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Indictment P. Riot English (Part 1.1.)

The Prosecutor of the Central
Administrative District of Moscow
Senior Advisor of Justice
"____" July 2012
on charges
for Nadezhda Andreevna Tolokonnikova who is charged with a criminal offense pursuant to Part 2 of Art. 213 of the Russian Federation Criminal Code;
Maria Vladimirovna Alekhina who is charged with a criminal offense pursuant to Part 2 of Art. 213 of the Russian Federation Criminal Code;
Catherine Stanislavovna Samucevič who is charged with a criminal offense pursuant to Part 2 of Art. 213 of the Russian Federation Criminal Code.
Charged with:
1. Name, Patronymic, Family name – Nadezhda Andreevna Tolokonnikova
2. Date of birth:***
3. Place of birth:***
4. Place of residence and/or register: *** temporarily registered at: ***
5. Nationality: ***
6. Education: ***
7. Marital status, family members: married to Peter Yurievich Verzilov with whom she has a daughter, G.***, born in 04.03.08
8. Place of work or study: *** (Vol. 7 record page 52)
9. Bound to military service: not bound
10. Criminal record: previously unconvicted (Vol. 7 record page 55-57)
11. A passport or other identity document of the accused: *** (Vol. 1 record page 75, Vol. 7 record page 53, Vol. 5 record page 153)
12. Other information about the accused: she is not registered at a psychiatric or addiction facility (Vol. 7 record page 36, 39, 41). Administrative proceedings were previously instituted against her on 27 October 2011 pursuant to Art. 200.2.2 of the Russian Federation Administrative Code by the Internal Affairs Department responsible for protecting the subway (station “Airport” police department # 352) and on 20 January 2012 by the Russian Federation Ministry of Interior, China Town District of Moscow. (Vol. 7 record page 57, Vol. 5 record page 144-162)
On April 26, 2012 at the N. Alekseev, Psychiatric Clinic № 1. Department of Forensic Psychiatric Examinations, a forensic psychological and psychiatric evaluation conducted on Tolokonnikova N., where was concluded***. The accused’s personal history and the results of the evaluation of her personality traits illustrated the following: she has a pro-active attitude to life, relies on personal experience in decision-making, and strives for self-realization up to defending her social values with predominant significance. This evaluation also demonstrates the particularity of her interests, self-confidence, over-estimated level of aspiration along with high sensitivity for criticism with a predisposition emphatically to express her opinion. At the time of the alleged acts Tolokonnikova N. did not suffer from any chronic mental illness, temporary mental disorder, dementia or other mental condition depriving her of the possibility to realize the actual nature and social danger of her actions and control them. *** (Vol. 6 record page 268-273)
She is charged with an act of disorderly conduct, i.e., gross violation that caused disturbance of the public peace, which indicates a clear disrespect for society, committed on grounds of religious hatred and enmity and hate against any social group by a group of persons acted by previous concert with each other, namely:
under the unexplained consequence of circumstances Tolokonnikova N. conspired (the place and time being unknown, however, it was no later than on 17 February 2012) with Samucevič C., Alekhina M., and other unknown individuals, with the objective to commit a gross violation of public order which expresses a clear disrespect for society on grounds of religious hatred and enmity and on grounds of religious hatred and enmity and hate against any social group in the form of provocative and offensive actions in the religious building, drawing the attention of a wide community of religious citizens. In order to carry out their unlawful acts, Tolokonnikova N., Samucevič C., Alekhina M., and other unknown confederates divided amongst themselves the roles, and deliberately bought clothing to wear that clearly and obviously contradict the general rules of the Church, requirements of order, discipline, and inner structure of the Church. Tolokonnikova N., Samucevič C., Alekhina M., and other unknown criminal conspiracy participants, claiming to be members of the female punk band Pussy Riot, planned to wear the above-mentioned clothing in the Cathedral of the Russian Orthodox Church, which is the Cathedral of Christ the Saviour (referred to as the Cathedral), with the objective openly to express their contempt for the Christian world and Church principles, being aware of the offensive nature of their look and behavior which was intended to be seen by the whole Russian Orthodox Church. Tolokonnikova N., Samucevič C., Alekhina M., and other unknown confederates planned to hide their faces behind colourful masks with slots for their eyes and mouths. By so doing, they understood the wrongfulness of their planned Act and the seriousness of the offence they were preparing to cause for all the congregants of the Church and believers. Tolokonnikova N., Samucevič C., Alekhina M., and other unknown confederates used means to prevent their identification. As a consequence, this makes it complicated to prosecute them as set out by the criminal law. That increases the danger of the committed Act and turns it into a malicious, deliberate and carefully planned action, meant to humiliate the feelings and beliefs of many followers of the Orthodox Christian religion, and to undermine the spiritual foundation of the State.
Joint sinister intent of Tolokonnikova N., Samucevič C., Alehina M., and other unknown confederates is not only limited to a violation of a sacred place of worship in the presence of the congregants. Intending to make their planned acts publicly known and attract public attention, they notified various media members and active blog participants about their Campaign in confederate with or through another unknown individual/or through other unknown individuals.
Therefore, a joint criminal intent of Tolokonnikova N., Samucevič C., Alekhina M., and other unknown confederates was also meant to draw public attention to their sacrilegious act and express their disrespect to the ministers and visitors of the Cathedral as well as to other citizens, who were not present in the Cathedral at the time the Act was committed, and yet still share the Orthodox traditions and customs. Inflicting such a serious suffering on all the persons who found their spirituality in serving the Orthodox teachings was intended to provoke unrest among the believers, hurt their innermost and precious ideals and understandings of justice and good and evil, make them unknowingly seek for a response reaction, create the background for enhancing hostile actions of the community groups that gave their moral preference to other religious denominations.
