The Case of Dr Oleg Maltsev: Documents & Timeline

• Name: Dr Oleg Maltsev
• Date of arrest: 12 September 2024
• Place of detention: Odesa pre-trial detention centre (SIZO-21)
• Time in custody: more than 330 days on remand, without bail
• Charges: Criminal Code of Ukraine, Article 109 (“conspiracy aimed at the violent overthrow of the constitutional order and the seizure of state power”) and Article 260 (“creation of an unlawful paramilitary formation”).
• Profile note: academic positions, memberships and publications summarised in section Academic biography.
• Context note (expression & belief): the materials at issue concern conditional, non-public civil-protection planning in spring 2022; as a Jewish scholar, Dr Maltsev’s convictions include a duty—grounded in din rodef (stopping an immediate attacker) as a contextual articulation of belief, not as a call to violence—to protect life and community; any reference to defensive measures was framed only as a last resort and within the bounds of law, consistent with public guidance issued by the Ministry of Defence of Ukraine¹ (Articles 18 and 19 of the ICCPR, subject to legality, necessity and proportionality). (see Exhibit H01)

¹ Center of National Resistance (Special Operations Forces, Ministry of Defence of Ukraine), Civil Resistance in Occupied Territories (pocketbook), 28 March 2022. Official guidance for civilians under occupation and clandestine organisation; includes operational security and community protection measures, and explicitly references knowledge of improvised weapons and self-defence as last-resort options within the law.

16 March 2023 — Academic publication

Official presentation of the monograph “The Work of the Mind in Task Execution Mode. Vol. I” (co-authored with I. I. Lopatyuk). The research programme included cooperation with the Shooting Federation at the Olympic Shooting Range in Odesa (coach: Olympic champion Mykola Milchev). The work received endorsements from Ukrainian and international experts and athletes, including:

– Yakov Zheleznyak – Olympic champion in shooting;

– Iryna Vynohradova – International Master of Sport, Honoured Coach of Ukraine in shooting sports;

– Svetlana Boikova – International Master of Sport of Ukraine; member of the USSR and Ukrainian national shooting teams;

– Viktor Bankin – CISM Cadet World Champion, medallist at the 2022 World Championship;

– Vladyslav Boykov – Master of Sport in fencing; elite-level fencing coach at the Olympic Training Centre of Kyiv Oblast; Member of the Presidium of the Ukrainian Fencing Federation.

29 May 2023 — Registration of International Sport and Tactical Shooting Federation

To establish a material and technical base, lawfully registered sporting and hunting firearms were acquired between 2022 and early 2024 in full compliance with legal requirements.

December 2023 — Email extortion alert

Defence counsel Olha Panchenko received an anonymous email alleging covert SBU activity against Dr Maltsev and soliciting payment to “close the case”. She reported this to SBU military counterintelligence leadership. (see Exhibit A05)

29 February 2024 — Search and property loss

A search at Dr Maltsev’s residence was conducted in his absence. Defence arrived after an air-raid delay. The door was broken; personal property and photographic equipment were reported missing (approx. €10,000). Official search video reportedly “disappeared”. A theft case under Article 185(3) CCU was opened. Lawfully registered sporting/hunting firearms were seized; no charges followed from this search.

March–April 2024 — Court orders to return lawfully registered firearms; subsequent non-execution

1. March 2024 — trial court order. The Kyivskyi District Court of Odesa refused the prosecutor’s motion to arrest the property and ordered the return of the lawfully registered sporting and hunting firearms to their owner. (see Exhibit A01)

2. April 2024 — appellate confirmation. The Odesa Court of Appeal upheld the trial court’s ruling directing that the firearms be returned. (see Exhibit A02)

3. Spring–summer 2024 — non-execution. Notwithstanding the binding force of the above decisions, enforcement was delayed for months. Various pretexts were cited (pending examinations; the weapons allegedly being held in Kyiv; logistical unavailability), after which a new proceeding was initiated in which the same firearms were again referenced as evidence. (see Exhibits A01–A02)
   Defence statements (selected).
   – Yevheniia Tarasenko (defence counsel): “I have five court rulings in hand directing the return of the property, yet these decisions have not been executed even after six months.”
   – Summary of the position: the courts ordered the firearms to be returned to the lawful owner on the basis that they were duly registered, but the orders remained unexecuted.

1–6 July 2024 — Acute health episode and rehabilitation

Dr Maltsev was admitted to ICU (St Catherine’s Clinic, Odesa) with hypertensive crisis, then transferred to in-patient care and outpatient rehabilitation. (see Exhibits C01–C02)

12 September 2024 — Arrest and remand without bail

Detained at a private rural residence and charged under Articles 109 and 260 CCU. The Temporary Detention Facility (IVS) initially refused admission due to inability to ensure adequate emergency care (pre-existing conditions: bronchial asthma, diabetes; later also documented sleep apnoea). Notwithstanding medical concerns, the court ordered pre-trial detention without bail and transfer to SIZO-21 (a historic facility known for poor conditions). (see Exhibits C03–C04)

Context underlying the charges (Spring 2022) — Internal, conditional planning**

An internal EUASU meeting (video) discussed contingency planning should state protection in Odesa collapse and occupation occur, focusing on safeguarding staff and the Academy’s material base from looting and lethal harm. As a Jewish scholar, Dr Maltsev articulated convictions grounded in din rodef (stopping an immediate attacker). Any reference to defensive measures was framed only as a last resort within the law, consistent with Ministry of Defence of Ukraine public guidance at that time. These were non-public, security-related discussions, not public calls to hatred or unlawful violence.

18 November 2024 — Early NGO warning of fabrication (HRWF, Brussels).

Human Rights Without Frontiers (HRWF), a Brussels-based human-rights organisation founded in 2001 by Willy Fautré, issued a public note flagging the apparent fabrication of criminal charges against Dr Oleg Maltsev. HRWF called for heightened scrutiny of the case and adherence to fair-trial guarantees under Ukrainian and international law.

Significance: independent, early third-party alert corroborating defence concerns about the case’s integrity; supports the need for urgent review of prosecutorial conduct and due-process safeguards. (see VI.18)

28 March 2025 — UN Human Rights Council oral statement (CAP/Liberté de Conscience, Geneva).

At the 58th Session of the UN Human Rights Council, CAP/Liberté de Conscience (a secular NGO founded in France in 1995, holding consultative status with the United Nations) delivered an oral declaration through its representative, Christine Mirre, identifying Security Service of Ukraine (SBU) counterintelligence officer Mr Yevhen Volosheniuk as the alleged orchestrator of the criminal case against Dr Oleg Maltsev, and urging an impartial investigation and compliance with international fair-trial guarantees.

Significance: escalates the case to a UN forum; names a specific official allegedly responsible; reinforces concerns of political motivation and due-process violations; supports the need for independent scrutiny and immediate protective measures.

15 April 2025 — Odesa | Search and arrest of defence counsel

Security Service of Ukraine (SBU), in coordination with the Odesa Regional Prosecutor’s Office, conducted a search at the home of Ms Olha Panchenko (defence counsel to Dr Oleg Maltsev), after which she was detained. (see Section III(3)) (see Exhibit F01)

15–25 April 2025 — Odesa (SIZO-21) | Custody pending appeal; 25 April — release on bail

Ms Panchenko remained in custody for approximately ten days pending appeal and was released on 25 April 2025 after the Court of Appeal set bail of UAH 60,560. (see Exhibit F01)

17 April 2025 — Odesa | Remand without bail ordered

The Prymorskyi District Court of Odesa ordered pre-trial detention without bail in respect of Ms Panchenko. (see Section III(3)) (see Exhibit F01)

4 June 2025 — Odesa (Peresyp District Court) | Seizure of electronic devices belonging to defence counsel Ms Olha Panchenko (legal counsel to Dr Oleg Maltsev); refusal to seize lawfully registered firearms.

Case No. 523/8177/25; Proceedings No. 1-кс/523/3208/25; Investigating Judge O. V. Derkachov.
Following Ms Panchenko’s detention and subsequent release on bail, the Peresyp District Court partly granted the renewed prosecutorial motion and imposed an arrest (seizure) until 1 August 2025 on specific electronic devices seized on 15 April 2025 — namely: an iPhone 12 Pro Max (red; without SIM); a Xiaomi smartphone (turquoise; s/n 49466/63XW00644) with a lifecell SIM; a second Xiaomi handset (model 24030PN60G; s/n …F4Q101555) with a lifecell SIM; and a MacBook Pro (s/n C02PT1M9FVH7). (see Exhibit A03)

At the same time, the court refused the prosecutor’s request to arrest the lawfully registered firearms and associated permits/registry papers, including a Beretta 686 Silver shotgun (s/n F19490X; with case) and a Fort-205 carbine 7.62×39 (s/n ВІ073480) with four magazines, together with licence No. 4884 (carrying), the Unified Arms Register extract for storage/carry of the Beretta, and the notice of acquisition. (see Exhibit A03)

18 June 2025 — Odesa Court of Appeal | First-instance order upheld (property of Ms Olha Panchenko, defence counsel to Dr Maltsev)

Appeal Proceedings No. 11-сс/8131/168/25; underlying Case No. 523/8177/25; panel: R. I. Kotelevskyi (rapporteur), O. V. Kopitsa, V. V. Kostrytskyi.
The Court of Appeal dismissed both appeals (prosecutor and owner) and left the 4 June 2025 order unchanged: the arrest on the listed electronics remained in force until 1 August 2025; the refusal to arrest the lawfully registered firearms and related documents stood. (see Exhibit A04)

August 2025 — Return of property to defence counsel Ms Olha Panchenko

Counsel reports that by August 2025 all items were returned to Ms Panchenko — both the gadgets and the lawfully registered firearms. This occurred despite Ms Panchenko being under suspicion under Article 260 CCU (creation/participation in an unlawful paramilitary formation). The return of lawfully registered firearms during martial law was interpreted by the defence as indicating evidential insufficiency; the allegation of fabrication is stated as the defence’s position. (see Exhibits A03–A04)

13 Aug 2025 — Kyiv | Court-ordered ERDR entry re alleged SBU Military Counterintelligence offences

• Court / Ref. Shevchenkivskyi District Court of Kyiv; Case No. 761/22431/25; Proceedings 1-кс/761/15129/2025; Investigating Judge Olena Chaika.

• Parties. Complaint by lawyer Oleksandr Babikov for Olha Panchenko against the State Bureau of Investigation (DBR) for failure to record a crime report in the ERDR (Unified Register of Pre-Trial Investigations).

• Outcome. Complaint partly upheld: the court found unlawful inaction contrary to CPC Art. 214 and ordered the DBR to (i) enter data from Panchenko’s 26 May 2025 application into the ERDR; (ii) commence a pre-trial investigation within 24 hours of receiving the ruling; and (iii) provide an ERDR extract. The request to register under specific Criminal Code provisions was refused (outside judicial powers). The ruling took effect immediately and is not appealable.

Context (alleged offences). CCU Art. 182(2) (violation of privacy); 361(5) (unauthorised interference with information/communications systems, aggravated); 362(3) (unauthorised actions with computer data by a person with access rights, aggravated); 365(3) (excess of authority by a law-enforcement officer causing serious consequences); 366(2) (official forgery with grave consequences); 397(2) (interference with a defence lawyer’s lawful activity by an official). (see Exhibit D01)

Significance. Confirms a procedural breach (non-registration) and triggers a DBR investigation, reinforcing due-process concerns in the case.

Prosecution expert (SBU).
The arrest was grounded in an expert examination of the same internal EUASU meeting videos in which Dr Maltsev addressed staff. In other words, the basis for his prolonged SIZO detention is an SBU-subordinate unit’s interpretation of his words expressing opinion and views.
Two linguistic opinions (see Exhibits B02–B03) by Ms Iryna Loeva (SBU expert, in post since 2023) were produced in September 2024 from the same April 2022 video: the first, alleging incitement to violent overthrow, was completed in 6 working days; the second, alleging incitement to create an unlawful paramilitary group, in 19 working days.

Independent state expertise (Ministry of Justice).
On 27 February 2025, the National Scientific Centre “Hon. Prof. M. S. Bokarius Forensic Science Institute” (Ministry of Justice) issued a comprehensive multi-disciplinary linguistic and semantic-textual analysis (commission of qualified experts). Key conclusions (select quotations):

• “No linguistic features characteristic of a call to change/overthrow/seize/remove government authorities by violent means.”

• References to weapons are solely for self-defence “against armed attackers in the context of potential future military conflict.”

• “No statements encouraging or calling for military, drill or physical training.”
  This assessment took 65 working days, was carried out by a senior independent body, and directly contradicts the SBU opinions.

Implication
The independent MoJ expertise supports that the materials concern conditional, non-public civil-protection planning and non-violent speech (Articles 18 and 19 ICCPR, subject to legality, necessity and proportionality), not incitement to violent overthrow or to form an unlawful paramilitary group. (see Exhibit B01)

Charge–evidence matrix (at a glance)

• CCU Article 109 (violent overthrow): The Ministry of Justice forensic commission found no linguistic features of calls to violently change/overthrow/seize/remove state authorities; statements referenced potential self-defence only in a hypothetical occupation scenario; the April 2022 meeting was non-public and contingency-based rather than a public incitement. (see Exhibit B01)

• CCU Article 260 (unlawful paramilitary formation): No evidence of a command structure, military/drill training, armed operations or intent to deploy force; participants are civilians (scientists, lawyers, journalists; majority women); firearms referenced in the case file were lawfully registered, and a court ordered their return. (see Exhibits B01, A01–A02)

• Harm, victims, concrete acts: The prosecution identifies no victims, no harm and no completed criminal acts; the case relies on interpretation of speech rather than conduct.

• Witnesses and risk: The only two witnesses are abroad and unavailable, as conceded in court; claims of witness-tampering risk are therefore unsubstantiated. (see Exhibits E01–E02)

(Cross-references: Chronology items 16 Mar 2023; Apr 2024; 12 Sep 2024; MoJ opinion 27 Feb 2025; Witnesses 10 Jun 2025.)

• Articles 9, 10 and 14 of the ICCPR: liberty and security of person; humane treatment; fair-trial guarantees (pre-trial detention as a measure of last resort; least-restrictive alternatives; periodic judicial review).

• Articles 18 and 19 of the ICCPR: freedom of thought, conscience and religion; freedom of expression (non-public, conditional discussions; restrictions must meet legality, necessity and proportionality).

• Standards on legal assistance and confidentiality: protection of attorney–client communications; effective access to counsel.

• Detention conditions: Mandela Rules 24-27; equivalence of medical care. In these circumstances, continued remand in SIZO-21 appears medically unsafe and legally unnecessary given the availability of non-custodial measures with conditions.

Legal framework (domestic law):

Criminal Procedure Code of Ukraine (CPC). Articles 176–183 set the regime for preventive measures: the court must prefer less-restrictive alternatives where risks can be managed, with house arrest (Art. 181) and bail (Art. 182) expressly available in place of custody (Art. 183). Article 194 empowers the court to impose tailored obligations (e.g., electronic monitoring, non-contact with witnesses, travel restrictions). Article 199 requires periodic judicial review of any continued pre-trial detention and a reasoned showing that less-restrictive measures remain insufficient.

Under CPC Arts 176–183, custody is exceptional; read together with ECHR Article 5 (Buzadji v. Moldova [GC]), the authorities must justify why bail or house arrest (Arts 181–182 CPC), coupled with tailored obligations (Art 194), is insufficient, and must review that assessment periodically (Art 199 CPC).

Legal framework (European):

Article 5 — Right to liberty and security. Pre-trial detention is an exceptional measure: the authorities must show “relevant and sufficient” reasons, consider less-restrictive alternatives, and conduct ongoing, reasoned review of necessity. The detainee is entitled to prompt judicial control, to trial within a reasonable time or release pending trial, and to take proceedings to challenge the lawfulness of detention (Art. 5(4)). ECtHR case-law (e.g., Buzadji v. Moldova [GC]) confirms a presumption in favour of release once initial grounds lose force.

Article 3 — Prohibition of inhuman or degrading treatment. Absolute in nature. States must ensure conditions of detention and medical care meet minimum standards; a failure to provide adequate treatment for serious conditions (e.g., sleep apnoea, asthma, diabetes), prolonged overcrowding or insanitary conditions can breach Article 3 (see, inter alia, Kudła v. Poland; Muršić v. Croatia). Where health risks cannot be effectively mitigated in custody, non-custodial measures should be preferred. (see Exhibits G01–G02)

A. Current roles & affiliations

• Academician & Presidium Member, European Academy of Sciences of Ukraine (EUASU).

• Head, Odesa Regional Branch of the Ukrainian Academy of Sciences (appointed 28 May 2019).

• Director, Criminological Research Centre; Founder/Head, Expeditionary Corps, G. S. Popov Research Institute of Memory.

• Chair, Odesa Photographic Society; President, Applied Sciences Association (comprising: Research Institute of Memory; Institute for the Study of Global Military Traditions & Forensic Research on the Use of Weapons; International Fate-Analysis Scientific Society).

• Memberships: American Psychological Association (APA); American Philosophical Association (APA); honorary memberships as supplied.

B. Education & fields

• Candidate of Sciences (Psychology); Candidate of Sciences (Philosophy).

• Research areas: applied history; sociology; depth psychology; philosophy; forensic science; criminology.

C. Conferences & expeditions

• Organiser, EUASU international conference Unknown Wars (2022); facilitated a special issue of American Behavioral Scientist for Ukrainian scholars.

• Field expeditions: >40 research trips (Germany, Spain, Sicily/Italy, Switzerland, Greece, Austria, Czech Republic, Belgium, Portugal, USA, Mexico, South Africa).

2015

• 70th Scientific Conference of Professors and Researchers of I. I. Mechnikov Odesa National University (Odesa, 2015) — presenter/participant.

• All-Ukrainian Scientific and Practical Conference (with international participation) Worldview Orientations of the Individual in Contemporary Socio-Cultural Conditions: Interdisciplinary Aspects (Poltava, 2015) — presenter/participant.

2016

• International Scientific and Practical Conference Social, Psychological and Political Problems of Cross-Border Security (Odesa, 2016) — presenter.

• 71st Scientific Conference of the Faculty and Researchers of I. I. Mechnikov Odesa National University (Odesa, 2016) — presenter.

• Fourth International Scientific and Practical Conference Personality Development within the Spatial and Temporal Organisation of the Life Path (Odesa, 2016) — presenter.

• V International Scientific and Practical Conference Socialisation and Resocialisation of Personality in Modern Society (Kyiv, 2016) — presenter.

• International Scientific and Practical Conference Religious Freedom: At the Crossroads of Epochs, Countries and Cultures (Kyiv, 2016) — participant.

• All-Ukrainian Roundtable The Role of Science, Religion and Society in Forming a Morally Sound Personality in Present-Day Ukraine (Rivne, 2016) — participant.

2017

• XIII Kharkiv Students’ Philosophical Readings (255th Anniversary of J. G. Fichte) (Kharkiv, 2017) — speaker.

• First International Interfaith Conference The Role of Religious Values in Strengthening Social Stability and Promoting a Culture of Peaceful Coexistence and Overcoming Hatred (Kyiv, 2017) — participant.

• International Scientific and Practical Conference Dialogue of Cultures and Religions in the Globalised World (Kyiv, 2017) — speaker.

• International Scientific and Theoretical Conference The Globalised World: Challenges of Human Being (Zhytomyr, 2017) — speaker.

• All-Ukrainian Scientific and Practical Conference Man Reforming and Being Reformed (Kyiv, 2017) — participant.

• IV Congress of Young Researchers of Religion Religion in Contemporary Culture (Lviv, 2017) — participant.

2018

• International Scientific Conference Days of Science of the Faculty of Philosophy of Taras Shevchenko National University of Kyiv – 2018 (Kyiv, 2018) — presenter.

• International Scientific and Practical Conference Society, State and Church in the Spectrum of Interdisciplinary Studies (Khmelnytskyi, 2018) — presenter.

2019

• UAS Odesa Branch expert roundtables and public seminars (Odesa, 2019) — convenor/participant.

2020

• International scientific online conference Life in the Post-Apocalyptic Era (15–20 May 2020) — speaker (online).

• International scientific online conference City as a Classroom (23–28 Aug 2020) — speaker (online).

• International scientific online conference Problems of the Source Researcher / Challenges of Source Evaluation in Science and Correlated Areas (23–27 Nov 2020) — programme committee; speaker (online).

• International Online Roundtable on Organised Crime & Criminal Traditions (26–27 Sep 2020) — speaker (online).

2021

• International scientific online conference Sketch a Subculture (21–26 Feb 2021) — speaker (online).

• International Online Roundtable on Organised Crime & Criminal Traditions (28–29 Apr 2021) — speaker (online).

• International Interdisciplinary Conference Real Life and Real Economy (15–20 May 2021) — contributor; panellist (online).

• International scientific online conference The Role of Mentality in Human Life and Culture (8–13 Nov 2021) — speaker (online).

2022

• International scientific conference Unknown Wars (15–19 Jul 2022; hybrid) — organiser; speaker (hybrid: Odesa/remote).

2024

• International conference Local and Global Impacts of the War in Ukraine (Prague, 6–7 Jun 2024) — invited participant/speaker (in-person/remote as scheduled).

D. Selected scholarly books (with ISBN)

• Maltsev, O. V.; Patti, T. Non-Compromised Pendulum: The Book about Cus D’Amato’s Style. EN ed., ISBN 978-617-7696-46-8; RU ed., ISBN 978-617-7599-09-7.
• Maltsev, O. V.; Lopatiuk, I. I. The Work of the Mind in Task Execution Mode. Vol. I. Odesa: Private Publishing House “Patriot”, 2023. ISBN 978-617-8108-00-7 (alt: 6178108001 / 9786178108007). 493 pp.
• Maltsev, O. V. Black Logic (South African Criminal Knife Tradition, Vol. 2). ISBN 978-617-7599-48-6.
• Maltsev, O. V. 54 (South African Criminal Tradition, Vol. 3). RU ISBN 978-617-7599-40-0; EN ISBN 978-617-7599-43-1.
• Maltsev, O. V. On Your Knives: Knife in the Russian Criminal Tradition (Russian Criminal Tradition, Vol. 1). ISBN 978-617-7599-44-8.
• Maltsev, O. V. Deceptive Silence: Study of the Calabrian Criminal Tradition. ISBN 978-617-7599-95-0.
• Maltsev, O. V. Maestro: Jean Baudrillard — The Last Prophet of Europe. ISBN 978-617-95114-3-1.
• [Edited volume] Real Life and Real Economics: International Interdisciplinary Conference. Accent Graphics & Communications. ISBN 978-1-77192-604-1.

E. Research monographs

• Scientific Environment of the Contemporary Individual: Education and Upbringing, Philosophy, Culture and Art, Jurisprudence, History, Architecture and Construction — monograph (chapter contribution by O. V. Maltsev, Ch. 13). Odesa: Kuprienko SV, 2018. 169 pp. ISBN 978-617-7414-29-1.
  Role: co-authored chapter (Research Institute of World Traditions of Martial Arts and Criminal Studies of the Use of Weapons).

• Theoretical Foundations of the Premeditated Murder Investigation. Psychological Portrait of a Serial Killer: Criminal Law, Forensic and Psychological Aspects — monograph. Maltsev, O. V.; Sainchin, O. S.; Sotula, O. S. Ottawa: Accent Graphics & Communications, 2019. ISBN 978-1-77192-485-6 (also 1771924853).

• Photography as a Source of Scientific Research Data — monograph. Maltsev, O. V.; Lepsky, M. V.; Samsonov, A. V. Dnipro: Serednyak T. K., 2020. 322 pp. ISBN 978-617-7822-72-0.

• Philosophy of Southern Italy — monograph. Maltsev, O. V.; Luniov, V. E. Dnipro: Serednyak T. K., 2020. 443 pp. ISBN 978-617-7822-50-8.

• How I Was Forced to Study the Psychology of Europe: ‘The Moment of Truth’ — monograph. Maltsev, O. V. Dnipro: Serednyak T. K., 2020. 360 pp. ISBN 978-617-7822-84-3.

• Invisible Angel: What to Photograph — monograph. Maltsev, O. V.; Lepsky, M. V.; Samsonov, A. V. Odesa, 2020. 274 pp. ISBN 978-617-95051-4-0.

• The Secret of the Third Order — monograph. Maltsev, O.; Yavtushenko, O. Odesa, 2021. 341 pp. ISBN 978-617-95051-8-8.

• The Robinson Crusoe Effect — monograph (under the scientific supervision of O. V. Maltsev). Havrylenko, I. M.; Lopatiuk, I. I. 2022. 471 pp. ISBN 978-617-95051-9-5.
  Role: scientific supervisor.

• The Work of the Mind in Task Execution Mode. Vol. I — monograph. Maltsev, O. V.; Lopatiuk, I. I. Odesa: Private Publishing House “Patriot”, 2023. 493 pp. ISBN 978-617-8108-00-7 (alt: 6178108001 / 9786178108007).
  Note: also listed in Section D. Selected scholarly books.

• How to Become a World Champion in Five Years — monograph. Maltsev, O. V. Odesa, 2023. 409 pp. ISBN 978-617-8108-04-5.

• Consciousness. Theory of Training. Vol. 2 — monograph. Maltsev, O. V.; Lopatiuk, I. I. 2023. 202 pp. ISBN 978-617-8108-03-8.

F. Peer-reviewed journal articles (American Behavioral Scientist — SAGE; with DOIs)

1. Does Ukraine Have the Right to be an EU Member? American Behavioral Scientist, 67(3), 2023. DOI: 10.1177/00027642221144818.
2. War Crimes: Their Nature and Parameters (with I. I. Lopatyuk). American Behavioral Scientist, 67(3), 2023. DOI: 10.1177/00027642221145029.
3. Editors’ Introduction: Terrorism Through a Different Lens (with H. W. Kushner; K. Tursunbaeva). American Behavioral Scientist, 28 Nov 2023. DOI: 10.1177/00027642231214132.
4. Countering Terrorism: Sociopsychological and Geopolitical Aspects. American Behavioral Scientist, 28 Nov 2023. DOI: 10.1177/00027642231214089.
5. Psychological Underpinnings of Terror Awareness: A Comprehensive Dive into Ukrainians’ Perception of Terrorist Threats Amidst War Tensions (with V. Lunov; M. Matiash; V. Mosiichuk; B. Tkach). American Behavioral Scientist, 3 Dec 2023. DOI: 10.1177/00027642231214083.
6. The Impact of Russian Military Aggression on the Psychological Health of Ukrainian Youth (co-authored). American Behavioral Scientist, 2023. DOI: 10.1177/00027642221144846.

G. Critical reception and endorsements

G1. Press reviews and coverage — Non-Compromised Pendulum (Maltsev & Patti)

• World of Martial Arts (US/UK). Dr Antonio Graceffo calls the book ‘an important lens’ on Cus D’Amato’s coaching system, drawing parallels with The Art of War and The Book of Five Rings, and highlighting the practical concept ‘2+3=5’.

• La Voce di New York (NY, USA). Coverage emphasises D’Amato’s psychological–philosophical approach and the detailed breakdown of technical elements (with Tom Patti’s contribution).

• Sports Illustrated (USA). A note by Kaelen Jones states the book ‘documents the ideology and scholarly merits’ of D’Amato’s method and records an effort to preserve his legacy.

• World Boxing News (UK). Feature on the English-language release describes a ‘comprehensive account’ of D’Amato’s system and cites historian Steve Lott (Las Vegas Boxing Hall of Fame).

G2. Endorsements — The Work of the Mind in Task Execution Mode. Vol. I (2023)

Endorsements were received from the following sport-science and elite-performance figures:

• Yakov Zheleznyak — Olympic champion (shooting).

• Iryna Vynohradova — International Master of Sport; Honoured Coach of Ukraine (shooting sports).

• Svetlana Boikova — International Master of Sport of Ukraine; former member of the USSR and Ukrainian national shooting teams.

• Viktor Bankin — CISM Cadet World Champion; 2022 World Championship medallist.

• Vladyslav Boykov — Master of Sport (fencing); coach at the Olympic Training Centre of Kyiv Oblast; Presidium member, Ukrainian Fencing Federation.

G3. Reviews and scholarly reactions — Strike with the Deadliest Manner Possible (Maltsev & Kushner; foreword by Prof Jerome Krase)

• EUASU international roundtable (26 May 2025). Presentation and discussion of the new book; organisers characterised it as ‘an unprecedented deep examination’ of the evolution of war crimes, including contemporary cases from the war in Ukraine.

  • Dr Harvey W. Kushner (co-author; Chairman of the EUASU Presidium): praised analyses linking PMC Wagner and Camorra, noting the contribution at the intersection of war-crimes and terrorism studies.

  • Prof Jerome (Jerry) Krase (President of EUASU; foreword author): urged policymakers to adopt the book’s ‘difficult perspective’ that challenges simplistic logics and impedes facile claims of ‘just’ conclusions to wars.

Key remarks reported by EUASU News.

• Prof James Finckenauer (Rutgers, criminology): called the book ‘eclectic’ and novel, stressing its central thread on paramilitary organisations reshaping future warfare and blurring lines with terrorism and organised crime.

• Prof Jerome Krase: underlined how state and non-state entities create distance between command-givers and executors to evade accountability — a point the book ‘illustrates very well’.

• Dr Lucien Oulahbib (sociologist): highlighted the notion of ‘soft terrorism’ via state–corporate fusion and media influence; quoted the line, ‘Civilised people are incapable of facing challenges of an uncivilised nature.’

• Dwight Wilson (security expert): noted emerging private military administrations with multi-sector reach; found the book ‘highly relevant’ and recommended it to those seeking to understand what lies ahead.

H. Teaching & community

• 100 academic seminars; multiple international conferences and roundtables under the UAS Odesa branch.

• Founded the Educational & Creative Studio of Journalism (Head: Kim Kanevskyi); produced 50 scientific/educational documentary films.

1. Jerome Krase. Emeritus and Murray Koppelman Professor at Brooklyn College of The City University of New York, and an activist-scholar who works with public and private agencies on urban community issues. President of the European Academy of Sciences of Ukraine. Krase has authored numerous pioneering works on visual sociology and gentrification; his recent books include Diversity in Local Contexts (2017) and COVID-19 in Brooklyn (2022). He co-edits Urbanities and serves on the editorial boards of Visual Studies and the Journal of Video Ethnography. He has received numerous prestigious awards and honors for his contributions to academia, journalism, and community engagement. His work has been recognized globally, spanning research, education, and public service. Citizenship: USA

2. James O. Finckenauer. Distinguished Professor Emeritus at Rutgers. He has served as President of the NJ Council of Educational Institutions for Law Enforcement, the Academy of Criminal Justice Sciences and the International Association for the Study of Organized Crime. He is an Academician of the European Academy of Sciences of Ukraine. He has written and edited a dozen books, along with numerous articles, chapters, and reports, and has overseen the publication of the Journal of Research in Crime and Delinquency and Trends in Organized Crime. Dr. Finckenauer has received prestigious academic awards, held leadership positions in major criminology organizations, and contributed to global research. His impact is reinforced by the U.S. Department of State’s Distinguished Public Service Award and the Outstanding Book Award from the American Society of Criminology. Citizenship: USA

3. Lucien-Samir Oulahbib. Writer, lecturer, sociologist, and political scientist. Academician of the European Academy of Sciences of Ukraine and chief editor of the scientific journal Dogma. He spent many years working together with French thinker Jean Baudrillard. He authored numerous scientific papers and books on French nihilism and neo-Leninism, radical Islamism, anti-Americanism, and antisemitism. In the past, he was a reporter and host at Radio Canal 75. Oulahbib was also an editor of Magazine Sans Nom, Citizen K., and Technikart, and worked as a freelance journalist for Esprit Critique, Dogma, Marianne, and Tumulte. Citizenship: France

4. Avi Nardia. An expert in the field of security. Master of martial arts. For 24 years he served as an official hand-to-hand combat instructor, security officer, and also served in the Special Anti-Terrorism Unit. Citizenship: USA

5. Dwight Wilson. Security professional with over a decade of experience in the private security industry, specializing in protecting high-profile clients and operating in high-risk environments. He is a Corresponding Member of the European Academy of Sciences of Ukraine and the author of several scientific articles on security, as well as multiple books on human and wildlife tracking. Dwight has worked as a professional tracker and instructor for various government agencies. He holds the title of Guro in Filipino Martial Arts with Rister International Martial Arts and has more than 20 years of experience in the field. Citizenship: USA

6. Oleksandr Suslensky. President of the Jewish Council of Ukraine; President of the Babyn Yar Foundation; Head of the Ukrainian Society for Jewish Culture. Honoured Artist of Ukraine; Academician of the National Academy of Arts of Ukraine; Doctor of Technical Sciences, Professor. Citizenship: Ukraine.

7. Svitlana Boikova. Shooting coach; International Master of Sport of Ukraine. Multiple World, European and Ukrainian champion in individual and team events. Multiple winner and medallist at international tournaments. World record holder (as part of the USSR national team), as well as record holder of Europe and Ukraine. Repeated medallist at the World Military Championships. Multiple champion of the USSR and Ukraine. Citizenship: Ukraine.

8. Daniil Averbukh. Master of Sport in foil fencing; European Championship winner. Coach at the prestigious ASA Jerusalem Fencing Club (Academic Sports Association of Jerusalem). Citizenship: Israel.

9. Vladyslav Boikov. Epee fencing coach; Master of Sport of Ukraine. Citizenship: Ukraine.

10. Mark McKinley. FAA A&P mechanic/engineer with 36 years of experience in commercial heavy aviation. Bachelor of Psychology. FAA multi-engine pilot; flight engineer; FAA A&P mechanic/engineer; EASA A1/B1 certified engineer; NAUI certified diving instructor. Citizenship: USA.

11. Jenny Schmeikhilman. Planner at Lake Medical Imaging (Leesburg, Florida 34748). Citizenship: USA.

12. Giorgi Vachnadze. Philosopher and researcher. MA, KU Leuven; BA, New Mexico State University. Currently teaching English and American literature at the European School, Tbilisi. Former editor and reviewer of the postgraduate philosophy journal Abrikos, with publications in numerous popular and academic journals worldwide. Research focus: philosophy of language and discourse analysis. Citizenship: Georgia.

13. Italo Pardo. Emeritus Professor of Social Anthropology, University of Kent, UK. Founder and President of the International Urban Symposium (IUS). Long-standing member of the Association of Social Anthropologists of the Commonwealth and other bodies. Co-founder and editor of Urbanities – Journal of Urban Ethnography. Author of numerous articles and books; founder and editor of several academic book series in anthropology. Academician of EUASU. Citizenship: United Kingdom.

14. Giuliana B. Prato. Emeritus Professor of Social Anthropology, University of Kent, School of Social Sciences. Former Chair of the Commission on Urban Anthropology (IUAES). Co-founder and Secretary-Treasurer of the International Urban Symposium (IUS). Co-founder (with Prof. Italo Pardo) and editor of Urbanities, Journal of Urban Ethnography. Author of numerous articles and books; founder and editor of several anthropological book series. Academician of EUASU. Citizenship: United Kingdom.

15. Ketil Haugsand. Emeritus Professor of Harpsichord, Hochschule für Musik Köln. Considered one of the foremost harpsichordists and early-music performers of our time. Has appeared as soloist, chamber musician, and conductor with leading ensembles including the Norwegian Baroque Orchestra, Norwegian Radio Orchestra, Stavanger Symphony, Lyra Ensemble, Real-Art Ensemble, and Berlin Komische Oper. Performed across Europe, USA, Israel and the Far East. Chamber partners included Laurence Dreyfus, Wieland Kuijken, Pieter Holtslag and others. Citizenship: Norway.

16. Maksym Lepskyi. Doctor of Philosophy; Professor, Department of Sociology, Zaporizhzhia National University; Academician of the Ukrainian Academy of Sciences; Chair, Research Committee on Social Forecasting, Sociological Association of Ukraine. Citizenship: Ukraine.

17. Anatael Palmero Ramos. Martial arts master; instructor of Canarian tolete. Head of the historic Spanish school Escuela De Artes Marciales Achinech (Canary Islands). Citizenship: Spain (Santa Cruz de Tenerife).

18. Vitalii Luniov. Candidate of Psychological Sciences; Associate Professor; Academician of the Ukrainian Academy of Sciences; Senior Research Fellow, H. S. Kostiuk Institute of Psychology, National Academy of Pedagogical Sciences of Ukraine. Citizenship: Ukraine.

19. Roberto Alcain. Lawyer; Director of Human Resources, Teatro de la Maestranza, Seville. Citizenship: Spain.

20. Alexandra Rivas. Opera singer. Citizenship: Austria.

21. Liudmyla Sedun. Professor of Music, University of Hartford (Connecticut, USA). Pianist and musicologist; lecturer in music history. Graduate of Odesa National A. V. Nezhdanova Academy of Music. Defended a dissertation on accelerated methods for teaching advanced harmony chords to gifted musicians (creator and author of this methodology). Applies her system in the USA to train young talents. Composer of classical music, including instrumental works in tango and classical blues. Citizenship: USA.

22. Marco Andreacchio. PhD, University of Illinois (East-Asian philosophy in dialogue with Western thought); PhD, University of Cambridge (Platonic interpretation of religious authority in Dante). Lecturer at multiple institutions; frequent publications in political philosophy. Editorial board member, Dogma journal. Citizenship: USA.

23. Alex Maisey. Award-winning author. Recipient of the Roy Fisher Prize (Keele University, 2018) and Creative Future Writers’ Award (2019). Visiting researcher in sociology and postmodern theory for Baudrillard Now. Author of Living in Disneyland and Sad Boy Aesthetics. Debut poetry collection Ghost Lives: Cursed Edition published in 2024. Citizenship: United Kingdom.

24. Judith N. DeSena. PhD in Sociology; Professor of Sociology, St John’s University, New York. Research focus: neighbourhood studies, race/class/gender inequalities, gentrification. Author of Protecting One’s Turf (1990, 2005), People’s Power (1999), and co-editor of The World in Brooklyn (2012). Editor of Gender in an Urban World (2008). Co-editor (with Jerome Krase) of Race, Class and Gentrification in Brooklyn (2016) and Gentrification Around the World (2020). Latest book: COVID-19 in Brooklyn (Routledge, 2023). Citizenship: USA.

25. Bruno Fournier. Fashion and advertising photographer. Published fashion series in French and international magazines (Jalouse, Marie-Claire, Icon, Urban, Flaunt, Qvest). Known for dynamic imagery that animates clothing. Citizenship: France.

26. Frederic Conrod. PhD in Comparative Literature. Studied Religious Studies at Allegheny College (Pennsylvania, USA); doctoral work in Spanish and French literature and film, University of Colorado at Boulder. Professor of Comparative Literature, Florida Atlantic University. Research examines the interaction between religion and culture in literary spaces. Citizenship: USA.

27. Andy Ibbott. Internationally recognised motorcycle coach, speaker, athlete, journalist and former Road Test Editor at Motor Cycle News. First UK coach engaged by the California Superbike School (Silverstone, Rockingham, Cadwell Park). Citizenship: United Kingdom.

28. Israel Gorelik. Tour guide. Citizenship: Israel.

29. Mark Horvath. Philosopher and researcher based in Budapest. Co-founder (with Adam Lovasz) and co-editor of Absentology (philosophy and speculative science) and Poli-p (Hungarian posthumanist collective). Research interests: posthumanism, digital studies, speculative realism, pessimism, nihilism, finitude and the Anthropocene. Author of 13 books, including two monographs in English. Citizenship: Hungary

30. Ahmet Dag. Professor, Faculty of Theology, Bursa Uludag University. BA, Atatürk University (1999). MA, Marmara University (2009), thesis on Baudrillard’s concept of simulation. PhD, Kırklareli University (2015), dissertation on religion, ethics and politics in Hume. Research areas: Turkish-Islamic thought, Western philosophy, contemporary philosophy, 21st-century philosophy, digitalisation, modern/postmodern, transhumanism, posthumanism, artificial intelligence. Citizenship: Turkey.

