electricity transmission towers that provided Crimea with
electricity (energy blockade);
(c) Blocking transport communication between Ukraine and Crimea (transport
blockade); and
(d) A ban on the supply of goods to Crimea (trade blockade).
10. Fortunately, Crimea, with Russia’s support, was able to successfully withstand the actions
that Ukraine and the Mejlis carried out as revenge for the Crimeans’ choice of
reunification with the Russian Federation in 2014.
11. Of course, the blockades put an end to the Mejlis’s dreams of having any support among
Crimean Tatars living on the peninsula. How can anyone in their sound mind support an
organisation that tried to leave their people without water, food and electricity?
12. Both I and other Crimean public activists have repeatedly tried to draw international
attention to the falsehood of the information that the Mejlis has disseminated regarding
the situation in Crimea, as well as to the devastating consequences and human suffering
that the Mejlis' blockade of the peninsula caused:
(a) In 2018, as part of the Crimean delegation, at the OSCE conference in
Warsaw to give a presentation on the real situation in Crimea and the blockade
imposed by Ukraine and the Mejlis. After
2 TODAY, Mejlis Refuses to Work with Yanukovych (30 August 2010), available at:
https://politics.segodnya.ua/politics/medzhlic-otkazalcja-rabotat-c-janukovichem-211454.html (Exhibit B).
Annex 33
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the microphone was switched off at the request of the Ukrainian
delegation; 3
.
(b) .
.4
(c) At the UN videoconference in 2020 (“Arria formula” meeting of the Security
Council), the Crimean delegation of which
5
13. The Mejlis’s blockade of Crimea was a direct attempt to make life unbearable for Crimean
Tatars, apparently to force them to reverse the choice that our people made in 2014
together with other Crimean residents, i.e. to continue their historical path with Russia.
B. CRIMEAN TATAR REPRESENTATION ISSUES
14. In my view, the real protection of Crimean Tatars is provided not by the Mejlis in Ukraine
in the persons of Mustafa Dzhemilev and Refat Chubarov, but by people working in
Crimea for the benefit of Crimea and Crimeans.
15. Crimean Tatars are represented both at the level of the Republic of Crimea and at the
federal level.
(a) At the level of the Republic of Crimea, the Council of Crimean Tatars under the
auspices of the Head of the Republic of Crimea has the mandate to resolve issues
of the Crimean Tatar population.
3 TASS, Media: Crimean Journalists Prevented from Speaking at OSCE Conference in Warsaw (11 September
2018), available at: https://tass ru/politika/5550761 (Exhibit C).
4 RIA Novosti, Journalist Urges OSCE to Respond to International Blockade of Crimea (17 September 2019),
available at: https://ria.ru/20190917/1558770402 html (Exhibit D).
5 Crimean Newswire, Water Blockade and Language Rights: What Crimeans Talked About at the UN (22 May
2020), available at: https://crimea-news.com/politics/2020/05/22/654978.html (Exhibit E).
Annex 33
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(b) At the federal level, the Council on Interethnic Relations under the auspices of the
President of the Russian Federation, which includes a Crimean Tatar Chingiz
Fevzievich Yakubov, is functioning.
16. It should also be noted that Crimean Tatars also represent their people in local elected
authorities. In September 2019, more than 200 Crimean Tatars joined representative
authorities.
17. Besides, there is a number of public non-governmental organisations in Crimea that
cooperate with the competent authorities of the republic. In my opinion, the role of these
organisations in protecting Crimean Tatars is mainly to collect opinions and complaints
from the population.6 The direct implementation of initiatives for the development of the
Crimean Tatar community is handled by the federal and regional authorities, which have
the necessary resources for that. I am very glad that since 2014 the Crimean Tatars have
been living in a welfare state that has both the means and will to improve their life.
18. The Council of the Crimean Tatars under the auspices of the Head of the Republic, unlike
the Mejlis, does not take on uncharacteristic functions, but deals with what a
representative organisation is created for, i.e. with informing the competent authorities
about problems faced by the Crimean Tatar people. It must be said that the Council and
other Crimean Tatar organisations perform that function effectively. Since Crimea's
reunification with the Russian Federation, the authorities have resolved a number of
problems which affected, among others, Crimean Tatars in the period before 2014. They
include the allocation of land to Crimean Tatars, the resolution of forced land squatting
issues, and the construction of infrastructure, including new educational facilities in the
areas of compact settlement of Crimean Tatars. It is important to note that under state
funding, social problems are resolved much more effectively: the problems of the
population are dealt with by relevant agencies, i.e. professionals, and the budget is
transparent and documented.
6 See, for example, Saksy District of the Republic of Crimea, Representatives of the Council of Crimean Tatars
under the Auspices of the Head of the Republic of Crimea Visited Saksky District and Saki (18 September 2018),
available at: http://sakirs.ru/rajonnaya-administratsiya/prioritety-ra/33-press-sluzhba/novosti/3222-predstavitelisoveta-
krymskikh-tatar-pri-glave-respubliki-krym-posetili-sakskij-rajon-i-g-saki (Exhibit F). Armyansk Urban
District, Public Meeting with Representatives of the Council of Crimean Tatars under the Auspices of the Head of
the Republic of Crimea Held in Armyansk (3 September 2018), available at:
http://armgov.ru/sobytiya/v_armyanske_proshla_vstrecha_obwestvennosti_s_predstavitelyami_soveta_krymskih
_tatar_pri_glave_respubliki_krym/ (Exhibit G).
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C. ACTIVITIES OF THE CRIMEAN TATAR MEDIA
19. Following Crimea’s reunification with the Russian Federation, the Russian authorities
provided Crimean Tatars with unprecedented assistance to establish their own media. At
the initiative of the Head of the Republic of Crimea, the ANO “Crimean Tatar Public
Television and Radio Company” was established in 2015, which has provided the basis
for a 24-hour television channel “Millet” and a 24-hour Crimean Tatar radio station
“Vatan Sedasy”.
20. but I was quite familiar with its
activities even when
.
21. It is no exaggeration to say that Millet is a unique product for Crimean Tatars. For the
first time in the history of the Crimean Tatar community, there is a resource that promotes
Crimean Tatar culture and language. During the time I was in charge of Millet, most of
the channel’s staff were ethnic Crimean Tatars; more than 50% of the channel’s own
content was in Crimean Tatar – I am sure that these indicators are still being met.
22. Millet airs broadcasts on various aspects of Crimean Tatar culture and history on a daily
basis.
23. The channel also takes part in the organisation and coverage of major events dedicated to
Crimean Tatar culture: competitions in the traditional Crimean Tatar wrestling Kuresh,
the Crimean Tatar festival Khydyrlez, events dedicated to Islamic festivals.
24. As far as I understand, the Ukrainian side indicates Lenur Islyamov’s ATR channel,
allegedly banned by the Russian Federation, as an alternative to Millet, while trying to
present Millet itself as a pro-government channel. In this regard, I can explain the
following.
25. First, during the time I Millet, I never encountered censorship or attempts
to interfere in the channel’s editorial policy and impose some kind of information agenda.
As mentioned, the channel specialises in promoting the Crimean Tatar culture and does
so autonomously, conscientiously and consistently.
Annex 33
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26. Second, as far as I know, no one forcedly closed ATR. The ATR management made a
political move by refusing to go through the media re-registration procedure to obtain a
broadcasting license, which is the same for absolutely all mass media, and the channel
moved to Kiev.
27. Third, the claim that ATR promoted Crimean Tatar culture is a big exaggeration. Rather,
ATR exploited the Crimean Tatar agenda when it was to its owner’s advantage. In 2014,
Lenur Islyamov together with Mustafa Dzhemilev and Refat Chubarov started
cooperating with the Ukrainian authorities and ATR was his “mouthpiece”, which had
very little to do with covering the life of the Crimean Tatar community. Thus, during the
blockade of Crimea, when thousands of Crimean Tatars suffered because of actions of
the Mejlis and Ukraine, ATR justified and supported the blockade.7 Islyamov himself
stated that he was “proud” to be personally involved in the blockade of Crimea. 8
Islyamov's subversive activities in Crimea were appreciated by the Ukrainian authorities,
who repaid Islyamov and ATR's multi-million-dollar debts from the state budget.9
28. Fourth, time has shown that ATR TV did not really enjoy the interest of Crimean Tatars.
In 2020, ATR was closed due to financial problems.10 Lenur Islyamov himself admitted
that ATR’s stories were “not highly rated”.11
7 See for example, the ATR TV report on the results of the three-year blockade of Crimea. I draw attention to
several things: (1) In the story about the food blockade, people living in Crimea are referred to as “enemies” and
“occupants” who should stop being “fed”. (2) It admits that the Mejlis and personally Refat Chubarov initiated the
blockade and refers to the involvement of the Ukrainian nationalist formations Azov, Right Sector, Aydar and
others. (3) It admits that the blockade, which condemned thousands of people to a lack of basic necessities (food,
water and electricity), was organised to create a debated news event. See YouTube, ATR TV, The civil blockade
of Crimea: how it all started 3 years ago and what the outcome was (21 September 2018), available at:
https://www.youtube.com/watch?v=_2J5XG_qgjs (Exhibit H).
8 Ukrinform, ATR Owner Proud to Be Involved in Crimea's Electricity Blockade (5 October 2020), available at:
https://www.ukrinform.ru/rubric-crimea/3112326-vladelec-atr-gorditsa-tem-cto-pricasten-k-blokadeelektroenergii-
v-krymu.html (Exhibit I). See also Events.info, ATR TV Owner Called the Peninsula Blockade the
Crimean Maidan (19 September 2015), available at:
http://web.archive.org/web/20220225040442/http://www.sobytiya.info/news/15/55768 (Exhibit J).
9 Crimea Inform, Ukraine Will Repay Islyamov’s Private TV Channel Multimillion-Dollar- Debts from the State
Budget (23 April 2016), available at: https://www.c-inform.info/news/id/37932 (Exhibit K).
10 TASS, Crimean Authorities Commented on the Termination of Broadcasting of ATR TV Channel in Ukraine (11
February 2020), available at: https://tass ru/obschestvo/7732411 (Exhibit L).
11 Youtube, The Civil Blockade of Crimea: How it All Began 3 Years Ago and What its Outcomes Were (21
September 2018), available at: https://www.youtube.com/watch?v=_2J5XG_qgjs (Exhibit H).

Annex 33
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Witness
[Signature]
Simferopol, 7 March 2023
Annex 33
LIST OF EXHIBITS
Number: Name of exhibit:
Exhibit A Ukraine.ru, Dzhemilev and the West try to prevent Crimea from joining
Russia (28 November 2014).
Exhibit B TODAY, Mejlis refuses to work with Yanukovych (30 August 2010).
Exhibit C TASS, Media: Crimean Journalists Were Prevented from Speaking at the
OSCE Conference in Warsaw (11 September 2018).
Exhibit D RIA Novosti, Journalist Urges the OSCE to Respond to International
Blockade of Crimea (17 September 2019).
Exhibit E Crimean Newswire, Water Blockade and Language Rights: What
Crimeans Talked About at the UN (22 May 2020).
Exhibit F Municipal Entity Saksky District of the Republic of Crimea,
Representatives of the Council of Crimean Tatars under the Auspices of the
Head of the Republic of Crimea Visited Saksky District and Saki
(18 September 2018).
Exhibit G Municipal Entity Armyansk Urban District, Public Meeting with
Representatives of the Council of Crimean Tatars under the Auspices of the
Head of the Republic of Crimea Held in Armyansk (3 September 2018).
Exhibit H YouTube, ATR TV, The Civil Blockade of Crimea: How it All Started 3
Years Ago and What the Outcome Was (21 September 2018).
Exhibit I Ukrinform, ATR Owner Proud to Be Involved in Crimea's Electricity
Blockade (5 October 2020).
Exhibit J Events.info, ATR TV Owner Called the Peninsula Blockade the Crimean
Maidan (19 September 2015).
Exhibit K Crimea Inform, Ukraine Will Repay Islyamov’s Private TV Channel
Multimillion-Dollar Debts from the State Budget (23 April 2016).
Annex 33
Exhibit L TASS, Crimean Authorities Commented on the Termination of
Broadcasting of ATR TV Channel in Ukraine (11 February 2020).
Exhibit M RIA Novosti, Who and When Will Build a New Dormitory for KFU
Students in Simferopol (5 December 2022).
Exhibit N KFU, New Multimedia Technology Presented at KFU (28 January 2016).
Exhibit A
Ukraine.ru, Dzhemilev and the West try to prevent Crimea from joining Russia
(28 November 2014)
(translation)

Annex 33 Exhibit A
Translation
Ukraine.ru, Dzhemilev and the West Try to Prevent Crimea from Joining Russia (28
November 2014), available at: https://ukraina.ru/20141128/1011319376.html.
Ukraina.ru
Dzhemilev and the West Try to Prevent Crimea from Joining Russia
By Vasip Muravitsky, Ukraina.ru
28 November 2014 at 04:43 PM
© RIA Novosti. Grigory Vasilenko
On the 12th of November, Mustafa Dzhemilev announced his intention to create a Crimean
Tatar territorial defence battalion. According to him, he discussed this with Ukrainian
President Petro Poroshenko. Mr. Dzhemilev said about 450 ethnic Crimean Tatars are fighting
for Kyiv in Donbass and their families in Crimea are in danger. That is why their names
should be classified. At the same time, Mr. Dzhemilev handed over to the Ukrainian
Prosecutor General’s Office a list of almost 400 people allegedly infringing human rights in
Crimea.
Fearing for the families of those fighting Tatars, he, nevertheless, denounced his opponents
whose relatives may be in Mainland Ukraine to the Ukrainian Prosecutor General’s Office.
Making his statement about the planned creation of an ethnic battalion, which the German
newspaper Der Freitag, citing the ARD TV channel, called an “Islamic State” battalion, Mr.
Dzhemilev did not fail to say that the future of the Crimean Tatar people is with “an
Annex 33 Exhibit A
independent and strong Ukraine”. Today, Al-Jazeera released another publication repeating
all the myths about Crimean Tatars, alleging that they were mercilessly oppressed, kidnapped
and prevented from developing their culture. However, while quoting the detained Tatars
whose house was searched, Al-Jazeera forgot to mention that all of them are members of a
radical Islamist organisation banned in the homeland of the Al Jazeera’s founders.
© RIA Novosti. Konstantin Chalabov
Tatar “refugees” from Crimea are members of Hizb ut-Tahrir
Hizb ut-Tahrir and the Mejlis clashed on the basis of their conflict of ideas of statehood in
recent years in Crimea. Banned in many countries of the world, including Russia, and allowed
in Ukraine, Hizb ut-Tahrir wants to build a worldwide Islamic Caliphate where the Caliph
will revive Islam on Earth. The Mejlis conflicted with Hizb ut-Tahrir not only for power but
also on ideological grounds: the organisation led by Mr. Dzhemilev and Mr.Chubarov dreams
of building a Crimean Tatar national state rather than of an independent and strong Ukraine.
When Crimea became part of Russia, it fell under the jurisdiction of the laws of the Russian
Federation, one of which prohibits Hizb ut-Tahrir in the country. That’s when Tatar
“refugees” fondled by the Ukrainian Kyiv-based TV channels flew from Crimea. While
showing the “sufferings” of the humiliated Tatars, the Kyiv media ignored the fact that,
against the background of anti-Russian hysteria around Crimea, the Tatars did not stay in
Ukraine but began to emigrate to EU countries such as Germany where there is a large
Turkish community close to them.
Annex 33 Exhibit A
The Mejlis does not represent the entire Crimean Tatar people
However, Al-Jazeera and most Ukrainian and even Russian media present the Mejlis as an
unconditional representative of the interests of Crimean Tatars, which has been far from truth
so for a long time.
The Mejlis is a political organisation founded in the Soviet times, something like Vyacheslav
Chornovil’s People’s Rukh of Ukraine. It only represented the Crimean Tatar people for the
purpose of increasing nationalist movements in the USSR, and while more than 90% Crimean
Tatars supported the Mejlis at the time of the collapse of the Union, the number of its
supporters has dramatically decreased now. In 2013, the Mejlis was opposed by the Tatar
organisation Milliy Firqa and by the radical organisation Hizb ut-Tahrir, which emigrated
from the peninsula after it was annexed by Russia. For example, Vasvi Abduraimov, a wellknown
Crimean Tatar politician, recently stated that “in the early 1990s, this support [for the
Mejlis] amounted to 90%, but today it is only 18%. These 18-20% of Crimean Tatars,
perhaps, support Euromaidan, while other 60-70% are apolitical and are fully engaged in
efforts to survive and maintain their families because, unlike all the others, they began to live
in Crimea from different starting conditions, and still other 10-15% are actively opposing
Euromaidan”.
© RIA Novosti. Taras Litvinenko
Even these facts help to understand that not all Crimean Tatars support the Mejlis, and, given
the fact that there are only about 300,000 Crimean Tatars residing on the peninsula, the real
support for the Mejlis appears to be miserable.
Annex 33 Exhibit A
Dzhemilev is a Ukrainian politician, not a Tatar one...
Mustafa Dzhemilev has never been a Crimean Tatar national politician. He began his career
as an anti-Soviet politician and a dissident and has never changed his political views. He is
not really interested in representing Crimean Tatars as his goal is to destruct the common
Russian-Ukrainian cultural and economic space. That is why he has spent most of his political
life in Kyiv as a member of certain Ukrainian nationalist political parties rather than in
Crimea. It may seem surprising, but Mr. Dzhemilev is a Ukrainian nationalist politician of the
Crimean Tatar origin and has no right to represent this once nomadic ethnic group. Moreover,
he is one of the most “experienced” members of the Verkhovna Rada, the Parliament of
Ukraine, and used to spend most of his time in Kiev rather than in Crimea even before he was
expelled from the peninsula.
© RIA Novosti. Eygene Kotenko
Being part of the central vertical of power for more than 20 years of his membership of the
Verkhovna Rada, Mr. Dzhemilev could not or did not want to achieve the official status for
the Crimean Tatar language in Crimea. Moreover, not even a decent textbook has been
created over those the years to teach that language in schools. Once the Mejlis was the
presidium of the Kurultai, a congress of representatives of the Crimean Tatar people. But it
had not performed its real representative functions for a long time but only for a few years
beginning from 1990. Further, the Mejlis was literally privatised and became a private entity
serving Mustafa Dzhemilev’s political interests.
While criticising Russia, Mr. Dzhemilev is afraid to mention the fact that the Crimean Tatar is
now one of the three official languages in Crimea, the Crimean Tatar holidays are now
celebrated as official public holidays on the peninsula, and the Kurultai has been officially
recognised for the first time in the 20 years following the return of the Crimean Tatars to
Annex 33 Exhibit A
Crimea. What prevented Mustafa Dzhemilev from achieving official rights for the Kurultai
during the entire period of Ukraine’s independence, and what allowed Russia to do this? The
answer is simple: this issue had never been paramount for Mustafa Dzhemilev.
Mr. Dzhemilev’s assertion that the future of the Crimean Tatars is a strong and independent
Ukraine contains a huge share of cunning. Unlike, by the way, Hizb ut-Tahrir, the Mejlis
stands for building a powerful and independent Crimean Tatar state. It would be quite logical
to think that such a state should be independent from Ukraine, too.
***
A further, apparently inevitable and complete administrative and legal merger of Crimea and
Russia will begin from the 1st of January 2015. That is why Mr. Dzhemilev’s speeches are
becoming more and more aggressive and he is getting support from the West.
Mustafa Dzhemilev is an agent of influence of the West rather than of the Crimean Tatar
people. Real representatives of this ethnic group, but not fake ones, should emerge very soon.

Exhibit B
TODAY, Mejlis refuses to work with Yanukovych (30 August 2010)
(translation)

Annex 33 Exhibit B
Translation
TODAY, Mejlis Refuses to Work with Yanukovych (30 August 2010), available at:
https://politics.segodnya.ua/politics/medzhlic-otkazalcja-rabotat-c-janukovichem-
211454.html.
Segodnya
Mejlis Refuses to Work with Yanukovych
The President was urged to return to the previous principle of forming the Council of
Representatives of the Crimean Tatar People.
Delegates of the Qurultay, the national congress of the Crimean Tatars, call on Ukrainian
President Viktor Yanukovych to return to the previous principle of forming the Council of
Representatives of the Crimean Tatar People, delegation by Tatars instead of appointment by
the head of state.
The Qurultay made this decision on Sunday in Simferopol.
Until the Ukrainian leader does this, the members of the Mejlis will not intend to participate
in the work of this Council, Mustafa Dzhemilev, the head of the Mejlis, told reporters upon
completion of the Qurultay proceedings.
“After people are appointed to this Council, they no longer have the right to say anything on
behalf of the Crimean Tatar people. The resolution calls on the President to revise [the
principle forming the council of representatives of the Crimean Tatar people] with due regard
for the requirements of both the Constitution and international laws, in particular the UN
Declaration on the Rights of Indigenous Peoples, which clearly states that authorities should
only interact with indigenous peoples through their legitimately elected representative
bodies”, the Mejlis’ leader said.
However, he noted the Qurultay tried to “avoid a confrontational tone” when drawing up its
resolution.
“Many delegates said that they should crisply state that they will not participate in this
Council, but then they explained that, as appears from the very text [of the resolution], the
Mejlis of the Crimean Tatar People will not participate in this Council”, Mr. Dzhemilev said.
According to him, the members of the Mejlis and the delegates of the Qurultay, who occupy 9
of the 19 seats in the Council of Representatives of the Crimean Tatar People, will not go to
the meeting to be convened in the next two weeks by Vasyl Dzharty, Chairman of the
Crimean Government, on instructions from President Yanukovych.
As reported, President Yanukovych on the 26th of August signed his decree titled “On Matters
of the Council of Representatives of the Crimean Tatar People”, which reduced the
composition of the Council from 33 to 19 members and included in the Council a number of
politicians opposed to the Mejlis. According to the Decree, the composition of the Council
shall be subject to approval by the head of state.