Having finished a preparatory stage of this planned Act that took place on 21 February 2012 at approximately 11: 00 a.m., Tolokonnikova N., with Samucevič C., Alekhina M., and the other unknown criminal conspiracy confederates came to the Cathedral of the Russian Orthodox Church (Cathedral of Christ the Saviour) and put into force their joint criminal intent at the following address: Moscow, Volkhonka Str., building 15. There, in order to be allowed to enter the place where sacred religious ordinances were being performed, they used clothing that fully met places of worship requirements and under the pretence of regular visitors found their way into the Cathedral. Therefore, meticulous planning of their joint criminal enterprise with or through other confederates, careful preparation for each criminal step and the use of required elements made it possible for them successfully to accomplish all the stages of the intended Act and reach the finish line.
Tolokonnikova N., together with Samucevič C., Alekhina M., and other unknown confederates on 21 February 2012 approximately at 11:20 a.m. came to the Orthodox Church Cathedral (The Cathedral of Christ the Saviour), where they started executing their criminal end-objective, severely harming spiritual values of the Christian service, and encroached upon the sacramental church ordinances, ignoring the candle lady S*** L.A. who requested them to stop the desecration of the area, tried to make them leave and explained why it was not permissible to stay in that part of the Cathedral. Then they illegally entered the fenced-off area of the Cathedral, meant for sacred religious ordinances, and by so doing blasphemously desecrated the ancient foundation of the Orthodox Church and its core principles.
Not limiting themselves to all the desecration they had accomplished, they desired to inflict even more profound spiritual wounds on the Russian Orthodox Christians, placing themselves on a little elevation in front of the altar (soleí) solely meant for the Russian Orthodox Church clergy. Tolokonnikova N., together with Samucevič C., Alekhina M., and other unknown confederates, also had approached a special place destined for Scripture reading, praying and preaching (ambon) where they removed their outer clothing, having thrown it in front of the doors which lead to the altar and symbolize the gates into Heaven (the Holy doors). The persons mentioned above wore rather immodest clothing not suitable for this place, improperly revealing different body parts (arms and shoulders) while at the same time having their faces covered with provocatively-coloured protective masks.
Dressed like this, they stayed in the most fundamental and sacred place, situated in the country's main church building, and Samucevič C. in order to act her criminal part removed the case of the electric guitar, with the knowledge and acceptance of all her confederates, and during the attempt to play was forcibly taken away from the soleí by the guard B*** S.N. of the private security company Kolokol. At the same time, Tolokonnikova N.A., staying in the soleí and ambon area, without delay hooked up the microphone to her sound-system and after that switched on the track record with the previously prepared song which contained the blasphemous (for the Orthodox believers and clergy) content. The private company security guard hired by Kolokol Sh*** S.A. turned the sound-system off and forcibly removed it from the soleí.
Invited in advance, media representatives and weblog participants violated the Cathedral rules of conduct by recording videos and taking photos. They recorded the criminal acts committed by Tolokonnikova N., Samucevič C., Alekhina M., and other unknown individuals, ignoring the legitimate requests of the Cathedral workers to stop recording; some of them even entered into the fenced-off part of the Church, meant for officiating in sacred and symbolic religious ordinances with ceremonies, and continued recording.
Not satisfied with the course of events, ignoring the shouting of churchgoers and the actions of guards and Cathedral workers, Tolokonnikova N., Samucevič C., Alekhina M., and other, unknown to the investigation department, members of the group continued seriously to violate public order, namely by disregarding the religious rules of conduct and demonstrating obvious disrespect for the Cathedral’s behaviour rules. Despite all attempts to take them away from the sacred places of worship, they stayed in the sanctuary of the Cathedral, provocatively, cynically and in an indecent manner moving around the soleí and ambon, of which the entrance is strictly forbidden for any visitors, and then, for about 1 minute, they were loudly chanting profane words and phrases, on grounds of the religious hatred and enmity that offend believers. They also jumped, lifted their legs, imitating dancing and simulating punching an imaginary enemy.
By their actions, Tolokonnikova N. together with Samucevič C., Alekhina M., and other unknown individuals have grossly violated public order, deprived people of peace and interrupted the normal functioning of the Christ the Saviour Cathedral as set out by the visitors’ guidelines. They have demonstrated obvious disrespect for believers and workers of the Cathedral, who have become unwitting witnesses of the above-mentioned illegal acts, and deeply insulted and humiliated the feelings and religious principles of believing Orthodox citizens. By carrying out their disrespectful and irreverent act that lacked any ethical and moral foundation, they have set themselves against the Orthodox world. Thus they have attempted defiantly and publicly to desecrate the centuries-old cared-for and respected church traditions and doctrines. They have put themselves into a light that belittles inner convictions of people who feel a spiritual connection with God and have clearly demonstrated their religious hatred and enmity to one of the existing religions - Christianity - by having encroached upon its equal rights, identity and high significance for a large number of nations and peoples.
Therefore, Tolokonnikova N., Samucevič C., Alekhina M., and other unknown individuals have grossly violated public order with their actions and behaviour and expressed contempt for society; they have set themselves against the society in the Cathedral, defiantly ignored the common norms of conduct, offended the Cathedral visitors and all the religious people on grounds of hatred and enmity, i.e., committed an offence pursuant to part 2, Art. 213 of the Russian Federation Criminal Code.


( 2 comments — Leave a comment )
(Deleted comment)
Oct. 22nd, 2012 12:19 pm (UTC)
Thank you very much! I am happy to hear that.
( 2 comments — Leave a comment )