TO THE PRESIDENT OF THE HIGH CRIMINAL COURT
FILE NO.: …/… E.
DEFENDANT:
DEFENSE COUNSEL:
SUBJECT: This is our appeal against the decision of the Criminal Court of … to continue the daily detention of …
INSTRUCTIONS:
1-) At the hearing held on the date when the public case filed by your court against our client for the crime with file number E was opened, it was decided to arrest our client.
2-) Our client is the owner of a permanent residence, and the residence in which he lives belongs to him. In addition, our client owns a company, which he personally operates at the address ….. …. …… …./….. Our client has not been involved in any crime to date, and there is no record of any crime in his criminal record. It is clear that there is no suspicion of flight.
3-) Our client is the sole suspect in the relevant crime, and there is no other accomplice in the suspect position; all evidence related to the crime has been collected and preserved. Therefore, there is no suspicion that our client will tamper with the evidence.
4-) The witnesses also gave statements during the preliminary investigation, both to the law enforcement authorities and to the Public Prosecutor’s Office.
5-) Considering the nature and elements of the crime, and in any case based on the contents of the file, there is no situation that would require a decision to continue the detention of our client, who has no criminal record and is a permanent resident.
CONCLUSION AND REQUEST: … Upon acceptance of our appeal against the Criminal Court’s decision of …// to continue detention, we respectfully request that our client be released on behalf of our client. …/…/…
Defense of the Defendants