CSR archive submission P2.1435/24 — 22 December 2025

Full translation of the submission on the first two pages of the supplied 15-page file. Its heading and closing date are 22 December 2025; the court receipt stamp is dated 24 December 2025. The new public PDF contains these two submission pages. The historical attachments are identified below and linked to the existing dossier. The source’s party labels, quotations, dates and name variants are preserved.

Source page 1

REPUBLIC OF SERBIA
AP VOJVODINA
CENTRE FOR SOCIAL WORK OF THE CITY OF NOVI SAD

Novi Sad, Zmaj Ognjena Vuka 13
Telephone: 021/210-1400
Email: [email protected]
Number: 560-111-1/2024
Date: 22 December 2025

BASIC COURT IN NOVI SAD
Case no. P2.1435/24

Plaintiff: Centre for Social Work of the City of Novi Sad, Zmaj Ognjena Vuka 13, Novi Sad.

Defendant: Milan Petrović, of Kragujevac, Kraljevačkog bataljona Street no. 110.

SUBMISSION

In accordance with the ruling of the Basic Court in Novi Sad, case no. P2.1435/24, of 26 November 2025, the defendant provides documentation obtained from the archive, namely:

1. Copy of the file cover, Miletić Cvita Milivoj, registration no. 3871/79, no. UP 03-335/79;
2. Foster-family questionnaire for Julka Vizmet;
3. Family-placement agreement no. 05-320/6, of 25 April 1979;
4. Copy of the decision of the Self-Managing Community of Interest for Social Protection in Novi Sad, no. Up-3-355/79, of 16 April 1979;
5. Copy of the decision of the Self-Managing Community of Interest for Social Protection in Novi Sad, no. Up-3-356/79, of 5 July 1979;
6. Contact and case-work monitoring sheet for Miletić Milivoj, no. 3871/79;
7. Personal record of a social-protection service user, no. 3871, of 10 April 1979.

The documentation supplied indisputably shows that the plaintiff, then the minor Milivoje Miletić, was a child without parental care who needed family-law protection, and that adoption was assessed as the best form of protection, given that the mother had abandoned the child, the child’s paternity had not been established, and that after the death of Pál Lakatoš, who had allegedly passed himself off as the child’s father, none of his close relatives wanted to assume care of the child. That the relatives did not want to assume care of the child can clearly be concluded from the narrative of the statement of claim on page 4, which states:

“…the lawyer Helena Uzelac very soon, specifically on 3 April 1979, ceases to be the co-heirs’ representative, of which

[The quoted passage continues on source page 2.]

Court receipt stamp visible on page 1

BASIC COURT IN NOVI SAD
Sent by registered post on: [field blank]
“Рно”: [field blank]
Received in person / by post (registered / ordinary): [printed alternatives, no method selected]
Date: 24 December 2025
Copies and attachments: [fields blank]
Fees paid / no fee: [printed fields, no entry]
Time: [field blank]
Signature: [field blank]

Source page 2

she informs the probate court, and the co-heirs then retain a new representative who succeeds, through an appeal allowed by the second-instance court, in overturning the first-instance judicial decision by which the minor Miletić Milivoj was declared a co-heir of Pál Lakatoš to a quarter of the estate. The grounds of the appeal concerned the fact that kinship with the deceased—paternity—had not been established in the manner prescribed by law.”

The fact that Milivoj Miletić was a child deprived of parental and family care also follows from the contact and case-work monitoring sheet, particularly the entry of 6 April 1979, where it states, among other things:

“Establishing the circumstances of prenatal and postnatal development—during pregnancy the mother led a disorderly life. After childbirth he lived with his mother for a short time, when she abandoned him. He was brought up by Pál Lakatoš, who claims to be the child’s natural father, but this is unlikely because Cvita lived with several men at the same time.”

“Establishing the manifestations of the origin and development of the problem: after the death of the child’s natural father, the child was left without parental care.”

Based on the entry of 16 April 1979, it is established that care of the minor Milivoj was taken over by Pál Lakatoš’s sister, Julka Vizmet, who lived in Irig, and that she agreed to care for the child for payment as a foster carer, which constitutes a temporary form of protection.

In view of all the above, the defendant maintains all its previous statements and again emphasizes that it opposes the action and the claim as formulated, because grounds for annulment of the adoption did not exist at the time it was established, in accordance with the provisions of the Law on Adoption adopted by the Assembly of the Socialist Autonomous Province of Vojvodina at the session of the Council of the Municipality on 23 September 1976 and at the session of the Socio-Political Council on 23 September 1976, no. 01-551/1976.

In Novi Sad, 22 December 2025.

For the defendant, by authorization

Maja Petrović, law graduate

[Official institutional seal and signature]

Existing historical attachments and source boundaries

Pages 3–15 of the supplied file correspond to physical pages 1–13 of the already archived Vera Radovanović dossier 3871/79: the cover and inventory, the decision dated 16 April, the three-page foster-family questionnaire, the two-page agreement dated 25 April, four contact-monitoring sheets and the front of the personal record. The existing complete 14-page PDF and confirmed English reading remain available.

The supplied annex set does not include the personal record’s reverse, which is physical page 14 of the existing dossier. Nor is a separate copy of the listed decision Up-3-356/79 of 5 July 1979 visible among those thirteen scans. This describes the supplied file, not what was or was not filed with the court. The monitoring-sheet entry about delivery on 5 July does not by itself identify that particular decision.

Editorial notes on the printed submission

The heading again labels CSR as plaintiff and Milan Petrović as defendant; the body and signature describe CSR as the defendant. These labels are preserved. The submission attributes its quoted passage to 6 April; the existing confirmed transcription places that passage under 8 April. The confirmed handwriting transcription has not been changed. The printed name Vizmet is a variant of the already identified Julka Vizmeg.

Later author’s note

The author regards this submission as crowning evidence supporting his case and describes his joy on reading it. He believes that Maja selected the parts she thought served her position, expecting him not to decipher Vera’s handwriting. This is his interpretation of their intention, separate from the words of the submission. The comparison remains available through the existing, previously confirmed transcription of Vera’s notes.