Case Document 124 Filed 03/15/18 Page 1 of 7 PageID: 847 The United States District Court for the District of New Jersey . Martin Luther King Building 7 U. S. 2' 3 urthouse 50 Walnut Street Newark, NJ 07101 973- 645- 3730 22 mm 2118? From Rytikov Mykhaylo Serhiyovych, born on 25th May 1987 Mailing address. Zhrovtnya (Lesya Kurbasa) avenue, 1a, Apt. 54, Kyiv, Ukraine, e-mail: Mikhail.rytikov@ua.fm advokatcri1ne@gmail.com STATEMENT for ensuring the person?s rights and fundamental freedoms This statement for ensuring the person?s rights and fundamental freedoms is ?led by the citizen of Ukraine Rytikov Mykhaylo Serhiyovych who has been unlawfully prosecuted by US law enforcement agencies over the past eight years, Thus, the law enforcement agencies of the United States of America are conducting investigation of the circumstances of breach of the large enterprise networks around the world by the number of persons by prior conspiracy to steal commercial data and steal more than 160 million credit card numbers that caused a loss of hundreds of millions of dollars. In the abovementioned criminal proceeding my alleged involvement to the committing of the illegal actions is being checked. Moreover, I discovered that from the initiative of the law enforcement agencies the international wanted list due to my alleged involvement in commitment of the fraud in the Internet and personal data stealing. The ?nal decision in my case has not been made. According to the received information, in March 2009 the US Department of Justice addressed the General Prosecutor?s of?ce of Ukraine with the request for international legal assistance. In the abovementioned request the US Department of Justice asked for conducting searches to identify and seize equipment, which contains information related to the VendorsName v.n. website. Moreover, the USA bodies emphasized that: the equipment should be seized without disabling it from the power supply to prevent the of useful information - during searches one or more representatives of the US law enforcement agencies should be present to provide advice how to conduct searches and collect evidence to maintain the validity of such evidence for the US law enforcement system. Case Document 124 Filed 03/15/18 Page 2 of 7 PageID: 848 2 At the same time, in the course of conducting the searches upon the request for the international legal assistance, of?cials of the State Security Service in the Odessa region ignored all the abovementioned recommendations of the USA authorities. In particular: - server and other equipment was removed without any veri?cation, if it has any relation. to the VendorsName v.n. website. or providing hosting services in general; while removing the server equipment the of?cials of the State Security Service of Ukraine in the Odessa region disabled all the items from the power supply, despite the possible risks that information, necessary for the criminal case, could be damaged or lost; - the searches were conducted without the involvement of any representatives of the USA, who could assist and advice how to save information which is important to for the investigation. Taking into account that, as was mentioned above, the request for the international legal assistance contained clear recommendations how the searches should be conducted it seems that: - such recommendations were intentionally ignored by the of?cials of the State Security Service of Ukraine in Odessa region as direct executors; such recommendations were intentionally hidden by the of?cials Prosecutor?s General Of?ce of Ukraine as an addressee of the request for international legal assistance Given the circumstances that the: the seized equipment obviously did not correspond to subject of the request for international legal assistance, - no