From Department of Internal Affairs
Chief of the Department of Internal Affairs of the Central District of Krasnodar
Ostapenko P.I.
Mr. Roy Den Hollander
On 25.01.2002 the procuracy of the Central District of the city of Krasnodar brought criminal action № 47603 pursuant to Article 129.2 of the Criminal Code of the R.F. against Shipilina, A.I. The conduct of the preliminary investigation was directed to the Department of Internal Affairs of the Central District of the City of Krasnodar.
In connection with this matter it is necessary to question you as a victim and therefore we ask you to answer the following questions in full detail.
I, Roy Den Hollander, a citizen of the USA, residing at 545 East 14th Street, New York, New York 10009, US passport No. 200315516, speaking under oath, hereby depose and say as follows, to the best of my knowledge and belief, in answer to the attached questions:
On July 4, 1999, I arrived in Moscow to begin work as the manager of the Russian Division for the American firm Kroll Associates. I was hired on a consulting basis to improve the firm’s operations and increase its business in Russia. Kroll is a worldwide security and consulting company.
I met Alina Shipilina, whom I later called Angel, on Friday, July 23, 1999. I was walking back to my apartment at 7 Denis Davidov in Moscow around 23:00. As I turned into the driveway leading to my front door, I came upon a party emanating from the basement of the building where I lived. The night was warm and a handful of people, including a couple of very pretty Russian girls who were talking with two men, were standing outside by the driveway. I decided to check it out and headed for the basement entrance to the party when a man whom I assumed to be the host told me it was for invitees only. I said, “How do I get an invitation?" He asked whether I was an American, I said yes. We exchanged names and he showed me inside to the bar and left. I didn’t speak Russian beyond that of a three year old, but the bartender spoke English, so we struck up a conversation. While we were talking, I heard someone behind me say my name or something in English. I turned and there she was, a few inches taller than me, beautiful, blonde, all a glow and smiling—I fell like a sack of bricks and said to myself, this is the one. She said, “Hi I am Angelina.” We went outside at her suggestion where she told me she was a model and dancer and that the party was hosted by her model agency, and that she would be in Moscow for another week working as a model. She told me one of her pictures was on display in an exclusive clothing store a few blocks down Kutuzovsky from my apartment building, which I saw later on. She came from Krasnodar, said she didn’t have any boy friends at the moment and that she had been a three-time Russian long jump champion when in school. From that night until she left for Krasnodar the following Friday, we went out every night except one. She wanted to dance and dance all night long. I wanted to be with her always. We only kissed and hugged, but I was in heaven—I was in love. I had found the girl of my dreams. I couldn’t believe my good fortune. When she left, I took her to the airport with my driver, and we kept in touch through letters and telephone calls until she returned to Moscow the end of August.
I fell in love with Alina and wanted to build a life together with her in America. I never met anyone before for whom I felt this way. I didn’t what to lose her. I wrote her love letters that included statements such as “I received your photographs and put them on the pillow next to mine, so I could smell your perfume the night through and dream of you,” or “Its just like heaven being here with you. You are an Angel too good to be true.” We got married on March 11, 2000, in Krasnodar at ZAGS. I was surprised that she had not invited any of her friends and especially that her mother did not show for the wedding. I would have invited my friends for sure because I felt exhilarated and proud, but my friends were in America. It appears that one reason for my joy was that Alina was secretly putting, as she wrote in her diary, “salts and sugars” in my meals before the wedding that caused narcotic like symptoms in me.
I visited Alina and her mother, Inessa, in Krasnodar over New Year’s when the millennium changed to the year 2000. We spent the evening celebrating at her and her mother’s house. Her mother was hospitable and friendly, serving up many different courses, of which Alina couldn’t eat too much because she was already bursting out of the seams of her skin tight mini dress. At midnight we all went outside to the road to set off fireworks. It was very dark, but I could see the black shapes of lots of people standing around. All of a sudden the entire sky lit up with rockets and sparklers and bombs bursting everywhere. It looked like a war as far as the eye could see. Alina was setting off rockets and firecrackers; jumping up and down in her mini shirt filled with glee like a little child.
I considered my relations with Inessa good but was troubled by why she didn’t come to our wedding in Krasnodar in March 2000. At the time, Alina said her mother had to work. By the end of August 2001 when the marriage was on the rocks, the relations were not good. In one fax that Inessa sent to Alina on my fax machine, Inessa said I was like a bloodsucker, never satisfied, and she ended the fax wishing her married daughter “new conquests”.
a) What was the reason for divorce?
I learned from Alina’s diary, her words, and her actions that she was a prostitute, repeatedly committed adultery, consistently lied to me, wanted to date the men who watched her strip at “Flash Dancers” (a club) and married me in order to obtain a green card. Within three months of our marriage she traveled to Italy on her second passport to keep the entry stamp out of her other passport that she would use to travel to the United States with me. In Italy she engaged in adultery and prostitution with an old client of hers from Mexico, Alfredo Ibarra. In July, just four months after out marriage, she engaged in sexual conduct in Krasnodar with a man named Vladimir from St. Petersburg. After that tryst at 5:30 in the morning, she allowed a taxi driver to fondle her knee in order to save on the fare.
She insisted on working as a lap dancer rather than devoting her time to pursuing modeling, acting or singing that many of my friends were willing to help her with. It became clear to me that Alina was driven solely by greed for the wealth the sex industry could provide her. All her talk of “special love”, karma philosophy, and dreams were no more than a ruse to trick me into bringing her to America, so she could sell herself to as many men for big money as possible.
Some examples from her diary:
About our wedding she said, “And on Saturday, March 11, 2000, we registered our marriage. It was merry! I did not accept it very seriously; for me it was only business. I become so tired of him.” Page 41 of the certified English translation of her diary; p 101 of the Russian language copy.
Her June 25, 2000, diary entry states, “The problem is in his real feelings to me. I am a stimulus for him. He sees me as a real wife, but it is absurd…. I will never see him as a real husband.” Page 46 English; pp 120-21 Russian.
January 17, 2000, “Roy says that I am the only happiness of his. He wants me to be near him…. If only he were younger….” Page 37 English; p 90 Russian.
April 5, 2000, “He wrote me a letter saying how it was difficult for him to be alone…. Frankly speaking, I cannot imagine what I will do with him in Moscow. Listen to his philosophy? To wash, to clean and to cook? And leave my mother all alone…. On one hand I would like that we remained friends, but he would not hinder my meetings with friends and I would give him freedom.” P 41, 42 English; p 103 Russian.
April 20, 2000, “What will happen if I will not receive a visa to America? I will go—with Leonid’s help—to Greece or Venezuela. In June I am sure to go somewhere!” Page 43 English; p 108 Russian.
July 6, 2000, “I decided to go to America for now and make some money and to get a divorce from him. Then better to go to Japan.”
b) Is your marriage with Shipilina dissolved? Yes
a) Under New York law I sued Alina for an annulment or in the alternative a divorce based on her adultery or cruel and inhuman treatment. Under any of these causes of action I needed to provide evidence to the court concerning her conduct. Annulment required I prove to the judge or jury that my wife lied about or failed to tell me something of such importance that had a reasonable man in my position known the truth he would not have married her. Cruel and inhuman treatment required showing any type of conduct by Alina towards me that the court considered to make our continued cohabitation physically or mentally harmful or just improper.
The key evidence I possessed for all these causes of action was a copy of Alina’s diary, but before the court would accept the diary as evidence, I needed to prove that she wrote the diary and that the events depicted were accurate. In order to do that, I needed to find potential witnesses knowledgeable about her writing style and some of the events Alina wrote about. Once I found such witnesses, I could obtain their testimony for the court under the Hague Convention on Taking Evidence Abroad in Civil or Commercial Matters. Furthermore, Alina’s defense for annulment and adultery also required me to find additional evidence that I previously did not know about. In order to authenticate Alina’s diary and find additional evidence for the court proceedings, I traveled to Krasnodar in search of knowledgeable witnesses willing to tell the truth.
I was in Krasnodar from April 15 to 22, 2001, and from June 10 to 17, 2001.
b) Yes, I met or contacted acquaintances of Alina. I assume that you want to know which ones. I recall meeting the following: Alexey Dikov, Katherina Alexevna Gerokaris, Vera Ivanasova, A man who answered the door at Vita C by the Aurora Movie Theater. I was looking for the manager whom Alina introduced me to and said had helped her move from Grozny. Evegeniy Martianov, V.G. Minchenko, Acting Rector Kubanskaya State Academy of Physical Training, Yulya Yurevna Kudinova, Dmitri Morosov, photographer of models, Andrei Sergeyvich Petrov, Alexey Smolin, Manager of Troika Restaurant, Anastasia and Dima Vasilyeva of the Tatianna Vasilyeva Fashion House, The head of ZAGS whose name I believe is G.I. Klimova, Next-door neighbors of Alina at 138 Rashpilevskaya. I associated with my two translators, Natalya Martys, Nadya Sanchez and my attorney Svetlana Povaliy and a reporter named Victoria Aleynikova.
I believe I first learned about Inessa’s efforts to keep people from providing me information by defaming me and threatening potential witnesses during a telephone call to my translator Natalya Martys or from an email she sent to me on May 16, 2001.
The best I can discern follows:
At first, she (Inessa) came into my (Natalya) office, she told me very bad things, also she told that you are criminal, crazy, etc. In addition she told me that you’d never visit Russia again, because you are a criminal and our police know it. She forced me to say with whom you met in Krasnodar. After this she tried to force me to write a paper with number of my passport and current address for Court with detailed describing of your last visit into Krasnodar: each meeting, with whom and when.... I said, O.k., see you tomorrow, I'll make this paper. When she left our office I called my lawyer, and she refused to make any paper without special request from Court. When Alina's mother came again, I told her, I agreed to help to show the real matter of justice but you haven't any possibilities for this. She was very angry, she promised to locate me at the prison very soon. Yes, it was very unpleasant, you know. Also she told that you forced Alina to write her diary, she could kill me! Natalya was frighten because Alina and Inessa have money from Alina’s prostitution and stripping work in New York and also have connections with Chechen gangsters.
