… CRIMINAL COURT
Case No.: … / … E.
DEFENDANT:
Defense Counsel:
Address:
CHARGE:
Subject: This concerns our request for the annulment of the seizure order.
INSTRUCTIONS
1 -) On …, a public prosecution was initiated in your court against our client …/ …/ … for the crime of …, following the acceptance of the preliminary investigation file by the Prosecutor’s Office on …/…; and an order was issued to forfeit the …-brand hunting rifle, registered on …/…, and the …-brand blank-firing pistol, registered on …/….
2 -) According to the reports prepared by police officers on duty at the … Police Station on …/…/… and included in file No. …, the act in question was committed using a …-brand hunting rifle.
3 -) As can be seen from the relevant reports, a decision cannot be made to confiscate the …-brand blank-firing pistol, as it is deemed not to have been used in the crime and its possession does not constitute a crime.
4 -) Accordingly, you must file a petition with this court to have the seizure order lifted regarding the …-brand blank-firing pistol, which was registered on …/ … and was determined not to have been used in the crime.
Legal grounds: Turkish Penal Code No. 5237, Art. 54; Turkish Code of Criminal Procedure No. 5271, Arts. 256, 257, 258, 259.
CONCLUSION AND RECOMMENDATION
For the reasons explained above, we respectfully request, on behalf of our client,. That the seizure order regarding the registered brand-name waterproof pistol be lifted. …/ …/ …
Defense of the Defendant
Attorney.