FOURTH: That, among the most significant events in the history of the Cuban revolution --for its military, patriotic and political impact-- is the Bay of Pigs mercenary invasion organized by the United States Central Intelligence Agency on instructions given by President Eisenhower on March 17, 1960. President Eisenhower himself wrote in his memoirs: "On March 17, 1960 [...] I ordered the Central Intelligence Agency to begin to organize the training of the Cuban exiles, mainly in Guatemala."

As part of the preparation for the invasion, the airports at Ciudad Libertad, San Antonio de los Baños and Santiago de Cuba were bombed at dawn on April 15, 1961. The aggression was repelled and although some planes from the Cuban defense forces were destroyed that could not render useless our small recently established Revolutionary Air Force. This was thanks to the courageous performance of the anti-aircraft artillery made up almost entirely by young people who would play an extraordinary role only two days later. Twelve of those youths lost their lives, including Eduardo Garcia Delgado, who entered the history of that epic struggle when he wrote Fidel's name, with his own blood on a board, as he lay dying.

Two days later, on April 17, 1961, at 2:30 in the morning, a group began to land on the southern coast of the former province of Las Villas, at Cienaga de Zapata. The group organized, trained, equipped and financed by the U.S. government had come from Puerto Cabezas in the Republic of Nicaragua. Its own members called it Assault Brigade 2506 and it was made up of about 1,500 men. According to documents seized from those who were taken prisoners, the mercenary invasion plan contemplated landing at three places in Cienaga de Zapata: Playa Larga, which they called Playa Roja in their plans where those on board the ship named Aguja were to disembark; Playa Giron, called Playa Azul, where the vessels known as Ballena and Tiburon were to disembark their passengers; and Caleta Verde, called Playa Verde, where those on board ships Marsopa, Barracuda and Atun were to disembark.

At the same time, two battalions of parachutists would occupy positions in the vicinity of the Australia sugar mill, also at San Blas and Soplillar, their mission being to cut off access to the landing and operation zone, then to isolate it, to fortify it and to establish a provisional government there. This would have created the conditions for immediately airlifting to Cuba a government impatiently waiting in Miami with its luggage ready that would request a military intervention by the United States of America at the head of the OAS "troops".

During the invasion, the members of this "government" were forcibly kept incommunicado in the United States territory while the CIA issued one statement after another in their name.

The mercenary brigade landed at Playa Giron and Playa Larga despite the resistance put up by small units of the National Revolutionary Militias. They landed their tanks and armored vehicles and dropped the parachutists' battalion north of Giron in order to block the paved road leading to the Australia sugar mill. B-26 planes disguised with Cuban insignia and escorted by American fighter planes began bombing the area, strafing the civilian population, killing people --including women and children whose full names can be found at the end of this document-- and causing considerable damage. American Navy units --including an aircraft-carrier (the Essex, with 40 fighter planes and a marine battalion on board), a helicopter-carrier, five destroyers and one LSD [Landing Ship Dock] among other naval units-- escorted the ships that transported the mercenary forces and remained a few miles off the operation zone throughout the whole battle.

The mercenary brigade had plenty of equipment and weaponry. It had five transport gunboats, two modified LCI artillery war units, three LCV landing craft for transporting heavy equipment and four LCVP troop-carrier landing craft. For air operations, the mercenaries were backed by sixteen B-26 fighter planes, six C-46, eight C-54 transport planes and two Catalina seaplanes. They had five M-41 Sherman tanks, with 76-millimeter guns; 10 armored cars equipped with .50-caliber machine-guns; 75 bazookas; 60 mortars of different caliber; 21 recoiless cannons, 75-millimiter and 57-millimeter; 44 machine-guns .50-caliber and 39 light and heavy machine-guns .30-caliber; eight flame-throwers; 22,000 hand-grenades; 108 Browning automatic rifles; 470 M-3 submachine-guns; 635 Garand rifles and M-1 carbines; 465 pistols and other light weapons.

The members of the mercenary brigade received military training from American instructors at bases in the United States, Guatemala and Puerto Rico. They received monthly allowances to support their families provided by the United States government which spent a total of 45 million dollars to finance the operation.

