The plaintiff’s final submission: void adoption, violent assimilation and the continuing breach — 12 January 2026

The submission is dated 12 January 2026 on pages 26 and 75 and answers CSR’s 22 December response. The event uses that written date; no separate filing date is inferred.

## Source page 26 ### XIII. ANNEXES (FOR CLARITY) Note: The following annexes have already been supplied to the Court with the statement of claim and/or previous submissions and are listed here for clarity; they are not physically attached again unless the Court orders otherwise. 1. Birth-register extract KJ-8 / entry 2512/1974, concerning the mother’s nationality and the state of the entries — already supplied as an annex to the plaintiff’s submission of 27 October 2025; not attached again here, but expressly referred to. 2. Municipal Court in Novi Sad file O.196/79, insofar as already supplied: - the decision of 23 November 1979; - the minutes of 19 March 1979; - the letter of 20 July 1979. Those portions were already attached to the plaintiff’s submission of 30 June 2025; they are not attached again here, but expressly referred to. 3. File P-1642/76 — the divorce case containing Pal Lakatoš’s acknowledgment of paternity — already supplied as an annex to the plaintiff’s submission of 27 October 2025; not attached again here, but expressly referred to. 4. Appeal proceedings Gž 11/80 — portions of the appeal proceedings up to the point when Milivoj Miletić ceases to be among the heirs, rather than the entire appeal file, covering the course legally relevant to this case — already supplied to the Court as Annex 1; not attached again here, but expressly referred to. 5. Defendant’s submission no. 560-111-1/2024 of 22 December 2025 — already in the court file as the defendant’s submission; this submission only analyzes and quotes its contents without attaching it again. **Annex 2:** Social worker Vera Radovanović’s handwriting and a reconstruction — a readable transcription — of the exact text of the relevant note / monitoring sheet invoked in this submission. 6. Psychologist’s findings and opinion concerning married couple Periša and Gorgina Petrović dated 10 January 1984 — already supplied to the Court as a photocopy of the original and an OCR transcription to facilitate reading; not attached again here, but expressly referred to. **Annex 3:** Psychologist’s findings and opinion concerning married couple Periša and Gorgina Petrović dated 10 January 1984 — a photocopy of the original and an OCR transcription to facilitate reading. Kragujevac, 12 January 2026 Plaintiff, Official first name and surname — Milan Petrović ____________________________

The opening expressly identifies the CSR submission dated 22 December 2025, no. 560-111-1/2024. The plaintiff’s detailed reply should be read against those exact two pages and their linked archive.

## Source page 1 BASIC COURT IN NOVI SAD Case no.: P2.1435/24 PLAINTIFF: Milan Petrović (born as Milivoj Miletić), Kraljevačkog bataljona 110, Kragujevac DEFENDANT: Centre for Social Work of the City of Novi Sad, Zmaj Ognjena Vuka 13, Novi Sad # PLAINTIFF’S SUBMISSION (In response to defendant’s submission no. 560-111-1/2024 of 22 December 2025; supplementation of proposed evidence and legal reasoning) ### I. INTRODUCTION AND PROCEDURAL FRAMEWORK By submission no. 560-111-1/2024 of 22 December 2025, the defendant supplies certain archive documents (the dossier cover, foster-carer questionnaire, contracts and decisions on family placement, case-monitoring sheet and beneficiary’s personal record), and draws the following conclusions from those documents: - that, as a child, I was “without parental care”; - that allegedly “none of the close relatives” wanted to assume care of me; - that adoption was “the best form of protection under family law”; - that “there were no grounds for annulling the adoption at the time it was established” and “everything complied with the regulations then in force”. At the same time, the defendant has still not complied with all this Court’s orders, particularly those requiring submission of: - the complete documentation concerning the acquisition of authority over the case (“how the child came under its authority”); and - the complete file on the full adoption in 1979, in accordance with: 1. the minutes and orders from the hearing of 26 March 2025; and 2. the Court’s decision at the hearing of 26 November 2025 (the fifteen- and thirty-day periods). Through this submission, I: 1. respond to the assertions in the defendant’s submission of 22 December 2025; 2. point out the selective and incorrect interpretation of the documentation supplied; 3. specify the nature of the violation — deprivation of identity, forced assimilation (Serbianization), and the fact that this is a continuing act; 4. propose that, because of the persistent failure to supply crucial acts, the Court draw adverse evidentiary inferences regarding the disputed points. Note: This submission is presented as a procedural act in these proceedings, but was also written to reconstruct the facts and institutional conduct comprehensively through evidence, bearing in mind that the consequences of the contested act constitute a continuing violation and that the contents of the judgment and case file will matter beyond a single courtroom.

The final record states that Milan Petrović maintains all submissions and all oral and written assertions. The linked submission dated 12 January 2026 contains his final written case on nullity, violent assimilation and the historical evidence chain. The general preservation statement connects that written argument to the closing hearing.

The plaintiff states that he maintains the action and the claim as formulated, all assertions and all submissions. He has no further evidence proposals. He proposes that the hearing be closed. He withdraws all other evidence proposals that may have been made. He expressly states that he maintains all assertions made thus far, both orally and in writing.

The plaintiff compares CSR’s November and December responses. The November submission describes separate adoption-file storage; its archive-search attribution is separately distinguished from the 26 November hearing record.

