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| : 04.12.2011. 75947/11


List of Appendices

EUROPEAN COURT OF HUMAN RIGHTS

First Section

_____ ___________________ 2013

Application no. 75947/11

Davydov and others v. Russia

Dear Mr. Nielsen,

Dear Sirs,

In reply to your letter and the request of the European Court of Human Rights as of March 7, 2013 in respect of submitting additional documents and information in the framework of complaint no.75947/11 Davydov and others v. Russia we hereby submit to the Court on behalf of the Applicants the following information concerning the issues raised by the Court together with a number of documents (in accordance with the list attached) in translation into English.

Claim Summary

Applicants: candidates for elections from a political party, members of district election commissions (hereinafter the DEC) with the right of a casting vote, observers from parties spent the voting day at polling stations. Then they participated in counting and received official protocols with polling results. At those DECs where in violation of the law they were denied the right to receive the protocols formal notes of wrongdoing were drawn. The notes were signed by the party representatives at the DEC. The next day on an official portal of SAS (state automation system) Vybory/ Election applicants saw the information on the number of votes cast for the parties different from the original protocols.

The Applicants filed complaints with the Municipal Election Committee (hereinafter the MEC), the Investigative Committee of the Russian Federation and Russian Prosecutors Office, with no result. The Applicants turned to court. Yet the position of the courts was unexpectedly tough: "Electoral fraud does not concern electoral rights of citizens. To protect the rights of citizens in court turned out to be impossible.

The Applicants filed a claim with the Constitutional Court of the Russian Federation. In the course of preparation for the litigation the Court requested from the state in the face of different government bodies and independent experts to give their opinion on the issue of the essence of citizens electoral rights.

The difference in the stands of the former and the latter participants of the discussion was dramatic and thus demonstrative. In the opinion of the Claimants the difference of opinions of the state and the people shows difference in priorities and clearly demonstrates the real attitude of the state toward its obligation as of art.3 Protocol 1 to the Convention and art.13 of the Convention

I. Explanations concerning art. A), B), C) of the Court request

1. The First Claimant:

Andrey V.Davydov

The right violated to be elected to a legislature of the constituent entity of the Russian Federation, the Legislative Assembly of St.Petersburg (hereinafter the Assembly).

Status at the elections of December 4, 2011 a citizen of the Russian Federation, a member of the regional office of the Spravedlivaya Rossiya political party in St.Petersburg (hereinafter the SR regional office), ran for the position of deputy of the Assembly from the abovementioned faction (see Appendix 1 the List of candidates for deputy at the Assembly of the fifth convocation nominated by the regional office of the SR in respect of the first Claimant; Appendix 2 Decision of the Municipal Election Committee of St.Petersburg (hereinafter the MEC) on registration of the list of candidates for deputy at the Assembly of the fifth convocation nominated by the regional office of the SR)) for the intracity election territory 19 (see Appendix 3 Certificate of a candidate for deputy of the Assembly of the fifth convocation).

Nature of the violation in connection with electoral fraud in the abovementioned territory the Claimants political party lost a significant number of votes, and the Claimant himself did not receive the seat at the Assembly, while in accordance with the protocols received by the First Claimant from watchers and members of the district election commissions (the DECs), the regional office of the SR party at the moment of vote counting in the intracity election territory 19 accounted for 10031 votes (Appendix 4.1 the Summary table with the information of the initial and total numbers of votes, and separate and aggregate number of electoral votes taken from specific political parties and their transfer to other parties (fraud) in the intracity election territory 19, Appendix 4.2 election results from the website of the MEC for the intracity election territory 19, Appendix 4.3 the DECs protocols with the voting results for the Assembly in the intracity election territory 19 (attached are the protocols which were later changed, in the intracity election territory 19 - the DECs protocols 638, 639, 641, 642, 643, 644, 646, 648, 649, 651, 652, 653, 654, 657, 661, 662, 664, 665, 666, 667, 668)). At the time of official announcement of the election results the number of votes cast for the political party from which the first Claimant ran for the election amounted to 4538 votes, while the results of the Edinaya Rossiya political party had increased from the initial 8,695 votes to 17,265 votes.

the Source of receiving the Protocols:

being a candidate from the regional office of the SR the Claimant had access to final protocols of the DEC in the territory from which he stood for election. The protocols were given by the watchers and members of the DEC present at the polling stations during voting and vote counting, representing the interests of the SR political party, as well as the First Claimant. The protocols were received by the abovementioned persons on the basis of subart. ) paragraph 9 art.30 of the Federal law as of June 12, 2002 N 67- On Basic Guarantees of electoral rights and right to participate in referendums for citizens of the Russian Federation, subart. ) paragraph 9 art. 17 of the Law of St.Petersburg as of June 15, 2005 N 252-35 "On election of deputies of the Assembly of St.Petersburg in respect of the right of watchers from political parties nominating candidates, the candidates watchers to receive copies of protocols with the election results; subart ) paragraph 23, art. 29 of the Federal law as of June 12, 2002 N 67- On Basic Guarantees of electoral rights and right to participate in referendums for citizens of the Russian Federation, subart. ) paragraph 11 art. 16 of the Law of St.Petersburg as of June 15, 2005 N 252-35 "On election of deputies of the Assembly of St.Petersburg in respect of the right of the DEC members to receive copies of protocols with the election results (see Appendix 5 abstract from the regulatory enactments).

Ally political parties (regional office of the Communist party of the Russian Federation (hereinafter the CP regional office) and the regional office of the Russian United Democratic party YABLOKO (hereinafter the Yabloko regional office) gave the First Claimant the DEC protocols at their disposal with election results for the Assembly in the intracity election territory 19

The list of citizens who received first hand protocols for specific DECs can be found in the right column (Source of protocols/Name (party)) of the Summary table with the information of the initial and total numbers of votes in the intracity election territory 19 (see Appendix 4.1) (the abovementioned list can also be found in summary tables for other election territories).

Out of the protocols presented, always containing the same information about voting results, yet sometimes without indication of the time (hour) of their filling, the copy number, etc. the most comprehensive were chosen to be submitted to the Court.

2. The Second Claimant

Olga O. Andronova

The right violated the right to elect to the Assembly, the State Duma of the Federal Assembly of the Russian Federation (hereinafter the State Duma).

Status at the elections of December 4, 2011 a citizen of the Russian Federation with the right to vote, registered for voting for the Assembly, the State Duma at polling station 652 of the Kolpinsky district of St.Petersburg (Appendix 6 Statement by the Second Claimant of registering for voting at polling station 652 of the Kolpinsky district of St.Petersburg) because of her acting as a member of the election commission with the right of casting vote from the SR political party (Appendix 7 Certificate of a member of the election commission of polling station 652, Appendix 8 Decision of the SR regional office on candidates to the DEC).

Nature of the violation:

in connection with electoral fraud in territory 19, where polling station 652 is located, political party the Second Claimant voted for lost a significant number of votes. Thus, in accordance with the initial results of elections to the State Duma (Appendix 4.3 the DECs protocol on the voting results to the State Duma) at polling station 652 315 persons cast their votes for the SR political party, while under the official information this number amounted to 115 votes, the numbers for the CP changed from 174 votes in the original protocol to 74 on the official website, the Yabloko political party retained only 42 out of the initial 72 votes. At this the results of the Edinaya Rossiya (the ER) political party had increased from the initial 274 votes to 574 votes, and the original results of the Liberal Democratic Party of Russia (hereinafter the LDPR), 113 votes, transformed into 143 (Appendix 4.1 the Summary table for the intracity election territory 19, Appendix 4.2 election results from the website of the MEC for the intracity election territory 19)

The number of votes at the elections to the Assembly was redistributed significantly, which also violated the right of the Second Claimant to the fair election. Thus, according to the initial information on the Assembly election results (Appendix 4.3 the DECs protocol 652 on the results of elections to the Assembly) at the polling station 299 votes were cast for the regional office of the SR party, 164 for the regional office of the CP, 77 for the regional of the Yabloko. Yet according to the official information the SR regional office got only 19 votes, the CP regional office 14, and the Yabloko regional office 7. The number of votes for the ER regional office increased form the initial 259 to 599, and for the LDPR from the initial 148 to 308 votes (Appendix 4.1 the Summary table for the intracity election territory 19, Appendix 4.2 election results from the website of the MEC for the intracity election territory 19).

The Second Claimant became familiar with the fact that the MEC of St.Petersburg and the CEC of RF acknowledged the election results for polling station 652 different from the ones indicated in the DECs protocol 652 on the election results after the results were officially published on the election commission websites.

Nobody informed the Second Claimant of the fact of recounting of votes cast by the citizens at polling station 652, despite the fact that under the Russian legislation (paragraphs 8,9 art. 69 of the Federal law as of June 12, 2002 N 67- On Basic Guarantees of electoral rights and right to participate in referendums for citizens of the Russian Federation) such recounting shall be performed only with the participation of the DEC members who made the initial counting; the Second Claimant has no information concerning the grounds for recounting as well. No claims were received by DEC 652, whose member the Second Claimant was, during the elections.

the Source of receiving the Protocols:

Being a member of DEC 652 (Appendix 7), on the basis of subart. ) paragraph 23 art.29 of the Federal law as of June 12, 2002 N 67- On Basic Guarantees of electoral rights and right to participate in referendums for citizens of the Russian Federation, subart. ) paragraph 11 art. 16 of the Law of St.Petersburg as of June 15, 2005 N 252-35 "On election of deputies of the Assembly of St.Petersburg the Second Claimant received a copy of the final protocol in person.

