… TO THE PRESIDENCY OF THE HIGH CRIMINAL COURT
CASE NO:
DEFENDANT/PERSON REQUESTING RELEASE:
DEFENSE COUNSEL:
PROSECUTOR:
CRIME: Establishing a criminal organization, membership in a criminal organization, drug trafficking within the scope of the organization’s activities.
DATE OF CRIME: …/…/…
SUBJECT: Requests a decision to release the defendant.
EXPLANATIONS
We request that the defendant be released for the following reasons:
1- Despite learning that an arrest warrant had been issued against him during the investigation phase of the case, the defendant voluntarily surrendered. This behavior demonstrates that he had no intention of fleeing and that he intends to see justice served.
2- The defendant has a specific place of employment and residence address. The municipal certificate we have submitted as an attachment also proves his residence address. Similarly, my client works in traffic control in the city where he lives, and if he remains in custody, it will cause him distress as his social circle will shrink and he will face difficulties at work. 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 that can be gathered against him. We would like to state that we will present the evidence in his favor during the trial.
4- The defendant has no connection or affiliation with any organization. As we can see when reviewing the file, we can see that a few phone calls do not mean membership in an organization and that it is not fair to see it that way. In other words, it is highly likely that the charges against him will change.
CONCLUSION: For the reasons stated above, we request that the defendant be released without bail or with the necessary bail and surety. …/…/…
ATTACHMENT: 1- Residence certificate from the village headman.
2- SSK certificate proving the defendant’s employment.
DEFENDANT’S ATTORNEY