9-page indictment against Ümit Özdağ revealed: Here are the meetings and accusations...

The 9-page indictment prepared against Özdağ includes details regarding the accusations attributed to him and the discussions he held.

CRIME:Publicly Inciting the Public to Hatred and

Hostility in a Chain Manner via Press and Media

DATE AND PLACE OF CRIME : 18/04/2020 - 24/12/2024

DATE OF DETENTION:20/01/2025 - 21/01/2025 (1 Day)

DATE OF ARREST : 21/01/2025, Istanbul 2nd Criminal Court of Peace, decision dated 21/01/2025, numbered 2025/108

REFERRAL ARTICLE:Turkish Penal Code 216/1, 43, 218/1, 63, 53

EVIDENCE:Allegation, ex officio investigation report, open-source research reports, image examination and analysis reports, Public Security Bureau of the Kayseri Provincial Police Department Security Branch

report dated 21/01/2025,

Ankara Chief Public Prosecutor's Office investigation file number 2023/197905, Kayseri Chief Public Prosecutor's Office investigation file number 2024/47082,

expert report dated 21/03/2025, criminal record, population registration sample, and the entire scope of the file.

INVESTIGATION DOCUMENTS EXAMINED:

Our Chief Public Prosecutor's Office initiated investigation proceedings on 20/01/2025 against the suspect Ümit ÖZDAĞ, who is the Chairman of the Zafer Party.

Investigation proceedings were initiated on 20/01/2025.

Due to the words spoken by suspect Ümit ÖZDAĞ against the President of the Republic of Turkey, Recep Tayyip ERDOĞAN, at his party's provincial chairmen consultation meeting on 19/01/2025, a separation decision was made on 17/02/2025, and the investigation was registered under number 2025/39440. An indictment dated 17/02/2025 and numbered 2025/6525 was prepared regarding the charge of Insulting the President.

Within the scope of the investigation conducted for the crime of Inciting the Public to Hatred and Hostility or Publicly Humiliating, the suspect, from his official X (Twitter) account "Ümit Özdağ@umitozdag":

1- On 18/04/2020, he posted, "Hatay Mayor Lütfü Savaş reacted: Syrians have started buying land suitable for planting."

This post was denied by the Hatay Governor's Office.

2- On 04/08/2020, he posted, "Syrians' vehicles are undergoing free visa inspections." This post was denied by the Ministry of Interior.

3- On 03/04/2021, he posted, "Syrians do not commit crimes is a big lie. The Syrian mafia is growing every day."

4- On 18/05/2022, he posted, "Yesterday I spoke with S.A., who worked as a war correspondent for 30 years in the Middle East, Pakistan, and Afghanistan. He visited our southern provinces 1 month ago. He said he expects very severe events within 6 months.

He described his observations in Afghanistan-Iraq-Syria. Listen to the recording of the Soylu/Fidan WhatsApp conversation. Talk to S.A."

5- On 23/05/2022, he shared a video containing statements such as: "Turkey has been under a migration wave exceeding 10 million between 2011-2022. And the migration is not over yet... Our country is becoming more insecure every day.

In Gebze, an Afghan who came via Iran crushed Ayşegül's head with a stone and killed her because she resisted rape. Our women are being harassed on the streets by fugitives from Afghanistan and Pakistan. Minister of Interior Süleyman Soylu, who is tasked with protecting the borders, says, 'Let's send the Afghans, the Pakistanis. Who will do the shepherding, who will work in certain places...

I will see the business people then. He will say, 'Don't go, I'll increase your salary.' The Minister of Interior, who should protect the honor of the Turkish Nation, defended not our harassed women but the behavior of the harassers in a television program. 'Syrians are taking all the X-rays. All the X-rays.

So now I'm taking a selfie. If you were ill-intentioned, if there was a woman behind me when I took a selfie and I published the selfie, well look, he is X-raying this woman.' The Turkish Public is watching the silent resignation of its country in a tense and angry manner."

6- On 05/06/2022, he posted, "The Zafer Party warns. The wrong refugee policy is dragging Turkey into a disaster. You have filled Turkey with 10 million people, including all kinds of perverts, under the name of the Ummah. If there hasn't been a disaster until today, it is because of the nobility and patience of the Turkish Nation. But every patience has an end."