3. The Third Claimant

Alexey V. Andronov

The right violated the right to elect to the Assembly, the State Duma of the Federal Assembly of the Russian Federation (hereinafter the State Duma).

Status at the elections of December 4, 2011 a citizen of the Russian Federation with the right to vote, registered for voting for the Assembly, the State Duma at polling station 651 of the Kolpinsky district of St.Petersburg (Appendix 9 Statement by the Third Claimant of registering for voting at polling station 651 of the Kolpinsky district of St.Petersburg) because of his acting as a member of the election commission with the right of casting vote from the SR political party (Appendix 10 Certificate of a member of the election commission of polling station 651, Appendix 8 Decision of the SR regional office on candidates to the DEC).

Nature of the violation:

in connection with electoral fraud in respect of the election to the State Duma in territory 19, where polling station 651 is located, political party the Third Claimant voted for lost a significant number of votes. Thus, in accordance with the initial results of elections to the State Duma (Appendix 4.3 the protocol on the voting results to the State Duma of DEC 651) at polling station 651 345 persons cast their votes for the SR political party, while under the official information this number amounted to 125 votes, the numbers for the CP changed from 173 votes in the original protocol to 113 on the official website, the Yabloko political party retained only 24 out of the initial 74 votes. At this the results of the Edinaya Rossiya (the ER) political party had increased from the initial 310 votes to 640 votes (Appendix 4.1 the Summary table for the intracity election territory 19, Appendix 4.2 election results from the website of the MEC for the intracity election territory 19)

The number of votes at the elections to the assembly was redistributed significantly, which also violated the right of the Third Claimant to the fair election. Thus, according to the initial information on the Assembly election results (Appendix 4.3 the DECs protocol 651 on the results of elections to the Assembly) at the polling station 328 votes were cast for the regional office of the SR party, 209 for the LDPR regional office, 154 for the regional office of the CP, 81 for the regional office of the Yabloko, 15 for the regional office of the All-Russia political party Pravoye Delo (The Just Cause) (hereinafter the PD regional office) and 11 for the regional office of the political party Patrioty Rossii (the Patriots of Russia) (hereinafter the PR regional office). Yet according to the official information the SR regional office got only 9 votes, the CP regional office 11, the Yabloko regional office 6, the PD and PR regional offices 7 and 3 votes respectively. Yet the number of votes for the ER regional office increased form the initial 299 to 807, and for the LDPR from the initial 209 to 254 votes (Appendix 4.1 the Summary table for the intracity election territory 19, Appendix 4.2 election results from the website of the MEC for the intracity election territory 19).

The Third Claimant became familiar with the fact that the MEC of St.Petersburg and the CEC of RF acknowledged the election results for polling station 651 different from the ones indicated in the DECs protocol 651 on the election results after the results were officially published on the election commission websites, on December 5, 2011.

Nobody informed the Third Claimant of the fact of recounting of votes cast by the citizens at polling station 651; the Third Claimant has no information concerning the grounds for recounting as well.

Moreover, the Head of DEC 651 in a telephone conversation with the Third Claimant informed the latter that by 1915 December 5, 2011 the protocol had not been submitted by him to TEC (Territorial Election Commission) 21, he was at TEC 21 waiting for his turn to hand the protocols over.

Thus, by the time the election results were officially published, the TEC had no information about voting results in DEC 651 at its disposal, as well as the MEC.

However, the information on the results of election to the State Duma of the Federal Assembly of the RF had already been published on the MEC official website (in particular, for DEC 651) and most important, this information was absolutely different from the real one.

the Source of receiving the Protocols:

Being a member of DEC 651 (Appendix 10), the Third Claimant received a copy of the final protocol in person.

4. The Fourth Claimant

Tatiana A. Nikolayeva

The right violated the right to elect to the Assembly, the State Duma of the Federal Assembly of the Russian Federation (hereinafter the State Duma).

Status at the elections of December 4, 2011 a citizen of the Russian Federation with the right to vote, registered for voting for the Assembly, the State Duma at polling station 654 of the Kolpinsky district of St.Petersburg (Appendix 11 Statement by the Fourth Claimant of registering for voting at polling station 654 of the Kolpinsky district of St.Petersburg) because of her acting as a member of the election commission with the right of casting vote from the SR political party (Appendix 12 Certificate of a member of the election commission of polling station 654, Appendix 8 Decision of the SR regional office on candidates to the DEC).

Nature of the violation:

in connection with electoral fraud in respect of the election to the State Duma in territory 19, where polling station 654 is located, political party the Fourth Claimant voted for lost a significant number of votes. In accordance with the initial results of elections to the State Duma (Appendix 4.3 the protocol on the voting results to the State Duma of DEC 654) at the polling station 307 persons cast their votes for the SR political party, while under the official information this number amounted to 157 votes, the numbers for the Pravoye Delo political party (hereinafter the PD) changed from 13 votes in the original protocol to 9. At this the results of the ER political party had skyrocketed from the initial 274 votes to 424 votes, and of the Patrioty Rossii (the PR) amounted to 13 votes against the initial 9 (Appendix 4.1 the Summary table for the intracity election territory 19, Appendix 4.2 election results from the website of the MEC for the intracity election territory 19)

The number of votes at the elections to the assembly was redistributed significantly, which also violated the right of the Fourth Claimant to the fair election. Thus, according to the initial information on the Assembly election results (Appendix 4.3 the DECs protocol 654 on the results of elections to the Assembly) at the polling station 287 votes were cast for the regional office of the SR party, 197 for the regional office of the CP, 92 for the regional office of the Yabloko, 6 for the PD regional office and 16 for the PR regional office. Yet according to the official information the SR regional office got only 14 votes, the CP regional office 12, the Yabloko regional office 8, the PD and PR regional offices 1 and 6 votes respectively. Yet the number of votes for the ER regional office increased form the initial 261 to 748, and for the LDPR from the initial 182 to 252 votes (Appendix 4.1 the Summary table for the intracity election territory 19, Appendix 4.2 election results from the website of the MEC for the intracity election territory 19).

The Fourth Claimant became familiar with the fact that the MEC of St.Petersburg and the CEC of RF acknowledged the election results for polling station 654 different from the ones indicated in the DECs protocol 654 on the election results after the results were officially published on the election commission website.

Nobody informed the Fourth Claimant of the fact of recounting of votes cast by the citizens at polling station 654; the Fourth Claimant has no information concerning the grounds for recounting as well.

the Source of receiving the Protocols:

Being a member of DEC 654 (Appendix 12), the Fourth Claimant received a copy of the final protocol in person.

5. The Fifth Claimant

Alla G. Nikolayeva withdrew her claim.

6. The Sixth Claimant

Evgeny P. Sizionov

The right violated the right to elect to the Assembly, the State Duma of the Federal Assembly of the Russian Federation (hereinafter the State Duma).

Status at the elections of December 4, 2011 a citizen of the Russian Federation with the right to vote performed at the place of residence, at polling station 661 of the Kolpinsky district of St.Petersburg. At the same time the Claimant acted as a member of the election commission from the Russian United Democratic party Yabloko (Appendix 13 Certificate of a member of the election commission of polling station 661).

Nature of the violation:

in connection with electoral fraud in respect of the election to the State Duma in territory 19, where polling station 661 is located, political party the Sixth Claimant voted for lost a significant number of votes. Thus, in accordance with the initial results of elections to the State Duma (Appendix 4.3 the protocol on the voting results to the State Duma of DEC 661) at polling station 661 358 persons cast their votes for the SR political party, while under the official information this number amounted to 138 votes, the numbers for the CP changed from 204 votes in the original protocol to 103 on the official website, the Yabloko political party retained only 40 out of the initial 90 votes. The number of votes for the PD political party was down from 11 to 9. At this the results of the ER political party had increased from the initial 396 votes to 667 votes, and the LDPR original result of 178 votes transformed into 180 (Appendix 4.1 the Summary table for the intracity election territory 19, Appendix 4.2 election results from the website of the MEC for the intracity election territory 19)

The number of votes at the elections to the assembly was redistributed significantly, which also violated the right of the Sixth Claimant for the fair election. Thus, according to the initial information on the Assembly election results (Appendix 4.3 the DECs protocol 661 on the results of elections to the Assembly) at the polling station 360 votes were cast for the SR party, 199 for the CP, 103 for the Yabloko, 12 for the PD and 14 for the PR. Yet according to the official information the SR got 13 votes, the CP 9, the Yabloko 8, the PD and PR 4 for each. Yet the number of votes for the ER regional office increased form the initial 281 to 861, and for the LDPR regional office from the initial 183 to 251 votes (Appendix 4.1 the Summary table for the intracity election territory 19, Appendix 4.2 election results from the website of the MEC for the intracity election territory 19).

The Sixth Claimant became familiar with the fact that the MEC of St.Petersburg and the CEC of RF acknowledged the election results for polling station 661 different from the ones indicated in the DECs protocol 661 on the election results after the results were officially published on the election commission website.

