… TO THE CRIMINAL COURT

File No.: …/…

OFFSET FROM PENALTY

ACCUSED AT REQUEST :

Defense :

Subject: my client ./../.. In history ….. It is the request that the day-to-day period of detention for his crime be deducted from the conviction of the Criminal Court against my accused client at the time of his conviction.

INSTRUCTIONS :

1 -) the defendant who is my client ../ … / … in his history … he was imprisoned for a period of time … for his crime; as a result of the ongoing trial, the client was acquitted of the defendant. At this time, my client has been sentenced to one year in the Criminal Court’s history for his crime. About the decision in question…/../ … due to the fact that an appeal has been filed, the file is at the Supreme Court stage.

2 -) Mülga No. 40 of the Turkish Penal Code No. 765 and No. 63 of the Turkish Penal Code No. 5237. as stated in the articles, it is stated that it will be sufficient to commit another crime or crimes before the date of finalization of the decision given for the crime of detention in order to make the offset.

3 -) as a matter of fact, in the decision of the criminal General Assembly dated 06.03.1940 and numbered 1940/5 and 1940/68, it was stated that <the period of detention of an acquitted person for the crime he acquitted should be deducted from the period of punishment given for the other crime he committed before the decision of acquittal

4 -) the provisions of the above mentioned legal legislation and the case law of the Court of Cassation due to the decision of the General Assembly of the Penal Union, the decision taken before the final and the result of limiting personal freedom…. The period of daily detention must be reduced from the sentence of the sentenced. For these reasons we have explained, it is necessary to write the petition for deduction from this penalty.

Legal reasons: 5237 S. K. m. 63, 765 P. K. m. 40

Conclusion and claim : for the reasons described above, your court ../../…. we respectfully request, on behalf of my client, that my client’s sentence of conviction be deducted from his time in custody. …/…/…

Defense Of The Accused