Maja Petrović’s CSR response: prior acts, the metal cabinet and the 1984 consent record — 27 November 2025

The CSR submission in case P2.1435/24 is dated 27 November 2025, while the court stamp records receipt on 2 December. The document date and the court receipt date describe different actions.

Date: **27 November 2025** **BASIC COURT IN NOVI SAD** Case no. **P2.1435/24**

The response quotes the plaintiff’s requests for adoption records, professional opinions, certificates, summonses, service documents and the preceding acts. The supplied plaintiff submission is dated 27 October; CSR calls it a submission of 29 October and asserts receipt on 5 November. Reading the October request beside this response shows which items are identified and which are not.

The defendant received the plaintiff’s submission dated **29 October 2025** on **5 November 2025**, and responds to it as follows: In that submission, in **Section II**, entitled **Proposals for Evidence and Official Documents**, at **point 4**, the plaintiff proposes that the defendant again provide the adoption record, the expert service’s opinion (social worker, pedagogue, psychologist), medical certificates, summonses, proof of service, the instruction to the registrar, all acts concerning registration/annulment, and the complete set of “preceding” acts (how the child came under the institution’s authority, communication with the probate court). **1.** Regarding provision of the **adoption record**, the defendant states that a copy of that record was **submitted with the statement of claim, designated as attachment no. 4** (on page 11 of the statement of claim), and that the defendant does not dispute its authenticity. **2.** Regarding provision of the expert service’s opinions, the defendant states that the reports of the social worker, pedagogue and psychologist were **attached to the statement of claim and designated as attachment no. 7, attachment no. 8 and attachment no. 9** (on pages 16–22 of the statement of claim). **3.** Regarding the requested *medical certificates, summonses and proof of service*, the defendant states that **the submission of 8 May 2025 provided copies** of the following documents:

The response invokes the hearing of 26 November when describing where earlier files are kept. The actual hearing record sets separate periods of 15 days for a response and 30 days for archive evidence possessed by CSR and invoked by the plaintiff. It records Maja Petrović’s search for a 1974 file, but does not mention a metal cabinet. The record allows the statement about storage and the actual court orders to be compared.

**4.** Regarding the requested “instruction to the registrar, all acts concerning registration/annulment”, the defendant hereby states that the document in question was **submitted with the statement of claim and designated as attachment no. 5** (on pages 13 and 14). **5.** Regarding the “complete preceding acts”, the **plaintiff** stated at the hearing held on **26 November 2025**, explaining that **adoption files are kept separately in a special metal cabinet** at the Centre for Social Work, under special regulations, while the files of all other proceedings at the Centre constitute archival material kept in accordance with the law.

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;

In March, the plaintiff asked for the records showing how he came under CSR authority; CSR opposed the preceding protective files, while the court’s order concerned adoption documentation held by CSR. The November response again addresses the preceding acts through a storage description. The link traces the same request across the hearings without treating descriptions of storage as the act establishing the institutional basis.

**5.** Regarding the “complete preceding acts”, the **plaintiff** stated at the hearing held on **26 November 2025**, explaining that **adoption files are kept separately in a special metal cabinet** at the Centre for Social Work, under special regulations, while the files of all other proceedings at the Centre constitute archival material kept in accordance with the law.

CSR refers to the 1979 adoption record already attached to the claim and separately to the three professional reports. The linked package contains the record and decision of 21 June 1979, including the subsequent civil-register instruction. It provides the original adoption act against which the October request for the complete file and all status acts can be read.

**1.** Regarding provision of the **adoption record**, the defendant states that a copy of that record was **submitted with the statement of claim, designated as attachment no. 4** (on page 11 of the statement of claim), and that the defendant does not dispute its authenticity. **2.** Regarding provision of the expert service’s opinions, the defendant states that the reports of the social worker, pedagogue and psychologist were **attached to the statement of claim and designated as attachment no. 7, attachment no. 8 and attachment no. 9** (on pages 16–22 of the statement of claim).