Official statement by the defence in the case of the scholar Dr Oleg Maltsev

In view of the prosecution in this case—represented by Ruslan Voitov of the Odesa Regional Prosecutor’s Office—artificially delaying the proceedings and preventing the court from moving to an examination of the “evidence of guilt” of our clients, while they have already spent almost a year in custody on unfounded charges and supposed “risks”, we have taken the following decision.

At every hearing that fails to take place because of fresh procedural manoeuvres by the prosecution—such as the absence of the prosecutor or interpreter, or the prosecutor’s wish to spend four hearings merely droning through the indictment, with which we are fully familiar—we will begin to place in the public domain the evidence of our clients’ innocence. According to the inventory signed by Prosecutor R. Voitov pursuant to Article 290 of the Criminal Procedure Code of Ukraine, there are 1,359 such items.

If “the mountain will not come to Mohammed”, then we shall come to you.

Defence counsel

• For Oleg Viktorovych Maltsev — Olha Panchenko; Yevheniia Tarasenko

• For Maryna Illiusha — Olena Babikova; Olha Panchenko

• For Serhii Engelmann — Oleksandr Babikov

• For Kostiantyn Slobodianyuk — Ihor Fedorenko

• For Anna Filippova, Maryna Hebesht, Olena Klimanova — Olha Panchenko

001

002

Methodology (editorial note). This annex relies on primary judicial records, official correspondence, medical documentation, independent forensic expertise, and contemporaneous media/NGO reports. Each material fact is referenced to a primary record where available; defence submissions are identified as such. Personally identifiable information is redacted where not strictly necessary. All exhibits are listed in the Exhibit List with preserved metadata; hashes available on request.

Neutrality rider. Where individual officials are named, allegations are presented as reported by defence counsel and civil-society submissions; the presumption of innocence applies. Requests for official comment have been or will be transmitted to the relevant bodies.

A — Court decisions & enforcement

Exhibit A01 — Trial court order on property arrest (partial) Date: 20 March 2024 • Issuer: Kyivskyi District Court of Odesa (Investigating Judge D.A. Tishko) • File ref: Case № 947/7336/24; Proceedings № 1-кс/947/3333/24
Short description: Prosecutor’s motion satisfied in part: arrest imposed on selected electronics/data carriers and other items; arrest refused for lawfully registered sporting/hunting firearms (listed by make/serial), entailing return to the lawful owner.
Cited in sections: I (Chronology: March–April 2024), VI (Ukrainian law & proceedings, item 13).
Key point supported: Binding first-instance refusal to arrest firearms (later upheld on appeal); prolonged non-execution.
Filename: Exhibit_A01_PropertyArrest_Partial_2024-03-20_KyivskyiCourt_ua.pdf

Exhibit A02 — [Court of Appeal confirmation of return order] Date: 11 April 2024 • Issuer: Odesa Court of Appeal • File ref: [№/case-id]
Short description: Appellate court upholds the order to return firearms.
Cited in sections: I (Chronology), VI (Ukrainian law & proceedings, item 14)
Key point supported: Finality/binding nature; subsequent non-execution.
Filename: Exhibit_A02_ReturnOfFirearms_2024-04-11_OdesaCourtOfAppeal_ua.pdf

Exhibit A03 — Peresyp District Court of Odesa, Order on partial seizure (electronics) and refusal to seize lawfully registered firearms (Olha Panchenko), 4 June 2025 Date: 4 June 2025 • Issuer: Peresyp District Court of Odesa (Investigating Judge O. V. Derkachov)
Case/Proceedings: Case No. 523/8177/25 • Proceedings No. 1-кс/523/3208/25 • (within criminal proceeding № 2202516000000117 of 14 Feb 2025)
Short description: The court partly granted the renewed prosecutorial motion: it imposed arrest (seizure) until 1 August 2025 on the following electronic devices seized on 15 April 2025 — iPhone 12 Pro Max (red, without SIM); Xiaomi smartphone s/n 49466/63XW00644 (turquoise, with lifecell SIM); Xiaomi model 24030PN60G (s/n …F4Q101555), with lifecell SIM; and a MacBook Pro (s/n C02PT1M9FVH7).
At the same time, the court refused to arrest the lawfully registered firearms and related papers, namely: Beretta 686 Silver shotgun (s/n F19490X, in plastic case); FORT-205 carbine 7.62×39 (s/n ВІ073480) with four magazines; licence No. 4884; Unified Arms Register extract (storage/carry for the Beretta); notice of acquisition; as well as a Vodafone SIM-card № 1160788891038 and a lifecell starter pack (scratch card +380934540015).
Cited in sections: I (Chronology: 4 June 2025); III(3) (Arrest of Defence Attorney… — parity/consistency note)
Key point supported: The court drew a clear line between digital carriers potentially relevant to the investigation and lawfully registered firearms, which it declined to treat as items requiring arrest — a material indicator for evidential sufficiency and consistency analysis.
Filename: Exhibit_A03_PeresypCourt_Order_Seizure_Electronics_Refusal_Firearms_Panchenko_2025-06-04_523-8177-25_1кс-523-3208-25_ua.pdf

Exhibit A04 — Odesa Court of Appeal, Ruling upholding first-instance order (Olha Panchenko: partial seizure of electronics; refusal to seize lawfully registered firearms), 18 June 2025 Date: 18 June 2025 • Issuer: Odesa Court of Appeal (Presiding Judge R. I. Kotelevskyi; Judges O. V. Kopitsa, V. V. Kostrytskyi)
Case/Proceedings: Appeal Proceedings No. 11-сс/8131/168/25 • Underlying Case No. 523/8177/25 • Proceedings No. 1-кс/523/3208/25
Short description: The Court of Appeal dismissed both appeals (prosecutor R. H. Voitov and the property owner’s representative adv. O. P. Babikova) and left unchanged the 4 June 2025 Peresyp District Court order: arrest (seizure) remains limited to specified electronic devices until 1 August 2025; the refusal to arrest lawfully registered firearms and related permits/registry papers is upheld. The ruling entered into legal force upon pronouncement and is not subject to cassation. Cited in sections: I (Chronology: 18 June 2025); III(3) (Arrest of Defence Attorney… — parity/consistency note)
Key point supported: Appellate confirmation that lawfully registered firearms were not treated as items requiring arrest, reinforcing the evidential boundary drawn by the first instance.
Filename: Exhibit_A04_Odesa_Court_of_Appeal_Ruling_Upheld_Seizure_Electronics_Refusal_Firearms_Panchenko_2025-06-18_11-cc-8131-168-25_523-8177-25_ua.pdf

Exhibit A05 — Alleged solicitation & SBU Military Counterintelligence correspondence (Dec 2023) Date: 6–8 December 2023 • Issuer: (a) Department of Military Counterintelligence, Security Service of Ukraine (SBU); (b) private email sender “Maltsev Oleg Viktorovych” <[email protected]> to counsel Olha Panchenko <[email protected]>.
Short description: Bundle confirming (i) an official SBU Military Counterintelligence letter signed by Brigadier General Oleksandr Dubrovin inviting counsel to a personal meeting to discuss reported violations; and (ii) email screenshots with full header panes showing a message proposing “assistance in resolving the matter” for payment and asserting that SBU Military Counterintelligence had opened an operational-search case concerning O. Maltsev. Materials were forwarded by counsel to SBU leadership the same day.
Cited in sections: I (Chronology — December 2023); III (Procedural issues — Pressure on the defence).
Key point supported: Evidence of early pressure/solicitation directed at defence; counsel’s immediate reporting to authorities; need for scrutiny of integrity safeguards.

