Application to the BGH (Federal Court of Justice) for an interim order concerning systematic refusal to record submissions

Dmitry Bagrash, Alt-Moabit 12a, 10559 Berlin — To the Bundesgerichtshof, Karl-Heine-Straße 12, 04229 Leipzig. Berlin, 13.03.2025.

Subject: Application for an interim order and acceptance of Parts 3 and 4 of the supplements to the grounds for the appeal on points of law, together with a complaint about repeated refusal to record submissions (522 Ks 5/23; 176 Js 4/22).

Dear Sir or Madam, on 12.03.2025 and on 13.03.2025 I made applications subject to a deadline under §§ 344, 345 StPO to the court registry officers at JVA Moabit to supplement my grounds for the appeal on points of law. Unfortunately, there has been no response to date. As early as 15.01.2025, a registry officer at Amtsgericht Tiergarten (Tiergarten Local Court) refused to accept my supplement to the appeal on points of law, referring to direct instructions from superiors. Likewise, on 24.02.2025 my request to record an immediate complaint (sofortige Beschwerde) against a decision of Kammergericht Berlin (Berlin Higher Regional Court) was refused.

I call upon JVA Moabit to accept all my supplements to the grounds for the appeal on points of law — in particular Parts 3 and 4 — without delay. I also request provisional inclusion of the already submitted Parts 1 and 2 in my appeal proceedings. Since I have been denied access to the case file to date, I cannot check whether the arbitrary interruptions of my final statement by Groß, Presiding Judge at the Landgericht (Regional Court) (VRiLG), and Senior Public Prosecutor Wachs (OStA) were noted in the verbatim record; I therefore request that the accredited journalists be summoned as witnesses.

I apply for an interim order under § 32 BVerfGG to ensure immediate acceptance of Parts 3 and 4 of my supplements to the grounds for the appeal on points of law.

Requests

1. Acknowledgement of receipt under § 37 StPO for Parts 1 and 2. 2. Inclusion of these supplements in my appeal on points of law proceedings. 3. A finding that submissions by a lawyer who is no longer authorised have no effect after 16.12.2024. 4. An order for a uniform approach to future supplements. 5. Forwarding to the competent court under § 17a Abs. 2 GVG if the BGH lacks jurisdiction.

Postscript: On 14.03.2025 I was again refused acceptance of my supplement to the grounds for the appeal on points of law at the Tiergarten registry officers’ service on the pretext of expired deadlines (see declaration in lieu of oath of 14.03.2025, F2-035).

Yours sincerely, Dmitry Bagrash