Declaration in lieu of oath (failure to provide medical care + threat/suspicion of provocation) sent to media/justice administration
On 27.10.2025 I prepared a declaration in lieu of oath and sent it by email to the press, the Berlin Senate Department for Justice (Senatsverwaltung für Justiz Berlin) and selected journalists. In it I document that at Heidering correctional facility (JVA Heidering), despite repeated urgent applications (20.–26.10.2025) concerning severe, persistent abdominal pain, I was effectively not given timely access to medical care. I additionally describe the context of earlier and renewed threats/defamation by the prisoner “Pavlo S.” (previously at JVA Moabit, later again at JVA Heidering), and the resulting suspicion of deliberate provocation in connection with my submissions to the media and international bodies; delayed/prevented access to legal remedies through the court clerk (Gerichtsschreiber) is also addressed again. (Annex 81_F2 / evidence)
Dmitry Bagrash, JVA Heidering, Ernst-Stargardt-Allee 1, 14979 Großbeeren. Declaration in lieu of oath (§ 294 Abs. 1 ZPO; §§ 156, 163 StGB).
I, Dmitry Bagrash, currently held at JVA Heidering, hereby affirm in lieu of oath as follows:
Facts
20.10.2025 (approximately 08:00, workshop no. 3): During work I approached a security officer at JVA Heidering, described acute abdominal pain and requested access to a doctor. The officer replied that he could send me to my cell, where I should make a written application.
21.10.2025: I wrote an application concerning acute abdominal pain and handed it to the guard in building 1, expressly stressing the urgency. There was no response.
24.10.2025, 07:10: I again made an application to the doctor, handed it to the guard and stressed the urgent and acute nature of the symptoms.
24.10.2025, 11:30 (workshop no. 3): I told a guard that I had unbearable abdominal pain, had already made two applications without any response and again requested access to a doctor. The guard said that he could do nothing and advised me to make another written application.
25.–26.10.2025 (weekend): As a result I suffered extremely severe abdominal pain throughout the weekend and could take no action.
For context — earlier events and provocations: I have worked in workshop no. 3 since 04.08.2025 without infringements or complaints. In mid-October 2025 the prisoner Pavlo S. appeared there. There had already been a conflict at Moabit Prison (JVA Moabit): on 24.07.2024 (8:00, the day the judgment was pronounced), in the presence of around 40 people in the courtyard before German classes, Pavlo S. loudly stated that he knew I was imprisoned for paedophilia and called for me to be killed; guards were also present. He continued to spread this defamation among other prisoners. I immediately informed JVA Moabit’s management orally and in writing; there was no response. For 10 days I was denied access to the court clerk to file a criminal complaint. After threatening a hunger strike, I was able after 10 days to prepare a complaint through the court clerk. The first formal response came only after 4 months. The witnesses I named were questioned by neither the public prosecutor nor the police. The proceedings were discontinued on the grounds that Pavlo S. had refused to testify. Until mid-March 2025, despite my submissions, Pavlo S. worked distributing food on my floor at JVA Moabit. In view of these circumstances I did not leave my cell for my own protection (even for exercise) until 10.06.2025, when I was transferred to JVA Heidering.
Renewed threat at JVA Heidering: Following my substantiated criticism of the Prosecutor General’s Office (Generalstaatsanwaltschaft) and the Heidering facility management for obstructing my access to justice, the prisoner Pavlo S. again appeared near me and threatened me with death without witnesses. To my knowledge, Pavlo S. was sentenced to 10 years’ imprisonment for murder in summer 2024. In view of the open nature of this letter, I disclose no further personal data concerning third parties.
Assessment of the events: Taking the above facts into account, I suspect an organised provocation against me in connection with my submissions to the media and the European Court of Human Rights (EGMR), which displease the Generalstaatsanwaltschaft and Berlin Justice Senate (Justizsenat Berlin). In my view, the denial of access to medical care and the court clerk, and the provocations, cannot be attributable solely to individual acts by guards, but only to direct instructions from the Justice Senate or the Generalstaatsanwaltschaft.
Clarification concerning my conduct: I declare that I have never possessed prohibited items in my cell, have consumed no prohibited or narcotic substances and have never disrupted prison operations.
Affirmation in lieu of oath: I affirm in lieu of oath that the above statements are true and were made to the best of my knowledge and belief. I am aware that false declarations in lieu of oath under § 156 StGB and false declarations in lieu of oath before an authority competent to receive them under § 163 StGB are punishable.
Place/date: Großbeeren, 27.10.2025. Signature: Dmitry Bagrash / Дмитрий Баграш, JVA Heidering.
Gmail — dispatch evidence: “Transmission — declaration in lieu of oath and documents (27.10.2025)”.
Note: This evidence exists only as a poorly legible screenshot export (limited OCR quality); its essential content — emailing the declaration in lieu of oath to the press, Senatsverwaltung für Justiz and journalists on 27.10.2025 — already follows from the subject and the text above. Please consult the Drive link for the original.
Comment — assessment by Dmitry Bagrash
This declaration connects two strands that later converge: the medical treatment not provided and the threats from a fellow prisoner. The second strand is tracked as a separate series in the chronology; the report of danger was therefore on file by October 2025 at the latest — eight months before the spatial proximity in June 2026.
Document source
Annex 81_F2 (declaration in lieu of oath of 27.10.2025): Anlage_81_F2.pdf
Evidence of email dispatch: Anlage_81_F2_Mail.pdf (limited OCR quality)