Filename: Exhibit_A05_Extortion_Alert_and_SBU_MCI_Correspondence_2023-12_bundle_ua.pdf

B — Expert opinions on charges

Exhibit B01 — [MoJ “Bokarius” forensic linguistic/semantic analysis] Date: 27 February 2025 • Issuer: NSC “Hon. Prof. M. S. Bokarius” (MoJ) • File ref: [№]
Short description: Multidisciplinary report; no linguistic features of calls to violent overthrow/paramilitary formation; references to self-defence only.
Cited in sections: II (Evidence record: Independent state expertise), Charge–evidence matrix, VI (Independent expert opinion, item 16)
Key point supported: Contradiction with SBU opinions; speech as non-violent/conditional.
Filename: Exhibit_B01_BokariusReport_2025-02-27_MoJ_uk.pdf

Exhibit B02 — [SBU linguistic opinion #1 (Article 109)] Date: 11 September 2024 • Issuer: SBU forensic unit • File ref: [№]
Short description: Opinion alleging incitement to violent overthrow (6 working days).
Cited in sections: II (Prosecution expert), Charge–evidence matrix
Key point supported: Basis for arrest; timing/scope versus MoJ report.
Filename: Exhibit_B02_SBU_LinguisticOpinion_Art109_2024-09-11_ua.pdf

Exhibit B03 — [SBU linguistic opinion #2 (Article 260)] Date: 30 September 2024 • Issuer: SBU forensic unit • File ref: [№]
Short description: Opinion alleging incitement to create an unlawful paramilitary group (19 working days).
Cited in sections: II (Prosecution expert), Charge–evidence matrix
Key point supported: Alternative SBU theory; contrast with MoJ findings.
Filename: Exhibit_B03_SBU_LinguisticOpinion_Art260_2024-09-30_ua.pdf

C — Medical documentation

Exhibit C01 — [St Catherine’s Clinic — ICU admission & discharge summary] Date: 2 July 2024 • Issuer: St Catherine’s Clinic, Odesa • File ref: [№]
Short description: Hypertensive crisis; comorbidities incl. bronchial asthma, diabetes; mobility limitation.
Cited in sections: I (Chronology: 1–6 July 2024), III(7), VI (Medical documentation, item 21)
Key point supported: Heightened medical risk in remand.
Filename: Exhibit_C01_DischargeSummary_2024-07-2_StCatherines_ua.pdf

Exhibit C02 — [Odrex Medical Centre — subsequent admission/assessment]
Date: 6 July 2024 • Issuer: Odrex Medical Centre, Odesa • File ref: [№]
Short description: Post-stabilisation assessment; continuity of care; apnoea subsequently recorded.
Cited in sections: VI (Medical documentation, item 21)
Key point supported: Objectivity/consistency across two clinics.
Filename: Exhibit_C02_Odrex_Assessment_2024-07-06_ua.pdf

D — Procedural documents (LEA/prosecution/registries)

Exhibit D01 — [Shevchenkivskyi District Court of Kyiv — ERDR entry order] Date: 13 August 2025 • Issuer: Shevchenkivskyi District Court of Kyiv • Case: 761/22431/25; Proc.: 1-кс/761/15129/2025
Short description: Court orders DBR to enter application into ERDR and commence investigation (CPC Art. 214).
Cited in sections: I (13 Aug 2025 entry), III(2), VI (Ukrainian law & proceedings, item 15)
Key point supported: Remedy for non-registration; due-process concerns.
Filename: Exhibit_D01_ERDR_Order_2025-08-13_ShevchenkivskyiCourt_ua.pdf

Exhibit D02 — Prosecutor’s resolution re designation of prosecutorial oversight (Barabolia, 29 Aug 2024) Date: 29 August 2024 • Issuer: Odesa Specialised Prosecutor’s Office in the Defence Sphere (Southern Region) • Signer: Prosecutor Artem Barabolia
Case refs: Criminal proceeding № 62024150020000693 (ERDR entry 08.05.2024)
Short description: Formal postanova designating the Odesa Regional Prosecutor’s Office to exercise procedural supervision (процесуальне керівництво) over the pre-trial investigation in proceeding № 62024150020000693; orders (i) entry/updates to ERDR; (ii) transmission of the case materials to the SBU Investigative Division in Odesa Oblast for organisation of the pre-trial investigation; (iii) dispatch of a copy to the Odesa Regional Prosecutor’s Office; notes that complaints against this resolution are not considered at the pre-trial stage.
Cited in sections: III(2) Unlawful change of prosecutorial authority.
Key point supported: Documentary proof of the reassignment of supervising prosecution from the specialised (military/defence) prosecutor to the Odesa Regional Prosecutor’s Office—central to the defence’s argument that the change lacked legal basis.
Language: Ukrainian (original); English working translation on file.
Pages: 3
Filename: Exhibit_D02_Resolution_Prosecutorial_Supervision_Barabolia_29-08-2024_ua.pdf

E — Witnesses & court transcripts

Exhibit E01 — [Court transcript/extract re witness unavailability] Date: 23 June 2025 • Issuer: [Court/Clerk] • File ref: [№/hearing-id]
Short description: Record of statements that both key witnesses are abroad/out of contact.
Cited in sections: III(5), Charge–evidence matrix
Key point supported: No realistic risk of witness tampering.
Filename: Exhibit_E01_Transcript_2025-06-23_WitnessStatus_ua.pdf

Exhibit E02 — Courtroom video & transcript (Primorskyi District Court of Odesa, 10 June 2025): statements by Prosecutor Ruslan Voitov and SBU investigator Maksym Tsurkan on witnesses being abroad/out of contact Date: 10 June 2025 • Issuer/Source: Primorskyi District Court of Odesa (open hearing); recording provided by the defence
Language / format / duration: Ukrainian • MP4 (video) + PDF (verbatim transcript; EN summary optional) • Duration: [to be inserted]
Participants (on the record): Prosecutor Ruslan Voitov (Odesa Regional Prosecutor’s Office); SBU investigator Maksym Tsurkan

Short description: During an open hearing, the prosecutor and investigator state on the record that prosecution witnesses Angela Khamitsevich (Belarus) and Kanykey Tursunbaeva (Kyrgyzstan) are outside Ukraine and out of contact/unknown location. According to the case materials provided to the defence and reviewed for this annex, remand applications for over eight months relied inter alia on a purported risk of interference with witnesses.

Cited in sections:

• I (Chronology) — entry for 04 June 2025 (court hearing)

• III(5) Disappearance of Prosecution Witnesses

• Charge–evidence matrix (Witnesses & risk)

• V (Remedy sought) — reassessment of remand justifications

Key point supported: The asserted witness-tampering risk used to justify continued custody is not borne out by the court record, warranting reconsideration of the necessity and proportionality of remand.

Chain of custody / integrity: Original digital file preserved with device metadata; transcript prepared with time-coded quotations; integrity verified via SHA-256 hash. (Pinpoint timecodes to be inserted after final transcript check.)

Filename(s):

Exhibit_E02_Court_Video_Primorskyi_Odesa_2025-06-10_Witnesses_Abroad_ua.mp4

F — Lawyers’ protection & bar responses

Exhibit F01 — Odesa Court of Appeal, Ruling replacing custody with bail (Olha Panchenko), 25 April 2025 Date: 25 April 2025 • Issuer: Odesa Court of Appeal (Presiding Judge O. V. Kopitsa; Judges R. I. Kotelevskyi, V. V. Kostrytskyi)
Case/Proceedings: Appeal Proceedings No. 11-сс/813/874/25 • Underlying Case No. 522/7397/25 • Proceedings No. 1-кс/522/2676/25 • (within criminal proceeding № 2202516000000117 of 14 Feb 2025)
Short description: The Court of Appeal partly allowed the defence appeals, set aside the Primorskyi District Court order of 17 April 2025 on remand in custody, and replaced custody with bail for Olha Panchenko. Bail fixed at 20 subsistence minima (able-bodied) = UAH 60,560; immediate release ordered upon deposit. The court imposed obligations under CPC Art. 194 until 13 June 2025, including: (i) to appear on request of the investigator/prosecutor/court; (ii) not to leave Odesa Oblast without permission; (iii) to notify of any change of residence/work; (iv) to surrender travel passport(s) to the State Migration Service; and (v) to refrain from contact with witnesses in the case. The ruling entered into legal force upon pronouncement and is not subject to cassation. Cited in sections: I (Chronology: 19–26 Apr 2025 — custody pending appeal; 26 Apr — release on bail) • III(3) (Arrest of Defence Attorney… — parity/consistency note)
Key point supported: Establishes that detention was replaced by bail with standard CPC safeguards; confirms the lawfulness and conditions of Panchenko’s release.
Filename: Exhibit_F01_Odesa_Court_of_Appeal_Bail_Panchenko_2025-04-25_11-cc-813-874-25_522-7397-25_1-ks-522-2676-25_ua.pdf

Exhibit F02 — UNBA/RAU: Working group to monitor violations of lawyers’ rights (re Panchenko)
Date: 16 April 2025 • Issuer: National Bar Association of Ukraine (UNBA) / Council of Bars of Ukraine (RAU)
Short description: Official UNBA/RAU notice announcing a decision to create a working group to monitor and summarise violations of lawyers’ rights and guarantees over the past three years, with explicit reference to the detention of defence attorney Olha Panchenko in the case where she acted as counsel; RAU will also consider addressing the Verkhovna Rada regarding the creation of a Temporary Investigative Commission under Article 89 of the Constitution.
Cited in sections: I (Chronology — 16 Apr 2025), III(3) (Arrest of Defence Attorney Olha Panchenko), VI (Independent expert opinion & civil society).
Key point supported: National Bar-level acknowledgement of pressure on the defence and institutional response; relevance to parity/consistency concerns in the Maltsev proceedings.
Language: Ukrainian (official)
Filename: Exhibit_F02_UNBA_RAU_Working_Group_Monitoring_2025-04-16_ua.pdf
URL (official): https://unba.org.ua/news/10182-rau-stvoryue-robochu-grupu-dlya-monitoringu-porushen-prav-advokativ-ta-rozglyane-mozhlivist-zvernennya-do-vr.html

G — Detention conditions & standards

Exhibit G01 — ECtHR, Zinchenko v. Ukraine (Application no. 63763/11) — Judgment of 13 March 2014 Date: 13 March 2014 • Issuer: European Court of Human Rights (Fifth Section)
Short description: The Court found a violation of Article 3 (degrading treatment) on account of the physical conditions of detention in Odesa SIZO, and a violation of Article 13 for lack of an effective remedy; the applicant complained of overcrowding and poor sanitary facilities.
Cited in sections: III(7); IV (Legal framework); VI (ECtHR case-law)
Key point supported: Authoritative confirmation that conditions in Odesa SIZO fell below Article 3 standards; supports the risk assessment and standards arguments.
Filename: Exhibit_G01_ECtHR_Zinchenko_v_Ukraine_63763-11_Judgment_2014-03-13_en.pdf

Exhibit G02 — Council of Europe — CPT, Report on Ukraine (visit 6–17 Oct 2023; published 26 Apr 2024; CPT/Inf(2024)20) Date (published): 26 April 2024 • Issuer: Committee for the Prevention of Torture (CPT), Council of Europe
Short description: Records particularly dire conditions at Odesa SIZO, with elements liable to amount to inhuman or degrading treatment; highlights deficits in accommodation, sanitation, ventilation/light and medical staffing, and issues urgent recommendations.
Cited in sections: III(7); IV (Legal framework — Article 3 context); VI (Detention conditions & standards)
Key point supported: Independent, authoritative assessment of Odesa SIZO conditions and the urgency of remedial measures.
Filename: Exhibit_G02_CPT_Report_Ukraine_Visit_2023-10_Published_2024-04-26_CPTInf2024-20_en.pdf

H — Context & government guidance

Exhibit H01 — [Civil Resistance in Occupied Territories (pocketbook)] Date: 28 March 2022 • Issuer: Center of National Resistance (SSO/MoD of Ukraine)
Short description: Official guidance for civilians under occupation; includes improvised-weapons knowledge and self-defence as last resort.
Cited in sections: Summary (Context note, fn. 1), VI (Government guidance, item 22)
Key point supported: Contextual legality/necessity/proportionality of conditional planning.
Filename: Exhibit_H01_CivilResistancePocketbook_2022-03-28_MOD_UA.pdf

International instruments & standards

1. International Covenant on Civil and Political Rights (ICCPR) — Arts. 9, 10, 14, 18, 19. Liberty, humane treatment, fair trial; thought, conscience and expression.

2. UN Human Rights Committee, General Comment No. 35 (Art. 9) and No. 34 (Art. 19). Pre-trial detention as last resort; legality/necessity/proportionality of speech restrictions.

3. UN Standard Minimum Rules for the Treatment of Prisoners (Nelson Mandela Rules) (2015). Equivalence and continuity of medical care; record-keeping and safeguards.

4. UN Basic Principles on the Role of Lawyers (1990). Confidentiality; protection from interference in lawyers’ work.

5. Council of Europe: European Prison Rules (Rec(2006)2, as revised). Detention conditions; healthcare standards.

ECtHR case-law (illustrative)

6. Buzadji v. Moldova (GC, 2016). Presumption in favour of release as time passes; need for “relevant and sufficient” reasons.

7. Muršić v. Croatia (GC, 2016). Overcrowding and minimum personal space; Article 3 threshold.

8. Kudła v. Poland (GC, 2000). Positive obligations on healthcare in detention; Article 3/13 interplay.

9. Kharchenko v. Ukraine (2011). Systemic issues with Article 5 in Ukraine; reasoning and time-limits for remand.

10. Selected ECtHR judgments on Ukraine re SIZO medical care/conditions (e.g., Melnik v. Ukraine, Yakovenko v. Ukraine). Continuity of treatment; conditions breaching Art. 3.

Ukrainian law & proceedings

11. Criminal Procedure Code of Ukraine (CPC) — Arts. 176–183, 194, 199. Hierarchy of preventive measures; tailored obligations; periodic judicial review.

12. Criminal Code of Ukraine (CCU) — Arts. 109, 260. Charges referenced in this case.

13. Kyivskyi District Court of Odesa (March 2024) — order to return lawfully registered firearms. Property rights; enforcement issues.

14. Odesa Court of Appeal (April 2024) — appellate confirmation of the return order. Finality and binding nature of return; subsequent non-execution.

15. Shevchenkivskyi District Court of Kyiv (13 Aug 2025) — order to enter data into the ERDR and commence investigation (re alleged SBU MCI offences). Judicial remedy against non-registration (CPC Art. 214).

Independent expert opinion & civil society

16. National Scientific Centre “Hon. Prof. M. S. Bokarius” Forensic Science Institute (MoJ) — 27 Feb 2025 linguistic/semantic report. No linguistic features of calls to violent overthrow or paramilitary formation; references to self-defence only.

17. CAP/Liberté de Conscience — Oral statement to UN Human Rights Council (Session 58), 28 Mar 2025. Call for impartial investigation; identifies alleged orchestrator.

18. Human Rights Without Frontiers (HRWF) — Public note, 18 Nov 2024. Early third-party alert of possible fabrication; due-process concerns.

19. Ukrainian National Bar Association / Council of Advocates of Ukraine — statements, 16–26 Apr 2025 (re detention of defence counsel). Protection of lawyers’ professional rights; call for parliamentary TIC.

Medical documentation (context)

20. Odesa City Clinical Hospital No. 1 (“Jewish Hospital”) — correspondence of 20 Aug 2025 (with patient consent). Disputed consultation conclusion; alleged omissions and document integrity concerns.

21. St Catherine’s Clinic, Odesa — ICU admission and diagnoses (1–6 July 2024); subsequent admission to Odrex Medical Centre, Odesa. Emergency hospitalisation for hypertensive crisis; following stabilisation at St Catherine’s, Dr Maltsev was admitted to Odrex for further assessment and care. Documented comorbidities include bronchial asthma and diabetes, with obstructive sleep apnoea subsequently recorded; temporary mobility limitation. Medical records and diagnostic findings from both clinics are available, reinforcing the objectivity of the diagnoses and the assessment of the severity of Dr Maltsev’s conditions.

Government guidance (Ukraine: MoD / Special Operations Forces)

22. Center of National Resistance (Special Operations Forces, Ministry of Defence of Ukraine), Civil Resistance in Occupied Territories (pocketbook), 28 March 2022. Official guidance for civilians under occupation and clandestine organisation: operational security, basic medical guidance, non-violent resistance and community protection; explicitly references knowledge of improvised weapons and self-defence as a last-resort measure, alongside a safety notice to delete or securely store the PDF after reading.