measures to present the damage or of the information contained on the server equipment were taken, - no representatives of the USA authorities were involved during the searches, there are suf?cient grounds to assume that such actions of the of?cials of the Prosecutor?s General Of?ce of Ukraine and State Security Service of Ukraine in Odessa region were not aimed at ful?lling the request for international legal assistance. Instead, such actions could have been taken from other personal corruption) motives. The of?cials of the Prosecutor?s General Of?ce of Ukraine and State Security Service of Ukraine in Odessa region assure that all the seized equipment and documents were send to the competent authorities of the USA. At the same time, the total number of the seized equipment is more than 140 servers, documents and photographic equipment, information carrier with personal data, which obviously have no relation to the hosting services and are useless for the competent authorities of the USA. This, in turn, dives grounds to presume that the information provided by the of?cials of the Prosecutor?s General Of?ce of Ukraine and State Security Service of Ukraine in Odessa region do not correspond to reality. Moreover, according to the received information with the letter from 01St February 2010 the Department of Justice of USA addressed the Prosecutor General Of?ce of Ukraine with the motion to ensure the storage of the seized property by the State Security Service of Case Document 124 Filed 03/15/18 Page 3 of 7 PageID: 849 3 Ukraine as the? USA'authority has already made all necessary copies and do not need physical carriers. At the same time, the of?cers Prosecutor?s General Of?ce of Ukraine and the State Security Service of Ukraine deny that the competent authorities of the USA returned any equipment and argue that after sending the equipment to the USA authorities, no further information regarding its current status and location was received. This, in turn, requires the inspection: - if the actions of the of?cials of the law enforcement agencies of Ukraine comply with the rules of international cooperation and - if the information provided by the of?cials of the law enforcement agencies of Ukraine correspond to reality. Taking into account the abovementioned, - I REQUEST: 1. Within the given competence, to verify if the list of equipment that were provided by the Prosecutor?s General Of?ce of Ukraine match the list of all the equipment seized during the searches in 2009 and 2016 (enclosed). 2. Within the given competence, to verify the current location of all the equipment seized during the searches in 2009 and 2016, mentioned in the list. 3. Provide in written the list of the items transferred to the competent authorities of the USA in 2009 and 2016. 4. If necessary in the prescribed manner request from the of?cers of the Prosecutor?s General Of?ce of Ukraine explanations and documents reacted to the execution of the request for the international legal cooperation and further requests of the USA competent authorities (in particular, the US Department of Justice). 5. The answer with the results of the consideration of the statement please send me Via e- mail: or contact my attorney Artem Kravchenko by the mailing address: Zhrovtnya (Lesya Kurbasa) avenue, la, Apt. 54, Kyiv, Ukraine, telvia e-mail: advokatcrime@gmail.com. Appendix: 1. he list of the items, seized during the searches in 2009 and 2016. I M.S. Rytikov Case Document 124 Filed 03/15/18 Page 4 of 7 PageID: 850 Appendix to the statement for ensuring the person ?s rights and fundamental freedoms THE LIST of the items, seized during the searches in 2009 and 2016. 1. Things (documents) seized during the search at the address: Odessa city, street. Marselska 44 in 2009: Seagate NDMD 9QK1C7VY - Western Digital 3/ WCARW3594774 Maxtor 3 662200445121 Seagate 9QK1C82P Western Digital 5 WMANS2463962 Western Digital 5 WMANSZ464340 Western Digital WCASJ0722811 Western Digital 5 9WMART1094726 NTMD Maxtor 5 9QM2J1N9 Seagate 5VMON42X cell phone manufactured by Motorola 5 SJUG23 89BB Kingston 5 CH 031808 USB storage device Optical disk Titanium 3 78-06-05-80-33 0 USB Transcend JF V30 5 11 506421 0952 0 PC unit system UA80078060974 - PC unit UA80586050910 - Flash drive with silver inserts on both sides, on one side the silver insert contains the inscription - 8 Gb, on the other hand - Samsung Flash Memory - Mobile Storage 0 One hundred and forty one servers are numbered according to the location in the rack 1-1 21?1, 1- 2 30-2, 1?3 333, 1-4 24 -4, 1-5 33-5 0 Nokia cell phone with phone number 80936178419 0 Nokia cell phone with IMEI 358627015748260, phone number 80935842007 2. Things (documents) seized during the search at the address: Yuzhne city, Odessa region, 7 Lenin street, app. 25 in 2009 - ACER notebook 74307839616 - Canon 32 memory cards; San Disk - USB ?ash drive in gray color - Agreement on the provision of mobile communication services No. 4559 with appendices (4 sheets) - eight DVD DVD Samsung SPH-M300 mobile phone - one drive - Notepad "Strategy" Notepad "09" (orange colour) - A card from the Kyivstar SIM card - A piece of paper with records "Frankfurt" and "Misha" - Contract N9 670/ 1001.1-1761 on 2 sheets - Statement from 10/07/08 on page 1 - Contract N9 0670/00006435 on the sheet - Minutes No. 2 dated February 21, 2008 on the 1 st sheet Q+n+ll+o 1 nn 1/1 phonic Case Document 124 Filed 03/15/18 Page 5 of 7 PageID: 851 2 - Centract N2 with attachments on 3 sheets - Contract number LL3 15 09 OD with the applications on 3 sheets - Contract 1-7 91832 with annexes on 3 sheets. - Contract N9 0670 00006434 on one sheet - Contract N2 04959898 on one sheet - The PIN code to the card No 4149507007060823 on one sheet Contract N9 26206181850301 on 2 sheets - "Statement" dated July 21, 2008 on 2 sheets - Contract-questionnaire No. 454 with annexes on 4 sheets Additional agreement No. 123 dated July 21, 2008 on 2 sheets. Black computer system block unit with CDMA MODEM People Net connected to it without serial number - Card 80028986 - VISA card Ukrsotsbank - VISA Card. PrivatBank - 7 DVD disc - 3 CDs - USB-TRANSCEND ?ash drive Apple 88210PUVSI LaptOp - DVD - Account for payment No. 166 from May 26, 09 and No. 166 from May 26, 2009 on 2 sheets. Card from Kyivstar sim card Black computer system block. 3. Things (documents) seized during the search at the address: Odessa city, 37 Zabolotny street app. 31 in 2009 system unit (in the off state) SAMSUNG 10W 6064 74 Kingston Memory Card No. 3500007-001AO0LF 100906 Optical media (tick?) Magnetic Media National Business card of Rytikov 0.8., where on the reverse side is the e-mail address. 4. Things (documents) seized during the search at the address: Odessa city, 5/3 Gagarinsk plateau, app.110 in 2009 0 Logitech wireless mouse, Rgi 830 GGF, mouse case 0 - Wireless USB 3G modem 5. Things (documents) seized during the search at the address: Odessa city, 99 Dnipropetrovsk road, app. 32 in 2009 Nokia 95 mobile phone in the black body with a sim-card company Kyivstar Chargers to Vertu mobile phones Bank Card Bank Aval N9 4149 5070 0691 8249 to the name of Mykhailo Rytikov Bank card "Ukrsibbank" N9 4874 1200 1699 6747 to the name of Mykhailo Rytikov The black computer system block RC 93OSKN21074600077 Samsung Hard Disk Drive Gray Information Storage 0 Memory Card Kingston micro SD, Serial No. 1-081?400060-1202 0 White SanDisk USB Flash Drive with a protective insert 0 USB Transcend 2Gb USB ?ash drive in the white case 0 Prestigio USB flash drive in the black leatherette case 0 