Vera Radovanović dossier 3871/79 — father when useful, unknown when identity is at stake

Maja Petrović’s response expressly distinguishes adoption-establishment records from earlier family-law-protection files explaining how the plaintiff came under the Centre’s authority. The linked 3871/79 dossier contains actual pre-adoption placement documentation and work notes, including the conflicting April 1979 descriptions of the father. It supplies directly inspectable earlier records for the plaintiff’s requested administrative history.

Responding to the foregoing, the defendant’s representative states that, concerning the complete documentation of his adoption by Gospava and Milorad Vasić and requiring the defendant to supply it, **we do not oppose supplying files concerning the establishment of the full adoption, but we oppose supplying files involving the application of family-law-protection measures before the full adoption was established**, or, as the plaintiff requested, supplying **“how he came under our jurisdiction”**, because this would burden the proceedings in question and the relevance of such files to these proceedings is in question.

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**.

Vera’s April 1979 notes name Pal Lakatoš as the man who raised the child and presented himself as the natural father, then refer to the natural father’s death; the placement contract leaves the father field blank. The 1977 judgment records Pavle’s child with Miletić Cvita and care by Kopljan Roža. This is the specific father-line comparison behind the existing relation.

... from 1968 onward, the plaintiff took over the economic management connected with the grain mill, while the defendant cultivated land about 4 km from Novi Sad. They completely separated their assets and behaved toward one another as though they were strangers (the plaintiff sold bran to the defendant, sold him meat, etc.). The defendant came home very rarely; in the final years the plaintiff did not cook for him, nor wash for him, so he organized all of this on the land, building a hut of wattle and mud, unsuitable for winter habitation. In recent years, the plaintiff did not even allow the defendant into the house, and he slept in the stable when he came from Bački Vinogradi. From the compensation for the expropriated land, the defendant bought two jutro of vineyard and a house in Bački Vinogradi, where he engages in fruit growing, mainly by leasing out the orchard, because he is ill and a serious heart patient. After the first hospitalization, because of heart disease, abandoned and without visits, while his brother managed the cultivation of the land, he began living with the laborer Miletić Cvita, with whom he also fathered a child. This child is being cared for by the parties' daughter, Kopljan Roža, for which the defendant pays 1,000 dinars per month and also provides foodstuffs.

The court uses the mother’s recorded unknown whereabouts and unsuccessful searching years later to conclude she was unavailable for consent in 1979. The contemporary protective dossier records the mother, insurance through her and an address on the reverse of the personal sheet. It supplies the earlier evidentiary context for that inference.

proceedings and the plaintiff’s own testimony show that, after that decision was set aside, a new decision was issued which did not establish that status, although the court had sought information from the guardianship body. Therefore, it could not in any event be considered that, when the full adoption was established on 21 June 1979, the plaintiff had a living or known father. On the other hand, in the adoption proceedings the guardianship body recorded that the plaintiff’s mother had for a long time been at an unknown place of residence. In his testimony the plaintiff stated that he had seen his mother several times in childhood and never thereafter, and that he had lived with the late Pavle until his death. From that it follows that the plaintiff’s mother could not have been available to the guardianship body to consent to adoption. This is also supported by the circumstance that even years later the guardianship body could not find any information about the plaintiff’s mother. Thus the plaintiff’s grounds of appeal alleging that it is unclear whether his case was brought under paragraph 1 or paragraph 4 of the cited provision are not acceptable, bearing in mind that, in the situation described, the conditions for adoption relating to the status of the plaintiff’s parents were in any event met. The first-instance court correctly finds that the guardianship body established fulfilment of all the other conditions necessary for full adoption, which also concern assessment of the prospective adopters by professionals—an educational specialist, psychologist, social worker and doctor. This court finds no inconsistencies in their findings, and the grounds of appeal advanced in that respect are not acceptable.

The judgment reproduces the mother’s allegedly unknown residence, Vera’s appointment and her consent to full adoption. The earlier casework dossier records information about the parents, health insurance through the mother and her later stated address. The connection permits the particular parental information to be compared with the general assertions relied on in the judgment.

