TO THE PRESIDENCY OF THE HIGH CRIMINAL COURT
BASIC NO:
REQUESTING DECISION OF RELEASE/DEFINANT:
ADVOCATE:
PLAINTIFF:
CRIME: Establishing a criminal organization, being a member of an organization, dealing in drugs within the framework of organizational activity.
HISTORY OF CRIME: …/…/…
SUBJECT: It includes the request for the release of the accused.
DESCRIPTIONS
We request the release of the accused for the following reasons;
1- The accused surrendered voluntarily, although he learned that an arrest warrant had been issued for him during the investigation phase, which was the subject of the case. This shows that he has no intention of escaping due to his behavior and that he intends to find justice.
2- The accused has a certain place of work and residence. The mukhtar’s certificate we provide in the appendix also proves the residence address. Likewise, my client works in the traffic monitoring business in the city where he lives, and if he continues to be detained, it will lead to a decrease in his environment and difficulty in his job. His surrender is also a guarantee that he will not escape.
3- All the evidences were collected from the file and the witnesses and other defendants were also heard. There is no evidence to be gathered against him. We also state that we will present the evidence in favor of you at the trial stage.
4- The accused has no affiliation or connection with any organization. As we can see when we examine the file, we can see that making a few phone calls does not mean membership in the organization, and seeing it is not in accordance with equity. In other words, there is a high probability that the accusation against him will change.
CONCLUSION: Due to the reasons stated above, we request the release of the accused without security or with the necessary security and bail. …/…/…
APPENDIX: 1- Residence certificate from the headman.
2- SSK document showing that the accused is working.
ATTORNEY’S ATTORNEY
