… TO THE PRESIDENCY OF THE HIGH CRIMINAL COURT
CASE NO:
REQUEST FOR RELEASE/DISMISSAL:
DEFENDANT:
PROSECUTOR:
CRIME: Establishing a criminal organization, being a member of an organization, engaging in drug trafficking within the framework of the organization’s activities.
DATE OF CRIME: …/…/…
SUBJECT: Requests the release of the defendant.
EXPLANATIONS
We request the release of the defendant for the following reasons:
1- Despite learning that an arrest warrant had been issued against him during the investigation phase, the defendant voluntarily surrendered; this forms the subject matter of the case. This situation demonstrates that the defendant had no intention of fleeing due to his actions and that he intended to seek justice.
2- The defendant has a specific place of employment and residence. The mayor’s certificate we have submitted as an attachment also proves his place of residence. Similarly, my client works in traffic control in the city where he lives, and his continued detention would disrupt his work environment and cause difficulties in his job. His surrender is also a guarantee that he will not flee.
3- All evidence has been collected from the file, and witnesses and other defendants have been heard. There is no evidence to be gathered against him. Furthermore, we would like to state that we will present evidence in your favor during the trial.
4- The defendant has no connection or relationship with any organization. As we can see when reviewing the file, making a few phone calls does not mean being a member of an organization, and this situation is contrary to justice. In other words, there is a high probability that the charges against him will be changed.
CONCLUSION: For the reasons stated above, we request that the defendant be released without any guarantee or with the necessary guarantee and bail. …/…/…
ATTACHMENT: 1- Residence certificate obtained from the village headman.
2- SSK certificate showing that the defendant is employed.