Statement of Claim

The claim expressly invokes P.1642/76 and the father’s, family members’ and witness’s statements about the plaintiff’s origin. The linked archival divorce file makes those earlier statements available alongside the 2024 pleading.

The following primarily supports the assertion that the late Pavle Lakatoš was known to be the plaintiff's biological father. The late Pavle Lakatoš divorced his wife Veronika because of disagreements in their married life. In their divorce proceedings before the District Court in Novi Sad, case No. P.1642/76, the records of the hearings contain statements in several places, made by Pavle Lakatoš himself as a party to the proceedings, by his wife Veronika as the other party, by their daughter Roža, who wished to testify in her parents' divorce proceedings and in whose care the then minor plaintiff was even placed, and by the witness Gabrić Nikola. Those statements say that Pavle Lakatoš had fathered an extramarital child — a son — with the day labourer Cvita, who helped him run his farm and with whom he had meanwhile begun living together.

The claim identifies the O.196/79 probate file and Helena Uzelac’s statement that the deceased acknowledged and cared for another child. The archived hearing and probate decision provide the source of the inheritance and paternity argument, without guessing the numbering of the claim’s thirteen exhibits.

In the probate proceedings opened after the late Pavle Lakatoš, formerly of Novi Sad, which were conducted before the Municipal Court in Novi Sad under case No. O.196/79, at the hearing on 19 March 1979, attorney Helena Uzelac, counsel for the daughter and heir Roža Lakatoš, stated that, apart from the reported marital children of the deceased, there was another child who was an heir and whom the deceased had had from an extramarital relationship. Admittedly, as she herself stated, it had not been judicially established that the deceased was his father, but he had acknowledged the child as his own on several occasions, kept him and cared for him. Following the death, the minor Milivoj was in the care of the deceased's mother and father. We submit to the Court that attorney Helena Uzelac's foregoing statement about the existence of another heir is crucial to understanding everything that

The claim names the social, pedagogical and psychological assessments dated 12, 18 and 19 June 1979. The linked dossier contains those reports, whose favourable conclusions the plaintiff challenges through his childhood account of violence, hostility and abandonment.

Through its employees, using all manner of platitudes and paeans of praise about the adopters, the defendant established completely untrue facts about their suitability in the reports prepared by social worker Vera Radovanović on 12 June 1979, pedagogue Miroslava Gudelj on 18 June 1979, and psychologist Cvetko Ratković on 19 June 1979. To this day, the plaintiff has not been given access to the medical report on the adopters' suitability.

The claim identifies the full adoption act of 21 June 1979 that it seeks to annul. The existing archival record is connected as the challenged act, not as proof of its lawfulness. The claim’s differing OCR references /74 and /70 remain visible in the separate source passages.

The other important date is 21 June 1979, when the plaintiff, then the minor Miletić Milivoj, was placed for full adoption with the adopters Vasić Milorad and Vasić Gospava, a childless married couple from Budisava, both now long deceased. That decision of the defendant was declared in the Record of Full Adoption of the Self-Managing Community of Interest for Social Welfare of Novi Sad, No. 03-507/79 of 21 June 1979. The defendant also issued

The ruling identifies the claim received on 22 February 2024 and its request to annul the 1979 full adoption. It is the next procedural act in the same claim, not a new lawsuit or a judgment on its merits.

On 22 February 2024, the plaintiff Milan Petrović of Kragujevac, through counsel, filed with this Court a statement of claim against the defendant Centre for Social Work of the City of Novi Sad, of Novi Sad, seeking annulment of full adoption.

The judgment quotes the relief sought in the claim before dismissing it. The original claim sets out why the author seeks annulment for absolute nullity and restoration of his birth identity. Linking the two allows the requested measures to be distinguished from the court’s operative result.