## Source page 16 Beyond its substantive contents, the very form of the defendant’s submission reveals a deeper problem: its heading states: > “Plaintiff: Centre for Social Work of the City of Novi Sad > Defendant: Milan Petrović…” Thus, even after proceedings began in which I am the plaintiff and the Centre for Social Work in Novi Sad is the defendant, the Centre still records itself as the “plaintiff” and me as the “defendant”. Formally this may look like a “typing error”, but substantively it reveals what the entire dossier shows: the Centre behaves as though it owns my identity and case, while I am merely an object at its disposal, even when I am procedurally the plaintiff before the Court. ### VIII. FAILURE TO SUPPLY CRUCIAL EVIDENCE AND ADVERSE EVIDENTIARY INFERENCES Despite multiple orders by this Court, particularly at the hearings of 26 March and 26 November 2025, the defendant has still not supplied: - the complete file on the full adoption in 1979, including all internal acts, opinions, correspondence, delivery records and communication with the probate court; - the acts concerning how the child came under the guardianship body’s authority before 21 June 1979 — thus before adoption — particularly in connection with probate proceedings O.196/79, in which the Court had already taken action concerning my inheritance status on 19 March and 20 July 1979. Instead of supplying the requested acts, the defendant: - on one hand, admits in its submission of 27 November 2025 that finding the archive is a “complex task” and that it does not know “where everything is located”; - on the other, declares in its submission of 22 December 2025 that the documentation supplied so far “indisputably” demonstrates that everything was lawful. As I have already explained in detail in my submission of 27 October 2025, whose assertions the Court accepted as the basis for further evidentiary orders, I propose: - that the Court establish that the defendant has not fully complied with the orders; - that, regarding the disputed issues — the guardianship body’s authority in 1979, fulfilment of the conditions under Article 30 of the Adoption Act, its relationship to probate proceedings O.196/79, communication with the Court, mandatory parental consent and so forth — it draw adverse evidentiary inferences, particularly considering that I have already supplied: - a birth-register extract showing the mother’s nationality as Croatian; - a marriage-register extract for the adoptive parents showing their nationality as Serbian; - divorce case file P-1642/76, containing Pal Lakatoš’s acknowledgment of paternity;

The appeal names the 12 January 2026 submission and summarises its connection of probate, the child’s status, Vera’s monitoring sheet, the second adoption and the adverse 1984 psychological assessment. The full 75-page source allows the alleged lack of an answer to be checked.

The judgment gives no genuine reasons addressing any of these questions. Instead, the court uses general formulas stating that the guardianship body “established” the requirements “in the preliminary proceedings”, and that the court established lawfulness “beyond doubt”. These are not reasons for a judgment, but a bare declaration. It is especially significant that the first-instance court incorporated into the reasoning of the challenged judgment the fact that the plaintiff was adopted again in 1984 by another couple, without explaining that fact in legal terms. The court thereby incorporated into its own reasoning a fact that destabilises its own conclusion that the full adoption in 1979 was lawfully and permanently established, and then left that fact without any legal analysis. Such reasoning is internally contradictory and does not permit a proper examination of whether the challenged judgment is correct. #### 2. The court did not answer the plaintiff’s decisive arguments in his submissions During the proceedings, in my submissions of 30 June 2025, 27 October 2025 and 12 January 2026, and in my testimony at the hearing of 15 October 2025, I raised the decisive points of the dispute precisely, repeatedly and with documentary support. In the submission of 30 June 2025, I specifically raised the question of how authority was acquired, the relationship between the probate and adoption proceedings, and the fact that the full adoption was carried out before the body had a clear legal basis for such action. In the submission of 27 October 2025, I identified in detail which files and acts the court had to obtain, why they were relevant and which legal issues they clarified, particularly concerning divorce file P-1642/76, probate file O.196/79, authority, the mother, paternity, the second adoption in 1984 and identity. In the submission of 12 January 2026, I connected the probate proceedings, the child’s status, the question of the guardianship body, the Monitoring Sheet, Vera Radovanović’s role, the second adoption in 1984, the adverse psychologist’s assessment of the Petrović couple and the continuity of unlawful conduct. The judgment does not show that it substantively answered any of those submissions as a central body of argument. It does not engage with their reasoning, discuss their key points or rebut their central assertions; instead, it bypasses them and formally covers them over. This violated my right to have the court genuinely decide the arguments I presented, rather than merely take formal note of them. Furthermore, the judgment does not show why my decisive arguments and attachments were rejected; it shows only that the defendant’s assertions and documentation were accepted. #### 3. The judgment does not demonstrate a genuine assessment of the attachments and evidence the plaintiff had already placed in the file Besides the arguments in the submissions themselves, the decisive facts and corresponding evidence had already been physically placed in the file through attachments to my earlier submissions and to the claim itself. This applies particularly to parts of probate file O.196/79, parts of appellate proceedings Gž 11/80, divorce file P-1642/76, civil-register extracts and other attachments that I expressly relied on and specifically identified as decisive for clarifying the guardianship body’s authority, paternity, the mother and consent, and the relationship between the probate and adoption proceedings.

The plaintiff invokes the 26 November orders. That record contains the separate 15-day response and 30-day archive deadlines and the actual statement about archive locations.

## Source page 1 BASIC COURT IN NOVI SAD Case no.: P2.1435/24 PLAINTIFF: Milan Petrović (born as Milivoj Miletić), Kraljevačkog bataljona 110, Kragujevac DEFENDANT: Centre for Social Work of the City of Novi Sad, Zmaj Ognjena Vuka 13, Novi Sad # PLAINTIFF’S SUBMISSION (In response to defendant’s submission no. 560-111-1/2024 of 22 December 2025; supplementation of proposed evidence and legal reasoning) ### I. INTRODUCTION AND PROCEDURAL FRAMEWORK By submission no. 560-111-1/2024 of 22 December 2025, the defendant supplies certain archive documents (the dossier cover, foster-carer questionnaire, contracts and decisions on family placement, case-monitoring sheet and beneficiary’s personal record), and draws the following conclusions from those documents: - that, as a child, I was “without parental care”; - that allegedly “none of the close relatives” wanted to assume care of me; - that adoption was “the best form of protection under family law”; - that “there were no grounds for annulling the adoption at the time it was established” and “everything complied with the regulations then in force”. At the same time, the defendant has still not complied with all this Court’s orders, particularly those requiring submission of: - the complete documentation concerning the acquisition of authority over the case (“how the child came under its authority”); and - the complete file on the full adoption in 1979, in accordance with: 1. the minutes and orders from the hearing of 26 March 2025; and 2. the Court’s decision at the hearing of 26 November 2025 (the fifteen- and thirty-day periods). Through this submission, I: 1. respond to the assertions in the defendant’s submission of 22 December 2025; 2. point out the selective and incorrect interpretation of the documentation supplied; 3. specify the nature of the violation — deprivation of identity, forced assimilation (Serbianization), and the fact that this is a continuing act; 4. propose that, because of the persistent failure to supply crucial acts, the Court draw adverse evidentiary inferences regarding the disputed points. Note: This submission is presented as a procedural act in these proceedings, but was also written to reconstruct the facts and institutional conduct comprehensively through evidence, bearing in mind that the consequences of the contested act constitute a continuing violation and that the contents of the judgment and case file will matter beyond a single courtroom.

The 26 March record separates the plaintiff’s request to establish how he came within CSR’s authority from the operative order requiring the adoption documentation held by the defendant. Reading both passages prevents the author’s broader request from being presented as the exact wording of the order.

## Source page 1 BASIC COURT IN NOVI SAD Case no.: P2.1435/24 PLAINTIFF: Milan Petrović (born as Milivoj Miletić), Kraljevačkog bataljona 110, Kragujevac DEFENDANT: Centre for Social Work of the City of Novi Sad, Zmaj Ognjena Vuka 13, Novi Sad # PLAINTIFF’S SUBMISSION (In response to defendant’s submission no. 560-111-1/2024 of 22 December 2025; supplementation of proposed evidence and legal reasoning) ### I. INTRODUCTION AND PROCEDURAL FRAMEWORK By submission no. 560-111-1/2024 of 22 December 2025, the defendant supplies certain archive documents (the dossier cover, foster-carer questionnaire, contracts and decisions on family placement, case-monitoring sheet and beneficiary’s personal record), and draws the following conclusions from those documents: - that, as a child, I was “without parental care”; - that allegedly “none of the close relatives” wanted to assume care of me; - that adoption was “the best form of protection under family law”; - that “there were no grounds for annulling the adoption at the time it was established” and “everything complied with the regulations then in force”. At the same time, the defendant has still not complied with all this Court’s orders, particularly those requiring submission of: - the complete documentation concerning the acquisition of authority over the case (“how the child came under its authority”); and - the complete file on the full adoption in 1979, in accordance with: 1. the minutes and orders from the hearing of 26 March 2025; and 2. the Court’s decision at the hearing of 26 November 2025 (the fifteen- and thirty-day periods). Through this submission, I: 1. respond to the assertions in the defendant’s submission of 22 December 2025; 2. point out the selective and incorrect interpretation of the documentation supplied; 3. specify the nature of the violation — deprivation of identity, forced assimilation (Serbianization), and the fact that this is a continuing act; 4. propose that, because of the persistent failure to supply crucial acts, the Court draw adverse evidentiary inferences regarding the disputed points. Note: This submission is presented as a procedural act in these proceedings, but was also written to reconstruct the facts and institutional conduct comprehensively through evidence, bearing in mind that the consequences of the contested act constitute a continuing violation and that the contents of the judgment and case file will matter beyond a single courtroom.

The author expressly maintains the reservations in his 27 October submission and states that the relief sought is unchanged. The earlier submission gives the full records requests and reserved claims.

## Source page 22 - whether today’s Centre has the right to behave as the owner of a child’s identity and origin; and - whether, through its silence, the Court agrees to be an accomplice in this. ### XI. RESERVATION OF THE RIGHT TO DAMAGES AND FURTHER PROCEEDINGS I fully maintain Section IX of my submission of 27 October 2025, entitled “Reservation of the right to costs and damages”, without changing the relief sought: - I reserve the right to seek compensation for material and non-material damage in separate proceedings; - I reserve the right, once the obstacle created by full adoption is removed, to commence proceedings to establish paternity and obtain corresponding corrections to civil registers; - I consider that the defendant should bear the costs of these proceedings, while any question of recourse against third parties, such as heirs, concerns exclusively the defendant’s relationship with those persons and is not a burden for the plaintiff. I particularly emphasize that the falsified identity, founded upon unlawful full adoption and forced administrative assimilation, had direct consequences for my life and bodily integrity. As a person constructed on paper as a “domestic” citizen with an assigned majority identity, during the wars of the 1990s, including the 1999 war, I was legally and effectively exposed to obligations of military service, mobilization and wartime measures precisely in the state that had previously falsified my identity. Had I grown up with truthful knowledge of my Hungarian–Croatian origin, actual family connections and opportunities to establish ties with other legal orders, I would never have voluntarily agreed to become that state’s soldier or to have my life used as a resource in its wars. I therefore consider that all obligations the state imposed on me precisely through that unlawfully constructed identity — including military obligations and being taken into a war zone — were substantively founded upon a void act of full adoption and forced assimilation. I leave the question of the legal consequences of that nullity for those obligations, and the scope and method of compensation for endangering my life, to separate proceedings that I reserve the right to initiate after this dispute ends. **Proposal to the Court:** - To take note of this submission and add it to the case file. - In accordance with previous orders, to establish which evidence the defendant has failed to supply and draw adverse evidentiary inferences in that respect. - In deciding the case, to apply the law in force at the time of the acts — the 1974 Constitution of the SFRY, the 1976 Adoption Act of the Socialist Autonomous Province of Vojvodina, the ICCPR and ICERD — and assess the defendant’s present conduct, including failure to supply files, denial of the violation and maintenance of an unlawful state, in light of current law: the 2006 Constitution of the Republic of Serbia, minority legislation, the Anti-Discrimination Act and relevant international conventions. - To deliver a clearly and fully reasoned judgment confronting the facts and documents as a whole, rather than the selective quotation practised by the defendant.

The 19 March 1979 record places the child with Pál’s parents and records Helena Uzelac’s statement about his acknowledgment. It is the source for the plaintiff’s argument about existing family care.

