The Text of the Lawsuit Against Jiang Zemin

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The Text of the Lawsuit Against Jiang Zemin

November 05, 2000

COMPLAINT Two Litigants names are omitted Plaintiffs Vs. Jiang Zemin, Male, President of the People's Republic of China, Secretary General of Chinese Communist Party, President of National Military Committee Zeng Qinhong, Male. Member of Standing Committee, Central government of the People's Republic of China, Chief of the Secretariat of the Chinese Communist Party, Minister of the Ministry of Human Resources and Personnel Luo Gan, Male, Member of State Council, Secretary of Political and Legal Committee of the State Council ________________________________________________________________

Nature of the Complaint Jiang Zemin, Zeng Qinhong and Luo Gan have severely damaged our national image and social morality, undermined government system, and violated the Constitution and laws through their all-out efforts to persecute Falun Gong practitioners. Their action and its impact have brought about immeasurable detriments to our nation, society and people, and thus, they shall be tried and judged according to the law to avoid further damage. The plaintiffs demand:

Withdraw and cancel the following:

a. Personal arrest warrant (Warrant # 19990102) on Mr. Li Hongzhi, founder of Falun Gong. The warrant was issued to all provinces, autonomous regions and municipality directly under the Central Government by China National Security Ministry on July 29, 1999 authorized by Jiang Zemin, Zeng Qinhong and Luo Gan in the name of government action, b. The "General Notice" issued by China National Security Ministry on July 20, 1999, which was in violation of the constitution; and c. Any other conclusions, regulations, bans, orders and constraints unfairly and illegally imposed on Falun Gong and Falun Gong practitioners;

Immediate release of all Falun Gong practitioners being detained, educated through labor, and sentenced to jail terms, and process of their rehabilitation according to law and regulation;
Allow legal publication and distribution of Falun Gong books and video/audio materials;
Prosecute Jiang Zemin, Zeng Qinhong and Luo Gan for their legal and criminal liabilities under the law;
Order the defendants to publicly apologize to citizens penalized by them, and to compensate the victims' economic loss and mental distress;
Prosecute those who followed Jiang Zemin, Zeng Qinhong and Luo Gan and engaged in plotting against and framing-up Falun Gong, and those who participated in arresting, physically abusing, and torturing Falun Gong practitioners, for their legal liabilities.

STATEMENT OF FACTS AND CAUSATIONS SINCE May 1992, particularly since July, 1999, Jiang Zemin, Zeng Qinhong and Luo Gan, and those who followed them have conducted brutal suppression of Falun Gong in the name of the nation and government in order to maintain and procure their personal powers and interests in the government. The "evil cult" label they put on Falun Gong and so called facts and conclusions thereof were fabricated by the defendants after careful plotting. Their illegal fabrication of false evidence and framing-up of Falun Gong resulted in several hundreds of thousands Falun Gong practitioners' arrests, detention, labor camp sentences and prison term sentences. Among them, more than 50 practitioners were murdered and tortured to death. More practitioners were persecuted inhumanely resulting in their grievous bodily injury, disfigurement and dismemberment. Countless practitioners' family were forcefully separated and destroyed. WE HEREBY request the Supreme Procuratorate of the People's Republic of China to investigate and prosecute Jiang Zemin, Zeng Qinhong and Luo Gan, et al and for their legal and criminal liabilities under the law, invalidate any and all conclusions, regulations, bans, orders and constraints unfairly and illegally imposed on Falun Gong and Falun Gong practitioners, release immediately all Falun Gong practitioners now detained, educated through labor, and sentenced to jail terms, and process their rehabilitation according to law and regulation. Ground for this Complaints

Falun Gong has been righteous since Mr. Li Hongzhi made it known in 1992:
Mr. Li Hongzhi is the first person to reveal "Truthfulness-Compassion-Forbearance" to be the highest characteristic of the Universe, and Falun Gong is the supreme method to uplift people's morality and improve their health, thus, it is beneficial and harmless to the country and people;
Falun Gong is righteous and beneficial to people of the world.
Truth of Appealing by Practitioners at Zhongnanhai, the Central Government Compound.

He Zuoxiu of the Chinese Academy of Science published an extremely defamatory article against Falun Gong in a magazine by Tianjin College of Education. A group of practitioners went to the college to clarify the truth about Falun Gong and request the magazine to publish a correct notice on this untruthful report by He Zuoxiu. Article 38 of the Constitution states: " The personal dignity of citizens of the People's Republic of China is inviolable. Insult, libel, false accusation or false incrimination directed against citizens by any means is prohibited. " Therefore, He Zhuoxiu's action in intentionally writing and publishing the slanderous article was against the Constitution, and the peaceful reasoning by the Tianjin practitioners was to protect the right for human dignity of a citizen under the Constitution and therefore legal. It was against the criminal law and procedure for Tianjin city police to disperse and assault the practitioners, and to arrest forty five of them. Tianjin Police Bureau also rejected the request from practitioners to release the unlawfully arrested practitioners. At the time, practitioners had no one to turn but seek help from the Central Government in Zhongnanhai. There weren't tens of thousands of them at the beginning. More people showed up because the Central Government also refused to receive any practitioners. Article 37 of the Constitution provides: " Freedom of the person of citizens of the People's Republic of China is inviolable. No citizens may be arrested except with the approval or by decision of a people's procuratorate or by decision of a people's court, and arrests must be made by a public security organ. Unlawful detention or deprivation or restriction of citizens' freedom of the person by other means is prohibited, and unlawful search of the person of citizens is prohibited. " Therefore, it was obviously unlawful for Tianjin police to arrest and ill-treat the practitioners who violated no law of this country. In addition, Article 41 of the Constitution provides that " Citizens of the People's Republic of China have the right to criticize and make suggestions regarding any state organ or functionary. Citizens have the right to make to relevant state organs complaints or charges against, or exposures of, any state organ or functionary for violation of the law or dereliction of duty, but fabrication or distortion of facts for purposes of libel or false incrimination is prohibited. The state organ concerned must deal with complaints, charges or exposures made by citizens in a responsible manner after ascertaining the facts. No one may suppress such complaints, charges and exposures or retaliate against the citizens making them. Citizens who have suffered losses as a result of infringement of their civic rights by any state organ or functionary have the right to compensation in accordance with the law. " Practitioners at Zhongnanhai, in several dozens or tens of thousands, did not shout slogans, or block traffic, or have any uncivilized behaviors or remarks. They merely stood on sidewalks, quietly waiting for the government authority's decision on this matter. In middle of June 1999, China Central Television (CCTV) announced several main points from the discussion between practitioners and the officials from the Communist Party, State Council and Bureau of Complaint-processing. The main points indicated that there were rumors among practitioners that "The Public Security Bureau was going to suppress the Falun Gong and those practitioners who are Communist Party members or the Communist Youth League members or government employees would be expelled from the Party or the League, or be removed from government positions; the announcement also indicated another rumor that the "Chinese government was going to use 500 million dollars trade surplus to have Mr. So and So extradited." The government warned that "no one should believe in these ridiculous rumors." The main points also included that "the Communist Party and government has a clear policy to people who participate in activities of healing and fitness," and that "they announced their policy on April 25 of this year when Falun Gong practitioners gathered at Zhongnanhai." They also claimed that "they later printed and disseminated the 'Key Points on Propaganda and Education,' where they further established their policy." The announcement stated, one more time, their policy; all levels of governments have never banned any fitness activities. People have the freedom to believe in any form of cultivation exercise and the freedom to not believe certain exercise method; it is normal to have different opinions and viewpoints, and people should report their opinions through normal channels and manners." Millions of Falun Gong practitioners and other people believed that the above policy represented where the government stood on this issue.

