Observations submitted within the time limit to the Landesamt für Einwanderung (State Office for Immigration) opposing the intended expulsion

Observations in the procedure allowing representations concerning the intended expulsion

Großbeeren, 19 May 2026 — To the Landesamt für Einwanderung Berlin, Friedrich-Krause-Ufer 24, 13353 Berlin (by fax). Reference: the State Office’s letter of 27.04.2026 (case reference R 4411–092080437849), received on 30.04.2026. Copy for documentation to the press, parliamentary bodies and the Federal Republic of Germany’s OSZE (OSCE) delegation.

Requests: (1) to abandon the intended expulsion; (2) in the alternative, to fully investigate all asylum, refugee, human-rights and family circumstances; (3) to establish that deportation to the Russian Federation is ruled out by the specific risk of political persecution, my protection status, my long-standing roots in Germany, and Art. 3 and Art. 8 EMRK; (4) to grant access to the file; (5) to acknowledge receipt in writing.

Risk of political persecution (§ 60 Abs. 1 AufenthG, Art. 33 GFK)

The Russian OSZE special representative Lukaschewitsch expressly mentioned UnKremlin e.V.Registered anti-Putin activist organisation founded by Dmitry Bagrash (VR 39791 B, Berlin). Designated an “undesirable organisation” by the Russian Prosecutor General’s Office on 1 September 2023. in two official statements before the OSZE Permanent Council (document No. 499588 of 24.09.2021 and No. 519702 of 08.04.2022) — the latter refers to “Russophobic views” and the publication of addresses of Russian journalists. On 1 September 2023 the Russian Prosecutor General’s Office designated UnKremlin e.V. an “undesirable organisation” (Art. 284.1 StGB RF — imprisonment of up to 6 years for organisation leaders). Deportation would therefore amount to delivering myself into criminal prosecution.

Right to respect for private and family life (Art. 8 EMRK)

I have lived in Germany since 1992 and have a son with whom I maintain close, regular contact — according to the sentence and integration plan of 17.04.2026 several hours of telephone contact every day.

Protection status and Jewish origin

I was admitted in 1992 as a Jewish quota refugee from the former Soviet Union and hold a permanent residence permit together with recognised refugee status (§ 51 AufenthG).

The sentence plan as an impermissible use of legal defence against me

The sentence and integration plan of JVA Moabit (Moabit prison) of 17.04.2026 expressly assesses my criticism of the justice system, my failure to admit guilt and my announcement of further protests negatively. The State Office’s letter inviting representations is dated three days after the sentence plan was issued and one day before my application for a judicial decision against the sentence plan — a coincidence in timing that, in my view, requires explanation.

Absence of a practical possibility of deportation (§ 60a Abs. 2 AufenthG)

My Russian passport expired on 16.05.2024. Appearing before Russian consular authorities to renew it would involve a specific risk in view of my organisation’s designation as “undesirable”.

The annexes included, among other documents: the State Office’s letter of 27.04.2026, the sentence and integration plan, the application challenging the sentence plan, the OSZE documents No. 499588/519702, the Sergey Feoktistov dossier and the press release on Case 0.