Nobody informed the Sixth Claimant of the fact of recounting of votes cast by the citizens at polling station 661; the Sixth Claimant has no information concerning the grounds for recounting as well.

the Source of receiving the Protocols:

Being a member of DEC 661 (Appendix 13), the Sixth Claimant received a copy of the final protocol in person.

7. The Seventh Claimant

Vladimir A. Ryzhkov withdrew his claim.

8. The Eighth Claimant

Vladimir G. Belyakov

The right violated the right to elect to the Assembly.

Status at the elections of December 4, 2011 a citizen of the Russian Federation with the right to vote performed at the place of residence, at polling station 637 of the Kolpinsky district of St.Petersburg.

Nature of the violation The votes cast at the election to the Assembly were significantly redistributed, which violated the right of the Eighth Claimant to the fair election. Thus, in accordance with the initial results of elections to the Assembly (Appendix 4.3 the protocol on the voting results to the Assembly of DEC 637) at polling station 200 votes were cast for the CP regional office, 337 for the SR regional office, 170 for the regional office of the Liberal Democratic Party of Russia (hereinafter the LDPR regional office), 128 for the Yabloko regional office, 18 and 13 for the PD and PR regional offices respectively. Yet under the official information the number of votes for the CP regional office amounted to 14, 404 for the SR regional office, 101 for the LDPR regional office, 4 for the Yabloko regional office, 5 and 2 for the PD and PR regional offices respectively. At this the results of the ER regional office had increased from the initial 380 votes to 804 votes (Appendix 4.1 the Summary table with the information of the initial and total numbers of votes, and separate and aggregate number of electoral votes taken from specific political parties and their transfer to other parties (fraud) in polling stations 637 and 623, Appendix 4.2 election results from the website of the MEC polling stations 637 and 623, Appendix 14.3 the DEC protocol on the election results for the Assembly at polling station 637).

the Source of receiving the Protocols:

The Eighth Claimant received a copy of the protocol of DEC 637 on election results for the Assembly from Vladimir I. Moskovtsev, who in his turn had access to them as the Head of Kolpino organization of the CP regional office. The CP regional office, as it was mentioned above, received the protocols with election results at the DEC from watchers and DEC members from the CP regional office under the law (Appendix 5).

.

9. The Ninth Claimant

Sergey V. Yakushenko

The right violated the right to elect to the Assembly.

Status at the elections of December 4, 2011 a citizen of the Russian Federation with the right to vote performed at the place of residence, at polling station 623 of the Kolpinsky district of St.Petersburg.

Nature of the violation The votes cast at the election to the assembly were significantly redistributed, which violated the right of the Ninth Claimant to the fair election. Thus, in accordance with the initial results of elections to the Assembly (Appendix 4.3 the protocol on the voting results to the Assembly of DEC 623) at polling station 731 votes were cast for the ER regional office, 131 votes were cast for the CP regional office, 213 for the SR regional office, 102 for the LDPR regional office, 99 for the Yabloko regional office, 12 and 9 for the PD and PR regional offices respectively. Yet under the official information the number of votes for the ER regional office amounted to 798, 7 for the CP, 622 for the SR regional office, 22 for the LDPR regional office, 3 for the Yabloko regional office, 3 and 5 for the PD and PR regional offices respectively. (Appendix 4.1 the Summary table with the information of the initial and total numbers of votes at polling stations 637 and 623, Appendix 4.2 election results from the website of the MEC polling stations 637 and 623, Appendix 14.3 the DEC protocol on the election results for the Assembly at polling station 623).

the Source of receiving the Protocols:

The Ninth Claimant received a copy of the protocol of DEC 637 on election results for the Assembly from Vladimir I. Moskovtsev, who in his turn had access to them as the Head of Kolpino organization of the CP regional office. The CP regional office, as it was mentioned above, received the protocols with election results at the DEC from watchers and DEC members from the CP regional office under the law (Appendix 5).

10. The Tenth Claimant

Nikolay L. Payalin

The right violated to be elected to the Assembly.

Status at the elections of December 4, 2011 a citizen of the Russian Federation, a member of the SR regional office, ran for the position of deputy of the Assembly from the abovementioned faction (see Appendix 15 the List of candidates for deputy at the Assembly of the fifth convocation nominated by the regional office of the SR in respect of the Tenth Claimant; Appendix 2 Decision of the MEC on registration of the list of candidates for deputy at the Assembly of the fifth convocation nominated by the regional office of the SR) for the intracity election territory 22 (see Appendix 16 Certificate of a candidate for deputy of the Assembly of the fifth convocation).

Nature of the violation in connection with electoral fraud in the abovementioned territory the Tenth Claimants political party lost a significant number of votes, and the Claimant himself did not receive the seat at the Assembly, while in accordance with the protocols received by the Tenth Claimant from watchers and members of the DEC, the regional office of the SR party at the moment of vote counting in the intracity election territory 22 accounted for 9616 votes (Appendix 17.1 the Summary table for the intracity election territory 22, Appendix 17.2 election results from the website of the MEC, Appendix 17.3 the DECs protocols with the voting results for the Assembly in the intracity election territory 22 (attached are the protocols which were later changed, and wrongful falsification of which was appealed, for the intracity election territory 22 - the DECs protocols 721, 722, 723, 724, 725, 726, 727, 728, 729, 731, 733, 734, 735, 736, 739, 740, 741, 742, 743, 744, 745, 794)). At the time of official announcement of the election results the number of votes cast for the political party from which the Tenth Claimant ran for the election in the territory 22 amounted to 6415 votes.

.

the Source of receiving the Protocols:

being a candidate from the regional office of the SR the Claimant had access to final protocols of the DEC in the territory from which he stood for election. The protocols were given by the watchers present at the polling stations during voting and vote counting, representing the interests of the SR political party.

Ally political parties (regional office of the CP, Yabloko) also gave the Tenth Claimant the DEC protocols at their disposal with election results for the Assembly in the intracity election territory 22

11. The Eleventh Claimant

Gennady B. Truskanov

The right violated to be elected to the Assembly.

Status at the elections of December 4, 2011 a citizen of the Russian Federation, a member of the SR regional office, ran for the position of deputy of the Assembly from the abovementioned faction (see Appendix 18 the List of candidates for deputy at the Assembly of the fifth convocation nominated by the regional office of the SR in respect of the Eleventh Claimant; Appendix 2 Decision of the MEC on registration of the list of candidates for deputy at the Assembly of the fifth convocation nominated by the regional office of the SR) for the intracity election territory 17 (see Appendix 19 Certificate of a candidate for deputy of the Assembly of the fifth convocation).

Nature of the violation in connection with electoral fraud in the abovementioned territory the Eleventh Claimants political party lost a significant number of votes, and the Claimant himself did not receive the seat at the Assembly, while in accordance with the protocols received by the Eleventh Claimant from watchers and members of the DEC, the regional office of the SR party at the moment of vote counting in the intracity election territory 17 accounted for 7539 votes (Appendix 20.1 the Summary table for the intracity election territory 17, Appendix 20.2 election results from the website of the MEC, Appendix 20.3 the DECs protocols with the voting results for the Assembly in the intracity election territory 17 (attached are the protocols which were later changed, and wrongful falsification of which was appealed, for the intracity election territory 17 - the DECs protocols 486, 489, 495, 496, 497, 498, 500, 501, 508, 509)). At the time of official announcement of the election results the number of votes cast for the political party from which the Eleventh Claimant ran for the election in the territory 17 amounted to 5765 votes, while the results of the Edinaya Rossiya increased form the initial 5677 votes to 12,598 votes.

Besides, two polling stations organized at the closed territory of a factory (with the biggest (the unique) overbalance of the ER) were closed for watchers, candidates and the press supervision.

the Source of receiving the Protocols:

being a candidate from the regional office of the SR the Claimant had access to final protocols of the DEC in the territory from which he stood for election. The protocols were given by the watchers present at the polling stations during voting and vote counting, representing the interests of the SR political party.

Ally political parties (regional office of the CP, Yabloko) also gave the Claimant the DEC protocols at their disposal with election results for the Assembly in the intracity election territory 17

12. The Twelfth Claimant

Liudmila V. Pushkareva

The right violated to be elected to the Assembly.

Status at the elections of December 4, 2011 a citizen of the Russian Federation, a member of the SR regional office, ran for the position of deputy of the Assembly from the abovementioned faction (see Appendix 21 the List of candidates for deputy at the Assembly of the fifth convocation nominated by the regional office of the SR in respect of the Twelfth Claimant; Appendix 2 Decision of the MEC on registration of the list of candidates for deputy at the Assembly of the fifth convocation nominated by the regional office of the SR) for the intracity election territory 33 (see Appendix 22 Certificate of a candidate for deputy of the Assembly of the fifth convocation).