Exhibit C
TASS, Media: Crimean Journalists Were Prevented from Speaking at the OSCE Conference in
Warsaw (11 September 2018)
(translation)

Annex 33 Exhibit C
Translation
TASS, Media: Crimean Journalists Were Prevented from Speaking at the OSCE
Conference in Warsaw (11 September 2018), available at:
https://tass.ru/politika/5550761.
11 September 2018 at 01:35 PM
Media: Crimean Journalists Were Prevented from Speaking at the OSCE
Conference in Warsaw
After Ervin Musayev, Director of Millet, a Crimean Tatar TV channel, came to the
rostrum and introduced himself as “Republic of Crimea, Russia”, three countries
protested.
Simferopol, 11 September, TASS. Crimean journalists were disallowed to speak at the OSCE
conference in Warsaw on the observance of human rights, Krym-24 TV channel, whose film
crew is working at the conference, reported on Tuesday.
“After Ervin Musayev, Director of Millet, a Crimean Tatar TV channel, came to the rostrum
and introduced himself as “Republic of Crimea, Russia”, three countries protested: Ukraine,
Canada, and Austria. Ervin’s microphone was immediately turned off”, Krym-24 said.
Krym-24 noted that the other members of the Crimean delegation were not even allowed to
come to the rostrum as their presentations were removed from the agenda in advance.
According to earlier reports, the Crimean delegation includes journalists and members of the
Crimean Public Chamber.
Last year, the speech of Andrey Trofimov, Chairman of the Crimean Branch of the Russian
Union of Journalists, at the OSCE conference on media freedom was also interrupted at the
insistence of the members of the Ukrainian delegation.
After the coup d’état in Ukraine in February 2014, the authorities of Crimea and the city of
Sevastopol held a referendum on reunification with Russia. More than 80% of the eligible
voters in both regions took part in that referendum, and 96.7% of those voters in Crimea and
95.6% in Sevastopol voted for reunification with Russia. On 18 March 2014, Russian
President Vladimir Putin signed a treaty on the admission of the Republic of Crimea and the
city of Sevastopol to the Russian Federation, which was ratified by the Federal Assembly on
the 21st of March. Despite the convincing results of the referendum, Kyiv refused to recognise
Crimea as part of Russia.

Exhibit D
RIA Novosti, Journalist Urges the OSCE to Respond to International Blockade of Crimea
(17 September 2019)
(translation)

Annex 33 Exhibit D
Translation
RIA Novosti, Journalist Urges the OSCE to Respond to International Blockade of Crimea
(17 September 2019), available at: https://ria.ru/20190917/1558770402.html.
RIA Novosti
17 September 2019 at 02:31 PM
Journalist urges the OSCE to respond to international blockade of Crimea
© RIA Novosti / Konstantin Mikhalchevsky
Swallow’s Nest Castle on a coastal rock in the village of Gaspra, Crimea. Archival photo
Simferopol, 17 September, RIA Novosti. Ervin Musayev, General Director of Millet, a
Crimean Tatar public TV and radio company, called on the OSCE to work more actively with
Crimea and respond to the international blockade of the peninsula.
Mr. Musayev arrived in Warsaw as a member of the Crimean delegation to take part in the
OSCE conference on human rights.
“In my speech, I called on the OSCE to pay attention to a number of vital issues facing the
Crimeans, one of which is the international blockade. Ukraine ignored the need to respect
human rights by imposing water, transport and energy blockades for the inhabitants of
Crimea. Why were other countries silent? Or does a blockade become an international
standard?”, Mr. Musayev told RIA Novosti.
According to him, despite the fact that Crimea has successfully overcome all the blockades,
they must be judged internationally. “We have coped with this and are moving forward”, Mr.
Musayev stressed.
Annex 33 Exhibit D
He noted that the OSCE should judge the ban on Crimean residents to travel with Russian
passports to a number of Western countries.
“Such double standards in respect of Crimea contradict the fundamental principles of this
organisation. I urge [the other countries] to follow the examples of China, Turkey and Saudi
Arabia, who are actively dealing with Crimea and issuing visas to its residents”, the journalist
said.
Exhibit E
Crimean Newswire, Water Blockade and Language Rights: What Crimeans Talked About at the
UN (22 May 2020)
(translation)

Annex 33 Exhibit E
Translation
Crimean Newswire, Water Blockade and Language Rights: What Crimeans Talked About
at the UN (22 May 2020), available at: https://crimeanews.
com/politics/2020/05/22/654978.html.
Crimean News
Water Blockade and Language Rights: What Crimeans Talked About at
the UN
22 May 2020 at 12:55, Politics
Simferopol, 22 May, RIA Novosti (Crimea). During a UN
Security Council Arria formula meeting, representatives of
the Crimean public once again confirmed that the merger of
Crimea into Russia was a conscious choice made by an
overwhelming majority of Crimeans. The participants of the
videoconference stressed that their freedoms in Russian
Crimea are respected, while pointing to the infringement of
their rights by the Ukrainian state.
On the night of 21-22 May 2020, the Permanent Mission of Russia to the UN held an informal
video conference of the Security Council with participation of residents of Crimea in
accordance with the so-called “Arria formula”. Such meetings are not directly attributed to the
events held by the Security Council and imply consultations which not only diplomats but
also representatives of non-governmental organisations and the public may be invited to.
The meeting was attended by representatives from more than 30 countries. Esadullah Bairov,
Deputy Mufti of Crimea, Anastasia Gridchina, head of the Ukrainian community on the
Crimean Peninsula, Ervin Musayev, a member of the Bakhchysarai Town Council, and
Alexander Makar, a journalist and TV presenter, spoke at the conference.
Speaking on air on Radio Sputnik in Crimea, Anastasia Gridchina noted that the past video
conference became “a unique opportunity for Crimeans to speak and convey their point of
view to the world community”. She recalled that Crimeans were disallowed to speak at the
last UN Security Council Arria formula meeting arranged for by the Ukrainian side.
According to Ms. Gridchina, her speech concerned the observance of the linguistic and
cultural rights of Ukrainians in Crimea as well as the oppression of the Russian language in
Ukraine. She noted that a representative of Germany was most active, asking many questions
to the representatives of Crimea and thereby greatly enlivening the discussion. In particular,
he asked about the legitimacy and legality of the 2014 referendum and the attitude of the
Crimeans to joining Russia.
“We communicate with representatives of international organisations on a regular basis, and,
unfortunately, we hear the same rhetoric in the United Nations, the OSCE and other venues.
The words spoken by representatives of Western countries have not changed since 2014 and
Annex 33 Exhibit E
are repeated from year to year. People rely on superficial information and have no objective
details. Therefore, I am not willing to say we have reached out them somehow”, Ms.
Gridchina said.
In turn, Ervin Musayev, a member of the Bakhchysarai Town Council and a public figure,
called upon the UN Security Council to respond to the water blockade of Crimea by the
Ukrainian authorities.
“This topic is rarely covered by world media. But there are a lot of things to talk about. How
could they cut off the water and electricity supply to 2.5 million people in the 21st century?
For six years, Crimea has not been receiving water through the North Crimean Canal. All this
runs counter to the foundations of international law. I am sure the UN should find resources to
resolve this issue”, RIA Novosti quoted Mr. Musayev as saying.
According to him, the issue of the water supply to Crimea should be resolved with due regard
for the fact that the peninsula is part of the Russian Federation.
Exhibit F
Municipal Entity Saksky District of the Republic of Crimea, Representatives of the Council of
Crimean Tatars under the Auspices of the Head of the Republic of Crimea Visited Saksky
District and Saki (18 September 2018)
(translation)

Annex 33 Exhibit F
Translation
Saksy District of the Republic of Crimea, Representatives of the Council of Crimean Tatars
under the Auspices of the Head of the Republic of Crimea Visited Saksky District and Saki
(18 September 2018), available at: http://sakirs.ru/rajonnaya-administratsiya/prioritetyra/
33-press-sluzhba/novosti/3222-predstaviteli-soveta-krymskikh-tatar-pri-glaverespubliki-
krym-posetili-sakskij-rajon-i-g-saki.
Representatives of the Council of Crimean Tatars under the Auspices of the
Head of the Republic of Crimea Visited Saksky District and Saki
The representatives of the Council of Crimean Tatars under the Head of the Republic of Crimea
visited the town of Saki and the Saki District to meet with local public leaders.
During the working meeting, they spoke about the key goals and objectives of their work and
discussed the major topics of concern to the residents, namely the development of the Crimean
Tatar language and culture, the registration of land plots and religious buildings, and the
development of the district and town infrastructures.
Annex 33 Exhibit F
One of the key goals of the visit was to promote active cooperation between the Council and
the population, to consider the major topics and to study and solve problematic issues.
The opening speech was delivered by Eskender Bilyalov, a member of the Presidential Council
for Interethnic Relations and President of Inkishaf Society of Crimean Tatars (a Russian public
organisation). “The Saki District and the town of Saki are set as an example in matters of
interethnic relations in the Republic. Not a single unauthorised acquisition of lands has taken
place in the Saki District. I present to you the Council of Crimean Tatars, which is headed by
Sergey Aksyonov, Head of the Republic of Crimea, himself. The Council is intended to work
to better understand those issues facing the Tatars in Crimea”.
“That is why we are now travelling to various regions to reveal and discuss matters of concern
to people”, said Ayder Adzimambetov, Executive Secretary of the Crimean Mufti.
Annex 33 Exhibit F
Ayder Emirov, a research fellow at the Research Institute of the Crimean Tatar Philology and
the History and Culture of Crimean Ethnic Groups of the Crimean Engineering and Pedagogical
University (a state budgetary higher educational institution of the Republic of Crimea), told the
stories of some Crimean Tatars who were heroes of the Great Patriotic War and have deserved
but never received their awards, raising the issues of perpetuating the memory of the dead.
Lemara Selendili, Doctor of Philology and Professor of the Department of the Crimean Tatar
Philology of the Faculty of the Crimean Tatar and Oriental Philology at the Taurida Academy
of the V.I. Vernadsky Crimean Federal University (a federal autonomous state higher
educational institution), raised the problem of the Crimean Tatar language. “The Council was
established to resolve the problematic issues of small peoples, and the Crimean Tatar people
are the most numerous among the small peoples – it is an indigenous people of Crimea”, she
said. “Our task is to enable the implementation of the Crimean Tatar language as the state
language”. She used as an example the Bakhchysarai District where the bus stop signs are
written in both Russian and Crimean Tatar.
The meeting continued as a dialogue, with those present asking questions of concern to them
and receiving competent and exhaustive answers.
Annex 33 Exhibit F
Galina Miroshnichenko, Head of the Saki District Administration, summed up the results of the
meeting. “I am sure, there are no interethnic problems in the Saki District. If any issues arise,
we convene our National Council – we have competent advisers such as Eskender Bilyalov and
Mesfer Settarov, and solve all those issues in a calm atmosphere”, she said.
The meeting was attended by Galina Miroshnichenko, Head of the Saki District Administration;
Andrey Ivkin, Head of the Saki Town Administration; Eskender Bilyalov, a member of the
Presidential Council for Interethnic Relations and President of Inkishaf Society of Crimean
Tatars; Ayder Emirov, a research fellow at the Research Institute of the Crimean Tatar
Philology and the History and Culture of Crimean Ethnic Groups of the Crimean Engineering
and Pedagogical University; Ayder Adzhimambetov, Executive Secretary of the Crimean
Mufti; Lemara Selendili, Doctor of Philology and Professor of the Department of the Crimean
Tatar Philology of the Faculty of the Crimean Tatar and Oriental Philology at the Taurida
Academy of the Vladimir Vernadsky Crimean Federal University; Tamila Abduveliyeva,
secretary of the meeting; the deputy heads of the Saki Town and District Administrations;
members of the Saki Town and District Councils; Mesfer Settarov, Saki District Imam and
Imam of the Yany Jami Cathedral Mosque in Saki; representatives of the administrations of
rural settlements of the Saki District; the heads of structural subdivisions of the Saki District
and Saki Town Administrations; representatives of the Centre of Culture, Arts and Folk Arts of
the Saki Town and Saki District; business people and agricultural producers from the town of
Saki and the Saki District; and representatives of the media established by the Spiritual
Direction of the Muslims of Crimea.
Annex 33 Exhibit F
Section of Organisational and Information Work of the Administration Office
Public discussions

Exhibit G
Municipal Entity Armyansk Urban District, Public Meeting with Representatives of the Council
of Crimean Tatars under the Auspices of the Head of the Republic of Crimea Held in Armyansk
(3 September 2018)
(translation)

Annex 33 Exhibit G
Translation
Armyansk Urban District, Public Meeting with Representatives of the Council of Crimean
Tatars under the Auspices of the Head of the Republic of Crimea Held in Armyansk
(3 September 2018), available at:
http://armgov.ru/sobytiya/v_armyanske_proshla_vstrecha_obwestvennosti_s_predstavit
elyami_soveta_krymskih_tatar_pri_glave_respubliki_krym/.
Public Meeting with Representatives of the Council of Crimean Tatars
under the Auspices of the Head of the Republic of Crimea Held in
Armyansk
3 September 2018
In order to restore historical justice and facilitate the political, social and spiritual revival of
those Crimean Tatars subjected to illegal deportation and political repression on a national
basis, Sergey Aksyonov, the Head of the Republic of Crimea, by his Decree No. 93-U dated
29 March 2018 “On the Establishment of the Council of Crimean Tatars under the Head of
the Republic of Crimea” established the Council of Crimean Tatars under the Head of the
Republic of Crimea, consisting of 15 members. The key tasks of the Council are to develop
and implement a set of measures to restore historical justice and facilitate the political, social
and spiritual revival of the Crimean Tatars in accordance with Russian Federation Presidential
Decree No. 268 dated 21 April 2014 “On Measures to Rehabilitate the Armenian, Bulgarian,
Greek, Italian, Crimean Tatar and German Peoples and Governmental Support for Their
Revival and Development”, RSFSR Laws No. 1107-1 dated 26 April 1991 “On the
Rehabilitation of Repressed Peoples” and No. 1761-1 dated 18 October 1991 “On the
Rehabilitation of Victims of Political Repression” and Article 10 of the Constitution of the
Republic of Crimea, as well as to enable the full integration of the Crimean Tatars into the
multinational and multi-confessional community of Russia, identify and analyse the issues
facing the Crimean Tatars in the Republic of Crimea that need to be resolved in accordance
with Russian Federation Presidential Decree No. 268 dated 21 April 2014 “On Measures to
Rehabilitate the Armenian, Bulgarian, Greek, Italian, Crimean Tatar and German Peoples and
Governmental Support for Their Revival and Development” and RSFSR Laws No. 1107-1
dated 26 April 1991 “On the Rehabilitation of Repressed Peoples” and No. 1761-1 dated 18
October 1991 “On the Rehabilitation of Victims of Political Repression”, and review the
effectiveness and completeness of the implementation of measures to restore historical justice
and facilitate the political, social and spiritual revival of the Crimean Tatars in the Republic of
Crimea in accordance with Russian Federation Presidential Decree No. 268 dated 21 April
2014 “On Measures to Rehabilitate the Armenian, Bulgarian, Greek, Italian, Crimean Tatar
and German Peoples and Governmental Support for Their Revival and Development” and
RSFSR Laws No. 1107-1 dated 26 April 1991 “On the Rehabilitation of Repressed Peoples”
and No. 1761-1 dated 18 October 1991 “On the Rehabilitation of Victims of Political
Repression”.
Annex 33 Exhibit G
On the 30th of August, the administration of the town of Armyansk in the Republic of Crimea
hosted a meeting of Armyansk residents with members of the Council of Crimean Tatars
under the Head of the Republic of Crimea.
The meeting was attended by the following members of the Council of the Crimean Tatar
people under the Head of the Republic of Crimea: Ayder Emirov, a journalist, a publicist and
the first director of the Ismail Gasprinsky Library; Ayder Ismailov, Deputy Mufti of Crimea
Annex 33 Exhibit G
and Master of Islamic Law; Zera Emirsuin, Press Secretary of the Spiritual Direction of the
Muslims of Crimea and Sevastopol; Armyansk religious clerics; the CEOs of various
businesses, institutions and organisations based in Armyansk; and local activists. They
discussed matters of teaching Crimean Tatar children their native language, providing the
local general education libraries with textbooks in the Crimean Tatar language, restoring
toponymic names of settlements and some other matters of interest to the residents of our
town.

Exhibit H
YouTube, ATR TV, The Civil Blockade of Crimea: How it All Started 3 Years Ago and What the
Outcome Was (21 September 2018)
(translation)

Annex 33 Exhibit H
Transcript
Translation
YouTube, ATR TV, The civil blockade of Crimea: how it all started 3 years ago and what
the outcome was (21 September 2018), available at:
https://www.youtube.com/watch?v=_2J5XG_qgjs.
[00:00]
[Host]: “Stop feeding the occupier!” - This was the slogan with which the trade blockade of Crimea
began three years ago on 20 September 2015. It was initiated by the Mejlis. Crimean Tatar leaders
decided to stop trade with the enemy. They allowed only cars to enter the peninsula from Crimea,
completely blocking truck traffic. How did it all begin? And what were the consequences of this action?
My colleagues will tell you.
[00:28]
[Voice-over]: On 20 September 2015, at noon sharp, civic activists block 3 checkpoints into occupied
Crimea: Chongar, Kalanchak and Cheplinka. Anti-vehicle hedges and tyres are deployed at the
administrative border of mainland Ukraine in occupied Crimea. People with Ukrainian and Crimean Tatar
flags walk continuously along the pedestrian crossing. From now on, it is only possible to get in and out
of the peninsula by car or on foot. Trucks carrying goods to the peninsula queue up for kilometres. With
some drivers, emotions fly high.
[01:00]
[Driver]: Where should I go? Am I going to stick here, live here? I need to go to Genichesk. I live there.
Am I driving on my own?
[01:08]
Annex 33 Exhibit H
[Refat Chubarov]: I don't want you to feed those bandits who kill our people. That's it! You will not feed
them.
[01:15]
[Voice-over]: Stop feeding the occupier - this is the principled position of the organizers of the blockade
of Crimea. The Mejlis of the Crimean Tatar people has stopped the supply of goods to the occupied
peninsula.
[01:23]
[Refat Chubarov]: It is unacceptable that our goods should be supporting the occupying power,
especially the military garrisons, which they have set up all over Crimea. Let them think how they are
going to bring food from mainland Russia instead of tanks.
[01:40]
[Voice-over]: Over time, the blockers were joined by the Right Sector, Azov Civil Corps activists and
hundreds of patriotically-minded people. Half a thousand activists guarded the administrative border with
Crimea every day.
[01:52]
[Evelina Arifova]: Here, if you remember all the emotions you had back then. It's unreal to describe,
because my heart was bursting out of my chest. There was such a fountain of patriotism, when you
wanted to do everything possible for Crimea. Someone showed their talents, who could cook - cooked,
who could build - built.
[02:12]
[Voice-over]: This poster contains almost the entire history of the blockade of Crimea. It was created by
Evelina Arifova, now a member of the ‘Asker’ civic formation. From the first days of blockade she was
on duty. It contains names, messages, autographs of those who together wrote the newest history of the
annexed peninsula.
[02:30]
[Lenur Islyamov]: That’s from Donbass here, it says: ‘27.09’. Here, that’s his signature. Enver’s, that is,
his name is Enver Kutia. Here, his signature; he is still here with us now. That’s Amina who is not here
anymore, she is dead now. Here, she wrote: ‘25.09.2015. Amina Tatar Bandera.’ She is, unfortunately, no
longer with us. Here we have: Azov, Right Sector. Here, Vorobey Cossack - the biggest patriot of
Ukraine. Here [unintelligible]. Before that, here, Aydar. Those are from Turkey, who came here: Rambo,
Serbes Turklesov, Lagov.
[03:08]
[Voice-over]: Lenur Islyamov, the organiser of the blockade, recalls that in those days the phone was
ringing off the hook with people wanting to help.
Annex 33 Exhibit H
[03:15]
[Lenur Islyamov]: People called, saying: ‘Hold on!’ People called and said: ‘Come on, where can I
transfer money to?’ You have to give credit to those people who came and worked completely as
volunteers, as cooks. They helped, washed, cleaned and served. It was very hard work! Doctors came.
Doctors who stayed with us. The only thing we didn’t have was childbirth. But there were even weddings.
Really, energy was everywhere. People were all on fire.
[03:41]
[Voice-over]: However, not everyone was so enthusiastic. Ukrainian business at the time, which had close
relations with the already annexed Crimea, was in no way willing to lose billions of dollars in revenue. So
threats to the organizers of the blockade were pouring in every day.
[03:56]
[Lenur Islyamov]: They pushed business cards of some secret service officers in our hands in the vans:
‘Here, please, we are from that man.’ Yanukovych was no longer there, but business was still operating
by those laws. I grew up in that time, I was setting up my business in the time of banditry. That is why,
when people threaten me, I'm not afraid of such people. It is much more difficult with people who quietly
do their business.
[04:18]
[Voice-over]: The leader of the Crimean Tatar people, Mustafa Dzhemilev. Then in 2015 he was at the
forefront of the blockade of Crimea.
[04:26]
[Mustafa Dzhemilev]: In the history of world wars, it had never happened that a partially occupied
country continued to supply the occupier with everything it needed. That happened here because many
people did not give a fig about the territorial integrity of their country, about the dignity of the country.
The main thing for them was to make money.
[04:44]
[Voice-over]: Empty shelves in shops, rising prices on markets - Ukrainian goods stopped coming to
Crimea. Two weeks after the blockade began, high-voltage lines supplying electricity to the peninsula
began to fall down. On 22 November, unknown persons damaged the last tower. The next day, the
occupation authorities declared a state of emergency in Crimea. The lights went out, mobile phone service
was cut off, and people did not go to work. Recalling that time, Mustafa Dzhemilev says that the blockade
was the only right answer to the challenges of reality. Crimea returned to the global political agenda, and
the Cabinet of Ministers officially banned the movement of cargo vehicles across the administrative
border after an appeal by the president. Sanctions against Russia for the annexation of the peninsula,
including trade sanctions, were imposed by almost all EU countries and the US.
[04:26]
Annex 33 Exhibit H
[Mustafa Dzhemilev]: They talked about the blockade, but at the same time they talked about how it had
happened – the occupation of Crimea. Thousands and tens of thousands of publications all over the world.
This is the subject that was understood in Crimea. And the main point of our strategy, as long as we do
not contemplate military liberation of Crimea, is to make the maintenance of the occupied territory of
Crimea as expensive as possible for Russia. And we have achieved that goal too.
[06:15]
[Voice-over]: On 31 December, activists removed all roadblocks at checkpoints with occupied Crimea. In
another year, the trade blockade of Crimea will be hailed in Ukraine and around the world as the first
most effective step to begin de-occupation. But there are many more steps ahead. The main one is
granting autonomy to Crimean Tatars.
[06:36]
[Lenur Islyamov]: The pace we maintained since the blockade, we must keep it up. The ATR TV channel
that airs news every day. It is like an information bomb that flies out of the mainland and hits right on
target because we are telling the truth about what is happening in Crimea. It is not highly visible and
doesn’t bring in cash, but it is very important politically for those people who are now in this hostage
situation in Crimea.
Exhibit I
Ukrinform, ATR Owner Proud to Be Involved in Crimea's Electricity Blockade (5 October 2020)
(translation)

