US Responds to The Glorious Revolution in Cuba
The triumph of the Cuban Revolution on January 1st, 1959 meant for the people of Cuba -- for the first time in its long history of struggles -- the conquest of true independence and sovereignty, with a death toll of about 20,000 people who perished in direct and heroic combat against the forces of a military dictatorship trained, equipped and advised by the United States government.
The revolutionary victory in Cuba was one of the most humiliating political defeats the United States sustained after it became a great imperialist power. This determined that the historic dispute between the two nations would enter a new and more acute stage of confrontation characterized by the implementation of a brutal policy of hostility and all sorts of aggressions emanating from the United States and aimed at the destruction of the Cuban Revolution, the recapture of the country and the return to the neocolonial domination system that it had imposed on Cuba for over a century and which it definitely lost over 40 years ago.
The war unleashed by the United States against the Cuban Revolution, conceived as a state policy, has been historically proven and can be fully confirmed by multiple information released in that country as of late showing a number of political, military, economic, biological, diplomatic, psychological, propagandist and spying actions; the execution of acts of terrorism and sabotage; the organization and logistic support of armed bandits and clandestine groups of mercenaries; the encouragement of defection and migration and the attempts at the physical elimination of the leaders of the Cuban revolutionary process. All this has been exposed in very significant public statements made by senior officials of the U.S. government as well as in the countless and irrefutable evidences accumulated by the Cuban authorities. Also, numerous declassified secret documents are particularly eloquent and although not all have been released those that already have sufficed to fairly prove the grounds for this claim.
One of the documents annexed in confirmation of the events described is the already declassified "Program of Covert Actions against the Castro Regime" approved on March 17, 1960 by United States President Dwight D. Eisenhower. The second, entitled the Cuban project and introduced on January 18, 1962 by Brigade General Edward Landsdale to the highest echelons of the Unites States government and the National Security Council special expanded group contains the list of 32 covert actions to be carried out by the agencies and departments taking part in the so-called Operation Mongoose. Every hostile and aggressive action conducted by the U. S. Government against Cuba from the very triumph of the Revolution up to the present has caused enormous material and human losses and incalculable suffering to the people of this country as well as hardships resulting from the shortage of medication, food and other indispensable means of life which we deserve and have the right to obtain with our honest labor. Likewise, the political and ideological subversion, which resulted in a continual, extensive and unjustified distress endured by all the people, has posed constant dangers and caused damages characterized by their pervasive presence and almost immeasurable scope. This has jeopardized an accurate assessment which we are not including this time for the purpose of this lawsuit in order to strictly limit ourselves to the content of the restitution for moral damages as prescribed by the Cuban Civil Code presently in force, although we do not renounce our right to do it in due course. Pursuant to international practice, a State is responsible for the damages caused by the behavior and actions -- in legislative, as well as in administrative and judicial terms -- of its agents and officials, and even for the actions of each country's citizens, if the corresponding authorities in said State fail to take preventive or suppressive measures. Thus, it is its duty to compensate for such damages in compliance with what is universally rated as civil liability.
Accordingly, the United States of America, as a State represented by its government, is accountable for the damages caused to Cuban citizens and entities due to the unlawful actions undertaken by its agencies, departments, representatives, officials or the Government itself.
SECOND: That the recent declassification in the United States of a report produced by Central Intelligence Agency (CIA) Inspector General Lyman Kirkpatrick on October 1961, with a review of the reasons for the failure of the Bay of Pigs invasion -- as it is called in America -- has revealed that the covert operations organized in Washington against Cuba began in the summer of 1959, a few weeks after the adoption of the Land Reform Law on May 17, that year. In the month of October, President Eisenhower approved a program proposed by the Department of State and the CIA to undertake covert actions against Cuba, including air and naval pirate attacks and the promotion of, and direct support to, counter-revolutionary groups inside Cuba. According to the document, the operations were to have succeeded in making the overthrow of the revolutionary regime look like the result of its own mistakes. Those days saw the beginning of a campaign of flights over Cuban territory by small aircraft coming from the United States with such missions as the infiltration of agents, weapons and other equipment and the realization of acts of sabotage, bombings and other acts of terrorism. On October 11, 1959, a plane dropped two firebombs on the Niagara sugar mill in Pinar del Río province.
On October 19, another two bombs were hurled from the air over the Punta Alegre sugar mill in Camagüey province. On October 21, a twin-engine aircraft machine- gunned the city of Havana, killing several people and injuring dozens while another light aircraft dropped subversive propaganda. On October 22, a passenger train was machine-gunned in Las Villas province. On October 26, two light aircraft attacked both the Niagara and Violeta sugar mills. From the very month of January 1960, while that year's sugar harvest was in full swing, the number of flights over sugar-cane plantations multiplied. On January 12 alone, 500,000 arrobas [1 arroba equals 25 pounds] of sugar cane were set on fire from the air in Havana province.
On January 30, over 50,000 arrobas were lost at the Chaparra sugar mill in the former province of Oriente and, on February 1st , more than 100,000 arrobas were set alight in Matanzas province. Other air attacks followed: on January 21st, a plane dropped four 100-pound bombs over the urban areas of Cojímar and Regla, in the nation's capital. On February 7, 1960, a light plane set afire 1.5 million arrobas of sugar cane in the Violeta, Florida, Céspedes and Estrella sugar mills in Camagüey province. On February 18, a plane that was bombing the España sugar mill in Matanzas province was destroyed in mid air by one of its own bombs. The pilot was identified as Robert Ellis Frost, a U.S. citizen. The flight card registered the plane's departure from Tamiami airport in Florida. Other documents found on the corpse revealed that on three previous occasions the pilot had taken part in similar flights over Cuba. On February 23, several light aircraft sprayed incendiary capsules over the Washington and Ulacia sugar mills in the former province of Las Villas, as well as over Manguito in Matanzas province.
On March 8, another light aircraft dropped inflammable substances over the area of San Cristóbal and set alight more than 250,000 arrobas of sugar cane. At that stage, along with the bombing, strafing and burning missions, there were successive flights over Havana and almost every other province in the country with the aim of spreading subversive propaganda. Dozens of such flights were recorded just in the first three months of 1961. In the aforementioned report by Lyman Kirkpatrick on the Bay of Pigs invasion, it was stated that "at the time of the invasion, 12 million pounds of leaflets had been dropped over Cuba", leaflets containing counter-revolutionary propaganda. In his report, the high-ranking CIA officer described the steps that had been taken from August 1959 by a paramilitary group from that institution.
This is but an example. The covert war against Cuba had begun, with high intensity, in the year 1959 itself. An infinite number of hostile and aggressive actions, impossible to list in detail, would follow in the coming years. The Inspector General of the Central Intelligence Agency recognized that "from January 1960, when it had 40 people, the branch expanded to 588 by April 16, 1961, becoming one of the largest branches in the Clandestine Services". He meant the CIA station in Miami which concentrated on activities against Cuba. There is a mountain of evidence, background information and facts that cannot possibly be ignored. What is beyond question is that, in just a few weeks, the hemorrhagic dengue epidemic in Cuba -- where it had never existed -- had affected a total of 344,203 people, a figure with no known precedent in any other country of the world. Another record was set when 11,400 new patients were reported in a single day on July 6, 1981. A total of 116,143 people were hospitalized. About 24,000 patients suffered from hemorrhaging and 10,224 suffered some degree of dengue- induced shock. One hundred and fifty-eight people died as a result of the epidemic, including 101 children.
The whole country and all its resources were mobilized to fight the epidemic. The vector's presence was strongly and simultaneously controlled in all of Cuba's towns and cities, using all possible means and with products and equipment urgently bought from anywhere, including the United States. A request was made to the United States through the Pan-American Health Organization and finally, in the month of August, an important larvicide was purchased. Chemicals and equipment were brought in, often by plane and sometimes from countries as far away as Japan, whose factories sold Cuba thousands of individual motor fumigators. Malathion had to be brought from Europe at a transportation fee of 5,000 dollars a ton, that is, three and a half times the cost of the product. In addition to the existing hospital network, dozens of boarding schools were turned into hospitals in order to isolate every new patient reported, without exception. At the same time, intensive care units were built and equipped in all of the country's children's hospitals. The last infected case was reported on October 10, 1981.
If it had not been for this enormous effort, tens of thousands of people, the vast majority of them children, would have died. An epidemic that many experts had forecast would take years to eradicate was eradicated in little more than four months. The adverse economic impact was also considerable. The list of the dead as a result of the epidemic is authenticated through the corresponding certification issued by the Ministry of Public Health, and attached as document number 22.
THIRD: That barely fifteen months after the revolutionary victory, armed banditry was planned and finally unleashed by the United States government, practically all over Cuba. It began in 1960 under the Republican Administration of President Eisenhower and lasted five years until 1965. Its main thrust would be on the Escambray, region in the former province of Las Villas, which now comprises the provinces of Villa Clara, Cienfuegos and Sancti Spíritus. A so-called front operated in that zone with columns, bands and a commanding post. Weeks before the Bay of Pigs mercenary invasion, 40,000 workers and students from the nation's capital, supported by local forces from the central region and peasants and farm workers from the Escambray and organized in militia battalions, surrounded and rendered helpless that bulwark which was to have co-operated with the invasion forces. Hundreds of bandits were captured and their number reduced to a minimum in those critical days. Those bandits, organized by the CIA, had the support of the U. S. Government which made the greatest efforts and resorted to every possible means to supply them with weaponry, ammunition, explosives, communication equipment and general logistics.
To this end, the U.S. government used different routes by air, by sea and even via diplomatic channels through the United States embassy in Havana, until relations were severed at the beginning of 1961. In this respect, the previously mentioned report by the CIA Inspector General explicitly recognized the logistical support provided by that institution to the mercenary bands. One example is the so-called Operation Silence, which consisted of the United States Central Intelligence Agency carrying out twelve air operations between September 1960 and March 1961 in order to supply the bandits with arms, ammunition, explosives and other equipment. About such operation the author of the report stated: "In all, about 151,000 pounds of arms, ammunition and equipment were transported by air."
On September 29, 1960, a four-engine plane dropped a cache of weapons over the Escambray mountains, near the Hanabanilla waterfall. On November 7, a plane dropped another cache of arms over the area of Boca Chica, near El Condado village on the Escambray mountain range. On December 31st, another package was dropped over the area known as Pinalillo, between Sagua and La Mulata, in Cabañas in Pinar del Río province. On January 6, 1961, an aircraft dropped twenty parachutes with arms, ammunition, explosives and communication equipment between El Condado and Magua, in Trinidad, Las Villas province. On January 7, the following day, an aircraft dropped U.S. weapons between Cabañas and Bahia Honda, Pinar del Río.
On February 6, a plane dropped thirty parachutes with arms, ammunition, explosives, communication equipment and food over the area of Santa Lucia in Cabaiguán, Las Villas province. On February 13, twenty other parachutes were dropped from a plane over the area of El Naranjo, in Cumanayagua, Las Villas. On February 17, a plane dropped thirteen parachutes between San Blas and Circuito Sur, near La Sierrita, Las Villas. On March 3, a plane dropped two cache of arms, ammunition and explosives in the areas of El Mamey and Charco Azul, both in Las Villas province.
On March 29, there was another drop of arms and supplies over the Jupiter farm in Artemisa municipality, Pinar del Río province. In other words, a total of more than 70 tons of weapons were sent by air in that períod. Significant pockets of subversion were created in the provinces of Pinar del Río, Havana, Matanzas, Camagüey and Oriente. It is worth emphasizing that the first group was organized in the province of Pinar del Río, led by Luis Lara Crespo, a former corporal with Batista's army who was a fugitive from revolutionary justice for his crimes. It was in that same province, that Rebel Army private Manuel Cordero Rodríguez was killed in action against a group of bandits commanded by U.S. citizens Austin Young and Peter John Lambton. These two men were captured along with the rest of the bandits, and their weapons -- part of those supplied by the United States -- were seized. These mercenary groups were to be succeeded by others.
It is equally useful to highlight those headed by Pedro Roman Trujillo in the Escambray region and Olegario Charlot Pileta in the former province of Oriente, both were also among the first groups created in those provinces. Faced with these expressions of growing aggression orchestrated by the U.S. government, the Cuban people -- through their defense and security institutions and revolutionary organizations -- were actively and resolutely mobilized. They dealt sensitive blows to the enemy and captured, dispersed or dismantled most of the bandits thus, writing pages of heroism and sacrifice with their own blood and the loss of many precious lives. This situation was not correctly assessed by the CIA which assumed that the mercenary invasion would have the support of these forces. However, after the historic defeat it persisted in its plans of a dirty war. Under the Administrations of Presidents John F. Kennedy and Lyndon B. Johnson, the CIA multiplied its efforts to that end, so there was a resurgence of bands which forced our people to pay an additional toll in blood and lives.
The unquestionable historical truth about these events and the cynicism and lies that have invariably accompanied all U.S. actions against Cuba can be found in the original documents of the time, produced by those who planned the policy of aggression and subversion against Cuba from within that country.
In this context, it may be illustrative for this Court that on March 17, 1960, at a meeting attended by Vice President Richard Nixon, Secretary of State Christian Herter, Secretary of the Treasury Robert B. Anderson, Assistant Secretary of Defense John N. Irwin, Undersecretary of State Livingston T. Merchant, Assistant Secretary of State Roy Rubottom, Admiral Arleigh Burke of the Joint Chiefs of Staff, CIA Director Allen Dulles, high-ranking CIA officers Richard Bissell and J. C. King and White House officials Gordon Gray and General Andrew J. Goodpaster, the United States president approved the so-called "Program of Covert Action Against the Castro Regime" proposed by the CIA.
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