Jiang Zeming Reversed the Government Official Statements and Labeled Falun Gong "Evil Cult," in an Attempt to Serve his Personal Interest and Maintain his Political Power, Showing no Concern of the Interest of People and Reputation of the Government. He Violated the Constitution of the People's Republic of China.

Soon after the government announcement that recognized the legality of Falun Dafa practitioners, it suddenly reversed its position on July 20, 1999. The rumors claimed by the government then became reality. As a matter of fact, Jiang Zeming was very upset with the Zhongnanhai appeal by practitioners because he believed that this incident made him lose face as the President. He also feared the reoccurrence of the similar action by Falun Gong practitioners or other social groups so that his political position and power could be endangered. He called upon Zeng Qinhong, his so-called advisor, and Luo Gan, to secretly lay out a plan for series actions to destroy Falun Gong once for all. Ministry of Civil Administration first announced that "Falun Gong is an illegal organization." Then Communist Party Central Committee announced that "Communist Party members and Communist Youth League members shall sever their relationship with Falun Gong." In the meantime, Ministry of Public Security issued the arrest warrant on Mr. Li Hongzhi and started arresting practitioners nationwide. Jiang Zemin, without decision from the People's Procuratorate, or court, or congress, made a remark to a French newspaper reporter that "Falun Gong is an evil cult harmful to society and people.'" His inappropriate and also unlawful remark was copied by other government agencies and by the media resulting an all-out media propaganda campaign against Falun Gong founder and practitioners. Public Security Bureau was arresting and detaining anyone who practiced Falun Gong without any legal basis, legal authority and due process of law. Jiang's remark in fact charged and convicted Falun Gong all by himself. Articles 80 and 81 of the Constitution relating to scope of the Presidential power do not confer any power to the President to convict any organization, individuals or a school of cultivation system. Instead, Article 5 clearly states: " No organization or individual is privileged to be beyond the Constitution or the law. " Therefore, Jiang Zemin's remark without a decision or approval or authorization from People's Procuratorate, Court and Congress is a flagrant violation of the Constitution and the law. In Mr. Li Hongzhi's books and the actual practice of millions of practitioners, there is not a shred of evidence to support Jiang's remark. Therefore, the remark constituted slander and defamation against Falun Gong founder and practitioners, which is in violation of Article 51 of the Constitution and Section 101 of the Civil General Provision. [Article 51 of the Constitution: " Citizens of the People's Republic of China, in exercising their freedoms and rights, may not infringe upon the interests of the state, of society or of the collective, or upon the lawful freedoms and rights of other citizens. "] There was no provision in law and regulation of this country that makes it a crime to exercise certain Qigong or participate in religion. Therefore, Jiang Zemin, Zeng Qinhong and Luo Gan used their political power to supercede law to order arrest, detention, torture and sentencing of practitioners nationwide. Their actions not only violated Section 3 of the Criminal Law, they also constituted a severe violation of the Constitution and laws of this country. [Section 3 of the Criminal Law: "If a person's conduct constitutes a crime under specific provisions of law, he shall be charged, convicted and sentenced according to the law; If a person's conduct does not constitute a crime under specific provisions of law, he shall not be charged and convicted."] The preparation to crack down Falun Gong by Jiang Zemin, Zeng Qinhong and Luo Gan started even before the CCTV announcement on government and party policy toward Falun Gong and the practitioners. The three defendants operated the crackdown via regular memo, confidential memo, verbal instruction and order, in total discard of legal procedures. They even issued two memorandums that had conflicting policies. Below is an example. After the Central Government's Memorandum #27 (the above mentioned "main points on the discussion between government officials and practitioners.) was announced on June 14, 1999, officials of Department of Personnel of the Hebei Provincial Government revealed a Provincial Memo [1999]#21 to its Deputy-Chief of the Department, Mr. Xinmu Xu. The Provincial Memo [1999]#21 was on several strict measures in dealing with Falun Gong issue. Mr. Xu noticed the conflicting policies in the Central Government Memo #27 and the provincial one. He requested the Provincial Memo from a clerk who was in charge of the classified documents. Mr. Xu realized the seriousness of the Provincial Memo#21 that would implement an opposite policy against the Memo#27. He decided to report this to the Central Government and to draw their attention to this matter. At 4:00 am of July 20, 1999, police from the city of Shijiazhuang took away Mr. Xu, his wife and daughter from their home, and confiscated all Falun Dafa materials. (They are all practitioners.) The wife and daughter were released after 8 days of detention. Mr. Xu was formally arrested and charged by the Proscuratorate on September 6, 1999 for leaking government classified documents to unauthorized persons. As a matter of common knowledge, a provincial government cannot issue any documents that contradict Central Government's policy, and as a matter of fact, the Provincial Memo[1999]#21 was issued prior to the Central Government Memo #27. Therefore, it is not difficult to see that the Central Government had this harsh policy to deal with Falun Gong long before the CCTV announcement was made. There is no doubt that the Memo#27 was to fool people, while they were preparing an all-out assault against Falun Gong. Jiang Zemin, Zeng Qinhong and Luo Gan gambled with the interest of the state, government and people to reinforce their political power and status, and thus made the government untrustworthy among people. Their actions infringed the interest of Falun Gong founder and the practitioners as well as the interest of the state and government, which constitutes a crime under Article 51 of the Constitution. (Article 51 of the Constitution: " Citizens of the People's Republic of China, in exercising their freedoms and rights, may not infringe upon the interests of the state, of society or of the collective, or upon the lawful freedoms and rights of other citizens. ")