Annex 33 Exhibit I
Translation
Ukrinform, ATR Owner Proud to Be Involved in Crimea's Electricity Blockade (5 October
2020), available at: https://www.ukrinform.ru/rubric-crimea/3112326-vladelec-atrgorditsa-
tem-cto-pricasten-k-blokade-elektroenergii-v-krymu.html.
ATR Owner Proud to Be Involved in Crimea’s Electricity Blockade
By Ukrinform
Lenur Islyamov, the owner of the ATR TV channel, is confident that Russia will be tried in
international courts for violating the territorial integrity of Ukraine because the entire civilised
world is talking about the occupation of Crimea by the Russian Federation.
Mr. Islyamov said this at a briefing at the Ukrainian Ministry of Foreign Affairs on Monday,
an Ukrinform correspondent reports.
“They are trying to prove that our statements encroached on the territorial integrity of the
Russian Federation. I use this venue to declare that not only Lenur Islyamov but the entire
civilised world says the Crimea is occupied and this is an illegal violation of the territorial
integrity of the [Ukrainian] state, so Russia will be prosecuted in international courts”, he
said.
As for the Russian accusations of Mr. Islyamov of organising the blockade of the power
supply of the peninsula, he said he was proud to be involved in this decision.
“Now as regards the fact that I am accused of blocking the power supply of Crimea. There are
different times and periods in people’s lives sometimes you want to forget about, but this is
the time I just want to be proud of because the best citizens of Ukraine did not allow
electricity to be supplied to Crimea... I am proud of what we did, and I am proud of the
decisions made at that time”, Mr. Islyamov said.
The so-called “Prosecutor’s Office of Crimea” reportedly charged Mr. Islyamov under three
articles of the Criminal Code of Russia, viz. “organisation of an illegal armed formation”,
“preparation and commission of acts of sabotage” and “public calls to violate the territorial
integrity of Russia”.
Furthermore, according to lawyer Nikolay Polozov, Russian authorities are trying to claim
against Mr. Islyamov RUB 1 bln (about USD 130-140 mln) in damages allegedly caused to
Russia by the loss of electricity resulting from the power supply blockade of Crimea by
Mainland Ukraine.

Exhibit J
Events.info, ATR TV Owner Called the Peninsula Blockade the Crimean Maidan
(19 September 2015)
(translation)

Annex 33 Exhibit J
Translation
Events.info, ATR TV Owner Called the Peninsula Blockade the Crimean Maidan (19
September 2015), available at:
http://web.archive.org/web/20220225040442/http://www.sobytiya.info/news/15/55768.
ATR TV Owner Called the Peninsula Blockade the Crimean Maidan
By Krym.Realii
Lenur Islyamov, the businessman who owns the Crimean Tatar TV channel ATR, believes no
business may be run with the occupied Crimea.
He made this statement the day before, on the 18th of September in Henichesk, at a meeting of
the coordination council on the blockade of Crimea which Crimean Tatars plan to impose on
the 20th of September.
“Trading with Crimea is a matter of honour for us now, there can be no business. Let us stop
trading on blood. We’re going to stand to the death... This is a Crimean Maidan”, he
said.
At the meeting of the coordination council, a decision was made to allocate a place for the
event where tents will be set up, electricity supplied, a sanitary zone provided around, garbage
collection arranged for, water delivered, and rescue, ambulance, police, SBU and military
operations enabled.
The Kherson police reported earlier that they will install tents and toilets for those activists
who will block the entry of trucks into the annexed Crimea.
Crimean Tatars plan to start blocking the movement of trucks carrying goods to Crimea at
noon on the 20th of September.
Crimean head Sergey Aksyonov said the peninsula is fully prepared for the blockade of food
supplies from Mainland Ukraine.

Exhibit K
Crimea Inform, Ukraine Will Repay Islyamov’s Private TV Channel Multimillion-Dollar Debts
from the State Budget (23 April 2016)
(translation)

Annex 33 Exhibit K
Translation
Crimea Inform, Ukraine Will Repay Islyamov’s Private TV Channel Multimillion-Dollar-
Debts from the State Budget (23 April 2016), available at: https://www.cinform.
info/news/id/37932.
Ukraine Will Repay Islyamov's Private TV Channel Multimillion-dollar-
Debts from the State Budget
Simferopol, 23 April, Kryminform. The Ukrainian Cabinet of Ministers passed a resolution to
allocate financial aid to the private TV channel ATR owed by Lenur Islyamov, who has
arranged for numerous “blockades” of Crimea, the press service of the Ukrainian Ministry of
Information Policy reported.
“According to the resolution, the financial aid will be allocated to pay for satellite
communication services, including the related charges in arrears since February 2014, TV
equipment and premises leased and purchased, and copyrighted properties purchased and
used”, the press service said in its statement.
As became known earlier, Mr. Islyamov’s ATR TV found itself under the threat of winding up
due to UAH 10 mln (about RUB 25 mln) in a debt owed to Sweden-based SES ASTRA AB
(for the use of an Astra A4 satellite). On the 1st of March, the Ukrainian Ministry of
Information Policy suggested that the debt should be paid out of the funds of the Ukrainian
state budget earmarked for support of the Crimean Tatars. On the 10th of March, Arseniy
Yatsenyuk, the then Prime Minister of Ukraine, ordered that UAH 5 mln (RUB 15 mln) be
allocated to repay ATR TV’s debt owed to the Swedish company. ATR TV’s owner himself
donated a chevron worth UAH 1 (RUB 2.5) of the Crimean Tatar battalion he is establishing
to save his media business.

Exhibit L
TASS, Crimean Authorities Commented on the Termination of Broadcasting of ATR TV Channel
in Ukraine (11 February 2020)
(translation)

Annex 33 Exhibit L
Translation
TASS, Crimean Authorities Commented on the Termination of Broadcasting of ATR TV
Channel in Ukraine (11 February 2020), available at: https://tass.ru/obschestvo/7732411.
Crimean Authorities Commented on the Termination of Broadcasting of
ATR TV Channel in Ukraine
By TASS
Simferopol, 11 February, TASS. The employees of the Crimean Tatar TV channel ATR, which
has stopped broadcasting due to the lack of funding from the Ukrainian state budget, should
be invited to work in Crimea, Albert Kangiyev, Chairman of the Republican State Committee
for Interethnic Relations, told TASS.
On Monday, the channel began showing an empty studio with the background slogan “Save
ATR”. ATR’s Deputy General Director Ayder Muzhdabayev said on his YouTube channel
that ATR had stopped broadcasting due to the lack of funding from the Ukrainian state budget,
which has provided UAH 50 mln ($2 mln) for such funding.
“Of course, I feel sorry for those people who went to work there. Some of them are patriotic
about their native land. Probably, we should invite them to work in our Crimean media.
Labour force is always needed”, Mr. Kangiyev said.
He also clarified that the dismissed ATR employees could find a job on the Crimean TV
channel Millet (“People”) or the Crimean radio station Vatan Sedasy (“Voice of the
Motherland”).
In 2016, the Verkhovna Rada of Ukraine permitted state budget funds to be used to support
ATR. The channel has stopped analogue broadcasting in Crimea since the 1st of April 2015 as
it had not been issued a Russian licence. ATR has been broadcasting from Kyiv since the 17th
of June 2015.
Millet Public Crimean Tatar TV and Radio Company were established as an autonomous nonprofit
organisation on the 22nd of April 2015 by a decree of Crimean head Sergey Aksyonov.
The TV channel began broadcasting in the test mode in September 2015. It is designed to
develop the culture and language of the Crimean Tatars and interethnic relations. It broadcasts
24 hours a day in Crimean Tatar (70%) and Russian (30%). The Crimean Tatar radio Vatan
Sedasy (“Voice of the Motherland”) started broadcasting 24 hours a day in Crimea on the 6th
of February 2017.

Exhibit M
RIA Novosti, Who and When Will Build a New Dormitory for KFU Students in Simferopol
(5 December 2022)
(translation)

Annex 33 Exhibit M
Translation
RIA Novosti, Who and When Will Build a New Dormitory for KFU Students in Simferopol
(5 December 2022), available at: https://crimea.ria.ru/20221205/kto-i-kogda-postroitnovoe-
obschezhitie-dlya-studentov-kfu-v-simferopole-1125687137.html.
Who and When Will Build a New Dormitory for KFU Students in
Simferopol?
Tekhstroy LLC will build a new hostel for 250 students of the Crimean Federal
University.
5 December 2022 at 12:53 PM
© RIA Novosti (Crimea). Alexander Druzhinovich
Simferopol, 5 December, RIA Novosti (Crimea). A contractor has been chosen to build a new
hostel for 250 students of the Vladimir Vernadsky Crimean Federal University (CFU) in
Simferopol, the press service of the Single Construction Customer (SCS), an entity that
controls the implementation of the construction project in Russia, reports.
According to the press service, a state contract for developing as-built documentation and
building the hostel having a total area of over 5,000 square meters was awarded to Tekhstroy
LLC.
“The new hostel will accommodate residential, educational, utility and administrative
premises. A sports ground and an open guest parking area will be provided in its territory”,
the company said.
Annex 33 Exhibit M
The façades of the building will be finished in grey-blue and light grey colours with orange
decorative elements, and its underground floor will house a buffet and utility premises. The
project is expected to be completed in 2024.
RIA Novosti (Crimea)’s website says a permit to build the ten-storey hostel building
containing residential, educational, utility and administrative premises was obtained in
February 2022.
The SCS’ press service also recalled that a state contract had been earlier awarded for
building a second hostel for 450 CFU students.
Exhibit N
KFU, New Multimedia Technology Presented at KFU (28 January 2016)
(translation)

Annex 33 Exhibit N
Translation
KFU, New Multimedia Technology Presented at KFU (28 January 2016), available at:
https://cfuv.ru/news/v-kfu-prezentovali-novuyu-multimedijjnuyu-tekhniku.
VLADIMIR VERNADSKY CRIMEAN FEDERAL
UNIVERSITY
New Multimedia Technology Presented at KFU
28 January 2016
By CFU Media Centre
DNK Corporation presented the management, teachers and students of the
Vladimir Vernadsky Crimean Federal University (CFU) with new multimedia
equipment, which is becoming increasingly needed for the educational
process these days.
The presentation took place at the Faculty of Slavic Philology and Journalism of the CFU’s
Taurida Academy. It was attended by Elena Chuyan, CFU’s First Prorector, Vladimir
Polishchuk, CFU’s Prorector for Innovation and Prospective Development, and Vladimir
Kurianov, CFU’s Prorector for Academic and Methodological Activities.
Vladimir Polishchuk noted that the ability to use new state-of-the-art equipment is a key
factor in training qualified personnel today.
“It is no secret that the introduction of the latest technology will qualitatively improve the
educational process and increase the focus of attention and the perception of materials taught
by students. I hope this meeting will become a starting point for our further joint projects”, he
said.
Vladimir Kurianov added that the use of advanced multimedia technology will help to create
a uniform environment, which will perform educational functions for social and humanitarian
disciplines as well as for natural science, engineering, medical and other specialties. That is
especially important for the Crimean Federal University, given the fact that its branches are
located throughout Crimea.

Annex 34
, Informational Note
(translation)

Annex 34
Informational note
1. The Eshref Shemyi-Zade Secondary General Education School No. 42 (hereinafter
referred to as the “School”) is located at the address 33 Selsky lane, Simferopol, Crimean
Republic.
2. There are approximately 2,000 children of various nationalities (Russian, Crimean Tatar,
Armenians and representatives of other nationalities). The main priority of school’s
educational work is promoting respect and tolerance to each other regardless of ethnic
origin.
3. School creates all necessary conditions for studying Crimean Tatar culture and language
in accordance with the Federal law as of 19 December 2012 No.273-FZ “On education
in Russian Federation”, legislative acts of Crimean republic, letters and ordinances of
Ministry of education, science and youth of Crimean Republic, Education Directorate of
administration of Simferopol, the Charter of the School.
4. All pupils at the school are familiar with Crimean Tatar culture and respect the national
traditions. It is named after the famous Crimean Tatar poet Eshref Shemyi-Zade.
5. The School is located in a place with a high concentration of Crimean Tatars and a
particular attention to language learning is paid at the School. The Crimean Tatar
language is included in the curriculum of all classes, and our teachers participate in
thematic workshops where they share methods of teaching the language. Besides, on a
yearly basis upon application of parents (under art. 14 of the Federal law as of 19
December 2012 No.273-FZ “On Education in Russian Federation”) classes are created
with education on Crimean Tatar language, among other classes and all spheres of school
social life certain elements of Crimean Tatar language are integrated.
6. In order to successfully master Crimean Tatar language one should not rely only on school
education, but also practice in live communication within the family which is a priority
in language study.
7. There is an ethnographic corner museum within the walls of the school of Crimean Tatar
decorative and applied arts, household items, national costume, embroidery, coinage etc.,
schools’ library is being regularly supplemented. The school anthem, written by our
Annex 34
students (music and words) is also performed in Crimean Tatar. The signs in the corridors
and on the doors of the classrooms, the informational boards are bilingual.
8. As a result of the education of native language – participation and victories in regional
and municipal stages of Federal competition of students (discipline Crimean Tatar
language and literature).
9. A dance ensemble “Yildizlar” (Starlets) functions in our school as an out of curriculum
activity. Classes are led by Honoured Artist of Crimea Maye Dilyaverovna Anafieva.
10. The result of the constructive work of our teachers, parents and children aimed at
performing the educational standards is a high presentage of our students being admitted
to the universities. Some students go to Crimean universities in faculties directly related
to the study of the Crimean Tatar language (e.g., Crimean Tatar Philology Faculty) and
then come back to us as young teachers.
11. Existence of such schools is important as it prevents linguistic or cultural discrimination
and supports the development of Crimean Tatar language, history, and culture of Crimean
Tatar people.
Annex 35
Ministry of Internal Affairs, Information on the number of missing persons in the Republic of
Crimea and the City of Sevastopol between 2014 and 2022, No. 3466/dp, 22 February 2023
(translation)

Annex 35
Translation
Ministry of Internal Affairs, Information on the number of missing persons in the Republic of
Crimea and the City of Sevastopol between 2014 and 2022, No. 3466/dp, 22 February 2023.
MINISTRY OF INTERNAL
AFFAIRS OF THE RUSSIAN
FEDERATION
16 Zhitnaya Street, Moscow, 119991
1 March 2023 No. 1/2165
In reply to No. 3466/dp dated 22 February 2023
To the Deputy Minister of Foreign
Affairs of the Russian Federation,
M. Yu. Galuzin
[Stamp]:MFA of Russia 172
Legal Department
Entry No. 4017
3 March 2023
[Stamp]: MFA of Russia 172
General Secretary
No. 8901
1 March 2023
19 55
Re sharing of information
Dear Mikhail Yuryevich,
The Ministry of Internal Affairs of the Russian Federation is hereby forwarding
information within the scope of our competence concerning the results of our
considering the request of the Ministry of Foreign Affairs of Russia regarding the
defence of our country’s interests in “Ukraine v. Russian Federation”.
Annex: as per text, 2 pages, 1 copy.
Respectfully,
Deputy Minister A. I. Khrapov
THE DOCUMENT IS SIGNED WITH ELECTRONIC
SIGNATURE
Certificate <…>
Owner <…>
Valid from 14 October 2022 till 7 January 2024
Prepared by <…>
<…>
Annex 35
Annex No. 1
Information
on the number of missing persons in the Republic of Crimea and Sevastopol
between 2014 and 2022
Between 2014 and 2022, 1,353 cases were opened to search for missing persons
(1,039 Russians, 228 Ukrainians and 86 Crimean Tatars), 1,095 were discontinued (878
Russians, 148 Ukrainians and 69 Crimean Tatars) and the location of 258 such persons is
being established (161 Russians, 80 Ukrainians and 17 Crimean Tatars) in the Republic
of Crimea and Sevastopol1.
Of the total number of such persons, 188 missing person search cases were
opened in relation to persons whose disappearance led to a criminal investigation (148
Russians, 23 Ukrainians and 17 Crimean Tatars); 55 cases were discontinued (42 Russians,
10 Ukrainians and 3 Crimean Tatars); and the location of 133 such persons (106 Russians,
13 Ukrainians and 14 Crimean Tatars) is being established.
Ministry of Internal Affairs of Russia
1 According to the Ministry of Internal Affairs of the Republic of Crimea and the Sevastopol Department of the Ministry
of Internal Affairs of Russia.
Annex 35
Annex No. 2
Information
on criminal prosecutions for extremist crimes and the number of missing persons in
the Russian Federation between 2014 and 2022
Between 2014 and 2022, 7,679 persons were prosecuted for extremist crimes in
the Russian Federation. 1
A total of 588,265 (taking into account the previous years balance) missing persons
were searched for; of these 243,315 were reported missing during the period in
question. A total of 131,246 criminal proceedings were instituted in connection with
the disappearance of people.
The search for 266,563 such persons was discontinued; of these 230,313 persons
were located.
As of 1 January 2023, there were 321,752 missing persons; of these 124,744 are
searched for as part of criminal investigations.
Moreover, please note that the search for missing persons is conducted in
accordance with the requirements of the Constitution of the Russian Federation, Federal
Law No. 3 "On the Police" dated 7 February 2011 and Federal Law No. 144 "On the
Conduct of Investigations" dated 12 August 1995, as well as departmental and
interdepartmental regulations. When applications concerning such incidents are
considered, the nationality of the persons concerned or their racial or ethnic background
do not affect the objectivity in the consideration of the applications or of decisions in
their respect or the comprehensiveness of investigations conducted.
Ministry of Internal Affairs of Russia
1 According to the Federal State Institution "Main Information and Analysis Centre of the Ministry of Internal Affairs of
the Russian Federation".

Annex 36
Uspishna Varta, THE RIGHT TO FREEDOM OF SPEECH AND OPINION IN UKRAINE: THREATS AND
OPPORTUNITIES, 2018

Annex 37
Mediacentre n.a. I. Gasprinsky, Letter, 2 March 2023
(translation)

Annex 37
Page 1 out of 7
Translation
Mediacentre n.a. Ismail Gasprinsky, Letter, 2 March 2023.
State Committee on Inter-
Ethnic Relations of the
Republic of Crimea (in
Ukrainian)
State Committee on Inter-
Ethnic Relations of the
Republic of Crimea (in
Russian)
State Committee on Inter-
Ethnic Relations of the
Republic of Crimea (in
Crimean Tatar)
State Autonomous Institution of the Republic of Crimea Mediacentre n.a. Ismail
Gasprinskiy (in Russian)
State Autonomous Institution of the Republic of Crimea Mediacentre n.a. Ismail
Gasprinskiy (in Ukrainian)
State Autonomous Institution of the Republic of Crimea Mediacentre n.a. Ismail
Gasprinskiy (in Crimean Tatar)
Trubachenko Str., 23a, Simferopol, Republic of Crimea, 295048, 8(918) 024-46-24, E-mail:
[email protected]
TIN 9102192812, KPP 910201001, Reg. No. 1159102113455
To the Ministry of Foreign Affairs
of the Russian Federation
Russian Federation, 119002,
Moscow, 32/34 Smolensky Blvd.
To Monastyrsky, Zyuba, Stepanov
& Partners
Russian Federation, 121099,
Moscow, 3 Novinsky Blvd., bld. 1
To Partner, Attorney at law
K.N. Udovichenko
2 March 2023
Dear Attorneys at law!
In response to your request for information about the work of Mediacentre n.a. Ismail
Gasprinskiy we inform on the following
The State Autonomous Institution of the Republic of Crimea Mediacentre n.a. Ismail
Gasprinskiy (hereinafter, “Mediacentre”) considered the request for information dated 24 February
2023, sent by Monastyrsky, Zyuba, Stepanov & Partners, acting on behalf of the Ministry of Foreign
Affairs of the Russian Federation.
Below we provide you with answers to the questions contained in the request concerning the
work of the Mediacentre with printed publications in various languages of peoples living in Crimea,
for their use in the preparation of the written position of the Russian Federation in the dispute initiated
by Ukraine against the Russian Federation before the International Court of Justice.
On the setting up and objectives of the Media Center
Annex 37
Page 2 out of 7
The Mediacentre was set up in 2015 as part of the state programme for the ethno-cultural
development of nationalities living in Russia. It is named after Ismail Gasprinskiy, a famous Crimean
Tatar activist, who worked hard throughout his life to produce various newspapers and magazines,
carried out educational activities with purpose to promote the Crimean Tatar language and to preserve
and develop cultural diversity. Media Center has a similar aim – to support the production of media
and literature in the languages of all peoples, ethnic groups, and national minorities, thus contributing
to the preservation of languages, culture and traditions.
In the past seven years alone, we have published more than 220 books in the languages of the
peoples living in Crimea: Crimean Tatar, Armenian, Ukrainian, Greek, Hebrew, German, Italian,
Bulgarian and others.
Since our creation, we have continued to develop: every year the number of print media
published at the expense of state subsidies increases, and all of them actively popularize the culture
and literature of the Crimean peoples. Since 2019 we have a small printing house of our own. It is
noteworthy that before 2014 there were very few such opportunities in Crimea.
The Media Center has three main areas of activity:
- support of 15 mass media, including in Russian, Crimean Tatar, Ukrainian, Armenian,
German, Bulgarian and Greek languages;
- publication of books on the culture of the peoples of Crimea, including in Russian,
Crimean Tatar, Ukrainian, Armenian, Bulgarian and Krymchak languages;
- organisation of events: conferences, presentations, round tables, etc.
Support of mass media operations
We support a range of mass media, most of which target specific ethnic groups in Crimea. At
the moment, the Mediacentre n.a. I. Gasprinskiy has 15 different newspapers and magazines. Many
of the publications have a very rich history and it is therefore important to support them.
A special place in the Media Center is given to Crimean Tatar periodicals. In particular, the
Mediacentre publishes under its aegis:
- the weekly newspaper «Yan’i Dunya» (“New World”) – a publication with a unique
history. It was first published in 1918 and changed within the development of the
Crimean Tatar language. Its circulation is 1,000 copies.
- the magazine “Yildiz” (“The Star”) can be called a unique monument to the Crimean
Tatar literary language. It was created during the years of the deportation of Crimean
Tatars, and prominent Crimean Tatar writers and poets have published in it. Its
circulation is 500 copies.
- the magazine “Arzy” is dedicated to the role of Crimean Tatar women in history and
literature. It was created recently, but continues the tradition established back in 1906
by Ismail Gasprinskiy’s daughter, Shefika, leader of the Muslim women’s movement.
Its circulation is 200 copies.
- the newspaper “Meraba” (“Hello”) is a relatively new publication (it was created in
2015) that on a weekly basis publishes information about the latest developments not
Annex 37
Page 3 out of 7
only in the lives of Crimean Tatars but also of other peoples of Crimea. Its staff also
takes part in radio and TV programmes where they discuss current news. Its
circulation is 1,000 copies.
- the magazine for teachers of the Crimean Tatar language «Ana tili odzhalaryna»
provides methodological and didactic support for the teaching process and also gives
advice on how to preserve the mother language in families. Its circulation is 500
copies.
The newspaper “Yan’i Dunya” was shortlisted (10 best projects) and placed 6th at the All-
Russian Public Award for Preservation of Linguistic Diversity of the Russian Federation “Key word”,
in the nomination “For Contribution to Preservation of Mother Language”. In 2022, 232 applications
from 61 regions of the Russian Federation and from Belarus were received for this competition.
We also attach great importance to preserving the languages and cultures of other peoples of
Crimea.
To support the functioning of the Ukrainian language, the newspaper “Krymsky Visnyk”
(“Crimean Herald”) publishes both ethnographic essays and articles on topical issues. Its circulation
is 500 copies.
The Mediacentre also publishes media aimed at other peoples: for example, the newspaper
“Hoffnung” (“Hope”) is intended for Crimean Germans, who participate directly in its production (its
circulation is 500 copies); the magazine “Dove of Masis”, which was founded as far back as 1855
and is publishing periodically for almost 30 years, tells about the history, culture and famous
personalities of Crimean Armenians (its circulation is 500 copies); the Bulgarian newspaper “Izvor”
(its circulation is 500 copies) are published for Crimean Bulgarians, and the newspaper “Tavrik” is
for Greeks.
It is up to the staff of the publications to decide on the content, and it is important to us that the
newspapers and magazines involve people from specific cultures.
We consider it important to create and support mass media that could be of interest to Crimeans
from different ethnic backgrounds. For example, the magazine “Crimea” publishes literary works in
Crimean Tatar, Ukrainian and Russian. The cultural and educational magazine “Our Crimea”, which
was founded in 2016, tells both about the culture of Crimea in general (architecture, theatre, traditions
of the people, iconic figures) and about activities and events of separate national-cultural formations,
and a certain part of each issue is devoted to one of the peoples of Crimea. And our new project –
youth magazine “We! Youth magazine Crimea” – has no “nationality” at all. Its target audience is all
Crimean youth. It publishes materials in the 3 national languages.
All mass media that were registered on the peninsula before 2014 and expressed a desire to reregister
were able to do so after submitting the relevant application without any bureaucratic delays
and within the time limits stipulated by Russian law.
Publication of socially significant literature
We believe that the foundation for preserving both the functionality of language and culture is
books, so the Mediacentre also publishes socially significant literature. A particularly important area
Annex 37
Page 4 out of 7
is the publication of books in native languages.1 To control the quality of published literature, the
Mediacentre has an Advisory Council for publishing socially significant literature in native languages
that includes writers, teachers, academics and journalists, including those of Crimean Tatar,
Ukrainian, Armenian and Greek origin.2 The Advisory Council meets at least once a year to review
manuscripts whose authors or compilers have applied for inclusion on the list for publication at the
expense of the state budget.
In the seven years of its existence, more than 220 books in Crimean Tatar, Ukrainian, Bulgarian,
Armenian, Hebrew, Krymchak, and Russian have been published, as well as books about the culture
of other nationalities: Karaites, French, Estonians, Greeks.3 The publication of literature and printed
mass media in the languages of the peoples of Crimea is financed both from the federal budget
(Federal Agency for Nationalities) and from the budget of the Republic of Crimea.
In accordance with Federal Law No. 77-FZ dated 23 November 1994 “On Mandatory Copies
of Documents”, part of the circulation of publications published with the assistance of the
Mediacentre is distributed free of charge to libraries, including outside Crimea. In particular, the
Media Center sends:
- to the federal executive branch in the area of the press, mass media and mass
communications one obligatory copy of all types of printed publications;
- to the Russian State Library mandatory copies of all types of printed publications for
subsequent distribution to the largest libraries and information institutions (from 3 to
16 copies);
- to the Russian State Library, within seven days from the date of publication of the
first batch of printed publications using information and telecommunications
networks two mandatory copies of the printed publications in electronic form,
certified by a qualified electronic signature;
- to the State Budgetary Institution of Culture of the Republic of Crimea «Crimean
Republican Universal Scientific Library named after I.Y. Franko» three mandatory
copies of all types of printed publications.
Also, in accordance with the Law of the Republic of Crimea “On Mandatory Copies of
Documents” dated 22 March 2017 No. 368-ZRK/2017 the Mediacentre sends three mandatory copies
of all types of printed publications to the State Budgetary Institution of Culture of the Republic of
Crimea “Republican Crimean Tatar Library n.a. I. Gasprinskiy” if the publication is done in Crimean
Tatar language or concerns Crimean Tatars.
1 See, for example, Y. Bolat, A FLOCK OF SHEEP CAUGHT IN A STORM. TRANSLATION FROM THE CRIMEAN TATAR INTO
RUSSIAN, UKRAINIAN, ARMENIAN (Mediacentre n.a. I. Gasprinsky, 2020) (Exhibit A); L. Ukrainka, A FLOWER IN THE
PALM OF ETERNITY. SELECTED WORKS (Mediacentre n.a. I. Gasprisnky, 2021) (Exhibit B).
2 See Mediacentre n.a. I. Gasprinsky, Membership Composition of the Advisory Council on the publication of socially
important literature in native languages at the State Autonomous Institution of the Republic of Crimea “Mediacentre n.a.
I. Gasprinsky” (Exhibit C).
3 See Mediacentre n.a. I. Gasprinsky, List of books published by the State Autonomous Institution of the Republic of
Crimea “Mediacentre n.a. I. Gasprinsky” (Exhibit D).
Annex 37
Page 5 out of 7
Multiple copies of the books are sent to the Ministry of Culture of the Republic of Crimea and
distributed throughout the library network of the whole peninsula.
According to their content and focus, the publications are donated to national-cultural
autonomies and other public organizations of the Republic, many of which have established their own
libraries based on the books, albums and almanacs published by the Media Center.
The Mediacentre prides itself on books that glorify the exploits of the multinational people of
Crimea during the Great Patriotic War. For example, under aegis of the Media Center were published
the book “Loyal Daughters of Crimea. Officers, Partisans, Underground Women” describing the valor
and contribution to the victory of Crimean Tatars in the war years,4 a photo album for the 100th
anniversary of Amet-Khan Sultan, twice Hero of the Soviet Union, “Kyrymnin Sadyk Kyzy” about
the exploits of Hero of Russia Alime Abdennanova.5 The Mediacentre also supported the publication
of the multi-volume book “Contribution of the Repressed Peoples of the USSR to the Victory in the
Great Patriotic War of 1941-194”» and the multi-volume book “Reverse side of the war” dedicated
to the exploits of Crimean Tatars among others.6
In addition, the Mediacentre is publishing facsimile editions of the rarest books that exist in
Crimean libraries in a single copy.
The Mediacentre’s website works active, with the most current news from the national-cultural
associations of Crimea and PDFs of all newspapers and magazines published by Media Center. There
you can also find books published during all the years of the organization's existence.
Organisation of events, educational activities
We also see our aim as promoting and developing the culture of Crimea and its nationalities,
and so we regularly hold conferences, round tables and meetings on various subjects, celebrate
memorable dates in the history of Crimea and, of course, organise presentations of our new books. In
all, we have organised and participated in 28 events in 2022, including:
• Cheronopolye Village, Belogorsk District, Greek holiday “Panair”;
• Chutuf-Kale Fortress, Bakhchisaray District, Crimean Karaites’ Cultural Days;
• Simferopol, Republican Crimean Tatar Library n.a. I. Gasprinsky, Library Forum
“Crimean Tatar Book”;
• Simferopol, International Round Table “Development of Links between Crimean
Ukrainians and their Compatriots Abroad”;
• Simferopol, Crimean Tatar State Academic Musical and Drama Theatre, Khydyrlez
national holiday;
4 L. Khalilova, FAITHFUL DAUGHTERS OF CRIMEA: OFFICERS, PARTISANS, UNDERGROUND WOMEN (Mediacentre n.a. I.
Gasprinsky, 2020) (Exhibit E).
5 U. Edemova, THE HERO GIRL OF THE CRIMEAN TATAR PEOPLE (Mediacentre n.a. Gasprinsky, 2020) (Exhibit F).
6 S. Akieva, R. Kurtseitov, CONTRIBUTION OF THE REPRESSED PEOPLES OF THE USSR TO VICTORY IN THE GREAT
PATRIOTIC WAR OF 1941-1945, VOLUME II. CRIMEAN TATARS, BULGARIANS, GREEKS AND ARMENIANS OF CRIMEA
MESKHETIAN (AHISKA) TURKS (Mediacentre n.a. I. Gasprinsky) (Exhibit G).
Annex 37
Page 6 out of 7
• Peschanoye Village, Bakhchisaray District, interethnic youth forum;
• Bakhchisaray, Central Library n.a. A.S. Pushkin, historical excursus “In the Unity of
the Peoples of Crimea”;
• Simferopol, meeting of the Public Council for Harmonisation of Interethnic Relations;
• Simferopol, Republican Crimean Tatar Library n.a. I. Gasprinsky, literary readings
“The World of Ismail Gasprinsky”;
• Simferopol, Republican Crimean Tatar Library n.a. I. Gasprinsky, International Book
Giving Day, “Give Books with Love” event;
• Simferopol, mourning events dedicated to the Day of Remembrance for victims of the
deportation from Crimea;
• Simferopol, Gagarin Park, Crimean Tatar Flag Day;
• Simferopol, Beloye-5, participation in the celebration of “Eid al-Fitr”;
• Simferopol, Beloye-5, Crimean Tatar national holidays “Derviza”;
• Kerch, V.G. Belinsky Central City Library, library forum “Crimean Tatar Book”;
• Feodosiya, festival of Crimean Tatar culture “Kefe Gulleri”;
• Simferopol, Crimean Tatar Academic Music and Drama Theatre, festival of Crimean
Tatar culture “Qirim Naghmeleri”;
• Simferopol, Republican Crimean Tatar Library n.a. I. Gasprinsky, Crimean Tatar
Writing and Culture Day;
• Simferopol, International Round Table “Development of links between Crimean Tatars
and their compatriots abroad”.
We already have 24 events planned for 2023, and the number is growing.
We also help to develop national journalism in Crimea – we regularly host internships for
journalism students who learn how to work in a creative multicultural environment, also we organise
seminars, forums and workshops for young aspiring journalists.
2 March 2023
[SIGNATURE] Vagan Vazgenovich Vermishyan,
Head of State Autonomous Institution of
the Republic of Crimea Mediacentre n.a.
Gasprinsky
Annex 37
Page 7 out of 7
LIST OF EXHIBITS:
Number: Name:
Exhibit A Y. Bolat, A FLOCK OF SHEEP CAUGHT IN A STORM. TRANSLATION FROM THE
CRIMEAN TATAR INTO RUSSIAN, UKRAINIAN, ARMENIAN (Mediacentre n.a. I.
Gasprinsky, 2020).
Exhibit B L. Ukrainka, A FLOWER IN THE PALM OF ETERNITY. SELECTED WORKS
(Mediacentre n.a. I. Gasprisnky, 2021).
Exhibit C Mediacentre n.a. I. Gasprinsky, Membership Composition of the Advisory
Council on the publication of socially important literature in native languages
at the State Autonomous Institution of the Republic of Crimea “Mediacentre
n.a. I. Gasprinsky”.
Exhibit D Mediacentre n.a. I. Gasprinsky, List of books published by the State
Autonomous Institution of the Republic of Crimea “Mediacentre n.a. I.
Gasprinsky”.
Exhibit E L. Khalilova, FAITHFUL DAUGHTERS OF CRIMEA: OFFICERS, PARTISANS,
UNDERGROUND WOMEN (Mediacentre n.a. I. Gasprinsky, 2020).
Exhibit F U. Edemova, THE HERO GIRL OF THE CRIMEAN TATAR PEOPLE (Mediacentre
n.a. Gasprinsky, 2020).
Exhibit G S. Akieva, R. Kurtseitov, CONTRIBUTION OF THE REPRESSED PEOPLES OF THE
USSR TO VICTORY IN THE GREAT PATRIOTIC WAR OF 1941-1945, VOLUME II.
CRIMEAN TATARS, BULGARIANS, GREEKS AND ARMENIANS OF CRIMEA
MESKHETIAN (AHISKA) TURKS (Mediacentre n.a. I. Gasprinsky).
Annex 37
Exhibit A
Y. Bolat, A FLOCK OF SHEEP CAUGHT IN A STORM. TRANSLATION FROM CRIMEAN TATAR TO
RUSSIAN, UKRAINIAN, ARMENIAN (Mediacentre n.a. I. Gasprinsky, 2020).
Annex 37
Exhibit B
L. Ukrainka, A FLOWER IN THE PALM OF ETERNITY. SELECTED WORKS (Mediacentre n.a. I. Gasprisnky, 2021).
Lesya Ukrainka
A Flower in the Palm of Eternity
Annex 37
UDC 821.161.2
BBK 84(Ukr)
U 45
Published by the Ismail Gasprinsky Media Centre state-funded
autonomous institution of the Republic of Crimea with the support of
the State Committee for Interethnic Relations of the Republic of
Crimea on funds from the federal budget and from the budget of the
Republic of Crimea. Approved by the Advisory Council on publication
of socially important literature in native languages under the Ismail
Gasprinsky Media Centre state-funded autonomous institution of the
Republic of Crimea.
Not for commercial distribution
Lesya Ukrainka
A Flower in the Palm of Eternity. Selected works. Simferopol, I.
Gasprinsky Media Centre state-funded autonomous institution of the
Republic of Crimea, 2021, 168 pages, In Ukrainian and Crimean Tatar
languages.
ISBN 978-5-6046689-2-4
The artistic legacy of Lesya Ukrainka is fertile soil for researchers of
the phenomenon of literary space and time. Translation is also a path to
the Poet. There is always a small miracle of turning “the indifference
of a dictionary” indifference" into a trembling vibration of the strings
of one’s soul.
UDC 821.161.2 BBK84(Ukr)
ISBN 978 5-6046689-2-4
© Lesya Ukrainka, author, 2021
© Basyrov, V., compiler, 2021
© Kandymov, Yu., translation from Ukrainian into Crimean Tatar,
2012
© I. Gasprinsky Media Centre state-funded autonomous institution of
the Republic of Crimea, 2021,
Annex 37
[Inclined Melody poem in Ukrainian] [Inclined Melody poem in Crimean Tatar]
Annex 37
A literary/artistic publication
Lesya Ukrainka
A FLOWER IN THE PALM OF ETERNITY
Selected Works
Compiled by V.M. Basyrov
Translated from Ukrainian into Crimean Tatar by Y.U. Kandymov
Preface by Doctor of Philology, professor, senior research fellow of the Fevzi Yakubov
Research Institute for Crimean Tatar Philology, History and Culture of the Ethnic Groups of
the Crimea V.I. Gumenyuk
Ukrainian texts edited by N.Y. Seitvelieva
Crimean Tatar texts edited by: N I. Bekirov, E R. Ajalimova
Artist: R I. Vaapov
Crimean Tatar text proofread by S.S. Sitzhalilova
Computer layout by E R. Ajalimov
Signed to print: 02 August 2021. Format: 70x100 1/16.
Offset printing. Font: BannikovaC. Conventional printed sheet: 13.65.
Quantity: 10.5 conventional printed sheets. Circulation 300 copies. Order No. 21 -14795.
I. Gasprinsky Media Centre state-funded autonomous institution of the Republic of Crimea
23-a Trubachenko Street, Simferopol, 295048, Republic of Crimea
E-mail: [email protected] | OGRN 1159102113455
Printed by CONSTANT LLC printing house
1/12 Berezovaya Street, Severny, 308519, Belgorod region
Phone/Fax +7 (4722) 300-720, www.konstanta-print.ru
Annex 37
Exhibit C
Mediacentre n.a. I. Gasprinsky, Membership Composition of the Advisory Council on the
publication of socially important literature in native languages at the State Autonomous
Institution of the Republic of Crimea “Mediacentre n.a. I. Gasprinsky”.
Membership Composition of the Advisory Council on the publication of socially important
literature in native languages at the State Autonomous Institution of the Republic of
Crimea “Mediacentre n.a. I. Gasprinsky”
Chairman:
VERMISHYAN
Vagan Vazgenovich
Director of the State Autonomous Institution of the Republic of
Crimea “Mediacentre n.a. I. Gasprinsky”
Deputy chairman:
IBRAGIMOVA
Adile Aidynovna
Deputy Director for editorial and publishing activities of the State
Autonomous Institution of the Republic of Crimea “Mediacentre n.a. I.
Gasprinsky”
Secretary:
VESELOV
Andrey Viktorovich
executive secretary of the publishing department of the State
Autonomous Institution of the Republic of Crimea “Mediacentre
n.a. I. Gasprinsky”
Council members:
YAKUBOV
Ruslan Rishatovich
First Deputy Chairman of the State Committee for Interethnic
Relations of the Republic of Crimea;