On or about July 12th:
Inessa apparently sent to Natalya’s home a forged court summons in an effort to threaten and intimidate her into no longer providing translation services to me.
Inessa went to Vera and threatened to sue her in court, accusing Vera of taking money from me to distribute Alina’s diary. Inessa said some very negative things about me that Vera did not want to repeat in my presence. Inessa told “everybody” in the Gymnastic Department at the Academy of Physical Culture that Vera was distributing the diary to people in the Academy because I had paid her money. Others found out that Inessa was lying and made her apologize to Vera in front of the Academy’s instructors.
Alina telephoned Anastasia and asked to come over and meet with Anastasia about her meeting the previous week with me. Anastasia refused. Later, Inessa telephoned Anastasia and asked Anastasia questions about her meeting with me. Inessa told Anastasia that I was a criminal. Inessa also talked to Dima. Then Alina and Inessa sent a message on Anastasia’s pager that they know Anastasia had sold information to me, and they will meet in court. Anastasia was very scared over the situation and Dima was very upset.
Inessa called Alexei to try to intimidate him into not talking to me.
Inessa called Martianov to ask whether I had talked to him and had given him some papers. Inessa said Roy was a crazy person.
I believe Alina or Inessa contacted Morosov and defamed me to him because when my translator called him he acted nasty and refused to meet with me, saying he had heard about me.
Inessa walked over to Nadya, my translator, and me and tried to intimidate Nadya into giving Inessa her name. When Nadya refused, Inessa said in a very threatening manner, “If you work for Roy, you will get into a big mess.”
On June 16, 2001: Inessa called Alexei Dikov looking for an FSB person to deal with Roy.
On June 17, 2001: In the morning, Inessa called Roy’s driver in Moscow and told him not to pick Roy up at the airport that night. When Roy arrived at the Krasnodar Airport to leave for Moscow, Inessa was standing with a militiaman and pointed Roy out to him and said a photograph was taken. Then Inessa followed Roy and his translator to the car and stood near the car apparently talking on her mobile telephone.
Inessa visited the office of the editor of “Улица Красная” shouted and threatened her over an article the paper had printed in its April 30 – May 6 edition about the situation between Roy and Alina. I believe Inessa defamed me to the editor. The editor was intimidated into not reporting any follow up stories.
According to Anastasia Vasilyeva, Inessa told her before my trips to Krasnodar that I was not generous enough.
I am a lawyer with a Masters of Business in Finance. I received my MBA with honors from Columbia University in May 1997 and my Juris Doctor degree with high honors from George Washington University in1985. I belong to two of the four national academic honor societies in America: Order of the Coif and Beta Gamma Sigma. I have worked for ABC Television News, the United States Department of the Treasury for which I received a Top Secret Security Clearance from the Federal Bureau of Investigation, and one of the best law firms in America: Cravath, Swaine & Moore. These credentials attract people and businesses not only in the US but Russia to retain my services not just for my skills but my integrity, honesty and dependability. In Russia, I have been providing legal and business advice to Russian organizations, the government and individuals since 1991, which included the Department of Overseas Business Promotion in the Ministry of Foreign Economic Affairs, Intertraining Association and Kroll Associates Moscow. My reputation for straightforwardness has enabled me to publish a number of articles on law, politics, economics and Americans in Business World Weekly and Law Gazette, and appear on BK TV KT on one occasion to provide analysis of laws governing the buying and selling of securities.
As our world becomes smaller and smaller, a mean-spirited individual’s defamation of another person can easily have reach beyond the parochial geography in which it was made. Inessa Shipilina’s malicious, premeditated and willful efforts to besmirch my character in a wholly unjustified attempt to keep the truth about her daughter from the New York State Courts not only harmed the concept of justice by which civilized people live but left a spreading stain on my reputation not only in Russia but one that could easily expand to wherever I may conduct business or deal with decent-minded people in this small world of ours. It is not as unlikely as one might think to accidentally meet someone who knew an acquaintance of ours in a distant city or country. In fact, contemporary population mathematics postulates that any of us can have a message personally delivered to anyone else in the world by going through a chain of at most six people. Unless the Krasnodar court puts a stop to Ms. Shipilina’s spurious statements calculated to cause grievous harm to my dignity, honor, worth and reputation, and to call into question in the minds of others all the credentials I have garnered thus far in this life, then there is no telling how far and deep her injurious conduct may reach. In addition, when considering the surprises that life brings, it is not unfeasible that this time next year I might have the opportunity to work with organizations or individuals in Krasnodar, but not unless my name is cleared.
____________________
Roy Den Hollander, M.B.A., J.D.
545 East 14th Street
New York, NY
10009 USA
Sworn to before me as true to the best of his knowledge and belief by Roy Den Hollander, M.B.A., J.D., to me known to be the individual described in and who executed the foregoing document, and acknowledged that he executed the document on this day of March 2002.