The plaintiff’s claim, which reads: > “The plaintiff’s claim is upheld as well-founded. > > The full adoption established and declared by the decision of the Self-Managing Community of Interest for Social Welfare Novi Sad, no. UP.03-507/79 of 21 June 1979, in Novi Sad, whereby Vasić Milorad, born on 15 February 1941 in Osiječani, Municipality of Doboj, and Vasić Gospava, born on 21 August 1932 in D. Klakar, Municipality of Doboj, both residing in Budisava, Petefi Šandora Street no. 52, adopt the minor Miletić Milivoj, and whereby the adopted minor Miletić Mulivoje receives the new name Vasić Milan, is annulled as absolutely void. > > The defendant is ordered, immediately upon receipt of this judgment, to issue a decision annulling the decision of the Self-Managing Community of Interest for Social Welfare Novi Sad, no. UP.03-507/79 of 21 June 1979, authorizing a subsequent entry in the register of births of the particulars of adopters Vasić Milorad and Vasić Gospava, of Budisava, as the parents of the fully adopted child, the plaintiff in these proceedings, so that annulment of that decision restores the first birth registration of the fully adopted child, the plaintiff in these proceedings. ## Source page 2 > The defendant is ordered to reimburse the plaintiff in full for the costs of these civil proceedings, whatever their amount, together with statutory default interest from the date of enforceability until payment, all within 15 days from the date on which the judgment becomes final, under threat of compulsory enforcement.” **— is dismissed.**

The claim expressly requests the P.1106/82 divorce file and the hearing record of 20 September 1982. The linked file permits comparison of the earlier adults’ statements and court narrative with the plaintiff’s account of pre-existing marital violence, childhood beatings and loss of maintenance.

- **EVIDENCE:** examination of the plaintiff as a party to the proceedings; examination of the witness Ignjatić Vinka of Budisava, Petefi Šandora Street No. 168; examination of the witness Dragan Ignjatić of Budisava, Petefi Šandora Street No. 168; inspection of the file of the divorce proceedings of the adopters Milorad and Gospava Vasić before the Higher Court in Novi Sad, case No. P.1106/82; inspection of the enclosed hearing record of the Higher Court in Novi Sad in divorce case No. P.1106/82 of 20 September 1982 (attachment No. 10); inspection of the enclosed Record of Incomplete Adoption of the minor Vasić Milan by Periša and Gorgina Petrović, Centre for Social Work of Novi Sad, No. UP.02-987/84 of 26 September 1984, with Vasić Milorad's statement of consent to the adoption (attachment No. 11); that

The claim identifies Milorad Vasić’s consent statement with the later adoption record. The separately archived consent is dated 12 September 1984 and records no contact with the child since August 1983; it is distinct from the adoption act of 26 September. This provides a concrete earlier source for comparison with the plaintiff’s account of abandonment.

- **EVIDENCE:** examination of the plaintiff as a party to the proceedings; examination of the witness Ignjatić Vinka of Budisava, Petefi Šandora Street No. 168; examination of the witness Dragan Ignjatić of Budisava, Petefi Šandora Street No. 168; inspection of the file of the divorce proceedings of the adopters Milorad and Gospava Vasić before the Higher Court in Novi Sad, case No. P.1106/82; inspection of the enclosed hearing record of the Higher Court in Novi Sad in divorce case No. P.1106/82 of 20 September 1982 (attachment No. 10); inspection of the enclosed Record of Incomplete Adoption of the minor Vasić Milan by Periša and Gorgina Petrović, Centre for Social Work of Novi Sad, No. UP.02-987/84 of 26 September 1984, with Vasić Milorad's statement of consent to the adoption (attachment No. 11); that

The request identifies the claim filed on 22 February 2024. It maintains that the Higher Court has jurisdiction while also requesting urgent transfer to the Basic Court and a certified copy of the corrected ruling. Both positions are preserved; the submission does not prove completion of the requested steps.

Therefore, although the plaintiff's counsel remains of the view that the Higher Court in Novi Sad has subject-matter and territorial jurisdiction over this legal matter, for the reasons set out in detail in the statement of claim, she does not wish to exercise a right to which she is not entitled by law and have her appeal rightly dismissed as inadmissible by the Court of Appeal in Novi Sad. If an oversight were to occur and the appeal were nevertheless decided, the question would arise of the validity of such a decision, delivered on an appeal that could not properly be decided. Time is being lost, and it is extremely precious in this case. In any event, if the Basic Court in Novi Sad does not raise a conflict of jurisdiction, there is a legally permitted way to review its decision accepting jurisdiction.

The opening substantive paragraph expressly maintains all statements in the claim, the requests made against the Centre for Social Work, and the proposed and enclosed evidence. It links the December written position to the already catalogued statement of claim (Document 1), rather than treating it as a separate new claim or a court ruling on the existing claim.

I hereby declare that I maintain all the statements made in the claim and the requests I have set out in the proceedings against the defendant Centre for Social Work Novi Sad. I consider the stated grounds of the claim, as well as the proposed and enclosed evidence, to be of crucial importance for establishing the facts and reaching a decision in 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.

The claim invokes incomplete adoption record UP.02-987/84 of 26 September 1984 and recounts the change from Milan Vasić to Milan Petrović. The existing record identifies the second act in the same child’s trajectory. It does not settle the legality of the first adoption or create a second child.

- **EVIDENCE:** examination of the plaintiff as a party to the proceedings; examination of the witness Ignjatić Vinka of Budisava, Petefi Šandora Street No. 168; examination of the witness Dragan Ignjatić of Budisava, Petefi Šandora Street No. 168; inspection of the file of the divorce proceedings of the adopters Milorad and Gospava Vasić before the Higher Court in Novi Sad, case No. P.1106/82; inspection of the enclosed hearing record of the Higher Court in Novi Sad in divorce case No. P.1106/82 of 20 September 1982 (attachment No. 10); inspection of the enclosed Record of Incomplete Adoption of the minor Vasić Milan by Periša and Gorgina Petrović, Centre for Social Work of Novi Sad, No. UP.02-987/84 of 26 September 1984, with Vasić Milorad's statement of consent to the adoption (attachment No. 11); that

The existing timeline event opens the full public redacted claim. This source passage dates the power of attorney to 20 February 2024. The later Higher Court ruling P. 98/2024, page 1, confirms filing on 22 February 2024; the timeline now uses this exact date. The OCR reconstruction alone did not establish it.

- **EVIDENCE:** the original power of attorney for counsel dated 20 February 2024, signed by the principal, the plaintiff Milan Petrović.

The plaintiff expressly maintains his original action and claim, his own examination, the proposed neighbours’ testimony about conditions before adoption, and the divorce-record proposals. The linked full 2024 claim supplies the substantive allegations and documentary arguments to which those evidentiary requests relate. This hearing is a procedural continuation of that action.

The plaintiff states that he maintains his action and the claim made, and his evidentiary proposal that the witness **Vinka Ignjatić** of Budisava, Petefi Šandora 168, and her son **Dragan Ignjatić** be examined in these proceedings. They were neighbours of the late adopters Gospava and Milorad Vasić and are acquainted with the fact that their marriage was dysfunctional even before the full adoption. He maintains his proposal to be examined as a party. He maintains his evidentiary proposal to inspect the Higher Court record already attached to the file, from the hearing in the divorce litigation of his adopters Gospava and Milorad. He maintains the proposal to request inspection of the file in which the marriage was dissolved, **P.1106/82**. He withdraws his evidentiary proposal to obtain officially from the Budisava Health Centre the medical record and medical history of his late adoptive mother Gospava Vasić. He proposes that the defendant be ordered to supply the documentation explaining how he **“came under their jurisdiction”**. These are his evidentiary proposals. He particularly emphasizes that, although at the previous hearing the court gave him the period he himself requested — 30 days to state whether he maintained the proposed witnesses or not — he did not properly understand what he was required to do. He therefore identified only Vinka Ignjatić of Budisava as a witness in his submission dated 10.03.2025, and at today’s hearing has stated that he also maintains the other proposed witnesses.

The closing record generally withdraws other evidence proposals while maintaining the action and all assertions. The earlier claim through counsel expressly proposed examination of Vinka and Dragan Ignjatić; the March record maintained those proposals. This connection identifies their earlier source without inventing a named witness-rejection decision in the final hearing record.

The plaintiff states that he maintains the action and the claim as formulated, all assertions and all submissions. He has no further evidence proposals. He proposes that the hearing be closed. He withdraws all other evidence proposals that may have been made. He expressly states that he maintains all assertions made thus far, both orally and in writing.