## Source page 11 - the chauvinistic attitude towards Croatians and erasure of Hungarian identity did not begin in the 1990s; - it already existed in a “quiet”, social and administrative form, precisely within the body supposed to protect the child. #### 7. Conclusion for these proceedings Vera Radovanović’s conduct constitutes: - a misogynistic attack on a Croatian mother, through sexual and moral disqualification; - chauvinistic erasure of the child’s Croatian and Hungarian identity; - dehumanization of the service user — the mother — and the child as “material” to be transferred into a majority family. By defending the proposition that “everything complied with the regulations”, today’s Centre for Social Work: - accepts and legitimizes that discourse as “worthy of the profession”, thereby assuming joint responsibility. This Court therefore cannot ignore the substance of that vocabulary, because today, in 2024/2025/2026, it is being signed again before this Court, this time with the names of Maja Petrović, Jelena Zorić and Katarina Stolić. #### 8. The crowning evidence of falsehoods — the Court minutes of 19 March 1979 As the crowning evidence that social worker Vera Radovanović’s report of 8 April 1979, on which the removal of the child rests, constitutes a grave distortion of the facts, effectively equivalent to a forgery, I attach the Municipal Court in Novi Sad’s minutes in probate case O.196/79 dated 19 March 1979. Only twenty days before Vera Radovanović opens the dossier and claims that the child is “neglected”, “without parental care” and that the mother “does not care” for him, the following is established before the Court: 1. The family’s representative, lawyer Helena Uzelac, explicitly states: > “…minor Milivoj is currently with his grandmother and grandfather, that is, the deceased’s parents.” This is documentary evidence that the child was neither on the street nor wandering with his mother, but cared for in the home of his paternal grandfather and grandmother. 2. The same lawyer confirms the father’s identity: > “…it has not been judicially established that the deceased is the father, but he acknowledged him…” Thus, the family and the Court know that the father acknowledged the child. 3. The Court instructs the Centre: > “Therefore… appointment of a guardian to represent the interests is to be obtained from the Centre for Social Work.”

Annex 1 reproduces the probate appeal sequence already partly archived. This submission additionally contains the first page of the 18 April 1980 hearing and the 4 February 1981 costs/payment order; the older archive remains available in its own form.

## Source page 27 # ANNEX 1 ### Portions of appeal proceedings Gž 11/80 (O.196/79) This annex contains portions of appeal proceedings Gž 11/80 before the Higher Court in Novi Sad that are relevant to this case, up to the point when Milivoj Miletić ceases to be among the heirs in probate proceedings O.196/79. The annex is structured as follows: - first come photocopies of the relevant portions of file Gž 11/80, as they appear in the original; - then, on the following pages, comes the typed text — a transcription — of those portions, obtained following OCR analysis, with brief technical notes only where handwriting or printing is difficult to read. The transcription serves solely to facilitate reading and does not change the contents of the original documents.

The ruling closes with a general statement that the remaining appeal grounds were assessed. The final submission of 12 January 2026 contains the earlier detailed arguments and historical exhibits concerning parental status, the protective file, consent and conflicting roles; these can be compared with the reasons actually given.

For the stated reasons, and because the other grounds of appeal, which this court also assessed, did not affect the correctness and lawfulness of the challenged judgment, applying Article 390 of the Civil Procedure Act, the court decided as set out in the operative part.

Annex 2 contains four of Vera Radovanović’s handwritten monitoring sheets and the author’s accompanying transcription. The existing full dossier supplies their wider context, including the personal-record reverse and maternal details.

## Source page 63 # ANNEX 2 ### Vera Radovanović’s handwriting — monitoring sheet no. 3871/79 and reconstruction of the text This annex contains documentation concerning social worker Vera Radovanović’s handwriting in the case of Miletić Milivoj, no. 3871/79: - photocopies of the original handwriting come first — the monitoring sheet and other handwritten notes concerning this case; - then, on the following pages, comes the typed text: a reconstruction of what the handwriting says, prepared following OCR analysis using Google Gemini, with notes where the original is difficult to read or partly unclear. The text is reconstructed so that: - it does not change the contents of the handwriting; - it merely clarifies exactly what the handwritten passages say; - technical notes, such as “[illegible]” or “[probably reads…]”, are clearly marked as such. This annex allows the Court to compare the original handwriting directly with the clear transcription and follow, without difficulty, the vocabulary, characterizations and way the social worker handled the case.

The author identifies Vera Radovanović’s 12 June 1979 recommendation of the Vasić couple. The linked assessment dossier permits checking that recommendation alongside the other professional reports.

## Source page 6 - records my crying at “Milivoj”; - instructs the foster carer to call me by the imposed name; - records that I soon “declare that my name is now Mišo”; - takes me into full-adoption proceedings with the Vasić family, with the ultimate objective of making me Vasić Milan. Thus, in its own official notes, the Centre recorded the entire process of psychologically preparing a child for the erasure of his original name and identity. This is not a neutral social intervention; it is the engineering of a child’s identity. ### The role of social worker Vera Radovanović and the conflict of interest (1979–1984) A further level of the Centre’s self-incrimination is visible in the fact that the same person — social worker and head of guardianship Vera Radovanović — simultaneously, in this case: - constructs the narrative about the mother and disputes my father’s paternity; - recommends specific adoptive parents for me in particular; - is appointed as an “ad hoc guardian”; - in that role, gives consent to full adoption; - and then, several years later, also participates in manufacturing the first adoptive parent’s “consent” to a new adoption of the same child. The chronology is indisputable: - **8 April 1979:** Vera Radovanović maintains the monitoring sheet for no. 3871/79: she describes my mother as “prone to prostitution, alcohol and wandering”, relativizes Pal Lakatoš’s paternity (“claims to be the father”), but simultaneously records that I am well cared for, tidy and without behavioural problems at my aunt Julka Vizmeg’s home — she is my father’s sister. - **12 June 1979:** As social worker and head of guardianship, she draws up the report on the suitability of Vasić Gospava and Milorad, in which, on the basis of housing, material and “moral” conditions, she explicitly concludes that “VASIĆ GOSPAVA and MILORAD be approved to adopt minor MILIVOJ MILETIĆ”. Thus, it was already being determined that precisely this married couple should adopt precisely me. - **20 June 1979:** By decision no. Up.03-506/79, Vera Radovanović is formally appointed ad hoc guardian “for the purpose of giving consent to the adoption of minor Miletić Milivoj”. The person who had already recommended the adoption now receives the role of the child’s “neutral” protector. - **21 June 1979:** In the minutes of full adoption, drawn up before the guardianship body, Vera Radovanović appears precisely in that role — as ad hoc guardian — and gives consent to full adoption, after which it is stated that my future name will be Vasić Milan. - **12 September 1984:** As social worker at the Centre for Social Work in Novi Sad, she draws up the minutes of the first adoptive parent Vasić Milorad “giving consent” to the adoption of minor Vasić Milan. In that act, the first adoptive parent is effectively treated as a father who “gives his son for adoption”, although I had already been fully adopted once, in 1979, so that the same official actively participates in the unlawful second adoption of the same child.

The 21 June 1979 record identifies the consent role and the resulting name Vasić Milan. It directly connects the author’s argument about Vera’s combined functions with the original adoption act.

## Source page 6 - records my crying at “Milivoj”; - instructs the foster carer to call me by the imposed name; - records that I soon “declare that my name is now Mišo”; - takes me into full-adoption proceedings with the Vasić family, with the ultimate objective of making me Vasić Milan. Thus, in its own official notes, the Centre recorded the entire process of psychologically preparing a child for the erasure of his original name and identity. This is not a neutral social intervention; it is the engineering of a child’s identity. ### The role of social worker Vera Radovanović and the conflict of interest (1979–1984) A further level of the Centre’s self-incrimination is visible in the fact that the same person — social worker and head of guardianship Vera Radovanović — simultaneously, in this case: - constructs the narrative about the mother and disputes my father’s paternity; - recommends specific adoptive parents for me in particular; - is appointed as an “ad hoc guardian”; - in that role, gives consent to full adoption; - and then, several years later, also participates in manufacturing the first adoptive parent’s “consent” to a new adoption of the same child. The chronology is indisputable: - **8 April 1979:** Vera Radovanović maintains the monitoring sheet for no. 3871/79: she describes my mother as “prone to prostitution, alcohol and wandering”, relativizes Pal Lakatoš’s paternity (“claims to be the father”), but simultaneously records that I am well cared for, tidy and without behavioural problems at my aunt Julka Vizmeg’s home — she is my father’s sister. - **12 June 1979:** As social worker and head of guardianship, she draws up the report on the suitability of Vasić Gospava and Milorad, in which, on the basis of housing, material and “moral” conditions, she explicitly concludes that “VASIĆ GOSPAVA and MILORAD be approved to adopt minor MILIVOJ MILETIĆ”. Thus, it was already being determined that precisely this married couple should adopt precisely me. - **20 June 1979:** By decision no. Up.03-506/79, Vera Radovanović is formally appointed ad hoc guardian “for the purpose of giving consent to the adoption of minor Miletić Milivoj”. The person who had already recommended the adoption now receives the role of the child’s “neutral” protector. - **21 June 1979:** In the minutes of full adoption, drawn up before the guardianship body, Vera Radovanović appears precisely in that role — as ad hoc guardian — and gives consent to full adoption, after which it is stated that my future name will be Vasić Milan. - **12 September 1984:** As social worker at the Centre for Social Work in Novi Sad, she draws up the minutes of the first adoptive parent Vasić Milorad “giving consent” to the adoption of minor Vasić Milan. In that act, the first adoptive parent is effectively treated as a father who “gives his son for adoption”, although I had already been fully adopted once, in 1979, so that the same official actively participates in the unlawful second adoption of the same child.

Annex 3 reproduces the psychologist’s 10 January 1984 assessment and its transcription. The full existing assessment packet gives the original context of the recommendation to refuse adoption and propose foster care.

## Source page 72 # ANNEX 3 The Centre for Social Work in Kragujevac psychologist’s findings and opinion dated 10 January 1984 concerning married couple Periša and Gorgina Petrović — a photocopy of the original act and an OCR transcription to facilitate reading.

This is an editorial comparison with the author’s final submission, which challenges the parentage, consent and historical-record contradictions. The judgment instead explains its documentary credibility criterion and acceptance of the plaintiff’s consistent testimony. Linking the two exposes the particular arguments to which that reasoning can be compared; it does not treat the author’s conclusions as findings of the judgment.

The court accepted all the written documentation submitted, because it had been drawn up and issued by authorized and qualified persons, and therefore had no reason to doubt its credibility. The court established that the plaintiff was born on 28 June 1974 in Novi Sad as Milivoj Miletić and that his biological mother was Cvita Miletić, born on 23 March 1931 in Bila Vlaka, Benkovac, SR Croatia, on the basis of the extract from the City of Novi Sad register of births maintained for the Novi Sad registration district, under serial number 2512 for 1974, and the social worker’s report in the search procedure for Miletić Cvita of 9 March 2005. The court established that, after his birth, the plaintiff lived briefly with his mother, who then abandoned him, and that he subsequently lived with Pavle Lakatoš, on the basis of the contact and casework tracking sheet for Miletić Milivoj, no. 3871/79. The court established that **it had never been judicially determined that Pavle Lkatoš was the plaintiff’s father** on the basis of the plaintiff’s testimony, which was also corroborated by the written documentation submitted. The court established the contents of the Self-Managing Community of Interest for Social Welfare Novi Sad decision no. Up-03-335/79 of 16 April 1979, the full-adoption record no. Up.03-507/79 of 21 June 1979 and the Self-Managing Community of Interest for Social Welfare Novi Sad decision no. Up.03-507/79 of 21 June 1979 by reading those documents. The court established that Vasić Milorad and Tomić Gospava had married on 21 January 1962 in Petrovaradin, and that Gospava had taken the surname Vasić upon marrying, on the basis of the extract from the Municipality of Novi Sad register of marriages maintained under serial number 1 for 1962. The court established the contents of Municipal Court in Novi Sad certificate case no. Kr.II1353/79 of 5 June 1979, Municipal Court in Novi Sad certificate case no. Kr.II1354/79 of 5 June 1979, the “Novograp” certificate no. 02-17/243 of 6 June 1979, the medical certificate, protocol no. 805 of 4 June 1979 and the medical certificate, protocol no. 9/7 of 11 June 1979, by reading those documents. The court established the contents of psychologist Cvetko Ratković’s opinion of 19 June 1979, social worker Vera Radovanović’s report of 12 June 1979 and pedagogue Milosava Gudelj’s report of 18 June 1979 by reading those documents. The court established that, by the Centre for Social Work of the City of Novi Sad record no. Up.02-987/84 of 26 September 1984, the plaintiff was adopted by Petrović Periša and Petrović Georgina, née Miljković, and that it was determined that he would henceforth bear the adopters’ surname, Petrović, by reading the extract from the City of Novi Sad register of births maintained for the Novi Sad registration district, under serial number 2463 for 1979. The court evaluated the plaintiff’s testimony as a party to the civil proceedings and accepted the parts that were relevant to deciding this legal matter and the parts that were consistent with the evidence to which the court had given credence.

