Application submitted to Bundesgerichtshof (Federal Court of Justice; BGH):

Dmitry Bagrash, Alt-Moabit 12a, 10559 Berlin — To the Bundesgerichtshof, Karl-Heine-Straße 12, 04229 Leipzig. Berlin, 17.02.2025. Case reference: (522 Ks) 176 Js 4/22 (5/23) — Landgericht Berlin (Berlin Regional Court).

Subject: Application for inclusion of a supplement to the grounds for the appeal on points of law in the proceedings and a finding that written submissions by an unauthorised lawyer have no effect.

I. Submission of the supplement to the grounds for the appeal on points of law and difficulties caused by the court

My supplement to the grounds for the appeal on points of law was submitted on 20 January 2025 under § 345 Abs. 2 StPO for recording by the court registry. Despite repeated reminders, I have not yet received confirmation of receipt. VRiLG Groß also substantially hindered the submission process, which constitutes a violation of the right to a fair trial under Art. 6 Abs. 1 EMRK.

II. Withdrawal of the previous lawyer’s power of attorney and lack of access to the case file

I have had no contact with my previous lawyer Bernd Römer since September 2024. On 16 December 2024 I withdrew his power of attorney in writing. I also applied to the competent court on 17 December 2024 for the lawyer to be discharged from his duties as defence counsel (§ 143a StPO); no decision on this has been made to date. I have still not been granted access to the case file, although this is necessary to prepare comprehensive grounds for the appeal on points of law under § 147 Abs. 7 StPO.

III. Lack of effect of submissions by the lawyer whose authority has been withdrawn

I request that all written submissions filed by lawyer Bernd Römer after 16 December 2024 be treated as invalid, as he has been acting without my power of attorney since that date (§ 138 Abs. 1 StPO).

IV. Difficulties caused by the court and the prosecution

VRiLG Groß and OStA Wachs substantially obstructed the submission of my supplement to the grounds for the appeal on points of law and my search for a new lawyer.

V. Requests

1. Confirmation of receipt of this letter and notification of the case reference for the appeal on points of law. 2. Inclusion of my supplement to the grounds for the appeal in the proceedings. 3. A finding that all documents submitted by lawyer Bernd Römer after 16 December 2024 have no effect. 4. An order granting access to the case file under § 147 Abs. 7 StPO. 5. Examination of a possible violation under § 308 StPO.

I inform you that the second part of my supplement to the grounds for the appeal on points of law will be submitted within the next ten days for recording by the court registry.

Yours sincerely, Dmitry Bagrash