Jiang Zemin, Zeng Qinhong and Luo Gan Manufactured Massive False Evidences to Defame Falun Gong.

We hereby allege to the Supreme Procuratorate of the People's Republic of China and the people that all the evidences Jiang Zemin, Zeng Qinhong and Luo Gan have shown to the people are false. The examples given below are part of the lies from Jiang Zemin, Zeng Qinhong and Luo Gan to demonstrate their total disregard of the truth. Yuan Yuge, a clerk of the city of Renqiu, Hebei Province, fell into a river on her bike in order to avoid a pedestrian. Jiang Zemin, Zeng Qinhong and Luo Gan changed it into a story that she jumped into the Baima River with her baby in her arms because she was insane due to Falun Gong practice. A long-time mental patient murdered his parents while he was in the state of delirium; yet it was turned into a Falun Gong story. A Hokkien young man, driven to insanity under the extreme pressure from making a difficult life, makes another testimony of the smear campaign against Falun Gong. Touted with monetary reward and reimbursement of medical expenses, hospitalized patients were often approached by state-run media body to make false allegation against Falun Gong. Patients were asked to read pre-drafted scripts in front of the video camera. Such blatant violence of moral codes and professional ethics was stunned and despised by many patients. Anything that could be possibly attributed to Falun Gong will be hyper falsified. Those who used to practice Falun Gong out of desperate need to cure critical illness and diseases but failed to achieve the result are often the targets for making false accusation against Falun Gong. Many people served this dishonorable purpose under high pressure from government and/or the lure of monetary compensation. To defame Mr. Li Hongzhi, they even presented an 80-year old midwife as a false witness on Mr. Li Hongzhi's date of birth. This woman, who claimed that she helped Li's mother with the delivery, said she used induced labor for Li's birth in the year when the induction medication had not yet been invented. Such a ridiculous act is like a self-deriding boomerang on those who plotted vile scheme to defame Falun Gong and its founder Mr. Li Hongzhi. Another defamation story that they plotted is to allege that Mr. Li owns a villa, which is a private estate under another individual whose name happened to share the same phonetic name of Mr. Li. (The writing of the Chinese character is different). This villa was purposely shot with close-up and broadcast in national TV campaign against Falun Gong. The smear propaganda claims that Mr. Li Hongzhi has three "filthy expensive houses" in China. This accusation is an outright lie. Mr. Li did have a simple dormitory apartment in Changchun. Private ownership of real estate was not allowed at that time. Mr. Li Hongzhi had to find another apartment to stay in when the old dormitory building was torn down for new construction. Those who have been to that apartment can vouch that there was not even regular electricity and regular water supply in that apartment. Mr. Li Hongzhi's temporary lodging in Beijing, a simple two bedrooms apartment whose ownership doesn't belong to Mr. Li, is also pictured as a "filthy expensive house" in the state-run propaganda. The use of vehicles offered by those who volunteered to assist Mr. Li in his teaching activities in Beijing is also cited to illustrate Mr. Li's "extravagant life style". All of the above fabrications are outright defamation of Mr. Li's personal character. Mr. Li Hongzhi has always been known for his simple, thrifty and personable lifestyle. All the proceeds from running Falun Gong workshops completely went to the further development of Falun Gong teachings. He personally set up principles and guidelines, under which the fund is meant for nothing but Falun Gong development. There were many touching stories about the altruistic character of Mr. Li Hongzhi. When he first started teaching Falun Gong, he quit his job in order to concentrate on the cause completely. He worked tirelessly and ran 50 workshops across the country in two years. He sacrificed many holidays and personal time with his family. His wife independently assumed all responsibilities at home to support her husband's philanthropic cause. There are many other stories about Mr. Li Hongzhi's virtuous characteristics. Mr. Li set up a simple and thrifty lifestyle for the family. He is strict yet also compassionate about his child's upbringing. Once he took his time and bought a pair of shoes for his daughter, his only child, from a street vendor. It cost only RMB 2 Yuan. This is the true picture about Mr. Li's private life in contrast to the prevailing indulgence of the younger generation in China's one-child families. The false allegation on Mr. Li's economic gain is again an outright lie. The Beijing Police Bureau established a special taskforce to collect information and tried in vain to allege that Mr. Li was involved in lucrative undertaking. For example, they investigated the two workshops conducted in the 2^nd branch of Beijing Aviation and Space Bureau. The accounting book shown to the auditor effectively vouched for Mr. Li's personal integrity. The accounting book detailed the following facts: the number of participants attending the two workshops totals nearly 3000, three fourth of which have attended more than once before. New participates were charged RMM40 yuan per person and those who had attended before were charged RMB 20 Yuan. After paying out site fees, and contribution to the Qigong Academy, there was less than RMB 20,000 Yuan remaining as gross profit. There is very marginal net income left after the deduction of cost of printing materials, transportation, and administrative expenses. The well-documented book demonstrated that Mr. Li Hongzhi's Falun Gong teaching is a non-profit undertaking. It is all known that fees charged to attend Falun Gong workshop, which is about one third to even one half lower than average Qigong classes, is the lowest among all Qigong classes across the country. Mr. Li Hongzhi was even asked to raise fees to the average level by the concerned authority. He insisted on the low fee so that more people would be able to afford going his classes. Mr. Li Hongzhi truly established an honorable image for Falun Gong's noble and altruistic nature. The state-run propaganda also accused Mr. Li Hongzhi of tax evasion in his Falun Gong teaching activity. The truth is that all proceeds to Falun Gong Research Institute were taxed since tax responsibility was assumed by parties who organized the workshops. Organizations who invited Mr. Li and organized workshops filed tax reports for all proceeds in return for 40% of the net income. The remaining taxed-income went to the Falun Gong Research Institute. The smear accusation about the proceeds from selling Falun Gong books, video and audio materials is also groundless. The first batch of video exercise teaching tape was produced and sold by China Qigong Research Academy. The second batch of the video tapes were produced and sold by Physical Education Publisher. Later Beijing Television Arts Center started mass production and publishing of Falun Gong books and study materials. Mr. Li Hongzhi and Falun Gong Research Institute were not at all involved in any production and selling of Falun Gong study aids and materials. Only a small amount of loyalty fees were paid to Falun Gong Research Institute. The pricing of Falun Gong books and study materials is also the lowest in the category. The exercises teaching video tape was priced at RMB 55 Yuan (equivalent of US$ 6), about half to one third of that of average price. As more and more people started to get interested in learning Falun Gong, many volunteers helped make copies of the video tapes or sent to shops for duplication. This was to meet the growing demand of the local groups. Falun Gong volunteers strictly adhered to the Falun Gong principles set by Mr. Li Hongzhi by assisting the new comers without seeking any profit or other types of monetary return. All tapes were sold at cost. As for the Falun Gong works, several commercial publishers like China Radio and TV Broadcasting Publishing House officially authorized publishers. Mr. Li Hongzhi and the Falun Gong Research Institute were not involved in any of the printing, publishing, distributing and selling activities. As the author of the Falun Gong works, Mr. Li Hongzhi only received a very small amount of loyalty fees from the publishers. The above facts have demonstrated that Mr. Li Hongzhi, the Falun Gong Research Institute and Falun Gong volunteers are free of the false accusation of being engaged in "illegal money making activity". Rather, the facts suggested that all teaching activity conducted by Mr. Li Hongzhi and Falun Gong Research Institute was not only legitimate, but also highly commendable for the unselfish efforts in serving the public. Truth can never be smothered despite the falsification in the state-run media launched to serve the evil personal agenda by Jiang Zemin, Zeng Qinhong, Luo Gan and the cohorts. Jiang and his political allies have seriously violated the Chinese constitution by steering a smear campaign against Falun Gong through false witness, fabrication, defamation and vicious slandering. A huge amount of money and other resources which would have been used otherwise to benefit the public have been allocated to crackdown the innocent and to suffocate the truth. However, millions of Falun Gong practitioners and their families & friends and the public are not gullible. Jiang's lies can only fool a small number of people who have not been exposed to the truth. As the truth is being revealed to all, Jiang's bubble of lies will break by itself. Jiang Zemin, Zeng Qinhong and Luo Gan employed their political powers and a large amount of state fund and manpower to engineer this massive crackdown on Falun Gong with false evidence and despicable means. They have disgraced our nation image and injured Falun Gong Founder and 100 millions of Practitioners severely. Therefore, we request the Supreme Procuratorate of the People's Republic of China to prosecute Jiang Zemin, Zeng Qinhong and Luo Gan for fabricating false evidence, and to seek remedy for their criminal and civil liabilities.