The January submission is an editorial comparison for continuity of the author’s identity and institutional-responsibility argument. This relation does not imply that the revision expressly names that submission on this page.

The plaintiff did not discover the truth about his origins because the state enabled effective exposure of the severing of identity it had itself produced. He discovered it through his own personal investigation over several years, connecting scattered family, archival and judicial traces. The present-day violation of the right to identity in this case therefore lies not only in historical concealment of origins. It also lies in the fact that, after the plaintiff’s original identity line was uncovered and documented, the domestic courts maintained the legal consequences of a full adoption whose lawfulness falls apart before the text of the law then in force and the files examined in the proceedings. The case is no longer confined to the right to discover one’s origins. The plaintiff discovered them without the state’s assistance. It now concerns the right not to have the state, after the truth has emerged, continue judicially maintaining an administrative order founded on erasure of his original identity. ### 2. Article 78 of the Constitution of the Republic of Serbia is directly relevant Within the domestic constitutional framework, this violation has a direct basis in Article 78 of the Constitution of the Republic of Serbia, prohibiting forced assimilation of persons belonging to national minorities and guaranteeing protection against any act directed towards such assimilation. The plaintiff does not invoke this article as an abstract legal-political assertion. He invokes it as the domestic constitutional expression of the same identity protection violated in these proceedings. The plaintiff is the child of a mother of Croatian origin, Cvita Miletić, and a man whose paternal line, family trail and inheritance track emerge from state files as connected with Pavle Lakatoš, a Hungarian. By administrative removal from that circle, the child was not merely renamed. He was cut off from his mother’s Croatian line, his father’s Hungarian line, his father’s language, blood relationships, inheritance position and actual family continuity. The domestic courts now refuse to resolve or correct the legal consequences of that act. Maintaining the legal consequences of the contested full adoption today is not neutral preservation of an old family-law act. It constitutes continued administrative assimilation through a contemporary judicial act. Such an approach directly conflicts with the prohibition of forced assimilation in Article 78 of the Constitution of the Republic of Serbia. ### 3. Article 8 of the European Convention protects origins, identity and personal history The European Court of Human Rights has repeatedly confirmed in its case-law that the right to private life under Article 8 of the European Convention includes: - a person’s right to know their origins; - the right to discover the identity of their biological parents; - the right to establish their biological relationship; - the right to personal history and the reasons for adoption;

The plaintiff challenges treating Milorad Vasić’s 12 September 1984 consent as the act of a father entitled to place the child for another adoption. The linked record preserves the actual roles, wording and Vera Radovanović’s involvement.

## Source page 14 - effectively presents the first adoptive parent, Vasić Milorad, as the holder of parental rights who “gives consent” to a new adoption; - thereby creates the appearance of a “first”, regular adoption, as though the child had no previous adoptive parents; whereas, in reality: - the law prohibits double adoption — Article 7; - the previous full adoption of 1979 already exists and produces effects. In this way: - the second adoptive parents, Periša and Gorgina Petrović, are deceived: they are given the impression that they are receiving a child with valid consent from the “old father”, instead of a precise legal explanation that the child is already fully adopted by the first married couple and that the law does not recognize “readoption”; - violent manipulation of the child’s identity continues: a child already erased as Palika Lakatoš and renamed Vasić Milan is now further “transferred” into another family, with a newly altered line of belonging; - the guardianship body effectively behaves as though it owns the child and his identity: first name, surname, family status and affiliation are changed, while the first adoptive parent is presented as a “father” whenever needed merely to satisfy the condition of “parental consent” on paper. When the guardianship body: - holds the negative assessment from the psychologist of the Centre for Social Work in Kragujevac, stating that adoption is not recommended; - knows that full adoption from 1979 already exists; - nevertheless organizes the first adoptive parent’s “consent” as though he were the biological father, to create an appearance of legality before the second family, this is no longer an ordinary “omission”, but: - a conscious and continuing violation of the law; - involving deception of the second adoptive parents too; - and further continuation of the forced assimilation of a child whose identity changes to suit the case file, rather than in accordance with the law and his rights. I therefore propose that the Court: 1. clearly establish that double adoption in 1979 and 1984 is contrary to Article 7 of the 1976 Adoption Act of the Socialist Autonomous Province of Vojvodina; 2. establish that disregard of the negative psychological assessment from 1984 and manufacture of the first adoptive parent’s “consent” as a “father” prove that the defendant acted not as a body protecting a child, but as a body disposing of a child and his identity; 3. treat all of this as evidence of the continuity of unlawful conduct, rather than isolated technical errors.

The second adoption is cited as part of the continuing sequence and the use of a status derived from the contested first act. The linked 1984 record allows that argument to be examined against the actual decision.

## Source page 12 **Conclusion:** On 8 April 1979, the guardianship body — Vera Radovanović — consciously ignored the fact that the child was with his grandmother and grandfather. Instead of complying with the Court’s instruction and protecting the property interests of the child living with his grandparents, the social worker: - conceals the existence of the grandmother and grandfather; - removes the child from his biological family; - constructs a story about a “vagrant mother” to justify the unlawful removal of a child already being cared for; - takes the child into full adoption, directly depriving him of the inheritance for which the Court sought protection. These minutes prove that the conditions for removing the child did not exist, because he was within his family — with the deceased father’s parents — which the Centre must have known and consciously concealed. ### VI. DOUBLE ADOPTION, DISREGARD OF THE NEGATIVE 1984 ASSESSMENT, AND FALSE “PATERNAL CONSENT” On several occasions, including the earlier submission of 27 November 2025, the defendant supplies the file on incomplete adoption no. UP 02-987/84 concerning Periša and Gorgina Petrović, while stating that it considers that file “irrelevant”, because formally this action does not seek annulment of that adoption. However, the very facts: - that full adoption by Vasić Milorad and Gospava was already established in 1979, which the defendant does not dispute; and - that, in 1984, the same body — the Centre for Social Work in Novi Sad — participated in a second adoption by different adoptive parents, are directly contrary to Article 7 of the Adoption Act of the Socialist Autonomous Province of Vojvodina then in force (1976), which provides that multiple persons cannot adopt one person unless they are married to one another. An already established full adoption cannot be “transferred” to a new married couple — that is precisely why it is called full adoption. Thus, the 1984 incomplete-adoption file is not irrelevant: it is evidence of the continuity of the defendant’s unlawful conduct: - first, full adoption in 1979 before the fifth birthday, without fulfilling the conditions under Article 30 — without the mother’s consent, effectively disregarding Pal Lakatoš’s paternity and probate proceedings O.196/79; - then “readoption” in 1984 by different adoptive parents, although full adoption already existed and would, under the law, exclude another round of adoption. This is compounded by another crucial element from the 1984 files:

The full email exchange documents the 3 March 2025 peaceful-settlement proposal and the receipt acknowledgment at 08:30. The present submission develops the author’s argument about good faith and the absence of a substantive reply.

