TO THE PRESIDIUM OF THE HEAVY CRIMINAL COURT
FILE NO : …/… E.
DEFENDANT :
THE DEFENDER :
SUBJECT : … This is our Appeal against the Decision of the Criminal Court on the Continuation of /…// daily Detention.
INSTRUCTIONS :
1-) At the hearing held on the date of the public case filed for the crime of your Court with file E about our client, it was decided that our client would be arrested.
2-) Our client is the owner of a fixed settlement, as well as the house in which he lives belongs to him. In addition, it belongs to our client and is personally operated by him ….. …. …… …./….. at the address ….. ….. our client, who has a company, has not been involved in any crime so far and has no record of foul play in the criminal record. It is obvious that there is no suspicion of escape.
3-) Although there is no other accomplice of our client, who is a suspect in the relevant crime alone, who is in a suspicious position; All the evidence related to the crime has been collected and stored. For this reason, our client is also not suspected of obscuring the evidence.
4-) The witnesses also gave their statements both in law enforcement and to the Public Prosecutor’s Office during the preparatory investigation.
5-) Considering the nature and elements of the crime and in any case according to the contents of the file, there is no reason to decide on the continuation of the detention given about our client with a fixed residence who has no criminal record.
CONCLUSION AND REQUEST: … We respectfully request on behalf of our client that the decision on the release of our client be decided with the acceptance of our appeal against the decision of the Criminal Court on the continuation of /…// day detention. …/…/…
Defender of the Defendant
