I write a supplement to the LG (Regional Court) concerning the above-mentioned

To Landgericht Berlin I (Berlin Regional Court I), Turmstr. 91, 10559 Berlin. From Bagrash, Dmitry, JVA Moabit (Moabit Prison; register no. 2796/22/6), Alt-Moabit 12a, 10559 Berlin. Re: case reference (522 Ks) 176 Js 4/22 (5/23). Berlin, 11.12.24.

Dear Sir or Madam, I hereby wish to supplement my application for a court decision of 10.12.24.

28.11.24 was the final day for submitting grounds for the appeal on points of law (Revision). My defence counsel, lawyer Römer, did so in time. However, I received the copy of the submitted grounds only on 06.12.24. I wish and need to submit my supplement to the grounds for the appeal under § 345 StPO.

I agree with the grounds submitted, but must supplement them because there is a decisive, inexplicable contradiction between the content of the case file and the grounds of the judgment under § 337 StPO. The trial judge did not fulfil his duty to assess the evidence exhaustively. The assessment of the evidence is also flawed because principles derived from experience were not taken into account.

The judgment contains contradictory and insufficient findings of fact. I will therefore also request my acquittal in my supplement and give reasons for that request; as a precaution, I will request that the case be remitted to another criminal chamber of the Regional Court for a new hearing and decision.

I hereby inform the court that, from the beginning of September 2024 to date, I have no longer had any contact with my defence counsel, lawyer Römer — either in writing or orally. Moreover, on 12.09.24 the Presiding Judge at the Regional Court, Mr Groß, ordered the discharge of my previous defence counsel, lawyer Mumm and lawyer Jochmann, from their duties. I was therefore unable to supplement the content of the grounds earlier.

Since I am able to submit a detailed supplement for recording by the court registry within a maximum of one month, I hereby apply for permission (an extension of the deadline). This will enable me to exercise my rights in the appeal on points of law.

I further apply to be granted access to the case file. This will enable me to show the court hearing the appeal on points of law exactly where the above-mentioned violations of the law lie. Otherwise, I can only name witnesses or experts, which makes that court’s work substantially more difficult, because it may (but need not) take the content of the case file into account when examining the complaint of substantive legal error (Sachrüge).

Yours faithfully, Dmitry Bagrash.