7- On 05/06/2022, he posted, "The Zafer Party warns. The wrong refugee policy is dragging Turkey into a disaster. You have filled Turkey with 10 million people, including all kinds of perverts, under the name of the Ummah. If there hasn't been a disaster until today, it is because of the nobility and patience of the Turkish Nation. But every patience has an end."

8- On 22/06/2022, he posted, "They harass as if they are walking, breathing, drinking water. They don't think what they are doing is wrong. They think Turkish women deserve this because of their clothing. If this continues, a father will pull out a gun and shoot. Then don't say the Zafer Party provoked it. You filled them here."

9- Quoting the post made from the official X (Twitter) account of Member of the Grand National Assembly of Turkey Süleyman Soylu,

"WE ARE NOT TALKING EMPTY, WE ARE PRODUCING SOLUTIONS! 62,145 briquette houses have been completed in Idlib for the HONORABLE VOLUNTARY SAFE RETURN of our Syrian brothers. TARGET BY THE END OF THE YEAR IS 100,603 BRIQUETTE HOUSES. AFAD with the instruction of our President," on 06/08/2022, he posted, "Letters were sent to the Governorates requesting them to transfer resources from provincial budgets for these houses. The Ordu Governorate transferred 8 million TL, which it should have spent for the people of Ordu, to Syria. They will send some Syrians to Idlib for show purposes before the election and feed them there."

This post was denied by the Ordu Governor's Office.

10- On 13/08/2022, he posted, "In Gaziantep Karataş neighborhood, a girl is walking on the street, listening to music with headphones in her ears. A car approaches from behind and wants to pull her inside. The girl resists, and as she is about to be forced into the car, citizens intervene. The gendarmerie passing by sees the situation and takes the Syrian. The prosecutor arrests him." This post was denied by the Gaziantep Governor's Office.

11- On 22/09/2022, he posted, "While the tension between Turkey and Greece is at its peak, refugees are starting forest fires." This post was denied by the Ministry of Interior.

12- On 22/11/2022, he posted, "6 Afghan attackers who came to a gas station in Konya Argıthanı sent 2 Turkish employees to the hospital. Allegedly, this was done in front of the Gendarmerie. The beaten Turkish workers were told, 'Don't get involved in the fact that the attackers are Afghans.' The detained Afghans were released!" This post was denied by the Konya Governor's Office Press and Public Relations Directorate.

Directorate.

13- On 11/12/2022, he posted, "SYRIAN TERROR IN GAZIANTEP! THEY RAPED AND BRUTALLY MURDERED! Videos of the horror of Syrians who brutally murdered 3 women after raping them in Antep spread on social media. The public in Antep took to the streets. Clashes broke out between Syrians and Turks.

Although the Gaziantep Governor announced that a curfew had been declared, the clashes that started in the city center spread to the districts of Gaziantep and Kilis. According to the information provided by the police, unfortunately, there are many casualties and injuries. They took people of unknown origin into this beautiful country, they filled it with members of terrorist organizations, God damn it! Now someone presses the button and puts the Salafi jihadists into action. They will definitely not be able to control the events.

It will not be possible to control 13 million refugees. STATE OF EMERGENCY HAS BEEN DECLARED! It was decided to declare a state of emergency. We learned that some foreign intelligence agencies are behind the events.

Our Minister of Foreign Affairs will invite the ambassadors of these countries to the ministry and warn them severely. In this process, the MIT undersecretary, who provided information to our National Security institution, said that PKK and YPG terrorists decided to infiltrate Turkey and start their actions. All evil forces have united against our country, friends," he shared a fictional video containing such words and writings,

adding the comment, "There is a terrible nightmare scenario planned for the Turkish Nation... It is time for #awakening to avoid living this nightmare... Great Turkish Nation, remember that; 'Sleeping nations either die or wake up as captives!'"

14- On 08/02/2023, he posted, "Looting, carried out mainly by refugees, is becoming widespread. Jewelry stores are being looted. Gold necklaces and bracelets are common among women in the region.

Gold jewelry has started to be stolen from corpses under the rubble. Some people have started to keep watch with guns."

15- On 10/02/2023, he posted, "From the first moment of the biggest disaster Turkey has experienced, refugees and fugitives are looting the cities. This is called dishonor! You brought this trouble upon us @RTErdoğan, and they will go, and you will go too."

16- On 10/02/2023, he retweeted the post by the user @zaferpartisi: "While our nation is struggling for its life, refugees and fugitives are looting the tents, clothes, and food sent to earthquake victims.