Nature of the violation in connection with electoral fraud in the abovementioned territory the Twelfth Claimants political party lost a significant number of votes, and the Claimant herself did not receive the seat at the Assembly, while in accordance with the protocols received by the Twelfth Claimant from watchers and members of the DEC, the regional office of the SR party at the moment of vote counting in the intracity election territory 33 accounted for 9794 votes (Appendix 23.1 the Summary table for the intracity election territory 33, Appendix 23.2 election results from the website of the MEC, Appendix 23.3 the DECs protocols for territory 33 (attached are the protocols which were later changed, and wrongful falsification of which was appealed, for the intracity election territory 33 - the DECs protocols 1070, 1084, 1089, 1090, 1093, 1097, 1098, 1103, 1104, 1107, 1108, 1109, 1111, 1114, 1115, 1116, 1118, 1126, 1127)). At the time of official announcement of the election results the number of votes cast for the political party represented by the Twelfth Claimant in territory 33 amounted to 7131 votes. At this, the results of voting in four polling stations (1071, 1091, 1099, 1113) were repealed in full by the election commission of a higher rank without repeat voting. For this reason on the one hand the voters in the abovementioned polling stations were derived of the right to elect, and the Twelfth Claimant, on the other hand, of the right to be elected by voters at these stations

.

the Source of receiving the Protocols:

being a candidate from the regional office of the SR the Claimant had access to final protocols of the DEC in the territory from which she stood for election. The protocols were given by the watchers present at the polling stations during voting and vote counting, representing the interests of the SR political party.

Ally political parties (regional office of the CP, Yabloko) also gave the Claimant the DEC protocols at their disposal with election results for the Assembly in the intracity election territory 33

13. The Thirteenth Claimant

Sergey S. Shestakov

The right violated to be elected to the legislature of a constituent entity of the Russian Federation, the Legislative Assembly of St.Petersburg (hereinafter the Assembly).

Status at the elections of December 4, 2011 a citizen of the Russian Federation, a member of the SR regional office, ran for the position of deputy of the Assembly from the abovementioned faction (see Appendix 24 the List of candidates for deputy at the Assembly of the fifth convocation nominated by the regional office of the SR in respect of the Thirteenth Claimant; Appendix 2 Decision of the MEC on registration of the list of candidates for deputy at the Assembly of the fifth convocation nominated by the regional office of the SR) for the intracity election territory 15 (see Appendix 25 Certificate of a candidate for deputy of the Assembly of the fifth convocation).

Nature of the violation in connection with electoral fraud in the abovementioned territory and numerous violations recorded by the watchers in the abovementioned territory the Thirteenth Claimants political party lost a significant number of votes, and the Claimant himself did not receive the seat at the Assembly, while in accordance with the protocols received by the Thirteenth Claimant from watchers and members of the DEC, the regional office of the SR party at the moment of vote counting in the intracity election territory 15 accounted for 6629 votes (Appendix 26.1 the Summary table for the intracity election territory 15, Appendix 26.2 election results from the website of the MEC, Appendix 26.3 the DECs protocols for territory 15 (attached are the protocols which were later changed, and wrongful falsification of which was appealed, for the intracity election territory 15 - the DECs protocols 554, 555, 557, 592, 593, 597, 598, 600, 601, 605, 606, 610, 611)). At the time of official announcement of the election results the number of votes cast for the political party represented by the Thirteenth Claimant in territory 15 amounted to 3894 votes. At this, the number of claims for violations in the course of voting and counting in the territory is so large scale that even the information of original (primary) protocols was falsified as early as at the voting stage (Appendix 26.3 the DECs Protocols 549, 552, 553, 554, 555, 556, 558, 592, 594, 598, 601, 605, 606, 607, 608, 611 with the claims attached).

the Source of receiving the Protocols:

being a candidate from the regional office of the SR the Claimant had access to final protocols of the DEC in the territory from which he stood for election. The protocols were given by the watchers present at the polling stations during voting and vote counting, representing the interests of the SR political party.

Ally political parties (regional office of the CP, Yabloko) also gave the Claimant the DEC protocols at their disposal with election results for the Assembly in the intracity election territory 15

II. Explanations concerning art. D) of the Court request

1. Information concerning combined claims of the first six Claimants with the aim to exhaust internal remedies:

1.1 On December 12, 2011 the Claimants filed a claim with the Supreme Court of the Russian Federation to repeal the decision of the Central Election Commission of the Russian Federation on the result of elections to the State Duma of the Federal Assembly of the Russian Federation of the sixth convocation, on the basis of electoral fraud which did not allow to determine the real will of the voting citizens of Russia, thus violating the electoral rights of the Claimants (Appendix 27).

1.2. On December 23, 2011 the judge of the RF Supreme Court ruled to dismiss the claim to repeal the decision of the Central Election Commission of the Russian Federation on the result of elections to the State Duma of the Federal Assembly of the Russian Federation of the sixth convocation, stating that the violations the Claimants indicate (falsification of the voting results after the result was determined by authorized district election commissions) do not violate the rights of citizens of the Russian Federation (Appendix 28).

1.3. On January 24, 2012 the Claimants filed a special appeal with the Supreme Court from the Order of the Supreme Court dated December 23, 2011 (Appendix 29).

1.4 On February 9, 2012 the Supreme Court Board of Appeals ruled to dismiss the special appeal of the Claimants and affirm the Order of the Supreme Court dated December 23, 2011 (Appendix 30).

1.5. On December 12, 2011 the Claimants filed a claim with the City Court of St.Petersburg to repeal the decision of the Central Election Commission of the Russian Federation on the result of elections to the legislative Assembly of St.Petersburg, on the result of elections to the State Duma of the Federal Assembly of the Russian Federation of the sixth convocation, on the basis of electoral fraud which did not allow to determine the real will of the voting citizens of Russia, thus violating the electoral rights of the Claimants (Appendix 31).

1.6. In its Order dated December 23, 2011 the City Court of St.Petersburg dismissed the claim with regard to ruling electoral fraud illegal and violating the Claimants rights, and set it aside with regard to repealing the decision of the Municipal Election Commission (Appendix 32).

1.7. On December 30, 2011 the Claimants filed a special appeal with the Court in respect of dismissing the claim (Appendix 33).

1.8. In the Order dated February 22, 2012 Supreme Court affirmed the Order of the City Court of St.Petersburg dated December 23, 2011 with regard to the section under appeal (dismissing the claim), and dismissed the special appeal. The ruling was not sent to the Claimants, they became familiar with the results of considering their special appeal on the Supreme Court website (http://www.vsrf.ru/moving_case.php?findByNember=78-%C312-3).

1.9. On January 11, 2012 the Claimants filed a revised claim with the court, having fulfilled the demands of the court stipulated in its Order dated December 23, 2011 with regard to setting the claim aside (Appendix 34).

1.10. On January 12, 2012 the judge of the City Court of St.Petersburg ruled to dismiss the claim on the grounds that the issue raised by the Claimants is not in the competence of a federal court, but of a district court, as the Claimants were appealing the actions of territorial election commissions (Appendix 35). A similar ruling was issued on January 13, 2012 (Appendix 36).

1.11. On January 20, 2012 the Claimants filed a special appeal with the City Court of St.Petersburg for the rulings as of January 12 and 13, 2012, with the reason that they supposed that appealing the election results for the Legislative Assembly of St.Petersburg and actions of the MEC are in the competence of a federal court (Appendix 37 in the copy provided the names of the Second and Third Claimants are written off. However, the abovementioned persons also filed a similar special appeal for the rulings as of January 12 and 13, 2012, which can be seen from the court ruling in respect of the abovementioned special appeal).

1.12. On February 7, 2012 the City Court of St.Petersburg ruled to affirm the Order of the City Court of St.Petersburg dated January 13, 2012 and to dismiss the special appeal of the Claimants (Appendix 38).

2. Steps taken by the Second Claimant.

2.1. On December 5, 2011 the Second Claimant filed an application to the Chief Investigatory Directorate of the Investigative Committee of the RF in St.Petersburg (hereinafter the CID) stating that the election commission of St.Petersburg committed a wrongdoing impeding performance of electoral rights of citizens by way of falsifying election results and election documents (Appendix 39).

2.2. On December 12, 2011 the CID sent the application of the Second Claimant to the Prosecutors office in St.Petersburg, suggesting that in case the Prosecutors office finds elements of offence it shall send the materials back to the CID (Appendix 40).

2.3. At the Prosecutors office in St.Petersburg the Second Claimant was told that her application was sent to the Prosecutors office in the Kolpinsky district of St.Petersburg, where it was received on December 28, 2011 (the Second Claimant did not receive any documents proving this fact).

2.4. On December 5, 2011 (prior to final establishment of election results by the MEC of St.Petersburg) the Second Claimant filed an application with the MEC of St.Petersburg in respect of major violations in establishing the election result which prove falsification of results and election documents, which violated her electoral right (Appendix 41). Similar applications were filed by the Second Claimant on December 5, 2011 prior to 6 p.m. to the CID and the Prosecutors office in St.Petersburg.

2.5. On December 9, 2011 respective applications of the Second Claimant was sent by the MEC to the Prosecutors office of the Kolpinsky district of St.Petersburg (Appendix 42), and was received on December 28, 2011.

2.6. On February 14, 2012 the Prosecutors office of the Kolpinsky district of St.Petersburg sent a notice to the Second Claimant that after consideration of her applications by the DEC and the CID dated December 5, 2012 no violation of the current legislation was found, in which respect there are no grounds for the prosecutors reaction (Appendix 43).