In less than 72 hours, the Cuban revolutionary forces overwhelmingly crushed the powerful invading mercenary brigade. In this respect, the White House issued an official statement on April 24, 1961, where it indicated that "President Kennedy has stated from the beginning that as President he bears sole responsibility" for the invasion. The statement added that "the President is strongly opposed to anyone, within or without the administration, attempting to shift the responsibility".

The United States government's association with the events described in this document was also corroborated in the well-known report by the CIA Inspector General, elaborated six months after the failed invasion, a document that remained classified 'top secret' for 37 years until 1998 when it was declassified following intense efforts by the National Security Archive, a non-profit organization based in Washington D.C.

Although the Bay of Pigs invasion was a major political and military defeat for the United States government, this war conflict left a high number of victims and countless grieving or badly afflicted Cuban families, since 176 people died and over 300 were wounded by enemy weapons. This included people living in the area who were machine-gunned by the mercenary air force; 50 of them were permanently incapacitated for their obligations. We vouch for these extreme situations with certificates that have been attached to this demand as documents marked numbers 12 and 13, respectively.

Pilots, advisers, frogmen and other Americans were directly involved in action. In the violent engagements of April 19, the active participation of American pilots was confirmed when the anti-aircraft forces brought down a B-26 plane manned by American citizens Thomas Willard Ray and Frank Leo Baker, National Guard pilots in the state of Alabama. On that same day, another B-26 was brought down over the sea. It was manned by Ryley W. Shamburger and Wade Carroll Gray, the former an officer with the National Guard.

FIFTH: That, terrorism has permanently been used by the United States of America as an instrument of its foreign policy against Cuba. One of the U.S. government first acts of terrorism against our country was a monstrous crime: the sabotage of the French vessel La Coubre on March 4, 1960, at a pier in the port of Havana. In Europe, the boat had loaded a significant batch of weaponry and ammunition purchased from the Belgian national industry by Cuba's revolutionary government, which was already concerned at the growing acts of aggression by the United States.

The cargo was sabotaged by CIA agents at the port of shipment; the devices they planted exploded that day while the ship was unloaded. The bombs were placed with great sophistication, so that there would be a second explosion while the victims of the first one were receiving assistance. Both, the ship and the neighboring pier were crowded with port workers, rescue personnel and soldiers who, regardless of the danger, had gone to there to help the victims of the disaster and prevent accidents.

This act of terrorism left 101 dead, including six French sailors, and hundreds of wounded. Now, so many years after the event it is impossible to give the exact number of the wounded because they were cared for in numerous hospitals and health care centers in the nation's capital.

The modes of terrorism used against Cuba have mainly been the following: sabotage or destruction of civilian targets inside the country; pirate attacks against coastal facilities, merchant vessels and fishing boats; attacks against Cuban staff and facilities abroad, including diplomatic missions, airline bureau and aircraft; the constant incitement of subversive elements, through radio and television stations, to carry out acts of this nature against production and service centers, even with indications of how to do so.

If our country has been a constant target of terrorist actions during these forty years of Revolution, it was in 1961 that they became more systematic as a result of the covert action program against Cuba approved on March 17, 1960 by United States President Dwight D. Eisenhower. In the aforementioned now declassified secret document on the program of covert action against Cuba, followed up later by President Kennedy, Eisenhower specified that "the method of accomplishing this end will be to induce, support and, so far as possible direct action, both inside and outside of Cuba, by selected groups of Cubans of a sort that they might be expected to and could undertake on their own initiative."

It was precisely one of these "selected groups" that, on the afternoon of April 13, 1961, set fire to and completely destroyed El Encanto, the biggest department store in the country. This action was carried out by Carlos L. Gonzalez Vidal, member of a terrorist group known by the abbreviation MRP [People's Revolutionary Movement]. It was also discovered that the main organizer was Mario Pombo Matamoros, who was in contact with leaders of the M-30-11 group. The consequences of this fire were not only economic but more painful still due to the death of worker Fe del Valle Ramos, plus burns and injuries sustained by 18 other people among the hundreds working in the store. A month before, on March 13, 1961, as part of these same terrorist plans there had been an attack on the Hermanos Diaz oil refinery in Santiago de Cuba, where 27-year-old sailor Rene Rodriguez Hernandez, on sentry duty, was killed and 19-year-old Roberto Ramon Castro was seriously injured. This action was carried out by a CIA commando unit in a gunboat equipped with heavy machine-guns which had been launched from the American ship Barbara J., as described by CIA Inspector General Lyman Kirkpatrick in his report. On May 28, 1961, some terrorists set alight the Riego cinema in Pinar del Rio city, during a showing for children. Twenty-six children and 14 adults were injured.

On September 5, 1963, two twin-engines aircraft dropped explosives over the city of Santa Clara, causing the death of teacher Fabric Aguilar Noriega and injuring three of his four children.

On December 23, 1963, a CIA commando unit transported by sea from the United States, using underwater demolition devices, sank the Revolutionary Navy's LT-385 torpedo boat in Siguanea dock on the Isle of Pines, killing frigate second lieutenant Leonardo Luberta Noy and midshipmen Jesus Mendoza Larosa, Fe de la Caridad Hernandez Jubon and Andres Gavilla Soto.

Dozens of similar cases could be listed that occurred in those years. Plane hijackings, unprecedented in the world, were devised and used precisely by the CIA in its terrorist actions program against Cuba from 1959. Many such actions took place, especially during the early years of the Revolution. Some took on dramatic characteristics. As an example, we will relate what happened on March 27, 1966 when an unscrupulous man, Angel Maria Betancourt Cueto, using a firearm, tried to divert to the United States --where they were always welcomed as heroes-- an Ilyushin-18 Cubana Airlines plane en route from Santiago de Cuba to Havana, with 97 people on board, including 14 children. Seeing his plan thwarted by the courage and resolution of Fernando Alvarez Perez, the plane's captain who refused to divert the plane and landed at the international airport in the Cuban capital, the frustrated hijacker, once on land, murdered the pilot and the guard Edor Reyes Garcia and seriously injured co-pilot Evans Rosales. The whole country was shocked by this event.

Other forms of terrorism also persisted. On October 12, 1971, a speedboat and a larger vessel, coming from U.S. territory, machine-gunned the town of Boca de Sama, on the north coast of Oriente province. This cowardly action against the civilian population resulted in two dead and several other people from the town wounded, including two children.

In those years, terrorism also took the shape of paramilitary actions against merchant vessels and fishing boats from Cuba or third countries in the Straits of Florida. On October 4, 1973, the Cuban fishing boats Cayo Largo 17 and Cayo Largo 34 were attacked by two gunboats manned by terrorists, who murdered fisherman Roberto Torna Mirabal and abandoned the others on rubber rafts, without food or water.

But, undoubtedly the most atrocious and repulsive act of terrorism perpetrated against Cuba in that period took place on October 6, 1976 when a Cubana airline aircraft with 73 people on board was blown up in mid flight. Fifty-seven passengers were Cuban, including the 24 members of the junior fencing team who had just won all the gold medals in a Central American championship. Eleven passengers were young people from Guyana, six of whom had chosen to study medicine in Cuba. And, five passengers were citizens of the Democratic People's Republic of Korea. There were no survivors. The aircraft, a DC-8 with registration number CUT-1201, had taken off from the international airport in Barbados 10 minutes before. A programmed explosive device had been set off in the plane's toilet by two individuals who, traveling from Trinidad and Tobago, had left the aircraft at that usual stopover on its route. At the airport, they immediately took a taxi and asked the driver to take them to the United States embassy, according to testimony by Maurice Firebrace, the taxi driver who drove them and gave this deposition to the Barbadian authorities. Another taxi driver, Roger Pilgrim, also testified to the Barbadian authorities that, on the afternoon of that same day, he took both men to the U.S. embassy on two occasions; first, between 2.00 and 3.00 p.m., and then at around 4:55 p.m. That same afternoon, from the Village Hotel they managed to communicate with, and report to, their bosses in Venezuela that their mission had been accomplished. In the evening, they returned to Trinidad and Tobago, where on October 7, at dawn, they were identified and arrested by the local authorities, to whom they almost immediately confessed their participation in the events.