GLUSHCHENKO
Elizaveta Alexeyevna
Deputy Minister of Internal Policy, Information and
Communications of the Republic of Crimea;
PATRUSHEV
Sergei Anatolievich
Head of the Department of Museums, Libraries and Culture
Education of the Ministry of Culture of the Republic of Crimea;
OSMANOV
Dlyaver Kazimovich
Head of the Department of Interethnic Relations and Socio-Cultural
Adaptation of Migrants;
JAGYAEVA
Gulnara Sabrievna
Director of the state budgetary institution of the Republic of Crimea
“Mediacentre n.a. I. Gasprinsky”;
SELENDILY
Lemara Sergeyevna
Doctor of Philology, Professor of the Department of Crimean Tatar
Philology at the Institute of Philology of the Vernadsky KFU,
Secretary and Coordinator of the Council of Crimean Tatars under
the auspices of the Head of the Republic of Crimea;
LAPTEV
Yuri Nikolayevich
Director of the State Budgetary Institution of the Republic of
Crimea “Mediacentre n.a. I. Gasprinsky”;
RICKMAN
Grigory Mihailovich
Member of the All-Russian Public Organization "Union of
Journalists of Russia", PhD in Biology, Chairman of the Board of
the Local National and Cultural Autonomy Public Organization
“Mediacentre n.a. I. Gasprinsky”;
Annex 37
GANIEVA
Emine Suleymanovna
PhD. in Philology, Associate Professor, Dean of the Faculty of
History, Arts, Crimean Tatar Language and Literature
BASYROV
Valery Magafurovich
Chairman of the Board of the Public Organisation “Union of Writers
of the Republic of Crimea”, Director of the Limited Liability
Company “Izdatelstvo Dolya”
EDEMOVA
Urie
Crimean Tatar writer, novelist
VELIEV
Ablyaziz
Head of the Laboratory of the Research and Development Institute
of Crimean Tatar Philology, History and Culture of Ethnic Groups
of the State Budget Educational Institution of the Republic of
Crimea “Fevzy Yakubov KIPU”;
GRIDCHINA
Anastasia Sergeyevna
Chairman of the Council of the Regional Public Organisation
"Ukrainian Community of Crimea";
OSMANOV
Dlyaver Ibraimovich
Editor-in-chief of the literary magazine Yildiz;
SULEIMANOV
Seyran Akbaraliyevich
poet, novelist, editor-in-chief of the newspaper Yan’y Dunya;
SHONUS
Ivan Aristovich
Deputy Chairman of the Committee of the State Council of the
Republic of Crimea on People's Diplomacy and Interethnic
Relations, Chairman of the public organisation “Tavrida Regional
National and Cultural Autonomy of Greeks of the Republic of
Crimea”
Annex 37
Exhibit D
Mediacentre n.a. I. Gasprinsky, List of books published by the State Autonomous
Institution of the Republic of Crimea “Mediacentre n.a. I. Gasprinsky”.
List of books published by the State Autonomous Institution of the Republic
of Crimea “Mediacentre n.a. I. Gasprinsky”
10 books published in 2015.
## Title
1. "Russia, the West and the Muslim World", I. Gasprinsky;
2. "Chynlar ve maneler", K.Jamanakli;
3. "Eight Steps in the Footsteps of a Teacher", R. Shakir-Aliyev;
4. "The I. Gasprinskiy Crimean Tatar Republican Library: 25 Years";
5. "Fikir Injileri, U. Kurkchi;
6. "Takdirler Alemi", S. Medjitova;
7. "Calendar of Significant and Commemorative Dates", D. Belyalova;
8. "Tales and Legends of the Tatars of Crimea";
9. "Bekle meni den'iz", B. Ablaev;
10. "Ocalar”, L. Haibullaeva, Z. Islyamova.
23 books published in 2016.
## Title
1. "Fikir Injileri;
2. "San'yrzyz alem", A. Veliyev;
3. "Origin of the Crimean Tatars", A. Memetov;
4. "Crimean Bulgarians: Historical and Ethnographic Sketch", I. Noskova;
5. "Crimean Tatar violin music", N. Amedov;
6. "The Book of Travel. Crimea and Adjacent Regions", by E. Chelebi;
7. "The historical and cultural heritage of the Crimean Karaites";
8. "The Germans of Crimea. The Spirit of Activity", Y.N. Laptev, Y.K. Gempel;
Annex 37
9. "Kyrymchahlar", N. Sumina;
10. "The Almanac;
11. "Tales and Legends of the Crimean Tatars";
12. "The Peoples of Crimea", Laptev Y.N., Prokopenkov V.N.;
13. "Tylsimli masallar", R. Suleymanov;
14. "Sailama Eserler", R. Fazil;
15. "Aineji tilkichik", Dermenji;
16. "Tylsymly kyuvet", L. Shamil;
17. "Qyssa-i Yusuf", by Khalil oghlu Ali;
18. "Masallar balalar ichun", A. Useinov;
19. "Alim akında yır, legend ve khatyrlav jıyıntıgı";
20. "Aivanlar akında masallar", L.N. Tolstoy;
21. "Kyrym Tatar Masallar ve Legendalar";
22. "Balychyk ve balikchi akynda masal", A.S. Pushkin;
23. "Masallar", H.H. Andersen;
33 books published in 2017
## Title
1. “Tales and Legends of the Crimean Tatars" in Russian
2. "Yurek syrlarym" collection of poems in the Crimean Tatar language by V. Kipchakova
3. "Ismail bey Gasprinsky. Ayats ve faalieti" by S. Gafarov, translated by R. Fazil.
4. "Chokarak" collection of selected poetry, in Crimean Tatar by B. Mambet
5. "Crimea. Surb Khach Monastery" in Russian and Armenian
6. “Unruly Taurica. Asandr" in Russian by Kesmeji
7. "Eger anamny tapsa edim..." a collection of stories in Tatar, by Ilyasova
8. “Altyn Ornekler" (golden patterns) collection of stories in Crimean Tatar, Useinova
9. “Combat Officers”, Veliyev
Annex 37
10. “Crimean Tatar artists, masters of arts and crafts and architects", E. Cherkezova
11. "Buyuk-As", by U. Kenzhikaeva, in Crimean Tatar and Russian
12. "Crimean Tatars in the underground guerrilla movement in the Crimea during the Great
Patriotic War (1941-1944)". Documentary study, in Russian. Author R. Muzafarov
13. Baar (novel) by I. Abduramanov, in Crimean Tatar
14. "Halk shairi Eshmyrza" (facsimile edition), by Eshmyrza
15. “In Search of the Elixir of Rebirth", in Russian. Author F.Y. Yakubov
16. "Vatanda bir ev kurayym", (story) in the Crimean Tatar language.Author M. Mambetova
17. Zamanymyzny karamany (A Hero of Our Time), by M. Lermontov (facsimile edition),
in Crimean Tatar
18. "Ikyayeler" (stories), by M. Gorky (facsimile edition), in Crimean Tatar
19. "Ornamental Embroidery of the Crimea" (facsimile edition), by P.Y. Chepurina in
Russian
20. "Almanac No. 7". A collection of stories by Armenian writers in Russian and Armenian
21. "Children's notebook" work for accordion and accordion, by Ibadlaev
22.
23. "Eski kyuyu" (The old well) by Memetov N.
24. "Tatar Tilinin Grammatics. Phonetics, Morphology, Syntax", by E. Kurtmollaev, A.
Islyamov.
25. Wings Grow in the Sky, by Chalbash E.U., in Russian
26. "Altyn Yuzyuk" (Equiritual songs) by Pintya I.V.
27. "Current Problems of Crimean Tatar Philology" in Russian, by A.M. Emirova.
28. "Vak'yt beklemey" (Time does not wait) by Emirov A., in Crimean Tatar
29. Crimean Tatar children's calendar - flip-flap, AZ Author Yunusova E.R.
30. "Concordance of Hearts" Translations of poems into Russian. Translation by Golubeva
O.
31. "Aziz Khalkyma" (To My People), a collection of poems, in the Crimean Tatar
language. Author Asanin I., compiled by Khairedinova Z.Sh.
32. "The Estonian settlement of Konči Šavva", by Salman L., in Russian
33. "Chechekler aleminde" (The World of Flowers), in Crimean Tatar by A. Osmanova.
Annex 37
33 books published in 2018
## Title
1. "The Greeks of Crimea" in Russian, by Panayot Kesmeji
2. Ilk bilgiler (First Knowledge) - A collection of poems and stories for children aged 3 to
12 about holidays, national heroes and traditions of Crimean Tatars in Crimean Tatar,
author: Hayredinova Nial
3. Adalet kureshi saflarynda (In the ranks of the struggle for justice) Book 4 in the Crimean
Tatar language, by: Zera Bekirova
4. "With Dance Through Life" in Russian, by R.U. Bakkal
5. Author's album "Songs embroidered with threads" in Ukrainian and Russian, compiled
by: Roik V.M.
6. “Scraps of Memory" collection of works in Russian and Armenian, by Rushan Pilosyan
7. "Belarusians" in Russian by author-compiler Balayan B.S.
8. "Kyrymtatardzha laf etmege ogrenemiz" (Learning to speak Crimean Tatar), phrasebook
in Crimean Tatar and Russian, by N.M. Ganieva, L.M. Bryukhova.
9. "Gonyul Ezgileri" (Songs of the Soul), a collection of poems in the Crimean Tatar
language, by A. Osmanova.
10. "The Three Ages of Osmanchik" in Russian, by Tabakurskaya L., Timirgazin A.
11. Almanac No. 8, 2018. A collection of stories by Armenian writers in Russian and
Armenian
12. Halk Sevgisini qazangan yirji, in Crimean Tatar, compiled by: Z. Bekirova.
13. "The Bulgarians of the Crimea. Return to the roots" Photo album in Russian and
Bulgarian by Ludmila Radeva
14. The White Book of the National Movement of the Crimean Tatars in Russian, by Y.B.
Osmanov.
15. "The Russian Community of Crimea: the Road to Russia.Part 1.Memories of Veterans of
the Community" in Russian, co-authored by I. Evtyushkin.В.
16. “Traditional culture of the Crimean Tatars", Compiler-Editor: Churlu Mamut
17. "Approaching the Horizon", by S.G. Yurieva, N.G. Yurieva
18. "Sary Gul", by: Kadirova Uriye.
19. "Uzyulgen zynjyr" by: Pashi I., compiled by: Salyadinov K.
20. "Sailama eserler", by Ipchi U., compiled by Ipchi Y.
Annex 37
21. "Tan'nag'mesi", by: Seytumerova Alie
22. "The Karaite cemetery in Feodosia. History Sealed in Stone" by V.A. Eliashevich.
23. "Sailama eserler", by: Edemova Uriye
24. "Kechmish ile kuryushuv", by: Bekirov Sh.A.
25. Music by Fevzi Aliyev, author: Aliyev F.
26. "Qalbmimnin Ai Zary", by: Chaylak Refat
27. Facsimile edition of "Yahshy ne ve yaramai", by V. Mayakovsky
28. Facsimile edition of "Kyrym Eskizleri", by A.M. Gorky
29. "My favourite Crimea", Wreath of Crimean Graces Project, by: Shevchenko T.
30. Facsimile edition of Adji Murat, by L.N. Tolstoy
31. "In the Museum of History, Culture and Religion of the Crimean Karaites-Türks named
after Tamara Ormeli", author: Polkanova A.Yu.
32. "In the Afternoon", by: Petrosyan M.A.
33. "The Krymchaks. Historical and Ethnographic Sketch" by Achkinazi I. V.
36 books published in 2019
## Title
1. "Crimean Tatar poetry of the Khan period" set of postcards in Crimean Tatar and
Russian, author-compiler: Zarema Trasinova
2. Asanchik ve Kashkachik (Asanchik and Kashkachik, Asanchik i Kashkachik, Asanchik
and Kashkachik) in Crimean Tatar, Russian, Ukrainian and English, by Rustem Muedin,
compiled by Fevzi Rustemovich Muedinov
3. "Ana kalbi" (Mother's Heart) collection of poems in Crimean Tatar, by Riza Yusufov
4. A collection of articles and stories in Armenian and Russian, 'Almanac 9' ('Motherland
in the Heart')
5. Collection of articles and stories in Russian by the Crimean Krymchak Society
"Krymchahlar" Public Association "Almanac 9"
6. "Kelejekni oylap: A collection of journalistic articles", in Crimean Tatar and Russian
7. "Revision Tales of the Crimean Armenians, 1782", in Russian
8. Sailama Eseler (Selected Works), in Crimean Tatar by Gulzar Dermendzhi
Annex 37
9. Kuneshchik (Sunshine), in Crimean Tatar by Yunus Qandym
10. "Evlyatlargya, torunlargya k'aviy miras k'alajak...". ("A worthy heritage for future
generations") a collection of poems in the Crimean Tatar language by Alie Veliulaeva
11. Balalar dunyasi (Children's World) in Crimean Tatar and Russian by Ablyaziz Veliyev,
translated by Olga Golubeva
12. "Eyilikler Olsun" in Crimean Tatar by Sevil Karashayeva, Ayshe Akiyeva
13. Essays on the History of Crimean Tatar Music Culture (Genesis, Evolution, Modern
State), volume 1 in Russian by Zaatov I. A.
14. The Estonian settlements of Jurči and Kijat Orka" in Russian, by Leongard Salman
15. Duygularım (My Feelings) in Crimean Tatar, by Bilal Mambet
16. The Germans of Crimea - Life for Good" in Russian, by I. P. Zadereichuk.
17. Production of the catalogue "Crimean Tatar Art" (volume 1). Paintings, graphics,
sculpture in Russian compilers: Zaatov I. A., Izetov
18. Terms of Reference for the production of the book Silama Eserler (Selected Works)
Volume I - and Volume II in the Crimean Tatar language, by Ablyaziz Veliyev
19. Syrly, tylsymly dunya (The mysterious magical world), in Crimean Tatar, by Isa
Abduraman
20. "Mayys Yagmury Sepelegende" ("When it Rains in May"), in Crimean Tatar, by Gulnar
Ziyadinova
21. Insanlık Borju (Man's Duty), in Crimean Tatar, by Kadyr Veliyev
22. Saylama Eseler (Selected Works), in Crimean Tatar, by Dzhevdet Ametov
23. "Akim Dzhemilev - war hero and dance genius", in Russian, by Sh. Abduramanova
24. "En'kadirli, suygen yerim" (The dearest favourite place), in Crimean Tatar, by Kerim
Jamanakli
25. "Crimean Tatar cuisine: original recipes", in Crimean Tatar and Russian, by R. Ibadlaev
26. "My Crimea is a tormented song", in Crimean Tatar and Russian, by Osmanov Dilyaver
27. "Sary Kunesh" (The Yellow Sun), in Crimean Tatar, by Nadzhie Ametova
28. "The French of Crimea" in Russian, by Amfiteatrova J. S. С.
29. "Music of a Stone", in Russian and English by Yakubuk P. G.
30. "Qisqachlar qayda qişlaylar" and "Tav evchikleri", in Crimean Tatar (reprinted edition),
by V. Bianki
Annex 37
31. "Aglavuk kyzchyk" and "Ormanda yıldızchıklar", by A. Barto (reprinted edition), in
Crimean Tatar
32. “Architecture of the Crimean Armenians" in Russian, by O. Khalpakhchyan, compiled
by T. E. Sargsyan.
33. "Yyrlar jayintygı 1940", (reprinted edition), in Crimean Tatar
34. "Kyrym Tatar Ornekleri Boyundja Boyalav Defteri" in Crimean Tatar and Russian, by
R.I. Vaapov.
35. "Proverbs, Sayings and Omens of the Crimean Tatars, 1914 in Crimean Tatar and
Russian (facsimile edition)
36. "The Prehistoric Past of the Crimea" in Russian, by G.A. BONCH-OSMOLOVSKY
(facsimile edition, 1929).
30 books published in 2020
## Title
1. "My mother's image is a guiding star", by S. Medjitova. Medjitova
2. What Animals Talk About, by A. A. Chergeev
3. "Lines as the patterns of a rushniki" by N. S. Ryndych
4. All things can wisdom and years, by A. S. Sklyaruk
5. "Kyrym Tatar halkynynyn karaman kyzy" (Girl - Hero of the Crimean Tatar people),
compiled by U. Edemova
6. Krymchahlar Almanac, by A.N. Sumina
7. "Tufanda k'algyan kyoy suryusi" (The storm that seized a flock of sheep), by Yu.Bolat,
compiled by V.V. Kachula and N.S. Bekirov
8. Photo album "The Legend of the 20th Century: Amet-Khan Sultan" by V.M. Basyrov
9. Ivan Genov: The Fate of the Partisan, co-authored by M. E. Sudnev, I. A. Noskova
10. "Living Witnesses to Events: The Little Heroes of the Great War" by N.P. Kriklya, coauthor
11. Book Almanac No. 10 "Motherland in the Heart", compiled by: R. K. Pilosyan. K.
Pilosyan
12. The Legends of the Crimea for Children by M. H. Fayzi.
13. "Sailama eserler" ("Selected works"), author: Cherkez-Ali (Ch.-A. Ametov), compiled
by: R. Ametov
Annex 37
14. "Sailama eserler uch tomlykъ. Birinji vol: novostler" (Selected works in three volumes.
Volume one: novels), by Uriye Edemova
15. "Loyal Daughters of Crimea" (Officers, Partisans, Underground Women) by L.
Khalilova
16. "Crimean Tatar women in the Great Patriotic War" Vol. 4, by A. Veliyev in Crimean
Tatar and Russian
17. Tebessum ile yasha (Live with a Smile) Book Musical collection, by S. S. Kakura
18. "Istek. (Desire) Poems, Memoirs, by: Dermendji L.
19. "Crimean Tatar-Russian Dictionary (1916)" by Bilâl Terlekçi [Qırımtatarca-rusça luğat
(1916)] [Bilâl Terlekçi], Special editor, foreword author: I.A. Kerimov, Editor: T.N.
Kirimov, compiler: H.B. Terlekçi
20. "Sailama eserler alty tomlykъ". Birinji vol: shiirler ve novostler (Selected Works in Six
Volumes. Volume One: Poems and Stories), by Sh. Alyadin compiled by Alyadinova L.
21. HISTORY OF THE NATIONAL ORGANIZATIONS OF CRIMEA, by B. S. Balayan
22. "The Folklore Heritage of the Thracian Greeks of the Republic of Crimea", co-authors:
Kifnidi S. A., Lazaridi S. A., Banach L. S.
23. "Between Crimea and Paris", by: Kenzhikaeva U.
24. "Crimean Tatar music by professional composers"
by F. M. Aliyev.
25. "Uchurym bashynda (Above the precipice)",
by: Mambetova M.
26. "Alem-i teselli (Graceful Peace)",
by Voloshin M. (Translated into Crimean Tatar by Yunus Qandym)
27. "Sailama eserler (Selected works)", by Murad R., compiled by Mambetova M.
28. Military and patriotic album "There was a war..." by Olkhovskaya V. Ya. Я.
29. "Menim Yollarym" (The Road Acquired) by Emin S. compiled by Ilyasov D.,
Khurshutov A., Osmanov D.
30. "The contribution of the repressed peoples of the USSR to the victory in the Great
Patriotic War of 1941-1945", compiled by: Akieva S.I., Kurtseitov R. J.
31 books published in 2021
## Title
1. "Agathangel of Crimea - Son of Three Nations", by E. Belousov
Annex 37
2. "Kyrym bizim er sheyimiz", by R. Gafarov. Gafarov
3. Unusual inhabitants of the Crimea, by V. Olkhovskaya
4. "Duwan S. Memories", co-editor-compiler: V. Strunina
5. The Complete Works. Literary Works. Volume 1, by I. Gasprinsky, compiled by S.
Seitmemetova, G. Seitvaniyeva
6. "Hayatny bakhshyshlary", by G. Useinova
7. Facsimile edition of "Izergil k'arty" (The Old Woman Izergil), by A. M. Gorky
8. Facsimile edition of Robinson Crusoe, by D. Defoe
9. Facsimile edition of Menim Aivanlarym, by V. Durov
10. Almanac No. 11 "Motherland in the Heart", compiled by: R. Pilosyan Pilosian
11. "Tylsimli masallar", by R. Suleymanov.
12. "Gonyul Ilhamy ve Emirinen", by A. Kokieva
13. "A Quiet Place on the Colon of Vicinity. Vibrant creations. Bakiyilik avuchyndaki
chechek. Saylama eserler", by L. Ukrainka, translated into Crimean Tatar by Y.
Kandym, compiled by V. Basyrov
14. On the Road, by O. Gabrielyan
15. "Edebiyatshynaslyk ve medeniy ayat", by S. Yunusov
16. "Karaites - the last inhabitants of Mangup",
Compilation Editors: V. A. Eliashevich, I. S. Lipunov, M. B.Kizilov
17. "Righteous among the Nations of the World in the Republic of Crimea", compiled by: A.
Gendin
18. Mummy's Fairy Tales, by A. Em (M. Heydiūnas)
19. Album "Artist Mamut Churlu", by M. Churlu
20. The Legacy of the Ancestors, by I. Abdullayev, compiled by E. Seitbekirov
21. "Hayallarym merjan kibi" by D. Medjitova, compiled by S. Medjitova
22. "The Burnt Villages of Crimea during the Great Patriotic War, 1941-1944" by K.
Ametov. K. Bokova
23. "The Link of Times", by P. Kesmeji, compiled by: S. Yurieva (Kesmedji)
24. “From Ararat to Ai-Petri" by G. Khachatryan
25. Ebediilik (Eternity), by I. Abduraman
Annex 37
26. "Yuri Bekirovich Osmanov. A man from another dimension", compiled by A. O. Dobro
27. "Sailama eserler alty tomlykъ" Ekinji vol. Novestler (Selected Works in Six Volumes.
Volume Two. Novels), by Sh. Alyadin, compiled by L. Alyadinova
28. "I wasn't a guest on earth... Interviews. Memories. List of publications. Volume 1" by V.
Basyrov
29. "Catalogue-album: Akhtem Aliyev - artist and poet", by A. Aliyev, compiled by R.
Aliyev
30. "Crimea 1941-1944.The Reverse Side of the War. Selected aspects of the history of the
occupation of the Crimea. Volume 2", by A. Nemenko
31. Facsimile edition of "Ikyaye Etuv Ichun Makiyaler Jyyntygy" by P. O. Afanasyev, I. N.
Shaposhnikov, E. E. Solovyova. O. Afanasyev, I. N. Shaposhnikov, E. E. Solovyova
27 books published in 2022
## Title
1. "I Love Crimea in All Weathers. Volume 1", by: Djerbinova L.
2. "Children's Galaxy, by Amedov N.
3. "Yureklerni tepretken edebiyu kyrym tatar edibiyati akkend maqaleler (Literary world,
stirring hearts. Articles on Crimean Tatar literature)", by: A. Dzhemileva.
4. "Vatan tarta bagirina (I am striving to embrace the Fatherland), by Kafadar E., compiled
by Kafadar R.
5. "Saylama eserler. Uch tomlykъ. Ekindzhi tom. Novel", by: Edemova U.
6. "Adiy insan olsa da (Even if a simple man)", by: Veliyev (Veli) K.
7. "Saylama eserler. Alty tomlykъ. Uchunji tom. Narrative, ikyaeler", author: Alyadin Sh.
compiled by Alyadinova L.
8. "Saylama eserler", by Selim Sh. compiled by Jelilova L.
9. "Tilimiznin degerligi (Wealth of Language)", by E. Bekirov.
10. "Atalar sösleri ve aytymlar (Proverbs and sayings)", author: Asanov S., compiled by
Asanov A.
11. "Selime Chelebiyeva. Ayyrylamam sanadan. (I will not part with the scene)", compiled
by: Jemileva
12. Facsimile edition. "Songs of the Crimean Turks", by A. Olesnitsky.
13. Facsimile edition. "Dubrovsky", by Pushkin A.
Annex 37
14. Facsimile edition. "Ikjaeler (stories)", by Chekhov A.
15. "Ha-ha-ha", by: Veliyev A.
16. "Memories of Peter Aljanaka", by the author-compiler: Jan T.
17. "The Khan's Palace in Bakhchisaray", by V. Gergross.
18. Crimea. Prosperity in unity.
19. "Almanac No. 12. Homeland at Heart", co-editor-compiler: R. Pilosyan.
20. "...(Collected Essays)", by Petrosian M.
21. "Alexander Mikhalyants. Jewellery Art. Enamel. Sculpture. Painting. Photo", author:
Mikhalyants A.
22. "Poems and songs", by: Klossowski I.
23. Greeks. Crimean Hellas. Authors-composers: Schonus I.A., Pipia O.M., Laptev Y.N.,
Gabrielyan A.O., Budurova N.V.
24. "The shtetl mystery of Elena Kotlyar", by: Kotlyar E.
25. "URANOIS (Heaven)", by I. Borokhov.
26. "Ashik Garip. A Krymchak tale", by Reby D., compiled by Zengina N.
27. "Durante (Persistent)", by Petrov A. (Krymsky A.)
Annex 37
Exhibit E
L. Khalilova, FAITHFUL DAUGHTERS OF CRIMEA: OFFICERS, PARTISANS, UNDERGROUND
WOMEN (Mediacentre n.a. I. Gasprinsky, 2020).
Annex 37
Exhibit F
U. Edemova, THE HERO GIRL OF THE CRIMEAN TATAR PEOPLE (Mediacentre n.a. Gasprinsky,
2020).
Annex 37
UDC 821.512.19-94
BBC 84 (2Ros)
K 977
Approved by the Advisory Council on the Publication of Socially Important Literature in
Native Languages at the State Autonomous Institution of the Republic of Crimea
Mediacentre n.a. Ismail Gasprinskiy. Published with the support of the State Committee on
Interethnic Relations of the Republic of Crimea at the expense of the federal budget, the
budget of the Republic of Crimea, is not subject to commercial distribution
K 977 The Hero Girl of the Crimean Tatar People: collected book / complier U. Edemova
- Simferopol: State Autonomous Institution of the Republic of Crimea “Mediacentre n.a.
Gasprinsky”, 2020. — 504 p. : illust. — In Crimean Tatar and Russian languages.
UDC 821.512.19-94
ISBN 978-5-6044686-1-6 BBC 84 (2Ros)
The book "The Hero Girl of the Crimean Tatar People" is an extensive collection of fiction
and documentary works dedicated to the difficult fate and heroic deed of Alime Abdenanova.
The name of the legendary hero girl, a Soviet servicewoman of Crimean Tatar origin and a
resident of the intelligence department of the Primorskaya Army Headquarter during the
Second World War, will live forever in the memory of generations.
© U. Edemova, complier, 2020
ISBN 978-5-6044686-1-6 © SAI "Mediacentre n.a. Gasprinsky", 2020
[…]

Annex 38
Council of Ministers of the Republic of Crimea, Letter No. 1/01-46/8775/3/3/214, 14 February
2023
(translation)

Annex 38
Page 1 out of 7
Translation
Mediacentre n.a. Ismail Gasprinsky, Letter, 2 March 2023.
State Committee on Inter-
Ethnic Relations of the
Republic of Crimea (in
Ukrainian)
State Committee on Inter-
Ethnic Relations of the
Republic of Crimea (in
Russian)
State Committee on Inter-
Ethnic Relations of the
Republic of Crimea (in
Crimean Tatar)
State Autonomous Institution of the Republic of Crimea Mediacentre n.a. Ismail
Gasprinskiy (in Russian)
State Autonomous Institution of the Republic of Crimea Mediacentre n.a. Ismail
Gasprinskiy (in Ukrainian)
State Autonomous Institution of the Republic of Crimea Mediacentre n.a. Ismail
Gasprinskiy (in Crimean Tatar)
Trubachenko Str., 23a, Simferopol, Republic of Crimea, 295048, 8(918) 024-46-24, E-mail:
[email protected]
TIN 9102192812, KPP 910201001, Reg. No. 1159102113455
To the Ministry of Foreign Affairs
of the Russian Federation
Russian Federation, 119002,
Moscow, 32/34 Smolensky Blvd.
To Monastyrsky, Zyuba, Stepanov
& Partners
Russian Federation, 121099,
Moscow, 3 Novinsky Blvd., bld. 1
To Partner, Attorney at law
K.N. Udovichenko
2 March 2023
Dear Attorneys at law!
In response to your request for information about the work of Mediacentre n.a. Ismail
Gasprinskiy we inform on the following
The State Autonomous Institution of the Republic of Crimea Mediacentre n.a. Ismail
Gasprinskiy (hereinafter, “Mediacentre”) considered the request for information dated 24 February
2023, sent by Monastyrsky, Zyuba, Stepanov & Partners, acting on behalf of the Ministry of Foreign
Affairs of the Russian Federation.
Below we provide you with answers to the questions contained in the request concerning the
work of the Mediacentre with printed publications in various languages of peoples living in Crimea,
for their use in the preparation of the written position of the Russian Federation in the dispute initiated
by Ukraine against the Russian Federation before the International Court of Justice.
On the setting up and objectives of the Media Center
Annex 38
Page 2 out of 7
The Mediacentre was set up in 2015 as part of the state programme for the ethno-cultural
development of nationalities living in Russia. It is named after Ismail Gasprinskiy, a famous Crimean
Tatar activist, who worked hard throughout his life to produce various newspapers and magazines,
carried out educational activities with purpose to promote the Crimean Tatar language and to preserve
and develop cultural diversity. Media Center has a similar aim – to support the production of media
and literature in the languages of all peoples, ethnic groups, and national minorities, thus contributing
to the preservation of languages, culture and traditions.
In the past seven years alone, we have published more than 220 books in the languages of the
peoples living in Crimea: Crimean Tatar, Armenian, Ukrainian, Greek, Hebrew, German, Italian,
Bulgarian and others.
Since our creation, we have continued to develop: every year the number of print media
published at the expense of state subsidies increases, and all of them actively popularize the culture
and literature of the Crimean peoples. Since 2019 we have a small printing house of our own. It is
noteworthy that before 2014 there were very few such opportunities in Crimea.
The Media Center has three main areas of activity:
- support of 15 mass media, including in Russian, Crimean Tatar, Ukrainian, Armenian,
German, Bulgarian and Greek languages;
- publication of books on the culture of the peoples of Crimea, including in Russian,
Crimean Tatar, Ukrainian, Armenian, Bulgarian and Krymchak languages;
- organisation of events: conferences, presentations, round tables, etc.
Support of mass media operations
We support a range of mass media, most of which target specific ethnic groups in Crimea. At
the moment, the Mediacentre n.a. I. Gasprinskiy has 15 different newspapers and magazines. Many
of the publications have a very rich history and it is therefore important to support them.
A special place in the Media Center is given to Crimean Tatar periodicals. In particular, the
Mediacentre publishes under its aegis:
- the weekly newspaper «Yan’i Dunya» (“New World”) – a publication with a unique
history. It was first published in 1918 and changed within the development of the
Crimean Tatar language. Its circulation is 1,000 copies.
- the magazine “Yildiz” (“The Star”) can be called a unique monument to the Crimean
Tatar literary language. It was created during the years of the deportation of Crimean
Tatars, and prominent Crimean Tatar writers and poets have published in it. Its
circulation is 500 copies.
- the magazine “Arzy” is dedicated to the role of Crimean Tatar women in history and
literature. It was created recently, but continues the tradition established back in 1906
by Ismail Gasprinskiy’s daughter, Shefika, leader of the Muslim women’s movement.
Its circulation is 200 copies.
- the newspaper “Meraba” (“Hello”) is a relatively new publication (it was created in
2015) that on a weekly basis publishes information about the latest developments not
Annex 38
Page 3 out of 7
only in the lives of Crimean Tatars but also of other peoples of Crimea. Its staff also
takes part in radio and TV programmes where they discuss current news. Its
circulation is 1,000 copies.
- the magazine for teachers of the Crimean Tatar language «Ana tili odzhalaryna»
provides methodological and didactic support for the teaching process and also gives
advice on how to preserve the mother language in families. Its circulation is 500
copies.
The newspaper “Yan’i Dunya” was shortlisted (10 best projects) and placed 6th at the All-
Russian Public Award for Preservation of Linguistic Diversity of the Russian Federation “Key word”,
in the nomination “For Contribution to Preservation of Mother Language”. In 2022, 232 applications
from 61 regions of the Russian Federation and from Belarus were received for this competition.
We also attach great importance to preserving the languages and cultures of other peoples of
Crimea.
To support the functioning of the Ukrainian language, the newspaper “Krymsky Visnyk”
(“Crimean Herald”) publishes both ethnographic essays and articles on topical issues. Its circulation
is 500 copies.
The Mediacentre also publishes media aimed at other peoples: for example, the newspaper
“Hoffnung” (“Hope”) is intended for Crimean Germans, who participate directly in its production (its
circulation is 500 copies); the magazine “Dove of Masis”, which was founded as far back as 1855
and is publishing periodically for almost 30 years, tells about the history, culture and famous
personalities of Crimean Armenians (its circulation is 500 copies); the Bulgarian newspaper “Izvor”
(its circulation is 500 copies) are published for Crimean Bulgarians, and the newspaper “Tavrik” is
for Greeks.
It is up to the staff of the publications to decide on the content, and it is important to us that the
newspapers and magazines involve people from specific cultures.
We consider it important to create and support mass media that could be of interest to Crimeans
from different ethnic backgrounds. For example, the magazine “Crimea” publishes literary works in
Crimean Tatar, Ukrainian and Russian. The cultural and educational magazine “Our Crimea”, which
was founded in 2016, tells both about the culture of Crimea in general (architecture, theatre, traditions
of the people, iconic figures) and about activities and events of separate national-cultural formations,
and a certain part of each issue is devoted to one of the peoples of Crimea. And our new project –
youth magazine “We! Youth magazine Crimea” – has no “nationality” at all. Its target audience is all
Crimean youth. It publishes materials in the 3 national languages.
All mass media that were registered on the peninsula before 2014 and expressed a desire to reregister
were able to do so after submitting the relevant application without any bureaucratic delays
and within the time limits stipulated by Russian law.
Publication of socially significant literature
We believe that the foundation for preserving both the functionality of language and culture is
books, so the Mediacentre also publishes socially significant literature. A particularly important area
Annex 38
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is the publication of books in native languages.1 To control the quality of published literature, the
Mediacentre has an Advisory Council for publishing socially significant literature in native languages
that includes writers, teachers, academics and journalists, including those of Crimean Tatar,
Ukrainian, Armenian and Greek origin.2 The Advisory Council meets at least once a year to review
manuscripts whose authors or compilers have applied for inclusion on the list for publication at the
expense of the state budget.
In the seven years of its existence, more than 220 books in Crimean Tatar, Ukrainian, Bulgarian,
Armenian, Hebrew, Krymchak, and Russian have been published, as well as books about the culture
of other nationalities: Karaites, French, Estonians, Greeks.3 The publication of literature and printed
mass media in the languages of the peoples of Crimea is financed both from the federal budget
(Federal Agency for Nationalities) and from the budget of the Republic of Crimea.
In accordance with Federal Law No. 77-FZ dated 23 November 1994 “On Mandatory Copies
of Documents”, part of the circulation of publications published with the assistance of the
Mediacentre is distributed free of charge to libraries, including outside Crimea. In particular, the
Media Center sends:
- to the federal executive branch in the area of the press, mass media and mass
communications one obligatory copy of all types of printed publications;
- to the Russian State Library mandatory copies of all types of printed publications for
subsequent distribution to the largest libraries and information institutions (from 3 to
16 copies);
- to the Russian State Library, within seven days from the date of publication of the
first batch of printed publications using information and telecommunications
networks two mandatory copies of the printed publications in electronic form,
certified by a qualified electronic signature;
- to the State Budgetary Institution of Culture of the Republic of Crimea «Crimean
Republican Universal Scientific Library named after I.Y. Franko» three mandatory
copies of all types of printed publications.
Also, in accordance with the Law of the Republic of Crimea “On Mandatory Copies of
Documents” dated 22 March 2017 No. 368-ZRK/2017 the Mediacentre sends three mandatory copies
of all types of printed publications to the State Budgetary Institution of Culture of the Republic of
Crimea “Republican Crimean Tatar Library n.a. I. Gasprinskiy” if the publication is done in Crimean
Tatar language or concerns Crimean Tatars.
1 See, for example, Y. Bolat, A FLOCK OF SHEEP CAUGHT IN A STORM. TRANSLATION FROM THE CRIMEAN TATAR INTO
RUSSIAN, UKRAINIAN, ARMENIAN (Mediacentre n.a. I. Gasprinsky, 2020) (Exhibit A); L. Ukrainka, A FLOWER IN THE
PALM OF ETERNITY. SELECTED WORKS (Mediacentre n.a. I. Gasprisnky, 2021) (Exhibit B).
2 See Mediacentre n.a. I. Gasprinsky, Membership Composition of the Advisory Council on the publication of socially
important literature in native languages at the State Autonomous Institution of the Republic of Crimea “Mediacentre n.a.
I. Gasprinsky” (Exhibit C).
3 See Mediacentre n.a. I. Gasprinsky, List of books published by the State Autonomous Institution of the Republic of
Crimea “Mediacentre n.a. I. Gasprinsky” (Exhibit D).
Annex 38
Page 5 out of 7
Multiple copies of the books are sent to the Ministry of Culture of the Republic of Crimea and
distributed throughout the library network of the whole peninsula.
According to their content and focus, the publications are donated to national-cultural
autonomies and other public organizations of the Republic, many of which have established their own
libraries based on the books, albums and almanacs published by the Media Center.
The Mediacentre prides itself on books that glorify the exploits of the multinational people of
Crimea during the Great Patriotic War. For example, under aegis of the Media Center were published
the book “Loyal Daughters of Crimea. Officers, Partisans, Underground Women” describing the valor
and contribution to the victory of Crimean Tatars in the war years,4 a photo album for the 100th
anniversary of Amet-Khan Sultan, twice Hero of the Soviet Union, “Kyrymnin Sadyk Kyzy” about
the exploits of Hero of Russia Alime Abdennanova.5 The Mediacentre also supported the publication
of the multi-volume book “Contribution of the Repressed Peoples of the USSR to the Victory in the
Great Patriotic War of 1941-194”» and the multi-volume book “Reverse side of the war” dedicated
to the exploits of Crimean Tatars among others.6
In addition, the Mediacentre is publishing facsimile editions of the rarest books that exist in
Crimean libraries in a single copy.
The Mediacentre’s website works active, with the most current news from the national-cultural
associations of Crimea and PDFs of all newspapers and magazines published by Media Center. There
you can also find books published during all the years of the organization's existence.
Organisation of events, educational activities
We also see our aim as promoting and developing the culture of Crimea and its nationalities,
and so we regularly hold conferences, round tables and meetings on various subjects, celebrate
memorable dates in the history of Crimea and, of course, organise presentations of our new books. In
all, we have organised and participated in 28 events in 2022, including:
• Cheronopolye Village, Belogorsk District, Greek holiday “Panair”;
• Chutuf-Kale Fortress, Bakhchisaray District, Crimean Karaites’ Cultural Days;
• Simferopol, Republican Crimean Tatar Library n.a. I. Gasprinsky, Library Forum
“Crimean Tatar Book”;
• Simferopol, International Round Table “Development of Links between Crimean
Ukrainians and their Compatriots Abroad”;
• Simferopol, Crimean Tatar State Academic Musical and Drama Theatre, Khydyrlez
national holiday;
4 L. Khalilova, FAITHFUL DAUGHTERS OF CRIMEA: OFFICERS, PARTISANS, UNDERGROUND WOMEN (Mediacentre n.a. I.
Gasprinsky, 2020) (Exhibit E).
5 U. Edemova, THE HERO GIRL OF THE CRIMEAN TATAR PEOPLE (Mediacentre n.a. Gasprinsky, 2020) (Exhibit F).
6 S. Akieva, R. Kurtseitov, CONTRIBUTION OF THE REPRESSED PEOPLES OF THE USSR TO VICTORY IN THE GREAT
PATRIOTIC WAR OF 1941-1945, VOLUME II. CRIMEAN TATARS, BULGARIANS, GREEKS AND ARMENIANS OF CRIMEA
MESKHETIAN (AHISKA) TURKS (Mediacentre n.a. I. Gasprinsky) (Exhibit G).
Annex 38
Page 6 out of 7
• Peschanoye Village, Bakhchisaray District, interethnic youth forum;
• Bakhchisaray, Central Library n.a. A.S. Pushkin, historical excursus “In the Unity of
the Peoples of Crimea”;
• Simferopol, meeting of the Public Council for Harmonisation of Interethnic Relations;
• Simferopol, Republican Crimean Tatar Library n.a. I. Gasprinsky, literary readings
“The World of Ismail Gasprinsky”;
• Simferopol, Republican Crimean Tatar Library n.a. I. Gasprinsky, International Book
Giving Day, “Give Books with Love” event;
• Simferopol, mourning events dedicated to the Day of Remembrance for victims of the
deportation from Crimea;
• Simferopol, Gagarin Park, Crimean Tatar Flag Day;
• Simferopol, Beloye-5, participation in the celebration of “Eid al-Fitr”;
• Simferopol, Beloye-5, Crimean Tatar national holidays “Derviza”;
• Kerch, V.G. Belinsky Central City Library, library forum “Crimean Tatar Book”;
• Feodosiya, festival of Crimean Tatar culture “Kefe Gulleri”;
• Simferopol, Crimean Tatar Academic Music and Drama Theatre, festival of Crimean
Tatar culture “Qirim Naghmeleri”;
• Simferopol, Republican Crimean Tatar Library n.a. I. Gasprinsky, Crimean Tatar
Writing and Culture Day;
• Simferopol, International Round Table “Development of links between Crimean Tatars
and their compatriots abroad”.
We already have 24 events planned for 2023, and the number is growing.
We also help to develop national journalism in Crimea – we regularly host internships for
journalism students who learn how to work in a creative multicultural environment, also we organise
seminars, forums and workshops for young aspiring journalists.
2 March 2023
[SIGNATURE] Vagan Vazgenovich Vermishyan,
Head of State Autonomous Institution of
the Republic of Crimea Mediacentre n.a.
Gasprinsky
Annex 38
Page 7 out of 7
LIST OF EXHIBITS:
Number: Name:
Exhibit A Y. Bolat, A FLOCK OF SHEEP CAUGHT IN A STORM. TRANSLATION FROM THE
CRIMEAN TATAR INTO RUSSIAN, UKRAINIAN, ARMENIAN (Mediacentre n.a. I.
Gasprinsky, 2020).
Exhibit B L. Ukrainka, A FLOWER IN THE PALM OF ETERNITY. SELECTED WORKS
(Mediacentre n.a. I. Gasprisnky, 2021).
Exhibit C Mediacentre n.a. I. Gasprinsky, Membership Composition of the Advisory
Council on the publication of socially important literature in native languages
at the State Autonomous Institution of the Republic of Crimea “Mediacentre
n.a. I. Gasprinsky”.
Exhibit D Mediacentre n.a. I. Gasprinsky, List of books published by the State
Autonomous Institution of the Republic of Crimea “Mediacentre n.a. I.
Gasprinsky”.
Exhibit E L. Khalilova, FAITHFUL DAUGHTERS OF CRIMEA: OFFICERS, PARTISANS,
UNDERGROUND WOMEN (Mediacentre n.a. I. Gasprinsky, 2020).
Exhibit F U. Edemova, THE HERO GIRL OF THE CRIMEAN TATAR PEOPLE (Mediacentre
n.a. Gasprinsky, 2020).
Exhibit G S. Akieva, R. Kurtseitov, CONTRIBUTION OF THE REPRESSED PEOPLES OF THE
USSR TO VICTORY IN THE GREAT PATRIOTIC WAR OF 1941-1945, VOLUME II.
CRIMEAN TATARS, BULGARIANS, GREEKS AND ARMENIANS OF CRIMEA
MESKHETIAN (AHISKA) TURKS (Mediacentre n.a. I. Gasprinsky).
Annex 38
Exhibit A
Y. Bolat, A FLOCK OF SHEEP CAUGHT IN A STORM. TRANSLATION FROM CRIMEAN TATAR TO
RUSSIAN, UKRAINIAN, ARMENIAN (Mediacentre n.a. I. Gasprinsky, 2020).
Annex 38
Exhibit B
L. Ukrainka, A FLOWER IN THE PALM OF ETERNITY. SELECTED WORKS (Mediacentre n.a. I. Gasprisnky, 2021).
Lesya Ukrainka
A Flower in the Palm of Eternity
Annex 38
UDC 821.161.2
BBK 84(Ukr)
U 45
Published by the Ismail Gasprinsky Media Centre state-funded
autonomous institution of the Republic of Crimea with the support of
the State Committee for Interethnic Relations of the Republic of
Crimea on funds from the federal budget and from the budget of the
Republic of Crimea. Approved by the Advisory Council on publication
of socially important literature in native languages under the Ismail
Gasprinsky Media Centre state-funded autonomous institution of the
Republic of Crimea.
Not for commercial distribution
Lesya Ukrainka
A Flower in the Palm of Eternity. Selected works. Simferopol, I.
Gasprinsky Media Centre state-funded autonomous institution of the
Republic of Crimea, 2021, 168 pages, In Ukrainian and Crimean Tatar
languages.
ISBN 978-5-6046689-2-4
The artistic legacy of Lesya Ukrainka is fertile soil for researchers of
the phenomenon of literary space and time. Translation is also a path to
the Poet. There is always a small miracle of turning “the indifference
of a dictionary” indifference" into a trembling vibration of the strings
of one’s soul.
UDC 821.161.2 BBK84(Ukr)
ISBN 978 5-6046689-2-4
© Lesya Ukrainka, author, 2021
© Basyrov, V., compiler, 2021
© Kandymov, Yu., translation from Ukrainian into Crimean Tatar,
2012
© I. Gasprinsky Media Centre state-funded autonomous institution of
the Republic of Crimea, 2021,
Annex 38
[Inclined Melody poem in Ukrainian] [Inclined Melody poem in Crimean Tatar]
Annex 38
A literary/artistic publication
Lesya Ukrainka
A FLOWER IN THE PALM OF ETERNITY
Selected Works
Compiled by V.M. Basyrov
Translated from Ukrainian into Crimean Tatar by Y.U. Kandymov
Preface by Doctor of Philology, professor, senior research fellow of the Fevzi Yakubov
Research Institute for Crimean Tatar Philology, History and Culture of the Ethnic Groups of
the Crimea V.I. Gumenyuk
Ukrainian texts edited by N.Y. Seitvelieva
Crimean Tatar texts edited by: N I. Bekirov, E R. Ajalimova
Artist: R I. Vaapov
Crimean Tatar text proofread by S.S. Sitzhalilova
Computer layout by E R. Ajalimov
Signed to print: 02 August 2021. Format: 70x100 1/16.
Offset printing. Font: BannikovaC. Conventional printed sheet: 13.65.
Quantity: 10.5 conventional printed sheets. Circulation 300 copies. Order No. 21 -14795.
I. Gasprinsky Media Centre state-funded autonomous institution of the Republic of Crimea
23-a Trubachenko Street, Simferopol, 295048, Republic of Crimea
E-mail: [email protected] | OGRN 1159102113455
Printed by CONSTANT LLC printing house
1/12 Berezovaya Street, Severny, 308519, Belgorod region
Phone/Fax +7 (4722) 300-720, www.konstanta-print.ru
Annex 38
Exhibit C
Mediacentre n.a. I. Gasprinsky, Membership Composition of the Advisory Council on the
publication of socially important literature in native languages at the State Autonomous
Institution of the Republic of Crimea “Mediacentre n.a. I. Gasprinsky”.
Membership Composition of the Advisory Council on the publication of socially important
literature in native languages at the State Autonomous Institution of the Republic of
Crimea “Mediacentre n.a. I. Gasprinsky”
Chairman:
VERMISHYAN
Vagan Vazgenovich
Director of the State Autonomous Institution of the Republic of
Crimea “Mediacentre n.a. I. Gasprinsky”
Deputy chairman:
IBRAGIMOVA
Adile Aidynovna
Deputy Director for editorial and publishing activities of the State
Autonomous Institution of the Republic of Crimea “Mediacentre n.a. I.
Gasprinsky”
Secretary:
VESELOV
Andrey Viktorovich
executive secretary of the publishing department of the State
Autonomous Institution of the Republic of Crimea “Mediacentre
n.a. I. Gasprinsky”
Council members:
YAKUBOV
Ruslan Rishatovich
First Deputy Chairman of the State Committee for Interethnic
Relations of the Republic of Crimea;
GLUSHCHENKO
Elizaveta Alexeyevna
Deputy Minister of Internal Policy, Information and
Communications of the Republic of Crimea;
PATRUSHEV
Sergei Anatolievich
Head of the Department of Museums, Libraries and Culture
Education of the Ministry of Culture of the Republic of Crimea;
OSMANOV
Dlyaver Kazimovich
Head of the Department of Interethnic Relations and Socio-Cultural
Adaptation of Migrants;
JAGYAEVA
Gulnara Sabrievna
Director of the state budgetary institution of the Republic of Crimea
“Mediacentre n.a. I. Gasprinsky”;
SELENDILY
Lemara Sergeyevna
Doctor of Philology, Professor of the Department of Crimean Tatar
Philology at the Institute of Philology of the Vernadsky KFU,
Secretary and Coordinator of the Council of Crimean Tatars under
the auspices of the Head of the Republic of Crimea;
LAPTEV
Yuri Nikolayevich
Director of the State Budgetary Institution of the Republic of
Crimea “Mediacentre n.a. I. Gasprinsky”;
RICKMAN
Grigory Mihailovich
Member of the All-Russian Public Organization "Union of
Journalists of Russia", PhD in Biology, Chairman of the Board of
the Local National and Cultural Autonomy Public Organization
“Mediacentre n.a. I. Gasprinsky”;
Annex 38
GANIEVA
Emine Suleymanovna
PhD. in Philology, Associate Professor, Dean of the Faculty of
History, Arts, Crimean Tatar Language and Literature
BASYROV
Valery Magafurovich
Chairman of the Board of the Public Organisation “Union of Writers
of the Republic of Crimea”, Director of the Limited Liability
Company “Izdatelstvo Dolya”
EDEMOVA
Urie
Crimean Tatar writer, novelist
VELIEV
Ablyaziz
Head of the Laboratory of the Research and Development Institute
of Crimean Tatar Philology, History and Culture of Ethnic Groups
of the State Budget Educational Institution of the Republic of
Crimea “Fevzy Yakubov KIPU”;
GRIDCHINA
Anastasia Sergeyevna
Chairman of the Council of the Regional Public Organisation
"Ukrainian Community of Crimea";
OSMANOV
Dlyaver Ibraimovich
Editor-in-chief of the literary magazine Yildiz;
SULEIMANOV
Seyran Akbaraliyevich
poet, novelist, editor-in-chief of the newspaper Yan’y Dunya;
SHONUS
Ivan Aristovich
Deputy Chairman of the Committee of the State Council of the
Republic of Crimea on People's Diplomacy and Interethnic
Relations, Chairman of the public organisation “Tavrida Regional
National and Cultural Autonomy of Greeks of the Republic of
Crimea”
Annex 38
Exhibit D
Mediacentre n.a. I. Gasprinsky, List of books published by the State Autonomous
Institution of the Republic of Crimea “Mediacentre n.a. I. Gasprinsky”.
List of books published by the State Autonomous Institution of the Republic
of Crimea “Mediacentre n.a. I. Gasprinsky”
10 books published in 2015.
## Title
1. "Russia, the West and the Muslim World", I. Gasprinsky;
2. "Chynlar ve maneler", K.Jamanakli;
3. "Eight Steps in the Footsteps of a Teacher", R. Shakir-Aliyev;
4. "The I. Gasprinskiy Crimean Tatar Republican Library: 25 Years";
5. "Fikir Injileri, U. Kurkchi;
6. "Takdirler Alemi", S. Medjitova;
7. "Calendar of Significant and Commemorative Dates", D. Belyalova;
8. "Tales and Legends of the Tatars of Crimea";
9. "Bekle meni den'iz", B. Ablaev;
10. "Ocalar”, L. Haibullaeva, Z. Islyamova.
23 books published in 2016.
## Title
1. "Fikir Injileri;
2. "San'yrzyz alem", A. Veliyev;
3. "Origin of the Crimean Tatars", A. Memetov;
4. "Crimean Bulgarians: Historical and Ethnographic Sketch", I. Noskova;
5. "Crimean Tatar violin music", N. Amedov;
6. "The Book of Travel. Crimea and Adjacent Regions", by E. Chelebi;
7. "The historical and cultural heritage of the Crimean Karaites";
8. "The Germans of Crimea. The Spirit of Activity", Y.N. Laptev, Y.K. Gempel;
Annex 38
9. "Kyrymchahlar", N. Sumina;
10. "The Almanac;
11. "Tales and Legends of the Crimean Tatars";
12. "The Peoples of Crimea", Laptev Y.N., Prokopenkov V.N.;
13. "Tylsimli masallar", R. Suleymanov;
14. "Sailama Eserler", R. Fazil;
15. "Aineji tilkichik", Dermenji;
16. "Tylsymly kyuvet", L. Shamil;
17. "Qyssa-i Yusuf", by Khalil oghlu Ali;
18. "Masallar balalar ichun", A. Useinov;
19. "Alim akında yır, legend ve khatyrlav jıyıntıgı";
20. "Aivanlar akında masallar", L.N. Tolstoy;
21. "Kyrym Tatar Masallar ve Legendalar";
22. "Balychyk ve balikchi akynda masal", A.S. Pushkin;
23. "Masallar", H.H. Andersen;
33 books published in 2017
## Title
1. “Tales and Legends of the Crimean Tatars" in Russian
2. "Yurek syrlarym" collection of poems in the Crimean Tatar language by V. Kipchakova
3. "Ismail bey Gasprinsky. Ayats ve faalieti" by S. Gafarov, translated by R. Fazil.
4. "Chokarak" collection of selected poetry, in Crimean Tatar by B. Mambet
5. "Crimea. Surb Khach Monastery" in Russian and Armenian
6. “Unruly Taurica. Asandr" in Russian by Kesmeji
7. "Eger anamny tapsa edim..." a collection of stories in Tatar, by Ilyasova
8. “Altyn Ornekler" (golden patterns) collection of stories in Crimean Tatar, Useinova
9. “Combat Officers”, Veliyev
Annex 38
10. “Crimean Tatar artists, masters of arts and crafts and architects", E. Cherkezova
11. "Buyuk-As", by U. Kenzhikaeva, in Crimean Tatar and Russian
12. "Crimean Tatars in the underground guerrilla movement in the Crimea during the Great
Patriotic War (1941-1944)". Documentary study, in Russian. Author R. Muzafarov
13. Baar (novel) by I. Abduramanov, in Crimean Tatar
14. "Halk shairi Eshmyrza" (facsimile edition), by Eshmyrza
15. “In Search of the Elixir of Rebirth", in Russian. Author F.Y. Yakubov
16. "Vatanda bir ev kurayym", (story) in the Crimean Tatar language.Author M. Mambetova
17. Zamanymyzny karamany (A Hero of Our Time), by M. Lermontov (facsimile edition),
in Crimean Tatar
18. "Ikyayeler" (stories), by M. Gorky (facsimile edition), in Crimean Tatar
19. "Ornamental Embroidery of the Crimea" (facsimile edition), by P.Y. Chepurina in
Russian
20. "Almanac No. 7". A collection of stories by Armenian writers in Russian and Armenian
21. "Children's notebook" work for accordion and accordion, by Ibadlaev
22.
23. "Eski kyuyu" (The old well) by Memetov N.
24. "Tatar Tilinin Grammatics. Phonetics, Morphology, Syntax", by E. Kurtmollaev, A.
Islyamov.
25. Wings Grow in the Sky, by Chalbash E.U., in Russian
26. "Altyn Yuzyuk" (Equiritual songs) by Pintya I.V.
27. "Current Problems of Crimean Tatar Philology" in Russian, by A.M. Emirova.
28. "Vak'yt beklemey" (Time does not wait) by Emirov A., in Crimean Tatar
29. Crimean Tatar children's calendar - flip-flap, AZ Author Yunusova E.R.
30. "Concordance of Hearts" Translations of poems into Russian. Translation by Golubeva
O.
31. "Aziz Khalkyma" (To My People), a collection of poems, in the Crimean Tatar
language. Author Asanin I., compiled by Khairedinova Z.Sh.
32. "The Estonian settlement of Konči Šavva", by Salman L., in Russian
33. "Chechekler aleminde" (The World of Flowers), in Crimean Tatar by A. Osmanova.
Annex 38
33 books published in 2018
## Title
1. "The Greeks of Crimea" in Russian, by Panayot Kesmeji
2. Ilk bilgiler (First Knowledge) - A collection of poems and stories for children aged 3 to
12 about holidays, national heroes and traditions of Crimean Tatars in Crimean Tatar,
author: Hayredinova Nial
3. Adalet kureshi saflarynda (In the ranks of the struggle for justice) Book 4 in the Crimean
Tatar language, by: Zera Bekirova
4. "With Dance Through Life" in Russian, by R.U. Bakkal
5. Author's album "Songs embroidered with threads" in Ukrainian and Russian, compiled
by: Roik V.M.
6. “Scraps of Memory" collection of works in Russian and Armenian, by Rushan Pilosyan
7. "Belarusians" in Russian by author-compiler Balayan B.S.
8. "Kyrymtatardzha laf etmege ogrenemiz" (Learning to speak Crimean Tatar), phrasebook
in Crimean Tatar and Russian, by N.M. Ganieva, L.M. Bryukhova.
9. "Gonyul Ezgileri" (Songs of the Soul), a collection of poems in the Crimean Tatar
language, by A. Osmanova.
10. "The Three Ages of Osmanchik" in Russian, by Tabakurskaya L., Timirgazin A.
11. Almanac No. 8, 2018. A collection of stories by Armenian writers in Russian and
Armenian
12. Halk Sevgisini qazangan yirji, in Crimean Tatar, compiled by: Z. Bekirova.
13. "The Bulgarians of the Crimea. Return to the roots" Photo album in Russian and
Bulgarian by Ludmila Radeva
14. The White Book of the National Movement of the Crimean Tatars in Russian, by Y.B.
Osmanov.
15. "The Russian Community of Crimea: the Road to Russia.Part 1.Memories of Veterans of
the Community" in Russian, co-authored by I. Evtyushkin.В.
16. “Traditional culture of the Crimean Tatars", Compiler-Editor: Churlu Mamut
17. "Approaching the Horizon", by S.G. Yurieva, N.G. Yurieva
18. "Sary Gul", by: Kadirova Uriye.
19. "Uzyulgen zynjyr" by: Pashi I., compiled by: Salyadinov K.
20. "Sailama eserler", by Ipchi U., compiled by Ipchi Y.
Annex 38
21. "Tan'nag'mesi", by: Seytumerova Alie
22. "The Karaite cemetery in Feodosia. History Sealed in Stone" by V.A. Eliashevich.
23. "Sailama eserler", by: Edemova Uriye
24. "Kechmish ile kuryushuv", by: Bekirov Sh.A.
25. Music by Fevzi Aliyev, author: Aliyev F.
26. "Qalbmimnin Ai Zary", by: Chaylak Refat
27. Facsimile edition of "Yahshy ne ve yaramai", by V. Mayakovsky
28. Facsimile edition of "Kyrym Eskizleri", by A.M. Gorky
29. "My favourite Crimea", Wreath of Crimean Graces Project, by: Shevchenko T.
30. Facsimile edition of Adji Murat, by L.N. Tolstoy
31. "In the Museum of History, Culture and Religion of the Crimean Karaites-Türks named
after Tamara Ormeli", author: Polkanova A.Yu.
32. "In the Afternoon", by: Petrosyan M.A.
33. "The Krymchaks. Historical and Ethnographic Sketch" by Achkinazi I. V.
36 books published in 2019
## Title
1. "Crimean Tatar poetry of the Khan period" set of postcards in Crimean Tatar and
Russian, author-compiler: Zarema Trasinova
2. Asanchik ve Kashkachik (Asanchik and Kashkachik, Asanchik i Kashkachik, Asanchik
and Kashkachik) in Crimean Tatar, Russian, Ukrainian and English, by Rustem Muedin,
compiled by Fevzi Rustemovich Muedinov
3. "Ana kalbi" (Mother's Heart) collection of poems in Crimean Tatar, by Riza Yusufov
4. A collection of articles and stories in Armenian and Russian, 'Almanac 9' ('Motherland
in the Heart')
5. Collection of articles and stories in Russian by the Crimean Krymchak Society
"Krymchahlar" Public Association "Almanac 9"
6. "Kelejekni oylap: A collection of journalistic articles", in Crimean Tatar and Russian
7. "Revision Tales of the Crimean Armenians, 1782", in Russian
8. Sailama Eseler (Selected Works), in Crimean Tatar by Gulzar Dermendzhi
Annex 38
9. Kuneshchik (Sunshine), in Crimean Tatar by Yunus Qandym
10. "Evlyatlargya, torunlargya k'aviy miras k'alajak...". ("A worthy heritage for future
generations") a collection of poems in the Crimean Tatar language by Alie Veliulaeva
11. Balalar dunyasi (Children's World) in Crimean Tatar and Russian by Ablyaziz Veliyev,
translated by Olga Golubeva
12. "Eyilikler Olsun" in Crimean Tatar by Sevil Karashayeva, Ayshe Akiyeva
13. Essays on the History of Crimean Tatar Music Culture (Genesis, Evolution, Modern
State), volume 1 in Russian by Zaatov I. A.
14. The Estonian settlements of Jurči and Kijat Orka" in Russian, by Leongard Salman
15. Duygularım (My Feelings) in Crimean Tatar, by Bilal Mambet
16. The Germans of Crimea - Life for Good" in Russian, by I. P. Zadereichuk.
17. Production of the catalogue "Crimean Tatar Art" (volume 1). Paintings, graphics,
sculpture in Russian compilers: Zaatov I. A., Izetov
18. Terms of Reference for the production of the book Silama Eserler (Selected Works)
Volume I - and Volume II in the Crimean Tatar language, by Ablyaziz Veliyev
19. Syrly, tylsymly dunya (The mysterious magical world), in Crimean Tatar, by Isa
Abduraman
20. "Mayys Yagmury Sepelegende" ("When it Rains in May"), in Crimean Tatar, by Gulnar
Ziyadinova
21. Insanlık Borju (Man's Duty), in Crimean Tatar, by Kadyr Veliyev
22. Saylama Eseler (Selected Works), in Crimean Tatar, by Dzhevdet Ametov
23. "Akim Dzhemilev - war hero and dance genius", in Russian, by Sh. Abduramanova
24. "En'kadirli, suygen yerim" (The dearest favourite place), in Crimean Tatar, by Kerim
Jamanakli
25. "Crimean Tatar cuisine: original recipes", in Crimean Tatar and Russian, by R. Ibadlaev
26. "My Crimea is a tormented song", in Crimean Tatar and Russian, by Osmanov Dilyaver
27. "Sary Kunesh" (The Yellow Sun), in Crimean Tatar, by Nadzhie Ametova
28. "The French of Crimea" in Russian, by Amfiteatrova J. S. С.
29. "Music of a Stone", in Russian and English by Yakubuk P. G.
30. "Qisqachlar qayda qişlaylar" and "Tav evchikleri", in Crimean Tatar (reprinted edition),
by V. Bianki
Annex 38
31. "Aglavuk kyzchyk" and "Ormanda yıldızchıklar", by A. Barto (reprinted edition), in
Crimean Tatar
32. “Architecture of the Crimean Armenians" in Russian, by O. Khalpakhchyan, compiled
by T. E. Sargsyan.
33. "Yyrlar jayintygı 1940", (reprinted edition), in Crimean Tatar
34. "Kyrym Tatar Ornekleri Boyundja Boyalav Defteri" in Crimean Tatar and Russian, by
R.I. Vaapov.
35. "Proverbs, Sayings and Omens of the Crimean Tatars, 1914 in Crimean Tatar and
Russian (facsimile edition)
36. "The Prehistoric Past of the Crimea" in Russian, by G.A. BONCH-OSMOLOVSKY
(facsimile edition, 1929).
30 books published in 2020
## Title
1. "My mother's image is a guiding star", by S. Medjitova. Medjitova
2. What Animals Talk About, by A. A. Chergeev
3. "Lines as the patterns of a rushniki" by N. S. Ryndych
4. All things can wisdom and years, by A. S. Sklyaruk
5. "Kyrym Tatar halkynynyn karaman kyzy" (Girl - Hero of the Crimean Tatar people),
compiled by U. Edemova
6. Krymchahlar Almanac, by A.N. Sumina
7. "Tufanda k'algyan kyoy suryusi" (The storm that seized a flock of sheep), by Yu.Bolat,
compiled by V.V. Kachula and N.S. Bekirov
8. Photo album "The Legend of the 20th Century: Amet-Khan Sultan" by V.M. Basyrov
9. Ivan Genov: The Fate of the Partisan, co-authored by M. E. Sudnev, I. A. Noskova
10. "Living Witnesses to Events: The Little Heroes of the Great War" by N.P. Kriklya, coauthor
11. Book Almanac No. 10 "Motherland in the Heart", compiled by: R. K. Pilosyan. K.
Pilosyan
12. The Legends of the Crimea for Children by M. H. Fayzi.
13. "Sailama eserler" ("Selected works"), author: Cherkez-Ali (Ch.-A. Ametov), compiled
by: R. Ametov
Annex 38
14. "Sailama eserler uch tomlykъ. Birinji vol: novostler" (Selected works in three volumes.
Volume one: novels), by Uriye Edemova
15. "Loyal Daughters of Crimea" (Officers, Partisans, Underground Women) by L.
Khalilova
16. "Crimean Tatar women in the Great Patriotic War" Vol. 4, by A. Veliyev in Crimean
Tatar and Russian
17. Tebessum ile yasha (Live with a Smile) Book Musical collection, by S. S. Kakura
18. "Istek. (Desire) Poems, Memoirs, by: Dermendji L.
19. "Crimean Tatar-Russian Dictionary (1916)" by Bilâl Terlekçi [Qırımtatarca-rusça luğat
(1916)] [Bilâl Terlekçi], Special editor, foreword author: I.A. Kerimov, Editor: T.N.
Kirimov, compiler: H.B. Terlekçi
20. "Sailama eserler alty tomlykъ". Birinji vol: shiirler ve novostler (Selected Works in Six
Volumes. Volume One: Poems and Stories), by Sh. Alyadin compiled by Alyadinova L.
21. HISTORY OF THE NATIONAL ORGANIZATIONS OF CRIMEA, by B. S. Balayan
22. "The Folklore Heritage of the Thracian Greeks of the Republic of Crimea", co-authors:
Kifnidi S. A., Lazaridi S. A., Banach L. S.
23. "Between Crimea and Paris", by: Kenzhikaeva U.
24. "Crimean Tatar music by professional composers"
by F. M. Aliyev.
25. "Uchurym bashynda (Above the precipice)",
by: Mambetova M.
26. "Alem-i teselli (Graceful Peace)",
by Voloshin M. (Translated into Crimean Tatar by Yunus Qandym)
27. "Sailama eserler (Selected works)", by Murad R., compiled by Mambetova M.
28. Military and patriotic album "There was a war..." by Olkhovskaya V. Ya. Я.
29. "Menim Yollarym" (The Road Acquired) by Emin S. compiled by Ilyasov D.,
Khurshutov A., Osmanov D.
30. "The contribution of the repressed peoples of the USSR to the victory in the Great
Patriotic War of 1941-1945", compiled by: Akieva S.I., Kurtseitov R. J.
31 books published in 2021
## Title
1. "Agathangel of Crimea - Son of Three Nations", by E. Belousov
Annex 38
2. "Kyrym bizim er sheyimiz", by R. Gafarov. Gafarov
3. Unusual inhabitants of the Crimea, by V. Olkhovskaya
4. "Duwan S. Memories", co-editor-compiler: V. Strunina
5. The Complete Works. Literary Works. Volume 1, by I. Gasprinsky, compiled by S.
Seitmemetova, G. Seitvaniyeva
6. "Hayatny bakhshyshlary", by G. Useinova
7. Facsimile edition of "Izergil k'arty" (The Old Woman Izergil), by A. M. Gorky
8. Facsimile edition of Robinson Crusoe, by D. Defoe
9. Facsimile edition of Menim Aivanlarym, by V. Durov
10. Almanac No. 11 "Motherland in the Heart", compiled by: R. Pilosyan Pilosian
11. "Tylsimli masallar", by R. Suleymanov.
12. "Gonyul Ilhamy ve Emirinen", by A. Kokieva
13. "A Quiet Place on the Colon of Vicinity. Vibrant creations. Bakiyilik avuchyndaki
chechek. Saylama eserler", by L. Ukrainka, translated into Crimean Tatar by Y.
Kandym, compiled by V. Basyrov
14. On the Road, by O. Gabrielyan
15. "Edebiyatshynaslyk ve medeniy ayat", by S. Yunusov
16. "Karaites - the last inhabitants of Mangup",
Compilation Editors: V. A. Eliashevich, I. S. Lipunov, M. B.Kizilov
17. "Righteous among the Nations of the World in the Republic of Crimea", compiled by: A.
Gendin
18. Mummy's Fairy Tales, by A. Em (M. Heydiūnas)
19. Album "Artist Mamut Churlu", by M. Churlu
20. The Legacy of the Ancestors, by I. Abdullayev, compiled by E. Seitbekirov
21. "Hayallarym merjan kibi" by D. Medjitova, compiled by S. Medjitova
22. "The Burnt Villages of Crimea during the Great Patriotic War, 1941-1944" by K.
Ametov. K. Bokova
23. "The Link of Times", by P. Kesmeji, compiled by: S. Yurieva (Kesmedji)
24. “From Ararat to Ai-Petri" by G. Khachatryan
25. Ebediilik (Eternity), by I. Abduraman
Annex 38
26. "Yuri Bekirovich Osmanov. A man from another dimension", compiled by A. O. Dobro
27. "Sailama eserler alty tomlykъ" Ekinji vol. Novestler (Selected Works in Six Volumes.
Volume Two. Novels), by Sh. Alyadin, compiled by L. Alyadinova
28. "I wasn't a guest on earth... Interviews. Memories. List of publications. Volume 1" by V.
Basyrov
29. "Catalogue-album: Akhtem Aliyev - artist and poet", by A. Aliyev, compiled by R.
Aliyev
30. "Crimea 1941-1944.The Reverse Side of the War. Selected aspects of the history of the
occupation of the Crimea. Volume 2", by A. Nemenko
31. Facsimile edition of "Ikyaye Etuv Ichun Makiyaler Jyyntygy" by P. O. Afanasyev, I. N.
Shaposhnikov, E. E. Solovyova. O. Afanasyev, I. N. Shaposhnikov, E. E. Solovyova
27 books published in 2022
## Title
1. "I Love Crimea in All Weathers. Volume 1", by: Djerbinova L.
2. "Children's Galaxy, by Amedov N.
3. "Yureklerni tepretken edebiyu kyrym tatar edibiyati akkend maqaleler (Literary world,
stirring hearts. Articles on Crimean Tatar literature)", by: A. Dzhemileva.
4. "Vatan tarta bagirina (I am striving to embrace the Fatherland), by Kafadar E., compiled
by Kafadar R.
5. "Saylama eserler. Uch tomlykъ. Ekindzhi tom. Novel", by: Edemova U.
6. "Adiy insan olsa da (Even if a simple man)", by: Veliyev (Veli) K.
7. "Saylama eserler. Alty tomlykъ. Uchunji tom. Narrative, ikyaeler", author: Alyadin Sh.
compiled by Alyadinova L.
8. "Saylama eserler", by Selim Sh. compiled by Jelilova L.
9. "Tilimiznin degerligi (Wealth of Language)", by E. Bekirov.
10. "Atalar sösleri ve aytymlar (Proverbs and sayings)", author: Asanov S., compiled by
Asanov A.
11. "Selime Chelebiyeva. Ayyrylamam sanadan. (I will not part with the scene)", compiled
by: Jemileva
12. Facsimile edition. "Songs of the Crimean Turks", by A. Olesnitsky.
13. Facsimile edition. "Dubrovsky", by Pushkin A.
Annex 38
14. Facsimile edition. "Ikjaeler (stories)", by Chekhov A.
15. "Ha-ha-ha", by: Veliyev A.
16. "Memories of Peter Aljanaka", by the author-compiler: Jan T.
17. "The Khan's Palace in Bakhchisaray", by V. Gergross.
18. Crimea. Prosperity in unity.
19. "Almanac No. 12. Homeland at Heart", co-editor-compiler: R. Pilosyan.
20. "...(Collected Essays)", by Petrosian M.
21. "Alexander Mikhalyants. Jewellery Art. Enamel. Sculpture. Painting. Photo", author:
Mikhalyants A.
22. "Poems and songs", by: Klossowski I.
23. Greeks. Crimean Hellas. Authors-composers: Schonus I.A., Pipia O.M., Laptev Y.N.,
Gabrielyan A.O., Budurova N.V.
24. "The shtetl mystery of Elena Kotlyar", by: Kotlyar E.
25. "URANOIS (Heaven)", by I. Borokhov.
26. "Ashik Garip. A Krymchak tale", by Reby D., compiled by Zengina N.
27. "Durante (Persistent)", by Petrov A. (Krymsky A.)
Annex 38
Exhibit E
L. Khalilova, FAITHFUL DAUGHTERS OF CRIMEA: OFFICERS, PARTISANS, UNDERGROUND
WOMEN (Mediacentre n.a. I. Gasprinsky, 2020).
Annex 38
Exhibit F
U. Edemova, THE HERO GIRL OF THE CRIMEAN TATAR PEOPLE (Mediacentre n.a. Gasprinsky,
2020).
Annex 38
UDC 821.512.19-94
BBC 84 (2Ros)
K 977
Approved by the Advisory Council on the Publication of Socially Important Literature in
Native Languages at the State Autonomous Institution of the Republic of Crimea
Mediacentre n.a. Ismail Gasprinskiy. Published with the support of the State Committee on
Interethnic Relations of the Republic of Crimea at the expense of the federal budget, the
budget of the Republic of Crimea, is not subject to commercial distribution
K 977 The Hero Girl of the Crimean Tatar People: collected book / complier U. Edemova
- Simferopol: State Autonomous Institution of the Republic of Crimea “Mediacentre n.a.
Gasprinsky”, 2020. — 504 p. : illust. — In Crimean Tatar and Russian languages.
UDC 821.512.19-94
ISBN 978-5-6044686-1-6 BBC 84 (2Ros)
The book "The Hero Girl of the Crimean Tatar People" is an extensive collection of fiction
and documentary works dedicated to the difficult fate and heroic deed of Alime Abdenanova.
The name of the legendary hero girl, a Soviet servicewoman of Crimean Tatar origin and a
resident of the intelligence department of the Primorskaya Army Headquarter during the
Second World War, will live forever in the memory of generations.
© U. Edemova, complier, 2020
ISBN 978-5-6044686-1-6 © SAI "Mediacentre n.a. Gasprinsky", 2020
[…]