It's not enough, they are looting jewelry stores and even corpses. #ShootToKill order must be given against looters now!"

17- On 10/02/2023, he retweeted the post by a Twitter user named Uğur Batur: "Did you need electronic goods too? This is called looting, this is called theft. Will those who plagued this country with so many refugees be the solution? In 1 year, they will all go. EITHER THEY WILL GO OR THEY WILL GO."

18- On 10/02/2023, he retweeted the post by the account @emirkosif: "The footage is from Hatay Kırıkhan. There is so much looting. Those we have hosted for years are now attacking our people who are in a difficult situation with looting, rape, and threats. Whoever does this; may God damn them."

19-  On 10/02/2023, he retweeted the post by the account @zaferpartisi: "While our nation is struggling for its life, refugees and fugitives are looting the tents, clothes, and food sent to earthquake victims. It's not enough, they are looting jewelry stores and even corpses. #ShootToKill order must be given against looters now!"

20-  On 05/03/2023, he posted, "Seeing that the tension with Syrians in the earthquake zone would turn into a conflict, the Migration Administration directed Syrians to our western provinces, especially Istanbul.

600 thousand Syrians came to Istanbul and western provinces. I explained this issue with documents." This post was denied by the Presidency of Migration Management.

21- On 08/03/2023, he posted, "Looting, carried out mainly by refugees, is becoming widespread. Jewelry stores are being looted. Gold necklaces and bracelets are common among women in the region.

Gold jewelry has started to be stolen from corpses under the rubble. Some people have started to keep watch with guns."

22- On 07/03/2023, he posted, "Looting continues. Strict measures are needed," and the post was retweeted by the Zafer Party Kayseri Provincial Presidency as "We want a SHOOT order against looters."

23- On 08/03/2023, he posted, "Cold, earthquake, and Syrian looting in İskenderun."

24- On 02/07/2023, he posted, "Last night around 24.00, a group of Syrians were hitting stray dogs with sticks. The people of Dilovası who saw this intervened. Then the refugee group attacked the citizens' houses. Then a large group attacked them. The police intervened.

@zaferpartisi" This post was denied by the Kocaeli Governor's Office.

25- On 25/07/2023, he posted, "The police carried out a suicide bomber operation in Hatay Reyhanlı. It is stated that the detained terrorist is Syrian. @zaferpartisi" This post was denied by the Center for Combating Disinformation.

26-On 27/10/2023, he quoted an image with the text "While the country is going through very bad days, inflation is high, and due to the difficulty of living conditions, the Social Security Institution (SGK) is providing 4600 TL support to citizens to make their lives easier. Click here to register," and posted, "SGK is making an additional payment of 4600 TL to Syrian refugees so they are not crushed by inflation. Is this true SGK? @sgk"

This post was denied by the Center for Combating Disinformation.

27- On 18/08/2024, he posted, "Yunus Cengiz, an 18-year-old Yörük youth from Mersin. Yesterday, he was stabbed in 4 places by a group of Syrians. Since 2 wounds are near the heart, he is in intensive care. His older brother called me, saying, 'We are natives of Mersin. The youth are on the verge of exploding. I am barely holding them back.'

Dear youth, wait for the investigation to finish with a cool head. Pray for Yunus. Mersin police will do what is necessary. The Zafer Party will follow the incident. @zaferpartisi @MersininZaferii @EmniyetMersin" This post was denied by the Mersin Police Department.

28- On 24/12/2024, it was observed that he posted, "While the raise for minimum wage earners remains far below inflation, and our citizens who lost their homes in the February 6 earthquake are trying to live in containers, the Minister of Transport says AFAD will make infrastructure investments in Syria, and Ali Yerlikaya says we will build houses for Syrians. The Turkish people will continue to be crushed and exploited. @zaferpartisi"

Furthermore, in the examination of the digital materials of Ramin SAEİDİ, the user of the social media account named "Ambargotv" who was arrested within the scope of the Ankara Chief Public Prosecutor's Office investigation file number 2023/197905 for the crime of inciting the public to hatred and hostility or humiliation, it was determined that he used the social media account related to the crime in question. In the examination of Ramin SAEİDİ's digital materials,

regarding the use of the social media account named "Ambargotv" with suspect Ümit ÖZDAĞ;

1-In the correspondence on 05/07/2021;

Ramin: Hello, Professor, I will review the materials again and send them to Bekir Ali Bey via WhatsApp, and we will evaluate them... Regards...

