Plaintiff’s response of 30 June 2025: obstruction, backdating and nullity of the 1979 adoption

The timeline entry opens the plaintiff’s submission dated 30 June 2025, which responds to the CSR submission identified as 1 April. This date comes from the text; no receipt stamp is present.

**PLAINTIFF’S SUBMISSION** (concerning the defendant’s submission of 1 April 2025) Kragujevac, **30 June 2025** Dear Court, In this submission I respond to the defendant’s submission (Centre for Social Work of the City of Novi Sad, dated 1 April 2025), setting out the key facts, evidence and legal arguments with a view to a correct and lawful decision.

The response challenges the earlier CSR submission’s reversed parties and procedural conduct. That source has a 1 April heading and 7 May closing date; neither is treated here as a proven court receipt.

In this submission I respond to the defendant’s submission (Centre for Social Work of the City of Novi Sad, dated 1 April 2025), setting out the key facts, evidence and legal arguments with a view to a correct and lawful decision. ### 1. FORMAL AND PROCEDURAL FAILURES OF THE DEFENDANT - In its submission of 1 April 2025, the defendant incorrectly identified the parties to the dispute, demonstrating a lack of seriousness and negligence in its approach to this case. - The Centre for Social Work did not attend the hearing scheduled for 5 June 2025, thereby showing disrespect for the court and the proceedings. - The Centre also failed to comply with the court’s clear order of 26 March 2025 to provide the complete documentation on how and on what basis it acquired authority over the child (the plaintiff), thereby continuing to obstruct these proceedings.

The plaintiff describes the 26 March documentation order broadly. The linked court record gives his request, Maja Petrović’s objection to earlier protection files, and the exact final order for adoption documentation held by the defendant.

- The Centre also failed to comply with the court’s clear order of 26 March 2025 to provide the complete documentation on how and on what basis it acquired authority over the child (the plaintiff), thereby continuing to obstruct these proceedings.

The response states that CSR did not attend on 5 June. The separate author account supplies his description of the oral explanation, lack of a written document handed to him and acceptance of 3 September.

- The Centre for Social Work did not attend the hearing scheduled for 5 June 2025, thereby showing disrespect for the court and the proceedings.

The response dated 30 June says the settlement proposal remains unanswered and lists its receipt proof. The existing email archive supplies the 3 March sending and CSR acknowledgment as distinct earlier records.

On 3 March 2025, I sent the Centre for Social Work a settlement proposal aimed at a peaceful resolution of the dispute, with clearly defined terms. Along with this proposal I supplied evidence of my identity and origins. To this day the Centre has not responded, demonstrating a complete unwillingness to cooperate in resolving this dispute. I enclose proof that the settlement proposal was received.

The author expressly traces his competence and probate/adoption arguments back to the submission of 30 June 2025. This relation preserves the chronology of the written challenge before judgment.

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.

Attachments 1 and 2 point to two existing sections of the same probate dossier: the 20 July 1979 guardianship request for inheritance protection and the 19 March hearing. They are linked without creating duplicate documents.

- **ATTACHMENT 1:** Court order to the Centre for Social Work Novi Sad (20 July 1979). - **ATTACHMENT 2:** Probate-hearing record (19 March 1979).

Attachment 5 explicitly names the document comparing the June 1979 professional reports. The linked two-page author analysis preserves its original criticisms and a separately marked later correction about eighteen years of marriage.

- **ATTACHMENT 5:** Document on contradictions in the reports of the professional services (June 1979).