Annex 39
A. Dyukov, M. Vilkov, FROM MURDERS TO POGROMS: UNPUNISHED VIOLENCE
FROM THE SIDE OF RIGHT-WING ACTIVISTS AGAINST ROMA IN UKRAINE
(Warsaw, 2018).

Annex 39

Annex 40
S. Vnukov, O. Sharov, CRIMEA - TAURIDA. ARCHAEOLOGICAL RESEARCH IN CRIMEA IN 2017-
2018 (Institute of Archeology RAS, 2019, Vol. 1)
(excerpt, translation)

Annex 40
Excerpts
Translation
S. Vnukov, O. Sharov, CRIMEA - TAURIDA. ARCHAEOLOGICAL RESEARCH IN CRIMEA IN
2017-2018 (Institute of Archeology RAS, 2019, Vol. 1), p. 63.
Institute of Archaeology, Russian Academy of Sciences
To the 100th anniversary of Russian academic archaeology
CRIMEA — TAURIDA
Archaeological research in Crimea
in 2017-2018
Volume I
Moscow
2019
Annex 40
Approved for publication by the Scientific Council of the Institute of Archaeology, Russian Academy of Sciences
Editors-in-chief
Doctor of History C. Y. Vnukov
Doctor of History. О. V. Sharov
Reviewers
Doctor of History A. A. Maslennikov
Ph.D. in History A. V. Engovatova
К 85 Crimea — Taurida. Archaeological research in Crimea in 2017-2018 in 2vol. — M.: IA RAS, 2019. — Vol. 1. — 420 p.
ISBN 978-5-94375-269-8
DOI: 10.25681/IARAS.2019.978-5-94375-269-8
The collection includes articles presenting the most interesting preliminary results of the new construction excavations in the Crimea
in 2017-2018. The Crimean new construction archaeological expedition of the IA RAS at the end of 2018 completed field research on
objects under construction of the “Taurida” highway (Kerch - Simferopol - Sevastopol) and on the road and railroad access roads to the
Crimean bridge. Among the studied monuments of different cultural affiliation and dating there are settlements, villages and camps,
mounds and burial grounds, ancient defensive and architectural constructions. The archaeological excavation of each monument was
determined by the need to study them as thoroughly as possible before the beginning of the construction works. This publication
introduces into science the latest archaeological discoveries made during the rescue excavations made by the Institute of Archaeology
of the Russian Academy of Sciences in the Crimea. The publication is intended for archaeologists, historians and all those interested in
the history and archaeology of ancient Taurida.
UDC 902/904
BBK 63.4
© Federal State Budgetary Scientific Institution Institute of Archaeology, Russian
Academy of Sciences, 2019
© Authors of articles, 2019
UDC 902/904
BBK 63.4
К 85
Annex 40
DOI: 10.25681/IARAS.2019.978-5-94375-269-8.63-73
Research on the settlement of Hospital 1 in Kerch
I. V. Rukavishnikova, N. D. Dvurechenskaya, O. V. Dvurechensky, A. V. Alekseev
The settlement Hospital 1 is located within the
administrative boundaries of Kerch in 0.15-0.25 km to the
south-west of Nizhny Solnechny microdistrict. From the
west it adjoins the road connecting the central district of
Kerch with Arshintsevo district (Geroyev Stalingrada
ave.). At 0.03 km to the east-southeast of it is the
Gospitalny barrow (second half of the IV century BC).
The settlement of Hospital 1 occupied the top and slopes
of a small gently sloping hill on the right bank of the
Djordjava River. It was dammed in the twentieth century
and the pond has now effectively ceased to exist. The
settlement stretches along a long axis from south-west to
north-east. Originally a larger area, its eastern part was
destroyed by road construction. The central and especially
the northern parts have been affected by the
construction of numerous communications lines.
It was discovered in 1989 by N.F. Fedoseyev, who
supervised the rescue excavations for the road
under construction in 1989, 1990 and 1992. In the
area investigated by N.F. Fedoseev. of about 3000
sq. m. they discovered five building complexes,
among which there were half-houses for household
purposes with sewage drains running along the
hillside ending in a waste pit. In addition, about a
dozen household pits were examined and the
remains of a stone building were found on the
southern slope of the hill. Terracottas are an
interesting find,
(IA RAS, MOSCOW)
N. F. Fedoseev (t)
(IAC RAS, Simferopol)
Fig. 1. Panoramic image from a quadcopter of the 2017 excavation at Hospital 1 (V.V. Frolov)
Annex 40
Crimea — Taurida Archeological research in Crimea in 2017-2018
as well as red-figure pottery, graffiti, including a dedication to Zeus the Saviour, and plaques in the animalistic style.
The date of the monument is dated to the second half of the IV century BC (Fedoseev, 1991; 1994).
The total area of the monument, which was in the area of the ongoing construction and was subject to excavation
and archaeological observation, was 10,715 sq. m. Excavations in the spring and summer of 2017, conducted by the
KNAE IA RAS, revealed the remains of three stone buildings of various purposes, as well as seven utility pits (Fig. 1;
2).
The cultural layer of the Hospital settlement had a two-part structure. The upper horizon 1 was a well sodded,
homogeneous, humusified loam of varying degrees. Horizon 2 was a homogeneous, greyish-brown loam with a
thickness of 0.1-0.3 m and was the upper soil layer.
All the mentioned objects have been identified in the process of dismantling of horizon 1 or at the level of clearing
of the upper part of horizon 2. Most likely, the horizon 1 was formed in the process of ploughing up of the territory of
the monument no later than the 60-70s of the 20th century.
The integrity of all three architectural constructions is fragmentary. The masonry as a rule survived not more than
3-4 rows above the level of the ancient daytime horizon. The building complex 1 is most interesting despite the fact
that the greater part of it was destroyed by the section of the water supply trench.
Building complex 1 was a subrectangular building in plan from which the remains of foundation masonry (16,4 x
4,6-5,6 m), oriented by the long axis along the west-east line, are preserved. It was a three-part structure, sunk from
the level of the daylight surface to 0.55 m in the west side and to 0.20 m in the east side, which is due to the general
slope of the terrain to the east and north-east. Thus, the floor of the building was close to horizontal and had depth
differences of no more than 0.1m (Fig. 3). The wall masonry, up to 0.5m in height, were preserved in two or three
rows. The filling of the buried part represented rather homogeneous brownish grey ashy loam with numerous
inclusions of charcoal, clay and abundance of ceramic fragments. In the bottom part, practically in the whole area
there was a layer of organic sludge (brown sandy loam 1 to 5 cm thick) and ashy sub-layers. Most of the single stones
and their accumulations in the upper filling horizon are associated with wall collapses and are concentrated in the
southern part of the structure.
Fig. 2. Topographical plan of the 2017 mainland
clearance of the Hospitaller 1 settlement
Annex 41
S. Kozlov, GRU SPETSNAZ: FIFTY YEARS OF HISTORY, TWENTY YEARS OF WAR (Russkaya
Panorama Publishers, Essays on Contemporary History Series, 2003)
(excerpt, translation)

Annex 41
Excerpt
Translation
S.B. Kozlov, GRU SPETSNAZ: FIFTY YEARS OF HISTORY, TWENTY YEARS OF WAR
(RUSSKAYA PANORAMA PUBLISHERS, ESSAYS ON CONTEMPORARY HISTORY SERIES, 2003).
Sergey Vladislavovich Kozlov
“GRU Spetsnaz: Fifty Years of History, Twenty Years of War”
[page 165]
Special Group
Alexander, as the most experienced specialist, received under his command the most efficient
combat group. It did not include any Navy conscripts, as was the case in the other groups. Ten
officers and midshipmen became simple scouts for the duration of the combat mission. No
one knew the task itself, as Alexander’s group was at the direct disposal of the Commander of
the Ukrainian Fleet. But, judging by whose disposal the group was at and who was part of it,
it could be assumed that the task would not be easy.
The group was provided with weapons and ammunition in excess of any norm. Suffice it to
say that the scouts had at their disposal one hundred and seventy-five kilos of TNT, a box of
SZ-6 concentrated charges, a total of twelve KZ-5 and KZ-7 cumulative charges (in the
designation of a charge such as SZ-1e, for example, the number means the weight of the
explosive in kilograms), and a box of SPM magnetic mines.
The group included two snipers armed with SVD rifles. The other scouts were armed with
7.62-mm Kalashnikov (AKMS) assault rifles with silent and flameless firing devices (PBS-1).
The group could fight effectively at night as each weapon was provided with a NSPU night
sight device. Each member of the group, in addition to his main weapon, also had a silent
Stechkin automatic pistol and a scout firing knife. With such weapons, the group could act
silently. But in case they had to make some noise, they had two boxes of grenades and ten
Annex 41
RPG-22 grenade launchers. Every man was equipped with a bulletproof vest.
The group was located on the premises of the Ukrainian Fleet’s HQ. The fact that this group
was based in Sevastopol, unlike other groups demonstrating strength, was hidden in every
possible way. All of them were dressed in civilian clothes. The access of scouts to the city
was limited, and their identity documents were seized. In return, they were given cards stating
that “the bearer takes part in exercises”. Their documents, weapons and equipment are not
subject to inspection. If necessary, the Command of the Armed Forces of Ukraine could easily
abandon the special forces as these cards had no photos of their bearers. They could always
say that the cards had been forged and the seal affixed thereto was lost three months ago and
is currently invalid.
[…]
[pages 166-167]
According to Alexander’s plan, each scout had his own specific task. Having carried off the
sentries, an assault subgroup was expected to throw toxic-smoke grenades into armoured
personnel carriers (APCs) and guard rooms. After the marines, shedding tears, left them, the
scouts of the mining subgroup should install a medium sticky mine on the power
compartment of each APC and mine the guard room’s building with concentrated charges,
setting fuses for a minimum period. That was to ensure the almost instantaneous detonation of
the mines and charges after these were installed and the group withdrew. Further, under the
cover of other scouts, the miners should install seven TNT boxes and the remaining charges in
vulnerable places of the building and blow them up after retreating to the car waiting for them
in a pre-agreed place.