The prosecution's allegations against Şahin include the formation of a structure called S-1, which would include teams of police officers with experience in special operations. According to the prosecution, Şahin admitted in his testimony that he had done the preliminary work to form the S-1 teams, which, the prosecution says, would be death squads carrying out assassinations, bombings and other attacks. Şahin said in his testimony that he believed the S-1 teams were an official structure. He said he was called to the General Staff headquarters, where it was explained that the military was setting up a new team as part of anti-terrorism efforts and that he was a likely candidate to head this new establishment, about one month prior to his arrest in the Ergenekon investigation. Şahin claimed in his testimony that the person who gave him the task to form the S-1 units was a general named M.G., serving at the General Staff.
In his testimony, Şahin admitted to having prepared a list of 150 to 300 people, whom he believed would be good for the S-1 teams. However, he says this work was completed as part of an official and legal anti-terrorism project.
The indictment also includes many transcripts of Şahin's phone conversations with a number of army officers, special operations police officers and police department officers he considered for S-1, which he said would serve in operations in Syria and Iraq. The prosecution also included in the third indictment a statement from the General Staff that no such department exists and that no one had given Şahin instructions to form one. The indictment says the unit is an illegal and renegade structure formed by individuals working for state security forces.