Expanded submission to the State Office for Immigration (Landesamt für Einwanderung) after access to the file and presentation of the expert report

Großbeeren, 8 July 2026 — To the Berlin State Office for Immigration (Landesamt für Einwanderung Berlin), Friedrich-Krause-Ufer 24, 13353 Berlin (by fax: +49 30 90283480). Geschäftszeichen: R 4411 - 092080437849

I hereby make supplementary representations concerning your letter of 18.06.2026. Following access to the immigration file, the letter gives me three weeks for an expanded submission on the intended expulsion. I request written confirmation of receipt of the submission and annexes, particularly the enclosed expert report.

This submission supplements my submission of 19.05.2026, already transmitted within the time limit and, according to the fax transmission report available to me, successfully transmitted to the same fax number.

I. Clarification: not a matter of mere non-renewal

As a precaution, I clarify that my residence status must not be treated as though the matter concerned only non-renewal of a temporary residence permit. I have lived in Germany since 1992. Given my admission as a Jewish quota refugee from the former USSR and the permanent residence status granted to me, my right of residence is not simply a visa requiring regular renewal.

An indefinite residence status or one granted on a permanent basis does not cease merely because an authority does not renew it. A legally sustainable procedure can at most concern an expulsion with expressly stated reasons, and only under the statutory conditions and after a full assessment of the individual case.

II. Presentation of an expert report

As Annex 1 I submit the scientific and practical expert report of the Internationale Assoziation „Institut für nationale Politik“ (International Association “Institute for National Policy”), Dok.-Nr. IA-INP/SG-2026-001, Kyjiw, dated 02.07.2026 (151 pages including Annexes A1–A7).

The report examines the individual risk assessment in the event of expulsion or any other State measure that could lead to my transfer under the jurisdiction of the Russian Federation. Particular emphasis must be placed on the expert findings that my case must not be assessed as an ordinary return case: the report relies on several cumulative individual risk factors — my public visibility as an activist critical of the regime, my connection with UnKremlin e.V.A registered organisation of anti-Putin activists founded by Dmitry Bagrash (VR 39791 B, Berlin). On 1 September 2023 it was designated an “undesirable organisation” by the Russian Prosecutor General’s Office., mention of that organisation in official statements by the Russian OSCE delegation, and international and Russian media coverage.

III. Minimum human rights requirements and non-refoulement

Any measure that could lead to my transfer to the Russian Federation must be assessed against the principle of non-refoulement, Art. 3 EMRK, Art. 19 Abs. 2 GRCh, Art. 33 GFK, Art. 3 CAT, and §§ 60 Abs. 5 and 60 Abs. 7 AufenthG. Protection against torture and inhuman or degrading treatment is absolute. An individualised, source-bound risk assessment is required.

IV. Documentation and safeguarding access

Because of the difficulties I have already documented in accessing post, records and legal protection, I immediately preserve all incoming and outgoing correspondence with authorities and courts.

V. Requests

• Refrain from the intended expulsion
• Place the full expert report on the immigration file and expressly assess it before any decision
• Clarify that the residence status is not treated as merely requiring renewal
• Fully establish the protection and residence status existing since 1992
• Carry out an independent individualised risk assessment concerning the Russian Federation
• Take no measure that could lead to transfer under the jurisdiction of the Russian Federation
• Confirm in writing receipt of the letter, expert report and transmission report