## Source page 17 - probate file O.196/79 and the Court’s order of 20 July 1979 for appointment of a guardian to protect inheritance rights, rather than for adoption. Combined with the monitoring sheet and adoption minutes of 21 June 1979, this clearly shows that the guardianship body acted: - before the probate court’s order; - without full and lawful authority; - with the objective of removing me from the circle of heirs; - while simultaneously interfering with my identity and national affiliation. ### IX. ATTEMPTED SETTLEMENT IN GOOD FAITH AND DISREGARD OF THE WARNING ABOUT PERSONAL RESPONSIBILITY As early as the beginning of 2025, before this phase of the proceedings, the plaintiff offered the Centre for Social Work of the City of Novi Sad an opportunity to emerge from this case honourably and professionally through a peaceful resolution. The defendant thereby had a clear opportunity: - to acknowledge the unlawfulness of the full adoption in 1979; - to enable restoration of the child’s true identity; - to avoid international escalation and the issue of the personal responsibility of present managers and officials. Instead, the Centre chose to ignore that opportunity. #### 1. Chronology: email “Settlement proposal — P2 1435/24” (3 March 2025) On 3 March 2025, the plaintiff sent an email to the Centre’s official address, novisad.csr@minrzs.gov.rs, with the subject: > “Subject: Settlement proposal — P2 1435/24”. At 08:30 that same day, the Centre’s reception office replied: > “Your email has been duly received. Kind regards. Reception Office.” (Note: the original text is in Cyrillic.) Thus: - the Centre indisputably received the email; - it indisputably had access to the contents of the proposal; - it indisputably knew that a settlement was being offered. After that acknowledgment of receipt, the Centre sent no substantive reply and showed no willingness to consider the settlement proposal.

The civil-register source underlies the author’s reference to his mother Cvita’s identity and Croatian nationality. It remains linked to the later identity entries without turning those entries into different people.

## Source page 4 In practice, this means that, at the time the Court officially proceeds on the basis that I am Miletić Milivoj, the deceased’s son born outside marriage whose inheritance rights need protection, the Self-Managing Community of Interest / Centre for Social Work simultaneously conducts proceedings in which I am treated as a child “without identity” and “without capacity to inherit”, prepared for full adoption with the claim that the adoptive parents “do not seek for the child to inherit from anyone”. ### III. “OWNERSHIP” OF IDENTITY AND FORCED ADMINISTRATIVE ASSIMILATION — EFFECTIVE “SERBIANIZATION” OF THE IDENTITY OF A CHILD OF HUNGARIAN–CROATIAN ORIGIN — A CONTINUING ACT The documents cited reveal not merely a social picture, but a clear pattern of interference with the national, family and personal identity of a child of Hungarian–Croatian origin: - father: Pal (Pavle) Lakatoš, a Hungarian, with paternity acknowledged in civil case P-1642/76 and capacity to inherit recognized in probate case O.196/79; - mother: Cvita Miletić, a Croatian, as recorded in KJ-8 / birth-register entry 2512/1974; - adoptive parents in 1979: Milorad and Gospava Vasić, of Serbian nationality; - adoptive parents in 1984: Periša and Gorgina Petrović, also of Serbian nationality. Despite this, the guardianship body: - asserts in its internal notes that Pal Lakatoš “claims to be the biological father” and that this is “unlikely”, although judicial files now exist that unequivocally confirm paternity; - arrogates to itself the right effectively to nullify acknowledged paternity and paternal Hungarian origin, invoking a social worker’s “assessment” rather than law and facts; - rapidly carries out the child’s full adoption by a couple of Serbian nationality, changing the name and civil-register entry so that the adoptive parents appear to be biological parents. In effect, the Centre for Social Work in Novi Sad behaves as though it can dispose of my identity as property: - it changes my first name and surname; - it crosses out my paternal origin (Lakatoš, Hungarian) and maternal origin (Miletić, Croatian); - it administratively repackages me into an entirely new identity aligned with that of the adoptive parents (Serbian); - it does all this when, as a child, I had already developed the awareness that I was Palika — the son of Pal Lakatoš. Such conduct cannot be regarded as “neutral social protection”, but as forced administrative assimilation (Serbianization): the systematic conversion of a child of a different origin into the majority identity, with the erasure of traces in civil registers and family records. I particularly emphasize that this violation did not end in 1979. It was:

The author reserves separate claims for military and wartime consequences under the contested identity. The linked official service records distinguish documented service from his legal argument about state responsibility.

