WITNESS QUESTIONS

Cross-Examination of Adam Kezza (PW-1):

 Length of Surveillance:

 Can you provide specific details on the nature and extent of

surveillance on Hugo Chavez and Camilo Cienfuegos since 2017?
 What specific activities or events led to considering them as potential
threats to national security?

 Intelligence Gathering:

 How was the intelligence gathered on the alleged plan to have a march
and protest against the Kosovo Border Act?
 Were there any corroborating sources or multiple channels of
information confirming the protest plans?

 Handling of Intelligence:

 Did you share the intelligence gathered on the protest plans with any
other law enforcement agencies or relevant authorities?
 Were there any specific instructions or precautions given based on the
intelligence received?

 Protest Turned Riot:

 How quickly did the peaceful protest turn into a riot, and what were the
specific events or triggers?
 Can you clarify if the violence was instigated by the protest leaders or
if it was initiated by other elements?

 Arrest of Hugo Chavez and Camilo Cienfuegos:

 Were there specific actions or statements by Hugo Chavez and Camilo

Cienfuegos during the protest that led to their arrest?
 Can you provide details on the evidence that directly links them to
inciting violence?

Cross-Examination Responses:

Adam Kezza (PW-1):

 Length of Surveillance:
 Response: The surveillance on Hugo Chavez and Camilo Cienfuegos
was a part of routine monitoring of individuals expressing dissent
against the government. It was a precautionary measure based on their
activities during their student days.
  Intelligence Gathering:
 Response: The intelligence on the protest plans came from multiple
sources, including informants within the student union and electronic
communication intercepts. These sources independently confirmed the
intention to have a protest against the Kosovo Border Act.

 Handling of Intelligence:
 Response: The intelligence was shared with relevant authorities to
ensure preparedness for any potential disturbances during the protest.
Precautions were taken, but the rapid escalation of violence caught us
by surprise.

 Protest Turned Riot:

 Response: The protest escalated into a riot when some participants
turned violent, attacking law enforcement and causing damage. While
the protest leaders may not have initiated the violence, their speeches
and influence contributed to the volatile atmosphere.

 Arrest of Hugo Chavez and Camilo Cienfuegos:

 Response: The arrest of Hugo Chavez and Camilo Cienfuegos was
based on their visible leadership roles during the protest and evidence
linking them to the incitement of violence. They were actively trying to
control the narrative and direction of the protest.

Cross-Examination of Wagner Senzeni (PW-2):

 Deployment and Role:

 What specific instructions were given to the police personnel deployed
to oversee the protest?
 Can you confirm the rules of engagement for handling potential
disruptions during the protest?

 Initial Calmness:
 For the initial peaceful hour of the protest, were there any indications
or signs of potential violence?
 How did the police respond to the first instance of stone-throwing and
subsequent detainment?

 Instigation by Camilo Cienfuegos:

 Can you provide the context and full content of Camilo Cienfuegos'
statement during the protest about letting blood flow?
 Were there any attempts made by the protest leaders to de-escalate the
situation after this statement?

 Discovery of Weapons:
 How were the firearms, petrol bombs, and other weapons discovered
near the protest site?
  Was there any evidence linking these weapons directly to Hugo
Chavez and Camilo Cienfuegos?

CROSS EXAMINATION RESPONSE Wagner Senzeni (PW-2):

 Deployment and Role:

 Response: The police were deployed to ensure public safety during the
protest. Instructions included maintaining order, detaining those
engaging in violence, and responding appropriately to any threats to
public safety.

 Initial Calmness:
 Response: The initial hour of the protest was calm, and there were no
clear indicators of potential violence. The first instance of stone-
throwing prompted a measured response, leading to the detainment of
the individual involved.

 Instigation by Camilo Cienfuegos:

 Response: Camilo Cienfuegos' statement was made in the heat of the
moment, and it did contribute to the escalation of violence. However,
the situation had already become volatile, and his statement wasn't the
sole cause of the riot.

 Discovery of Weapons:
 Response: Weapons were discovered during a routine sweep near the
protest site. While there's no direct evidence linking the weapons to
Hugo Chavez and Camilo Cienfuegos, their leadership roles raise
questions about their awareness of potential violence.