That the full-adoption hearing had been scheduled at the request of Vasić Milorad and Vasić Gospava, of Budisava, as adopters, for the full adoption of the minor Miletić Milivoj, in accordance with Article 30 of the Law on Adoption (“Official Gazette of SAP Vojvodina”, no. 24/76); that, in the preliminary proceedings, the guardianship authority had established that all statutory conditions for full adoption were met, and that the adoption complied with Articles 2 and 4 of the Law on Adoption; that the mother of the minor Miletić Milivoj had been at an unknown place of residence for a considerable time and, without justified reasons, was not performing her parental duty, so that, for those reasons and pursuant to Article 5 of the Law on Adoption, the minor Miletić Milivoj had, by decision no. Ur.03-506/79 of **20 June 1979**, been assigned an ad hoc guardian in the person of Radovanović Vera, a social worker who gave consent to this adoption; that it had been established that there were no impediments under Articles 10 and 11 and that a positive opinion under Article 15 of the Law on Adoption had been given; that the adopters agreed that the adoptee should inherit any property they might have and exercise all rights under Article 36 of the Law on Adoption; that, having been informed of Article 40 of that same law, the adopters expressed the wish that the adoptee bear their family name and be called Vasić Milan; that, all statutory conditions for full adoption having been met, the guardianship authority declared that full adoption was established whereby Vasić Milorad and Gospava, both residing in Budisava, Petefi Šandora Street no. 52, adopted the minor Miletić Milivoj; that the adopted minor Miletić Milivoje would henceforth be called Vasić Milan; and that the guardianship authority would deliver a report of the full adoption to the competent registrar for entry of the adopters’ particulars as the parents of the minor Miletić Milivoj.

Annex 2 contains four of Vera Radovanović’s handwritten monitoring sheets and the author’s accompanying transcription. The existing full dossier supplies their wider context, including the personal-record reverse and maternal details.

## Source page 63 # ANNEX 2 ### Vera Radovanović’s handwriting — monitoring sheet no. 3871/79 and reconstruction of the text This annex contains documentation concerning social worker Vera Radovanović’s handwriting in the case of Miletić Milivoj, no. 3871/79: - photocopies of the original handwriting come first — the monitoring sheet and other handwritten notes concerning this case; - then, on the following pages, comes the typed text: a reconstruction of what the handwriting says, prepared following OCR analysis using Google Gemini, with notes where the original is difficult to read or partly unclear. The text is reconstructed so that: - it does not change the contents of the handwriting; - it merely clarifies exactly what the handwritten passages say; - technical notes, such as “[illegible]” or “[probably reads…]”, are clearly marked as such. This annex allows the Court to compare the original handwriting directly with the clear transcription and follow, without difficulty, the vocabulary, characterizations and way the social worker handled the case.

The linked dossier supplies the historical record for the revision’s allegation that Vera Radovanović combined narrative-building, recommendations, guardianship and consent. Her recorded acts and the author’s conflict-of-interest conclusion are distinguished.

