Shangdong Province Linyi Municipal People’s Procuratorate
Lin Proc Dept One Crim Indict  No. Z42
Defendant Ding Jiaxi (丁家喜) male, born on March 2, 1973, citizen ID number [REDACTED], ethnic Han, post-graduate education, former lawyer at Beijing Dehong Law Firm, currently jobless, household registration and current address at [REDACTED]. Xu was sentenced to three years and six months in prison on April 18, 2014, by Beijing Municipal Haidian District People’s Court for gathering a crowd to disrupt order in a public place, and released on October 16, 2016. On December 26, 2019, Ding was criminally detained by Yantai Municipal Public Security Bureau, Shandong Province, on suspicion of inciting subversion of state power, and placed under Residential Surveillance at a Designated Location on the following day. On June 19, 2020, this procuratorate approved the formal arrest of Ding, and the arrest was executed on the same day by Linyi Municipal Public Security Bureau.
Upon completing the case investigation, Linyi Municipal Public Security Bureau [PSB] submitted the case to this procuratorate for prosecution of charges of subversion of state power on January 19, 2021. Upon receiving the case, on January 21, 2021, this procuratorate notified the defendant his right to engage defense lawyers, as well as the related statutes with regard to admitting guilt and accepting punishment. According to the law, the prosecutors questioned the defendant, heard the opinions of the defense lawyers, and reviewed all the case materials. On March 6 and May 21 respectively, the procuratorate twice sent the case back to the PSB for supplementary investigation. On April 6 and June 21, 2021 respectively, the PSB resubmitted the case for prosecution upon completing its supplementary investigation. On February 19, May 6, and July 21, 2021 respectively, the time limit for examination and prosecution was extended by this procuratorate three times, each time for 15 days.
The review according to the law has ascertained:
From 2012 to 2013, out of dissatisfaction towards our country’s socialist system and the rule of the Chinese Communist Party, defendant Ding Jiaxi, colluding with Xu Zhiyong (prosecuted separately) and others, founded and developed the illegal organization “New Citizens Movement” and carried out criminal activities. For the purpose of overthrowing our country’s current political system, in 2017, after serving a prison term for gathering a crowd to disrupt order in a public place, Ding Jiaxi, colluding with Xu Zhiyong, founded the illegal organization “Citizens Movement” as its organizers and leaders, and recruited Wang Jiangsong, Zhang Zhongshun, Dai Zhenya, Chang Weiping (each handled separately) as key members. Ding disseminated a large quantity of inciting articles; held color revolution trainings on “non-violence”; operated the “China Citizens Movement” website; held secret meetings of the illegal organization “Citizens Movement” in Yantai and Xiamen, where they organized, planned, and carried out criminal activities to subvert state power and overthrow the socialist system, seriously endangering national security and social stability. The specifics are as follows:
1. From 2012 to 2013, defendant Ding Jiaxi, colluding with Xu Zhiyong and others using communications applications, organized “citizen meal gatherings” and “same-city meal gatherings” in Beijing, Xuzhou, Wuhan and other cities to recruit members for the illegal organization “New Citizens Movement.”
In 2017, defendant Ding Jiaxi, colluding with Xu Zhiyong, continued to network with Wang Jiangsong, Liu Jiacai and other members of the illegal organization “New Citizens Movement” and travelled to Yantai, Xiamen and other cities to connect with Zhang Zhongshun, Dai Zhenya, changing “New Citizens Movement” to “Citizens Movement,” establishing the illegal organization “Citizens Movement,” and organizing, planning and executing a series of criminal activities to subvert state power.
2. In 2017, defendant Ding Jiaxi, colluded with Xu Zhiyong and Hua Ze, a member of an overseas organization, to jointly operate the website ‘China Citizen Movement.’” They added new columns, selected and appointed website reporters and editors, raised funds for the website’s operation, and disseminated a large quantity of Xu Zhiyong’s inciting articles that promote ideas of subverting state power.
3. In 2018, defendant Ding Jiaxi, colluding with Xu Zhiyong, set up a Telegram group for the illegal organization “Citizens Movement” as the illegal organization’s platform for subversive activities. Ding Jiaxi and Wu Ming, a member of an overseas organization, were administrators at different points, and twenty or so key members, including Wang Jiangsong, Zhang Zhongshun, Dai Zhenya, and Hua Ze, used Telegram to contact and communicate with one another; Ding Jiaxi and Xu Zhiyong also organized key members, using Zoom software, to hold illegal online meetings and trainings and plan activities to subvert state power.
From 2018 to 2019, defendant Ding Jiaxi, colluding with Xu Zhiyong, instructed Hua Ze to hold regular color revolution trainings on “non-violence” using Zoom software for members of the illegal organization “Citizen Movement” to teach members methods of “non- violent” color revolution in order to subvert state power.
4. On September 22 and 23, 2018, defendant Ding Jiaxi, colluding with Xu Zhiyong, organized a secret meeting of 13 people, including Zhang Zhongshun, Chang Weiping, Wang Jiangsong, and Wu Ming, in Zhang Zhongshun’s villa in Yinhe Yihai Tianyuewan residential area, Gaoxin District, Yantai, Shandong Province, to organize and plan activities to subvert state power. [During the meeting they] reviewed lessons of the subversive activities of the “New Citizens Movement” and “Citizens Movement” hitherto, analyzed problems facing the current “Citizens Movement,” and asked members to infiltrate grassroots communities to subvert state power by means of “non-violent” color revolution.
5. On December 7 and 8, 2019, defendant Ding Jiaxi, colluding with Xu Zhiyong, organized a secret meeting of 20 people, including Zhang Zhongshun, Dai Zhenya, Wang Jiangsong, in Naisi Home Party villa and Mohe House, Jimei District, Xiamen city, Fujian Province, with Wu Ming and Liu Shuqing attending via online connection. Ding Jiaxi and Xu Zhiyong summarized the activities of the illegal organization “Citizens Movement” in 2019, proposed activity plans for 2020. They discussed topics such as organizational development, opposition to government, fundraising, and social transition. They identified forms, methods and objectives of subverting state power, namely, infiltrating grassroots communities, seeking to hold power on grassroots levels, and developing so-called “citizen community groups” and “a national citizen community” by means of “non-violent” color revolution in order to eventually subvert state power.
These facts have been ascertained based on the following evidence:
1. Material evidence: Notebook computers, USB drives, etc.; 2. Book and article evidence: “People’s Country,” “A Proposal to Citizens: Seek Candidacy in 2021 Elections,” “Non-violence,” and “A Beautiful China,” and other articles, case receipt registration form, criminal verdict, etc.; 3. Witness testimonies: testimonies by witnesses Wang Jiangsong, Zhang Zhongshun, and others; 4. Defendant’s confession and defense argument: defendant Ding Jiaxi’s confession and defense argument; 5. Forensic opinions: legal forensic opinions, etc.; 6. Fact-check, review, and ascertain interrogation transcripts: long-distance fact checking interrogation transcripts, reviewing interrogation transcripts, and ascertaining interrogation transcripts; 7. Video and audio materials: surveillance videos, etc.
This procuratorate believes that defendant Ding Jiaxi organized, planned, and carried out the subversion of state power and the overthrow of the socialist system, and his acts constitute a violation of the provisions of Article 105, Section 1, of the Criminal Law of the People’s Republic of China and he should be held criminally liable for the crime of subversion of state power as the criminal facts are clear, and the evidence is reliable and sufficient. Given that defendant Ding Jiaxi is a recidivist, he should be punished according to the provisions of Section 1, Article 65 of the Criminal Procedure Law of the People’s Republic of China. According to Article 176 of the Criminal Procedure Law of the People’s Republic of China, [the prosecutors] hereby issue this indictment and request punishment in accordance with the law.
Linyi Municipal Intermediate People’s Court, Shandong province
Procurators: Tang Changzhi (谭长志)
Li Tao (李涛)
Huang Zheng (黄政)
Assistant Procurator: Meng Li (孟丽)
August 5, 2021
Shangdong Province Linyi Municipal People’s Procuratorate
- Defendant Ding Jiaxi is currently detained in Linshu County Detention Center, Shandong province;
- 51 volumes of case files, 36 DVD discs;
- One copy of witness (expert witness) list.
(All redactions, brackets, and links are added by the China Change translator.)
Indictment of Citizens Movement Advocate Xu Zhiyong — A Full Translation, October 6, 2021.
Citizens Movement Advocates Xu Zhiyong and Ding Jiaxi Indicted for Subversion on Scant, Slanderous ‘Evidence’, China Change, September 25, 2021.
Prominent Human Rights Activist Ding Jiaxi Tells Lawyer Details of Torture Throughout His Year in Custody, China Change, February 5, 2021.