Operation "Self-Goal": How Novice OSINTers from NGO "Vilny Skhid" Attempted to Intimidate Investigators with Legal Threats

Response of "On the Other Side of Dialogue" to the retraction demand from NGO "Vilny Skhid" and "IRTA-fax": procedural facts, ECHR case law, and complete silence on Lysychansk’s missing hundreds of millions.

In classic administrative tradition, there is a golden rule: never interrupt an opponent in the process of committing public professional suicide—if they have begun, simply illuminate them with spotlights.

On the evening of October 30, exactly three hours after the release of our investigation into the media network of the Luhansk Regional Military Administration (OVA), our editorial inbox received an ultimatum. The publisher of "IRTA-fax"—the non-governmental organization "Vilny Skhid" (EDRPOU 44726298)—issued a pre-litigation cease-and-desist letter demanding an immediate retraction, apologies, and the cessation of critical coverage regarding their procurement record.

Any disciplined civil servant or legal clerk would have dismissed this communication immediately: it lacked an outgoing reference number, official letterhead, and the signature of either the organization’s director or editor-in-chief. It was an anonymous message dispatched from a free Gmail account.

While responding to such informal inquiries is rarely warranted, amateur attempts at legal pressure cannot be overlooked. In their haste to defend their 20% commission arrangements, the authors created an undeniable paper trail:

1. They explicitly acknowledged awareness of their status in investigative court rulings under SBU criminal proceeding No. 42026130000000016 (where the NGO is cited as a technical dummy participant in rigged procurement worth 3.21 million UAH);
2. They formally admitted receiving regional state budget contracts for "public relations services";
3. Most notably—across three pages of grievances, they failed to offer a single explanation regarding the allocation of 401.7 million UAH from the Lysychansk municipal budget or the undisclosed registry of regional officials granted mortgage cancellations.

We have provided our colleagues with a comprehensive legal rejoinder grounded in the case law of the European Court of Human Rights, the Law of Ukraine "On Information," and established criminal case records. Furthermore, to clarify the operational reality within the regional administration, we append the official response from department head Roman Mamedov dated October 30, confirming that the computers of the anti-corruption working group were confiscated by SBU investigators.

Below is the unabridged text of the formal response from the Association "DE L'AUTRE CÔTÉ DU DIALOGUE," which has been forwarded to the Dnipropetrovsk District Administrative Court under Case No. 160/34036/26 as evidence of extraprocedural pressure on the plaintiff.

FORMAL REJOINDER TO RETRACTION DEMAND

DE L'AUTRE CÔTÉ DU DIALOGUE

ASSOCIATION DE PRESSE ET D'INFORMATION

(Loi du 1er Juillet 1901 – Préfecture de l'Hérault)

Numéro RNA: W341015162 | SIÈGE SOCIAL: 11 rue Saint-Louis, 34600 Bédarieux, France

Ref. No. 12/10 dated October 31, 2026

To: The Editorial Board of the Information Portal "Irta-fax"

To the Publisher: Non-Governmental Organization "Vilny Skhid" (EDRPOU 44726298)

E-mail: admin@irtafax.com, severodonetcklg@gmail.com

RE: RESPONSE TO YOUR COMMUNICATION DATED OCTOBER 30, 2026

(Reply to Demand for Retraction and Clarification)

Dear Editors of "Irta-fax" and Leadership of NGO "Vilny Skhid",

The editorial board of "On the Other Side of Dialogue" and investigative journalist Serhii Stulov confirm receipt of your email dated October 30, 2026, concerning our publication “Criminal Choir on Call: How Pocket Media Shields Luhansk Regional Administration from a 500-Million-Hryvnia Embezzlement Scheme.”

Having reviewed your claims and the proposed retraction draft, we inform you that your demands for retraction and publication of your statement are rejected in their entirety as legally unfounded.

In accordance with professional standards of transparency, press freedom, and the jurisprudence of the European Court of Human Rights, we provide the following point-by-point clarification:

1. Legal Classification of Assertions (Verifiable Facts vs. Value Judgments)

Your letter conflates procedural factual findings with the value judgments of an investigative reporter.

