Among other things, that program enabled the creation of a secret intelligence and action organization within Cuba, for which the CIA allocated the necessary funds. In a recently declassified memorandum on that meeting, General Goodpaster noted: "The President said that he knows of no better plan for dealing with this situation. The great problem is leakage and breach of security. Everyone must be prepared to swear that he [Eisenhower] has not heard of it. [] He said our hand should not be seen in anything that is done."

One of the most impressive human works of social justice in our country has been done in the field of education. This has been highly appreciated by our people and enjoys admiration and respect in the world. The literacy campaign was undertaken in 1961. Almost 100,000 students joined it and went to the most remote places on our island to teach reading and writing to the people there. At the same time, the CIA directed its bandits to sow terror in order to sabotage the campaign. Those bandits carried out criminal actions against adolescents and youths working as teachers and against illiterate adults learning to read and write.

On January 5, 1961, voluntary teacher Conrado Benítez García and peasant Eliodoro Rodríguez Linares were murdered in Las Tinajitas, San Ambrosio, Trinidad municipality in Sancti Spíritus. The participants in this action were bandits Macario Quintana Carrero, Julio Emilio Carretero Escajadillo and Ruperto Ulacia Montelier, members of Osvaldo Ramírez Gracía's band. On October 3, that same year, teacher Delfín Sen Cedré was murdered at Novoa farm, Quemado de Güines, in Las Villas by Margarito Lanza Flórez's band.

On November 26, 1961, young literacy tutor Manuel Ascunce Domenech and peasant Pedro Lantigua Ortega were likewise murdered by bandits Julio Emilio Carretero, Pedro González Sánchez and Braulio Amador Quesada, at Palmarito farm, Río Ay, Trinidad municipality, in Sancti Spíritus.

Also children and adolescents became the victims of those bandits intent on sowing terror among peasants and farm workers in Cuba. Such is the case, among others, of Yolanda and Fermín Rodríguez Díaz, aged 11 and 13 years. They were murdered on January 24, 1963 at La Candelaria farm, Bolondrón, Pedro Betancourt municipality, in Matanzas province, by Juan José Catalá Coste's band, operating in the south of that province. It is also worthwhile mentioning for its cruelty, the event of March 13, 1962 in San Nicolás de Bari, Havana province, where a youngster named Andrés Rojas Acosta was hanged with the very rope he was using to tie up a pig. This crime was committed by bandits led by mercenary Waldemar Hernández. Another event occurred on October 10, 1960 on the road from Madruga to Ceiba Mocha when Gerardo Fundora's band shot at a passing jeep killing 22-month-old Reynaldo Nuñez-Bueno Machado. The baby's mother was also a victim of this action.

The mercenary bands, in a desperate attempt to succeed in their task, retaliated against the civilian population in the areas where they operated. An example of this is the murder of 10-year-old Albinio Sánchez Rodríguez on March 4, 1963. He was killed by Delio Almeida's band as a reaction for a previous attack by the National Revolutionary Militias.

Banditry was definitively removed from Cuba in 1965, when the last band was found out and defeated. That band was led by Juan Alberto Martínez Andrade, then leader of the so-called Camagüey Front.

Between 1959 and 1965, a total of 299 bands, with 3,995 mercenaries operated throughout the national territory in the service of the U.S. government.

The number of casualties in that struggle, including all the regular troops and militiamen taking part in the operations against the bandits, as well as people murdered by the bandits whose death it has been possible to document, were as high as 549. Also, a considerable amount of people were injured whose number it has not been possible to accurately determine 34 years later, when this lawsuit was prepared. However, there are still 200 survivors incapacitated as a result of those criminal plans. Not all the victims were among the revolutionary combatants fighting the bandits. Many civilians who had nothing to do with the military activities also died, victims of the crimes committed by the bands imposed from abroad.

The dirty war, that costly and bloody form of aggression created by the U.S. government, was definitely and completely defeated by the Cuban people, totally uprooted, and the CIA could never again organize a single band.

We have attached to this lawsuit the corresponding certificates of the 549 people who have so far been registered as dead due to that criminal action against our people, as well as a detailed list of all those currently incapacitated due to injuries sustained in the period described; these are the documents marked with the numbers 9 and 10, respectively.

FOURTH: That among the most significant events in the history of the Cuban revolution -- for its military, patriotic and political impact -- is the Bay of Pigs mercenary invasion organized by the United States Central Intelligence Agency on instructions given by President Eisenhower on March 17, 1960.

President Eisenhower himself wrote in his memoirs: "On March 17, 1960 [...] I ordered the Central Intelligence Agency to begin to organize the training of Cuban exiles, mainly in Guatemala."

As part of the preparation for the invasion, the airports at Ciudad Libertad, San Antonio de los Baños and Santiago de Cuba were bombed at dawn on April 15, 1961. The aggression was repelled and although some planes from the Cuban defense forces were destroyed that could not render useless our small recently established Revolutionary Air Force. This was thanks to the courageous performance of the anti-aircraft artillery made up almost entirely by young people who would play an extraordinary role only two days later. Twelve of those youths lost their lives, including Eduardo García Delgado, who entered the history of that epic struggle when he wrote Fidel's name, with his own blood on a board, as he lay dying.

Two days later, on April 17, 1961, at 2:30 in the morning, a group began to land on the southern coast of the former province of Las Villas, at Ciénaga de Zapata. The group, organized, trained, equipped and financed by the U.S. government, had come from Puerto Cabezas in the Republic of Nicaragua. Its own members called it Assault Brigade 2506 and it was made up of about 1,500 men.

According to documents seized from those who were taken prisoners, the mercenary invasion plan contemplated landing at three places in Ciénaga de Zapata: Playa Larga, which they called Playa Roja in their plans where those on board the ship named Aguja were to disembark; Playa Girón, called Playa Azul, where the vessels known as Ballena and Tiburón were to disembark their passengers; and Caleta Verde, called Playa Verde, where those on board ships Marsopa, Barracuda and Atún were to disembark.

At the same time, two battalions of parachutists would occupy positions in the vicinity of the Australia sugar mill, also at San Blas and Soplillar, their mission being to cut off access to the landing and operation zone, then to isolate it, to fortify it and to establish a provisional government there. This would have created the conditions for immediately airlifting to Cuba a government impatiently waiting in Miami with its luggage ready that would request a military intervention by the United States of America at the head of the OAS "troops".

During the invasion, the members of this "government" were forcibly kept incommunicado in the United States territory while the CIA issued one statement after another in their name.

The mercenary brigade landed at Playa Girón and Playa Larga despite the resistance put up by small units of the National Revolutionary Militias. They landed their tanks and armored vehicles and dropped the parachutists' battalion north of Girón in order to block the paved road leading to the Australia sugar mill. B26 planes disguised with Cuban insignia and escorted by U.S. fighter planes began bombing the area, strafing the civilian population, killing people -- including women and children whose full names can be found at the end of this document -- and causing considerable damage.

U.S. Navy units -- including an aircraft-carrier (the Essex, with 40 fighter planes and a marine battalion on board), a helicopter-carrier, five destroyers and one LSD [Landing Ship Dock] among other naval units -- escorted the ships that transported the mercenary forces and remained a few miles off the operation zone throughout the whole battle.

The mercenary brigade had plenty of equipment and weaponry. It had five transport gunboats, two modified LCI artillery war units, three LCV landing craft for transporting heavy equipment and four LCVP troop-carrier landing craft. For air operations, the mercenaries were backed by sixteen B-26 fighter planes, six C-46, eight C-54 transport planes and two Catalina seaplanes. They had five M-41 Sherman tanks, with 76-millimeter guns; 10 armored cars equipped with .50-caliber machine-guns; 75 bazookas; 60 mortars of different caliber; 21 recoiless 75-millimeter and 57-millimeter cannons; 44 .50-caliber machine-guns and 39 light and heavy .30-caliber machine-guns; eight flamethrowers; 22,000 hand grenades; 108 Browning automatic rifles; 470 M-3 submachine-guns; 635 Garand rifles and M-1 carbines; 465 pistols and other light weapons.

The members of the mercenary brigade received military training from U.S. instructors at bases in the United States, Guatemala and Puerto Rico. They received monthly allowances to support their families provided by the U. S. Government which spent a total of 45 million dollars to finance the operation.

In less than 72 hours, the Cuban revolutionary forces overwhelmingly crushed the powerful invading mercenary brigade. In this respect, the White House issued an official statement on April 24, 1961, where it indicated that "President Kennedy has stated from the beginning that as President he bears sole responsibility" for the invasion. The statement added that "the President is strongly opposed to anyone, within or without the administration, attempting to shift the responsibility".

The United States government's association with the events described in this document was also corroborated in the well-known report by the CIA Inspector General, elaborated six months after the failed invasion, a document that remained classified `top secret' for 37 years until 1998 when it was declassified following intense efforts by the National Security Archive, a non-profit organization based in Washington D.C.

Although the Bay of Pigs invasion was a major political and military defeat for the United States government, this war conflict left a high number of victims and countless grieving or badly afflicted Cuban families, since 176 people died and over 300 were wounded by enemy weapons. This included people living in the area who were machine-gunned by the mercenary air force; 50 of them were permanently incapacitated while fulfilling their duty. We vouch for these extreme situations with certificates that have been attached to this lawsuit as documents marked numbers 12 and 13, respectively.

Pilots, advisers, frogmen and other Americans were directly involved in the action. In the violent engagements of April 19, the active participation of U.S. pilots was confirmed when the anti-aircraft forces brought down a B-26 plane manned by U.S. citizens Thomas Willard Ray and Frank Leo Baker, National Guard pilots in the state of Alabama. On that same day, another B-26 was brought down over the sea. It was manned by Ryley W. Shamburger and Wade Carroll Gray, the former an officer with the National Guard.