… TO THE OFFICE OF THE PROSECUTOR GENERAL
CONVICT:
Defense:
CHARGE:
Subject: Request for a stay of execution of the sentence imposed on our client
This is our petition, which also includes our request for release.
INSTRUCTIONS:
1 -) On … / … / …, following the acceptance of the Prosecutor’s Office file, … / … preparatory proceedings (October 1)…. …… Court …/…. E. Our client was sentenced to …… years in prison pursuant to Case No. … / … / … and Decision No. … / … dated October 2, and has been incarcerated since …/…/… following the imposition of this sentence. (October 3)
2 -) The process regarding the sentence imposed on our client is ongoing in October. As can be seen in the report published by the Medical Board and approved by the Forensic Medicine Institution (October 4), our client has a medical condition.
3 -) Article 16 of Law No. 5275 on the Implementation of Criminal Penalties and Security Measures, titled “Postponement of the Execution of a Prison Sentence Due to Illness,”
“Inmates suffering from a severe illness or disability that poses a risk to prison and public safety, and who are unable to bear the heavy burdens of living alone, may be subject to a provision allowing the suspension of their sentence until they recover, following an assessment of their sentence in accordance with the procedure outlined in the third paragraph.”
4 -)
In the “Opinions” section of the medical report, it is stated that due to the ailments our client suffers from, it does not appear possible for them to sustain their life independently, that they require constant care from another person, and that their treatment can only yield positive results if such a living arrangement is provided.
5 -) Due to the reasons explained, the execution of our. Client’s sentence, who is seriously ill, has been delayed.
We have been compelled to request a decision regarding his release and parole.
Legal grounds: Criminal Procedure Code (PK) Art. 16, 17, 18.
Conclusion and Request: For the reasons outlined above, we respectfully request that the execution of our client’s sentence, who is suffering from a serious illness, be postponed and that a decision for his release be issued in his favor. …/ …/ …
Attachments:
1 -) … Public Prosecutor’s Office File …/… October Preparatory Proceedings
2) … Court …/… Case No. … / … No decision
3) … Prison records
4) … Hospital … A report published by the Medical Council and approved by the Forensic Medicine Institution.
5) A certified copy of the power of attorney
Defense of the Inmate
ATTORNEY