3. Steps taken by the Third and Fourth Claimants:

3.1. On December 6, 2011 (prior to establishing the results of election by the MEC of St.Petersburg) the Third and Fourth Claimants filed an application with the MEC of St.Petersburg in respect of major violations in establishing the election result which prove falsification of results and election documents, which violated their electoral rights (Appendices 44 and 45).

3.2. On December 8, 2011 respective applications of the Third and Fourth Claimants were sent by the MEC to the Prosecutors office of the Kolpinsky district of St.Petersburg (Appendices 46 and 47).

3.3. On December 15, 2011 the Prosecutors office of the Kolpinsky district of St.Petersburg sent the application of the Third Claimant to the Investigative Department of the Chief Investigatory Directorate of Russian Investigative Committee in the Kolpinsky district of St.Petersburg (hereinafter the ID CID in the Kolpinsky district) (Appendix 48). Supposedly at the same time the Fourth Claimants application was redirected in the same way.

3.4. On December 19, 2011 after establishing the results of election by the MEC of St.Petersburg the ID CID in the Kolpinsky district, stating that in essence the Third Claimants application reduces itself to violations in vote counting, sent the application back to the MEC, which had earlier sent this application to the Prosecutors office of the Kolpinsky district of St.Petersburg on December 8, 2011 (see art.4.2.) (Appendix 49).

3.5. On December 28, 2011 the DEC notified the third Claimant in a letter that after determining the voting results the decision on election results can be repealed only by court (Appendix 49.1) Thus, redirecting the application from one authority to the other over the course of almost two weeks gave the MEC the opportunity not to check whether the election results were falsified. Supposedly the Fourth Claimants application shared the same fate. Yet the Fourth Claimant does not have final answer to her application.

3.6. On February 2, 2012 the Fourth Claimant, and on February 8, 2012 the Third Claimant appealed to the Oktiabrsky district court for non-consideration of the MEC of the essence of their applications dated December 6, 2011 and determination of results of parliamentary elections by the MEC without consideration the essence of their applications (Appendices 50 and 51).

3.7. On February 9 and 15, 2012 the Oktiabrsky district court dismissed the Fourth and the Third Claimants appeals, respectively (Appendices 52 and 53).

3.8. On February 27, 2012 the Fourth Claimant filed an appeal with St.Petersburg City Court (via the Oktiabrsky district court) for the ruling the Oktiabrsky district court dated February 9, 2012 (Appendix 54). In connection with delaying the term of preparation of a motivated ruling in respect of the Third Claimant claim only on March 5, 2012 he filed a special claim to the ruling the Oktiabrsky district court dated February15, 2012 (Appendix 55).

3.9. On April 16, 2012 St.Petersburg City Court Civil division affirmed the ruling the Oktiabrsky district court dated February15, 2012 and dismissed the Third Claimants appeal (Appendix 56). On May 10, 2012 St.Petersburg City Court Civil division affirmed the ruling the Oktiabrsky district court dated February 9, 2012 and dismissed the Fourth Claimants appeal (Appendix 57).

3.10. On December 6, 2011 the Third and Fourth Claimants filed an application to the CID stating that the election commission of St.Petersburg committed a wrongdoing impeding performance of electoral rights of citizens by way of falsifying election results and election documents (Appendices 58 and 59).

3.11. On December 12, 2011 the CID sent the application of the Third Claimant to the Prosecutors office in St.Petersburg, suggesting that in case the Prosecutors office finds elements of offence it shall send the materials back to the CID (Appendix 60). Supposedly at the same time with directing the Third Claimants application to the Prosecutors office in St.Petersburg the application of the Fourth Claimant was similarly directed as well, of which she was not notified in writing and of which she can only judge on the basis of the result of transferring her application.

3.12. On December 26, 2011 the Prosecutors office in St.Petersburg sent the Third Claimants application (and similar o the paragraph above, the Fourth Claimants application as well, judging by results) to the Prosecutors office in the Kolpinsky district of St.Petersburg (Appendix 61), where it (they) was (were) received on January 10, 2012. The Fourth Claimant learnt that her application had been received by the Prosecutors office in the Kolpinsky district of St.Petersburg also on January 10, 2012 having contacted the abovementioned Office by telephone.

3.13. On February 14, 2012 the Prosecutors office of the Kolpinsky district of St.Petersburg sent a notice to the Third Claimant that after consideration of his applications by the CID as of December 6, 2012 no violation of the current legislation was found, in which respect there are no grounds for the prosecutors reaction (Appendix 62).

3.14. On February 14, 2012 the Prosecutors office of the Kolpinsky district of St.Petersburg sent a notice to the Fourth Claimant that an inspection is carried out in respect the facts indicated in her application to the ID CID in the Kolpinsky district of St.Petersburg (Appendix 63).

3.15. On January 18, 2012 the ID CID in the Kolpinsky district of St.Petersburg dismissed the Fourth Claimant's criminal complaint under art.142.1 of the Criminal Code of the RF in connection with absence of criminal act (Appendix 64).

3.16. Supposedly, the ruling as of January 18, 2012 was later repealed as illegal and invalid, as on February 21, 2012 the ID CID in the Kolpinsky district of St.Petersburg again ruled to dismiss the Fourth Claimant's criminal complaint under art.142.1 of the Criminal Code of the RF in connection with absence of criminal act (Appendix 65).

The Fourth Claimant supposed that there were several other similar rulings later recognized as illegal and invalid. The Fourth Claimant has no information concerning the final decision on the issue.

It shall be noted that the applications of the Third and Fourth Claimants were identical with the only difference in the numbers of polling stations. Nevertheless, the same authority reacted differently.

3.17. On February 8, 2012 the Third Claimant filed a claim with the Oktiabrsky District Court of St.Petersburg concerning failure to act on the part of the Investigation Committee of St.Petersburg concerning his criminal complaint in respect of electoral fraud dated December 6, 2011 (Appendix 118) (for details of the Third Claimant filing his claim with the Investigation Committee see art3.10 of the Response as of April 3, 2013).

3.18. On April 18, 2012 the Oktiabrsky District Court of St.Petersburg satisfied the claim of the Third Claimant, ruled illegal the failure to act on the part of the Investigation Committee and demanded that the latter remedy the breach (Appendix 119);

3.19. The Investigation Committee did not agree with the court ruling. However, on July 11, 2012 the penal chamber of the City Court of St.Petersburg as a result of the examination of the cassation brought into by the senior assistant of the prosecutor of Admiralteisky district of St.Petersburg and the cassation appeal brought into by the Head of the Chief Investigatory Directorate of the Investigation Committee of Russia in St.Petersburg in respect of the ruling of the Oktiabrsky District Court of St.Petersburg dated April 18, 2012 ruled to affirm the abovementioned ruling of the Oktiabrsky District Court of St.Petersburg, and to dismiss the cassation appeal (Appendix 120);

3.20. The Third Claimant so far has no information concerning actions taken by the investigating authorities to enforce the court ruling.

4. The Steps taken by the Eighth Claimant:

4.1. On December 11, 2011 (prior to establishing the results of election by the MEC of St.Petersburg) the Eighth Claimant filed an application with the ID CID in the Kolpinsky district of St.Petersburg with the claim that TEC 21 committed wrongdoings under art. 142 and 142.1. of the Criminal Code of the Russian Federation, i.e. falsification of election documents and voting results (Appendix 66).

4.2. On December 19, 2011 the application of wrongdoing was directed to the MEC with reference that the Eighth Claimant points to a wrongdoing in the course of vote counting (Appendix 67).

4.3. On December 30, 2011 the MEC notified the Eighth Claimant that after the election results were established by a higher level commission, the decision of a lower level commission on election results can be repealed only by court (Appendix 68).

4.4. The Eighth Claimant filed a claim with the Kolpinsky district court of St.Petersburg on unlawfulness of directing his application of wrongdoing by the ID CID in the Kolpinsky district of St.Petersburg on December 19, 2011 to the MEC (Appendix 69).

4.5. The Kolpinsky district court of St.Petersburg in its decision dated January 10, 2012 granted the application in part of the Eighth Claimant and ruled illegal the act of directing the application of wrongdoing to the MEC (Appendix 70). However, the court ruling of unlawfulness of actions of the ID CID in the Kolpinsky district of St.Petersburg at that stage could not help restore the Eighth Claimants violated rights.

4.6. On January 20, 2012 the Eighth Claimant appealed the violation of his right to elect to the legislature of a constituent entity of the RF in the City Court of St.Petersburg (Appendix 71).

4.7. On January 25, 2012 the City Court of St.Petersburg abandoned the Eighth Claimants appeal with the reason a number of defects which did not allow to the court to consider the case (Appendix 72).

4.8. On February 3, 2012 the Eighth Claimant filed with the City Court of St.Petersburg a revised appeal to perform the requirements of the court indicated in the decision of the City Court of St.Petersburg dated January 25, 2012 on abandoning the abovementioned claim of the Eighth Claimant (Appendix 73).

4.9. On February 9, 2012 the City Court of St.Petersburg ruled to return the appeal to the Eighth Claimant (Appendix 74).

4.10. On February 22, 2012 the Eighth Claimant filed with the City Court of St.Petersburg a special appeal to the Ruling of the City Court of St.Petersburg dated February 9, 2012 (Appendix 75).

4.11. On March 5, 2012 the City Court of St.Petersburg affirmed the Ruling of the City Court of St.Petersburg dated February 9, 2012 and dismissed the Eighth Claimants appeal (Appendix 76).