Mobinil Seven?Card 8920 0156 0807 0054 030 15 Case Document 124 Filed 03/15/18 Page 6 of 7 PageID: 852 3 Plastic card of the life package without a sim card, serial number 893800 6220 8230 991442, N9 +39093 6695360 Plastic card of the start package Life without a sim card, serial number 893800 6080 7317 900319, N2 +39093 0790031 Notepad in brown leather case with handwritten notes Fragment of a sheet from a Notepad with a handwritten note 738?74?12 3270611285 HP Notebook PC, serial number CNT 6381MP4, power supply the laptOp manipulator headphones. Things (documents) seized during the search at the address: Odessa city, 99 Dnipropetrovsk road, app. 32 in 2016 HSUPA USB Stick IMEI 35653804886853 modem USB device without serial number Bank card Privat Bank number 4627 0550 0928 6765 Bank card Privat Bank number 5218 5722 1095 3363 cardholder from SIM?card at +38073l401682 cardholder from sim-card at +3809l939 16 19 cardholder from sim?card at +3 80935099629 packing from SIM?card at +38090 577 65 61 packing from SIM-card at +38098 015 97 49 micro SD on 4 Gb HC serial number 1206308640 QPI Player COWON 60 Gb serial number KB 0802306115 notepad ?Diary?, on the ?rst page - Mikhail Sergeevich Rytikov with handwritten notes notepad ?Adress Book? on the ?rst page of the stamp of Bastion-Trade Group with handwritten notes notepad in a blue cover on the ?rst page - "multisport" with handwritten notes photocopy of passport Rytikov M.S. fragment of a sheet of paper with handwritten notes "tel. 799-08? 00 the printed text in the table begins with "38048-701- 05?45" on 1 sheet, Agreement No. l7-003 dated March 17, 2010 on 3 sheets DATA GROUP letter dated 08/28/2008 on 1 sheet. Agreement No. 0461247900 dated June 14, 2007 on the 1 st arch. Account No. 2008?08?8909 dated 02.09.2008 on the 1 sheet. -Statement "for the restoration of control over the VM on the 1 sheet. Sheet of paper with the handwritten text Sheet of paper with printed text on the 1 sheet. To the contract N9 17-003 dated March 17, 2010 on the sheet. Optical discs TDK-DVD-R 4.7 Gb, 8 pieces DiGitex DVD-R optical discs (white) 3 pieces; Optical discs Verbatim CD-R, 6 pieces; Optical discs SuperxPlus CD-R, 6 piece; Optical 4 pieces; Titanum 4.7 Gb optical discs, 1 1 pieces; Sky optical disc, 700 mb, 1 pc; Digital DVD-R Optical Discs, 4.7 Gb, 1 piece; Optical disk Sigma CD-R, 700 mb, 1 piece; Optical disk ANV CD-R, 700 mb, 1 piece; Optical DVD Sony DVD-R, 4.7 Gb, 1 pc; Optical disc KAKTUZ CD-R, 700 mb, 1 piece; Optical disc 2-sided, 1 piece; ?annl (11.011 D1 EHJUI AV thJ} A '7 1 ninth:- Case Document 124 Filed 03/15/18 Page 7 of 7 PageID: 853 4 Optical disk DiGitex 4.7 Gb, 1 piece; Optical Digital CD-R, 700 mb, 1 pc; Optical discs Verbatim CD-R, 700 mb, 6 pieces; Optical disc ARO 700 mb, 1 piece; Optical disk DiGitex CD-R, 700 mb, 1 piece; Optical drive ViDex CD-RW, 700 mb, 1 piece; Optical drive ACME 4.7, 1 piece 0 HP black notepad with explanatory sticker serial No C2C14760N9 Product No KK 765EA ACB . Computer storage device KF 4281702 0 Lenovo mobile phone IMEI 865095021139070, 865095021139088 from 38073-040?32?53 - Digitex optical media, 5 pieses 0 Orange optical media, 2 pieses. DATEX Optical Media, 1 piece 0 Optical Media, 1 piece 0 Optical media ESPERANZA, 1 piece 0 Optical media VERBATIM, 1 piece 0 ACME Optical Media, 1 piece 0 PRINCO Optical Media, 8 pieces, TDK optical media, 2 pieces. M.S. Rytikov 22 mm 2013 a Attorney Kravchenko Artem 5 Zhrovtnya (Lesya Kurbasa) avenue, 1a, Apt. 54, Kiev, Ukraine KYIV 148 4 A RH 031 78560 NIHWIHMI Iill Ill umAmg UKRAM I I I I I The United States District Court for the District of New Jersey Martin Luther King Building 7 US. 0arth0use5 0 Walnut Street Newark, NJ 0710] 973?645-3 730 Case Document 124-1 Filed 03/15/18 Page 1 of 1 PageID: 854 Wt.