The response expressly does not dispute the contents or authenticity of Milorad Vasić’s consent record of 12 September 1984. The linked record allows his words to be checked directly. The author’s challenge concerns the legal validity of that consent after the 1979 full adoption; non-dispute of the record’s contents is separate from that legal issue.

In the plaintiff’s aforementioned submission, in **Section II**, entitled **Proposals for Evidence and Official Documents**, at **point 5**, the plaintiff requested from the defendant the record of **12 September 1984** (Milorad Vasić’s statement concerning “consent to the adoption of the minor Vasić Milan”). Regarding this, the **plaintiff** states that the record was **submitted with the statement of claim and designated as attachment no. 11** (on page 30 of the statement of claim), and that the defendant does not dispute its contents or authenticity.

CSR names the 26 September 1984 adoption record, lists documents in that incomplete-adoption file and states that it supplies them while disputing their relevance. The linked record is the existing 1984 source. This connection addresses the plaintiff’s requested legal continuity after the 1979 full adoption; it does not make the later file a newly pleaded annulment claim.

In the plaintiff’s submission of **29 October 2025**, in **Section III**, entitled **Arranging Procedural Prerequisites and Time Limits (Powers of Attorney and Time Limits)**, at **point 2 — Delivery of Complete Documentation**, subpoint 4, **“the complete file on incomplete adoption”**, the **plaintiff** states that the statement of claim includes the **Adoption Record no. Up. 02-987/84, dated 26 September 1984, designated as attachment no. 11** (on page 28 of the statement of claim), and that, in addition to the aforementioned documents, this submission provides the documentation from the incomplete-adoption file, case no. **UP 02-987/84**, namely: - Application for establishment of adoption, **Up 02-987**; - Extract from the death register for **Gospava Vasić**; - Medical certificate no. **05-23** for **Georgina Petrović**, dated **29 August 1984**; - Medical certificate no. **05-24** for **Periša Petrović**, dated **29 August 1984**; - Findings and opinion of the psychologist of CSR Kragujevac, dated **10 January 1984**; - Social worker’s report with the opinion of CSR Kragujevac, dated **1 March 1984**; ## Source page 3 Continuation of the incomplete-adoption documentation list: - Findings and opinion of the pedagogue of CSR Kragujevac; - Extract from the marriage register for **Periša and Georgina Petrović**; - Certificate of CSR **“Solidarnost” Kragujevac**, no. **U-1304/83-2**; - Certificate of CSR **“Solidarnost” Kragujevac**, no. **U-1304/83-1**; - Certificate of the Municipal Court in Kragujevac, no. **2481/84**, dated **19 September 1984**; - Certificate of the Municipal Court in Kragujevac, no. **2305/84**, dated **30 August 1984**. The defendant submits the aforementioned incomplete-adoption documentation, although it considers it irrelevant because the claim does not seek annulment of this adoption.

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**.

The earlier CSR response of 27 November described adoption-file storage and referred to copies already held in the case; this December submission lists the historical foster-care archive and uses selected passages to defend adoption. Both are signed by Maja Petrović and both reverse the parties in their headings. Comparing the two separates document production from the inferences offered in support of lawfulness.

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:

The response selects the October submission’s Section III/2 request for the 1984 file. The October submission also reaffirmed the separate 2 October requests for evidence of the representative’s impediment and the court registry’s dispatch records concerning 28 August. These three response pages do not identify the dispatch records. The link exposes the original requests, alongside the November hearing’s separately recorded medical-copy handover.

In the plaintiff’s submission of **29 October 2025**, in **Section III**, entitled **Arranging Procedural Prerequisites and Time Limits (Powers of Attorney and Time Limits)**, at **point 2 — Delivery of Complete Documentation**, subpoint 4, **“the complete file on incomplete adoption”**, the **plaintiff** states that the statement of claim includes the **Adoption Record no. Up. 02-987/84, dated 26 September 1984, designated as attachment no. 11** (on page 28 of the statement of claim), and that, in addition to the aforementioned documents, this submission provides the documentation from the incomplete-adoption file, case no. **UP 02-987/84**, namely: