Maja Petrović’s CSR submission opposes annulment and dismisses the suitability criticism — closing date 7 May 2025

The closing conclusion, date 7 May 2025 and Maja Petrović’s signature identify the CSR’s opposition submission in P2.1435/24. The timeline uses this printed closing date and retains 1 April in the heading, without inventing a court-receipt or actual signing date.

It is undisputed from all of the above that the procedure in question was conducted in accordance with the legally prescribed procedures and professional standards applicable at the time the adoption ruling was issued, and that there is not a single statutory ground for its annulment. In Novi Sad, on 07.05.2025 For the defendant, by authorization **Maja Petrović, law graduate**

The CSR relies on the social worker’s, educational specialist’s and psychologist’s suitability findings and lists their dates: 12, 18 and 19 June 1979. The linked original dossier contains those three reports, as well as the listed medical, Municipal Court and employment documents. It permits direct comparison of the favourable conclusions and the internal differences in schooling and parental biography.

Taking the provisions quoted above into account, **it is undisputed that the guardianship authority conducted the adoption procedure in accordance with all statutory rules**, which involved conducting the assessment of the suitability of the prospective adopters through findings and opinions prepared by a social worker, an educational specialist and a psychologist, as well as obtaining the documentation necessary to meet the statutory conditions under Article 41 of the aforementioned Act. **Evidence:** - Extract from the register of births, Novi Sad register, entry no. 2512 for 1974, dated 27 March 1979, - Extract from the register of marriages, Novi Sad register, Petrovaradin, entry no. 1 for 1962, - Medical certificate for Vasić Milorad, protocol no. 9/7, dated 11 June 1979, - Medical certificate for Vasić Gospava, protocol no. 805, dated 4 June 1979, - Certificate of the Municipal Court in Novi Sad, case no. Kr II 1353/79, dated 5 June 1979, for Vasić Gospava, - Certificate of the Municipal Court in Novi Sad, case no. Kr II 1354/79, dated 5 June 1979, for Vasić Milorad, - Certificate of employment and average income of the Novi Sad Construction Work Organization with unlimited joint and several liability of its Basic Organizations of Associated Labour, “Novograp”, no. 02-17/243, dated 6 June 1979, - Psychologist’s opinion dated 19 June 1979, - Social worker’s report dated 12 June 1979, - Educational specialist’s report dated 18 June 1979.

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 submission expressly rejects the claim’s assessment criticism as sweeping, unqualified and inadmissible after 46 years. The linked full claim supplies the passages being challenged, including the reports’ content, Cvita Miletić’s consent and search, and the author’s account of beatings, hostility, witnessed violence and abandonment. The connection lets readers compare the CSR’s general rejection with the actual pleaded facts.

Taking all of the above into account, the sweeping allegations in the narrative of the claim are unfounded and cannot be given weight, and especially those allegations which, as grounds for the nullity ## Source page 3 of the adoption, assert that Gospava and Milorad Vasić were unsuitable for adoption, because in the narrative of the claim that assessment is made by **unqualified persons who have no statutory authority to do so**. It is inadmissible to interpret findings and opinions from a distance of 46 years and to state “that the checks on the suitability of those persons were not carried out properly, if any checks were carried out at all, since the defendant’s reports on the suitability of the adopters contain a series of stock phrases repeated over and over in all similar reports and situations”. It is undisputed from all of the above that the procedure in question was conducted in accordance with the legally prescribed procedures and professional standards applicable at the time the adoption ruling was issued, and that there is not a single statutory ground for its annulment.

Maja Petrović’s signature formula identifies her as acting for the defendant. At the 6 February 2025 hearing she represented the CSR, opposed the claim by invoking the 1976 Act and requested thirty days to obtain and study that Act. This later statutory defense is linked to that recorded procedural step and her identified role.

For the defendant, by authorization **Maja Petrović, law graduate**

The CSR maintains that no statutory annulment ground exists in a submission headed 1 April and closing 7 May 2025. Both dates follow its reception office’s 3 March acknowledgment of the author’s settlement proposal. The submission does not mention that proposal or the genetic companion; the link documents this sequence without treating the submission as a reply or assuming who read the attachments.

It is undisputed from all of the above that the procedure in question was conducted in accordance with the legally prescribed procedures and professional standards applicable at the time the adoption ruling was issued, and that there is not a single statutory ground for its annulment. In Novi Sad, on 07.05.2025

The court requires a detailed position, evidence and all adoption documentation held by the CSR within fifteen days. The linked CSR defense carries a heading of 1 April and closing date of 7 May 2025, quotes the 1976 Act and lists ten evidentiary items. The relation lets readers compare the order with the later defense’s actual contents; the defense’s printed dates do not establish its filing or receipt date or prove compliance with or breach of this order.

The defendant’s representative is required, **within 15 days from announcement of the order**, to provide a detailed written statement and submit the relevant evidence as stated above, and within the same period to supply **all documentation held by the defendant concerning the plaintiff’s adoption** by the adopters, now deceased, Gospava and Milorad Vasić.

The earlier CSR submission, with heading 1 April and closing date 7 May 2025, also labels CSR as plaintiff and Milan as defendant while presenting the defendant’s opposition to the claim. The November response repeats that reversal. Comparing these two signed institutional submissions documents the recurrence of the role-label error rather than assuming a new party configuration.

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**.