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I, NATALIA GOLENKOVA, of full age, being duly sworn, depose and say:

  1. I am submitting this affidavit in support of my Application for POLITICAL Asylum, Withholding of Removal, and Withholding of Removal under the Article III of the U.N. Convention Against Torture.
  • I am requesting the afore-mentioned relief because i was and will be persecuted by RUSSIAN AUTHORITIES because of my POLITICAL ACTIVITIES AND POLITICAL AFFILIATION.

I was born on April 23, 1981 in Oryol, Russia.  (Exhibit A)  In 1998, I graduated from Municipal Lyceum number 40 in Oryol, Russia and received an equivalent of a high school diploma.  In 2003, I graduated from the State Oryol Technical University and was awarded an equivalent of a Bachelor’s Degree in Civil Jurisprudence.  (Exhibit B) In 2011, I received an equivalent of Master’s Degree in Management from the Open University of Great Britain.  (Exhibit B)  That same year, I received a certificate of specialization in Management and Change Control from the “Link” International Institute of Management.  (Exhibit B)

In December 7, 2002, I married Vladimir Kharlamov.  Together we had two children.  My daughter, Valeriia Kharlamova, was born on December 29, 2012 (Exhibit C) and my son, Daniil Kharlamov, was born on February 23, 2006.  (Exhibit D)  Due to personal differences, my husband and I divorced on February 24, 2004.  (Exhibit E)

In or around 2002, while I was still studying at the State Oryol Technical University, I began working as a consultant lawyer for a group of law firms called “Elite.”  After graduation, I continued working there as a Manager of Legal Services Department.  In 2009, I opened my own wholesale company that specialized in distribution of grocery products to stores in Oryol Region of Russia.  The company became very successful within the next few years.  I hired Ekaterina Starykh as a CEO of the company who operates the business to this day.  In 2013, I opened another company called “Sreda” that specializes in providing banquet venues and services including decorations, food and catering.  My company leases two buildings and offers four banquet halls of different sizes.  Currently, the business is managed by Alexander Chuchko.      

In January 2016, I developed a new Limited Liability Company called “E-Marketing.”  The main undertaking of the company was to provide Internet Marketing Services.  The range of E-Marketing services were to provide website development, Internet advertisement, email marketing, search engine prioritization and website optimization.  Having little expertise in this market, I decided to enroll in a college program to gain the necessary skills to successfully develop the business.  Since there were no universities in Russia that provided such programs, I chose to attend The Rutgers University in New Jersey, which is one of the four U.S. colleges that have Internet Marketing academic programs.  (Exhibit F)  On July 1, 2016, I received my F-1 visa from the U.S. Consulate in Moscow.  I was planning to arrive to the U.S. sometimes in the beginning of September 2016 right before my classes were supposed to start.  But what I will describe below changed my life, my plans and I was forced to flee for my life and life of my children earlier than planned, on August 13, 2016.

Political opinion is one of those things that develops in a person’s mind gradually as s/he observes or experiences the surrounding environment.  As the political situation in Russia deteriorated and President Putin strengthened his power, civil rights of ordinary citizens and opposition politicians had been continuously violated.  Bribery cultivated and people who attempted to speak out about the situation in the country were immediately eliminated.  With time, such egregious acts as the arrest and murder of Sergei Magnitsky and theft and misappropriations of billions of dollars from the budget of the Sochi Olympics became an ordinary occurrence in the lawless Russia.

As the country’s political situation worsened and as I began experiencing effects of such changes in my business and daily life, I became interested in politics.  In 2011, I subscribed for a Russian Magazine called “New Times” which posted articles and opinions of prominent political opposition critics.  I became acquainted with works of many critics and politicians including Victor Shenderovich, Alexei Kudrin and Sergey Parkhomenko.

Today, I consider myself a strong supporter of liberal democratic ideals.  I believe that everyone must be guaranteed a freedom of ideas and speech and that the government cannot deprive its citizens the right to express their beliefs.  Moreover, everyone has a right to freely receive, transmit, produce and distribute information.  If the government deprives its citizens of such basic rights, people must fight for them in order to live in a democratic society. But People may not violate laws, harm others or act in an illegal way in pursuing such goals.

Although the Russian Government has always been known for its anti-democratic actions, the political situation in Russia severely deteriorated in 2011 when the Government began disregarding the Constitution and people’s basic rights. 

My political involvement began in 2012 when I started using Social Media websites including Facebook to express my political views and continuously posted anti-government news and actively criticized the government’s actions.

In July 2013, I went to Moscow to participate in a lawfully registered rally organized in support of Alexey Navalny who was arrested and sanctioned when running for a Mayor of Moscow and was winning in the pre-election polls.  Navalny’s political party “Narodnyi Aliyans” (The People’s Alliance), later known as “Partiya Progressa” (The Progress Party), was the only prominent opposition party that openly spoke out about the Russian government’s actions.

At the rally, I was distributing brochures and banners.  When the police came, they began forcing us out of the area by physically pushing us away.  Their goal was to prevent the media from showing that we actually attended the rally.  Therefore, many of us were arrested while others beaten and scared off.  Because I was with my son Daniil, I decided to leave knowing that otherwise I would be spending the night in jail.

In 2013, I created a website where I posted political notes and opinions of prominent political thinkers. I cited to classics such as Victor Pelevin, who said, that “Democracy will never exist in Russia because people do not allow it to exist.”  Unfortunately, I was so busy with work and raising two children on my own that I had to give up on the website and my domain was resold.  

On December 12, 2014, I took part in the event of Opposition Publicists.  That is where I became acquainted with Victor Shenderovich.  (Exhibit G)  I frequently communicated with him since then and we became very good friends.  Mr. Shenderovich is a famous political publicist and publishes his articles in various media sources including prominent Echo of Moscow and Ezhednevnyi Zhurnal.  He travels around the world conducting his so called literary nights in which he actively criticizes various government entities especially the Government of Russia.  Mr. Shenderovich’s influence on me was so strong that I became even more involved in politics.

In 2015, Governor Potomsky of Oryol Region announced his plan to erect a sculpture of Stalin in the City of Oryol. Stalin, the leader of the Soviet Union between 1920s and until 1953, murdered millions of innocent children, women and men, and imprisoned millions of innocent people without giving them any opportunity of fair trial.  I was shocked when I found out about Governor Potomsky’s plan to tribute this “monster”.  That is when I met Anna Dulevskaya and Victor Pankov.  They both were activists who organized various peaceful protests and rallies against government actions they believed were unethical or violated human rights.  I helped them with the campaign against erection of the sculpture, prepared a petition we posted on and contacted media companies thus raising awareness on the issue. Unfortunately, the media was not very interested in this story and only a few agencies mentioned it in their weekly releases.  Nonetheless, the attracted attracted several thousand people and we were able to fight off Governor Potomsky’s plans.  

In July 2016, I contacted Oleg Navalny, the brother of Alexey Navalny jailed in Oryol for political affiliation with his brother, offering him my help. Oleg wrote me back thanking me for the offer.  (Exhibit H)

But Governor Potomsky did not stop there.  In June 2016, he announced his intent of erecting a sculpture of Ivan the Terrible in front of the youth theater called “Svobodnoe Prostranstvo.”  (Exhibit I)  The building of the theater is the oldest building in the City of Oryol.

Ivan the Terrible was one of the bloodiest Tsars in the history of Russia.  He was responsible for deaths of thousands of children, women and men.  In the 450 years since his reign, there were no sculptures of him erected anywhere on the territory of Russia.  For these reasons, Governor Potomskyi’s plans were outrageous.  I could not agree with the initiative that was completely against my values.  I believe that the life of its citizens is any government’s primary concern.  To put up a sculpture of the person who saw no value in people’s lives was the most hideous decision any government could make.

As soon as we heard about the governor’s intent, Dulevskaya, Pankov and I began planning a rally against the decision of erecting the sculpture in the center of the city.  While at the campaign against the sculpture of Stalin I was only a participant, this time I was responsible for the campaign.  I was required to gather participants at the rally through social websites and media.  I began to actively contacting the media, posting short videos accompanied by explanations why this was such a hideous idea.  For the time of the rally, I ordered banners and created the texts for banners to assure that the text did not violate any laws.  I communicated with people who were afraid to come to the rally for security reasons.  I explained to them that the rally was organized according to the law of the Russian Federation, and that they would not have any problems with the police. 

As a person with a law degree, I was responsible for formulating our position and reasons for the protest, and submitting complaints to the President of the Russian Federation, Prosecutor’s Office of the City of Oryol, and the Moscow Patriarchy of the Russian Orthodox Church against the actions of the Oryol Region Government’s administration.  (Exhibit J) I also filed a petition with the Oryol City Administration to get a permission to have a rally.  (Exhibit K)  The petition was registered and approved, and the rally was scheduled for July 18, 2016 at 7 p.m. in front of the children’s theater and was supposed to last for about two hours.

On the day of the rally, two hours before the intended start time, Anna Dulevskaya and I were asked to appear at the Oryol City Administration’s Office.  We were formally served with a Notice advising us to change the place and the time of the rally. (Exhibit L)  We were explained that the City would be conducting cleaning work in the theater area at the same time when the rally was supposed to be held.  When I expressed my disagreement, I was told that the sculpture would be erected no matter what and people who were trying to play democracy would be taken care by the police.

Since the City Administration’s letter carried only an advisory character and we were not required to comply, we decided to disregard it.  Everything was ready, and we expected thousands of people to participate in the rally.  Had we followed the administration’s directive, these thousands of people would not be able to participate in the rally.

When we arrived at the place of the intended protest, the square was obstructed with crowd control barriers and caution tapes.  (Exhibit M)  There were cleaning machinery at the perimeter of the square, and police standing around telling people to leave.  (Exhibit M)  When I confronted the police, they could not give me a reasonable answer for why the square was barricaded.  So, I just went over the barriers and entered the square.  Other people followed me and soon many of us were standing on the square.

Soon, more and more people started arriving.  (Exhibit N)  Many who showed up and saw the police quickly left without participating in the rally.  The police began disorienting people by telling them that the rally was illegal.  When people refused to leave, the police began questioning them and collecting their personal information including names, telephone numbers, places of employment and addresses.  This line of actions scared many people off because they knew from the previous practice of the police that it systematically prosecuted and imprisoned protestors and rally participants, even the peaceful ones.

The police also did everything to neutralize the rally organizers including me.  They repeatedly interrogated us completing the forms of Interrogation of the Suspect in the Criminal Matter.  I personally was questioned by several policemen.  This tactic kept us away from our actions during the rally.  (Video available at:;;

At the same time, nationalists with the fascist swastikas on their t-shirts hanged a large banner on the roof of the theater building.  The Banner stated “God Bless Ivan the Fourth the Great, for enemies the Terrible”.  The nationalists were walking around the square and actively intimidated rally participants.  The police simply observed whatever they did without taking any actions.  When I attempted to confront the policemen about why they were not doing anything to stop the nationalists’ unlawful actions (they were not granted a permission to rally in the square), the police simply disregarded my requests.  (Video available at:

My son, Daniil Kharlamov, was also with me at the rally. (Exhibit O) (Video available at: )  Although Daniil is 10 years old, he is a history enthusiast, when he found out about the Governor’s plans, he was furious and insisted on participating at the rally.  He had been well aware that Ivan the Terrible killed his own son and so insisted on coming with me and fighting against the injustice. Daniil was interviewed at the rally by various members of the local media. (Exhibit P)

The rally ended a little earlier than expected due to weather conditions.  But what the administration did was genius.  While the police were neutralizing the organizers preventing us from organizing people, the police were also scaring away the bystanders and participants who wanted to take part in the rally.  At the same time the street cleaning machinery was so loud that journalists could not interview anyone, and the crowd could not hear us agitating.  Nonetheless, over 300 people participated at the rally.  The cleaning machinery stopped immediately after the rally was over and the police left immediately removing their barricades.  About an hour after the rally, I gave an interview to the National TV station “Dozhd”, in which I in details described all of these violations. (Available at:

The next day, I was receiving tens of phone calls from the media asking me to comment, write an opinion, to be interviewed, or appear on TV to describe the campaign, our plans of what we intended to do next and the government’s actions.

In the matter of days, our small campaign spread around the country and the world.  Because I actively communicated with the Press and reported about the developments of the protests and also submitted a complaint to the President’s Administration about the government’s actions, I became the symbol and the face of the rally.  My name appeared in news media worldwide including in UK Times, the Guardian, New York Times, Russian Tass, Interfax and Radio Free Europe.  I was mentioned in 90 percent of the media news and reports that covered the issue.  (Exhibit Q)

On July 19, 2016, my article “A Sculpture of the murderer or about insults of the faithful’s feelings,” was published in “Ezhednevnyi Zhurnal”, an anti-government media website prohibited in Russia. (Exhibit R)  In my article, I discussed another main aspect of the erection of the sculpture – that the Russian Orthodox Church publicly expressed its opinion that the sculpture should be installed.  This aspect of the events was very important because Ivan the Terrible murdered Holiness Patriach Phillip II of the Whole Russia for refusing to give his blessing to Ivan’s massacre of Novgorod.  As a result of this massacre, two thirds of the City of Novgorod was cleansed.  In this Article, I also discussed the legal aspect of this problem.  Specifically, I discussed how erection of the monument would violate the Criminal Act of Russian Federation – specifically, Insult of Feelings of Believers.  The Article was published when Holiness Patriarch Kirill II of the Whole Russia blessed erection of the sculpture.  After my article was published, I was giving various interviews to media worldwide.

The same day when my article was published, several agents of the Federal Security Services visited the logistic center of my product distributing company and interrogated Ekaterina Starykh, the CEO of the company and a protest participant, about my company.  They asked her about me, the business and threatened her asking whether we knew that such radical position towards Governor Potomsky could harm the business.  While the preparations for the protests were in progress, I stopped attending work and therefore was not there.

The pressure that the media created forced governor Potomsky to gather a public meeting inviting the organizers of the protests including me.  The meeting was scheduled for July 20, 2016. He postponed his plans.  (Exhibit S)

On the day of the meeting, on July 20, 2016, at around 11 a.m., my son was attacked by unknown people when returning home from training.  (Exhibit T)  His arm was broken, he was hospitalized and was required an elbow surgery.  Immediately after I found out about the incident, I ran to the hospital and was forced to miss the meeting with the Governor.  At the time I did not know that my son was attacked.  Instead, I was told that he accidentally fell and broke his elbow.  When my son was at the hospital, to my questions about what happened, his answers were vague and hard to understand.  He was very weak and was recovering from anesthesia.  Therefore, I decided not to pressure him and let him recover.  About ten days later, Daniil told me that an unknown adult male attacked him.  The man threatened Daniil, twisted his hand and threw him on the ground thus breaking his elbow.  He told Daniil such things as “son of a bitch, another one growing… worse than the mother, Zhid (kike, offensive word for a word Jew), learned to open his mouth… tell your mom that if you open your mouths one more time about the Terrible, I will break all of you people’s arms and legs.”  When I asked my son why he did not want to tell me the truth before, he said that he was scared and did not want to scare me.  Daniil was attacked because his face appeared in various news articles and it was easy for Governor Potomsky’s people to find out that he was my son.

On July 20, 2016, after my son’s surgery, I gave an interview to “Dozhd” one more time.  (Video available at: )  At that time, I already knew that Governor Potomsky decided to postpone erection of the monument to Fall 2016 after the public expressed its opinion.  By then, the Governor was a subject of public humiliation for not knowing the history of a person he so admired.  At one of the interviews he told the press that Ivan the Terrible never killed his son and that his son died on his way from Moscow to St. Petersburg.  What the Governor did not know was that St. Petersburg was founded more than 100 years after the death of Ivan the Terrible.  (Exhibit U)

As the popularity of the campaign grew, unknown people began threating us, the organizers, on the Internet.  Unfortunately, most of the threats were deleted a day or so after they were posted.  Therefore, when I made complaints to the local police about the threats, the police ignored them basing their decision on the fact that they could not find the posts online.  Therefore, I hired a notary public to record the fact of observing the threats, so that I could submit them to the police.  On July 25, 2016, the police accepted my complaint.  (Exhibit V)   Although by law the police were required to respond to my complaint within 14 days after its submission, I have never heard back from them.  I recently received an email from my attorney in Oryol stating that the matter was transferred to the Ministry of Internal Affairs and then later transferred to the Ministry of Foreign Affairs, to the Head Central Directorate for Combating Extremism.

By then, the Governor’s actions upset many people.  Another rally organized by the Communist Party of the Russian Federation was planned for August 8, 2016, with an agenda of forcing Governor Potomsky to leave the office.  On August 7, 2016 I met with one of the Party’s organizers and was offered to attend the meeting and give a speech as a person who was publicly known in the city and who was not afraid to fight against the Governor’s despotism.  I agreed to give a speech.  The agenda and speakers at the rally was registered at the City Hall.  However, I was not able to speak or participate in this rally because on August 7, 2016, I was attacked by an unknown man.  When I was walking home in the evening, the man swiftly approached me, pushed me very hard in the chest with two hands forcing me to fall on the ground.  He said something like “If you open your mouth one more time, bitch, or participate in a rally, we will kill you.”  The man was tall and beefy.  He was wearing sunglasses and a baseball cap.  On August 8, 2016, I reported this incident to the police.  (Exhibit W)  Unfortunately, since most of his face was covered, I was not able to give a good description of him to the police.  However, I told the police that there are cameras in the area where it happened since it was very close to a public school.  Recently, I received a response from the police stating that they would not be investigating the matter because there was no clear threat to my life.  (Exhibit W)

After this event, I refused to give a speech at the rally or participate in it because I was afraid for the life of my children and my own.  I also limited my appearance in the Media because I did not want to scare people off. The public just began expressing their opinion about the situation and if they heard what happened to me, they could get discouraged.  On August 8, 2016, several thousand people attended the rally.  The Online petition against the monument that I prepared, was signed by over 700 people. Only after the rally, I met with a member of Associated Press and briefly mentioned that I was attacked by Governor Potomsky’s people.  (Exhibit X)

On August 11, 2016, I received a call from a police detective who instructed me to appear at a local Police Precinct for questioning in regards to my report of an attack.  On August 12, 2016, I came with an attorney to the specified police location at around 11 a.m. and repeated my testimony I gave earlier on August 8, 2016.  The police Colonel Levichev had me sign all the paperwork and told us that we were free to go.  After we left the precinct, I headed home.  In about 5-7 minutes, Levichev called me and asked me to return to the precinct because I allegedly forgot to sign some documents in two places.  Since my lawyer already left me, I returned alone.  When I returned, Levichev began a second interrogation.  This time, it lasted for over 6 hours and ended late at night.

During this interrogation, I was threatened with imprisonment if I did not withdraw my complaint and did not stop “digging against the Governor.”  When I began screaming and demanding a lawyer, Levichev hit me in the face with a hand and said that he would personally kill me if I did not shut my Jewish mouth, if I did not shut the mouth of my freaking child and did not return the next day to withdraw my “false testimony”.  He promised that if I withdraw my complaint, he would help me not to be imprisoned for lying about the threats and would help me to get only a probation sentence.  I promised to do everything so that he would let me leave.

After I arrived home, I analyzed everything that happened and understood that I could not seek protection of my rights from the authorities.  It was a real possibility that I could get imprisoned and that my son and I could be mutilated – just as the detective described it.  Therefore, early next morning, I drove to Moscow with my children and together we took the first flight to the United States.

While in the United States, on around August 20, 2016, a police officer who did not state his name, called me on my Russian mobile phone ordering me to appear at the police station for further interrogations.  I told him that I was temporarily out of the country and could not appear.  The officer told me to visit him immediately after I return to Russia.

In October 2016, Ivan the Terrible’s sculpture was erected and Governor Potomsky personally inaugurated it saying that the tsar protected the orthodox church and Russia from its enemies.  (Exhibit Y)   Instead of placing it in front of the theater, the statue was erected in front of an Oryol Orthodox church with tsar holding up a cross.  Governor Potomsky said the following at the opening ceremony: “And no matter which enemies try to stop us from doing such acts – erecting sculpture to the first Russian tsar, – we will never bow and will not succumb.”  (Exhibit Y) Alexander Zaldostanov a.k.a. Khirurg (surgeon), a leader of the Russian biker club “Night Wolves” and a close friend of President Putin attended the opening ceremony at which he thanked Governor Potomsky and said the following: “You brought it to the conclusion, disregarding all the cockroach racing, all the counteractions, complaints and petitions.”  (Exhibit Y)  After the sculpture was unveiled, several social media sources cited the following phrase I used when I was interviewed by Associated Press: “Who was the fan of Ivan the Terrible? Stalin. Tyrants love Tyrants”.  (Exhibit Y)  

Governor Potomsky continued his revenge. For instance, recently, Anna Dulevskaya, one of the organizers of the rally, was attacked and threatened.  (Exhibit Z)  Andrey Roslov, organizer of a rally with an agenda of forcing Governor Potomsky to leave the office, is now under a criminal investigation.  (Exhibit Z). On October 21, 2016, the official newspaper of the Oryol Region “Orlovskaya Pravda” (The Oryol Truth) controlled by Governor Potomsky, published an article with my picture criticizing and ridiculing my actions.  (Exhibit AA)  This article created a whole new wave of discussions and many media companies began criticizing Governor Potomsky for using Soviet Era strategies in getting rid of his enemies.  (Exhibit BB)     

As a result of my political views, active expression of my beliefs and frequent criticism of the Government’s actions in the media, I was repeatedly persecuted by the Russian Government. My son was attacked, threatened beaten and injured by the people of Governor Potomsky because he was interviewed by the media and his name appeared in the news. I was also threatened and attacked by Potomsky’s people.  Additionally, the police interrogated, threatened, kept me in detention for many hours and physically abused me.  I was numerously threatened by the authorities and ordinary people who disliked my views.  I was summoned to appear at the local police department on several occasions.

I know that if I am forced to return to Russia, Governor Potomsky will not leave me alone.  He believes that I was the main cause of his humiliations in the media and he is probably right.  If I did not actively fight against his atrocious plan to erect a sculpture of Ivan the Terrible and did not actively involve the media, the sculpture would probably be in front of the children’s theater in the City of Oryol.  I am proud of what I did.  Unfortunately, my pride will not prevent Governor Potomsky from persecuting me.  If I return, he will probably have me arrested, prosecuted and imprisoned in jail for a long time.  Alternatively, he will simply order his people to get rid of me so that I cannot stand on his way anymore.

Here in the United States, I feel safe and secure for my children and I.  I am asking the U.S. Government to grant my asylum application so that I can live peacefully and continue making a difference in people’s lives.              

This statement has been prepared based on my recount of the events that I have provided in the Russian language.  This statement has been read back to me in its entirety in the Russian language.  I certify that all of the above statements and events are true to the best of my knowledge and belief.  I further certify that if any of the above statements or events are willfully false, I am subject to punishment.

Dated:                                                                                                   ______________________

                                                                                                              NATALIA GOLENKOVA


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