Ümit ÖZDAĞ: Okay, I'm waiting.

Ramin: Professor, I made a video, if you find it appropriate, publish it.. I will make changes if necessary..

I made the Syrians black and white... I'm not adding the crescent and star at the beginning so everyone watches... otherwise some people won't watch when they see the crescent and star at the beginning.

Ümit ÖZDAĞ: Ramin, let's revise this, put my speech at the very end.

Ümit Özdağ: Remove the Kilis section, remove the Syrians who say they will stay, let it start with unemployed Turks and continue, then Meral Akşener's statement on Habertürk like 'my son, Syrians are finding jobs' should enter, put my statement at the very end, don't put any logo.

2-In the correspondence on 19/07/2021;

Ramin: Hello Professor, recently Iran and the Taliban are holding official meetings and Iran plays a serious role in the migration of these Afghans to Turkey... I think the reason is that Iran sees Turkey as a major threat to South Azerbaijan, so the increase in ethnic diversity in Turkey works for them, they will use it as a trump card against Turkey. Let's be careful, most of those coming are Hazara (Persian), even Shia... I want to make a video about this topic by making Turkish subtitles from Iranian and Afghan sources and combining it with your speeches... Without touching Iran, of course...

3-In the correspondence on 22/07/2021;

Ümit Özdağ: This didn't work, Ramin.

Ramin: Professor, this Iran-Taliban relationship is very scary because Turkey will also fight a kind of war with Iran in Afghanistan, this also works for the US... I will subtitle this video, look at what Zarif says while meeting with the Taliban, he says 'We are proud that we are by your side against foreign powers during your Jihad period.' These people he is meeting are not Afghan authorities. Taliban. I will connect this topic to Afghan migration in a way and combine it with your Habertürk speech.

Ümit Özdağ: Okay.

4-In the correspondence on 01/08/2021;

Ramin: It wouldn't be bad if we got one of ambargo.tv, ambargo.com, ambargo.org, ambargo.org.tr, it will be useful for us in the future.

Ümit Özdağ: You buy it, I'll pay for it.

Ramin: Okay Professor, I'll handle it tomorrow," it was determined that such correspondence existed.

In his defense taken within the scope of the Ankara Chief Public Prosecutor's Office investigation file number 2023/197905, Ramin SAEİDİ stated exactly: "I am originally from Tabriz, East Azerbaijan, Iran. I earn my living from art and media. The Twitter accounts with the handle "@ambargo tv" do not belong to me. This account currently belongs to Zafer Party Chairman Ümit ÖZDAĞ. I was involved in the editing and cutting processes of the videos. There were many people I knew/didn't know who were involved in these things like me. I was just one of them. So there were other people using the account besides me.

My personal acquaintance with Ümit ÖZDAĞ took place in 2021. Upon this acquaintance, I started to voluntarily do the editing and cutting work of the videos shared on the Twitter, Youtube, and Instagram accounts named "@ambargo tv" belonging to Ümit ÖZDAĞ. I started to edit and arrange the video shares made through the Twitter,

Youtube, and Instagram accounts named "@ambargo tv". I am still carrying out these works. Apart from these, I did not make the posts that have news value mentioned in the research report in the investigation file.

I did not determine the content of the posts made. I was directly requested by Ümit ÖZDAĞ. I would do the editing and cutting of the videos in line with these requests and show them to them as requested. After their approval, I would make the posts through the social media platforms I mentioned. I did not get confirmation for the video editing and cutting I did. I only made arrangements as requested from me.

As I mentioned above, the posts made through the accounts named "@ambargo tv" in the research report shown to me do not belong to me. I only did and was doing the editing and cutting of the videos to be shared through the Twitter, Youtube, and Instagram accounts. And I was carrying out the instructions for these by receiving them from Ümit ÖZDAĞ himself," he stated.

From the X (Twitter) account with the handle "Ambargo_tv," which Ramin SAEİDİ stated in his defense taken within the scope of the Ankara Chief Public Prosecutor's Office investigation file number 2023/197905 belongs to suspect Ümit ÖZDAĞ and which is proven to be managed by suspect Ümit ÖZDAĞ as understood from the correspondence between them,

29- On 11/09/2023, posts were observed such as: "Who will stop refugee terror? In Bursa, Erkan Sarı warned an armed Syrian group that was harassing his girlfriend and asking for obscene photos. The Syrian group beat Erkan Sarı. The attacking Syrians were released with judicial control because they were underage."

30- On 11/09/2023, posts were observed such as: "In Bursa, only Zafer Party Chairman Ümit Özdağ reacted to the beating of a disabled Turkish youth by invading Syrians, which caused public outrage."

As a result of open-source research, it was determined that suspect Ümit ÖZDAĞ;

31- In the video shared from the X (Twitter) account @zaferpartisi on 26/10/2021, the suspect made statements such as: "It is known by the Turkish people how heavy an economic, political, cultural, and geopolitical burden the 5.3 million Syrian refugees living in our country are for Turkey. Unfortunately, it is not possible for us to say that they have responded positively to the compassion shown to them by the Turkish people. It has emerged that Syrian refugees, who started a banana campaign in the media against the complaint of a Turk, which I think is quite justified, do not love our country and do not like the Turkish people at all. The Zafer Party is starting a signature campaign all over Turkey, and the purpose of this signature campaign is to get the support of the Turkish People for the return of Syrians to Syria. We do not love those who do not love us. We promise that we will do our best for them to return to their countries as soon as possible."

32- In the program broadcast on the YouTube channel named Pena on 18/01/2022, he used expressions such as: "... Look, many Syrian women work as prostitutes in Turkey. Let's go out to Taksim and walk together. Many Syrian children are preparing to become mafia, members of Salafi organizations, members of Arab nationalist organizations in Turkey's future."

33- On 03/07/2022, at the Zafer Party Aydın Provincial Presidency meeting, which was also shared live from his own YouTube channel named "Ümit Özdağ - Zafer Party Chairman," to the person who asked the question, "and if you come to power within 7 years, you are constantly in Istanbul, I guess you are going back and forth, for example, we don't see many refugees here in Aydın, there are between seven thousand and twelve thousand refugees as far as we know, what is the biggest threat these refugees can pose to the Republic of Turkey, the Turkish State, the Turkish Nation?" suspect Ümit ÖZDAĞ answered, "Civil war, civil war, there is nothing bigger than that, its economic cost has already exceeded one hundred billion dollars, we are paying the price every day, our streets have become insecure, gangs are forming, but in the end, a civil war will break out, what percentage probability, ninety-nine, no, one hundred percent, the issue is when it will happen, yes."

34- On 08/11/2022, it was determined that he made a post from the Instagram account @umitozdag: "Are you really proud of this picture? Are you proud of the fact that you don't show the interest you don't show to Turkish children so that Syrians can be successful, that you allocate the university quota of Turkish youth to refugees, that you push Turkish children to hopelessness?"

In the video shot by Oğuzhan KUMPINAR, a suspect in the investigation file number 2024/47082 conducted by the Kayseri Chief Public Prosecutor's Office for the crime of Publicly Inciting the Public to Hatred and Hostility or Humiliation, a copy of which is included in the investigation file, containing the speech: "Good day viewers, today we are in Kayseri's Republic Square, a neighborhood of ours shown as the Damascus neighborhood, the back street of the square, it may be too late for everything tomorrow, before agreeing with that person, before saying he was right, I repeat that we must do something for our homeland and protect our homeland, we have just entered the street, there are Arabic writings on the windows everywhere, Turkish citizens appear before us rarely. You see, these places are completely full of refugees, there are back streets, we as Turks are no longer even brave enough to enter there. Reproduction is some percent, we don't know. One who gives birth gives birth to ten like an incubator.

The entire main street is full of shops belonging to refugees, if it goes on like this with this birth rate, what will happen to this country we live in, our paradise homeland 40 years later, are you aware of the danger, now there are also the words of that poet; Am I a stranger in my own homeland, shame on those who cast me aside, shame on those who despise the wolf because it doesn't bow, and hold the bastard in high esteem, we are at the moments when that holder is ashamed," he shared on his X Twitter account @umitözdağ on 27/04/2024 with the comment "This is Kayseri. The Turkish city where the withdrawal of the TBMM was considered in the first days of the Battle of Sakarya. The middle of Anatolia. Please spare 4 minutes and watch. @Zaferpartisi @Zaferpartisi38." According to the report dated 21.01.2025 prepared by the Public Security Bureau of the Kayseri Provincial Police Department Security Branch, it was stated that approximately 15,100 people participated in protest actions in the events that took place in Kayseri province between 30.06.2024 - 03.07.2024, damage occurred in 263 residences/workplaces and 166 vehicles in the neighborhoods where the events took place, and 25 police personnel and 1 firefighter were injured as a result of the events, and it was evaluated that the individuals participating in the events were influenced by the posts made on social platforms by Zafer Party members and supporters.

In his defense, the suspect stated in summary that he did not accept the accusation against him and that the legal elements of the alleged crime were not formed.

Following his defense, it was decided to arrest him with the decision of the Istanbul 2nd Criminal Court of Peace, interrogation number 2025/108, to which he was referred with a request for arrest.

When the entire investigation file is examined together, for the crime of Inciting the Public to Hatred and Hostility or Humiliation, which is stipulated in Article 216/1 of the Turkish Penal Code No. 5237, to be formed, a segment of the public with different characteristics in terms of social class, race, religion, sect, or region must be publicly incited to hatred and hostility against another segment, and a clear and imminent danger to public safety must arise due to this incitement. The legal interest protected by this crime is the prevention of possible hatred and hostility between different elements of society and the protection of public peace. Groups with the characteristics specified in Article 216/1 of the TPC having hostility or hatred towards each other would mean enabling them to hate each other, but for the crime to be formed, it is not necessary for the incitement to have brought the specified groups face to face; it is sufficient for people belonging to one class to be incited against some people belonging to another class, or for existing hatred to be strengthened. In the concrete case, the suspect, from his X (Twitter) account @umitozdag, on "22/11/2022, '6 Afghan attackers who came to a gas station in Konya Argıthanı sent 2 Turkish employees to the hospital. Allegedly, this was done in front of the Gendarmerie. The beaten Turkish workers were told, 'Don't get involved in the fact that the attackers are Afghans.' The detained Afghans were released!'", on 22/09/2022, "While the tension between Turkey and Greece is at its peak, refugees are starting forest fires", on 25/07/2023, "The police carried out a suicide bomber operation in Hatay Reyhanlı. It is stated that the detained terrorist is Syrian.

@zaferpartisi", on 02/07/2023, "Last night around 24.00, a group of Syrians were hitting stray dogs with sticks. The people of Dilovası who saw this intervened. Then the refugee group attacked the citizens' houses. Then a large group attacked them.

The police intervened. @zaferpartisi", on 05/03/2023, "Seeing that the tension with Syrians in the earthquake zone would turn into a conflict, the Migration Administration directed Syrians to our western provinces, especially Istanbul. 600 thousand Syrians came to Istanbul and western provinces. I explained this issue with documents.", quoting the image with the text "While the country is going through very bad days, inflation is high, and due to the difficulty of living conditions, the Social Security Institution (SGK) is providing 4600 TL support to citizens to make their lives easier. Click here to register" on 27/10/2023, "SGK is making an additional payment of 4600 TL to Syrian refugees so they are not crushed by inflation. Is this true SGK? @sgk", quoting the post made from the official X (Twitter) account of Member of the Grand National Assembly of Turkey Süleyman Soylu, "WE ARE NOT TALKING EMPTY, WE ARE PRODUCING SOLUTIONS!

62,145 briquette houses have been completed in Idlib for the HONORABLE VOLUNTARY SAFE RETURN of our Syrian brothers. TARGET BY THE END OF THE YEAR IS 100,603 BRIQUETTE HOUSES. AFAD with the instruction of our President", on 06/08/2022, "Letters were sent to the Governorates requesting them to transfer resources from provincial budgets for these houses. The Ordu Governorate transferred 8 million TL, which it should have spent for the people of Ordu, to Syria. They will send some Syrians to Idlib for show purposes before the election and feed them there", on 13/08/2022, "In Gaziantep Karataş neighborhood, a girl is walking on the street, listening to music with headphones in her ears. A car approaches from behind and wants to pull her inside. The girl resists, and as she is about to be forced into the car, citizens intervene. The gendarmerie passing by sees the situation and takes the Syrian. The prosecutor arrests him", on 18/04/2020, "Hatay Mayor Lütfü Savaş reacted: Syrians have started buying land suitable for planting", on 04/08/2020, "Syrians' vehicles are undergoing free visa inspections", his posts denied by various public institutions and the posts dated 03/04/2021, 18/05/2022, 23/05/2022 explained above,

