Deposition to the Court

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… To His Honor, the president of the Civil Court of the Seine.

Mr. Leon Sedov, known as Trotsky, who is a writer by profession and who resides in the country of Mexico …

Having Mr. Malinvaud as counsel,

Has the honor to inform you:

- That his daughter Zinaida married Mr. Platon Volkov, and that from their marriage issued a child, Vsievolod Volkov, born in Leningrad (Russia) in March 1926;

- That his daughter Zinaida died in Berlin in January 1933, and that his son-in-law Platon Volkov disappeared in Russia;

- That the petitioner is the maternal grandfather and sole surviving relative of the minor Vsievolod Volkov;

- That the custody of the child was assumed by another son of the petitioner, Mr. Leon Sedov, who resided in Paris at 26 rue Lacretelle until his death on 16 February 1938;

- That the petitioner desires, as maternal grandfather and sole surviving relative, to assume custody of the child Vsievolod Volkov, and that while waiting for a determination of the personal status of the child and the rulings applicable for the organization of his guardianship, he may have recourse to temporary emergency measures by which the person and property of the child may be immediately placed in his care.

- For these reasons, the petitioner requests, if it may please the Court, to appoint any administrator it may deem proper over the person and property of -the child Vsievolod Volkov, grandson of the petitioner…