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Necessary deposition to "document" "III. Utilization of weapons and weaponry"
(Declared in court 04.26.99)

  1. Document in question is absent from the "Record of search at the apartment, 11.20.97". It appears unexplained in the registry of seized documents in volume 5, page 31, paragraph 31, described as "3-page document".
  2. Volume 5, page 111, contains description of this "document". Just like absolutely all the other documents in this case, this so-called "document" does not have any stamps, nor signatures, nor numerical sequence of any kind; nothing that constitutes an official document.
  3. Volume 5, pages 119-121 contain copy of the document in question. It is obvious that we are presented not with the whole document, but just a part of it. This is further supported by number III appearing in the beginning of the text. Therefore, investigation should have established: This incomplete copy is part of what document? Who prepared it? What security clearance did it have, if any? Etc. This is an obvious violation of article 20 of criminal code of Russian Federation.
  4. During questioning I explained that this document is known to me as part of "Regional program of utilization of weapons and weaponry of TOF [Pacific Fleet] " (volume 1, page 269). I have seen this document in possession of the former chief of the URAV [Intelligence Office] TOF, Mr. Antonov, as well as in possession of some other people (Vorozhbit, Berezhnoi - Director of plant "Krasny Vympel", Kamalov - director of the firm, Miseenko - current chief of URAV TOF). Antonov permitted me to use this document to write an article in "Boevaya vahta" (it was published). Information, contained in this document, can also be found in the Federal program of utilization of common weaponry. Therefore, in order to achieve a complete and objective picture of all circumstances surrounding the presence of the document titled "III. Utilization of weapons and weaponry" in this case, certain people should have been interviewed, Antonov Gennady Nikolaevich in particular. Following documents should have been included in the case: 1) A complete version of the document; 2) Regional program of utilization of weapons and weaponry of TOF"; 3) Federal program of utilization of common weapons.
  5. In addition, witness Vorozhbit testified (volume 4, page 31), that this document was compiled in August-September of 1997. He also stated (volume 4, page 42) that document was compiled in 1996-1997, and he himself participated in the development of the regional program of utilization of weapons. This program was forwarded to the central office, and came back to the fleet in the form of Antonov's dissertation. Dissertation is also not included in the case, in spite of the fact that I formally requested that.
  6. In addition, witness Vorozhbit testified that regional program in question is not carried out due to the lack of funds (this is discussed in my article). Based on the regional division, plant "Krasny vympel" and aircraft company "Progress" are included in this program. Vorozhbit emphasized that program does not contain any secret information and arrived at the fleet in the form of non-secret document. Therefore it is obvious that document based on this program cannot be secret.
  7. Vorozhbit did not mention DVPO [Far-Eastern Production Union] "Voshod". This plant, like those that were named by Vorozhbit, is mentioned in the document "III. Utilization ", which proves that information contained in that document is identical with the Regional (non-secret) program of utilization of weapons and weaponry at TOF.
  8. In volume 4, pages 1-2, one finds that investigation indecisively attempted to clarify the origins of the document titled "III. Utilization ". For example, in separate directive (volume 4, page1), it is stated: "During the search at Pasko's apartment, copies of "Regional program ", report - presentation "Utilization of artillery ammunition" and document "Utilization of weapons and weaponry" were seized". Report on carrying out this directive states: "Regional program was developed personally by Antonov. Report - presentation "Utilization of artillery ammunition and rocket weaponry" and document "Utilization of weapons and weaponry", apparently imply reports "Utilization of ZRK "Volna" and "Shtorm""". Therefore, apart from the conclusion "apparently implies", investigation did not clarify the origins of these documents, even though it was supposed to do so according to the article 20 of the criminal code of Russian Federation. Comparative analysis with Regional program was not done either. Antonov - he is vice-admiral - was not questioned. Therefore, all of this should have been done during the court proceedings.
  9. Witness Moiseenko (volume 4, page 18) testified that "document "III. Utilization " is known to him as part of report-presentation regularly prepared for the higher authorities." And after that - a very important conclusion: "I can state unequivocally that document, with part of which I am presented, is non-secret." Therefore, a complete report-presentation should have been found and attached to this case; not just part of it, as was presented to the court by investigation during the proceedings.
  10. Witness Moiseenko (volume 4, page 21) testified, that this document is a part of report-presentation that we, that is "URAV, often prepare for higher-ups of TOF". I do not know how this document found its way to Pasko. I myself did not give it to him." It is obvious, that a chief of URAV Moiseenko could and should have explained more in regards to this document (unless investigation wanted to collect as little truthful information as possible). For example, Moiseenko did not say: Is he familiar with the document? Who and when prepared it? Does it have a security clearance of any kind? What relation does it have to the "Regional Program"? etc. I therefore insist on questioning of Moiseenko.
  11. In the prosecution statement of 04.28.98 it is stated (volume 9, page 17) that in 1997 I acquired in URAV TOF document titled "III. Utilization ", containing real name of the technical rocket base. Kept document at home and thereafter handed off to Japanese." However, all of this is no more than baseless allegations of FSB. Case itself does not contain any proof of where, when, from whom and under what circumstances document in question was received in URAV (was it indeed URAV?), and no facts are present of me transferring these documents to Japanese.
  12. It also has to be kept in mind, that I could use document in question in writing the article in "Boevaya vahta" under the signature of Fadeev. It is only necessary to compare text of the article and the document. This document could be handed off to me by Fadeev, however, he was not questioned. Also, this document could have been contained in my folder, which was stolen in editorial office on 09.02.97 (supposedly by officers of YFSB governing TOF).
  13. Experts of the 8-th directorate (12.22.97, volume 7, page 187) have concluded that this document is non-secret.
  14. However, second examination by experts contains conclusion (volume 7, page 266) that from the whole document the only secret part is the real name of the TRB (base). "Base in question falls under the agreement on SNV, but is declared to the American side as an object base "Pavlovskoe"." I considered that Agreement on SNV had to be attached to the case (incidentally, there are two of them, and it is therefore unclear, which one is referenced here; if it is SNV-2, it was not yet ratified by the Russian Parliament and any references to it are therefore illegal). Also, summary protocols of the inspection of our bases in 1995-1997 by Americans should have been attached to this document, where the name of the rocket base is mentioned.
  15. As noted before, the only part of the document considered secret was the numerical identity of the base -1427. In order to understand the absurdity and groundlessness of this accusation, I ask the court to consider following facts:

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Translated by Ilya