05/06/2022, 22/06/2022, 08/11/2022, 11/12/2022, 08/02/2023, 10/02/2023, 05/03/2023, 08/03/2023,

02/07/2023, 25/07/2023, 11/09/2023, 27/10/2023, and the statements he made on 26/10/2021

"It is known by the Turkish people how heavy an economic, political, cultural, and geopolitical burden the 5.3 million Syrian refugees living in our country are for Turkey. Unfortunately, it is not possible for us to say that they have responded positively to the compassion shown to them by the Turkish people. It has emerged that Syrian refugees, who started a banana campaign in the media against the complaint of a Turk, which I think is quite justified, do not love our country and do not like the Turkish people at all. The Zafer Party is starting a signature campaign all over Turkey, and the purpose of this signature campaign is to get the support of the Turkish People for the return of Syrians to Syria. We do not love those who do not love us. We promise that we will do our best for them to return to their countries as soon as possible", and the statements he made on 18/01/2022 "...

Look, many Syrian women work as prostitutes in Turkey. Let's go out to Taksim and walk together. Many Syrian children are preparing to become mafia, members of Salafi organizations, members of Arab nationalist organizations in Turkey's future.. These are just the tip of the iceberg, there is a much deeper structure underneath... In summary, we need to protect Turkey from disaster, the anger of the Turkish Nation is increasing, when the last Syrian leaves, we will play the Mehter March at the border gates", and the statements he made on 03/07/2022 "Civil war, civil war, there is nothing bigger than that, its economic cost has already exceeded one hundred billion dollars, we are paying the price every day, our streets have become insecure, gangs are forming, but in the end, a civil war will break out, what percentage probability, ninety-nine, no, one hundred percent, the issue is when it will happen, yes" contain expressions aimed at exhibiting provocative attitudes and behaviors, his posts and statements are of a nature to direct a segment of the public to hatred, hostility, and discrimination against another segment, the posts were shared many times by many accounts and groups with comments, creating an agenda in the media, and subsequently, by creating an effect that would cause concern in the eyes of those incited, a clear and imminent danger to public safety emerged, and as understood from the report dated 21/01/2025 prepared by the Public Security Bureau of the Kayseri Provincial Police Department Security Branch, it was effective in the formation of the events that took place in Kayseri province between 30.06.2024 - 03.07.2024, which resulted in the injury of 25 police personnel and 1 firefighter, and in this respect, the concrete danger element of the alleged crime was also realized, the suspect continued his posts of a nature to direct to hatred and discrimination on 18/08/2024 and 24/12/2024, in this context, the suspect

has sufficient suspicion of committing the crime of Publicly Inciting the Public to Hatred and Hostility, which is regulated in Article 216/1 of the TPC, and since the suspect, who committed his actions within the scope of the execution of a decision to commit a crime at different times, published the posts subject to the investigation through his publicly accessible X (Twitter), Instagram, and YouTube accounts, it is understood that the provisions of Articles 218 and 43 of the TPC should also be applied to the suspect in accordance with Article 6-g of the TPC,

it is understood that the provisions of Articles 218 and 43 of the TPC should also be applied to the suspect in accordance with Article 6-g of the TPC,

That the suspect be tried by your court and;

1) That he be punished in accordance with Articles 216/1, 218/1, 43 of the TPC for the crime of Publicly Inciting the Public to Hatred and Hostility in a Chain Manner via Press and Media,

which corresponds to his action,

2)In case of conviction for a prison sentence for the crime he committed intentionally, that he be deprived of using the rights in Article 53 of the TPC,

3)In case of the suspect's conviction, that the time he spent in detention and arrest be deducted in accordance with Article 63 of the TPC,

4) That it be decided to also apply Article 325 of the Criminal Procedure Code No. 5271 regarding the suspect,

It is claimed and requested on behalf of the public. 08/04/2025

MEHMET ATEŞ 198450

Public Prosecutor

NOTE: Due to the words spoken by suspect Ümit ÖZDAĞ against the President of the Republic of Turkey, Recep Tayyip ERDOĞAN, at his party's provincial chairmen consultation meeting on 19/01/2025, a separation decision was made on 17/02/2025, and as a result of the investigation registered under number 2025/39440,

an indictment dated 17/02/2025 and numbered 2025/6525 was prepared regarding the charge of Insulting the President.