Cross-Examination of Herb Pacos (PW-3):

 Membership in BSK Group:

 Why did you choose to leave the Bektashi Students of Central Kosovo
University (BSK) group on December 7, 2019?
 Were there specific messages or actions within the group that
influenced your decision to leave?

 Content of Messages:
 Can you provide more details on the posters, pamphlets, and messages
circulated within the BSK group?
 Were these materials solely focused on opposing the government and
the Kosovo Border Act?
  Involvement in Protest Planning:
 Were you personally involved in any planning or organizing activities
related to the protest against the Kosovo Border Act?
 Did you witness any direct involvement or instructions from Hugo
Chavez or Camilo Cienfuegos in planning the protest?

RESPONSE OF CROSS EXAMINATION OF Herb Pacos (PW-3):

 Membership in BSK Group:

 Response: I left the BSK group on December 7, 2019, due to concerns
about the escalating nature of the messages and potential legal
repercussions. I didn't want to be associated with any unlawful
activities.

 Content of Messages:
 Response: The messages circulated in the BSK group focused on
opposing the government and the Kosovo Border Act. While they
expressed dissent, there was no direct incitement to violence in the
messages I saw.

 Involvement in Protest Planning:

 Response: I was not personally involved in planning the protest. My
presence at the initial meeting was out of curiosity, and I did not
witness any direct involvement or instructions from Hugo Chavez or
Camilo Cienfuegos in organizing violence.

Cross-Examination of Defense Witness Hugo Chavez (DW-1):

 Knowledge of Unlawful Elements:

 Question: Mr. Chavez, you mentioned that during the protest, some
unlawful elements took over and turned it into a riot. Can you provide
specifics on how these elements infiltrated the protest, and were there
any indications of their presence before the protest started?

 Communication within the Group:

 Question: You highlighted WhatsApp groups and meetings as means
of organizing the protest. Can you clarify the nature of discussions
within these groups and meetings? Were there any indications or
discussions about the possibility of violence?

 Preparedness for Violence:

 Question: In your statement, you indicated that neither you nor
Camilo Cienfuegos had any hand in inciting violence. Were there any
preparations or strategies discussed within your group to prevent or
address potential violence during the protest?
Answers for Cross-Examination of Defense Witness Hugo Chavez (DW-1):

 Knowledge of Unlawful Elements:

 Answer: The protest was initially organized with the intent of
expressing our concerns peacefully. Unfortunately, as the protest
unfolded, we noticed individuals behaving violently. These elements
infiltrated the peaceful gathering, causing chaos. There were no
indications of their presence before the protest began.

 Communication within the Group:

 Answer: Discussions within WhatsApp groups and meetings primarily
focused on coordinating peaceful protests. We emphasized non-
violence, and there were no explicit discussions or indications of
violence within the group.

 Preparedness for Violence:

 Answer: Our preparations were centered on a peaceful protest, and no
strategies were discussed to address potential violence. We believed in
the power of peaceful expression and did not foresee the need for
measures against violence.

Cross-Examination of Defense Witness Judith Chekov (DW-2):

 Provocative Speech at NAPM Office:

 Question: Ms. Chekov, you mentioned a meeting at the offices of
"National Alliance of People's Movement (NAPM)," where a
provocative speech was given by Julian Lamella. Can you elaborate on
the content of this speech and whether it contributed to the heightened
emotions during the protest?

 Warnings about Unlawful Elements:

 Question: You mentioned that Camilo Cienfuegos warned the
protesters about possible unlawful elements trying to turn the protest
violent. Did he or any other organizer take any specific measures to
prevent or control the situation once violence erupted?

 Reason for Protest:

 Question: Your statement emphasized the protest against the Kosovo
Border Act. Can you provide more details on why this act was
perceived as unconstitutional and discriminatory by your group, and
how this perception influenced the nature of the protest?

Answers for Cross-Examination of Defense Witness Judith Chekov (DW-2):

 Provocative Speech at NAPM Office:

 Answer: The speech by Julian Lamella at the NAPM office focused on
expressing the gravity of our protest against the Kosovo Border Act.
While it was impassioned, there was no intention to incite violence.
 Unfortunately, the subsequent events deviated from our peaceful
intentions.

 Warnings about Unlawful Elements:

 Answer: Camilo Cienfuegos did warn protesters about potential
unlawful elements seeking to escalate the situation. However, no
specific measures were discussed in advance to prevent or control
violence during the protest.

 Reason for Protest:

 Answer: The Kosovo Border Act was perceived as unconstitutional
and discriminatory because it excluded Bektashi from citizenship
rights granted to other religious groups. Our protest aimed to highlight
the injustice and discrimination faced by our community.

Cross-Examination of Defense Witness Camilo Cienfuegos (DW-3):

 Student Body Involvement:

 Question: Mr. Cienfuegos, you mentioned consulting with the current
student body. Can you clarify the level of involvement of the student
body in planning and executing the protest, and whether their concerns
were aligned with the objectives of the protest?

 Media Attention and Police Force:

 Question: You noted the significant media attention and a large police
force during the protest. Did the organizers anticipate such a response,
and did it influence the conduct of the protest in any way?

 Arrest and Subsequent Events:

 Question: After your arrest, were there any efforts made to
communicate with the protesting groups to calm the situation or clarify
the intentions behind the protest?

Answers for Cross-Examination of Defense Witness Camilo Cienfuegos (DW-3):

 Student Body Involvement:

 Answer: The student body was actively involved in planning and
executing the protest. They shared concerns about the discriminatory
nature of the Kosovo Border Act, aligning with the objectives of our
protest for justice and equal rights.

 Media Attention and Police Force:

 Answer: While we anticipated media attention due to the sensitive
nature of the protest, the scale of the police force was unexpected. It
did not influence the conduct of the protest, as our focus remained on
peaceful expression.
  Arrest and Subsequent Events:
 Answer: Following our arrest, there were no direct communication
channels with the protesting groups. We were unable to address or
clarify intentions due to the legal proceedings. Our commitment to
peaceful protest remains evident in our actions before the unfortunate
turn of events.

Witness: Herb Pacos (PW-1)

 Background and Presence at Gathering:

 Can you please provide your name, occupation, and background for the
record?
 Were you present at the university campus gathering on 13/12/2019? If
yes, can you describe your observations during the gathering?

 Witness to Anti-National Remarks:

 Did you witness Hugo Chávez and Camilo Cienfuegos making any
anti-national remarks during the gathering?
 Were there any instances of them criticizing the Kosovo Border Act
during the gathering?

 Pre-Planned Conspiracy:
 Based on your observations, do you believe there was a pre-planned
conspiracy by Hugo Chávez and Camilo Cienfuegos to organize public
gatherings in support of the rally?
 Were there any indications that the gatherings were organized to gain
support for the rally against the Kosovo Border Act?

Witness: Judith Chekov

 Background and Participation in the Protest:

 Could you please state your name and occupation for the record?
 Were you part of the protest on 13/12/2019? If yes, can you share your
experiences during the protest?

 Involvement of BSK and SCKU:

 Were you a member of the WhatsApp groups "Bektashi Students of
Central Kosovo University (BSK)" and "Student of CKU (SCKU)"?
 Can you describe any discussions or plans related to the protest that
you observed in these groups?
Witness: Wagner Senzeni (Police Constable)

 Observations during the Protest:

 Can you provide your name, rank, and role during the protest on
13/12/2019?
 What did you observe during the protest, especially regarding the
behavior of the gathered individuals?

 Use of Firearms and Deadly Weapons:

 Were there instances of the use of firearms, petrol bombs, acid attacks,
or deadly weapons against police officials during the protest?
 Can you describe the extent of injuries sustained by police personnel
and any damage to public/private property?

