Petition For Appeal Against The Decision To Continue Detention
TO THE PRESIDENCY OF THE 3RD HIGH CRIMINAL COURT OF BURSA
FILE NO. : …/… E.
DEFENDANT :
DEFENSE ATTORNEY :
SUBJECT : This is to submit our petition containing our objections to the decision of the … Heavy Penal Court dated …/…/… regarding the continuation of detention.
OUR EXPLANATIONS
1-) In the public prosecution case against our client, filed under your Court’s file no. …/ … E, for the crime of …, it was decided to arrest our client at the hearing held on …/ …/ ….
2-) Our client has a permanent place of residence, and the house he lives in belongs to him. Our client has been a farmer since childhood and had planted his field before his arrest. Besides him, there is no one else who can take care of his field, and the crops are ready for harvest. If they are not harvested, they will be ruined, and our client and his family will face extreme economic hardship. Furthermore, he has not been involved in any crime to date, and there is no negative record in his criminal record. It is clear that there is no suspicion of him fleeing.
3-) Our client is the sole suspect in the crime in question, and there are no other accomplices suspected of involvement in the crime; all evidence related to the crime has been collected and secured. Therefore, there is no suspicion that our client will tamper with the evidence.
4-) The witnesses have also given their statements to both the police and the Public Prosecutor’s Office during the preliminary investigation, and there are no remaining questions regarding the investigation phase.
5-) Considering the nature and elements of the crime and, in any case, based on the file content, there is no reason to decide to continue the detention of our client, who has no criminal record and a fixed residence.
CONCLUSION AND REQUEST: We respectfully request that our appeal against the decision of the Heavy Penal Court dated …/…/… to continue the detention be accepted and that our client be released. …/…/…
Defense Attorney