… TO THE HEAD OF THE HIGH CRIMINAL COURT

File NO: … / … E.

DEFENDANT :

Defense :

Subject: …our appeal against the decision of the High Criminal Court …/…/ … to continue the day-to-day detention.

INSTRUCTIONS :

1 -) it is decided that our client should be arrested at the hearing held on the date of the public trial against him, with file E of your court.

2 -) our client is the owner of a fixed settlement as well as the house he lives in belongs to him. It is also owned and operated by our client himself ….. …. …… …./….. at ….. ….. our client, who owns the company, has not been involved in any crime so far and has no criminal record. There is no suspicion of escape.

3 -) our client, who is a suspect in the related crime alone, does not have any other accomplices in the suspect position, but all the evidence related to the crime has been collected and kept under protection. Therefore, our client is not suspected of tampering with evidence.

4 -) during the preparatory investigation, witnesses gave their statements to both the law enforcement and the Public Prosecutor’s Office.

5 -) considering the nature and elements of the crime and in any case there is no reason to decide on the continuation of the detention given to our client with a permanent residence who has no criminal record according to the contents of the file.

Conclusion and request : … we respectfully request on behalf of our client that our client be released with the acceptance of our objection to the decision of the High Criminal Court …/…/… to continue his day-to-day detention. …/…/…