14 Sep PETITION FOR REMOVAL OF ARREST DUE TO ROAD ACCIDENT
TO THE HONORABLE JUDGE
…….
APPEAL AGAINST ARREST
DEFENDANT:…….
ATTORNEYS:…….
APPEALED:
Verdict:…… Magistrates ‘ Court../../…. history and ../…. MUT. Resolution No.
Subject: our request that the arrest decision be lifted on appeal and that the eviction decision be decided is Hk.
Explanations: 1-our client is the defendant ………., ../../…. 15 hours of the day in the order of dispatch and administration………. Official license plate belonging to the municipality .. . …… with a garbage truck with a license plate number……. direction …… watching the direction………….. when he came in front of him, he realized that a person wanted to go on the road, and he warned him by honking, reducing his speed. A person who wanted to go on the road paused decisively when he heard the horn, but then suddenly jumped into the road quickly to cross the street. Because there was a very short distance between them when he jumped into the road, our client was unable to prevent the impact, despite the decisiveness of the defendant.
2-as can be seen from the traffic accident detection report, our client does not have any defects of the accused in the incident.
3 -…… 1 Magistrate’s Court../../…. history and ../…. Being the owner of the residence of the query with the decision our client is hard, and accidents for your arrest is a measure by considering the shape of the defect and the status of a traffic accident report to be released because it was decided for his arrest is not the place.
4-but on the same day the Public Prosecutor. ../…. On his objection from file number Hz ….. Criminal Court Of First Instance ../…. MUT. He was ordered to be arrested in absentia and is in the Sentry Magistrates ‘ Court where he was released ../…. The interrogation was translated into absentia with the numbered decision.
5-Mr. public prosecutor regarding the release of our client ….. 1 Magistrate’s Court ../…. The other witness of the incident was questioned………..because his statement received by the prosecutor’s office was not in the documents at the time, he objected to the examination of this document and the arrest of our client in absentia, depending on the nature of the crime and the state of evidence.
6-witness ……… in his testimony to the prosecutor’s office, he states that his father stopped in the middle of the road so as not to interfere with our client’s passage, Our client hit his father very quickly and saw this incident from the mirror of his own car, which was stopping.
7-witness ………’it is not possible to see this event, which occurred in a very short time, through the mirror of his vehicle, which is parked parallel to the road in all its details. When the traffic accident detection report is examined, it is clear that the vehicle in the dispatch and administration of our client is in its lane. At the time of the accident, our client’s car was not too fast. On the day of the accident, the weather is very bad and the road is crowded and the traffic continues at normal speed in a convoy. Witness Ramadan says in his testimony that our client certainly didn’t help him, he didn’t even come to the clinic where he took his father. However, as soon as our client got out of the car, he helped the person he hit and took him to the clinic. Another friend who was with me reported it to the traffic cops.
8-traffic accident detection report as stated in the appeal petition of Mr. Public Prosecutor, our client is in the same vehicle as the defendant ………. it is not drawn according to the declaration. The crashed vehicle is still standing on the road when traffic police arrive. After traffic police examined the scene, they asked for the vehicle to be removed and the vehicle was towed off the road.
9-as mentioned above, our client has no flaws in the incident. Our client, the accused, made every effort to prevent the incident from happening, but despite all his efforts, he was unable to prevent the incident from happening. Although our client is deeply saddened by the incident, he feels remorse.
10-our client is married and has three children and has a fixed residence. ………. He works as a driver in the municipality. Evidence has been collected evidence cannot be destroyed and blacked out.
As a result of the request : we request that the arrest be lifted in order not to cause victimization of our client and his family, taking into account the reasons provided and the content of the investigation documents, the manner of the accident and the defect situation, and that the evacuation of our client be decided in exchange for bail, which your bihakkın or your court deems appropriate.
DEFENDANT’S ATTORNEY
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