At a meeting held in Trinidad and Tobago, at the request of that country's Prime Minister Eric Williams, fourteen days after the sabotage, the foreign minister of Guyana, Fred Willis, referred to the notebooks belonging to the accused which incriminated the CIA by revealing its links with the detainees. They were two mercenaries of Venezuelan nationality who had been hired by Orlando Bosch Avila and Luis Posada Carriles, two of the best-known terrorists recruited by the Central Intelligence Agency since 1960 and experts in sophisticated sabotage techniques with every sort of equipment. Both were registered as members of an organization called CORU [Co-ordination Committee of United Revolutionary Organizations] which derived from the CIA-ordered unification of the main groups that had until then been acting under different names from United States territory. This organization was given the task of carrying out an ambitious program of sabotage and acts of terrorism against Cuba, with the full support of the United States government. About that time, the same group unified by the CIA carried out among others the following actions:

April 6, two fishing vessels, Ferro-119 and Ferro-123, are assaulted by pirate speedboats from Florida, killing fisherman Bienvenido Mauriz and causing great damage to the vessels;

April 22, a bomb set off at the Cuban embassy in Portugal kills two diplomats, Adriana Corcho Callejas and Efren Monteagudo Rodriguez and seriously wounds several others, completely destroying the premises;

June 5, the Cuban mission to the UN is the target of an attack with explosives causing important material damage;

July 9, a bomb explodes in the cart carrying the luggage to a Cubana Airlines plane in Kingston airport, Jamaica, a moment before the luggage was transshipped. That is, it was out of sheer luck that a Cubana aircraft was not blown off in flight on that July 9;

July 10, a bomb explodes in the British West Indies offices in Barbados representing Cubana Airlines in that country;

July 23, a technician from the National Fishing Institute, Artagnan Diaz Diaz, is murdered in the aftermath of an attempt to kidnap the Cuban consul in Merida [Mexico - editor];

August 9, two staff members of the Cuban Embassy in Argentina, Crescencio Galañena Hernandez and Jesus Cejas Arias, are kidnapped and they have never been heard of again;

August 18, a bomb explodes in the Cubana Airlines offices in Panama, causing considerable damage. The groups that made up the CORU had been issuing public statements in the United States, claiming responsibility for each of these misdeeds. In August 1976, a Miami newspaper published a shameless war report where, after relating how they had blown up a motor car opposite the Cuban embassy in Colombia and destroyed the offices of Air Panama, the CORU ringleaders concluded: "We will very soon attack aircraft in flight." Approximately six weeks later, the Cuban aircraft that made a stopover in Barbados exploded in mid-flight.

Orlando Bosch and Luis Posada Carriles were arrested, jailed and subjected to a long, winding legal process in Venezuela together with the two Venezuelan mercenaries who following their orders had set off the bomb in the Cubana airline DC-8 aircraft . In August 1985, Posada Carriles was rescued by the CIA through the so-called Cuban-American National Foundation from San Juan de los Moros maximum security prison and taken in a matter of hours to El Salvador, where he was immediately put to work in one of the most secret, delicate and incriminating operations undertaken by a United States administration: the notorious Iran-Contra operation, which led to a huge political scandal in that country. Posada Carriles was in charge of storing and, in practice, distributing the weapons for the dirty war in Nicaragua, under direct orders from the White House. He had never had such senior responsibilities in his 25 years of service to the United States government. Orlando Bosch, who had been the at the head of the operation in the loathsome crime because he was then higher-ranking than Posada Carriles in the terrorist organization unified by the CIA, was cynically acquitted by a corrupt and shameless court. The perpetrator of numerous acts of terrorism against Cuba, now lives peacefully as a distinguished guest of the United States of America.

Another shameful and painful terrorist action had been committed after the brutal crime in Barbados: on September 11, 1980, Cuban diplomat Felix Garcia Rodriguez was murdered in a crowded New York street in day time. The crime was perpetrated by a commando from the terrorist organization known as Omega-7 whose mission it was to assassinate this and three other officials from the Cuban U.N. mission.

The changes in the international arena have led to changes in the expression of what is no less than flagrant state terrorism against the Republic of Cuba. In this token, the most reactionary sectors of Cuban immigrants in the United States encouraged terrorist activities at the end of Republican President George Bush's administration which marked the development of somewhat significant actions under the first and second administration of Democrat President William Clinton.