4.12. On January 25, 2012 Eighth Claimant filed a claim with the Kolpinsky district court to the violation by the Territorial Election Commission 21 his right to elect to the legislature of a constituent entity of the RF (Appendix 77).

4.13. On January 27, 2012 the Kolpinsky district court abandoned the Eighth Claimants claim demanding to eliminate a number of defects (Appendix 78).

4.14. On February 7, 2012 the Claimant filed the revised claim with the Kolpinsky district court (Appendix 79).

4.15. On March 1, 2012 the Kolpinsky district court closed the case ruling that wrong establishment of election results in the form of factual falsification of voting results does not violate citizens electoral right, in particular, the Eighth Claimants rights (Appendix 80).

4.16. The Eighth Claimant filed a special claim with the City Court of St.Petersburg to the ruling of the Kolpinsky district court to close the case dated March 1, 2012 (Appendix 81).

4.17. On April 12, 2012 the City Court of St.Petersburg ruled to repeal the ruling of the Kolpinsky district court to close the case dated March 1, 2012, and remand the case to examine the merits. At this the City Court did not support the conclusion of the Kolpinsky district court that falsification of elections does not concern the citizens right to elect (Appendix 82).

It shall be noted that in this ruling the City Court of St.Petersburg comes into direct collision with the position of the Supreme Court of the RF as stated in its Ruling as of December 23, 2012 in respect of the claim of the first six Claimants, as the latter as well as the Kolpinsky district court of St.Petersburg considered that active electoral right of citizens is not be violated in case of falsification of election results.

4.18. On May 24, 2012 the Kolpinsky district court dismissed the Eighth Claimants claim (Appendix 83). At this the court examined in a court session DEC protocol 637, but denied o the Eighth Claimant to summon any persons to certify authenticity of the protocol and circumstances of its receiving by the Eighth Claimant, i.e. the CP regional office watcher who gave the document to the Claimant, members of DEC 637 able to certify authenticity of the information stated in the protocol, etc.

4.19. The Claimant appealed in the City Court of St.Petersburg the ruling of the Kolpinsky district court dated May 24, 2012 (Appendix 84).

4.20. On August 16, 2012 the penal chamber of the City Court of St.Petersburg passed the Appellate ruling to affirm the ruling of the Kolpinsky district court dated May 24, 2012 and to dismiss the Eighth Claimants appeal (Appendix 85).

5. Steps taken by the Ninth Claimant:

5.1. On December 14, 2011 the Ninth Claimant filed an application with the Kolpinsky district court of St.Petersburg to repeal the election results with the reason that voting results (including the polling station where he voted) were falsified, which resulted in violation of his right to elect (Appendix 86).

5.2. On December 19, 2011 the Kolpinsky district court dismissed the application of the Ninth Claimant on the grounds that the issue of contesting results of election to legislative authorities of a constituent entity of the RF is not under the jurisdiction of a district court but under the jurisdiction of the court of a constituent entity of the RF, i.e. the City Court of St.Petersburg in the case of contesting the election results to the Assembly (Appendix 87).

5.3. On December 28, 2011 the Ninth Claimant filed an application with the City Court of St.Petersburg to repeal the election results with the reason that voting results (including the polling station where he voted) were falsified, which resulted in violation of his right to elect (Appendix 88). The ruling of the Kolpinsky district court stating the lack of jurisdiction of the district court over the issue raised was attached thereto.

5.4. On December 29, 2011 the Judge of the City Court of St.Petersburg dismissed the application of the Ninth Claimant on the grounds that the issue raised is not under the jurisdiction of a federal court. It was suggested by court that the Ninth Claimant shall apply to the Kolpinsky district court (Appendix 89).

5.5. On January 16, 2012 the Ninth Claimant filed a special claim with the court to the ruling dated December 29, 2011 (Appendix 90). In the special claim the Ninth Claimant stated inadmissibility of disputes concerning jurisdiction.

5.6. On January 26, 2012 the City Court of St.Petersburg dismissed the special claim of the Ninth Claimant and affirmed the ruling as of December 29, 2012 (Appendix 91).

5.7. On January 19, 2012 the Ninth Claimant again filed an application with the Kolpinsky district court to repeal the election results (Appendix 92).

5.8. On January 20, 2012 the Kolpinsky district court abandoned the Eighth Claimants claim demanding to eliminate a number of defects (Appendix 93).

5.9. On February 15, 2012 the Claimant filed the revised claim with the Kolpinsky district court (Appendix 94) along with a number of documents the court requested.

5.10. On July 16, 2012 the Kolpinsky district court dismissed the Ninth Claimants claim (Appendix 95).

5.11. On August 15, 2012 the Ninth Claimant filed an appeal with the City Court of St.Petersburg to the ruling of the Kolpinsky district court dated July 16, 2012 (Appendix 96).

5.12. On October 18, 2012 the penal chamber passed the appellate ruling to affirm the ruling of the Kolpinsky district court dated July 16, 2012 and to dismiss the Ninth Claimants appeal (Appendix 97).

6. Steps taken by the Tenth, Eleventh, Twelfth and Thirteenth Claimants.

6.1. The SR regional office filed an application with the City Court of St.Petersburg to repeal the election results, including in territories 22, 17, 33 and 15, where the Tenth, Eleventh, Twelfth and Thirteenth Claimants, respectively, represented the party (Appendix 98).

6.2. On February 27, 2012 the City Court of St.Petersburg dismissed the application of the SR regional office (Appendix 99).

6.3. The SR regional office appealed in the Supreme Court of the RF the ruling of the City Court of St.Petersburg dated February 27, 2012 in respect of dismissing the application (Appendix 100).

6.4. On May 23, 2012 the Supreme Court of the RF affirmed the ruling of the City Court of St.Petersburg dated February 27, 2012, and dismissed the appeal of the SR regional office (Appendix 101).

6.5. On April 11, 2012 the SR regional office filed a claim with the Kirovsky district court of St.Petersburg to the actions of TEC 3 and the MEC in respect of violation of two temporary polling stations in the territory from which the Eleventh Claimant stood (Appendix 102).

6.6. On August 16, 2012 the Kirovsky district court of St.Petersburg dismissed in full the claim of the SR regional office (Appendix 103).

6.7. On September 14, 2012 the SR regional office appealed the ruling of the Kirovsky district court of St.Petersburg dated August 16, 2012 (Appendix 104).

6.8. On October 17, 2012 the City Court of St.Petersburg passed the appellate ruling to affirm the ruling of the Kirovsky district court of St.Petersburg dated August 16, 2012 and to dismiss the appeal of the SR regional office (Appendix 105).

7. Application of the first Six Claimants and the Eighth claimant to the Constitutional Court of the RF.

7.1. After the first six Claimants made themselves familiar with the position of the Supreme Court of the RF in the Ruling dated December 23, 2011 (Appendix 28), in accordance with which a elector does not have a right to appeal election results, as they do not concern his electoral rights, the Claimants filed an application with the Constitutional Court of the RF stating that a number of regulatory enactments of the Russian Federation (sections 1 art.259 of the Civil Procedure Code of the RF, sections 2 and 3 art.77 of the Federal Law as of June 12, 2002 N 67- On Basic Guarantees of electoral rights and right to participate in referendums for citizens of the Russian Federation, and sections 4 and 5 art.92 of the Federal Law as of May 18, 2005 N 51- On election of deputies of the State Duma of the Federal Assembly of the Russian Federation)contravenes the Constitution of the Russian Federation, which acts could be interpreted as such by the Supreme Court of the RF and a number of lower instance courts (Appendix 106).

7.2. In response to the issues raised by the Constitutional Court of the RF in the course of preparation to the proceedings there were presented the responses of the Supreme Court of the RF (Appendix 107), General Prosecutors Office of the RF (Appendix 108), the State Duma of the Federal Assembly of the RF (Appendix 109), the Council of Federation of the Federal Assembly of the RF (Appendix 110) and the CEC of the RF (Appendix 111), Ministry of Justice of the RF (Appendix 112).

Furthermore, the court was presented with expert opinions of legal scholars: Chairman of the Department for constitutional and international law at the Federal State Budget Educational Institution of Higher Professional Education Altai State University V.V.Nevinsky and assistant professor of the abovementioned department, candidate of legal sciences A.V.Dolzhikov (Appendix 113), experts of the Department of constitutional and international law of the Saratov State Academy of Law (Appendix 114), Human Rights Commissioner of the RF (Appendix 115), experts of the Institute of Legislation and Comparative Law affiliated to the Government of the RF (Appendix 116).

Dramatic difference in the opinions of the sides in this argument is highly demonstrative. According to the Claimants opinion, this difference highlights the real attitude of the sate to its commitment provided in art.3 Protocol 1 to the Convention and art. 13 of the Convention.

On March 14, 2013 open hearings were held involving representatives of government bodies and the side of the Claimants. Until now the declaration has not been proclaimed.

III. List of Appendices

Appendix 1 List of candidates for deputy at the Assembly of the fifth convocation nominated by the regional office of the SR in respect of A.V.Davydov;

Appendix 2 - Decision of the Municipal Election Committee of St.Petersburg on registration of the list of candidates for deputy at the Assembly of the fifth convocation nominated by the regional office of the SR;

Appendix 3 Certificate of a candidate for deputy of the Assembly of the fifth convocation A.V.Davydov;

Appendix 4.1 Summary table with the information of the initial and total numbers of votes, and separate and aggregate number of electoral votes taken from specific political parties and their transfer to other parties (fraud) in the intracity election territory 19;

Appendix 4.2 Election results from the website of the MEC for the intracity election territory 19;

Appendix 4.3 DECs protocols with the voting results for the Assembly in the intracity election territory 19 (here and elsewhere attached are the protocols which were later changed in the intracity election territory 19; the protocols in which no changes were entered are not submitted to the Court);

Appendix 5 abstract from the regulatory enactments on the rights of watchers and members of election commissions;

Appendix 6 Statement of O.O.Andronova of registering for voting at polling station 652 of the Kolpinsky district of St.Petersburg;

Appendix 7 Certificate of a member of the election commission of polling station 652 - O.O.Andronova;

Appendix 8 Decision of the Meeting of the SR regional office as of 26.10.11 on candidates to the DEC;

Appendix 9 Statement of A.V.Andronov of registering for voting at polling station 651 of the Kolpinsky district of St.Petersburg;

Appendix 10 Certificate of a member of the election commission of polling station 651 A.V.Andronov;

Appendix 11 Statement of T.A.Nikolayeva of registering for voting at polling station 654 of the Kolpinsky district of St.Petersburg;

Appendix 12 Certificate of a member of the election commission of polling station 654 - T.A.Nikolayeva;

Appendix 13 - Certificate of a member of the election commission of polling station 661 E.P.Sizionov;

Appendix 14.1 Summary table with the information of the initial and total numbers of votes, and separate and aggregate number of electoral votes taken from specific political parties and their transfer to other parties (fraud) in polling stations 637 and 623;

Appendix 14.2 Election results from the website of the MEC polling stations 637 and 623;

Appendix 14.3 DEC protocol on the election results for the Assembly at polling station 637;

Appendix 15 List of candidates for deputy at the Assembly of the fifth convocation nominated by the regional office of the SR in respect of N.L.Payalin;

Appendix 16 Certificate of a candidate for deputy of the Assembly of the fifth convocation - N.L.Payalin;

Appendix 17.1 Summary table with the information of the initial and total numbers of votes, and separate and aggregate number of electoral votes taken from specific political parties and their transfer to other parties (fraud) in polling stations in the intracity election territory 22;

Appendix 17.2 Election results from the website of the MEC;

Appendix 17.3 DECs protocols with the voting results for the Assembly in the intracity election territory 22;

Appendix 18 List of candidates for deputy at the Assembly of the fifth convocation nominated by the regional office of the SR in respect of G.B.Truskanov;

Appendix 19 Certificate of a candidate for deputy of the Assembly of the fifth convocation G.B.Truskanov;

Appendix 20.1 Summary table with the initial and total numbers of votes for the intracity election territory 17;

Appendix 20.2 Election results from the website of the MEC;

Appendix 20.3 DECs protocols with the voting results for the Assembly in the intracity election territory 17;

Appendix 21 List of candidates for deputy at the Assembly of the fifth convocation nominated by the regional office of the SR in respect of L.V.Pushkareva;

Appendix 22 Certificate of a candidate for deputy of the Assembly of the fifth convocation - L.V.Pushkareva;

Appendix 23.1 Summary table for the intracity election territory 33;

Appendix 23.2 election results from the website of the MEC;

Appendix 23.3 DECs protocols for territory 33;

Appendix 24 List of candidates for deputy at the Assembly of the fifth convocation nominated by the regional office of the SR in respect of S.S.Shestakov;

Appendix 25 Certificate of a candidate for deputy of the Assembly of the fifth convocation - S.S.Shestakov;

Appendix 26.1 Summary table for the intracity election territory 15;

Appendix 26.2 election results from the website of the MEC in the intracity election territory 15;

Appendix 26.3 DECs protocols for territory 15;

Appendix 27 Application of A.V.Davydov, O.O.Andronova, A.V.Andronov, T.A.Nikolayeva, A.G.Nikolayeva, E.P.Sizionov with the Supreme Court of the Russian Federation of December 12, 2011 to repeal the decision of the Central Election Commission of the Russian Federation on the result of elections to the State Duma of the Federal Assembly of the Russian Federation of the sixth convocation on the basis of electoral fraud;

Appendix 28 Order of the Supreme Court dated December 23, 2011;

Appendix 29 Special claim of A.V.Davydov, O.O.Andronova, A.V.Andronov, T.A.Nikolayeva, A.G.Nikolayeva, E.P.Sizionov with the Supreme Court of the Russian Federation of January 24, 2012 to the Order of the Supreme Court dated December 23, 2011

Appendix 30 Ruling of the Supreme Court Board of Appeals as of February 9, 2012;

Appendix 31 Application of A.V.Davydov, O.O.Andronova, A.V.Andronov, T.A.Nikolayeva, A.G.Nikolayeva, E.P.Sizionov of December 12, 2011 to the City Court of St.Petersburg to repeal the decision of the Central Election Commission of the Russian Federation on the result of elections to the legislative Assembly of St.Petersburg, on the result of elections to the State Duma of the Federal Assembly of the Russian Federation of the sixth convocation, on the basis of electoral fraud;

Appendix 32 Order of the City Court of St.Petersburg dated December 23, 2011 to dismiss the claim of A.V.Davydov, O.O.Andronova, A.V.Andronov, T.A.Nikolayeva, A.G.Nikolayeva, E.P.Sizionov in part;

Appendix 33 Special claim of A.V.Davydov, O.O.Andronova, A.V.Andronov, T.A.Nikolayeva, A.G.Nikolayeva, E.P.Sizionov dated December 30, 2011 to the Order of the City Court of St.Petersburg dated December 23, 2011 to dismiss the claim of A.V.Davydov, O.O.Andronova, A.V.Andronov, T.A.Nikolayeva, A.G.Nikolayeva, E.P.Sizionov in part;

Appendix 34 Revised claim by A.V.Davydov, O.O.Andronova, A.V.Andronov, T.A.Nikolayeva, A.G.Nikolayeva, E.P.Sizionov dated January 11, 2012;

Appendix 35 Order of the City Court of St.Petersburg dated January 12, 2012 to dismiss the claim of A.V.Davydov, O.O.Andronova, A.V.Andronov, T.A.Nikolayeva, A.G.Nikolayeva, E.P.Sizionov;

Appendix 36 Order of the City Court of St.Petersburg dated January 13, 2012 to dismiss the claim of A.V.Davydov, O.O.Andronova, A.V.Andronov, T.A.Nikolayeva, A.G.Nikolayeva, E.P.Sizionov;

Appendix 37 Special claim of A.V.Davydov, O.O.Andronova, A.V.Andronov, T.A.Nikolayeva, A.G.Nikolayeva, E.P.Sizionov with the City Court of St.Petersburg dated January 20, 2012 to the Orders of January 12 and 13, 2012;

Appendix 38 Order of the City Court of St.Petersburg dated February 7, 2012;

Appendix 39 Claim of O.O.Andronova dated December 5, 2011 to the CID on committing a wrongdoing by the MEC;

Appendix 40 Notice by the CID to O.O.Andronova that her claim was redirected to the Prosecutors office in St.Petersburg on December 12, 2011;

Appendix 41 Application of O.O.Andronova to the MEC on violations in establishing the election results dated December 5, 2011;

Appendix 42 Notice by the MEC to O.O.Andronova that her claim was redirected on December 9, 2011 to the Prosecutors office of the Kolpinsky district of St.Petersburg;

Appendix 43 Notice by the Prosecutors office of the Kolpinsky district of St.Petersburg dated February 14, 2012 on the absence of grounds for the prosecutors reaction;

Appendix 44 Application of A.V.Andronov to the MEC dated December 6, 2011

Appendix 45 Application of T.A.Nikolayeva to the MEC dated December 6, 2011

Appendix 46 Notice by the MEC to A.V.Andronov that his claim was redirected on December 8, 2011 to the Prosecutors office of the Kolpinsky district of St.Petersburg;

Appendix 47 - Notice by the MEC to T.A.Nikolayeva that her claim was redirected on December 8, 2011 to the Prosecutors office of the Kolpinsky district of St.Petersburg;

Appendix 48 Notice by the Prosecutors office of the Kolpinsky district of St.Petersburg to A.V.Andronov that his claim was redirected on December 15, 2011 to the ID CID in the Kolpinsky district;

Appendix 49 - Notice by the ID CID in the Kolpinsky district to A.V.Andronov that his claim was redirected on December 19, 2011 to the MEC;

Appendix 49.1 Response of the MEC dated December 28, 2011 to the claim of A.V.Andronov dated December 6, 2011;

Appendix 50 Appeal of A.V.Andronov to the Oktiabrsky district court dated February 8, 2012 to nonfeasance of the MEC;

Appendix 51 - Appeal of T.A.Nikolayeva to the Oktiabrsky district court dated February 2, 2012 to nonfeasance of the MEC;

Appendix 52 Ruling of the Oktiabrsky district court dated February 9, 2012;

Appendix 53 - Ruling of the Oktiabrsky district court dated February 15, 2012;

