Maja Petrović: selected statements from Vera’s dossier used to defend adoption — CSR submission dated 22 December 2025

The CSR submission in P2.1435/24 is dated 22 December 2025; the visible Basic Court receipt stamp records 24 December. The timeline event represents the dated submission, with court receipt separately identified.

Date: **22 December 2025** **BASIC COURT IN NOVI SAD** Case no. **P2.1435/24**

The seven-item archive inventory and the quoted monitoring entries lead to the existing Vera Radovanović dossier 3871/79. The thirteen historical scans match its physical pages 1–13; the existing full source also has the personal record’s reverse on page 14. The complete dossier permits direct comparison of the misdated quotation, care arrangements, maternal records and the child’s reaction to his name.

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 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.

CSR infers relatives’ unwillingness to care from Helena Uzelac’s withdrawal from probate representation on 3 April 1979. The linked probate file contains her actual termination of representation of Roža Kopljan and the earlier record placing the child with Pál’s parents. The scope of inheritance representation and an appeal about legal paternity differs from actual child care.

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 December submission quotes doubt about Pál’s paternity, then refers to the natural father’s death and his sister. In the linked P.1642/76 divorce record, Pál states that he had a son with Cvita, and his wife Vera Lakatoš also describes that child. These are concrete records of knowledge and acknowledgment, distinct from formal judicial establishment of paternity.

> “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.

CSR concludes that no grounds for annulment existed when the adoption was established. The linked record and decision of 21 June 1979 show the actual adoption procedure and subsequent civil-register instruction. They allow comparison of the December best-protection argument with what the original act records about participation, consent and the resulting identity entries.

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**.

The concluding defence of adoption must be compared with the plaintiff’s specific requests of 27 October: the preceding protective acts, records of maternal consent and search, and the historical conditions for adoption. The December response relies on selected parental-care assertions rather than identifying those distinct procedural records. The linked plaintiff submission states his argument of nullity and violent assimilation in full.

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**.

The submission expressly invokes the court’s order of 26 November. That hearing record separately grants 15 days for a response and 30 days for archive documents possessed by CSR and relied upon by the plaintiff. The December inventory identifies what this response says it supplies; the linked hearing permits checking the actual scope of the archive order.

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 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: