TO THE THE PROSECUTOR GENERAL’S OFFICE
THE COMPLAINANT:
attorney :
address :
RESPONDENT :
(SUSPECTED)
CRIME : Sexual Abuse of a Child (TCK m.1034)
HISTORY OF CRIME : …/ …/ …
INSTRUCTIONS
1-) The accused … …. , …/ …/ … he manipulated the client by interrupting our client on the road while he was going to school; his father had a traffic accident and was hospitalized as a result, his condition was critical, and that he would take him to his father’s hospital, that he was his father’s colleague, and that his father had already sent him to his father’s office..
2-) Our client is … yet … years old. Although he has not completed the age of fifteen, he is not in a position to perceive the fact that he has been deceived with the anxiety that he will experience at that moment. Therefore, he did not have a chance to question what the accused had said and got into the defendant’s car, falling for the defendant’s excuse to take him to the hospital with the desire to see his father as soon as possible.
3-) The accused , …. He parked the car at the location of his province, locked the car and started to approach our client. Despite the fact that our client constantly pushed the defendant and resisted him, he could not get rid of his hands. During the resistance, our client fainted as a result of hitting his head in the glove compartment. The defendant took the opportunity to do so and repeatedly sexually assaulted our client.
4-) A few hours after the incident, the defendant left our client in a semi-unconscious state near his home and before leaving, he clung to my client’s throat, threatening that “If he tells your mother or father about the incident, he will do ten times that, there is nothing more that he has done, and he will also cut their throat”.
5-) Our client did not mention this to his family for a long time due to the fear and sadness he experienced, but the situation arose as a result of his mother forcing him to tell what happened one day.
6-) The defendant’s action against our client is in accordance with Article 103 of the Turkish Criminal Code No. 5237. since it constitutes the crime specified in the article, a complaint petition has been required to be filed.
LEGAL REASONS : 5237 P. K. m. 103 and related legislation.
CONCLUSION AND PROMPT : It is doubtful for the reasons described above …. …. we request and submit to the bilvekale that it be decided to open a public case for punishment by conducting an investigation against him. …/…/….
Attorney of the Client
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