## Source page 22 - whether today’s Centre has the right to behave as the owner of a child’s identity and origin; and - whether, through its silence, the Court agrees to be an accomplice in this. ### XI. RESERVATION OF THE RIGHT TO DAMAGES AND FURTHER PROCEEDINGS I fully maintain Section IX of my submission of 27 October 2025, entitled “Reservation of the right to costs and damages”, without changing the relief sought: - I reserve the right to seek compensation for material and non-material damage in separate proceedings; - I reserve the right, once the obstacle created by full adoption is removed, to commence proceedings to establish paternity and obtain corresponding corrections to civil registers; - I consider that the defendant should bear the costs of these proceedings, while any question of recourse against third parties, such as heirs, concerns exclusively the defendant’s relationship with those persons and is not a burden for the plaintiff. I particularly emphasize that the falsified identity, founded upon unlawful full adoption and forced administrative assimilation, had direct consequences for my life and bodily integrity. As a person constructed on paper as a “domestic” citizen with an assigned majority identity, during the wars of the 1990s, including the 1999 war, I was legally and effectively exposed to obligations of military service, mobilization and wartime measures precisely in the state that had previously falsified my identity. Had I grown up with truthful knowledge of my Hungarian–Croatian origin, actual family connections and opportunities to establish ties with other legal orders, I would never have voluntarily agreed to become that state’s soldier or to have my life used as a resource in its wars. I therefore consider that all obligations the state imposed on me precisely through that unlawfully constructed identity — including military obligations and being taken into a war zone — were substantively founded upon a void act of full adoption and forced assimilation. I leave the question of the legal consequences of that nullity for those obligations, and the scope and method of compensation for endangering my life, to separate proceedings that I reserve the right to initiate after this dispute ends. **Proposal to the Court:** - To take note of this submission and add it to the case file. - In accordance with previous orders, to establish which evidence the defendant has failed to supply and draw adverse evidentiary inferences in that respect. - In deciding the case, to apply the law in force at the time of the acts — the 1974 Constitution of the SFRY, the 1976 Adoption Act of the Socialist Autonomous Province of Vojvodina, the ICCPR and ICERD — and assess the defendant’s present conduct, including failure to supply files, denial of the violation and maintenance of an unlawful state, in light of current law: the 2006 Constitution of the Republic of Serbia, minority legislation, the Anti-Discrimination Act and relevant international conventions. - To deliver a clearly and fully reasoned judgment confronting the facts and documents as a whole, rather than the selective quotation practised by the defendant.

The author invokes divorce case P.1642/76 for Pál’s acknowledgment of the child. That file also contains Cvita’s testimony and is relevant to the public-document acknowledgment issue raised in the probate appeal.

## Source page 4 In practice, this means that, at the time the Court officially proceeds on the basis that I am Miletić Milivoj, the deceased’s son born outside marriage whose inheritance rights need protection, the Self-Managing Community of Interest / Centre for Social Work simultaneously conducts proceedings in which I am treated as a child “without identity” and “without capacity to inherit”, prepared for full adoption with the claim that the adoptive parents “do not seek for the child to inherit from anyone”. ### III. “OWNERSHIP” OF IDENTITY AND FORCED ADMINISTRATIVE ASSIMILATION — EFFECTIVE “SERBIANIZATION” OF THE IDENTITY OF A CHILD OF HUNGARIAN–CROATIAN ORIGIN — A CONTINUING ACT The documents cited reveal not merely a social picture, but a clear pattern of interference with the national, family and personal identity of a child of Hungarian–Croatian origin: - father: Pal (Pavle) Lakatoš, a Hungarian, with paternity acknowledged in civil case P-1642/76 and capacity to inherit recognized in probate case O.196/79; - mother: Cvita Miletić, a Croatian, as recorded in KJ-8 / birth-register entry 2512/1974; - adoptive parents in 1979: Milorad and Gospava Vasić, of Serbian nationality; - adoptive parents in 1984: Periša and Gorgina Petrović, also of Serbian nationality. Despite this, the guardianship body: - asserts in its internal notes that Pal Lakatoš “claims to be the biological father” and that this is “unlikely”, although judicial files now exist that unequivocally confirm paternity; - arrogates to itself the right effectively to nullify acknowledged paternity and paternal Hungarian origin, invoking a social worker’s “assessment” rather than law and facts; - rapidly carries out the child’s full adoption by a couple of Serbian nationality, changing the name and civil-register entry so that the adoptive parents appear to be biological parents. In effect, the Centre for Social Work in Novi Sad behaves as though it can dispose of my identity as property: - it changes my first name and surname; - it crosses out my paternal origin (Lakatoš, Hungarian) and maternal origin (Miletić, Croatian); - it administratively repackages me into an entirely new identity aligned with that of the adoptive parents (Serbian); - it does all this when, as a child, I had already developed the awareness that I was Palika — the son of Pal Lakatoš. Such conduct cannot be regarded as “neutral social protection”, but as forced administrative assimilation (Serbianization): the systematic conversion of a child of a different origin into the majority identity, with the erasure of traces in civil registers and family records. I particularly emphasize that this violation did not end in 1979. It was:

The submission recalls the genetic and family material presented with the settlement attempt. The linked author’s supplement preserves the surnames and family relationships with the previously agreed first-name redactions.

## Source page 18 #### 2. Substance of the settlement offer In that email, the plaintiff clearly set out what he sought and what he offered: - Acknowledgment of the nullity of the unlawful full adoption in 1979, which would: - open the way to restoring the original identity — Milivoj Miletić, the son of Cvita and Pal Lakatoš; - enable commencement of paternity-establishment proceedings before the competent court in Kragujevac; - remove the obstacle created today by the unlawful entry “Milan Petrović”. - The plaintiff’s biological identity is defined as: - Croatian through his mother, Cvita Miletić; - Hungarian through his father, Pal / Pavle Lakatoš; - supported by DNA evidence from 23AndMe and MyHeritage and kinship with paternal and maternal families in Croatia, the United States, Canada and Australia. - Legal facts concerning 1979: - the proceedings were conducted contrary to the law then in force — the six-month period for locating the mother had not been fulfilled; - full adoption was finalized seven days before the fifth birthday, to exploit the last opportunity for a permanent change to civil-register data; - such “injection” of identity into civil registers has the character of a legal forgery from today’s evidentially demonstrable standpoint. The plaintiff explicitly stated: - that his origin was “immeasurably important” to him; - that he was not someone “whose origin should be played with, rewritten or insisted upon remaining falsified”; - that he was proud of and sensitive about his national origin through both his mother and father. Concerning the possibility of agreement, the plaintiff offered: - that, if the Centre acknowledged the adoption’s nullity, he would direct his energy towards paternity-establishment proceedings and not open a new front against the Centre; - that prolongation of the proceedings, additional costs and consequences for employees would thereby be avoided; - that, if the settlement were accepted, “he would no longer have any legal or other contact with the Centre, nor would it have any obligations towards him”. In other words, the plaintiff offered a solution that: - corrects the unlawful adoption; - saves the resources of the Court and Centre; - protects present employees from further involvement in the act begun in 1979. #### 3. Clear warning about the consequences of rejection In the same email, the plaintiff warned the Centre that rejection would result in: