Petition For Order To Release The Accused
PRESIDENCY OF … HEAVY CRIMINAL COURT
PETITIONER FOR RELEASE ORDER:
ATTORNEY
THE PLAINTIFF
CRIME: Establishing a criminal organization, being a member of the organization, drug trafficking within the framework of the organization’s activities.
DATE OF CRIME: …/…/…
SUBJECT: It includes the request for the release of the defendant.
EXPLANATIONS
We request that the defendant be released for the following reasons;
1- The defendant surrendered voluntarily despite learning that an arrest warrant had been issued against him during the investigation phase of the crime subject to the case. This behavior shows that he has no intention of fleeing and that he intends to see justice done.
2- The defendant has a certain workplace and residence address. The mukhtar’s certificate that we have attached proves his residence address. Likewise, my client works in the traffic surveillance business in the city where he lives, and if he continues to be detained, his environment will decrease and his work will be difficult. His surrender is also a guarantee that he will not escape.
3- All evidence from the file has been collected and witnesses and other defendants have been heard. There is no evidence that can be collected against him. We state that we will present the evidence in his favor during the trial.
4- The defendant has no relationship and connection with any organization. As we can see when we examine the file, we can see that making a few phone calls does not mean membership in an organization, and it is not in accordance with justice. In other words, there is a high probability that the accusation against him will change.
CONCLUSION: For the reasons stated above, we request that the defendant be released without collateral or with the necessary collateral and bail. …/…/…
ANNEX: 1- Certificate of residence from the mukhtar.
2- SSK certificate that the defendant is employed.
ATTORNEY
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