From 1992 until the present --as it was clearly demonstrated during the recent trials against terrorists Raul Ernesto Cruz Leon and Otto Rene Rodriguez Llerena who exploded seven bombs in Havana hotels in 1997-- the Cuban-American National Foundation, a prominent financial contributor to presidential political campaigns and to a group of well-known American legislators, has planned, organized and financed with impunity in the United States this terrorist campaign against Cuba. The CANF has carried out its actions not only from the American territory itself, using mercenaries of Cuban origin residents in the United States but also from Central America, recruiting Central American mercenaries acting under the orders of notorious terrorist Luis Posada Carriles.

These recent criminal actions against Cuba originated in Central America --planned, organized and financed by the leaders of a Cuban-American Mafia in the United States-- were unquestionably carried out with the acquiescence and tolerance of the American authorities, for whom Posada Carriles always worked and who have never severed relations with him.

In addition to this, and as part of its political strategy, the American government has for forty years given major encouragement to the illegal emigration toward its territory, not only as an instrument in the ideological struggle and in its campaigns to discredit Cuba but also to promote indiscipline and social unrest. That has resulted in criminal acts because criminals were convinced that they would be welcomed and protected in the United States once they had achieved the main goal of departing from Cuba. This has not been the case with citizens from other parts of the world who tried to emigrate to the United States without first obtaining a visa. That cynical policy has been the source of many incidents, but January 9, 1992 is a milestone. On that day, Revolutionary National Police officers Yuri Gomez Rivero and Rolando Perez Quintosa were murdered and also Coastguard member Orosman Dueñas Valero and civilian security guard Rafael Guevara Borges, a worker at the "Jose Martí" Children's Camp in Havana. They were assaulted and murdered by a group of criminals --led by Luis Miguel Almeida Perez-- who intended to hijack a boat for leaving the country illegally. Likewise, on August 4, 1994, Revolutionary National Police officer Gabriel Lamouth Caballero was murdered by anti-social elements trying to leave the country illegally through the port of Havana and, on August 8, 1994, Lieutenant Roberto Aguilar Reyes was killed when an auxiliary ship of the Revolutionary Navy was hijacked in Mariel, Havana, by Leonel Macias Gonzalez, who managed to flee to the United States where he was welcomed as a hero and has enjoyed complete impunity after his cowardly act of murder.

As a result of the terrorist activities promoted by the United States government against our country throughout four decades, from the triumph of the Revolution until today 234 innocent people have lost their lives or been incapacitated. Evidence of this is provided in the documents attached to this demand marked with the numbers 14, 15, 16, 17, 18 y 19.

To have an idea of the intensity reached by terrorist activity against Cuba at a given moment, suffice it to say that in only 14 months, from November 30, 1961 --the day President Kennedy approved the implementation of the so-called Cuban Project-- up to the month of January 1963, a total of 5,780 acts of terrorism were perpetrated against Cuba, 716 of which can be described as substantial sabotage of industrial facilities.

The United States complete lack of scruples, its immorality and the inability to abide by civilized standards of political practice is best expressed in the plans conceived by that country's leadership for the physical elimination of the leader of the Cuban Revolution, initially in his capacity as Prime Minister from February 16, 1959 to December 3, 1976 and later as head of state.

On December 11, 1959, Colonel J.C. King, head of the CIA Western Hemisphere Division, in a secret memorandum to CIA Director Allen Dulles recommended that: "Thorough consideration be given to the elimination of Fidel Castro. None of those close to Fidel, such as his brother Raul or his companion Che Guevara, have the same mesmeric appeal to the masses. Many informed people believe that the disappearance of Fidel would greatly accelerate the fall of the present Government."

From that date up to the present, the Cuban state security has disclosed, investigated, uncovered or neutralized plausible indications of meticulously conceived or drawn-up plans, in an advanced stage of organization and implementation or about to be implemented, for 637 attempts on the life of Commander-in-Chief Fidel Castro, including those not implemented due to the cowardice of some who even managed to get a few meters away from their target. One can only guess how many other plans have never been known. The United States Senate has investigated and verified at least eight of such conspiracies, that is, barely 1.25 percent of those directly organized by the CIA or induced by the hostility, propaganda, conspiratorial tolerance and actions of the United States government against Cuba lasting already forty years.

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