Jiang Zemin, Zeng Qinhong and Luo Gan Conducted Brutal Crackdown on Falun Gong and Inhumane Torture against Practitioners with total disregard for Law;

(1) In July 1999, the Chinese Government started a full-scaled suppression of Falun Gong, and in October passed a law labeling Falun Gong as "Evil Cult". Since then, the number of Falun Gong practitioners who are detained has increased and some practitioners have been sentenced to more than 10 years in prison. Dozens of practitioners have already died in police custody including an old woman who was beaten to death. Three Falun Gong practitioners studying in Ireland were detained when they were visiting home in China last Christmas, two of whom are still detained as of now.

(2) I am a Falun Dafa practitioner. I went to Tiananmen to uphold Falun Dafa on June 25, 2000. I was thrown into the police vehicle after being beaten brutally. I was then sent to Tiananmen Police Station. Because there were too many practitioners, they transferred me to Shijingshan Stadium in the afternoon. I spent the night in the stadium. The next day, I was baked under the sun in a temperature of 40 C for the entire day. Later, I was transported to the Chaoyang District Detention Center. At around 6:30AM on June 27, interrogation stated. As I did not reveal my name, the investigator slapped me in the face three times. Around 8:00AM, I was interrogated by a different investigator. I informed the second investigator of the beating I received from the first one. He said that they have rules that investigators can not beat people. Evidently, the investigator broke the law by beating people when enforcing the law. After I returned to the detention center, the police instigated the criminals to physically punish me. The policy of the detention center clearly states that no physical punishment and beating is permitted. Isn't it breaking the law while enforcing the law?

(3) Several practitioners including myself went to the Bureau of Appeals together. Upon arriving at the gate of the Bureau, we ran into many policemen who asked us whether we were Falun Gong practitioners. We all answered "Yes." Then, we were immediately taken to the entrance of a courtyard. The police asked where I was from; I did not tell him. One police got angry. He pulled my hair and beat me viciously. Another police punched me and kicked me. The beating didn't stop until they felt tired.

(4) The persecution of Falun Gong practitioners by the Public Security of Yancheng has evidently escalated. Local practitioner Gao Yulan (female) was arrested at her home while she was practicing Falun Gong exercises at 5:00AM on December 31. The police pulled her hair, slapped in her face, kicked her and even pressed her head into the water vat. This lasted for 16 days and the practitioner suffered inhuman tortures.

(5) On New Year's Eve, many Falun Dafa practitioners from Japan, Hong Kong, Korea, etc, practiced Falun Gong exercises in Tiananmen Square. The police beat the practitioners and dragged them onto the police vehicles by beating, kicking and pulling their hair; some journalists were also brought into the police vehicle for taking pictures at the scene and their cameras were confiscated. In Qianmen Police Station, police registered and body-searched the practitioners brought there. Hoping that they could appeal, several practitioners did not give their names and were subsequently locked into a room with "Falun Division" written on the door. They were cruelly beaten. A woman in her 30s was detained for 72 hours and was beaten out of shape with extravasated blood on her eyes and head. Another woman in her 50s had her face and hands beaten by wood clubs numerous times, but this woman still patiently asked the police to read the book "Zhuan Falun". Later, another female practitioner was detained for practicing the Falun Gong exercise (the second set of exercise) on the square. The police used cigarettes to burn her hands.

(6) On July 2, 2000, Beijing is in the intense summer heat; the temperature is 40 C. Tiananmen Police Station has detained more than 300 Dafa practitioners, most of them did not give their names and addresses. The plain-clothed police from the Liaison Offices of different provinces in Beijing continuously went there to take back the practitioners from their provinces. Three of the practitioners were identified by them and they wanted to come in and take the practitioners away. However they could not get close as many practitioners blocked them using their bodies. Therefore, they were enraged. About 5:00PM in the afternoon, the City Police Station dispatched more than 10 thugs. The thugs ran into the practitioners and beat them with police batons. Practitioners including seniors and children were all beaten for no reason. Since we cultivate benevolence, we really did not fight back when beaten. They knocked down a young girl and tore her blouse. They also tore the pants of two young girls. Many practitioners lost their shoes; several seniors were short of breath from the cramming and beating. This lasted for more than half an hour.

(7) On December 31, 1999, 11 practitioners were detained while they were having a picnic at Tianhe Park. In Tianhe Detention Center, Dafa practitioners are forced to work with other prisoners making plastic flowers. There is a quota for each day: those who can not meet the quota will be punished. Practitioners who persisted in practicing Falun Gong were put in shackles. After one practitioner expressed his wish to continue to practice Falun Gong, he was kicked by the warden on his neck and blood spit out immediately. Because the legal rights of the citizens had been infringed upon, some practitioners went on hunger strike. Yet on the following day, they were force-fed with salt water. The inhuman acts were shocking. For example, one of the wardens asked 5 male prisoners to hold down a female practitioner who was on hunger strike, smother her nose using a wet towel. Then, they poured a bag of 500 grams of salt into a cup of water and fed her two bags of salt (1000 grams) consecutively. Because of the high concentration of the salt, this practitioner was suffocated for a while, then threw up grains of salt.

(8) She is a 62-year-old Dafa practitioner from out of town. She wanted to go to Beijing to appeal, to tell the government "Falun Dafa is the righteous Fa", "It is a wrong decision that the government labeled Falun Dafa as an evil cult". On May 13, when she arrived at Tiananmen Square, she saw a police kicking on the stomach of a practitioner on the ground. She went up to intervene and said: "Young man, don't beat people. Beating people is against the law." The police asked:" Who are you?" The old lady answered:" I am a Dafa practitioner." Without saying anything, the police twisted her arms, pushed her onto the police vehicle headed for Dongcheng District Detention Center. She was detained without being charged. During the period of her detention, using her own experience as an example, the old lady explained: Falun Dafa is the righteous Fa, the Fa of mighty virtue which transformed her, a person who often went to hospital for emergency treatments, into a healthy person, etc. She also expressed that she will practice Falun Dafa with firm resolution and demanded that she be released since she was innocent. However, her demand was not approved, so she had to adopt the only approach available in the detention center--hunger strike. One and half days later, after being force-fed, she suddenly fell down, breathed heavily, and her pulse became weaker and weaker. Still, the warden just ignored as if he did not see anything. It was not until after several hours later when two prisoners carried her away. This is the misfortune of another Dafa practitioner since the tragic death of Mei Yulan (who died on May 23, 2000 in the detention center).

(9) We happened to meet a laid-off worker (In China, many workers in the state enterprises are laid-off due to the nationwide economic reform) in front of the Bureau of Appeals of the State Department in Yongdingmen, Beijing. He told us he lived in the neighborhood. Since he had nothing to do after he was laid off, he roamed around near the Bureau everyday since last year. He said he knew very well about Falun Gong here. He told us that we better not to appeal here: the more we appeal, the worse it will get. He said that many Falun Gong practitioners came here to appeal last year, most of whom were from out of town. Shandong and Liaoning Provinces are the worst because they unreasonably beat practitioners, enraging several laid-off workers who lived nearby. A police once touched a female practitioner all over her body with the excuse of searching for Dafa materials. These laid-off workers cut in and beat the police. The police said:" Don't beat me. I'm a police." They replied:" What we want to beat is the police! How dare you bully people!" He said: "since then, the police restrained themselves a little bit." Another time, last winter, a police asked a male practitioner to take off his pants and pulled down to the heels on the excuse of searching for Dafa materials. At that time, he walked over and told the practitioner:" Put your pants on!" This practitioner put them on. The police yelled at the practitioner:" Who allowed you to put your pants on?" He stared at the police and said:" I did!" The police was scared and did not say anything. While we were talking, we saw a plain-clothed police interrogating the people in front of the Bureau one by one. The laid-off worker said:" It is because you are talking to me, otherwise they will also interrogate you. Anyway, the way government treats Falun Gong is condemned by heaven and resented by the people. They will eventually receive retribution for this conduct!"

(10) In the evening of June 24, our nine practitioners from Dingge Villiage, Fangshan District, Beijing were taken by force to the police station in Fangshan District while we were eating at home. The police illegally broke into our houses, beat, cursed at practitioners, pressed us down and handcuffed us. Two Dafa practitioners were beaten so badly that their heads bled and hurt severely. They brought the head of the village as well as all the villagers. At that time, I said to the head of the village that what they were doing was against the law. He said:" I am the local emperor of this village, even the king of hell, upon touching the land of mine has to obey me." I said that he was doing an evil thing. He slapped me in the face, and said boldly and assuredly: " I am violating the law. So what?"

A practitioner carried her 3-year-old daughter in her arms. Her daughter is also a little Dafa practitioner. The police yelled at her, but the little practitioner was very brave and didn't show any fear. This touched the heart of every practitioner. The police yelled, cursed, and beat these practitioners. On the same night, we were handcuffed from the back (two people were handcuffed together) for 6 hours. It was already 2:00AM when the interrogation was finished and we were put into the trunks like merchandise and sent to Public Security at Fangshan District. After we arrived there, we went on hunger strike. The next morning, they asked us to give our names and addresses, but we refused. Later, they pressed me down on the ground, two people dragged me from the room for about 10 meters (I did not wear shoes), and handcuffed me for nearly 2 hours. Later, I told them that they were violating article 258 of the Criminal Law which forbids inquisition by torture, they then released my hands.

We stayed in the Public Security for two days. On the next day, about 9:00AM, a police interrogated me. Because I refused to say anything, he kicked me and slapped me in the face using a flyswatter. The day after, they transferred me to Fangshan Detention Center. Everyday, before the interrogation started, one had to say "Report", if not, one would be beaten and kicked. On the fourth day of the hunger strike, we still did not give our names, therefore, they handcuffed and shackled us and sent us to the hospital to have tubes inserted through our noses. A practitioner whose surname is Jia did not cooperate with them and told them that practitioner Mei Yulan died from the force feeding. The thugs said they would take the responsibility if anyone died. When they tried to insert the tube, Jia used her life to guard Dafa. Then, Jia was handcuffed and shackled onto the bed and force-fed. Jia clenched her teeth tightly so that they could not pry her mouth open even using the pliers. They had to insert the tube through the nose again. Because Jia was handcuffed and shackled onto the bed, she could not move at all. She was force-fed like this for 2 times, actually 3 times since I went there for only 2 times. The first time was through the right nostril, on the second time when the tube was inserted into the left nostril, it was all blocked and could not go in, but the nurse still forced it in. At that moment, I felt extremely painful and felt the tube inserting into my brain. Because it was too difficult to insert, the nurse took it out. Later, the nostrils kept bleeding even after I came back to the detention center. On the fourth night, I could not sleep at all. After the interrogation at about 11:00PM in the evening (because in every interrogation, I just have this to say: I don't want to tell). They had no other way but to ask four of my cellmates to pressure me. Some beat me, some cursed me and some asked me to squat down using all kinds of means, but I insisted on not saying anything.

(11) Yin Shuyun was born on July 21, 1954. She has practiced Falun Gong for 5 years since 1995. On January 1, 2000, she was arrested for practicing Falun Gong on the Cultural Square of Changchun and subsequently detained in the Balibao prison in Changchun for 15 days. On March 6, she was arrested in Beijing and detained in Tiananmen Square Police Station. Because she refused to reveal her name and address, the police viciously beat her and banged her head onto the wall. Her face was so swollen that her eyes couldn't open. Later, she was sent back to Changchun and was sentenced to 1 year of forced-labor education by Chaoyang District Police Station of Changchun and was held in Heizuizi Labor Camp. She died on May 28, 2000.

(12) Falun Dafa practitioner Zhao Xin. The vertebra at the fourth, fifth and sixth joints of her neck were fractured, and she also had injuries on her head and eyes. Until now, she has been under special treatment for nearly half a month. The doctor said she is still in critical condition.

(13) On the night of October 1, 1999, while four of them were doing the Falun Gong sitting meditation exercise, a bunch of cops came in and began to violently punch and kick them. They also beat the practitioners with rubber clubs. They struck Wang Fenglan a few times with the club and then wrapped her up with a telephone cord to electrocute her with an old-style rotary telephone until she fell to the ground and lost consciousness. They hit Zhao Jinhua with a rubber club, then dragged her to the office and shocked her with the telephone. As she was being tortured, they repeatedly asked her if she would stop practicing. The answer was always "No!" Therefore, they continued to torture her in this manner. Three times Zhao Jinhua lost consciousness. Wang Fenglan witnessed all of this. Then the four practitioners were forced to stand barefoot on the concrete ground. Zhao Jinhua could hardly stand up. Her face was a pale yellow. After she fell down with her eyes closed, they sent Zhao Jinhua to a local hospital for emergency treatment. After a doctor gave her an injection, she was taken back to the police station. Zhao Jinhua said she felt pressure in her chest, and that the right side of her body felt numb. She felt a great deal of pain all over her body. There was blood in her urine, pain in both of her legs, and she was unable to eat. Her whole buttock was black and blue from the waist down. Wang Fenglan, Zhan Keyun and Ma Yufeng all witnessed this. The personnel in the police substation Ou Dafu and Fu Shaoxing also witnessed this. The police station did not take any further action to help her. At 4 o'clock in the afternoon on October 7, 1999, when Zhao Jinhua tried to go to the restroom, she fell down right after stepping outside the door. The other three practitioners came to help her but could not get her to stand up. "She gets what she deserves," A policeman named Bing Huachun commented. Finally, when she was pulled to her feet, she wet her pants. The police station sent her again to the emergency room at the local Hospital; the other three practitioners went along. But it was too late. She stopped breathing while medical personnel were doing an electrocardiogram.

(14) On the morning of February 5, the Chinese New Year's Day, dozens of fellow practitioners and I practiced Falun Gong together at the Huairou Park. Before we could finish the second exercise, a group of police pushed us onto the truck and took us to the courtyard of the Detention Center. About 10 minutes later, a group of armed police circled us. Then, they started to take us away to interrogate us. Later, I was given the criminal detention.

As soon as I entered the Detention Center, a few police on duty said, "Since you won't let us have a good New Year's Day, your punishment is to stand outside to freeze in the yard." Then they forced me to take off my cotton-padded trousers and stand barefooted on the icy ground with only underwear on. I stood out there in the cold wind for about one hour and I was not allowed to move. All I could do was to bite my teeth to bear the treatment.

An hour later, the guard allowed me to enter the cell while holding my clothes. As soon as I entered the cell, the guard ordered the inmate criminals to give me a supposed bath, of which about 11 tubs of cold water were poured down on me. It was then followed by their forcing me to recite the rules of the jail and not allowing me to have any breakfast. They gave me two steam buns and half a bowl of soup at 4pm. About 10 minutes later after I had my meal, I was called to the office of the guard. The guard asked me to take off my upper clothes and to lie on the ground. One of them took an electrical club to shock me all over the body. I rolled all over the ground. When I touched the office desk, they would kick and beat me madly. Thus like that, they had shocked me for about one hour. I could not bear this any longer, and screamed "I can not stand it anymore!" They then shocked me more intensely and said, "Would you still continue to practice Falun Gong?" I yelled three times, "Yes! Yes! Yes!" Then they became even more brutal. And then dipped the electrical club into my mouth. I could not bear that kind of suffering and then swung my head with force so that the electrical club got out of my mouth. They then slapped my mouth and used the shoes to slap my face, till my face bled. Another guard asked me to wash my face. However, this guard also asked me to lie on the ground. He sat on a chair and shocked me with the electrical club and sneered, "Which is more capable? Falun Gong or the electrical club?" 5 to 6 minutes later, they sent me back to the cell.

Why in today's society, are there so many people who are inhuman like beasts? If there is one more person practicing Falun Gong, there will be one more good person in the society. Why doesn't the government allow people to learn Falun Gong? The above cases are only a very tiny portion of the actual facts of the persecution of the Falun Gong practitioners.

If it weren't for the orders, commands and instructions from Jiang Zemin, Zeng Qinhong and Luo Gan, the police would not have dared to unleash the brutal physical torture on practitioners. Their bypassing the judiciary and attack Falun Gong using their governmental power violated the Article 5 of the Constitution, which provides: " The state upholds the uniformity and dignity of the socialist legal system. No laws or administrative or local rules and regulations may contravene the Constitution. All state organs, the armed forces, all political parties and public organizations and all enterprises and institutions must abide by the Constitution and the law. All acts in violation of the Constitution and the law must be investigated. No organization or individual is privileged to be beyond the Constitution or the law. " Jiang Zemin, Zeng Qinhong and Luo Gan were aware of their unlawful actions which would result in damage to the interest of the state, government and the people, they nonetheless plotted, ordered and encouraged public security and law enforcement agencies to violate laws of this country. The actions of Jiang Zemin, Zeng Qinhong and Luo Gan are in violation of Article 37, 38, 39, 41 and 51 of the Constitution, Section 75 of the Civil General Provisions, and Sections 13, 14, 243 and 254 of the Criminal Law, and thus constitute commission of crimes. [Article 37 of the Constitution: " Freedom of the person of citizens of the People's Republic of China is inviolable. No citizens may be arrested except with the approval or by decision of a people's procuratorate or by decision of a people's court, and arrests must be made by a public security organ. Unlawful detention or deprivation or restriction of citizens' freedom of the person by other means is prohibited, and unlawful search of the person of citizens is prohibited. " Article 38: " The personal dignity of citizens of the People's Republic of China is inviolable. Insult, libel, false accusation or false incrimination directed against citizens by any means is prohibited. " Article 39: " The residences of citizens of the People's Republic of China are inviolable. Unlawful search of, or intrusion into, a citizen's residence is prohibited. " Article 41: " Citizens of the People's Republic of China have the right to criticize and make suggestions regarding any state organ or functionary. Citizens have the right to make to relevant state organs complaints or charges against, or exposures of, any state organ or functionary for violation of the law or dereliction of duty, but fabrication or distortion of facts for purposes of libel or false incrimination is prohibited. The state organ concerned must deal with complaints, charges or exposures made by citizens in a responsible manner after ascertaining the facts. No one may suppress such complaints, charges and exposures or retaliate against the citizens making them. Citizens who have suffered losses as a result of infringement of their civic rights by any state organ or functionary have the right to compensation in accordance with the law. " Article 51: " Citizens of the People's Republic of China, in exercising their freedoms and rights, may not infringe upon the interests of the state, of society or of the collective, or upon the lawful freedoms and rights of other citizens. " Section 57 of the Civil Law General Provisions: "Personal properties of a citizen include his legal income, house, saving accounts, household contents, cultural relics, books and documents, forest and timber, livestock, and all production materials and other properties permitted by law. A citizen's lawful properties are protected under the law, and it is prohibited for any organizations or individuals to unlawfully trespass, loot, destroy, seal, withheld, freeze or confiscate." Section 13 of the Criminal Law: "All conducts that endanger state sovereignty, and completeness and safety of its land; divide the nation; sabotage the people's democratic rule and overturn the socialist system, undermine social and economic order; infringe on national property, or properties owned collectively by workers, or personal properties of citizens; infringe the personal right, democratic right and other right of citizens; and other conducts harmful to society, shall constitute violation of law and be punishable by law. " Section 14: "One who knows that his act will result in detriment to society, and who hopes the detriment to occur or disregards that it will occur, commits a criminal act, and it is an intentional criminal act. Person who committed intentional criminal act shall be criminally culpable." Section 243: "Anyone who seriously falsifies evidence against another person with the intent to have the person be criminally liable shall be put under criminal detention, or surveillance, or sentenced to a prison term of not more than three years, or in case severe consequences of this crime, sentenced to a prison term not more than ten years but not less than three years. Employees of government agencies who commit the above crime shall be punished more severely. " Section 254: "Employees of government agencies who abuse their power, use their public office for personal gain, frame-up and take revenge on those who complain, appeal, criticize, and report against them shall be put under criminal detention, or sentenced to a prison term of not more than two years. For the serious offenses, the sentence shall increase to not more than seven years but not less than 2 years."] A minority of law enforcement officers in the process of arresting, detaining, and sentencing, brutally tortured, and abused innocent practitioners, which seriously violated the Police Law, Section 22, Provisions 4 through 8, and Prison Law Section 14, Provision 4 through 6, and Sections 16, and 20 through 24. Their actions constitute crimes. [Police Law, Section 22, (4) to (8): "(4). Force confession through interrogation and bodily torture, abuse the prisoner; (5) unlawfully deprive of, or restrict one's freedom of his person, unlawfully search one's person, belongings, his residence or his domain; (6) blackmail, or extort, or accept bribes; (7) beat up, or instigate others to beat up a person; (8) implement physical abuse or collect fees contrary to the law;" Prison Law, Section 14 (4) to (6): "(4). Insult prisoner's personal dignity; (5) assault or encourage others to assault the prisoner; (6). Employ prisoner for labor for personal gain;" Section 16: "When a convicted criminal is delivered for execution of his/her penalties, the delivering people's court shall deliver the photocopy of the charging paper from the people's procuratorate, final judgment from the people's court, notice for execution of the judgment, and case disposition registration concurrently to the prison. Prison facility shall not accept the prisoner without the above documents. If the above documents are not complete, or contain incorrect record, the people's court that made its judgment effective, shall complete the documentation, and correct any errors immediately; If a prisoner can be wrongfully accepted due to the incompleteness of the documentation and incorrect record, such acceptance shall not be allowed." Section 20: "When a prisoner is accepted, the prison shall notify his family member within 5 days of the acceptance." Section 21: "If the prisoner does not agree to the final judgment that has been effective, he may appeal. Peoples procuratorate or people's court shall promptly process the appeal." Section 22: "Prison shall promptly process the complaint, accusation or report, or deliver them to public security bureaus or people's procuratorate. Public Security Bureaus or People's procuratorate shall notify the prison upon reaching decisions." Section 23: "Prison shall promptly deliver prisoner's appeal, accusation or report, which shall not be withheld." Section 24: "Prison believing that a judgment may have been wrongfully entered according to the prisoner's appeal during his prison term, shall request people's procuratorate or people's court to process the appeal. A procuratorate or court shall notify the prison of its decision within 6 months after it receives the request from the prison."] Therefore, we request the Supreme Procuratorate of the People's Republic of China to prosecute Jiang Zemin, Zeng Qinhong and Luo Gan, and other public security officers for their unlawful persecution of Falun Gong practitioners for their personal gains according to the facts and laws stated above, and to seek criminal and civil liabilities.

Since Jiang Zemin, Zeng Qinhong and Luo Gan labeled Falun Gong as "Evil Cult" and implemented their inhumane policy against practitioners, they have irreparably damaged our nation's image and interest.
Actions by Jiang Zemin, Zeng Qinhong and Luo Gan against Falun Gong shall not be tolerated under the principles of law.

Jiang Zemin, Zeng Qinhong and Luo Gan claimed that suppression of Falun Gong was for the country, but they indeed sabotaged our country's democracy and legal system, and in fact maintained their dictatorship and cruel politics. Under these circumstances, if our government and our people are unable to realize this, everything of our country and people shall be destroyed by Jiang Zemin and a small group of his followers. Therefore, we once again request that the Supreme Procuratorate of the People's Republic of China uphold the interest of this nation, and people, and exercise the power given by the country, people and the Constitution, to establish a case against Jiang Zemin, Zeng Qinhong and Luo Gan, to investigate their crimes, to prosecute them and seek their criminal and civil liabilities. It shall be a crime to have them go unpunished. We also request the Supreme Procuratorate of the People's Republic of China to bring this case to trail openly for the entire nation to witness. Other than the allegations and written evidence provided in this complaint, we will call a large number of victims and witnesses in the trial. We again request that the Supreme Procuratorate, according to the principle that all men are equal before law, do justice for millions of Falun Gong practitioner who have suffered despicable tortures known to men.

We hereby demand:

Withdraw and cancel the followings:

Personal arrest warrant (Warrant # 19990102) on Mr. Li Hongzhi, founder of Falun Gong. The warrant was issued to all provinces, autonomous regions and municipality directly under the Central Government by China National Security Ministry on July 29, 1999 authorized by Jiang Zemin, Zeng Qinhong and Luo Gan in the name of government action,
The "General Notice" issued by China National Security Ministry on July 20, 1999, which was in violation of the constitution; and
Any other conclusions, regulations, bans, orders and constraints unfairly and illegally imposed on Falun Gong and Falun Gong practitioners;

Immediate release of all Falun Gong practitioners now detained, educated through labor, and sentenced to jail terms, and process their rehabilitation according to law and regulation;
Allow legal publication and distribution of Falun Gong books and video/audio materials;
Prosecute Jiang Zemin, Zeng Qinhong and Luo Gan for their legal and criminal liabilities under the law;
Order the defendants to publicly apologize to citizens penalized by them, and to compensate the victims' economic loss and mental distress;
Prosecute those who followed Jiang Zemin, Zeng Qinhong and Luo Gan and engaged in plotting against and framing-up Falun Gong, and those who participated in arresting, physically abusing, and torturing Falun Gong practitioners, for their legal liabilities.

In addition, we clarify one more time to the Supreme Procuratorate, Central Government and the people all over the world: Falun Gong is not a form of religion, it is not an organization, nor has it any political agenda, and it does not have, and will never have any foreign power behind it. We shall never be enemies of government or people, regardless whether government and people understand us. We shall never do anything to hurt the interest of this country, society and people, nor shall we do anything against the law. However, we shall never admit or recognize the unfair conclusion, label, or ban, forced on us from anyone in any name. As long as Falun Gong is not rehabilitated, we shall exercise the right given to us by the Constitution to continue appealing, complaining to the government and spreading Falun Dafa, and to regain the right to be good people. Jiang Zemin, Zeng Qinhong and Luo Gan are using and encouraging some people to do bad deeds in the name of Falun Gong so as to frame it and ruin its name. We would like to declare that any conducts that are not in conformity of the principle of "Truthfulness-Benevolence-Forbearance" are not done by Falun Gong practitioners. Those conducts, if resulted in the detriment to government, society and people, shall be the responsibility of Jiang Zemin, Zeng Qinhong and Luo Gan and their followers. Plaintiffs: Two Falun Gong Practitioners August, 2000, in Beijing. Attached: One copy of the Original Complaint Two photocopies of the Complaint.

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Category: Karma & Virtue

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