Herb Pacos (PW-1):

 Can you describe your presence at Central Kosovo University on December

13, 2019?
 Did you witness the active involvement of Hugo Chavez and Camilo
Cienfuegos in organizing and addressing the crowd during the protest against
the Kosovo Border Act (KBA)?
 What remarks or statements did Hugo Chavez and Camilo Cienfuegos make
during the gathering that you found to be anti-national or provocative?
 Were there any indications of pre-planning, such as distribution of pamphlets
or organized meetings, before the protest on December 13, 2019?
 Could you provide details of how the atmosphere changed during the protest,
leading to violent actions against the police and property damage?

Judith Chekov (PW-2):

 As a participant in the protest against the KBA, can you describe your
involvement on December 13, 2019?
 Were Hugo Chavez and Camilo Cienfuegos visible leaders during the
demonstration, and if so, how did they coordinate and direct the crowd?
 What specific incidents of violence did you witness during the protest, such as
stone-pelting, arson, or attacks on the police force?
 Can you elaborate on the content of the pamphlets distributed by the BSK,
especially regarding their aim to create fear and insecurity among the Bektashi
community?
 Were there any communications within the WhatsApp groups, such as
"Bektashi Students of Central Kosovo University (BSK)," that indicated
planning or coordination for the protest?
Wagner Senzeni (PW-3):

 As a constable on duty during the protest on December 13, 2019, can you
describe your observations and experiences throughout the event?
 How did the crowd react to the leaders, Hugo Chavez and Camilo Cienfuegos,
and what role did they play in inciting violence?
 Were there specific instances where the protest escalated into violence,
resulting in injuries to police personnel and damage to property?
 Can you provide details on the use of firearms, petrol bombs, and acid attacks
against the police, leading to the death of a police personnel and injuries to
others?
 Were there any warnings issued to the assembly of students, and how did they
respond to those warnings?

Adam Kezza (PW-4):

 In your role as the informant of the riot, how did you receive credible
information about the planned and conspired riots on December 13, 2019?
 Can you explain the nature of the conspiracy, including the provocative
speeches, organized protests, and the collection of firearms and deadly
weapons?
 What actions did you take upon receiving this information, and how did you
report it to your senior officers?
 Were there any specific indications or evidence that pointed to the
involvement of Camilo Cienfuegos and Hugo Chavez in planning and
executing the conspiracy?
 How do you link the events described in the information you received to the
charges under the Kosovo Penal Code and UAP(A) Act?

Hugo Chavez (DW-1):

 Can you provide more details about your educational background and your
role as a doctoral student at Central Kosovo University?
 In your statement, you mentioned being affiliated with the student body of
Central Kosovo University. Could you elaborate on your responsibilities as its
president?
 What motivated you to participate in protests against the Kosovo Border Act,
and how did you perceive the impact of this act on minority communities?
 Can you explain the sequence of events during the protest on December 13,
2019, and your role in leading the protest to various places in the city?
 You mentioned that the protest turned into a riot due to the actions of unlawful
elements. How did you and other members of the student body attempt to stop
the violence?
Judith Chekov (DW-2):

 Could you provide more information about your educational background and
your involvement as a doctoral student at Central Kosovo University?
 You mentioned being a member of a WhatsApp group called "Student of
CKU." How did this group contribute to the organization and coordination of
the protest against the Kosovo Border Act?
 What discussions or decisions were made during the meetings you attended
with core members such as Hugo Chavez, Camilo Cienfuegos, Paco Geovanni,
and Julian Lamella?
 How did you perceive the intentions and instructions given by Julian Lamella
to maximize the gravity of the protest?
 During the protest on December 13, 2019, how did Camilo Cienfuegos
attempt to prevent the protesters from turning violent after an attack on one of
them?

Camilo Cienfuegos (DW-3):

 Can you share more details about your educational background and your
extensive involvement as a student leader for the past decade?
 What motivated you to voice against the oppression of the government and
discrimination towards minority communities, particularly regarding the
Kosovo Border Act?
 How did you communicate the unconstitutionality of the act to the students
and the public through lectures and talks?
 Can you provide insights into the planning and organization of the protest,
including the creation of WhatsApp groups and meetings with the student
body and political parties?
 In your statement, you mentioned being hit during the riot while trying to stop
the violence. Could you elaborate on the circumstances surrounding your
arrest by the police the next day?