The files show that Vera Radovanović: - participated in shaping the narrative about the plaintiff’s mother; - participated in relativising Pavle Lakatoš’s paternal line; - maintained and prepared the case documentation; - recommended the particular adopters specifically for the minor Milivoj Miletić; - was appointed ad hoc guardian to consent to full adoption; - consented to full adoption; - then reappeared in 1984 in a new cycle of institutional removal and a new adoption of the same child. In his appeal, the plaintiff clearly explained why assessing this concentration of roles in one person is decisive: the same official could not simultaneously: - build the case; - create the factual narrative; - recommend particular adopters; - assume the role of protector of the child’s interests; - and then consent to the outcome she herself had previously prepared, which proved wrong and contrary to the child’s best interests. The Court of Appeal did not assess these arguments, did not say that they were irrelevant to a correct and lawful decision, and did not consider them in any way. It completely disregarded them. It did not call the argument immaterial. It did not reject it. Such failure to assess the grounds of appeal violates Article 396(1) CPA and renders the second-instance judgment unlawful. ### 6. The second-instance court did not genuinely answer the ground of appeal concerning the guardianship authority’s competence The plaintiff’s appeal did not challenge in the abstract that the Self-Managing Community of Interest for Social Protection in Novi Sad could have had certain powers as a guardianship authority under a general decision from 1977. The plaintiff challenged: - by which specific act that authority acquired competence over the minor Milivoj Miletić before 21 June 1979; - when that competence was established; - on what facts; - how this fits with the Municipal Court in Novi Sad’s letter of 20 July 1979 directing the Secretariat for Veterans’ and Disability Affairs and Social Protection, as guardianship authority, to appoint a guardian to protect the rights and interests of the minor Milivoj Miletić in the probate proceedings after Pavle Lakatoš’s death.

The SIZ dossier records Pal’s role in raising Milivoj and mentions the natural father’s death while leaving the formal father field blank. The probate minutes separately record Helena Uzelac’s statement that the deceased acknowledged Milivoj and her request for a guardian; the ruling awards Milivoj a one-quarter share. The relation compares the dossier’s father trail with Milivoj’s recorded position in the probate file.

Attorney Helena Uzelac states that, besides the reported heirs, there is also the minor Milivoj Miletić, aged 5, for whom it has not been judicially established that the deceased was his father, but the deceased did acknowledge him, and the minor Milivoj is currently with his grandmother and grandfather, that is, with the parents of the deceased. Therefore, in accordance with that, it should be obtained from the Centre for Social Work that a guardian be appointed for the protection of his interests.

The appeal questions Vera Radovanović’s monitoring and case narrative, especially value judgments about Cvita based on neighbour consultation, alongside entries that describe a cared-for child. The relation opens the actual monitoring file for comparison.

The court was required to explain how a new adoption in 1984 was possible if a valid full adoption already existed in 1979, one that could not be dissolved under the law then in force. By failing to do so, it failed to apply substantive law to a decisive fact that directly undermines the conclusion that the first adoption was lawful. #### 4. Wrongly reducing the dispute to a mere family-law framework The court treated the case as a typical family dispute, although it is a dispute against the guardianship body concerning the lawfulness of its historical and present conduct, identity, origins, inheritance status and the consequences of an administrative change of identity. The first-instance court thereby wrongly marginalised the identity dimension of the dispute, although precisely that dimension determines a proper understanding of the legal significance of the contested adoption and the subsequent institutional maintenance of its consequences. ### VI. INCORRECT ASSESSMENT OF EVIDENCE The first-instance court did not critically assess the contents of the archive documentation. Instead, it effectively equated its formal authenticity and official provenance with the truth of its contents and the lawfulness of the conduct of the body that created it. It accepted particularly uncritically the documents created by the very body whose conduct is contested. Nor did the first-instance court critically assess the fact that the defendant’s internal documentation contains a degrading narrative permeated with value judgments and sex-based and cultural prejudices about my biological mother. Instead, it effectively accepted that content without genuine legal and evidentiary scrutiny. It thereby did more than uncritically adopt the defendant’s internal documentation: it indirectly provided a legitimising framework for descriptions contaminated by value judgments that could not be treated as a neutral and reliable basis for judicial conclusions. The contradictions and problems concerning the following were not properly assessed: - the monitoring sheet of contacts and casework; - social worker Vera Radovanović’s report; - formulaic and mutually inconsistent professional assessments; - moral characterisations of the mother based on “consultation with neighbours”, without a serious evidentiary basis; - the fact that CSR’s own internal documentation confirms in several places that the child was well cared for, tidy, staying with paternal relatives and undergoing accelerated psychological preparation for an identity change. In other words, the court did not compare and weigh conflicting evidence, but privileged the defendant’s internal documentation in advance. ### VII. DECISION ON COSTS I also challenge the decision that each party is to bear its own costs.