• Under Article 30, Part 2 of the Law of Ukraine "On Information," value judgments—including critical appraisals, satirical phrasing, metaphors, and hyperbole—do not contain verifiable factual assertions and are not subject to forced retraction or evidentiary burden of truth.
• The European Court of Human Rights (Lingens v. Austria, Thorgeir Thorgeirson v. Iceland, Ukrayinska Pres-Grupa v. Ukraine) has consistently held that journalistic freedom includes a degree of exaggeration or provocation. Outlets funded by government entities during wartime must withstand heightened public scrutiny and criticism.

The terms used in our reporting represent legitimate value judgments derived from verified documentary findings.

2. Specific Responses to Your 4 Inquiries

Regarding Points 1 and 2 (Allegations of Sponsored Content and Official Advocacy):

1. Editorial Coordination: On October 28, 2026, three identical publications based on the same assertions by Natalia Sokolenko, citing identical fragmented case files from Case No. 160/34036/26, were released simultaneously across three platforms: "IRTA-FAX," sd.ua, and "TRIBUN."
2. Obvious Slant: Your publications of October 28 and 30 sought to portray our administrative lawsuit challenging the 500-million housing allocation framework (Order No. 452) as completely without merit. By focusing on preliminary court fees and provisional motions, you omitted the foundational public inquiry: where were the 401.7 million UAH from the Lysychansk budget allocated under the 2025 Registry No. 2, and where is the complete registry of public officials who received these subsidies?
3. Institutional Conflict of Interest: You formally admit receiving regional administration contracts to "cover official activities." An organization funded by public administration budgets inevitably incurs an institutional conflict of interest when publishing biased reports defending that same administration against legal challenges.

Regarding Point 3 (Financial Allocations: 20% Fee and 80% Kickbacks): Our report explicitly states that these findings are drawn directly from official court records within SBU criminal proceeding No. 42026130000000016.

Your own letter states:

“We do not deny that published court decisions contain the prosecution’s version regarding the involvement of NGO Vilny Skhid as a technical tender participant...”

Rulings by the investigating judge of the Soborny District Court of Dnipro (Case No. 201/13681/26) document that the former head of the regional communications department, Albina Kusheleva, engaged NGO "Vilny Skhid" (EDRPOU 44726298) in tender UA-2026-03-13-012479-a (valued at 3,210,900 UAH) solely to simulate competitive bidding. Witnesses and court records confirm that intermediate contractors retained approximately 20% for intermediary handling, while 80% was converted to cash and funneled back to department officials via postal parcel services. Our article reported the operational mechanics established by court filings.

Regarding Point 4 (Nominal Beneficiary Classification): While non-profit organizations do not have ultimate beneficial owners in the commercial sense, the term describes the corporate umbrella under which an entity engaged in questionable public tenders functions concurrently as the institutional publisher of the "Irta-fax" outlet.

3. Formal Acknowledgment by the Regional Administration (Oct 30, 2026)

Simultaneously with your communication, our editorial office received formal correspondence No. 04/3-43/1024 from the acting director of the Luhansk Regional Media Department, Roman Mamedov.

This document officially confirmed:

1. That the workplace desktop computer of working group secretary Albina Kusheleva was confiscated by SBU investigators as physical evidence in criminal proceedings;
2. That the 3.21-million-UAH media contract involving NGO "Vilny Skhid" was never reviewed or approved by the regional anti-corruption oversight group.

4. Regarding Your Offer for a Guest Column Under "Opinion"

We acknowledge your offer to submit commentary to the "Opinion" section of "Irta-fax." However, independent investigative reporting cannot be subjected to editorial revisions or screening by an organization named in anti-corruption criminal filings. If "Irta-fax" seeks journalistic balance, it should publicly answer: why have you not published the complete recipient list of the 401.7 million UAH allocated from the Lysychansk community budget?

SUMMARY

1. The editorial board of "On the Other Side of Dialogue" and author Serhii Stulov formally reject your retraction demand. The published material serves an imperative public interest, is based on formal court records, and all characterizations represent protected value judgments.
2. Your letter, this rejoinder, and supporting criminal court records are being submitted to the Dnipropetrovsk District Administrative Court under Case No. 160/34036/26 as documentation of extraprocedural pressure on the plaintiff.

Serhii Stulov

Investigative Journalist,

Representative of Association «DE L’AUTRE CÔTÉ DU DIALOGUE» (France)