Appendix 54 Appeal of T.A.Nikolayeva dated February 27, 2012 to the Ruling of the Oktiabrsky district court dated February 9, 2012;

Appendix 55 Appeal of A.V.Andronov dated March 5, 2012 to the Ruling of the Oktiabrsky district court dated February 15, 2012;

Appendix 56 Ruling of the St.Petersburg City Court Civil division dated April 16, 2012 in respect of the appeal by A.V.Andronov;

Appendix 57 - Ruling of the St.Petersburg City Court Civil division dated May 10, 2012 in respect of the appeal by T.A.Nikolayeva;

Appendix 58 Application of A.V.Andronov dated December 6, 2011 to the CID on committing a wrongdoing by the MEC;

Appendix 59 Application of T.A.Nikolayeva dated December 6, 2011 to the CID on committing a wrongdoing by the MEC;

Appendix 60 Notice by the CID to A.V.Andronov dated December 12, 2011 that his claim was redirected to the Prosecutors office in St.Petersburg;

Appendix 61 - Notice by the Prosecutors office in St.Petersburg to A.V.Andronov dated December 27, 2011 that his claim was redirected to the Prosecutors office of the Kolpinsky district of St.Petersburg;

Appendix 62 Notice of the Prosecutors office of the Kolpinsky district of St.Petersburg dated February 14, 2012 to A.V.Andronov;

Appendix 63 - Notice of the Prosecutors office of the Kolpinsky district of St.Petersburg dated February 14, 2012 to T.A.Nikolayeva;

Appendix 64 Order of the ID CID in the Kolpinsky district of St.Petersburg dated January 18, 2012 to dismiss the claim;

Appendix 65 - Order of the ID CID in the Kolpinsky district of St.Petersburg dated February 21, 2012 to dismiss the claim;

Appendix 66 Application of V.G.Beliakov to the ID CID in the Kolpinsky district of St.Petersburg dated December 11, 2011 on committing by TEC 21 of wrongdoings under art. 142 and 142.1. of the Criminal Code of the Russian Federation;

Appendix 67 Notice by the ID CID in the Kolpinsky district of St.Petersburg dated December 19, 2011 to V.G.Beliakov that his claim was redirected to the MEC

Appendix 68 - Response of the MEC dated December 28, 2011 to the claim of V.G.Beliakov dated December 30, 2011;

Appendix 69 Appeal of V.G.Beliakov to the Kolpinsky district court of St.Petersburg dated December 19, 2011 to nonfeasance of the ID CID in the Kolpinsky district of St.Petersburg

Appendix 70 Ruling of the Kolpinsky district court of St.Petersburg dated January 10, 2012;

Appendix 71 Appeal of V.G.Beliakov to the City Court of St.Petersburg dated January 20, 2012;

Appendix 72 Order of the City Court of St.Petersburg dated January 25, 2012 to dismiss the claim of V.G.Beliakov;

Appendix 73 Revised claim of V.G.Beliakov to the City Court of St.Petersburg dated February 3, 2012

Appendix 74 - Order of the City Court of St.Petersburg dated February 9, 2012 to dismiss the claim of V.G.Beliakov

Appendix 75 Special claim of V.G.Beliakov to the City Court of St.Petersburg dated February 22, 2012 to the Order of the City Court of St.Petersburg dated February 9, 2012

Appendix 76 Order of the City Court of St.Petersburg dated March 5, 2012;

Appendix 77 Claim of V.G.Beliakov to the Kolpinsky district court of St.Petersburg dated January 25, 2012;

Appendix 78 Order of the Kolpinsky district court of St.Petersburg to dismiss the claim of V.G.Beliakov dated January 27, 2012; page 1, page 2

Appendix 79 Revised claim of V.G.Beliakov to the Kolpinsky district court of St.Petersburg dated February 7, 2012;

Appendix 80 Order of the Kolpinsky district court of St.Petersburg dated March 1, 2012;

Appendix 81 Special claim of V.G.Beliakov to the Order of the Kolpinsky district court of St.Petersburg dated March 1, 2012;

Appendix 82 Order of the City Court of St.Petersburg dated April 12, 2012 to repeal the ruling of the Kolpinsky district court of St.Petersburg dated March 1, 2012 and remand the case to the Kolpinsky district court of St.Petersburg to examine the merits;

Appendix 83 Ruling of the Kolpinsky district court of St.Petersburg dated May 24, 2012;

Appendix 84 Appeal of V.G.Beliakov to the Ruling of the Kolpinsky district court of St.Petersburg dated May 24, 2012;

Appendix 85 Appellate ruling of the City Court of St.Petersburg dated August 16, 2012 to affirm the Ruling of the Kolpinsky district court of St.Petersburg dated May 24, 2012 and dismiss the appeal of the Eighth Claimant;

Appendix 86 Application of S.V.Yakushenko with the Kolpinsky district court of St.Petersburg to repeal the election results;

Appendix 87 Order of the Kolpinsky district court of St.Petersburg dated December 19, 2011 to dismiss the claim of S.V.Yakushenko

Appendix 88 Claim of S.V.Yakushenko to the City Court of St.Petersburg dated December 28, 2011;

Appendix 89 Order of the City Court of St.Petersburg dated December 29, 2011;

Appendix 90 Special claim by S.V.Yakushenko to the Order dated December 29, 2011;

Appendix 91 Order of the City Court of St.Petersburg dated January 26, 2012;

Appendix 92 Claim of S.V.Yakushenko with the Kolpinsky district court of St.Petersburg;

Appendix 93 Order of the Kolpinsky district court of St.Petersburg dated January 20, 2012;

Appendix 94 Revised claim by S.V.Yakushenko dated February 15, 2012;

Appendix 95 Ruling of the Kolpinsky district court of St.Petersburg dated July 16, 2012;

Appendix 96 Appeal of S.V.Yakushenko dated August 15, 2012 to the ruling of the Kolpinsky district court of St.Petersburg dated July 16, 2012;

Appendix 97 Appellate ruling of the City Court of St.Petersburg dated October 18, 2012 to affirm the Ruling of the Kolpinsky district court of St.Petersburg dated July 16, 2012 and dismiss the appeal of the Ninth Claimant;

Appendix 98 Application of the SR regional office with the City Court of St.Petersburg to repeal the election results;

Appendix 99 Order of the City Court of St.Petersburg dated February 27, 2012 to dismiss the claim of the SR regional office;

Appendix 100 Appeal of the SR regional office to the Order of the City Court of St.Petersburg dated February 27, 2012 to dismiss the claim of the SR regional office;

Appendix 101 Ruling of the Supreme Court of the RF dated May 23, 2012 to affirm the Order of the City Court of St.Petersburg dated February 27, 2012 and dismiss the appeal of the SR regional office;

Appendix 102 Claim of the SR regional office dated April 11, 2012 with the Kirovsky district court of St.Petersburg to the actions of TEC 3 and the MEC;

Appendix 103 Ruling of the Kirovsky district court of St.Petersburg dated August 16, 2012;

Appendix 104 Appeal to the ruling of the Kirovsky district court of St.Petersburg dated August 16, 2012;

Appendix 105 Appellate ruling of the City Court of St.Petersburg dated October 17, 2012;

Appendix 106 Claim of A.V.Davydov, O.O.Andronova, A.V.Andronov, T.A.Nikolayeva, A.G.Nikolayeva, E.P.Sizionov and V.G.Beliakov to the Constitutional Court of the RF;

Appendix 107 Response of the Supreme Court of the RF to the inquiry of the Constitutional Court;

Appendix 108 Response of General Prosecutors Office of the RF to the inquiry of the Constitutional Court;

Appendix 109 Response of the State Duma of the Federal Assembly of the RF to the inquiry of the Constitutional Court;

Appendix 110 Response of the Council of Federation of the Federal Assembly of the RF to the inquiry of the Constitutional Court;

Appendix 111 Response of the CEC of the RF to the inquiry of the Constitutional Court;

Appendix 112 Response of the Ministry of Justice of the RF to the inquiry of the Constitutional Court;

Appendix 113 Expert opinion of the Chairman of the Department for constitutional and international law at the Federal State Budget Educational Institution of Higher Professional Education Altai State University V.V.Nevinsky and assistant professor of the abovementioned department, candidate of legal sciences A.V.Dolzhikov to the inquiry of the Constitutional Court, EN

Appendix 114 Expert opinion of the experts of the Department of constitutional and international law of the Saratov State Academy of Law to the inquiry of the Constitutional Court, EN

Appendix 115 Expert opinion of the Human Rights Commissioner of the RF to the inquiry of the Constitutional Court;

Appendix 116 Expert opinion of experts of the Institute of Legislation and Comparative Law affiliated to the Government of the RF to the inquiry of the Constitutional Court, EN;

Appendix 117 - All appendices in electronic form on the DVD (2 copies);

Appendix 118 - Claim of A.V.Andronov with the Oktiabrsky District Court of St.Petersburg;

Appendix 119 - Ruling of the Oktiabrsky District Court of St.Petersburg dated April 18, 2012;

Appendix 120 - Cassational ruling of the penal chamber of the City Court of St.Petersburg dated July 11, 2012.

Approved by the Claimants.

Legal counsel E.Napara __________________________________


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